AUDIT REPORT 

Audit of NRC’s Process for Placing Documents 

in the ADAMS Public and Non-Public Libraries 

OIG-07-A-16 September 6, 2007 

All publicly available OIG reports (including this report) are accessible through 

NRC’s Web site at: 

http:/www.nrc.gov/reading-rm/doc-collections/insp-gen/ 
 September 6, 2007 

MEMORANDUM TO: Luis A. Reyes 

Executive Director for Operations 

FROM: Stephen D. Dingbaum /RA/ 

Assistant Inspector General for Audits 

SUBJECT: AUDIT OF NRC’S PROCESS FOR PLACING DOCUMENTS 

IN THE ADAMS PUBLIC AND NON-PUBLIC LIBRARIES 

(OIG-07-A-16) 

Attached is the Office of the Inspector General’s (OIG) audit report titled, Audit of NRC’s 

Process for Placing Documents in the ADAMS Public and Non-Public Libraries.

This report presents the results of the subject audit. Agency comments provided at the 

exit conference on June 1, 2007, have been incorporated, as appropriate, into this 

report. The agency provided formal comments, which appear in Appendix C of the 

report. 

Please provide information on actions taken or planned on each of the 

recommendations within 30 days of the date of this memorandum. Actions taken or 

planned are subject to OIG follow up as stated in Management Directive 6.1. 

We appreciate the cooperation extended to us by members of your staff during the 

audit. If you have any questions or comments about our report, please contact me at 

415-5915, or Beth Serepca, Team Leader, Security and Information Management 

Team, at 415-5911. 

Attachment: As stated 

cc: V. Ordaz, OEDO 

 M. Malloy, OEDO 

 P. Tressler, OEDO
Electronic Distribution

Frank P. Gillespie, Executive Director, Advisory Committee on Reactor 

 Safeguards/Advisory Committee on Nuclear Waste 

E. Roy Hawkens, Chief Administrative Judge, Atomic Safety and 

 Licensing Board Panel 

Karen D. Cyr, General Counsel 

John F. Cordes, Jr., Director, Office of Commission Appellate Adjudication 

William M. McCabe, Chief Financial Officer 

Margaret M. Doane, Acting, Director, Office of International Programs 

Rebecca L. Schmidt, Director, Office of Congressional Affairs 

Eliot B. Brenner, Director, Office of Public Affairs 

Annette Vietti-Cook, Secretary of the Commission 

William F. Kane, Deputy Executive Director for Reactor 

 and Preparedness Programs, OEDO 

Martin J. Virgilio, Deputy Executive Director for Materials, Waste, Research, 

 State, Tribal, and Compliance Programs, OEDO 

Darren B. Ash, Deputy Executive Director for Information Services 

 and Chief Information Officer, OEDO 

Vonna L. Ordaz, Assistant for Operations, OEDO 

Timothy F. Hagan, Director, Office of Administration 

Cynthia A. Carpenter, Director, Office of Enforcement 

Charles L. Miller, Director, Office of Federal and State Materials 

 and Environmental Management Programs 

Guy P. Caputo, Director, Office of Investigations 

Edward T. Baker, Director, Office of Information Services 

James F. McDermott, Director, Office of Human Resources 

R. William Borchardt, Director, Office of New Reactors 

Michael F. Weber, Director, Office of Nuclear Material Safety and Safeguards 

James E. Dyer, Director, Office of Nuclear Reactor Regulation 

Brian W. Sheron, Director, Office of Nuclear Regulatory Research 

Corenthis B. Kelley, Director, Office of Small Business and Civil Rights 

Roy P. Zimmerman, Director, Office of Nuclear Security and Incident Response 

Samuel J. Collins, Regional Administrator, Region I 

William D. Travers, Regional Administrator, Region II 

James L. Caldwell, Regional Administrator, Region III 

Bruce S. Mallett, Regional Administrator, Region IV 

 

 
Audit of NRC’s Process for Placing Documents in the ADAMS Public and Non-Public Libraries 

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EXECUTIVE SUMMARY 

BACKGROUND

The U.S. Nuclear Regulatory Commission (NRC) relies on an 

electronic recordkeeping system called the Agencywide Documents 

Access and Management System (ADAMS) to maintain its public 

and non-public official agency records. NRC staff decide whether 

official agency records should be publicly or non-publicly available 

based on agency criteria regarding document content. NRC 

historically has strived for openness with the public. Since the 

events of September 11, 2001, however, the agency has become 

more restrictive in what it makes available to the public. 

ADAMS has four libraries. Two libraries, the ADAMS Main Library 

and the Legacy Library, are accessible to NRC staff but not to the 

public. These libraries contain both public and non-public records. 

The other two libraries, the Publicly Available Records System and 

the Public Legacy Library, contain public records only. 

PURPOSE

The audit objective was to determine the effectiveness and 

consistency by which documents are profiled1 and processed for 

entry into the public or non-public ADAMS libraries. 

RESULTS IN BRIEF

NRC profiles most documents appropriately for inclusion in public 

versus non-public ADAMS libraries; however: 

 The rationale for public versus non-public placements is not 

always clearly articulated in the agency’s guidance, and 

documents are sometimes miscategorized. 

 NRC needs to improve its quality control approach to ensure 

proper profiling of ADAMS records as public or non-public. 

 

1

 Profile information is descriptive information about the record, such as document title, 

sensitivity, availability (public or non-public), document date, ADAMS accession number, and 

number of pages. 
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Rationale for Public Versus Non-Public Placements Is Not 

Always Clearly Articulated in Guidance

NRC profiles most ADAMS records appropriately as public or nonpublic. However, the Office of the Inspector General (OIG) found 

that agency guidance did not explain the basis for placing 

documents in the public or non-public libraries. The rationale for 

placing about 14 percent of the non-public documents and about 17 

percent of the public documents was not clearly articulated in the 

guidance, and OIG also identified several specific instances of 

miscategorized documents. This lack of clear rationale in the public 

versus non-public profiling process occurs because agency 

guidance on the subject is not consolidated and, in some cases, is 

outdated. Furthermore, NRC does not offer training on making 

public versus non-public determinations. As a result, NRC risks 

releasing sensitive information to the public, which can impact 

public safety. The agency also risks unnecessarily withholding 

non-sensitive information, which can undermine public confidence 

in NRC as a fair and unbiased regulator. 

Improved Quality Control Approach Is Needed To Ensure 

Proper Profiling of ADAMS Records 

NRC needs to improve its quality control approach to ensure proper 

profiling of ADAMS records as public or non-public. Specifically, (1) 

the agency does not conduct regular reviews of all documents 

placed in ADAMS to ensure proper placement in either the public or 

non-public ADAMS libraries; (2) document originators do not 

always complete NRC Form 665, an agency requirement; and (3) 

some offices – which have instructed the Office of Information 

Services (OIS) to intercept their incoming mail, determine 

availability, and add it to ADAMS – do not routinely review whether 

OIS has made the appropriate availability determination or follow 

up on items designated non-public pending review.2

 

These conditions exist because the agency does not require 

documentation explaining why ADAMS documents were 

designated as public versus non-public and has not clearly 

communicated quality control expectations to staff. As a result, 

NRC cannot assess if it is meeting its criteria for ADAMS document 

profiling and risks both inappropriate release of information to the 

public and unnecessary withholding of information that should be 

publicly available. 

 

2

 Non-public pending review is the category NRC uses to designate items as non-public until the 

responsible office reviews it and makes a final determination concerning public or non-public 

availability. 
Audit of NRC’s Process for Placing Documents in the ADAMS Public and Non-Public Libraries 

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RECOMMENDATIONS

This report makes eight recommendations to support the public 

versus non-public profiling process for ADAMS records. A 

consolidated list of recommendations appears in Section V of this 

report. 

AGENCY COMMENTS

At an exit conference held on June 1, 2007, agency managers 

provided comments concerning the draft report. We modified the 

report in response to the comments, as we deemed appropriate. 

NRC reviewed these modifications and opted to submit formal 

comments, which appear in Appendix C of this report. 
Audit of NRC’s Process for Placing Documents in the ADAMS Public and Non-Public Libraries 

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ABBREVIATIONS AND ACRONYMS

ADAMS Agencywide Documents Access and Management 

System 

E-RIDS Electronic Regulatory Information Distribution System 

MD Management Directive and Handbook 

NRC U.S. Nuclear Regulatory Commission 

OIG Office of the Inspector General (NRC) 

OIS Office of Information Services 

PII Personally Identifiable Information 

SUNSI Sensitive Unclassified Non-Safeguards Information 
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TABLE OF CONTENTS

EXECUTIVE SUMMARY.........................................................................i 

ABREVIATIONS AND ACRONYMS ......................................................v 

I. BACKGROUND .............................................................................1 

II. PURPOSE......................................................................................2 

III. FINDINGS......................................................................................3 

 A. RATIONALE FOR PUBLIC VERSUS NON-PUBLIC PLACEMENTS IS 

NOT ALWAYS CLEARLY ARTICULATED IN GUIDANCE ....................3 

 B. IMPROVED QUALITY CONTROL APPROACH IS NEEDED TO 

 ENSURE PROPER PROFILING OF ADAMS RECORDS .................10 

IV. AGENCY COMMENTS ................................................................16 

V. CONSOLIDATED LIST OF RECOMMENDATIONS ....................17 

APPENDIXES

A. SCOPE AND METHODOLOGY...................................................19 

B. FORMS 665S AND 665P.............................................................21 

C. AGENCY COMMENTS ................................................................23 
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I. BACKGROUND

NRC has relied, since April 2000, on an electronic recordkeeping 

system called ADAMS to maintain its public and non-public official 

agency records.3

 As of March 2007, ADAMS held about 821,000 

records. During the 6-month period from mid-September 2006 

through mid-March 2007, an average of 5,883 new records were 

added to ADAMS each month, and about 50 percent of these were 

made public. 4 

ADAMS holds records generated both externally and internally. 

The term externally generated records refers to materials that are 

developed outside of the agency and sent to NRC. These items 

include correspondence from licensees, the public, other Federal 

agencies, research laboratories, and foreign governments. 

Internally generated records are materials developed within NRC 

such as correspondence to licensees or to the public, policy 

papers, bulletins, and inspection reports. 

Public and Non-Public Records

NRC staff decide whether official agency records should be publicly 

or non-publicly available based on agency criteria regarding 

document content. NRC historically has strived for openness with 

the public. Since the events of September 11, 2001, however, the 

agency has become more restrictive in what it makes available to 

the public. Prior to September 11, the agency’s policy was to 

automatically make information publicly available that was 

anticipated to be of interest to the public without anyone having to 

file a Freedom of Information Act request. Following September 

11, the agency revised its standard for withholding information from 

the public to include information that “could reasonably be expected 

to be useful to terrorists in planning or executing an attack.” Now, 

 

3

 Official agency records are all books, papers, maps, photographs, and other documentary 

materials made or received by a Government agency in connection with the transaction of public 

business and preserved by that agency as evidence of the organization, functions, policies, 

decisions, procedures, operations, or other Government activities or because of the informational 

value of data they contain. 

4

 ADAMS does not hold records containing classified, safeguards, or allegations information, and 

does not hold most Office of Investigations or Office of the Inspector General records or records 

on personnel matters. (Safeguards information specifically identifies the detailed security 

measures of a licensee or an applicant for the physical protection of special nuclear material; or 

security measures for the physical protection and location of certain plant equipment vital to the 

safety of production or utilization facilities.) 
Audit of NRC’s Process for Placing Documents in the ADAMS Public and Non-Public Libraries 

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certain items that were once publicly available, such as information 

on plant configurations or conditions that could be useful to an 

adversary, are considered sensitive and are routinely designated as 

non-public. 

ADAMS has four libraries. Two libraries, the ADAMS Main Library 

and the Legacy Library, are accessible to NRC staff but not to the 

public. These libraries contain both public and non-public records. 

The other two libraries, the Publicly Available Records System and 

the Public Legacy Library, contain public records only. NRC staff 

can access all ADAMS libraries via the agency’s Intranet. 

Members of the public can access the public libraries via NRC’s 

Website using a standard Web browser, but cannot access the 

non-public libraries. 

OIS estimates it will spend $705,000 in FY 2007 to maintain and 

operate ADAMS, $730,000 to enhance the system, and $3 million 

for OIS activities related to processing documents into ADAMS 

records. There are currently 18 staff assigned to support system 

operations, enhancements, and program management and 2 staff 

working on the activities necessary to prepare a business case for 

replacing the current ADAMS system with new technology. 

II. PURPOSE 

The audit objective was to determine the effectiveness and 

consistency by which documents are profiled and processed for 

entry into the public or non-public ADAMS libraries. The audit was 

initiated in response to a letter sent to NRC’s Inspector General by 

a public interest group. The letter reported several specific 

instances of NRC miscoding documents as non-publicly available 

when the items should have been publicly available. Appendix A 

contains information on the audit scope and methodology. 
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III. FINDINGS 

NRC profiles most documents appropriately for inclusion in public 

versus non-public ADAMS libraries; however: 

 The rationale for public versus non-public placements is not 

always clearly articulated in the agency’s guidance, and 

documents are sometimes miscategorized. 

 NRC needs to improve its quality control approach to ensure 

proper profiling of ADAMS records as public or non-public. 

By consolidating agency guidance and improving agencywide 

quality control expectations, NRC will better assure that its records 

are designated public and non-public in accordance with agency 

guidance while protecting sensitive information from improper 

disclosure. 

A. Rationale for Public Versus Non-Public Placements Is Not Always 

Clearly Articulated in Guidance 

NRC profiles most ADAMS records appropriately as public or nonpublic. However, the Office of the Inspector General (OIG) found 

that agency guidance did not explain the basis for placing 

documents in the public or non-public libraries. The rationale for 

placing about 14 percent of the non-public documents and about 17 

percent of the public documents was not clearly articulated in the 

guidance, and OIG also identified several specific instances of 

miscategorized documents. This lack of clear rationale in the public 

versus non-public profiling process occurs because agency 

guidance on the subject is not consolidated and, in some cases, is 

outdated. Furthermore, NRC does not offer training on making 

public versus non-public determinations. As a result, NRC risks 

releasing sensitive information to the public, which can impact 

public safety. The agency also risks unnecessarily withholding 

non-sensitive information, which can undermine public confidence 

in NRC as a fair and unbiased regulator. 

Agency Guidance 

NRC guidance to staff on what agency information should be 

publicly and non-publicly available is contained in Management 

Directive and Handbook (MD) 3.4, Release of Information to the 

Public; Yellow Announcement 2005-077, Policy Revision: NRC 

Policy and Procedures for Handling, Marking, and Protecting 

Sensitive Unclassified Non-Safeguards Information (SUNSI); 

Yellow Announcement 2006-069, Protection of Personally 
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Identifiable Information; SECY-04-0191, Withholding Sensitive 

Unclassified Information Concerning Nuclear Power Reactors from 

Public Disclosure; and Attachment 2 to RIS 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. 

Last revised in December 1999, MD 3.4 states that it is NRC’s 

policy to make available to the public as much as possible of its 

health and safety mission-related information. MD 3.4 includes a 

53-page listing of office-specific products that should be routinely 

released to the public and several pages of materials that are not 

routinely released to the public. Products routinely released, 

according to MD 3.4, include inspection reports, correspondence 

related to license amendments, NRC bulletins and licensee 

responses, and Commission meeting transcripts. Products not 

routinely released, according to MD 3.4, include records sent to or 

received from foreign governments, correspondence with other 

Federal agencies, predecisional information, and routine 

administrative records. 

The agency’s SUNSI policy, issued in October 2005, focuses on 

seven categories of information that should not be released 

publicly. These categories are allegation information; investigation 

information; security-related information; proprietary information; 

Privacy Act information; Federal, State, Foreign Government, and 

International Agency Controlled Information; and sensitive internal 

information. SUNSI is defined as, “any information of which the 

loss, misuse, modification, or unauthorized access can reasonably 

be foreseen to harm the public interest, the commercial or financial 

interests of the entity or individual to whom the information pertains, 

the conduct of NRC and Federal programs, or the personal privacy 

of individuals.” 

NRC also directs employees to protect personally identifiable 

information from public release, in accordance with Office of 

Management and Budget guidance. According to Yellow 

Announcement 2006-069, personally identifiable information is 

information that can be used to identify or contact a person 

uniquely or can be traced back to a specific individual (i.e., a 

person’s name in combination with other information such as 

relatives’ names, postal address, home e-mail address, home or 
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cellular telephone number, social security number, date or place of 

birth, mother’s maiden name, driver’s license number, credit card 

information, or any information that would make the individual’s 

identity easily traceable). 

 

Inconsistencies and Miscategorizations Occur 

NRC profiles most ADAMS records appropriately as public or nonpublic; however, some inconsistencies and miscategorizations 

occur. 

Random Sample

Auditors randomly sampled 10 percent of the 6,5595 public and 

non-public official agency records added to ADAMS in 

December 2006 to assess whether their public or non-public 

designation was in accordance with agency guidance.6 This review 

found that the rationale for designating about 14 percent of the nonpublic documents and about 17 percent of the public documents as 

such was not clearly articulated in MD 3.4, SUNSI, or Personally 

Identifiable Information (PII) guidance. Auditors did not consider 

these items to be misplaced in either the public or non-public 

libraries, but instead focused on the absence of clear, criteriabased justification for making the documents publicly versus nonpublicly available. The non-public placements were questioned by 

auditors because (1) similar items were available in public ADAMS, 

(2) the items were addressed to a public interest group, or (3) the 

item corresponded to an MD 3.4 category, suggesting it ought to be 

public. The public placements were questioned in most cases 

because (1) MD 3.4 did not mention the product type reviewed or 

(2) the submitting office was not listed in MD 3.4. 

Examples of questionable non-public placements included an NRC 

letter to a Michigan public interest group which included the 

handwritten notation, “public,” at the bottom or the page, nonsensitive inspection reports, and a county’s emergency response 

plan, which the county considers public information. Examples of 

questionable public placements included materials corresponding 

to parts of the Code of Federal Regulations that are not listed in MD 

3.4, such as correspondence related to license renewal or early site 

applications, information concerning a licensee’s credit report, and 

 

5

 The 6,559 figure includes both new records added to ADAMS and old “retrofit” records that 

predate ADAMS and which NRC has recently approved for scanning and inclusion in ADAMS. 

6

 To conduct the review, auditors located the sampled documents in ADAMS, examined the 

content, and attempted to find criteria within MD 3.4, SUNSI, and PII guidance that would justify 

its placement in public or non-public ADAMS. 
Audit of NRC’s Process for Placing Documents in the ADAMS Public and Non-Public Libraries 

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instrument calibration records for thermometers and gauges. 

Auditors did not perceive any risk associated with these public 

placements, but noted that the agency’s criteria for making public 

placements did not explain why these placements would be proper. 

Non-Random Examples

Auditors also learned of specific documents incorrectly profiled for 

public or non-public availability in ADAMS. In August 2006, a 

public interest group contacted OIG to relay two specific examples 

of documents miscoded as non-publicly available in ADAMS when 

they should have been publicly available. The representative said 

that this has happened before and that whenever it does, he 

contacts NRC to ask for a correction. In his experience, the agency 

always reviews and corrects the matter promptly; however, the 

errors caused him to question how many other documents are 

miscoded but not caught. 

Auditors also identified examples of document types that were 

treated inconsistently in terms of the public or non-public 

designation. These included safety inspection reports, staff trip 

reports, and delegations of authority. Auditors could not determine 

any difference between these items that would justify this different 

treatment in terms of availability. 

Another example of inconsistent treatment pertains to emergency 

preparedness exercise materials, which are sometimes placed into 

non-public ADAMS and sometimes not placed into ADAMS at all, 

depending on how the licensee submits them to NRC. In January 

2007, a power plant licensee mailed information it deemed 

sensitive concerning an upcoming emergency preparedness 

exercise to NRC in accordance with agency requirements. The 

licensee requested that the document be non-public and, 

furthermore, that it not be provided to NRC exercise participants 

until after the exercise, which was to occur in April. This precaution 

was intended to enhance the integrity of the emergency 

preparedness exercise. While the letter was placed in non-public 

ADAMS in accordance with the licensee’s request, it was also 

made available to all NRC staff without restriction, including those 

who would be exercise participants. 

An NRC emergency preparedness inspector acknowledged that the 

agency is inconsistent in handling emergency preparedness 

exercise information submitted by licensees. He said that when a 

licensee provides this information in hard copy to an emergency 

preparedness inspector, it will not be placed in ADAMS at all, but 
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that when the licensee mails it to headquarters, it is placed in 

ADAMS. The inspector said that he and other inspectors have 

sought instruction from headquarters on how to handle emergency 

preparedness exercise materials, but it was never provided. 

Guidance and Training Are Needed 

Inconsistent and incorrect public and non-public designations are 

made because NRC has not provided consolidated, up-to-date 

guidance to staff on what items should be public or non-public and 

NRC does not offer training on the public versus non-public 

decisionmaking process. 

Outdated Guidance

NRC guidance on making public versus non-public determinations 

is not consolidated and MD 3.4 is outdated and sometimes 

inaccurate. 

It is essential that staff undertake a hierarchical approach to making 

public versus non-public determinations in that first, an employee 

must decide whether an item is sensitive per SUNSI or personally 

identifiable information criteria. If an item is sensitive it will need to 

be non-public; however, if it is not sensitive the employee must then 

apply MD 3.4 criteria to assess whether it should be made public. 

Despite the importance of a hierarchical approach, it is not 

adequately addressed in agency guidance. First, MD 3.4 predates 

the agency’s SUNSI and PII policies and therefore does not 

mention these sets of screening criteria. Second, neither the 

agency’s guidance on SUNSI nor its guidance on PII fully describes 

the relationship among the three types of criteria. While PII 

guidance includes a reference to SUNSI, it does not mention MD 

3.4, whereas SUNSI guidance refers to MD 3.4 but not to PII. 

Finally, NRC Form 665, ADAMS Document Submission, requires 

proof that a SUNSI review occurred for NRC-generated documents 

or packages being routed for concurrence and for paper documents 

and packages that contain a mix of paper and electronic documents 

submitted to ADAMS. However, the form does not require 

evidence that a personally identifiable information review was 
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conducted. Appendix B contains copies of two versions of 

Form 665 used by agency staff; 665P is used for packages7

 of 

documents added to ADAMS and 665S is used for single 

documents. 

MD 3.4 also contains information that is no longer accurate. For 

example, this guidance states that power plant fire protection plans, 

Final Safety Analysis Reports, and emergency plans are routinely 

made public even though this is no longer the case. Organizational 

changes that have occurred since the directive’s issuance in 1999 

mean that office names and record types are not all reflected, and 

while MD 3.4 strives to be all-inclusive, it is not. 

Because MD 3.4 is inaccurate, staff do not use it to make public 

versus non-public decisions. Instead, based on OIG’s staff 

interviews, staff focus primarily on the need to protect sensitive 

information. When it comes to deciding what to release to the 

public, they rely on past practice, on-the-job experience, guidance 

from co-workers, and the concurrence process to make the right 

determination. 

Agency comments provided subsequent to the exit conference 

stated that while MD 3.4 does not refer to PII because the directive 

predated this category of information as a Federal policy issue, MD 

3.4 does refer to personal information as a screening criteria. In 

addition, the agency comments stated that MD 3.4 is currently 

being rewritten to include recent policy developments. 

Training

NRC offers six ADAMS training courses, but none on the 

decisionmaking process for determining public and non-public 

availability. According to a headquarters training center staff 

member, the courses focus on the mechanics of ADAMS and not 

ADAMS related policies. 

Impact on Safety and Public Confidence 

As a result of document profiling inconsistencies and errors, NRC 

risks releasing sensitive information to the public, which can impact 

public safety. The agency also risks unnecessarily withholding 

non-sensitive information, which can undermine public confidence 

in NRC as a fair and unbiased regulator. During NRC’s 2007 

 

7

 A package stores a group of pointers to related documents. These may include a main 

document which is a cover letter, and one or more attachments. Large documents may be 

divided into smaller files that are packaged together to make them easier to work with. 
Audit of NRC’s Process for Placing Documents in the ADAMS Public and Non-Public Libraries 

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Regulatory Information Conference, public stakeholders reiterated 

the importance of open communications with NRC, noting that 

public access to information remains a strong concern. 

Recommendations

OIG recommends that the Executive Director for Operations: 

1. Update MD 3.4 so it reflects the underlying principles of how to 

determine whether an official agency record should be public 

or non-public, and describes the relationship with other agency 

reviews for information sensitivity (e.g., personally identifiable 

information, SUNSI). 

2. Create a supplemental guidance document that is updated 

routinely to include, to the extent practicable, categories of 

information routinely not made public. 

3. After MD 3.4 and supporting guidance are updated and 

consolidated, conduct a training needs analysis and develop 

appropriate training for staff with responsibilities for 

determining whether ADAMS records should be publicly or 

non-publicly available. 
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B. Improved Quality Control Approach Is Needed To Ensure Proper 

Profiling of ADAMS Records 

NRC needs to improve its quality control approach to ensure proper 

profiling of ADAMS records as public or non-public. Specifically, (1) 

the agency does not conduct regular reviews of all documents 

placed in ADAMS to ensure proper placement in either the public or 

non-public ADAMS libraries; (2) document originators do not 

always complete NRC Form 665, an agency requirement; and (3) 

some offices – which have instructed OIS to intercept their 

incoming mail, determine availability, and add it to ADAMS – do not 

routinely review whether OIS has made the appropriate availability 

determination or follow up on items designated non-public pending 

review. 

These conditions exist because the agency does not require 

documentation explaining why ADAMS documents were 

designated as public versus non-public and has not clearly 

communicated quality control expectations to staff. As a result, 

NRC cannot assess if it is meeting its criteria for ADAMS document 

profiling and risks both inappropriate release of information to the 

public and unnecessary withholding of information that should be 

publicly available. 

Quality Control Expectations 

Quality control strategies are essential to ensure that staff follow 

agency guidance on when to profile ADAMS records as public or 

non-public. Such strategies include (1) regular reviews of ADAMS 

documents to determine how well staff are applying NRC’s criteria 

for public and non-public designations, (2) provision of clear 

instructions to staff who have responsibilities associated with 

completing the public versus non-public portion of the ADAMS 

document profile, and (3) office verification and followup in cases 

where OIS profiles incoming mail as public, non-public, or nonpublic pending review and adds the document to ADAMS before 

the office has a chance to see it. 

Agency guidance is limited on what quality control measures are 

needed to ensure that ADAMS documents are profiled correctly for 

public or non-public availability, although the agency does 

communicate some expectations in the ADAMS Desk Reference 

Guide and in ADAMS training courses. This guidance states that 

document originators8

 must complete NRC Form 665 for every 

 

8

 Document originator is the term used to indicate the person who wrote the document and is 

therefore most familiar with the document content. 
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record added to ADAMS. This form asks the originator to verify 

that the SUNSI review occurred and to specify key profiling 

elements including whether the record is to be publicly or nonpublicly available. 

In addition, the guidance states that offices, regions, and OIS are 

jointly responsible for adding documents to ADAMS and ensuring 

that they are correctly profiled for public or non-public availability. 

This cooperative approach is particularly important for offices that 

instruct OIS to intercept their external mail and assign document 

availability as public, non-public, or non-public pending review. 

While OIS makes this initial designation based on instructions 

provided by the addressee office, the addressee office is then 

expected to review the profiles for appropriateness and make the 

final determination concerning these items. Until an office makes 

this final determination, the items will remain inaccessible to the 

public, even if the ultimate decision is to release them publicly. 

Improved Quality Control Measures Are Needed 

NRC needs to improve its quality control measures to ensure 

proper profiling of ADAMS records as public or non-public. 

Specifically, (1) NRC does not conduct regular reviews of all 

documents placed in ADAMS to ensure proper placement in either 

the public or non-public ADAMS libraries; (2) document originators 

do not always complete NRC Form 665 as required; and (3) some 

offices do not routinely review their external mail, which OIS profiles 

and adds to ADAMS, to verify and follow up on OIS’s designation of 

these records as public, non-public, or non-public pending review. 

No Regular Review of ADAMS Records 

NRC does not conduct regular reviews of ADAMS records to 

assess whether their designation as public or non-public is 

appropriate. OIS assigns one full-time employee to perform quality 

control activities on ADAMS records. This employee reviews 

ADAMS profiles to ensure they are filled out completely, conducts 

searches to identify problem areas, and generates reports on the 

timeliness with which NRC records are made public. However, the 

employee does not attempt to assess whether agency staff are 

applying criteria correctly in designating records as public or nonpublic. According to agency comments provided subsequent to the 

exit conference, there are also many OIS employees and 

contractors who perform various ADAMS quality control activities 

as part of their routine duties. 
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OIG acknowledges that it would currently be difficult for NRC 

routinely to review whether ADAMS documents are profiled 

correctly as public or non-public due to a lack of information 

available to support such reviews. Document originators are not 

required to record their rationale for making a document public or 

non-public; yet, their justification for making items public versus 

non-public is not always readily apparent. Similar types of records 

are found in both public and non-public ADAMS, and it is not 

evident, based on the information in the ADAMS profile, why these 

placements were made. Other items in the public library do not fit 

any of the MD 3.4 categories and it is difficult to determine, in some 

cases, why a document was made public. For example, as part of 

its random sampling of ADAMS documents, OIG found four 

instrument calibration records in public ADAMS, but could not 

identify any MD 3.4 category that suggested this type of information 

ought to be public. An agency manager noted that calibration 

records are important in connection with planning for a high-level 

waste repository, which is an MD 3.4 category. The manager 

speculated that this could be the underlying rationale for placing the 

reports in public ADAMS, but was not certain. 

Form 665 Not Completed

Despite agency guidance stating that document originators 

complete a Form 665 for every record added to ADAMS, this does 

not always occur. OIG interviewed 25 NRC employees in 16 

offices who had job responsibilities associated with ADAMS records 

to assess their usage of Form 665. Staff from only seven offices 

reported routinely using Form 665 according to agency guidance 

(document originator completes form for each document submitted 

to ADAMS), while staff from the other nine offices described less 

frequent, inappropriate (e.g., Form 665 completed by administrative 

staff instead of document originator), or no usage of the form at all 

(see table 1 for a summary of office practices). 
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Table 1. Office Use of Form 665 

Profiles Not Reviewed

Although the process by which OIS profiles external mail depends 

on offices to review the profiles to verify they are correct and 

finalize items marked non-public pending review, a number of 

offices do not perform this review. After OIS assigns availability to 

intercepted mail based on office instructions, a notice is sent to the 

addressee and/or a predefined distribution list of NRC employees 

and organizations via the Electronic Regulatory Information 

Distribution System (E-RIDS) that the record is in ADAMS. 

NRC recently discovered a backlog of approximately 16,000 

documents assigned non-public pending review status, indicating 

that offices were not routinely reviewing their E-RIDS mailboxes to 

make final determinations on items marked non-pending public 

review.9

 OIS subsequently sent an e-mail to all offices asking them 

to take action concerning these documents. Offices were also 

reminded that to avoid future backlogs, E-RIDS mailboxes should 

be routinely checked so that items marked non-public pending 

review can be assigned final availability status. OIS could not 

provide a breakdown of how long the 16,000 documents had been 

awaiting this type of review, but an OIS employee said that some of 

the documents have been in that category since 2005. 

 

9

 The OIS employee also explained that not all of the 16,000 documents represented incoming 

mail that OIS had screened and designated as non-public pending review. A portion of these are 

records created by staff and profiled as non-public pending review in order to flag these 

documents as still needing a final availability determination. 

Office Routinely Uses According to Agency Guidance 7 

Office Sometimes Uses 4 

Office Uses Alternative 2 

Office Secretary Completes With Verbal Instruction From 

Document Originator 1 

Office Secretary Completes With No Instruction From 

Document Originator 1 

Office Does Not Use Form 665 or Alternative 1 

TOTAL OFFICES ASSESSED 16 
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OIG interviewed staff from three headquarters offices that have OIS 

profile their external mail and found a lack of clarity concerning the 

E-RIDS review process: 

 

 One individual reported regularly reviewing the E-RIDS mailbox 

and forwarding any E-RIDS notifications to the subject matter 

expert for review. 

 Another reported that while the E-RIDS mailbox is checked 

several times daily, the notifications are not reviewed for nonpublic pending review status. Instead, the subject line is 

scanned and the item is forwarded to the office director who has 

an interest in the subject matter. 

 Only one individual was aware of the E-RIDS review 

requirement; this was because her office had recently received 

the OIS e-mail reporting the backlog and she had been 

assigned to clear it up. 

Agency Needs To Document and Maintain Rationale for 

Making Records Public and Non-Public and Better 

Communicate Expectations 

NRC does not routinely assess whether NRC staff are correctly 

applying the agency’s criteria for making records public or nonpublic because document originators are not required to record 

their rationale for designating a document as public or non-public. 

In addition, there is no tool to facilitate such a review. While Form 

665 could serve as a useful tool on which to record the basis for 

why an item is designated as public or non-public, the form does 

not request this type of information. Finally, there is no requirement 

to retain the form. 

In addition, NRC has not clearly communicated quality control 

expectations to staff. Although the ADAMS Desk Reference Guide

and ADAMS training courses describe the importance of using 

Form 665, these materials do not convey requirements and there is 

no assurance that staff will be exposed to this information. 

Also not clearly conveyed is the requirement for offices to review 

their E-RIDS mail to verify that OIS availability profiling is correct or 

make final determinations on incoming mail profiled as non-public, 

pending review. While this expectation was recently conveyed in 

the e-mail to staff describing the backlog of 16,000 documents in 

non-public pending review status, the E-RIDS notices themselves 

do not instruct the recipient that such a step is needed. 
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Essentially, there is no red flag alerting staff that a document is in 

need of further review prior to being assigned a permanent 

availability. 

Agency Cannot Assess Its Practice 

Because NRC does not routinely review its records to ensure that 

they are properly profiled as public or non-public, it cannot gauge 

how successfully the criteria are applied or identify trends in 

miscategorization. Furthermore, by not following up on documents 

profiled in ADAMS as non-public pending review, NRC risks leaving 

documents that should be made public in a non-public status for an 

indefinite period of time. 

Recommendations 

OIG recommends that the Executive Director for Operations:

4. Develop a mechanism to indicate the rationale for a public or 

non-public designation. This rationale should be sufficiently 

detailed to allow for an assessment of whether agency criteria 

are being applied correctly. 

5. Require offices to use the mechanism developed in response 

to recommendation 4 to provide the rationale for public or nonpublic designation of official agency records.

6. Conduct periodic assessments of the accuracy with which 

NRC staff are applying the agency’s criteria for designating 

records as public or non-public by assessing a random sample 

of records against the agency’s criteria for making these 

determinations. 

7. Inform NRC office directors of the number of non-public 

pending review documents that have been awaiting review by 

their office for at least 30 days.

8. Add a non-public pending review category to E-RIDS 

notifications and clarify the language in the notifications to 

convey the need to finalize the document availability as either 

public or non-public. 
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IV. AGENCY COMMENTS 

At an exit conference held on June 1, 2007, agency managers 

provided comments concerning the draft report. We modified the 

report in response to the comments, as we deemed appropriate. 

NRC reviewed these modifications and opted to submit formal 

comments, which appear in Appendix C of this report. 
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V. CONSOLIDATED LIST OF RECOMMENDATIONS 

OIG recommends that the Executive Director for Operations: 

1. Update MD 3.4 so it reflects the underlying principles of how to 

determine whether an official agency record should be public 

or non-public, and describes the relationship with other agency 

reviews for information sensitivity (e.g., personally identifiable 

information, SUNSI). 

2. Create a supplemental guidance document that is updated 

routinely to include, to the extent practicable, categories of 

information routinely not made public. 

3. After MD 3.4 and supporting guidance are updated and 

consolidated, conduct a training needs analysis and develop 

appropriate training for staff with responsibilities for 

determining whether ADAMS records should be publicly or 

non-publicly available. 

4. Develop a mechanism to indicate the rationale for a public or 

non-public designation. This rationale should be sufficiently 

detailed to allow for an assessment of whether agency criteria 

are being applied correctly. 

5. Require offices to use the mechanism developed in response 

to recommendation 4 to provide the rationale for public or nonpublic designation of official agency records.

6. Conduct periodic assessments of the accuracy with which 

NRC staff are applying the agency’s criteria for designating 

records as public or non-public by assessing a random sample 

of records against the agency’s criteria for making these 

determinations. 

7. Inform NRC office directors of the number of non-public 

pending review documents that have been awaiting review by 

their office for at least 30 days.

8. Add a non-public pending review category to E-RIDS 

notifications and clarify the language in the notifications to 

convey the need to finalize the document availability as either 

public or non-public. 
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Appendix A 

SCOPE AND METHODOLOGY 

Auditors reviewed the ADAMS profiling process to determine the 

effectiveness and consistency by which documents are profiled and 

processed for entry into the public or non-public ADAMS libraries. 

This audit was initiated in response to a letter sent to NRC’s 

Inspector General reporting two specific instances of NRC 

miscoding documents as non-publicly available when the items 

should have been publicly available. 

The OIG audit team reviewed relevant criteria, including the 

ADAMS Desk Reference Guide; Management Directive 3.4, 

Release of Information to the Public; Yellow Announcement 2005-

077, Policy Revision: NRC Policy and Procedures for Handling, 

Marking, and Protecting Sensitive Unclassified Non-Safeguards 

Information (SUNSI); and Yellow Announcement 2006-069, 

Protection of Personally Identifiable Information. 

 

Auditors interviewed OIS staff and document originators and 

administrative staff from 18 NRC offices, including the 4 NRC 

regional offices. Auditors also interviewed a public interest group 

representative and attended sessions addressing communications 

issues at the agency’s 2007 Regulatory Information Conference. 

Auditors analyzed a 10-percent random sample of all agency 

records added to ADAMS during December 2006 to determine the 

consistency by which documents are designated public and nonpublic according to current agency guidance. Auditors compared 

MD 3.4, SUNSI, and personally identifiable information criteria to 

each document to determine whether the agency’s categorization 

seemed appropriate. 

This work was conducted from December 2006 through 

March 2007, in accordance with generally accepted Government 

auditing standards. Those standards require that we plan and 

perform the audit to obtain sufficient, appropriate evidence to 

provide a reasonable basis for our findings and conclusions based 

on our audit objectives. We believe that the evidence obtained 

provides a reasonable basis for our findings and conclusions based 

on our audit objectives. The work was conducted by 

Beth Serepca, Team Leader; Judy Gordon, Audit Manager; and 

Jaclyn Storch, Management Analyst. 
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Appendix B. 

Forms 665S and 665P 
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 Appendix C