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{{#Wiki_filter:Nuclear Regulatory Commission
{{#Wiki_filter:UNITED STATES
            Exhibit # - NRC000086-MA-BD01
NUCLEAR REGULATORY COMMISSION
            Docket # - 07007015
OFFICE OF NUCLEAR MATERIAL SAFETY AND SAFEGUARDS
            Identified: 01/25/2011
WASHINGTON, D.C. 20555-0001
Admitted: 01/25/2011          Withdrawn:
December 22, 2005
Rejected:                      Stricken:
NRC REGULATORY ISSUE SUMMARY 2005-31
                                                                                                              NRC000086
CONTROL OF SECURITY-RELATED SENSITIVE UNCLASSIFIED NON-
                                                            UNITED STATES
SAFEGUARDS INFORMATION HANDLED BY INDIVIDUALS, FIRMS,
                                              NUCLEAR REGULATORY COMMISSION
AND ENTITIES SUBJECT TO NRC REGULATION OF THE USE OF
                                  OFFICE OF NUCLEAR MATERIAL SAFETY AND SAFEGUARDS
SOURCE, BYPRODUCT, AND SPECIAL NUCLEAR MATERIAL
                                                  WASHINGTON, D.C. 20555-0001
ADDRESSEES
                                                          December 22, 2005
All licensees, certificate holders, applicants, and other entities (hereafter referred to as
                                    NRC REGULATORY ISSUE SUMMARY 2005-31
licensees and others) subject to regulation by the U.S. Nuclear Regulatory Commission (NRC)
                  CONTROL OF SECURITY-RELATED SENSITIVE UNCLASSIFIED NON-
of the use of source, byproduct, and special nuclear material, except for those as covered by
                      SAFEGUARDS INFORMATION HANDLED BY INDIVIDUALS, FIRMS,
provisions of Regulatory Issue Summary (RIS) 2005-26 for nuclear power reactors.  
                      AND ENTITIES SUBJECT TO NRC REGULATION OF THE USE OF
INTENT
                          SOURCE, BYPRODUCT, AND SPECIAL NUCLEAR MATERIAL
This RIS sets forth procedures that licensees and others are encouraged to follow when
                  ADDRESSEES
handling documents and/or when submitting documents to the NRC that contain security-
                  All licensees, certificate holders, applicants, and other entities (hereafter referred to as
related sensitive information, other than classified or safeguards information, that could be
                  licensees and others) subject to regulation by the U.S. Nuclear Regulatory Commission (NRC)
useful, or could reasonably be expected to be useful, to a terrorist in a potential attack.  
                  of the use of source, byproduct, and special nuclear material, except for those as covered by
Attached to this RIS are screening criteria that licensees and others should use to identify
                  provisions of Regulatory Issue Summary (RIS) 2005-26 for nuclear power reactors.
security-related sensitive information.
                  INTENT
No specific action nor written response is required.  
                  This RIS sets forth procedures that licensees and others are encouraged to follow when
BACKGROUND
                  handling documents and/or when submitting documents to the NRC that contain security-
NRC traditionally has given the public access to a significant amount of information about the
                  related sensitive information, other than classified or safeguards information, that could be
facilities and materials the Agency regulates. Openness has been and remains a cornerstone
                  useful, or could reasonably be expected to be useful, to a terrorist in a potential attack.
of NRCs regulatory philosophy. The Atomic Energy Act, subsequent legislation, and various
                  Attached to this RIS are screening criteria that licensees and others should use to identify
NRC regulations have given the public the right to participate in the licensing and oversight
                  security-related sensitive information.
process for NRC licensees. To participate in a meaningful way, the public must have access to
                  No specific action nor written response is required.
information about the design and operation of regulated facilities and use of nuclear materials.  
                  BACKGROUND
However, NRC and other Government agencies have always withheld some information from
                  NRC traditionally has given the public access to a significant amount of information about the
public disclosure for reasons of security, personal privacy, or commercial or trade secret
                  facilities and materials the Agency regulates. Openness has been and remains a cornerstone
protection.  
                  of NRCs regulatory philosophy. The Atomic Energy Act, subsequent legislation, and various
ML053480073
                  NRC regulations have given the public the right to participate in the licensing and oversight
NRC000086
                  process for NRC licensees. To participate in a meaningful way, the public must have access to
Nuclear Regulatory Commission
                  information about the design and operation of regulated facilities and use of nuclear materials.
Exhibit # - NRC000086-MA-BD01
                  However, NRC and other Government agencies have always withheld some information from
Docket #  - 07007015
                  public disclosure for reasons of security, personal privacy, or commercial or trade secret
Identified: 01/25/2011
                  protection.
Admitted:                   Withdrawn:         
                   ML053480073
Rejected:                  Stricken:           
          01/25/2011


                                                                                RIS 2005-31
  RIS 2005-31  
                                                                                Page 2 of 5
  Page 2 of 5
In the post-September 11, 2001, environment, NRC, like many other agencies, has found it
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
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
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
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
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
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
to documents in its electronic Agency-wide Documents Access and Management System
(ADAMS) on October 25, 2004. Subsequently, NRC screened those documents to determine
(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
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
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
continues as requests for specific documents are received and as new documents are created
by NRC and received from licensees and others.
by NRC and received from licensees and others.
To facilitate this screening process, NRC has developed screening criteria for conducting its
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
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
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
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
public disclosure security-related sensitive information associated with various NRC-regulated
activities of persons handling source, byproduct, and special nuclear material.
activities of persons handling source, byproduct, and special nuclear material.  
This RIS and its attachments do not apply to classified information or Safeguards Information.
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.
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
Safeguards Information is withheld because it provides details of security measures at nuclear
facilities. Handling requirements for classified information and Safeguards Information are set
facilities. Handling requirements for classified information and Safeguards Information are set
forth in various NRC orders, regulations, and generic communications (e.g., requirements for
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,
the handling and protection of Safeguards Information are discussed in RIS-2003-08,
Protection of Safeguards Information from Unauthorized Disclosure, dated April 30, 2003).
Protection of Safeguards Information from Unauthorized Disclosure, dated April 30, 2003).
Sensitive (but unclassified, non-safeguards) information covers a range of information for which
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
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
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-
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
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.
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.
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
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.
information designated for protection by other federal, State, or local agencies.
SUMMARY OF ISSUE
SUMMARY OF ISSUE
This RIS:
This RIS:  
    1) Informs licensees and others of the screening criteria that NRC uses to identify and
    1)
          protect security-related sensitive information in documents generated by the Agency
Informs licensees and others of the screening criteria that NRC uses to identify and
          and in documents received from licensees and others;
protect security-related sensitive information in documents generated by the Agency
    2) Encourages licensees and others to identify security-related sensitive information
and in documents received from licensees and others;
          contained in documents submitted to NRC, by using the screening criteria in
    2)
          Attachment 2 and marking procedures; and
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
  RIS 2005-31  
                                                                                Page 3 of 5
  Page 3 of 5
  3) Encourages licensees and others that may possess security-related sensitive
    3)
      information to control the information, to limit the risk that the information might fall into
Encourages licensees and others that may possess security-related sensitive
      the hands of those who would use it for malevolent acts.
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:
Specifically, protection of the information should be implemented in the following manner:
1. Screening of Future Documents Submitted to NRC
  1. Screening of Future Documents Submitted to NRC
      To assure that future submittals containing security-related sensitive information are not
To assure that future submittals containing security-related sensitive information are not
      made publicly available in ADAMS, while still making other appropriate information
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
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
accordance with the guidance in Attachment 2. If practical, documents submitted to
      NRC should avoid including security-related sensitive information to permit releasing the
NRC should avoid including security-related sensitive information to permit releasing the
      document to the public in its entirety.
document to the public in its entirety.  
2. Marking and Submitting Documents Containing Security-Related Sensitive Information
  2. Marking and Submitting Documents Containing Security-Related Sensitive Information
      If it is necessary to include security-related sensitive information in a submitted
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
document, the submittal should be marked to indicate the presence of such information
      as follows:
as follows:
          a)   The cover letter should clearly state that the attached documents contain
    a)
                security-related sensitive information. When separated from the attached
The cover letter should clearly state that the attached documents contain  
                documents, if the cover letter itself does not contain security-related sensitive
security-related sensitive information. When separated from the attached
                information, the cover letter itself is uncontrolled.
documents, if the cover letter itself does not contain security-related sensitive
          b)   As shown in Attachment 1 (Section A), the top of every page of a letter or
information, the cover letter itself is uncontrolled.
                document that contains security-related sensitive information should include the
    b)
                marking Security-Related Information  Withhold Under 10 CFR 2.390 (note
As shown in Attachment 1 (Section A), the top of every page of a letter or
                that NRCs procedure for these documents is to mark them as Official Use Only
document that contains security-related sensitive information should include the
                - Security-Related Information). For the pages having security-related sensitive
marking Security-Related Information  Withhold Under 10 CFR 2.390 (note
                information, an additional marking (e.g., an editorial notebox) should be included
that NRCs procedure for these documents is to mark them as Official Use Only
                adjacent to the material meeting the screening criteria in Attachment 2.
- Security-Related Information). For the pages having security-related sensitive
      Information on suggested handling and methods of submittal of security-related
information, an additional marking (e.g., an editorial notebox) should be included
      sensitive information is also contained in Attachment 1 (Section B).
adjacent to the material meeting the screening criteria in Attachment 2.
      Licensees and others can submit both a public and a non-public version of a document,
Information on suggested handling and methods of submittal of security-related
      when security-related documents need to be submitted. The public version could have
sensitive information is also contained in Attachment 1 (Section B).
      the security-related sensitive information marked out or removed with a notation that
Licensees and others can submit both a public and a non-public version of a document,
      the information was withheld on the basis that it is Security-Related Information. This
when security-related documents need to be submitted. The public version could have
      is similar to what is sometimes done to protect proprietary information under 10 CFR
the security-related sensitive information marked out or removed with a notation that
      2.390, except that an affidavit is not needed. Alternatively, security-related sensitive
the information was withheld on the basis that it is Security-Related Information. This
      information could be segregated from the main body of the document and included only
is similar to what is sometimes done to protect proprietary information under 10 CFR
      in attachments to the submittal. Only the attachments containing security-related
2.390, except that an affidavit is not needed. Alternatively, security-related sensitive
      sensitive information would be marked for withholding from public disclosure. Using this
information could be segregated from the main body of the document and included only
      approach, the public version need not be marked as containing security-related sensitive
in attachments to the submittal. Only the attachments containing security-related
      information.
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
  RIS 2005-31  
                                                                                    Page 4 of 5
  Page 4 of 5
3. Protection of Security-Related Sensitive Information
3. Protection of Security-Related Sensitive Information
        Documents that contain security-related sensitive information should be protected from
Documents that contain security-related sensitive information should be protected from
        public disclosure, using methods similar to that for protecting proprietary information.
public disclosure, using methods similar to that for protecting proprietary information.  
        To the extent practicable, any existing documents containing security-related sensitive
To the extent practicable, any existing documents containing security-related sensitive
        information that licensees or others have previously made available to the public should
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
be withdrawn from public access. As with proprietary information, licensees and others
        should have sufficient internal controls to prevent release of information. Possible
should have sufficient internal controls to prevent release of information. Possible
        methods to prevent the inadvertent release of security-related sensitive information
methods to prevent the inadvertent release of security-related sensitive information
        include marking documents Security-Related Information - Withhold Under 10 CFR
include marking documents Security-Related Information - Withhold Under 10 CFR
        2.390, restricting access to electronic recordkeeping systems that contain such
2.390, restricting access to electronic recordkeeping systems that contain such
        information, and controlling the reproduction, distribution, and destruction of potentially
information, and controlling the reproduction, distribution, and destruction of potentially
        sensitive records. Licensees and others should ensure that similar controls are in place
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
when security-related sensitive information is provided to outside parties such as
        contractors or other Government agencies, and that the information is made available
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
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.
who are made aware of the security-related nature of the information.  
This RIS, the attached screening criteria, and additional explanatory material, as appropriate,
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)
are also posted on the NRC Web site at http://www.nrc.gov/reading-rm/sensitive-info.html)
Line 173: Line 180:
questions regarding the application of the procedures and screening criteria set forth in this RIS
questions regarding the application of the procedures and screening criteria set forth in this RIS
and its attachments.
and its attachments.
NRC will continue to make available to the public as much information as possible. Much of
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 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
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
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
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
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
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.
and processed independently from the security-related sensitive information review process.  
BACKFIT DISCUSSION
BACKFIT DISCUSSION
This RIS requires no action nor written response and is, therefore, not a backfit under 10 CFR
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.
70.76, 72.62, or 76.76. Consequently, the NRC staff did not perform a backfit analysis.
FEDERAL REGISTER NOTIFICATION
FEDERAL REGISTER NOTIFICATION
A notice of opportunity for public comment on this RIS was not published in the Federal
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
Register because it is informational and does not represent a departure from current regulatory
requirements and practice.
requirements and practice.  


                                                                              RIS 2005-31
  RIS 2005-31  
                                                                              Page 5 of 5
  Page 5 of 5
SMALL BUSINESS REGULATORY ENFORCEMENT FAIRNESS ACT OF 1996
SMALL BUSINESS REGULATORY ENFORCEMENT FAIRNESS ACT OF 1996
NRC has determined that this action is not subject to the Small Business Regulatory
NRC has determined that this action is not subject to the Small Business Regulatory
Enforcement Fairness Act of 1996.
Enforcement Fairness Act of 1996.  
PAPERWORK REDUCTION ACT STATEMENT
PAPERWORK REDUCTION ACT STATEMENT
This RIS does not contain information collections and, therefore, is not subject to the
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.).
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.
Please direct any questions about this matter to the technical contacts listed below.
                                                    /RA/
/RA/
                                            Charles L. Miller, Director
Charles L. Miller, Director
                                            Division of Industrial and Medical
Division of Industrial and Medical
                                              Nuclear Safety
  Nuclear Safety
                                            Office of Nuclear Material Safety
Office of Nuclear Material Safety  
                                              and Safeguards
  and Safeguards
Technical Contacts:
Technical Contacts:
                                Spent Fuel Storage and
    Spent Fuel Storage and
Materials IMNS/Regional         Transportation                     Fuel Cycle
Materials IMNS/Regional           Transportation
Paul Goldberg, NMSS/IMNS       Joe Sebrosky, NMSS/SFPO             Patricia Silva, NMSS/FCSS
Fuel Cycle
301-415-7842                   301-415-1132                       301-415-8029
   
E-mail: pfg@nrc.gov             E-mail: jms3@nrc.gov               E-mail: pas6@nrc.gov
Paul Goldberg, NMSS/IMNS     Joe Sebrosky, NMSS/SFPO
Decommissioning                 HLWRS                               Import/Export
Patricia Silva, NMSS/FCSS
Ted Carter, NMSS/DWMEP         Alexander Sapountzis               Stephen Dembek
301-415-7842
301-415-6668                   301-415-7822                       301-415-2342
    301-415-1132
E-mail: thc1@nrc.gov           E-mail: aps@nrc.gov                 E-mail: sxd@nrc.gov
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:
Attachments:
1. Suggested Markings; Withhold From Public Disclosure in Accordance With 10 CFR 2.390
1. Suggested Markings; Withhold From Public Disclosure in Accordance With 10 CFR 2.390
Line 220: Line 241:
3. List of Recently Issued NMSS Generic Communications
3. List of Recently Issued NMSS Generic Communications


                                                                                              Attachment 1
Attachment 1
                                                                                              RIS-2005-31
RIS-2005-31
                                                                                                Page 1 of 2
Page 1 of 2
                          SUGGESTED MARKINGS AND HANDLING
Security-Related Information
Withhold Under 10 CFR 2.390
Subject
XXXXXXXXXX
XXXXXXXXXX
XXXXXXXXXX
XXXXXXXXXX
SUGGESTED MARKINGS AND HANDLING
This attachment provides information on suggested markings for pages of a document that
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
contains security-related sensitive information (Section A) and suggested handling of such
documents (Section B).
documents (Section B).
A. Page Markings
A. Page Markings
                                                            Overall page marking on the top of all pages
Overall page marking on the top of all pages
                                                            of a document that contains security-related
of a document that contains security-related
                                                            sensitive information
sensitive information  
            Security-Related Information                      Note that a cover letter should clearly state
          Withhold Under 10 CFR 2.390                        that attached documents contain security-
Note that a cover letter should clearly state
                                                              related sensitive information - - However,
that attached documents contain security-
                                                              this marking is also needed on the cover
related sensitive information - - However,
                                                              letter only if it itself contains security-
this marking is also needed on the cover
                                                              related sensitive information.
letter only if it itself contains security-
          Subject
related sensitive information.
                                                              Ensure Subject Line is non-sensitive
              Ensure Subject Line is non-sensitive
                  XXXXXXXXXX
                  XXXXXXXXXX
                  XXXXXXXXXX
                  XXXXXXXXXX


                                                                                      Attachment 1
Attachment 1
                                                                                      RIS-2005-31
RIS-2005-31
                                                                                        Page 2 of 2
Page 2 of 2
B. Appropriate Controls for Handling Documents
B. Appropriate Controls for Handling Documents
Access:                     Need-to-know in order to perform official licensee, applicant or
Access:
                            entity functions.
Need-to-know in order to perform official licensee, applicant or
Storage:                     Openly within licensee, applicant, or other entity facilities with
entity functions.
                            electronic or other access controls, for example, key cards,
Storage:
                            guards, alarms.
Openly within licensee, applicant, or other entity facilities with
Mail:                       U.S. Postal Service first class mail, registered mail, express mail,
electronic or other access controls, for example, key cards,
                            or certified mail in single opaque envelope with no external
guards, alarms.
                            markings to indicate 10 CFR 2.390 contents.
Mail:
Electronic Transmission:             Over phone if the recipient is confirmed as being
U.S. Postal Service first class mail, registered mail, express mail,
                                      authorized to access the information; over facsimile if it is
or certified mail in single opaque envelope with no external
                                      confirmed that a recipient who is authorized to access the
markings to indicate 10 CFR 2.390 contents.
                                      information will be present to receive the transmission;
Electronic Transmission:
                                      over encrypted computer e-mail (using computer software
Over phone if the recipient is confirmed as being
                                      such as SecureZip).
authorized to access the information; over facsimile if it is
                            Note that NRC is using SecureZip when transmitting security-
confirmed that a recipient who is authorized to access the
                            related sensitive information by e-mail to licensees and others to
information will be present to receive the transmission;
                            encrypt electronic information. Users will be prompted for a
over encrypted computer e-mail (using computer software
                            password to access a free download of the reader.
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
Attachment 2
                                                  RIS 2005-31
RIS 2005-31
                                                  Page 1 of 19
Page 1 of 19
                  NMSS GUIDANCE
-1-
    SCREENING CRITERIA FOR SECURITY-RELATED
NMSS GUIDANCE
SCREENING CRITERIA FOR SECURITY-RELATED  
SENSITIVE UNCLASSIFIED NON-SAFEGUARDS INFORMATION
SENSITIVE UNCLASSIFIED NON-SAFEGUARDS INFORMATION
                  DECEMBER 2005
DECEMBER 2005
                        -1-


                                                                                        Attachment 2
Attachment 2
                                                                                          RIS 2005-31
RIS 2005-31
                                                                                          Page 2 of 19
Page 2 of 19
                        SCREENING CRITERIA FOR SECURITY-RELATED
SCREENING CRITERIA FOR SECURITY-RELATED  
                SENSITIVE UNCLASSIFIED NON-SAFEGUARDS INFORMATION
SENSITIVE UNCLASSIFIED NON-SAFEGUARDS INFORMATION
                                          DECEMBER 2005
DECEMBER 2005
INTRODUCTION:
INTRODUCTION:
This guidance provides the criteria which will be used to determine the types of security-related
This guidance provides the criteria which will be used to determine the types of security-related
Line 287: Line 315:
licensees, applicants, certificate holders, and other entities that will not be voluntarily disclosed
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
to the public so as not to inadvertently provide assistance to those who might wish to use this
information for malevolent acts.
information for malevolent acts.
BACKGROUND:
BACKGROUND:
Historically, the Nuclear Regulatory Commission (NRC) has made routinely available to the
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,
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
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
more judicious in what it voluntarily releases, so as not to inadvertently provide assistance to
those who might use this information for malevolent acts.
those who might use this information for malevolent acts.
The NRC developed guidance several months ago for conducting a broad security/sensitivity
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
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
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
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
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
criteria for screening from public disclosure certain types of information associated with various
Line 304: Line 332:
(SECY 05-0091) and the Commission guidance on that Task Force Report, the screening
(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
criteria in these guidelines ...should follow the principles for withholding security-related
information under FOIA. Although the security-related sensitive screening criteria were
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
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
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
continue to be reviewed and processed independently from the security-related sensitive
information review process.
information review process.
ORGANIZATION OF THIS GUIDANCE:
ORGANIZATION OF THIS GUIDANCE:
This guidance is organized as follows (see Table 1 for an outline on navigating the 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
Section 1 indicates the thresholds under which documents may be released to the public
        withholding documents in certain cases even if the documents fall under the threshold.
without any further screening. However, Section 1 also notes specific requirements for
    -   Section 2 contains general criteria for screening documents above the threshold.
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
Attachment 2
                                                                                          RIS 2005-31
RIS 2005-31
                                                                                          Page 3 of 19
Page 3 of 19
    -    Appendices 1 - 5 contain guidance, in addition to that in Section 2, for screening
1  With regards to High-Level Waste, requirements for making information publicly
        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
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,
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
the "Joint DOE and NRC Sensitive Unclassified Information and Classification Guide for the
Office of Civilian Radioactive Waste Management Program" (CG-OCRWM-1) provides
Office of Civilian Radioactive Waste Management Program" (CG-OCRWM-1) provides
guidance for determining sensitive information.
guidance for determining sensitive information.
    -
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,
conversion, enrichment and fuel fabrication
facilities
Sections 1 and 2 for general information and
Appendix 1.
Decommissioning and low-level waste sites
Sections 1 and 2 for general information and
Appendix 2.
Medical, Industrial, and Academic Uses of
Nuclear Materials
Sections 1 and 2 for general information and
Appendix 3.
10 CFR Part 71: certificate holders, and
registered users
Sections 1 and 2 for general information and
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
holders
Sections 1 and 2 for general information and
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
licensees, and site specific licensees
Sections 1 and 2 for general information and
Appendix 4, parts A, B, C, D and E.
Export and Import
Sections 1 and 2 for general information and
Appendix 5.


                                                                                        Attachment 2
Attachment 2
                                                                                        RIS 2005-31
RIS 2005-31
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Page 4 of 19
1. NMSS THRESHOLD CRITERIA:
1. NMSS THRESHOLD CRITERIA:
Documents containing information falling under these thresholds may be released without any
Documents containing information falling under these thresholds may be released without any
further screening, except as specifically noted.
further screening, except as specifically noted.
A. Low Hazard: The following types of licensee files need NOT be screened due to the low
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:
hazard of the radioactive material at the sites:
    - Licensees authorized to possess quantities of radionuclides in any single location that
      - Licensees authorized to possess quantities of radionuclides in any single location that
        are below the International Atomic Energy Agencys (IAEA) Category 3 quantities (as
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
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
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
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
location (i.e., in a certain building), but documents giving the exact location should be
        withheld unless the location is intuitively obvious.
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
Licensees (other than fuel cycle) authorized to possess radionuclides which are not
        should be withheld.
listed in Table 1. However, information on the exact location of this radioactive material
      - Uranium recovery (yellow cake and tailings only)
should be withheld.
      - Current information on decommissioning materials sites with diffuse contamination only.
- Uranium recovery (yellow cake and tailings only)
        (Check for other active licenses or radioactive material at the site; e. g., high activity
- Current information on decommissioning materials sites with diffuse contamination only.
        reactor components, and high activity waste. Screen any such documents separately.)
(Check for other active licenses or radioactive material at the site; e. g., high activity
      - Terminated licenses where all radioactivity except diffuse contamination has been
reactor components, and high activity waste. Screen any such documents separately.)
        removed. (Screen old files for operational information which may contain sensitive
        information.)
- Terminated licenses where all radioactivity except diffuse contamination has been
B. Information Readily Available to the Public Elsewhere:
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):
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,
- 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
or other sources, an NRC decision to withhold the information may decrease the
        openness of our regulatory programs without obstructing an adversary.
openness of our regulatory programs without obstructing an adversary.
      - Information clearly visible from locations accessible to the public is generally released.
- Information clearly visible from locations accessible to the public is generally released.
        This includes general (low resolution) drawings of the site and adjacent areas.
This includes general (low resolution) drawings of the site and adjacent areas.


                                                                                        Attachment 2
Attachment 2
                                                                                        RIS 2005-31
RIS 2005-31
                                                                                        Page 5 of 19
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2. GENERAL CRITERIA FOR SCREENING DOCUMENTS ABOVE THE THRESHOLD
2. GENERAL CRITERIA FOR SCREENING DOCUMENTS ABOVE THE THRESHOLD
A. Descriptions of Facilities Where Licensed Material May Be Located
A. Descriptions of Facilities Where Licensed Material May Be Located
Criteria:
Criteria:
(1) Locations and quantities of radioactive material (above the thresholds listed in Table 1)
(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 identifying the exact locations of radioactive material
    - Withhold information on possession limits or actual inventories of radionuclides.
- Withhold information on possession limits or actual inventories of radionuclides.
    - Withhold manufacturers and model numbers of sealed sources and devices.
- Withhold manufacturers and model numbers of sealed sources and devices.  
    - For fuel cycle facilities, withhold information on possession limits and inventories of
- For fuel cycle facilities, withhold information on possession limits and inventories of
        enriched uranium above 6% U-235, and mixed oxide materials.
enriched uranium above 6% U-235, and mixed oxide materials.
    - Withhold lists of licensees registered to use NRC-approved 10 CFR Part 71
- Withhold lists of licensees registered to use NRC-approved 10 CFR Part 71
        transportation packages.
transportation packages.
    - Release identification of radionuclides and form.
- Release identification of radionuclides and form.
    - Release 10 CFR Part 71 certificates and 10 CFR Part 72 information related to
- Release 10 CFR Part 71 certificates and 10 CFR Part 72 information related to
        radionuclide form, content, quantities, model numbers, and locations of independent
radionuclide form, content, quantities, model numbers, and locations of independent
        spent fuel storage installations, regardless of the quantities.
spent fuel storage installations, regardless of the quantities.
    - Release event reports involving lost/stolen/abandoned/found radioactive material.
- Release event reports involving lost/stolen/abandoned/found radioactive material.
(2) Design of structures/equipment (site specific)
(2) Design of structures/equipment (site specific)
    - Withhold information related to security requirements, information from analyses which
- Withhold information related to security requirements, information from analyses which  
        could reveal vulnerabilities, reports of specific or predicted failures, and any other
could reveal vulnerabilities, reports of specific or predicted failures, and any other
        information which could reasonably be expected to be useful to potential adversaries.
information which could reasonably be expected to be useful to potential adversaries.
    - Release information regarding the design of structures provided to the NRC which
- 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
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
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,
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
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
information related to predicted structural failures that could be useful to terrorists. (See
        Appendix 1 for specific guidance on fuel cycle facilities.)
Appendix 1 for specific guidance on fuel cycle facilities.)
(3) Nearby Facilities
(3) Nearby Facilities
    - Withhold information related to nearby facilities if the information might reasonably be
- Withhold information related to nearby facilities if the information might reasonably be  
        helpful to those planning an attack.
helpful to those planning an attack.
B.   Design Information (non-site-specific): Spent Fuel Casks, Transportation Packages,
B. Design Information (non-site-specific): Spent Fuel Casks, Transportation Packages,
    Sealed Source and Device Catalog and Files, etc.
Sealed Source and Device Catalog and Files, etc.
    - Withhold drawings showing detailed design information.
- Withhold drawings showing detailed design information.  
    - Withhold design/performance information which indicates vulnerabilities that could
- Withhold design/performance information which indicates vulnerabilities that could
        reasonably be expected to be useful to potential adversaries.
reasonably be expected to be useful to potential adversaries.
    - Release text information containing descriptions of how packages/devices/sources are
- Release text information containing descriptions of how packages/devices/sources are
        constructed.
constructed.


                                                                                      Attachment 2
Attachment 2
                                                                                        RIS 2005-31
RIS 2005-31
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Page 6 of 19
C.  Emergency Planning/Fire Protection Information
C.  Emergency Planning/Fire Protection Information
    - Withhold information related to emergency planning, emergency response, and fire
- Withhold information related to emergency planning, emergency response, and fire
      protection. Review any considerations and/or requests for release on a case-by-case
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
basis. As part of the review, check to see whether the State or local governments are
      withholding related information as sensitive.
withholding related information as sensitive.
    - Withhold information describing licensee or government responses to malevolent
- Withhold information describing licensee or government responses to malevolent
      attacks.
attacks.
    - Withhold information and drawings identifying locations of radioactive material, and
- Withhold information and drawings identifying locations of radioactive material, and
      onsite routes and pathways to or from the locations of radioactive material.
onsite routes and pathways to or from the locations of radioactive material.
    - Withhold information which State or local government agencies have designated as
- Withhold information which State or local government agencies have designated as  
      sensitive.
sensitive.
D. Security Program Information
D. Security Program Information
    - Much information related to security programs at fuel cycle facilities and other materials
- 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
facilities with high risk sources has already been designated to be withheld as
      Classified, Safeguards, or Proprietary Information.
Classified, Safeguards, or Proprietary Information.
    - In addition to withholding Classified, Safeguards, or Proprietary Information, withhold
- In addition to withholding Classified, Safeguards, or Proprietary Information, withhold
      any security information which could reasonably be expected to be useful to potential
any security information which could reasonably be expected to be useful to potential
      adversaries.
adversaries.
E.  Vulnerability/Security Assessments/Accident Analyses/Safety Analyses/Risk Assessments
E.  Vulnerability/Security Assessments/Accident Analyses/Safety Analyses/Risk Assessments
    - Release typical accident analyses which involve conservative models to demonstrate a
- 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),
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.
unless the analysis could reasonably be expected to be useful to an adversary.
    - Withhold assessments which use a malevolent event as an initial condition
- Withhold assessments which use a malevolent event as an initial condition
      (e.g.,vulnerability/security analysis).
(e.g.,vulnerability/security analysis).  
    - Withhold descriptions of structural features related to potential malevolent attacks.
- Withhold descriptions of structural features related to potential malevolent attacks.
    - Withhold detailed information and drawings describing the specific locations of
- Withhold detailed information and drawings describing the specific locations of
      equipment relied upon for safety or security.
equipment relied upon for safety or security.  
    - Withhold discussions of safety features or mitigation strategies within
- Withhold discussions of safety features or mitigation strategies within
      vulnerability/security assessments.
vulnerability/security assessments.
    - Withhold any analysis that identifies which events have significant consequences and
- Withhold any analysis that identifies which events have significant consequences and
      which events don't.
which events don't.  
    - Withhold information related to security events and any information which could be
- Withhold information related to security events and any information which could be
      useful to an adversary due to identification of vulnerabilities.
useful to an adversary due to identification of vulnerabilities.


                                                                                      Attachment 2
Attachment 2
                                                                                      RIS 2005-31
RIS 2005-31
                                                                                      Page 7 of 19
Page 7 of 19
APPENDICES 1-5: ADDITIONAL GUIDANCE FOR SECURITY-RELATED SENSITIVE
APPENDICES 1-5: ADDITIONAL GUIDANCE FOR SECURITY-RELATED SENSITIVE
INFORMATION SCREENING REVIEWS
INFORMATION SCREENING REVIEWS  
These appendices contain additional guidance for screening documents for security-related
These appendices contain additional guidance for screening documents for security-related
sensitive information specific to fuel cycle facilities; decommissioning and low-level waste sites;
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
medical, industrial, and academic uses of nuclear materials; spent fuel/transportation; and
export/import licensing. These appendices are organized as follows:
export/import licensing. These appendices are organized as follows:
    1. Fuel cycle facilities including milling, conversion, enrichment and fuel fabrication
1. Fuel cycle facilities including milling, conversion, enrichment and fuel fabrication
        facilities;
facilities;
    2. Decommissioning and low-level waste sites;
2. Decommissioning and low-level waste sites;
    3. Medical, industrial, and academic uses of nuclear materials;
3. Medical, industrial, and academic uses of nuclear materials;
    4. Spent Fuel/Transportation (10 CFR Part 71: certificate holders, and registered users;
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
10 CFR Part 71: Quality Assurance Program holders; 10 CFR Part 72: certificate
        holders, general licensees, and site specific licensees);
holders, general licensees, and site specific licensees);
    5. Export/Import licensing.
5. Export/Import licensing.


                                                                                      Attachment 2
Attachment 2
                                                                                      RIS 2005-31
RIS 2005-31
                                                                                      Page 8 of 19
Page 8 of 19
APPENDIX 1 - - FUEL CYCLE FACILITY REVIEWS (NRC CONTACT: DIVISION OF FUEL
APPENDIX 1 - - FUEL CYCLE FACILITY REVIEWS (NRC CONTACT: DIVISION OF FUEL
CYCLE SAFETY AND SAFEGUARDS (FCSS), NMSS)
CYCLE SAFETY AND SAFEGUARDS (FCSS), NMSS)
A.  Descriptions of Facilities Where Licensed Material May Be Located
A.  Descriptions of Facilities Where Licensed Material May Be Located
    - Withhold information on possession limits or actual inventories of radionuclides, and
- Withhold information on possession limits or actual inventories of radionuclides, and
      quantities, including such information on the license itself, for mixed oxide material 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
uranium enriched to greater than 6 % U-235. (Release identification of radionuclides
      and their forms.)
and their forms.)
    - Withhold information related to military contract operations, even if it is publicly available
- Withhold information related to military contract operations, even if it is publicly available
      elsewhere.
elsewhere.
    - Withhold information identifying the exact locations (e.g., detailed floor plans) of
- Withhold information identifying the exact locations (e.g., detailed floor plans) of
      radioactive and hazardous material whose release or theft could allow adversaries to
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.
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
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
require less detailed information than theft where exact locations would likely be
      needed.
needed.
    - Withhold information about the design of structures that consists of analyses to show
- 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
that design features will withstand the forces associated with both security-related
      scenarios and non-security-related scenarios, such as tornadoes, high winds, snow
scenarios and non-security-related scenarios, such as tornadoes, high winds, snow
      loads, etc. Analyses indicating forces associated with non-security regulatory
loads, etc. Analyses indicating forces associated with non-security regulatory
      requirements could be useful in planning terrorist activities. For instance, information
requirements could be useful in planning terrorist activities. For instance, information
      related to seismic loadings could be used to determine blast loads for bombs.
related to seismic loadings could be used to determine blast loads for bombs.  
    - Withhold detailed design information, including diagrams showing dimensions, material
- Withhold detailed design information, including diagrams showing dimensions, material
      properties, and descriptions of how the facilities/equipment is constructed. Additionally,
properties, and descriptions of how the facilities/equipment is constructed. Additionally,
      withhold process information that could potentially allow an adversary to access
withhold process information that could potentially allow an adversary to access
      radioactive or hazardous materials or gain knowledge of detailed information or potential
radioactive or hazardous materials or gain knowledge of detailed information or potential
      weaknesses of systems designed to ensure safe operations (necessary to prevent or
weaknesses of systems designed to ensure safe operations (necessary to prevent or
      mitigate accidents) at fuel cycle facilities.
mitigate accidents) at fuel cycle facilities.
B. Design Information (non-site specific)
B. Design Information (non-site specific)
  No additional fuel cycle facility guidance for this category.
      No additional fuel cycle facility guidance for this category.
C. Emergency Planning/Fire Protection Information
C. Emergency Planning/Fire Protection Information
    - Withhold information contained in Emergency Planning and Fire Protection Plans that
- Withhold information contained in Emergency Planning and Fire Protection Plans that
      could potentially allow an adversary to gain knowledge of detailed information or
could potentially allow an adversary to gain knowledge of detailed information or
      potential weaknesses of systems designed to ensure safe operations (necessary to
potential weaknesses of systems designed to ensure safe operations (necessary to
      prevent or mitigate accidents) at fuel cycle facilities.
prevent or mitigate accidents) at fuel cycle facilities.


                                                                                      Attachment 2
Attachment 2
                                                                                        RIS 2005-31
RIS 2005-31
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Page 9 of 19
    - Withhold information and drawings identifying routes to or from the locations of
- Withhold information and drawings identifying routes to or from the locations of
      radioactive and hazardous material whose release or theft could allow adversaries to
radioactive and hazardous material whose release or theft could allow adversaries to
      achieve their goals.
achieve their goals.  
    - Withhold information that State or local government agencies have designated as
- Withhold information that State or local government agencies have designated as
      sensitive.
sensitive.
    - Withhold any detailed accident analysis that identifies which accidents have significant
- Withhold any detailed accident analysis that identifies which accidents have significant
      consequences and which accidents don't. Accident analysis information can appear in
consequences and which accidents don't. Accident analysis information can appear in
      many documents (i.e., emergency plan, fire protection plan, Integrated Safety Analysis
many documents (i.e., emergency plan, fire protection plan, Integrated Safety Analysis
      Summary, environmental assessment, etc.). General information may be releasable,
Summary, environmental assessment, etc.). General information may be releasable,
      but details should be withheld.
but details should be withheld.
D. Security Program Information
D. Security Program Information
    - Much information related to security programs at fuel cycle facilities and other materials
- 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
facilities with high risk sources has already been designated to be withheld as
      Proprietary, Classified or Safeguards Information.
Proprietary, Classified or Safeguards Information.
    - Withhold information about security equipment and programs, descriptions of equipment
- Withhold information about security equipment and programs, descriptions of equipment
      and radioactive or hazardous materials, and accident studies that bear a close
and radioactive or hazardous materials, and accident studies that bear a close
      resemblance to programs, equipment, radioactive or hazardous materials, and studies
resemblance to programs, equipment, radioactive or hazardous materials, and studies
      at other active licensee sites if that information would reveal vulnerabilities or be
at other active licensee sites if that information would reveal vulnerabilities or be
      expected to be useful to adversaries at active licensee sites.
expected to be useful to adversaries at active licensee sites.
E. Vulnerability/Security Assessments/Accident Analyses
E. Vulnerability/Security Assessments/Accident Analyses
    - Withhold detailed information and drawings describing the exact locations of radioactive
- Withhold detailed information and drawings describing the exact locations of radioactive
      or hazardous materials or gain knowledge of detailed information or potential
or hazardous materials or gain knowledge of detailed information or potential
      weaknesses of system designed to ensure safe operations (necessary to prevent or
weaknesses of system designed to ensure safe operations (necessary to prevent or
      mitigate accidents) at fuel cycle facilities.
mitigate accidents) at fuel cycle facilities.
    - Withhold any detailed accident analysis which contains accident sequences, identifies
- Withhold any detailed accident analysis which contains accident sequences, identifies
      accident consequences, identifies systems and components relied upon for safety, or
accident consequences, identifies systems and components relied upon for safety, or
      identifies which accidents have significant consequences and which accidents don't.
identifies which accidents have significant consequences and which accidents don't.  
      Accident analysis information can appear in many documents (i.e., emergency plan, fire
Accident analysis information can appear in many documents (i.e., emergency plan, fire
      protection plan, Integrated Safety Analysis Summary, environmental assessment, etc.).
protection plan, Integrated Safety Analysis Summary, environmental assessment, etc.).  
      General information may be acceptable, but details should be withheld.
General information may be acceptable, but details should be withheld.
    - Withhold information identifying the exact locations (e.g., detailed floor plans) of
- Withhold information identifying the exact locations (e.g., detailed floor plans) of
      radioactive and hazardous material whose release or theft could allow adversaries
radioactive and hazardous material whose release or theft could allow adversaries
      create a diversion for theft of material or result in a significant consequence.
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
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
require less detailed information than theft where exact locations would likely be
      needed.
needed.


                                                                                      Attachment 2
Attachment 2
                                                                                      RIS 2005-31
RIS 2005-31
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Page 10 of 19
APPENDIX 2 - - DECOMMISSIONING AND LOW-LEVEL WASTE SITE REVIEWS (NRC
APPENDIX 2 - - DECOMMISSIONING AND LOW-LEVEL WASTE SITE REVIEWS (NRC
CONTACT: DIVISION OF DECOMMISSIONING, WASTE MANAGEMENT, AND
CONTACT: DIVISION OF DECOMMISSIONING, WASTE MANAGEMENT, AND
ENVIRONMENTAL PROTECTION (DWMEP), NMSS)
ENVIRONMENTAL PROTECTION (DWMEP), NMSS)
DECOMMISSIONING AND LOW-LEVEL WASTE SITE THRESHOLD CRITERIA
DECOMMISSIONING AND LOW-LEVEL WASTE SITE THRESHOLD CRITERIA
  1. Diffuse contamination consists of soil, groundwater, surface contamination on and in
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
buildings, including that which is on equipment, floors, walls, etc. It also could include
      volumetrically contaminated materials whose concentrations are sufficiently low.
volumetrically contaminated materials whose concentrations are sufficiently low.
      For determining whether only diffuse contamination is present at a decommissioning
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
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
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
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
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
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
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
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
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,
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
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
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
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.
could easily be used for malevolent purposes because of its small volume.
      Reviewers should apply values taking into consideration the examples given above in
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.
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
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
may not be below the threshold. For example, import and export licensing could involve
      quantities of materials that would be useful to terrorists.
quantities of materials that would be useful to terrorists.  
GENERAL GUIDANCE FOR DECOMMISSIONING AND LOW-LEVEL WASTE SITES
GENERAL GUIDANCE FOR DECOMMISSIONING AND LOW-LEVEL WASTE SITES
  Most sites undergoing decommissioning are expected to be below the threshold, so that
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
most licensing documents can be released. Sensitivity reviews must be conducted on
  documents related to LLW storage, safety, and security systems and procedures. Reviews
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
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
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,
security arrangements for high-activity waste, the location of highly activated components,
  or the transportation security arrangements for high-activity waste or activated
or the transportation security arrangements for high-activity waste or activated
  components.
components.


                                                                                      Attachment 2
Attachment 2
                                                                                      RIS 2005-31
RIS 2005-31
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Page 11 of 19
    For fuel cycle, materials, and spent fuel pool and independent spent fuel storage
For fuel cycle, materials, and spent fuel pool and independent spent fuel storage
    installation (ISFSI) licensees that are undergoing decommissioning, issues that are not
installation (ISFSI) licensees that are undergoing decommissioning, issues that are not
    unique to decommissioning (such as descriptions of plant processes, vulnerability/security
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.
assessments, etc.) should be reviewed with regard to Appendices 1, 3, and 4, respectively.
A. Descriptions of Facilities Where Licensed Material May Be Located
A. Descriptions of Facilities Where Licensed Material May Be Located
    - Withhold information identifying the exact locations of radioactive material. For
- Withhold information identifying the exact locations of radioactive material. For
      example, detail drawings or maps of facilities, room numbers and locations, and specific
example, detail drawings or maps of facilities, room numbers and locations, and specific
      locations of waste storage/processing operations.
locations of waste storage/processing operations.
    - Withhold design information that could reasonably be expected to be useful to potential
- Withhold design information that could reasonably be expected to be useful to potential
      adversaries. Examples include detailed drawings or maps showing the locations of
adversaries. Examples include detailed drawings or maps showing the locations of
      security measures/operations and infrastructure, locations of critical site infrastructure
security measures/operations and infrastructure, locations of critical site infrastructure
      (electrical or power systems), and the design of facilities that could be useful in
(electrical or power systems), and the design of facilities that could be useful in
      developing approaches to breech the facility.
developing approaches to breech the facility.
    - For transportation package information provided in connection with decommissioning or
- For transportation package information provided in connection with decommissioning or
      LLW disposal licensing, consider Appendix 4 for sensitivity of the information.
LLW disposal licensing, consider Appendix 4 for sensitivity of the information.
No additional guidance for decommissioning and low-level waste sites for other categories.
No additional guidance for decommissioning and low-level waste sites for other categories.


                                                                                    Attachment 2
Attachment 2
                                                                                      RIS 2005-31
RIS 2005-31
                                                                                  Page 12 of 19
Page 12 of 19
APPENDIX 3 - - REVIEWS OF MEDICAL, INDUSTRIAL, AND ACADEMIC USERS OF
APPENDIX 3 - - REVIEWS OF MEDICAL, INDUSTRIAL, AND ACADEMIC USERS OF
NUCLEAR MATERIALS (NRC CONTACT: DIVISION OF INDUSTRIAL AND MEDICAL
NUCLEAR MATERIALS (NRC CONTACT: DIVISION OF INDUSTRIAL AND MEDICAL
NUCLEAR SAFETY (IMNS), NMSS)
NUCLEAR SAFETY (IMNS), NMSS)
A. Descriptions of Facilities Where Licensed Material May Be Located (above the thresholds in
A. Descriptions of Facilities Where Licensed Material May Be Located (above the thresholds in
    Table 1)
Table 1)
(1) Copies of Licenses and Mailing Lists
(1) Copies of Licenses and Mailing Lists
    - Copies of licenses: Release authorized radionuclides and form. Withhold authorized
- Copies of licenses: Release authorized radionuclides and form. Withhold authorized
      quantities. Withhold manufacturers and model numbers of sealed sources and devices.
quantities. Withhold manufacturers and model numbers of sealed sources and devices.  
      Withhold information which identifies buildings or rooms where radioactive material is
Withhold information which identifies buildings or rooms where radioactive material is
      located (this may be in the license condition specifying authorized location).
located (this may be in the license condition specifying authorized location).
    - Withhold mailings lists which are compiled for security purposes or identify high risk
- Withhold mailings lists which are compiled for security purposes or identify high risk
      facilities or vulnerable facilities.
facilities or vulnerable facilities.
    - Release individual mailing addresses, and street address where material is located
- Release individual mailing addresses, and street address where material is located
      (normally included on licenses).
(normally included on licenses).
(2) Locations of radioactive material
(2) Locations of radioactive material
    - Withhold lists of authorized or actual inventories of radionuclides.
- Withhold lists of authorized or actual inventories of radionuclides.
    - Withhold building numbers and room numbers (other than mailing addresses) or similar
- Withhold building numbers and room numbers (other than mailing addresses) or similar
      information which identify locations of material.
information which identify locations of material.
    - Withhold site drawings which identify individual buildings on the licensee site.
- Withhold site drawings which identify individual buildings on the licensee site.
    - Withhold building drawings which identify the location of radioactive material, or onsite
- Withhold building drawings which identify the location of radioactive material, or onsite
      pathways or routes to and from locations of radioactive material.
pathways or routes to and from locations of radioactive material.
    - Release individual mailing addresses and street addresses.
- Release individual mailing addresses and street addresses.
(3) Design/description of structures/equipment/operating procedures (site specific)
(3) Design/description of structures/equipment/operating procedures (site specific)
    - Most descriptions of structures/equipment/procedures may be released if they are not
- Most descriptions of structures/equipment/procedures may be released if they are not
      security-related.
security-related.
    - Withhold drawings of buildings/rooms/devices where radioactive material is located.
- Withhold drawings of buildings/rooms/devices where radioactive material is located.
    - Withhold manufacturers and model numbers of sealed sources and devices.
- Withhold manufacturers and model numbers of sealed sources and devices.
    - Withhold information on security programs, guards, access controls, key cards, alarms,
- Withhold information on security programs, guards, access controls, key cards, alarms,
      barriers, chains, locks, etc.
barriers, chains, locks, etc.
B. Design Information (non-site specific) - Sealed Source and Device Catalog
B. Design Information (non-site specific) - Sealed Source and Device Catalog
    - Release information on addresses of manufacturers/distributors.
- Release information on addresses of manufacturers/distributors.
    - Establish a password system for users with a valid need-to-know, and who have agreed
- Establish a password system for users with a valid need-to-know, and who have agreed
      to protect the information from unauthorized disclosure.
to protect the information from unauthorized disclosure.


                                                                                    Attachment 2
Attachment 2
                                                                                    RIS 2005-31
RIS 2005-31
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Page 13 of 19
C. Emergency Planning/Fire Protection Information
C. Emergency Planning/Fire Protection Information
    - Release general descriptions of emergency procedures for safety related events, such
- Release general descriptions of emergency procedures for safety related events, such
      as radioactive material spills, releases, contamination, and fires.
as radioactive material spills, releases, contamination, and fires.
    - Withhold information on routes to and from locations of radioactive material.
- Withhold information on routes to and from locations of radioactive material.
    - Withhold information related to responses to security events and malevolent events.
- Withhold information related to responses to security events and malevolent events.
    - Withhold information on responses of offsite law enforcement officials.
- Withhold information on responses of offsite law enforcement officials.
    - Withhold information designated by State or local governments as sensitive.
- Withhold information designated by State or local governments as sensitive.
D. Security Program Information
D. Security Program Information
    - Certain security information at specified facilities is already designated as Safeguards
- Certain security information at specified facilities is already designated as Safeguards
      Information and should continue to be withheld and protected accordingly.
Information and should continue to be withheld and protected accordingly.  
    - In addition to withholding Safeguards Information, withhold any security information
- In addition to withholding Safeguards Information, withhold any security information
      related to malevolent events or which could be useful to potential adversaries.
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
Examples as given in Section A above:   information on guards, access controls, key
      cards, alarms, barriers, chains, locks, etc.
cards, alarms, barriers, chains, locks, etc.
E. Vulnerability/Security Assessments/Accident Analyses
E. Vulnerability/Security Assessments/Accident Analyses
    - No additional guidance for medical, industrial, and academic users of nuclear material
- No additional guidance for medical, industrial, and academic users of nuclear material
      for this category.
for this category.


                                                                                      Attachment 2
Attachment 2
                                                                                      RIS 2005-31
RIS 2005-31
                                                                                    Page 14 of 19
Page 14 of 19
APPENDIX 4 - - SPENT FUEL/TRANSPORTATION REVIEWS (NRC CONTACT: SPENT
APPENDIX 4 - - SPENT FUEL/TRANSPORTATION REVIEWS (NRC CONTACT: SPENT
FUEL PROJECT OFFICE (SFPO), NMSS)
FUEL PROJECT OFFICE (SFPO), NMSS)
A. Descriptions of Facilities Where Licensed Material Be Located
A. Descriptions of Facilities Where Licensed Material Be Located
Subject                           Discussion and/or typical controls
Subject
10 CFR Part 72 Specific ISFSI     Uncontrolled - Information provided to the NRC for
Discussion and/or typical controls
Licenses and General Licenses      specific ISFSI licenses and general licenses typically
10 CFR Part 72 Specific ISFSI
- Text descriptions of the        consists of analyses to show that the design feature will
Licenses and General Licenses
following: general description,    withstand the combinations of forces associated with
- Text descriptions of the
site characteristics, principal    design basis events and natural hazards. The analyses
following: general description,
design criteria, storage cask      do not typically provide realistic information on the failure
site characteristics, principal
design, operations, waste          of structural features and are not considered sensitive.
design criteria, storage cask
management, radiation
design, operations, waste
protection, accident analyses,
management, radiation
conduct of operations, operating
protection, accident analyses,
controls and limits, and quality
conduct of operations, operating
assurance
controls and limits, and quality
10 CFR Part 72 Specific ISFSI     Potentially Controlled - Decisions regarding the control of
assurance
Licenses and General Licenses      information that show the plant site and buildings are
Uncontrolled - Information provided to the NRC for
- Drawings and locations of        dependent on the level of detail. Information clearly
specific ISFSI licenses and general licenses typically
related hazards                    visible from locations accessible to the public near the site
consists of analyses to show that the design feature will
                                    is generally released. This includes general (low-
withstand the combinations of forces associated with
                                    resolution) layout drawings of the site and adjacent areas.
design basis events and natural hazards. The analyses
                                    Drawings showing details such as the specific locations of
do not typically provide realistic information on the failure
                                    equipment within buildings, doorways, stairways, storage
of structural features and are not considered sensitive.
                                    areas, etc. are to be withheld under 10 CFR 2.390(d).
10 CFR Part 72 Specific ISFSI
                                    Drawings showing locations of hazards in relation to the
Licenses and General Licenses
                                    ISFSI are also withheld. A text description of the hazards
- Drawings and locations of
                                    in relation to the ISFSI is uncontrolled and will not be
related hazards
                                    reviewed.
Potentially Controlled - Decisions regarding the control of
10 CFR Part 72 Specific ISFSI     Controlled - Information related to non-nuclear facilities
information that show the plant site and buildings are
Licenses and General Licenses      located near the ISFSI such as pipeline data (usually
dependent on the level of detail. Information clearly
- Nearby industrial,              withheld per DOT) and chemical facilities (some data
visible from locations accessible to the public near the site
transportation, and military      withheld per EPA) is controlled. Other information may
is generally released. This includes general (low-
facilities                        be protected by other federal agencies (e.g., DHS, FERC,
resolution) layout drawings of the site and adjacent areas.  
                                    EPA, DOT)
Drawings showing details such as the specific locations of
10 CFR Part 72 Specific ISFSI     Uncontrolled - Information related to radionuclides, form,
equipment within buildings, doorways, stairways, storage
Licenses and General Licenses      and quantities
areas, etc. are to be withheld under 10 CFR 2.390(d).  
Lists of licensees registered to   Withhold lists and associated letters required by 10 CFR
Drawings showing locations of hazards in relation to the
use NRC-approved 10 CFR Part      71.17(c)(3).
ISFSI are also withheld. A text description of the hazards
71 transportation packages.
in relation to the ISFSI is uncontrolled and will not be
reviewed.
10 CFR Part 72 Specific ISFSI
Licenses and General Licenses
- Nearby industrial,
transportation, and military
facilities
Controlled - Information related to non-nuclear facilities
located near the ISFSI such as pipeline data (usually
withheld per DOT) and chemical facilities (some data
withheld per EPA) is controlled.   Other information may
be protected by other federal agencies (e.g., DHS, FERC,
EPA, DOT)
10 CFR Part 72 Specific ISFSI
Licenses and General Licenses
Uncontrolled - Information related to radionuclides, form,
and quantities
Lists of licensees registered to
use NRC-approved 10 CFR Part
71 transportation packages.
Withhold lists and associated letters required by 10 CFR
71.17(c)(3).


                                                                                    Attachment 2
Attachment 2
                                                                                    RIS 2005-31
RIS 2005-31
                                                                                    Page 15 of 19
Page 15 of 19
B. Design Information (non-site specific): Transportation Packages, and Spent Fuel Casks
B. Design Information (non-site specific): Transportation Packages, and Spent Fuel Casks
Subject                           Discussion and/or typical controls
Subject
10 CFR Part 71 Transportation     Uncontrolled - Information provided to the NRC typically
Discussion and/or typical controls
Package Descriptions Text        consists of analyses to show that the design feature will
10 CFR Part 71 Transportation
Descriptions Including            withstand the combinations of forces associated with
Package Descriptions Text
Radionuclide Form, Content and    design basis events and natural hazards. The analyses
Descriptions Including
Quantity                          do not typically provide realistic information on the failure
Radionuclide Form, Content and
                                  of structural features and are not considered sensitive.
Quantity
                                  Text descriptions regarding the design of transportation
Uncontrolled - Information provided to the NRC typically
                                  packages do not need to be controlled for 3 basic
consists of analyses to show that the design feature will
                                  reasons: 1) Part 71 does not authorize possession of
withstand the combinations of forces associated with
                                  byproduct, source or special nuclear material, 2) package
design basis events and natural hazards. The analyses
                                  design information is required for commerce both
do not typically provide realistic information on the failure
                                  domestically and internationally, and 3) the information
of structural features and are not considered sensitive.
                                  that could reasonably be expected to be useful to
Text descriptions regarding the design of transportation
                                  terrorists in planning or executing an attack for
packages do not need to be controlled for 3 basic
                                  transportation packages containing large quantities of
reasons: 1) Part 71 does not authorize possession of
                                  byproduct, source or special nuclear material is controlled
byproduct, source or special nuclear material, 2) package
                                  by other means (e.g., route controls, escort requirements,
design information is required for commerce both
                                  etc., in accordance with Commission Orders, interim
domestically and internationally, and 3) the information
                                  compensatory measures or other applicable
that could reasonably be expected to be useful to
                                  requirements).
terrorists in planning or executing an attack for
10 CFR Part 71 Drawings           Potentially Controlled - Withhold diagrams showing
transportation packages containing large quantities of
                                  detailed design information. Do not withhold drawings
byproduct, source or special nuclear material is controlled
                                  which have already been made public through FOIA
by other means (e.g., route controls, escort requirements,
                                  requests, hearings, rulemakings, or other public forums.
etc., in accordance with Commission Orders, interim
10 CFR Part 71 Transportation     Uncontrolled - An entity wishing to use or fabricate an
compensatory measures or other applicable
Quality Assurance Program        approved transportation package must submit a
requirements).
Plan Descriptions                description of its quality assurance program to the NRC.
10 CFR Part 71 Drawings
                                  This submittal is assigned a 10 CFR Part 71 docket and
Potentially Controlled - Withhold diagrams showing
                                  reviewed and approved by the staff. The QA program
detailed design information. Do not withhold drawings
                                  description typically does not contain the type of
which have already been made public through FOIA
                                  information found in the generic criteria that would cause
requests, hearings, rulemakings, or other public forums.
                                  it to be controlled. In addition, filing and approving a QA
10 CFR Part 71 Transportation
                                  program description does not authorize possession of
Quality Assurance Program
                                  byproduct, source, or special nuclear material.
Plan Descriptions
10 CFR Part 71 Package           Uncontrolled
Uncontrolled - An entity wishing to use or fabricate an
Information related to
approved transportation package must submit a
radionuclides, form and
description of its quality assurance program to the NRC.  
quantities
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
Information related to
radionuclides, form and
quantities
Uncontrolled


                                                                                  Attachment 2
Attachment 2
                                                                                  RIS 2005-31
RIS 2005-31
                                                                                  Page 16 of 19
Page 16 of 19
Subject                         Discussion and/or typical controls
Subject
10 CFR Part 71 Advance           NSIR has programmatic responsibility for reviewing and
Discussion and/or typical controls
Notification of Shipments of    controlling this information. 10 CFR 71.97 requires
10 CFR Part 71 Advance
Irradiated Reactor Fuel and      advance notifications to the governor of a State, or the
Notification of Shipments of
Nuclear Waste                    governors designee, of certain shipments of high-risk
Irradiated Reactor Fuel and
                                radioactive material.
Nuclear Waste
10 CFR Part 72 Dry Cask         Uncontrolled - Information provided to the NRC typically
NSIR has programmatic responsibility for reviewing and
Storage Systems -Certificates of consists of analyses to show that the design feature will
controlling this information. 10 CFR 71.97 requires
Compliance (COC) safety          withstand the combinations of forces associated with
advance notifications to the governor of a State, or the
analysis report information      design basis events and natural hazards. The analyses
governors designee, of certain shipments of high-risk
                                do not typically provide realistic information on the failure
radioactive material.  
                                of structural features and are not considered sensitive.
10 CFR Part 72 Dry Cask
                                Text information in the safety analysis report including
Storage Systems -Certificates of
                                design information is not controlled for the following
Compliance (COC) safety
                                reasons: 1) the design of the casks are simple by nature
analysis report information
                                and the criteria for which they are designed are widely
Uncontrolled - Information provided to the NRC typically
                                known; 2) most casks designs involve storage of the
consists of analyses to show that the design feature will
                                casks in open areas on concrete pads that are often
withstand the combinations of forces associated with
                                readily seen from offsite locations; and 3) this information
design basis events and natural hazards. The analyses
                                has been historically released to the public to support
do not typically provide realistic information on the failure
                                rulemaking for approved cask designs, and other public
of structural features and are not considered sensitive.
                                outreach efforts.
Text information in the safety analysis report including
10 CFR Part 72 Dry Cask         Potentially Controlled - Withhold diagrams showing
design information is not controlled for the following
Storage Systems -Drawings        detailed design information. Do not withhold drawings
reasons: 1) the design of the casks are simple by nature
                                which have already been made public through FOIA
and the criteria for which they are designed are widely
                                requests, hearings, rulemakings, or other public forums.
known; 2) most casks designs involve storage of the
10 CFR Part 72 Package           Uncontrolled
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
Storage Systems -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 72 Package
Information related to
Information related to
radionuclides, form and
radionuclides, form and
quantities
quantities
Uncontrolled


                                                                                      Attachment 2
Attachment 2
                                                                                      RIS 2005-31
RIS 2005-31
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Page 17 of 19
C. Emergency Planning Information
C. Emergency Planning Information
Subject                           Discussion and/or typical controls
Subject
10 CFR Part 72 Specific ISFSI     Potentially Controlled - Incoming documents are initially
Discussion and/or typical controls
Licenses and General Licenses      profiled as nonpublic - staff will review for release upon
10 CFR Part 72 Specific ISFSI
- Emergency Planning              request. Most information related to emergency planning
Licenses and General Licenses
                                    will not need to be designated as sensitive. Special
-  Emergency Planning
                                    attention is needed to determine if information relates to
Potentially Controlled - Incoming documents are initially
                                    the response by a licensee or government agency to a
profiled as nonpublic - staff will review for release upon
                                    terrorist attack. Note that some State and local
request. Most information related to emergency planning
                                    governments consider parts of their emergency plans to
will not need to be designated as sensitive. Special
                                    be sensitive.
attention is needed to determine if information relates to
D. Security Program Information
the response by a licensee or government agency to a  
Subject                           Discussion and/or typical controls
terrorist attack. Note that some State and local
10 CFR Part 72 Specific ISFSI     Potentially Controlled - Information related to security
governments consider parts of their emergency plans to
Licenses and General Licenses      programs is generally designated as SGI or SGI-M and is
be sensitive.  
- Security                        protected in a manner similar to classified confidential
D. Security Program Information
                                    information. Security-related information within the
Subject
                                    inspection and oversight program is withheld from public
Discussion and/or typical controls
                                    disclosure under 10 CFR 2.390(d).
10 CFR Part 72 Specific ISFSI
Licenses and General Licenses
-  Security
Potentially Controlled - Information related to security
programs is generally designated as SGI or SGI-M and is
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
E. Vulnerability/Security Assessments/Accident Analyses/Risk Assessments
Subject                           Discussion and/or typical controls
Subject
Vulnerability/Security             Controlled - Vulnerability/security assessments to
Discussion and/or typical controls
Assessments for:                  determine the ability of transportation packages, dry cask
Vulnerability/Security
-    10 CFR Part 71                storage systems, or ISFSIs to withstand events from
Assessments for:
      transportation package        malevolent acts have been and will continue to be
-
      designs                      withheld from public disclosure.
10 CFR Part 71
-    10 CFR Part 72 dry cask
transportation package
      storage systems
designs
-    10 CFR Part 72
-
      independent spent fuel
10 CFR Part 72 dry cask
      storage installations (ISFSI)
storage systems
-
10 CFR Part 72
independent spent fuel
storage installations (ISFSI)
Controlled - Vulnerability/security assessments to
determine the ability of transportation packages, dry cask
storage systems, or ISFSIs to withstand events from
malevolent acts have been and will continue to be
withheld from public disclosure.


                                                                                    Attachment 2
Attachment 2
                                                                                    RIS 2005-31
RIS 2005-31
                                                                                  Page 18 of 19
Page 18 of 19
APPENDIX 5 - - EXPORT/IMPORT LICENSING (NRC CONTACT: OFFICE OF
APPENDIX 5 - - EXPORT/IMPORT LICENSING (NRC CONTACT: OFFICE OF
INTERNATIONAL PROGRAMS (OIP)
INTERNATIONAL PROGRAMS (OIP)
    - Withhold information on authorized quantities or actual inventories of radionuclides,
- Withhold information on authorized quantities or actual inventories of radionuclides,
      above the thresholds in Table 1, mixed oxide materials, and enriched uranium above 6%
above the thresholds in Table 1, mixed oxide materials, and enriched uranium above 6%
      U-235. Release information identifying radionuclides and form.
U-235. Release information identifying radionuclides and form.
    - For quantities above the thresholds in Table 1, mixed oxide materials, and enriched
- 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
uranium above 6% U-235, withhold information on projected or actual shipment
      schedules, delivery dates, date required, mode of transport, storage arrangements, or
schedules, delivery dates, date required, mode of transport, storage arrangements, or
      any other related logistical information provided by the licensee in the application or
any other related logistical information provided by the licensee in the application or
      added by the NRC.
added by the NRC.


                                                                                          Attachment 2
Attachment 2
                                                                                            RIS 2005-31
RIS 2005-31
                                                                                          Page 19 of 19
Page 19 of 19
                  Table 1: Radionuclide Screening Threshold Values
      Table 1: Radionuclide Screening Threshold Values
                          Radionuclide             Quantity of        Quantity of
Radionuclide
                                                  Concern1 (TBq)     Concern2 (Ci )
Quantity of
                            Am-241                     0.06               1.6
Concern1 (TBq)
                          Am-241/Be                   0.06               1.6
Quantity of
                              Cf-252                   0.02               0.54
Concern2 (Ci )
                            Cm-244                     0.05               1.4
Am-241
                              Co-60                   0.03               0.81
0.06
                              Cs-137                     0.1               2.7
1.6
                              Gd-153                     1                 27
Am-241/Be
                              Ir-192                   0.08               2.2
0.06
                            Pm-147                     40               1100
1.6
                              Pu-238                   0.06               1.6
Cf-252
                            Pu-239/Be                   0.06               1.6
0.02
                              Se-75                     0.2               5.4
0.54
                          Sr-90 (Y-90)                   1                27
Cm-244
                              Tm-170                    20                540
0.05
                              Yb-169                    0.3                8.1
1.4
                  Combinations of                  See Footnote
Co-60
                  radioactive materials listed        Below4
0.03
                  above3
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
1
  The aggregate activity of multiple, collocated sources should be included when the total
27
Tm-170
20
540
Yb-169
0.3
8.1
Combinations of
radioactive materials listed
above3
See Footnote
Below4
1 The aggregate activity of multiple, collocated sources should be included when the total
activity exceeds the quantity of concern.
activity exceeds the quantity of concern.
2
2 TBq values are the regulatory standard and the Curie values are rounded to two significant
  TBq values are the regulatory standard and the Curie values are rounded to two significant
figures.  
figures.
3 Radioactive materials are to be considered collocated if breaching a common physical security
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
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
radioactive material or devices containing the radioactive material. For sources installed in
devices, each device should be considered a separate location.
devices, each device should be considered a separate location.
4
4 If several radionuclides are aggregated, the sum of the ratios of the activity of each source, I
  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
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
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 A)] + [(aggregated source activity for radionuclide B) ÷ (quantity of
concern for radionuclide B)] + etc........ >1
concern for radionuclide B)] + etc........ >1


                                                                                    Attachment 3
Attachment 3  
                                                                                    RIS 2005-31
RIS 2005-31
                                                                                    Page 1 of 3
Page 1 of 3
              Recently Issued NMSS Generic Communications
Recently Issued NMSS Generic Communications
  Date   GC No.                   Subject                             Addressees
Date
2/11/05 BL-05-01   Material Control and Accounting at All holders of operating licenses for
GC No.
                    Reactors and Wet Spent Fuel        nuclear power reactors, decommissioning
Subject
                    Storage Facilities                  nuclear power
Addressees
                                                        reactor sites storing spent fuel in a pool,
2/11/05
                                                        and wet spent fuel storage sites.
BL-05-01
11/23/05 RIS-05-24 Control of Radiation Dose to       All medical licensees.
Material Control and Accounting at
                    Visitors of Hospital Patients
Reactors and Wet Spent Fuel
11/14/05 RIS-05-21 Clarification of the Reporting     All U.S. Nuclear Regulatory Commission
Storage Facilities
                    Requirements in                    licensees and Part 76 certificate holders
All holders of operating licenses for
                    10 CFR 20.2201                      authorized to possess licensed material.
nuclear power reactors, decommissioning
11/08/05 RIS-05-27 NRC Timeliness Goals,               All 10 CFR Parts 71 and 72 licensees
nuclear power
                    Prioritization of Incoming License and certificate holders.
reactor sites storing spent fuel in a pool,
                    Applications and Voluntary
and wet spent fuel storage sites.
                    Submittal of Schedule for Future
11/23/05
                    Actions for NRC Review
RIS-05-24
10/28/05 RIS-05-22 Requirements for the Physical       All holders of licenses for the possession
Control of Radiation Dose to
                    Protection During Transportation of of special nuclear material (SNM) that
Visitors of Hospital Patients
                    Special Nuclear Material of         ship Category II and III quantities of this
All medical licensees.
                    Moderate and Low Strategic         material.
11/14/05
                    Significance: 10 CFR Part 72 vs.
RIS-05-21
                    Regulatory Guide 5.59 (1983)
Clarification of the Reporting
10/07/05 RIS-05-23 Clarification of the Physical       All gamma stereotactic radiosurgery
Requirements in
                    Presence Requirement During        (GSR) licensees.
10 CFR 20.2201
                    Gamma Stereotactic Radiosurgery
All U.S. Nuclear Regulatory Commission
                    Treatments
licensees and Part 76 certificate holders
09/27/05 RIS-04-17, Revised Decay-in-Storage           All licensees regulated under 10 CFR
authorized to possess licensed material.
          Rev. 1  Provisions for the Storage of      Parts 30, 32, 33, 35, 39, and 50.
11/08/05
                    Radioactive Waste Containing
RIS-05-27
                    Byproduct Material
NRC Timeliness Goals,
08/25/05 RIS-05-18 Guidance for Establishing and       All licensees, applicants for licenses,
Prioritization of Incoming License
                    Maintaining a Safety Conscious      holders of certificates of compliance, and
Applications and Voluntary
                    Work Environment                    their contractors subject to NRC authority
Submittal of Schedule for Future
08/10/05 RIS-05-16 Issuance of NRC Management         All licensees and certificate holders.
Actions for NRC Review
                    Directive 8.17, Licensee
All 10 CFR Parts 71 and 72 licensees
                    Complaints Against NRC
and certificate holders.
                    Employees
10/28/05
08/03/05 RIS-05-15 Reporting Requirements for         All material licensees possessing
RIS-05-22
                    Damaged Industrial Radiographic    industrial radiographic equipment,
Requirements for the Physical
                    Equipment                          regulated under 10 CFR Part 34.
Protection During Transportation of
Special Nuclear Material of
Moderate and Low Strategic
Significance: 10 CFR Part 72 vs.
Regulatory Guide 5.59 (1983)
All holders of licenses for the possession
of special nuclear material (SNM) that
ship Category II and III quantities of this
material.
10/07/05
RIS-05-23
Clarification of the Physical
Presence Requirement During
Gamma Stereotactic Radiosurgery
Treatments
All gamma stereotactic radiosurgery
(GSR) licensees.
09/27/05
RIS-04-17,
Rev. 1
Revised Decay-in-Storage
Provisions for the Storage of
Radioactive Waste Containing
Byproduct Material
All licensees regulated under 10 CFR
Parts 30, 32, 33, 35, 39, and 50.
08/25/05
RIS-05-18
Guidance for Establishing and
Maintaining a Safety Conscious
Work Environment
All licensees, applicants for licenses,
holders of certificates of compliance, and
their contractors subject to NRC authority
08/10/05
RIS-05-16
Issuance of NRC Management
Directive 8.17, Licensee
Complaints Against NRC
Employees
All licensees and certificate holders.
08/03/05
RIS-05-15
Reporting Requirements for
Damaged Industrial Radiographic
Equipment
All material licensees possessing
industrial radiographic equipment,
regulated under 10 CFR Part 34.


                                                                                      Attachment 3
Attachment 3
                                                                                        RIS 2005-31
RIS 2005-31
                                                                                          Page 2 of 3
Page 2 of 3
  Date     GC No.               Subject                                 Addressees
Date
07/13/05 RIS-05-13 NRC Incident Response and the       All licensees and certificate holders.
GC No.
                  National Response Plan
Subject
07/11/05 RIS-05-12 Transportation of Radioactive       Licensees authorized to possess
Addressees
                  Material Quantities of Concern      radioactive material that equals or
07/13/05
                  NRC Threat Advisory and            exceeds the threshold values in the
RIS-05-13
                  Protective Measures System          Additional Security Measures (ASM) for
NRC Incident Response and the
                                                      transportation of Radioactive Material
National Response Plan
                                                      Quantities of Concern (RAMQC) under
All licensees and certificate holders.
                                                      their 10 CFR Part 30, 32, 50, 70, and 71
07/11/05
                                                      licenses and Agreement State licensees
RIS-05-12
                                                      similarly authorized to possess such
Transportation of Radioactive
                                                      material in such quantities under their
Material Quantities of Concern
                                                      Agreement State licenses.
NRC Threat Advisory and
07/11/05 RIS-05-11 Requirements for Power Reactor     All holders of operating licenses for
Protective Measures System
                  Licensees in Possession of         nuclear power reactors and generally
Licensees authorized to possess
                  Devices Subject to the General     licensed device
radioactive material that equals or
                  License Requirements of 10 CFR     vendors.
exceeds the threshold values in the
                  31.5
Additional Security Measures (ASM) for
06/10/05 RIS-05-10 Performance-Based Approach for     All industrial radiography licensees and
transportation of Radioactive Material
                  Associated Equipment in 10 CFR      manufacturers and distributors of
Quantities of Concern (RAMQC) under
                  34.20                              industrial radiography equipment.
their 10 CFR Part 30, 32, 50, 70, and 71
04/18/05 RIS-05-06 Reporting Requirements for         All material licensees possessing
licenses and Agreement State licensees
                  Gauges Damaged at Temporary        portable gauges, regulated under 10 CFR
similarly authorized to possess such
                  Job Sites                          Part 30.
material in such quantities under their
04/14/05 RIS-05-04 Guidance on the Protection of       All holders of operating licenses or
Agreement State licenses.
                  Unattended Openings that            construction permits for nuclear power
07/11/05
                  Intersect a Security Boundary or    reactors,
RIS-05-11
                  Area                                research and test reactors,
Requirements for Power Reactor
                                                      decommissioning reactors with fuel on
Licensees in Possession of
                                                      site, Category 1 fuel cycle
Devices Subject to the General
                                                      facilities, critical mass facilities, uranium
License Requirements of 10 CFR
                                                      conversion facility, independent spent
31.5
                                                      fuel storage
All holders of operating licenses for
                                                      installations, gaseous diffusion plants,
nuclear power reactors and generally
                                                      and certain other material licensees.
licensed device
02/28/05 RIS-05-03 10 CFR Part 40 Exemptions for       All persons possessing aircraft
vendors.
                  Uranium Contained in Aircraft      counterweights containing uranium under
06/10/05  
                  Counterweights - Storage and        the exemption in
RIS-05-10  
                  Repair                              10 CFR 40.13(c)(5).
Performance-Based Approach for
11/17/05 IN-05-31 Potential Non-conservative Error in All licensees using the KENO V.a or
Associated Equipment in 10 CFR
                  Preparing Problem-dependent        KENO-VI criticality code module in
34.20
                  Cross Sections for use with the    Version 5 of the Standardized Computer
All industrial radiography licensees and
                  KENO V.a or KENO-VI Criticality    Analyses for Licensing Evaluation
manufacturers and distributors of
                  Code                                (SCALE) software developed by Oak
industrial radiography equipment.
                                                      Ridge National Laboratory (ORNL).
04/18/05
10/31/05 IN-05-28 Inadequate Test Procedure Fails     All licensees authorized to possess a
RIS-05-06
                  to Detect Inoperable Criticality    critical mass of special nuclear material.
Reporting Requirements for
                  Accident Alarm Horns
Gauges Damaged at Temporary
10/07/05 IN-05-27 Low Dose-Rate Manual               All medical licensees.
Job Sites
                  Brachytheraphy Equipment
All material licensees possessing
                  Related Medical Events
portable gauges, regulated under 10 CFR
Part 30.
04/14/05
RIS-05-04
Guidance on the Protection of
Unattended Openings that
Intersect a Security Boundary or
Area
All holders of operating licenses or
construction permits for nuclear power
reactors,
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
Uranium Contained in Aircraft
Counterweights - Storage and
Repair
All persons possessing aircraft
counterweights containing uranium under
the exemption in
10 CFR 40.13(c)(5).
11/17/05
IN-05-31
Potential Non-conservative Error in
Preparing Problem-dependent
Cross Sections for use with the
KENO V.a or KENO-VI Criticality
Code
All licensees using the KENO V.a or
KENO-VI criticality code module in
Version 5 of the Standardized Computer
Analyses for Licensing Evaluation
(SCALE) software developed by Oak
Ridge National Laboratory (ORNL).
10/31/05
IN-05-28
Inadequate Test Procedure Fails
to Detect Inoperable Criticality
Accident Alarm Horns
All licensees authorized to possess a
critical mass of special nuclear material.
10/07/05
IN-05-27
Low Dose-Rate Manual
Brachytheraphy Equipment
Related Medical Events
All medical licensees.


                                                                                              Attachment 3
Attachment 3
                                                                                                RIS 2005-31
RIS 2005-31
                                                                                                Page 3 of 3
Page 3 of 3
      Date       GC No.                   Subject                                 Addressees
Date
    07/29/05     IN-05-22   Inadequate Criticality Safety         All licensees authorized to possess a
GC No.
                            Analysis of Ventilation Systems at    critical mass of special nuclear material.
Subject
                            Fuel Cycle Facilities
Addressees
    06/23/05     IN-05-17   Manual Brachytherapy Source           All medical licensees authorized to
07/29/05
                            Jamming                              possess a Mick applicator.
IN-05-22
    05/17/05     IN-05-13   Potential Non-conservative Error in   All licensees using the Keno-V.a criticality
Inadequate Criticality Safety
                            Modeling Geometric Regions in        code module in Standardized Computer
Analysis of Ventilation Systems at
                            the                                  Analyses for Licensing Evaluation
Fuel Cycle Facilities
                            Keno-v.a Criticality Code            (SCALE) software developed by Oak
All licensees authorized to possess a
                                                                  Ridge National Laboratory (ORNL)
critical mass of special nuclear material.
    05/17/05     IN-05-12   Excessively Large Criticality Safety All licensees authorized to possess a
06/23/05
                            Limits Fail to Provide Double        critical mass of special nuclear material.
IN-05-17
                            Contingency at Fuel Cycle Facility
Manual Brachytherapy Source
    04/07/05     IN-05-10   Changes to 10 CFR Part 71             All 10 CFR Part 71 licensees and
Jamming
                            Packages                              certificate holders.
All medical licensees authorized to
  040/01/05     IN-05-07   Results of HEMYC Electrical           All holders of operating licenses for
possess a Mick applicator.
                            Raceway Fire Barrier System Full      nuclear power reactors, except those who
05/17/05
                            Scale Fire Testing                    have
IN-05-13
                                                                  permanently ceased operations and have
Potential Non-conservative Error in
                                                                  certified that fuel has been permanently
Modeling Geometric Regions in
                                                                  removed
the
                                                                  from the reactor vessel, and fuel facilities
Keno-v.a Criticality Code
                                                                  licensees.
All licensees using the Keno-V.a criticality
    03/10/05     IN-05-05   Improving Material Control and       All licensees authorized to possess a
code module in Standardized Computer
                            Accountability Interface with        critical mass of special nuclear material.
Analyses for Licensing Evaluation
                            Criticality Safety Activities at Fuel
(SCALE) software developed by Oak
                            Cycle Facilities
Ridge National Laboratory (ORNL)
05/17/05
IN-05-12
Excessively Large Criticality Safety
Limits Fail to Provide Double
Contingency at Fuel Cycle Facility
All licensees authorized to possess a
critical mass of special nuclear material.
04/07/05
IN-05-10
Changes to 10 CFR Part 71
Packages
All 10 CFR Part 71 licensees and
certificate holders.
040/01/05
IN-05-07
Results of HEMYC Electrical
Raceway Fire Barrier System Full
Scale Fire Testing
All holders of operating licenses for
nuclear power reactors, except those who
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
Accountability Interface with
Criticality Safety Activities at Fuel
Cycle Facilities
All licensees authorized to possess a
critical mass of special nuclear material.
Note: NRC generic communications may be found on the NRC public website at
Note: NRC generic communications may be found on the NRC public website at
http://www.nrc.gov, under Electronic Reading Room/Document Collections.
http://www.nrc.gov, under Electronic Reading Room/Document Collections.
}}
}}

Latest revision as of 00:15, 14 January 2025

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:
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

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

NRC000086

Nuclear Regulatory Commission

Exhibit # - NRC000086-MA-BD01

Docket # - 07007015

Identified: 01/25/2011

Admitted: Withdrawn:

Rejected: Stricken:

01/25/2011

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

Security-Related Information

Withhold Under 10 CFR 2.390

Subject

XXXXXXXXXX

XXXXXXXXXX

XXXXXXXXXX

XXXXXXXXXX

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

Note that a cover letter should clearly state

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.

Ensure Subject Line is non-sensitive

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

-1-

NMSS GUIDANCE

SCREENING CRITERIA FOR SECURITY-RELATED

SENSITIVE UNCLASSIFIED NON-SAFEGUARDS INFORMATION

DECEMBER 2005

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

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.

-

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,

conversion, enrichment and fuel fabrication

facilities

Sections 1 and 2 for general information and

Appendix 1.

Decommissioning and low-level waste sites

Sections 1 and 2 for general information and

Appendix 2.

Medical, Industrial, and Academic Uses of

Nuclear Materials

Sections 1 and 2 for general information and

Appendix 3.

10 CFR Part 71: certificate holders, and

registered users

Sections 1 and 2 for general information and

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

holders

Sections 1 and 2 for general information and

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

licensees, and site specific licensees

Sections 1 and 2 for general information and

Appendix 4, parts A, B, C, D and E.

Export and Import

Sections 1 and 2 for general information and

Appendix 5.

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

RIS 2005-31

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

RIS 2005-31

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

RIS 2005-31

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

RIS 2005-31

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

Licenses and General Licenses

- Text descriptions of the

following: general description,

site characteristics, principal

design criteria, storage cask

design, operations, waste

management, radiation

protection, accident analyses,

conduct of operations, operating

controls and limits, and quality

assurance

Uncontrolled - Information provided to the NRC for

specific ISFSI licenses and general licenses 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 are not considered sensitive.

10 CFR Part 72 Specific ISFSI

Licenses and General Licenses

- Drawings and locations of

related hazards

Potentially Controlled - Decisions regarding the control of

information that show the plant site and buildings are

dependent on the level of detail. Information clearly

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

Licenses and General Licenses

- Nearby industrial,

transportation, and military

facilities

Controlled - Information related to non-nuclear facilities

located near the ISFSI such as pipeline data (usually

withheld per DOT) and chemical facilities (some data

withheld per EPA) is controlled. Other information may

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

EPA, DOT)

10 CFR Part 72 Specific ISFSI

Licenses and General Licenses

Uncontrolled - Information related to radionuclides, form,

and quantities

Lists of licensees registered to

use NRC-approved 10 CFR Part 71 transportation packages.

Withhold lists and associated letters required by 10 CFR 71.17(c)(3).

Attachment 2

RIS 2005-31

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

Package Descriptions Text

Descriptions Including

Radionuclide Form, Content and

Quantity

Uncontrolled - Information provided to the NRC 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 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

Quality Assurance Program

Plan Descriptions

Uncontrolled - An entity wishing to use or fabricate an

approved transportation package must submit a

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

Information related to

radionuclides, form and

quantities

Uncontrolled

Attachment 2

RIS 2005-31

Page 16 of 19

Subject

Discussion and/or typical controls

10 CFR Part 71 Advance

Notification of Shipments of

Irradiated Reactor Fuel and

Nuclear Waste

NSIR has programmatic responsibility for reviewing and

controlling this information. 10 CFR 71.97 requires

advance notifications to the governor of a State, or the

governors designee, of certain shipments of high-risk

radioactive material.

10 CFR Part 72 Dry Cask

Storage Systems -Certificates of

Compliance (COC) safety

analysis report information

Uncontrolled - Information provided to the NRC 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 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

Storage Systems -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 72 Package

Information related to

radionuclides, form and

quantities

Uncontrolled

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

Licenses and General Licenses

- Emergency Planning

Potentially Controlled - Incoming documents are initially

profiled as nonpublic - staff will review for release upon

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

Licenses and General Licenses

- Security

Potentially Controlled - Information related to security

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

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

Assessments for:

-

10 CFR Part 71

transportation package

designs

-

10 CFR Part 72 dry cask

storage systems

-

10 CFR Part 72

independent spent fuel

storage installations (ISFSI)

Controlled - Vulnerability/security assessments to

determine the ability of transportation packages, dry cask

storage systems, or ISFSIs to withstand events from

malevolent acts have been and will continue to be

withheld from public disclosure.

Attachment 2

RIS 2005-31

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

RIS 2005-31

Page 19 of 19

Table 1: Radionuclide Screening Threshold Values

Radionuclide

Quantity of

Concern1 (TBq)

Quantity of

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

radioactive materials listed

above3

See Footnote

Below4

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

Reactors and Wet Spent Fuel

Storage Facilities

All holders of operating licenses for

nuclear power reactors, decommissioning

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

Visitors of Hospital Patients

All medical licensees.

11/14/05

RIS-05-21

Clarification of the Reporting

Requirements in

10 CFR 20.2201

All U.S. Nuclear Regulatory Commission

licensees and Part 76 certificate holders

authorized to possess licensed material.

11/08/05

RIS-05-27

NRC Timeliness Goals,

Prioritization of Incoming License

Applications and Voluntary

Submittal of Schedule for Future

Actions for NRC Review

All 10 CFR Parts 71 and 72 licensees

and certificate holders.

10/28/05

RIS-05-22

Requirements for the Physical

Protection During Transportation of

Special Nuclear Material of

Moderate and Low Strategic

Significance: 10 CFR Part 72 vs.

Regulatory Guide 5.59 (1983)

All holders of licenses for the possession

of special nuclear material (SNM) that

ship Category II and III quantities of this

material.

10/07/05

RIS-05-23

Clarification of the Physical

Presence Requirement During

Gamma Stereotactic Radiosurgery

Treatments

All gamma stereotactic radiosurgery

(GSR) licensees.

09/27/05

RIS-04-17,

Rev. 1

Revised Decay-in-Storage

Provisions for the Storage of

Radioactive Waste Containing

Byproduct Material

All licensees regulated under 10 CFR Parts 30, 32, 33, 35, 39, and 50.

08/25/05

RIS-05-18

Guidance for Establishing and

Maintaining a Safety Conscious

Work Environment

All licensees, applicants for licenses,

holders of certificates of compliance, and

their contractors subject to NRC authority

08/10/05

RIS-05-16

Issuance of NRC Management

Directive 8.17, Licensee

Complaints Against NRC

Employees

All licensees and certificate holders.

08/03/05

RIS-05-15

Reporting Requirements for

Damaged Industrial Radiographic

Equipment

All material licensees possessing

industrial radiographic 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

National Response Plan

All licensees and certificate holders.

07/11/05

RIS-05-12

Transportation of Radioactive

Material Quantities of Concern

NRC Threat Advisory and

Protective Measures System

Licensees authorized to possess

radioactive material that equals or

exceeds the threshold values in the

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

Licensees in Possession of

Devices Subject to the General

License Requirements of 10 CFR 31.5

All holders of operating licenses for

nuclear power reactors and generally

licensed device

vendors.

06/10/05

RIS-05-10

Performance-Based Approach for

Associated Equipment in 10 CFR 34.20

All industrial radiography licensees and

manufacturers and distributors of

industrial radiography equipment.

04/18/05

RIS-05-06

Reporting Requirements for

Gauges Damaged at Temporary

Job Sites

All material licensees possessing

portable gauges, regulated under 10 CFR Part 30.

04/14/05

RIS-05-04

Guidance on the Protection of

Unattended Openings that

Intersect a Security Boundary or

Area

All holders of operating licenses or

construction permits for nuclear power

reactors,

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

Uranium Contained in Aircraft

Counterweights - Storage and

Repair

All persons possessing aircraft

counterweights containing uranium under

the exemption in

10 CFR 40.13(c)(5).

11/17/05

IN-05-31

Potential Non-conservative Error in

Preparing Problem-dependent

Cross Sections for use with the

KENO V.a or KENO-VI Criticality

Code

All licensees using the KENO V.a or

KENO-VI criticality code module in

Version 5 of the Standardized Computer

Analyses for Licensing Evaluation

(SCALE) software developed by Oak

Ridge National Laboratory (ORNL).

10/31/05

IN-05-28

Inadequate Test Procedure Fails

to Detect Inoperable Criticality

Accident Alarm Horns

All licensees authorized to possess a

critical mass of special nuclear material.

10/07/05

IN-05-27

Low Dose-Rate Manual

Brachytheraphy Equipment

Related Medical Events

All medical licensees.

Attachment 3

RIS 2005-31

Page 3 of 3

Date

GC No.

Subject

Addressees

07/29/05

IN-05-22

Inadequate Criticality Safety

Analysis of Ventilation Systems at

Fuel Cycle Facilities

All licensees authorized to possess a

critical mass of special nuclear material.

06/23/05

IN-05-17

Manual Brachytherapy Source

Jamming

All medical licensees authorized to

possess a Mick applicator.

05/17/05

IN-05-13

Potential Non-conservative Error in

Modeling Geometric Regions in

the

Keno-v.a Criticality Code

All licensees using the Keno-V.a criticality

code module in Standardized Computer

Analyses for Licensing Evaluation

(SCALE) software developed by Oak

Ridge National Laboratory (ORNL)

05/17/05

IN-05-12

Excessively Large Criticality Safety

Limits Fail to Provide Double

Contingency at Fuel Cycle Facility

All licensees authorized to possess a

critical mass of special nuclear material.

04/07/05

IN-05-10

Changes to 10 CFR Part 71

Packages

All 10 CFR Part 71 licensees and

certificate holders.

040/01/05

IN-05-07

Results of HEMYC Electrical

Raceway Fire Barrier System Full

Scale Fire Testing

All holders of operating licenses for

nuclear power reactors, except those who

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

Accountability Interface with

Criticality Safety Activities at Fuel

Cycle Facilities

All licensees authorized to possess a

critical mass of special nuclear material.

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

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