Protecting Our Nation

A Report of the U.S. Nuclear

Regulatory Commission

Office of Nuclear Security and Incident Response
ACKNOWLEDGMENTS

Shyrl Coker

Sarah Loh

Rebecca Richardson

Jeffrey Riley

Rebecca Stone
TABLE OF CONTENTS

FOREWORD FROM THE CHAIRMAN..............................................................................2

EXECUTIVE SUMMARY.....................................................................................................4

SECURITY AT NUCLEAR REACTORS .............................................................................6

 Security for Operating, New, and Nonpower Reactors.......................................................6

 Design Basis Threat for Radiological Sabotage ..................................................................8

 Security Baseline Inspections ............................................................................................10

 Force-on-Force Security Inspections................................................................................. 11

MATERIALS SECURITY....................................................................................................13

 Security for the Use, Storage, and Transportation of Nuclear and Radiological Materials. 13

 Design Basis Threat for Theft or Diversion.......................................................................18

 Security Core Inspections...................................................................................................19

 Force-on-Force Security Inspections.................................................................................20

CYBER SECURITY.............................................................................................................22

NUCLEAR PREPAREDNESS AND RESPONSE .............................................................24

 Emergency Preparedness....................................................................................................24

 Incident Response...............................................................................................................25

 Headquarters Operations Center.....................................................................................25

 Continuity of Operations.................................................................................................26

 Interagency Response......................................................................................................26

ADDITIONAL SECURITY ACTIVITIES..........................................................................28

 Communications.................................................................................................................28

 Information Security...........................................................................................................29

 Intelligence .........................................................................................................................29

 Security Programs To Ensure Trustworthiness and Reliability.........................................31

 Access Authorization Programs......................................................................................31

 Fitness-for-Duty Program ...............................................................................................32

 Behavioral Observation Program....................................................................................32

 Insider Mitigation Program................................................................................................33

 International Safety and Security.......................................................................................33

CONCLUSION.....................................................................................................................35

GLOSSARY...............................................................................................................36

LIST OF ACRONYMS ...............................................................................................40
2 Protecting People and the Environment

FOREWORD FROM THE CHAIRMAN

Since 2004, the U.S. Nuclear 

Regulatory Commission (NRC) has 

published and periodically updated 

“Protecting Our Nation” to provide an 

overview of the various ways in which 

the NRC protects our nation’s civilian 

nuclear facilities from harm and works 

to ensure that radioactive material 

does not fall into the wrong hands. We 

are pleased to provide this updated 

edition to continue to share this important information with the public.

Since the last edition, published two 

years ago, the NRC has continued 

its strong commitment to nuclear 

security. Recent changes to some of 

the NRC’s security regulations will 

further strengthen our already rigorous 

program. We are also focusing 

significant attention on cyber security. The NRC recently developed 

and issued a cyber security roadmap 

to evaluate the need for cyber security 

requirements for fuel cycle facilities, 

nonpower reactors, Independent Spent 

Fuel Storage Installations (ISFSIs) 

and byproduct materials licensees. 

In January 2013, the NRC began 

conducting inspections of power 

reactor licensees’ cyber security plans 

and implementation. 

The NRC is also working cooperatively with its international regulatory 

counterparts to share best practices 

and lessons learned. In December 

2012, the NRC hosted the first-ever 

International Security Regulators 

Conference with the objective of deepening our relationships with security regulators around the world. In 

addition, our extensive cooperation 

with the International Atomic Energy 

Agency (IAEA) helps ensure that our 

program benefits from international 

insights, and vice versa. The NRC 

hosted an IAEA International Physical 

Protection Advisory Service mission 

in an effort to seek further feedback on 

some aspects of our security program 

from the international community.

As many of you are aware, one important component of the NRC’s security 

program is emergency preparedness 

and response. The 2011 Fukushima 

Daiichi accident reinforced the need 

for nuclear regulators to prepare themselves and their licensees to handle all 

kinds of emergencies, irrespective of 

their cause. At a nuclear site, safety 

and security systems are inherently 

integrated. The NRC is overseeing 

licensees’ enhancements to their 

Chairman Allison M. Macfarlane speaks 

during the Regulatory Information Conference 

at NRC Headquarters.
U.S. Nuclear Regulatory Commission 3

emergency communication and 

staffing plans as part of its effort to 

implement lessons learned from this 

accident. In addition, we continue 

to work diligently with our licensees 

and Federal, State, Tribal and local 

government officials in conducting 

safety- and security-focused drills and 

exercises. Our consistent attention to 

emergency preparedness and enhanced 

coordination with responsible organizations helps ensure that the NRC and 

its licensees would respond effectively 

to a variety of scenarios.

The tragedy of the September 11, 

2001, terrorist attacks left an indelible imprint on our memory and 

served as the catalyst for lasting 

enhancements to the NRC’s security 

program. Drawing upon this, we must 

be prepared to address threats from a 

variety of adversaries. We don’t need 

to look further than the daily newspaper to see that both are constantly 

evolving. In this publication, you 

will learn about the many ways in 

which the NRC and its licensees work 

together to maintain a robust security program that protects some of our 

nation’s most sensitive assets.

Allison Macfarlane

Chairman, NRC
4 Protecting People and the Environment

EXECUTIVE SUMMARY

An additional layer of protection is 

in place related to coordinating threat 

information and response. The NRC 

works closely with Federal, State, 

Tribal, and local authorities. These 

relationships help ensure that the NRC 

can act quickly to disseminate threat 

information to licensees and allow 

effective emergency response in the 

event of an attack. Together, these 

layers of defense provide a level of 

security second to none in the Nation’s 

commercial sector. 

The NRC regulates mature, robust, 

and integrated security, emergency 

preparedness, and incident response 

programs at licensed facilities. This 

includes the development of new 

programs to address new and changing 

real world threats, as well as future 

challenges.

For over 35 years, the NRC has 

maintained effective nuclear security, 

emergency preparedness, and incident 

response programs as part of its 

mission to ensure adequate protection 

of public health and safety, to promote 

the common defense and security, and 

to protect the environment. The NRC 

requires safe and secure operations at 

all nuclear facilities. Generally, safety 

refers to operating the facility in a 

manner that protects the public and the 

environment, while security refers to 

protecting the facility from adversaries 

who wish to harm people and the 

environment. Safety and security 

are achieved by employing people, 

programs, and equipment to ensure 

implementation of robust programs as 

required by NRC regulations.

Security, like safety, is achieved in 

layers, with multiple approaches 

at work to provide high assurance 

that licensed activities do not cause 

unreasonable risk to public health and 

safety. For example, nuclear power 

plants are secure, robust structures 

that are designed and built to withstand hurricanes, tornadoes, and 

earthquakes. In addition, well-trained 

and armed security officers, physical 

barriers, access controls, and intrusion 

detection and surveillance systems are 

used to protect certain NRC-licensed 

facilities, such as commercial power 

reactors. 
U.S. Nuclear Regulatory Commission 5

Among the topics covered in this 

document, the following major 

activities highlight recent NRC 

accomplishments:

• continued to verify that licensees 

have implemented security 

regulations through licensing 

reviews and inspections

• continued to use a high level of 

realism in force-on-force mock 

attack exercises while ensuring the 

safety of plant employees and the 

public and continually applying 

lessons learned from previous years

• continued to verify that licensees 

have implemented cyber security 

requirements

• continued efforts to safely and 

securely transport spent fuel 

along NRC approved routes using 

NRC-approved packages

• continued to implement the 

National Source Tracking System 

(NSTS) database, which enhances 

accountability for certain radioactive 

materials and requires licensees to 

report the manufacture, transfer, 

receipt, disassembly, and disposal 

of nationally tracked radioactive 

sources

• enhanced physical security 

requirements for radioactive 

materials and devices at facilities 

and in transportation

• assessed and shared threat 

information rapidly to promote 

protection of licensed facilities

• continued to support the 

development of international 

standards 

• coordinated activities related to 

the nuclear industry’s efforts to 

conduct emergency preparedness 

exercises initiated by hostile actions 

and prepared the industry and 

offsite response organizations for 

implementing hostile-action-based 

exercises

• ensured continuous training and 

improvement to equipment and 

procedures in the NRC Headquarters 

Operations Center (HOC) and 

regional Incident Response Centers

Executive Director for Operations, Mark A. 

Satorius speaks to NRC stakeholders.
6 Protecting People and the Environment

tions are one of the most significant 

components of the NRC’s baseline 

security inspection program. Forceon-force inspections assess the ability 

of these facilities to defend against 

the Design Basis Threat (DBT) for 

radiological sabotage1 and provide 

valuable insights that enable the NRC 

to evaluate and improve the effectiveness of licenesees’ security programs. 

This DBT describes the adversary 

force that operating power reactors 

must defend against with high assurance. It is based on realistic assessments of the tactics, techniques, and 

procedures used by international and 

domestic terrorist groups and organizations. Additionally, the NRC has 

comprehensive security regulations for 

operating power reactors that include 

a cyber security threat component to 

the DBT. All power reactor licensees 

have developed cyber security plans 

which the NRC has reviewed and 

approved. The NRC conducts inspections to verify that operating power 

Security for Operating, 

New, and Nonpower 

Reactors

The NRC requires robust security 

at the Nation’s nuclear facilities. 

Effective NRC regulation, licensee 

implementation of these regulations, 

and strong partnerships with a variety 

of Federal, State, Tribal, and local 

authorities have ensured effective 

security at operating power reactors 

across the country. In fact, nuclear 

plants are possibly the best protected 

industrial facilities in the United 

States. However, given the current 

threat environment, the agency recognizes the need for continued vigilance. 

The NRC’s operating power reactor 

security baseline inspection program is 

the primary way in which the agency 

verifies that nuclear power plants 

operate according to security regulations. Force-on-force security inspecSECURITY AT NUCLEAR REACTORS

An NRC-licensed operating nuclear power plant.

Infographic map of the U.S. operating commercial nuclear 

power reactors displayed by the four NRC regions.
U.S. Nuclear Regulatory Commission 7

reactor licensees are implementing 

cyber security requirements.

On an ongoing basis, the NRC ensures 

that the security posture at operating power reactors is appropriate, 

including any changes or updates 

to security plans or procedures, and 

that they provide a high assurance of 

protection against the DBT. As with 

other categories of licensees, this is 

accomplished through a wide spectrum of licensing, inspection, and 

enforcement activities. 

Additionally, 4 new nuclear power 

plants are currently under construction. In recent years, the NRC has 

received a number of applications for 

new reactors and expects to receive 

more in the future. As the Nation’s 

civilian nuclear regulator, the NRC 

has many programs in place to meet 

the challenges associated with new 

nuclear power plant construction. 

These “next-generation” nuclear 

plant designs have benefited from the 

decades of experience gained from 

current operating plants. The new 

designs are inherently safer and more 

secure. They will use many passive 

systems, further ensuring safety with 

limited reactor operator action.

NRC regulations require applicants 

for new reactor design approvals and 

construction to perform a designspecific assessment of the effects 

of the impact of a large commercial aircraft. New Reactors will have 

inherent protection against aircraft 

impact.

The physical location of each new 

nuclear power plant is also closely 

analyzed. The U.S. Department of 

Homeland Security (DHS) has the 

authority and responsibility for a 

An NRC Resident Inspector for a nuclear 

power plant construction site, explains the 

inspection activities.

A containment vessel under construction at 

a nuclear power plant site.

1Radiological sabotage is a determined violent external assault, attack by stealth, or deceptive actions, including diversionary actions, by an adversary 

force capable of operating in each of the following modes: a single group attacking through one entry point, multiple groups attacking through multiple 

entry points, a combination of one or more groups and one or more individuals attacking through multiple entry points, or individuals attacking through 

separate entry points, with attributes, assistance and equipment as described in Title 10 of the Code of Federal Regulations (10 CFR) Part 73 “Physical 

Protection of Plants and Materials.”
8 Protecting People and the Environment

unified National effort to secure the 

United States by preventing, deterring, 

and responding to terrorist attacks 

and other threats and hazards to the 

Nation. Therefore, the NRC consults 

with DHS about the potential vulnerabilities of a proposed facility’s location 

to a terrorist threat. 

Nonpower reactors (NPRs), on the 

other hand, pose significantly less risk 

of radiological exposure to the public 

than do power reactors. Consequently, 

the NRC has tailored the security 

requirements and oversight for NPRs 

to be consistent with these lower 

risks. The NRC works with the NPR 

community to improve security by 

identifying any potential vulnerabilities that warrant additional preventive 

or mitigating measures. 

The NRC considers the following two 

main elements in establishing additional security measures for NPRs:

(1) The low potential radiological 

consequences make it unlikely 

that a terrorist attack could 

compromise public health and 

safety.

(2) Each licensee implements site 

specific security plans because 

each NPR facility is unique 

in design, operation, use, and 

location.

The NRC also works with licensees 

and the U.S. Department of Energy 

(DOE) to evaluate steps to reduce the 

inventories of reactor fuel at NPRs. 

This includes converting those reactors using highly-enriched uranium to 

using low enriched uranium through 

the DOE’s Global Threat Reduction 

Initiative. 

Design Basis Threat for 

Radiological Sabotage

The DBT for radiological sabotage 

describes the adversary force that 

operating power reactors must defend 

against with high assurance. It is 

based on realistic assessments of the 

tactics, techniques, and procedures 

used by international and domestic 

terrorist groups and organizations. 

This DBT is developed by working 

with national experts and is based on 

classified and other sensitive information. The NRC also relies on the intelThe NRC regulates 32 Nonpower Reactors 

nationwide.
U.S. Nuclear Regulatory Commission 9

tional, to determine if any changes are 

warranted. Specific characteristics of 

this DBT are not publicly available 

in order to protect sensitive security 

information that could potentially aid 

an adversary. 

In general, this DBT determines how 

operating power reactors establish 

their:

• cyber security program

• security patrols 

• security posts and physical 

barriers

• vehicle inspections and the appropriate standoff distance

• training for security and emergency response personnel

• enhanced weapons systems 

needed to implement an effective 

strategy

• types and numbers of communication equipment

• site access controls for personnel, 

including more thorough 

employee background checks

ligence community, law enforcement 

agencies, and State and local governments to provide accurate and timely 

information about the capabilities and 

activities of adversary groups.

It is the responsibility of other Federal 

organizations, including the military, 

to protect the Nation against airborne 

threats. Nonetheless, the NRC has 

conducted several comprehensive 

studies that determined that an aircraft 

impact is unlikely to result in damage to 

the core or a radiological release. In its 

requirements for operating power reactors, the NRC also requires its licensees 

to take steps to mitigate the effects of 

large fires and explosions from any 

type of initiating event. The NRC is an 

active partner with other Federal, State, 

and local authorities in constant surveillance of the airborne threat environment and adjusts its regulatory actions 

or requirements, as necessary.

The NRC staff regularly reviews this 

DBT against the current threat intelligence, both domestic and internaBarriers are part of the physical protection system 

used by operating reactors to defend against the 

DBT. 

Barriers are part of the physical protection 

system used by operating reactors to defend 

against the DBT. 
10 Protecting People and the Environment

Security Baseline 

Inspections

The NRC’s operating power reactor 

security baseline inspection program 

is the primary method in which 

the agency verifies that nuclear 

power plants operate according 

to security regulations. Under the 

program, security experts from NRC 

Headquarters and Regional offices in 

the Philadelphia, Atlanta, Chicago, and 

Dallas areas carry out security inspections at each facility. On-site Resident 

Inspectors, in conjunction with 

inspectors from Headquarters and the 

Regional offices, monitor licensees’ 

security-related activities throughout 

the year. The inspectors provide 

firsthand, independent assessments 

of plant conditions and performance, 

document their findings in writing, 

and conduct follow-up inspections to 

ensure that the licensee has made any 

necessary corrections. 

Security baseline inspections include 

the following licensee activities:

• Access Authorization

• Access Control

• Contingency Response 

Force-on-Force

• Equipment Performance, Testing, 

and Maintenance

• Protective Strategy Evaluation

• Protection of Safeguards 

Information (SGI)

• Security Training

• Fitness-for-Duty Program

• Cyber Security

• Materials Control and Accounting

• Target Set Development

The NRC’s overall evaluation of an 

operating power reactor’s performance considers the results of security 

inspections. However, if a significant security issue is found, the NRC 

requires the licensee to resolve the 

issue promptly. If necessary, the NRC 

can take enforcement action which 

may result in civil penalties. Some 

information related to these inspections is available to the public via the 

NRC website. However, some of the 

information is not publicly available 

in order to protect sensitive security 

information that could potentially aid 

an adversary.

An NRC inspector gathers information at a nuclear 

power plant.
U.S. Nuclear Regulatory Commission 11

Force-on-Force Security Inspections

core and the spent nuclear fuel pool, 

both of which may contain radioactive 

fuel. For that reason, it is essential to 

protect these systems and components 

from being reached by the adversary 

force to avoid the potential for radiological release.

Along with the facility’s security 

personnel, many offsite organizations 

may participate in and/or observe 

force-on-force inspections. These 

organizations include Federal, State, 

and local law enforcement agencies. In 

addition, emergency planning officials, 

plant operators, and NRC personnel 

are present.

By law, the NRC conducts a forceon-force inspection at each plant at 

least once every 3 years. The NRC 

uses lessons learned from previous 

force-on-force inspections in making 

changes to its procedures and inspector 

training programs.

The force-on-force program ensures 

a high level of realism during the 

inspection, while ensuring the safety 

of operating nuclear reactor employees 

and the public. The force-on-force 

inspection involves two shifts of the 

licensee’s security officers: one set 

maintains the plant’s security, while 

the other set participates in the inspection. In addition, a separate group 

controls and monitors both inspection participants and on-duty security 

Force-on-force security inspections are 

one of the components of the NRC’s 

security baseline inspection program. 

The NRC has used force-on-force 

inspections regularly as part of its 

inspection process since 1991. Forceon-force inspections assess the ability 

of power reactor facilities to defend 

against the DBT for radiological sabotage and provide valuable insights that 

enable the NRC to evaluate the effectiveness of licensee security programs. 

They are an essential part of the oversight of the security of these facilities. 

A full force-on-force inspection 

spans several weeks. It includes 

both tabletop drills and simulated 

combat between a mock adversary 

force and the operating power reactor’s force. During the inspection, 

the mock adversary force attempts to 

reach and damage key safety systems 

and components identified as target 

sets while battling the plant’s security force. These key safety systems 

and components protect the reactor 

An adversary force approaches a nuclear power 

plant during a force-on-force training exercise. 
12 Protecting People and the Environment

officers during the inspection. The 

NRC has overall control of the exercise and the NRC inspection team 

monitors all aspects of the exercise 

activities to ensure the safety of the 

participants and the conduct of the 

exercise in accordance with approved 

NRC inspection standards. In preparation for a force-on-force inspection, 

participants compile information from 

tabletop drills, other inspections, and 

security plan reviews. This information is then used to design a number 

of mock attacks seeking to probe for 

potential vulnerabilities in the defensive strategy used at a specific operating power reactor. Any potentially 

significant findings identified during a 

force-on-force inspection are promptly 

reviewed, addressed, and corrected 

before the NRC inspectors leave the 

plant.

Active-duty U.S. Special Operations 

Forces advise the NRC inspection 

teams that conduct force-on-force 

inspections. These individuals participate in the inspections by helping the 

NRC inspectors develop the attack 

scenarios, providing expert technical 

advice to the mock adversary force, 

assisting the NRC inspectors in evaluating site security forces and systems, 

and providing an independent evaluation of mock adversary performance.

The adversary is a credible, well 

trained, and consistent mock force 

that is vital to the NRC’s force-onforce program. The NRC works with 

the nuclear industry to develop mock 

adversary training and uses rigorous 

performance standards to evaluate 

the mock adversary force at each 

inspection.

It is important to emphasize that the 

NRC designs, runs, and evaluates the 

force-on-force inspections. The mock 

adversary force does not establish the 

inspection’s objectives, boundaries, 

or timelines. To date, the performance 

of the mock adversary force has been 

exceptional, and no instances of a 

possible conflict of interest have been 

identified.

NRC Chairman Allison M. Macfarlane listens to 

staff discuss security topics at the International 

Regulators Conference on Nuclear Security at NRC 

Headquarters.
U.S. Nuclear Regulatory Commission 13

MATERIALS SECURITY

ways if not protected. Given the 

current threat environment, the agency 

recognizes the need for continued 

vigilance. 

The NRC licenses and inspects all 

commercial fuel cycle facilities that 

turn uranium ore from the ground into 

fuel for nuclear reactors. This includes 

uranium recovery facilities that mill 

uranium; facilities that convert, enrich, 

and fabricate the uranium into nuclear 

fuel for use in nuclear reactors; and 

deconversion facilities that will 

process the depleted uranium hexafluoride for recycling or disposal. 

Security for the 

Use, Storage, and 

Transportation of 

Nuclear and Radiological 

Materials

The NRC has longstanding regulatory programs to ensure the security 

of materials that it licenses. Nuclear 

materials are used to produce fuel 

for nuclear reactors and can be the 

primary ingredients for an improvised 

nuclear device. The NRC requires 

licensees to apply a graded level 

of physical protection and material 

control and accounting, depending on 

the material and the relative potential 

consequences if it is misused. Security 

programs may include background 

checks, personnel access controls, 

security barriers, detection of unauthorized access, and an armed law 

enforcement response. These programs 

provide the greatest protection to those 

materials that could be used in harmful 

The stages of the nuclear fuel cycle.

A small ceramic fuel pellet. 
14 Protecting People and the Environment

The NRC also regulates the fabrication 

of other types of nuclear fuel, such as 

mixed oxide fuel, which is a combination of uranium and plutonium oxides.

The NRC regulates fuel cycle facilities through a combination of the 

following:

• safety and security regulations 

that licensees must meet to obtain 

and retain a license to use nuclear 

materials

• authorization for an applicant to 

use or transport nuclear materials 

or operate a nuclear facility

• an oversight process that includes 

inspections, enforcement, assessment of licensee performance, 

and investigation of reports of 

wrongdoing

• support activities (e.g., research, 

hearings, independent reviews)

Additionally, the NRC has issued 

orders to various fuel cycle facilities containing detailed requirements 

related to detection of, assessment 

of, and response to malicious acts, 

including enhancing the protection 

of their computer systems. In 2012, 

the NRC developed and issued a 

cyber security paper that communicates the staff’s approach, or roadmap, 

to evaluate the need for cyber security requirements for specific types of 

licensees, including fuel cycle facilities. The roadmap is designed to ensure 

that appropriate cyber security protections are implemented efficiently at all 

NRC-licensed fuel cycle facilities. The 

purpose of these regulatory actions is 

to ensure adequate protection of public 

health and safety, promote the common 

defense and security, and to protect the 

environment for licensed activities at 

fuel facilities. 

Spent nuclear fuel refers to fuel from 

nuclear reactors that is no longer being 

used. Periodically, approximately one 

third of the nuclear fuel in an operating reactor needs to be replaced with 

fresh fuel. Spent nuclear fuel is safely 

stored in specially designed pools 

at reactor sites around the country. 

Spent fuel pools are robust structures 

constructed of very thick steel-reinforced concrete walls with stainless 

steel liners located inside protected 

areas at nuclear power reactor sites. 

Many fuel pools are located below 

ground level, are shielded by other 

structures, and have intervening walls 

that would obstruct something that 

could make a large impact, such as an 

aircraft. The NRC regulations require 

licensees to develop guidance and 

strategies to maintain and restore spent 

fuel pool cooling using existing or 

available resources if cooling is lost. 

The NRC imposes stringent requirements to 

ensure the safe and secure operation of spent 

fuel pools. 
U.S. Nuclear Regulatory Commission 15

The NRC encourages members of 

the public and other stakeholders to 

provide comments during the development of the updated regulations. 

In addition, the NRC continues to 

evaluate whether changes in adversary 

capabilities could significantly affect 

ISFSI security. The NRC is engaging 

with other Government agencies, intelligence and law enforcement communities, and national laboratories in this 

task. 

Nuclear and radioactive materials are 

also used in many beneficial ways in 

the areas of medicine, academia, and 

industry; however, some materials 

if misused can have negative effects 

on people and the environment. The 

terrorist attacks on September 11, 

2001, heightened concerns about the 

use of risk-significant radioactive 

materials in a malevolent act. Such 

materials could be used in a “dirty 

bomb”. 

After September 11, 2001, the NRC 

and its partners in Agreement States 

took steps to strengthen the security of 

risk-significant radioactive materials. 

The NRC and Agreement States issued 

various orders imposing comprehensive security measures that are 

A radiography camera and its approved transport container. 

For many events, plant operators 

would have significant time to correct 

a problem or implement fixes to 

restore cooling.

The NRC has also authorized nuclear 

power plant licensees to store spent 

nuclear fuel at current and former 

reactor sites in NRC-approved dry 

storage casks. Beginning in the 1980s, 

the nuclear industry began storing 

spent nuclear fuel on site in storage 

casks located at ISFSIs. These casks 

are robust, massive concrete and steel 

structures and provide additional space 

for sites with limited space in their 

spent fuel pools. The NRC conducted 

security vulnerability assessments 

of several cask designs used at dry 

storage ISFSIs. These assessments 

included aircraft impacts and ground 

assaults consistent with the DBT. 

The NRC has always required ISFSIs 

to have an onsite physical security 

system to protect against any unauthorized access to the spent nuclear 

fuel and its storage area. 

The NRC is updating regulations to 

improve the consistency and clarity 

of the security measures for ISFSIs. 

Independent spent fuel storage installations 

store spent fuel safely and securely. 
16 Protecting People and the Environment

appropriate to the facilities housing the 

materials and the level of security risk 

posed by the materials.

The security orders established a 

multi-layered, non-prescriptive framework that allows licensees to develop 

security programs specifically tailored 

to their facilities. 

Key elements of the program include:

• Background checks, including 

fingerprinting, to ensure that 

people with access to radioactive material are trustworthy and 

reliable

• Personnel access controls to areas 

where radioactive material is 

stored or used

• Security plans or procedures 

designed to detect, deter, assess 

and respond to unauthorized 

access attempts

• Coordination and response planning between licensees and local 

law enforcement agencies

• Coordination and tracking of 

shipments of radioactive material

• Additional security barriers to 

discourage theft of portable 

devices containing radioactive 

material

In 2013, the NRC published security regulations in a new comprehensive rule titled, Part 37, “Physical 

Protection of Byproduct Material”. 

The Part 37 rule incorporates and 

expands upon the requirements from 

the security orders and includes 

lessons learned from implementing, 

inspecting and enforcing the orders. 

Compliance with Part 37 will be 

required for NRC licensees by March 

2014. The Agreement States must 

publish compatible regulations by 

March 2016. The security orders 

will remain in effect until the rule is 

implemented. 

Additionally, the NRC developed 

an Integrated Source Management 

Portfolio. It includes the National 

Source Tracking System (NSTS) , 

the Web-Based Licensing (WBL) 

database, and the License Verification 

System (LVS). The NSTS is a database that enhances accountability 

for certain radioactive sources that 

pose the greatest safety and security 

concerns. The NSTS requires licensees 

to report the manufacture, transfer, 

receipt, disassembly, and disposal of 

radioactive sources that are required 

to be tracked nationally. The NSTS is 

an important component of the NRC’s 

effort to enhance the accountability 

and security of radioactive sources. 

WBL, a second database, was implemented in 2012. 
U.S. Nuclear Regulatory Commission 17

nuclear power plants. Spent nuclear 

fuel has been successfully transported 

in NRC-approved containers safely 

and securely since 1979.

For decades, the NRC has required 

radioactive material containers to 

withstand different types of accidents, including dropping, puncturing, 

flooding, and fire. Security measures 

complement these safety controls. For 

example, the NRC requires licensees 

and carriers involved in spent nuclear 

fuel shipments to follow approved 

routes and to provide armed escorts, 

vehicle immobilization devices, and 

redundant communications. The 

licensees notify the NRC and States the 

transport will pass through in advance 

of the shipments.

For more than 30 years, spent nuclear 

fuel has been transported under stringent security requirements. After 

September 11, 2001, the NRC reviewed 

its transportation security program. 

Following that review, the NRC 

required security enhancements for 

both shipments of spent nuclear fuel 

and shipments of significant quantities 

of radioactive material. 

This system manages the licensing 

lifecycle from initial application to 

license issuance, amendment, and 

termination. It also modernizes the 

method for authenticating radioactive material licenses. The NRC uses 

WBL as its licensing system, and it is 

available to Agreement States for their 

licensing purposes. Another important system was added in 2013 – the 

LVS. LVS provides a secure, fast, 

digital system that permits licensees to 

confirm that another party is properly 

licensed and authorized to possess 

radioactive material before shipping 

or transferring radioactive material to 

that party. 

The NRC regulates the transportation 

of nuclear and radiological materials 

through a combination of safety and 

security requirements. About 300 

million shipments of hazardous material are transported by road, rail, or 

water in the United States each year. 

Of those shipments, only about 3 

million involve radioactive material, 

most of which is low-level radioactive material. Fewer than 50 shipments contain spent nuclear fuel from 

NRC requires robust security measures when 

spent nuclear fuel or significant quantities of 

radioactive material are transported.

The NRC requires licensees and carriers involved 

in spent nuclear fuel shipments to follow approved 

routes.
18 Protecting People and the Environment

These enhancements include the 

following:

• preplanning, coordination, and 

advance notice of shipments

• additional monitoring of shipments

• verification of the trustworthiness 

of people with information about 

the shipments

The NRC also adjusted the security measures for shipments to 

reflect changes in the DHS National 

Terrorism Advisory System regarding 

the current threat level. During periods 

of heightened security, the NRC can 

issue specific advisories to enhance 

security. These advisories include 

suspending spent nuclear fuel shipments and requesting that licensees 

defer shipments of significant quantities of radioactive material.

Effective NRC regulation, licensee 

implementation of these regulations, 

and strong partnerships with a variety 

of Federal, State, Tribal, and local 

authorities have ensured effective 

security for the storage and transportation of nuclear and radiological materials across the country.

Design Basis Threat for 

Theft or Diversion2

The DBT for theft or diversion 

describes the adversary force that 

Category I3 fuel cycle facilities must 

defend against. Additionally, these facilities must defend against the DBT for 

radiological sabotage, as discussed on 

page 8. Similar to the DBT for radiological sabotage, the DBT for theft or 

diversion is based on realistic assessments of the tactics, techniques, and 

procedures used by international and 

domestic terrorist groups and organizations. The NRC also relies on the intelligence community, law enforcement 

agencies, and State and local governments to provide accurate and timely 

information about the capabilities and 

activities of adversary groups.

Following September 11, 2001, the 

NRC thoroughly reviewed both DBTs 

to ensure that Category I fuel cycle 

facilities continued to have effective 

security measures in place that account 

for the evolving threat environment. 

The NRC issued orders that upgraded 

the DBTs as a result of this review. 

These orders were later incorporated 

in a revised DBT rule. The rule reflects 

insights gained from the latest threat 

information and includes a cyber threat 

component. 

Security barriers provide one of the many layers of 

physical protection.

2 Theft or diversion of formula quantities of strategic special nuclear material is a determined violent external assault, attack by stealth, or deceptive actions, 

including diversionary actions, by an adversary force capable of operating in each of the following modes: a single group attacking through one entry point, 

multiple groups attacking through one or more groups and one or individuals attacking through multiple entry points, or individuals attacking through 

separate entry points, with attributes, assistance and equipment as described in Title 10 of the Code of Federal Regulations (10 CFR) Part 73 “Physical 

Protection of Plants and Materials.”

3 Fuel cycle facilities that possess more than 5,000 grams (about 11 pounds) of strategic special nuclear material (defined as a “formula quantity”) or more 

as computed by the formula, grams = (grams contained U-235) + 2.5 (grams U-233 + grams plutonium) as further described in 10 CFR Part 73 “Physical 

Protection of Plants and Materials.”
U.S. Nuclear Regulatory Commission 19

The agency also considered, and as 

appropriate, incorporated the following 

12 factors identified in the Energy 

Policy Act of 2005:

1) The events of September 11, 2001

2) An assessment of physical, cyber, 

biochemical, and other terrorist 

threats

3) The potential for attack on facilities by multiple coordinated teams 

of a large number of individuals

4) The potential for assistance in 

an attack from several persons 

employed at the facility;

5) The potential for suicide attacks

6) The potential for water-based and 

air-based threats

7) The potential use of explosive 

devices of considerable size and 

other modern weaponry

8) The potential for attacks by 

persons with a sophisticated 

knowledge of facility operations

9) The potential for fires, especially 

fires of long duration

10) The potential for attacks on spent 

fuel shipments by multiple coordinated teams of a large number of 

individuals

11) The adequacy of planning to 

protect the public health and safety 

at and around nuclear facilities, 

as appropriate, in the event of a 

terrorist attack against a nuclear 

facility

12) The potential for theft or diversion of nuclear material from such 

facilities

The NRC regularly reviews the DBTs 

against the current threat intelligence, 

both domestic and international, to 

determine whether any changes are 

warranted. Specific characteristics of 

the DBTs are not publicly available 

in order to protect sensitive security 

information that could potentially aid 

an adversary. 

Security Core Inspections

The NRC’s security core inspection program is the primary way in 

which the agency ensures the physical 

protection of fuel cycle facilities and 

transport of certain nuclear material according to security regulations. 

Under the program, security experts 

(primarily from NRC Headquarters 

and the regional office in Atlanta) 

carry out security inspections. 

Vehicle barriers are part of the physical protection 

system used by some nuclear facilities. 

NRC licensees have measures that limit the exposure 

of security personnel to possible attack, including 

the incorporation of bullet-resisting protected positions that provide protection against the DBT.
20 Protecting People and the Environment

The experts provide firsthand, independent assessments of site conditions 

and performance, document their findings in writing, and conduct follow-up 

inspections to ensure that the licensee 

has made any necessary corrections.

Resident inspectors, in conjunction 

with inspectors from Headquarters and 

the Region, monitor licensees’ security-related activities on a daily basis 

throughout the year. Security core 

inspections may include the following 

inspectable areas:

• Access Authorization

• Access Control

• Contingency Response 

Force-on-Force

• Equipment Performance, Testing, 

and Maintenance

• Protective Strategy Evaluation

• Protection of Classified and 

Safeguards Information

• Security Training

• Fitness-for-Duty Program

• Cyber Security

• Target Area Review

• Transportation Security

The NRC’s overall evaluation of 

licensee performance considers 

the results of security inspections. 

However, if a significant security issue 

is found, the NRC requires the licensee 

to resolve the issue promptly. If necessary, the NRC can take enforcement 

action that includes civil penalties. 

Some information related to these 

inspections is available to the public 

via the NRC website. However, much 

of the information is not publicly 

available in order to protect sensitive 

security information that could potentially aid an adversary. 

Force-on-Force Security 

Inspections

Force-on-force security inspections are 

one of the components of the NRC’s 

security core inspection program at 

fuel cycle facilities. Force-on-force 

inspections assess the ability of these 

facilities to defend against the DBT for 

theft or diversion and provide valuable insights that enable the NRC to 

evaluate and improve the effectiveness 

of the security programs at Category 

I fuel cycle facilities. They are an 

essential part of the oversight of the 

security of these facilities. The fuel 

cycle facility force-on-force program 

uses the same processes and many of 

the same staff as performed at power 

reactors.

An NRC inspector gathers information at an NRC 

facility.
U.S. Nuclear Regulatory Commission 21

As with power reactor programs, full 

force-on-force inspection spans several 

weeks. It includes both tabletop drills 

and simulated combat between a 

mock adversary force and the nuclear 

facility’s security force. During the 

inspection, the mock adversary force 

attempts to reach Target Areas while 

battling the site’s security force. 

Target Areas require protection from 

malicious actions such as theft or 

diversion. For that reason, it is essential to protect these systems and 

components from being reached by the 

adversary force.

Along with the facility’s security 

personnel, many offsite organizations 

may participate in and observe forceon-force inspections. These organizations include Federal, State, and local 

law enforcement agencies. In addition, emergency planning officials, 

site operators, and NRC personnel are 

present.

By law, the NRC conducts a force-onforce inspection at least once every 3 

years. The NRC uses lessons learned 

from previous force-on-force inspections in making changes to its procedures and inspector training programs.

The force-on-force program ensures 

a high level of realism during the 

inspection, while ensuring the safety 

of site employees and the public. The 

force-on-force inspection involves two 

sets of the licensee’s security officers. 

One set maintains the site’s security, while the other set participates in 

the inspection. In addition, a separate group controls and monitors both 

inspection participants and on-duty 

security officers during the inspection. The NRC has overall control of 

the exercise and the NRC inspection 

team monitors all aspects of the exercise activities to ensure the safety of 

the participants and the conduct of the 

exercise in accordance with approved 

inspection standards. 

Two members of the adversary force simulate a 

breach of the Protected Area at a site during a 

training exercise.

In force-on-force inspections, the use of 

weapons and explosives can be simulated using 

electronic equipment.
22 Protecting People and the Environment

In preparation for a force-on-force 

inspection, participants compile information from tabletop drills, other 

inspections, and security plan reviews. 

This information is then used to design 

a number of mock attacks seeking to 

probe for potential deficiencies in the 

defensive strategy used at a specific 

site. Any potentially significant findings identified during a force-on-force 

inspection are promptly reviewed, 

addressed, and corrected before the 

NRC inspectors leave the site.

Active-duty U.S. Special Operations 

Forces advise the NRC inspection 

teams that conduct force-on-force 

inspections. These individuals participate in the inspections by helping the 

NRC inspectors develop the scenarios, 

providing expert technical advice 

to the mock adversary force, and 

assisting the NRC inspectors in evaluating site security forces and systems. 

It is important to emphasize that the 

NRC designs, runs, and evaluates the 

force-on-force inspections. The mock 

adversary force does not establish the 

inspection objectives, boundaries, or 

timelines.

CYBER SECURITY

Establishing and maintaining effective 

cyber security is a growing challenge 

across the Nation. New domestic and 

international adversaries are emerging, 

as are new tools that these adversaries 

can use to exploit potentially vulnerable systems and their supply chains. 

Historically, digital computer systems 

played a limited role in the operation of nuclear facilities. However, 

digital systems are increasingly being 

used to help maximize plant productivity. Computer systems that monitor 

and control operating nuclear reactors’ safety systems and that help 

the plants operate are isolated from 

external communications, including 

the Internet, to protect against outside 

intrusion. The NRC is working with its 

Federal partners to address the complicated issue of cyber security.

Following September 11, 2001, the 

NRC issued a series of advisories 

and orders requiring nuclear facilities to take certain actions, including 

enhancing the protection of their 
U.S. Nuclear Regulatory Commission 23

computer systems. Since that time, 

the NRC has replaced those interim 

measures with comprehensive regulations for operating power reactors 

and added a cyber security threat 

component to both DBTs. Systems 

covered by the regulations include 

systems associated with those related 

to safety, important to safety, security, 

and emergency preparedness functions, and those support systems and 

equipment that, if compromised, could 

adversely impact safety, important 

to safety, security, and emergency 

preparedness functions. The NRC 

also published regulatory guidance for 

cyber security that provides an acceptable approach for protecting digital 

computers, communications systems, 

and networks from a cyber attack. All 

operating power reactor licensees have 

developed cyber security plans that 

the NRC has reviewed and approved. 

The NRC is conducting inspections 

to ensure that operating power reactor 

licensees are implementing cyber 

security requirements. 

Recent high-profile cyber attacks on 

critical infrastructure sectors underscore the importance of evaluating 

cyber security requirements for all 

classes of NRC licensees. The experience with operating power reactors 

has helped the agency develop new 

requirements promptly and effectively. In 2012, the NRC developed 

and issued a cyber security paper that 

communicates the staff’s approach, 

or roadmap, to evaluate the need for 

cyber security requirements for fuel 

cycle facilities, NPRs, ISFSIs, and 

byproduct materials licensees. The 

implementation of this roadmap will 

ensure that appropriate levels of cyber 

security actions are implemented in 

a timely and efficient manner at all 

NRC-licensed facilities and will identify whether any program improvements are needed. 

In addition, the agency established a 

new internal organizational component, the Cyber Security Directorate 

(CSD), in 2013 that plans, coordinates, 

and manages agency-wide activities related to cyber security for NRC 

licensees. The CSD is responsible 

for rulemaking, guidance, licensing, 

policy issues, and oversight related to 

cyber security requirements. Within 

the CSD is a cyber assessment team 

that assesses real world cyber events 

at NRC-licensed facilities. The team 

evaluates whether an identified threat 

could impact licensed facilities and 

makes recommendations for NRC 

actions and communications to the 

licensees.
24 Protecting People and the Environment

Emergency Preparedness

For over 35 years, the NRC has 

provided regulatory oversight for 

emergency planning and incident 

response for all of its licensees. 

Commercial nuclear power plants are 

required to conduct a full scale exercise involving Federal, State, Tribal, 

and local agencies at least once every 

2 years. The NRC and the Federal 

Emergency Management Agency 

(FEMA) evaluate these exercises to 

verify that emergency preparedness 

programs and the skills of the emergency responders remain effective and 

identify any weaknesses. The NRC 

assesses the onsite response, whereas 

FEMA assesses the offsite response. In 

the years between evaluated exercises, 

licensees conduct various drills to test 

key functions and maintain emergency 

responder skills.

NUCLEAR PREPAREDNESS AND 

RESPONSE 

Before 2001, only a few emergency 

preparedness exercises simulated 

hostile actions against a nuclear 

power plant as their full-scale exercise. A hostile action is an act that uses 

violent force in an attempt to destroy 

equipment, take hostages, or intimidate the licensee to achieve an end. 

Even though the potential radiological consequences would be the same 

whether caused by a hostile action or 

a safety event, hostile actions would 

likely pose unique challenges to emergency responders. Therefore, the NRC 

updated its regulations to require each 

site to conduct an evaluated hostile 

action-based (HAB) drill at least once 

every 8 years. 

A team of NRC officials views a steel plate-covered spent fuel pool at the 

Fukushima Daiichi complex in Japan. Courtesy of TEPCO.
U.S. Nuclear Regulatory Commission 25

With respect to HAB exercises, the 

NRC requires nuclear power plant 

licensees to:

• identify alternate emergency 

response facilities located offsite 

to support the mobilization and 

staging of licensee emergency 

response organization personnel

• notify the NRC promptly for 

identified potential or actual 

hostile actions against the nuclear 

power plant site

• develop specific hostile actionbased emergency action levels for 

the classification of emergencies

• establish new protective action 

strategies for onsite personnel 

in the event of a hostile action 

against the nuclear power plant 

site

These measures are tested through 

drills and exercises, and are continually verified by NRC inspectors.

The NRC has also conducted a formal 

review of each licensee’s emergency 

preparedness planning basis to verify 

that it will adequately protect public 

health and safety in light of the current 

threat environment. The review 

concluded that emergency preparedness at nuclear power plants remains 

strong, but could be improved in such 

areas as communications, resource 

management, drill programs, and NRC 

guidance. 

Many of these considerations and 

improvements have been incorporated as enhancements to emergency 

preparedness regulations.

Incident Response

The NRC responds to incidents associated with all of its licensed facilities 

and activities. In addition, the NRC 

regularly provides support to other 

Federal, State, and local response 

agencies during major events such as 

hurricanes, floods, and wildfires. The 

NRC coordinates its response actions 

with other agencies through the use 

of NRC guidance and in a manner 

consistent with the National Response 

Framework (NRF).

Headquarters Operations 

Center

The NRC directs its response to events 

from the Headquarters Operations 

Center (HOC). The operations center 

is staffed 24 hours a day, 7 days a 

week, with 2 Headquarters Operations 

Officers who have the experience and 

knowledge to evaluate and respond 

Chairman Allison M. Macfarlane discusses 

possible response measures with the members 

of the Executive Team during an Emergency 

Preparedness exercise.
26 Protecting People and the Environment

properly to reported events. Their 

actions may include: informing NRC 

management; informing the agency’s 

Federal partners, licensees, and the 

media; and potentially staffing the 

HOC at the necessary level based on 

the direction of senior management. 

Recently the HOC was upgraded to 

a new facility with advanced technology and improved equipment, 

which enhances the ability of the 

NRC to respond to events, including 

circumstances involving multiple 

facilities. NRC response capability is 

also improved through the continual 

training of qualified responders, 

training and qualification of new 

staff, and continuous reviews of policies, processes, and procedures of the 

response organization. 

An alternate incident response center 

exists to continue the work of the 

HOC in case the Headquarters facility 

is not available. Each of the NRC’s 

four regional offices also has an incident response center, all of which have 

been recently upgraded to allow seamless transition of response duties in the 

event that any of the other response 

centers become unavailable.

Continuity of Operations

The NRC Continuity of Operations 

(COOP) plan ensures that the agency 

can continue to operate after a major 

event that disrupts normal operations. 

In recent years, the NRC has upgraded 

and tested its COOP capabilities and 

has participated in annual nationallevel COOP exercises. The NRC exercises its COOP capabilities to prepare 

for incidents that could disrupt normal 

operations. In addition, the COOP 

plan addresses agency functions in 

the event of a pandemic. The NRC’s 

COOP plan is regularly reviewed and 

updated based on the lessons learned 

during exercises and real-world 

events.

Interagency Response

The NRC coordinates its activities with other Federal agencies to 

improve its response to both nuclear 

safety and security emergencies. Using 

the NRF, the NRC works with local, 

Tribal, State, and Federal agencies in 

both the prevention of and response 

to a nuclear safety or a hostile action 

event. The NRC has a proven history 

of providing resources to its partners 

during exercises and actual events 

and will continue to work with other 

Federal agencies to implement the 

NRF.

Staff at the NRC’s Headquarters Operations 

Center monitor simulated plant conditions during 

an Emergency Preparedness exercise with a 

nuclear power plant.
U.S. Nuclear Regulatory Commission 27

The National Infrastructure Protection 

Plan (NIPP), issued by DHS, also 

provides a framework for coordination and information sharing among 

Federal agencies, State and local 

governments, and private sector critical infrastructure protection stakeholders. The NIPP framework also 

facilitates a coordinated response 

to threats and events affecting the 

Nation’s critical infrastructure by 

establishing roles and responsibilities of Federal, State, local, Tribal, 

and private sector critical infrastructure partners. Furthermore, the NIPP 

sets national priorities and goals for 

the effective distribution of funding 

and resources to help enhance the 

resilience of the U.S. Government, 

economy, and public services in 

the event of natural or man-made 

disasters.

The NRC actively supports FEMA’s 

National Exercise Program. This 

program serves as the principal exercise mechanism for examining the 

preparedness and measuring the readiness of the United States by testing the 

Nation’s ability to perform missions or 

functions that prevent, protect against, 

respond to, recover from, and mitigate 

all hazards. Thus, scenarios can be 

used that potentially involve simulated 

weapons of mass destruction, major 

storms, or terrorist attacks. 

Participating in these exercises 

provides the NRC with valuable feedback to enhance its own response 

program.

Another example of interagency 

coordination is the DHS-led 

Comprehensive Review Program of 

commercial nuclear reactors and associated spent nuclear fuel storage facilities. This review identified strengths 

and potential areas for improvement in 

the Nation’s critical infrastructure and 

key resources. The NRC continues to 

work with industry and DHS to ensure 

that progress is made in addressing 

any notable improvement areas.

Effective preparedness and response requires 

cooperation among the Federal Government, 

State, and local officials, the public, and the NRC 

licensees.
28 Protecting People and the Environment

Communications

An important part of protecting 

nuclear facilities from acts of terrorism 

is effective communication among 

the NRC, NRC-licensed facilities and 

certificate holders, and Federal, State, 

Tribal, Territorial, and local governments. The NRC continues to enhance 

its communications with upgrades, 

including a protected web-based 

computer server system to exchange 

sensitive security information quickly 

with licensees and authorized government officials. Using secure transmission equipment, the NRC can rapidly 

communicate classified and sensitive 

unclassified information among NRC 

Headquarters, regional offices, and 

licensees.

The NRC works with a variety of partners to fulfill its mission and maintains close working relationships with 

Congress and State officials. The NRC 

regularly communicates with Federal 

partners about policy and programs 

including the following:

• U.S. Department of Defense 

• U.S. Department of Energy 

(DOE)

• DOE National Nuclear Security 

Administration

• U.S. Department of Homeland 

Security (DHS)

• DHS Federal Emergency 

Management Agency (FEMA)

ADDITIONAL SECURITY ACTIVITIES

• DHS Transportation Security 

Administration

• DHS Domestic Nuclear Detection 

Office

• U.S. Department of State

• U.S. Department of 

Transportation

• Federal Aviation Administration

• Federal Bureau of Investigation 

(FBI)

• National Security Council

• North American Aerospace 

Defense Command (NORAD)

• U.S. Northern Command

• Office of the Director of National 

Intelligence 

• National Counterterrorism Center

• Other members of the Intelligence 

Community

NRC staff speak at a public meeting on security 

requirements at NRC-regulated facilities.
U.S. Nuclear Regulatory Commission 29

In addition, the NRC communicates 

directly with other Federal agencies 

about specific threats. For example, 

NORAD contacts the NRC directory 

to share information about potential 

aircraft threats against NRC regulated 

nuclear facilities. This communication and coordination lays the foundation for ongoing national efforts to 

detect, prevent, and respond to terrorist 

attacks. 

The NRC continues to explore areas 

in which sharing information will 

result in a better-informed and betterprepared Nation. However, the agency 

must prevent unauthorized individuals 

or those without a need-to-know from 

gaining access to sensitive information that might compromise security at 

NRC regulated facilities. As a result, 

the NRC must balance its commitment 

to openness with the need to prevent 

the release of sensitive information. 

Information Security

The NRC’s information security 

program protects classified Restricted 

Data (RD) and National Security 

Information (NSI), SGI, and other 

sensitive information from unauthorized disclosure. Only those with the 

appropriate security clearance and a 

need-to-know can view such information. The NRC requires security clearances for appropriate individuals at 

NRC regulated facilities. These clearances provide licensees with access 

to sensitive information. The NRC, 

in coordination with DOE, has also 

developed comprehensive classification guides to protect sensitive nuclear 

technologies. This ensures that guidance on how to classify different types 

of information is applied consistently 

and is well understood.

The NRC has a long history of 

promoting openness and transparency 

in its regulatory and decision-making 

processes and is dedicated to appropriately sharing information among 

organizations and licensees to enhance 

prevention and response activities to 

terrorist and other security incidents. 

However, the NRC remains diligent 

in controlling sensitive information 

to prevent unauthorized access to 

the information by terrorists or other 

adversaries. Consequently, the NRC 

continues to balance its commitment 

to openness with the public with the 

need to prevent unauthorized releases 

of sensitive information.

Intelligence

The NRC’s intelligence staff assesses 

threats by reviewing and analyzing 

intelligence information and routinely 

communicating with intelligence and 

law enforcement agencies. 
30 Protecting People and the Environment

The intelligence staff constantly monitors the domestic and overseas threat 

environments for credible threats to 

NRC licensees. The NRC staff also 

serves as a liaison and coordinator 

with other organizations and Federal 

agencies. The NRC ensures that its 

licensees, its Agreement States, and 

Federal, State, and local authorities 

promptly receive notification of any 

imminent threat or security incident. 

In addition, the staff annually reviews 

and briefs the Commission on the 

current threat environment and any 

recommended changes to the DBTs 

based on the evolving characteristics 

of potential adversaries. 

The central mission of the NRC’s 

intelligence staff is to evaluate and 

warn of possible threats against NRC 

or Agreement State licensees. Since 

the 1970s, the NRC has assessed and, 

in some cases, investigated a variety 

of threats to licensed nuclear facilities and radioactive materials. These 

threat assessments provide indications 

and warnings of potential attacks or 

other malevolent activities directed 

at nuclear facilities or radioactive 

materials licensees. The intelligence 

staff assesses threats by reviewing 

thousands of pieces of classified and 

unclassified message traffic, evaluating 

intelligence products, and routinely 

communicating with other intelligence 

and law enforcement agencies.

In the event of an actual threat, the 

NRC’s intelligence staff forms the 

core of an interdisciplinary team that 

assesses the credibility of a communicated threat and, working with NRC 

physical security counterparts, recommends protective actions to licensees. 

The NRC’s intelligence staff also has 

a duty officer who is on call 24 hours a 

day, 7 days a week, to respond to security events and suspicious incidents at 

NRC-licensed facilities.

To assess and share threat information rapidly, the NRC developed the 

Information Assessment Team (IAT) 

process. If the NRC receives information about a possible threat to one 

of its licensees, it may issue an IAT 

advisory informing the site. IAT 

advisories are nonpublic communications from the NRC to licensees that 

provide information on changes to the 

threat environment. Another category of advisory, known as a Security 

Advisory, communicates time sensitive information to help defend against 

threats directed at NRC-licensed 

facilities. 
U.S. Nuclear Regulatory Commission 31

Additional interactions involving the 

intelligence community, DOE, and the 

IAEA, among others, are conducted in 

order to keep up-to-date on the latest 

significant changes to safety and security information. Based on these interactions and information assessments, 

the NRC informs licensees of changes 

to the safety environment and threat 

landscape and interacts with nuclear 

facilities to improve safety and security accordingly. 

Security Programs To 

Ensure Trustworthiness 

and Reliability

Access Authorization 

Programs 

The NRC requires licensees to control 

personnel access to nuclear facilities. 

Before new employees or contractor 

employees are allowed unescorted 

access to the areas containing nuclear 

and radiological materials they must 

pass several evaluations and background checks to determine if they are 

trustworthy and reliable. These evaluations may include drug and alcohol 

screening, psychological evaluations, prior employment history, and 

an assessment of education, criminal 

background (through the FBI), and 

credit histories.

The NRC continually examines the 

elements of the access authorization programs. The access authorization requirements employ a 

graded approach and may include the 

following depending on the type of 

nuclear facility :

• additional investigation of individuals who have electronic 

(cyber) means to adversely 

impact facility safety, security, or 

emergency preparedness

• enhanced psychological 

assessments

• increased information sharing 

among licensees

• expanded behavioral observation

• reinvestigations of criminal and 

credit history records for all individuals with unescorted access

• self-reporting of legal actions 

by individuals with unescorted 

access

• a 5-year psychological reassessment and a 3-year background 

reinvestigation for certain critical 

job functions

NRC requires fingerprinting for persons with 

unescorted access to sensitive areas of facilities 

and information.
32 Protecting People and the Environment

The NRC requires licensees to impose 

work-hour limits on certain workers 

and to develop procedures to evaluate their fatigue. The NRC fatigue 

management requirements, published 

in 2008, limit the work hours of 

personnel at certain nuclear facilities. The regulations also require a 

process for persons to report if they are 

fatigued and prevent licensees from 

retaliating against those individuals 

who self-report fatigue. Licensees are 

also required to conduct a documented 

fatigue assessment if, among other 

things, individuals report that they are 

unfit for work because of fatigue or if 

workers are observed to be inattentive. 

Behavioral Observation 

Program

The NRC requires certain nuclear 

facilities to implement a behavioral 

observation program. This program 

is conducted by personnel within a 

facility who are trained specifically 

on behavioral observation techniques. 

The program looks for individual 

behavioral changes that could indicate 

that a person might act in a manner 

detrimental to public safety if unmonitored or left unaddressed. Employees 

are offered counseling if they have 

job performance problems or exhibit 

unusual behavior. Similarly, anyone 

who appears to be under the influence of drugs or alcohol is immediately removed from the work area for 

evaluation under the licensee’s FFD 

program.

Fitness-for-Duty Program

NRC requires licensees that operate 

certain nuclear facilities to have a 

fitness-for-duty (FFD) program. 

The FFD programs provide reasonable assurance that nuclear facility 

personnel are trustworthy, safe, and 

will perform their tasks in a reliable 

manner. This prohibits employees 

from working while under the influence of any substance, legal or 

illegal, that may impair their ability 

to perform their duties, and ensures 

that they are not mentally or physically impaired to a degree that would 

adversely affect their ability to safely 

and competently perform their duties. 

The NRC requires licensees to conduct 

random drug and alcohol testing of 

their employees to detect and deter 

substance abuse. At least 50 percent 

of the individuals subject to testing are 

required to be tested annually. The 

NRC requires licensees to have procedures to ensure the integrity of the 

testing process. 

NRC requires drug and alcohol testing of personnel 

who perform safety-sensitive and security-sensitive 

work at nuclear power plants and Category I fuel 

cycle facilities. 
U.S. Nuclear Regulatory Commission 33

Many licensees use biometrics as part of their 

access requirements.

Insider Mitigation Program

The insider mitigation program 

contains elements of the access 

authorization, FFD, and behavioral observation programs at certain 

nuclear facilities. The insider mitigation program helps ensure that those 

who have unescorted access within a 

nuclear facility do not pose a potential insider threat. An insider threat is a 

person who could use the knowledge 

or access gained by his or her job at 

a nuclear facility to cause damage or 

sabotage or potentially aid an adversary. These programs are essential to 

the overall security of certain nuclear 

facilities.

International Safety and 

Security 

In 2003, the NRC staff joined with 

international and domestic partners to 

discuss with manufacturers of radioactive sources and devices possible ways 

to make high-risk radioactive sources 

more secure and less vulnerable to use 

by persons with malicious intent. The 

NRC also met with manufacturers to 

discuss improved methods for use in 

verifying the legitimacy of purchases 

of radioactive sources to ensure that 

these sources are only given to authorized users. Discussions also addressed 

concerns for ensuring the safe return 

and disposal of spent radioactive 

sources. 

The U.S. Government made a commitment to implement the IAEA Code of 

Conduct for the Safety and Security of 

Radioactive Sources (the Code) and 

its associated Guidance on Import and 

Export (the Guidance). In line with 

the commitments, the NRC considered the provisions of this Code and 

Guidance in its domestic regulations 

governing use, transfer, and tracking 

of the 16 radionuclides of concern. 

These particular radionuclides of 

concern are at the highest risk of use 

by a terrorist. Strong international 

support for the provisions in the Code 

and the Guidance is highlighted by 

the 115 countries that have agreed to 

implement the Code and 79 that have 

agreed to implement the Guidance (as 

of January 2013).

In 2005 and 2010, the NRC implemented rules with enhanced controls 

over the import and export of radioactive sources. Under the amendments, 

licensees must apply for specific 

licenses to export certain radioactive 

sources listed in Title 10 of the Code 

of Federal Regulations (10 CFR) Part 

110, “Export and Import of Nuclear 
34 Protecting People and the Environment

Equipment and Material,” Appendix 

P, “Category 1 and 2 Radioactive 

Material,” which includes the highrisk radioactive sources contained in 

the Code. Licensees are also required 

to document that the end user is authorized to receive and possess the material and must provide prior notice of 

shipments. For the export of highrisk sources, the NRC assesses and 

makes a determination on whether 

the importing country’s regulatory 

infrastructure is sufficient to maintain adequate control over the material. In countries without adequate 

regulatory controls, the Code provides 

for “exceptional circumstances” 

under which high risk sources can be 

exported with additional conditions 

imposed on the licensee.

The NRC regulations in part 110 also 

address criteria for physical security measures. NRC regulations in 

10 CFR Part 110 state that physical 

security measures in recipient countries must provide protection at least 

comparable to the recommendations in 

the current version of IAEA publication INFCIRC/225, ‘‘The Physical 

Protection of Nuclear Material and 

Nuclear Facilities.’’ 

To support the reviews and to 

exchange information on best security practices, NRC staff participates 

in U.S. interagency bilateral physical 

protection visits to foreign countries 

possessing special nuclear materials carrying U.S. obligations. The 

NRC also hosts meetings and tours 

to demonstrate U.S. physical protection practices. Additionally, the NRC, 

in partnership with other U.S. agencies, works to strengthen the international physical protection framework 

by providing technical expert support 

to the IAEA and by supporting U.S. 

policy initiatives to secure nuclear 

materials worldwide.

The NRC continues to support the 

development of international standards 

for implementing the recommendations of the IAEA Code of Conduct 

for the import and export of radioactive sources. This guidance is intended 

to balance the needs of international 

cooperation and commerce without 

affecting safety and security.

Chairman Allison M. Macfarlane speaks at the 

International Atomic Energy Agency.
U.S. Nuclear Regulatory Commission 35

CONCLUSION

Protecting the Nation’s nuclear facilities and materials is a top priority of the NRC. 

The NRC works aggressively to protect the public health and safety, promote 

the common defense and security, and protect the environment by regulating the 

commercial nuclear industry. Working closely with its partners, the NRC will 

continue to remain vigilant and provide oversight of security and emergency 

preparedness activities at nuclear facilities.

NRC Chairman Allison M. Macfarlane and her Commission colleagues are routinely briefed by agency staff.
36 Protecting People and the Environment

GLOSSARY

Agreement State

A State that has signed an agreement with the U.S. NRC under which the State 

regulates the use of byproduct, source, and small quantities of special nuclear material in that State.

Category I Fuel Cycle Facilities

Fuel cycle facilities that possess more than 5,000 grams (about 11 pounds) of 

strategic special nuclear material (defined as a “formula quantity”) or more as 

computed by the formula, grams = (grams contained U-235) + 2.5 (grams U-233 + 

grams plutonium). 

Classified Information

The two primary types of classified information at the NRC and NRC-regulated 

facilities are: 

1. National Security Information (NSI): Information classified by an Executive 

Order, whose compromise would cause some degree of damage to national 

security.

2. Restricted Data (RD): Information classified by the Atomic Energy Act of 

1954, as amended, whose compromise would assist in the design, manufacture, or use of nuclear weapons.

The lowest level of classified information is Confidential; the next higher is Secret, 

and the highest is Top Secret. Confidential, Secret, and Top Secret information will 

also be either NSI or RD. Access to classified information requires a need-to-know 

and a personnel security clearance equal to or higher than the level of information.

Depleted Uranium

Source material uranium in which the isotope uranium-235 is less than 0.711 

weight percent of the total uranium present. Depleted uranium does not include 

special nuclear material.

Design Basis Threat

A profile of the type, composition, and capabilities of a possible adversary. The 

NRC and certain licensees use the DBT as a basis for designing safeguards systems 

to protect against acts of radiological sabotage and to prevent the theft of special 

nuclear material. This term is applied to clearly identify for a licensee the expected 

capability of its facility to withstand a threat.
U.S. Nuclear Regulatory Commission 37

Emergency Preparedness

Action taken to be ready for emergencies before they happen. The objective of 

emergency preparedness is to simplify decision-making during emergencies. The 

emergency preparedness process incorporates the means to rapidly identify, evaluate, categorize, and react to a wide spectrum of emergency conditions.

Hostile Action

An act toward a nuclear power plant or radioactive material facility or its personnel 

that includes the use of force to destroy equipment, take hostages, or intimidate 

the licensee to achieve an end. This covers an attack by air, land, or water that uses 

guns, explosives, projectiles, vehicles, or other devices to deliver destructive force. 

Other acts that satisfy the overall intent may be incorporated.

Licensed Material

Source material, special nuclear material, or byproduct material received, 

possessed, used, transferred, or disposed of under a general or specific license 

issued by the NRC.

Licensee

An entity or individual authorized by the NRC to conduct the following activities:

• constructing, operating, and decommissioning commercial reactors and fuel 

cycle facilities

• possessing, using, processing, exporting, importing, and certain aspects of 

transporting nuclear materials and waste

• siting, designing, constructing, operating, and closing waste disposal sites

Nonpower Reactor

Nuclear reactors primarily used for research, training, and development. Formerly 

referred to as research and test reactors.

NRC Headquarters Operations Center

The NRC HOC is located in Rockville, MD, and serves as the focal coordination 

point for communicating with NRC licensees, State agencies, and other Federal 

agencies about operating events in both the nuclear reactor and nuclear materials 

industry. Headquarters operations officers, who are trained to receive, evaluate, and 

respond to reported events, staff the HOC 24 hours a day, 7 days a week.
38 Protecting People and the Environment

Nuclear Energy

The energy liberated by a nuclear reaction (fission or fusion) or by radioactive 

decay.

Nuclear Power Plant

An electrical generating facility that uses a nuclear reactor as its heat source to 

provide steam to a turbine generator.

Nuclear Waste

A particular type of radioactive waste that is produced as part of the nuclear fuel 

cycle (i.e., those activities needed to produce nuclear fission or the splitting of the 

atom). These activities include the extraction of uranium from ore, the concentration of the extracted uranium, the processing of the concentrated uranium into 

nuclear fuel, and the disposal of byproducts. “Radioactive waste” is a broader 

term that includes all waste that contains radioactivity. Residues from water treatment, contaminated equipment from oil drilling, and tailings from the processing 

of metals such as vanadium and copper also contain radioactivity but are not 

“nuclear waste” because they are produced outside of the nuclear fuel cycle. The 

NRC generally regulates only those wastes produced in the nuclear fuel cycle (e.g., 

uranium mill tailings, depleted uranium, and spent fuel rods).

Radionuclide

An unstable isotope of an element that emits radiation as it decays or disintegrates 

spontaneously.

Safeguards

The use of material control and accounting programs, physical protection equipment, and security forces to verify that all special nuclear material is properly 

controlled and accounted for. As used by the IAEA, “safeguards” refers to verification that the “peaceful use” commitments made in binding nonproliferation agreements, both bilateral and multilateral, are honored.

Safeguards Information

A special category of sensitive unclassified information authorized to be protected 

under Section 147 of the Atomic Energy Act of 1954, as amended. SGI concerns 

the physical protection of operating power reactors, spent fuel shipments, strategic 

special nuclear material, or other radioactive material. 

While SGI is considered to be sensitive unclassified information, its handling and 

protection more closely resemble the handling of classified Confidential information rather than other sensitive unclassified information.
U.S. Nuclear Regulatory Commission 39

The categories of individuals who are permitted access to SGI are listed in 10 CFR 

73.21, “Protection of Safeguards Information: Performance Requirements,” 10 

CFR 73.22, “Protection of Safeguards Information: Specific Requirements,” and 10 

CFR 73.23, “Protection of Safeguards Information—Modified Handling: Specific 

Requirements.”

Sensitive Unclassified Nonsafeguards Information

Information that is generally not publicly available, encompassing a wide variety of 

categories (e.g., personnel privacy, attorney-client privilege, investigations information, confidential source).

Under 10 CFR 2.390, “Public Inspections, Exemptions, Requests for Withholding,” 

information about a licensee’s or applicant’s physical protection or material control 

and accounting program for special nuclear material not otherwise designated 

as SGI or classified as National Security Information or Restricted Data must be 

protected in the same manner as commercial or financial information. In other 

words, such information is exempt from public disclosure. Policy and procedures 

related to sensitive unclassified non-safeguards information are the responsibility of 

the NRC Office of Information Services.

Special Nuclear Material

Plutonium, uranium-233, or uranium enriched in the uranium-235 isotope.

Spent Fuel Pool

An underwater storage and cooling facility for spent (used) fuel elements that have 

been removed from a reactor.

Spent Nuclear Fuel

Fuel that has been withdrawn from a nuclear reactor following irradiation, has 

undergone at least one year’s decay since being used as a source of energy in a 

power reactor, and has not been chemically separated into its constituent elements 

by reprocessing. Spent fuel includes the special nuclear material, byproduct 

material, source material, and other radioactive materials associated with fuel 

assemblies.
40 Protecting People and the Environment

LIST OF ACRONYMS

CFR Code of Federal Regulations

COOP Continuity of Operations 

CSD Cyber Security Directorate

DBT Design Basis Threat

DHS U.S. Department of Homeland Security

DOE U.S. Department of Energy

FBI Federal Bureau of Investigations

FFD Fitness-for-Duty

FEMA Federal Emergency Management Agency

HAB Hostile Action-Based 

HOC Headquarters Operations Center

IAEA International Atomic Energy Agency

IAT Information Assessment Team

ISFSI Independent Spent Fuel Storage Installation

LVS License Verification System

NIPP National Infrastructure Protection Plan

NORAD North American Aerospace Defense Command

NPR Nonpower Reactor

NRC U.S. Nuclear Regulatory Commission

NRF National Response Framework

NSI National Security Information

NSTS National Source Tracking System

RD Restricted Data

SGI Safeguards Information

WBL Web-Based Licensing

NUREG/BR-0314, Rev. 3

October 2013