AUDIT REPORT

Audit of NRC’s Oversight of ISFSI Security

OIG-11-A-10 May 3, 2011

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/
UNITED STATES

NUCLEAR REGULATORY COMMISSION

WASHINGTON, D.C. 20555-0001

OFFICE OF THE

INSPECTOR GENERAL

May 3, 2011

MEMORANDUM TO: R. William Borchardt

Executive Director for Operations

FROM: Stephen D. Dingbaum /RA/

Assistant Inspector General for Audits

SUBJECT: AUDIT OF NRC’S OVERSIGHT OF ISFSI SECURITY

(OIG-11-A-10)

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

Oversight of ISFSI Security.

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

April 13, 2011, exit conference have been incorporated, as appropriate, into this 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 followup 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 Audit 

Team, at 415-5911.

Attachment: As stated 
Electronic Distribution

Edwin M. Hackett, Executive Director, Advisory Committee 

 on Reactor Safeguards

E. Roy Hawkens, Chief Administrative Judge, Atomic Safety 

 and Licensing Board Panel

Stephen G. Burns, General Counsel

Brooke D. Poole, Director, Office of Commission Appellate Adjudication

James E. Dyer, Chief Financial Officer

Margaret M. Doane, 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

R. William Borchardt, Executive Director for Operations

Michael F. Weber, Deputy Executive Director for Materials, Waste,

 Research, State, Tribal, and Compliance Programs, OEDO

Darren B. Ash, Deputy Executive Director 

 for Corporate Management, OEDO

Martin J. Virgilio, Deputy Executive Director for Reactor

 and Preparedness Programs, OEDO

Mary C. Muessle, Assistant for Operations, OEDO

Kathryn O. Greene, Director, Office of Administration

Patrick D. Howard, Director, Computer Security Office

Roy P. Zimmerman, Director, Office of Enforcement

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

 and Environmental Management Programs

Cheryl L. McCrary, Director, Office of Investigations

Thomas M. Boyce, Director, Office of Information Services

Miriam L. Cohen, Director, Office of Human Resources

Michael R. Johnson, Director, Office of New Reactors

Catherine Haney, Director, Office of Nuclear Material Safety

 and Safeguards

Eric J. Leeds, 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

James T. Wiggins, Director, Office of Nuclear Security

 and Incident Response

William M. Dean, Acting Regional Administrator, Region I

Victor M. McCree, Regional Administrator, Region II

Mark A. Satorius, Regional Administrator, Region III

Elmo E. Collins, Jr., Regional Administrator, Region IV
Audit of NRC’s Oversight of ISFSI Security

i

EXECUTIVE SUMMARY 

BACKGROUND

Independent Spent Fuel Storage Installations (ISFSI) are facilities licensed 

by the U.S. Nuclear Regulatory Commission (NRC) to store dry casks 

containing used nuclear reactor fuel, otherwise known as spent fuel.1 

These massive structures typically contain spent fuel assemblies within a 

sealed steel canister, which are located in a thick concrete and steel cask 

for shielding and protection, and then placed on thick concrete pads for 

added strength and stability. These casks can be stored either vertically 

or horizontally in concrete storage bunkers.

With the anticipated growth of nuclear power in the United States, and the 

uncertainty over the permanent storage of spent nuclear fuel at Yucca 

Mountain,2nuclear power plants have a growing need for additional spent 

fuel storage capacity to support continued plant operation. ISFSIs are 

generally regarded as a safe and practical means to store spent fuel as 

they are passive systems that do not require the maintenance of spent 

fuel pools.3

NRC, which regulates the safe and secure use of nuclear materials, 

issues licenses and oversees licensee compliance with regulations for 

ISFSI facilities. The first dry storage ISFSI was licensed by NRC in 1986. 

As of April 2011, there were ISFSIs storing spent nuclear fuel or preparing 

to store spent nuclear fuel in the near term at 57 different locations across 

the United States. Of these ISFSI sites, 47 were located at operating 

reactors and the remaining 10 were located away from an operating 

reactor. 

 

1 NRC regulations allow the storage of spent fuel in both pool-type wet storage and dry casks. In 1971, 

the first ISFSI license was issued to a wet storage facility. This remains the only non-dry cask ISFSI in 

the United States.

2

Yucca Mountain, Nevada, has been the leading candidate site for a spent nuclear fuel repository since 

the 1980s. However, in recent years, scientific and political concerns have emerged over the suitability of 

the location. 

3

Spent fuel pools are underwater storage facilities for spent nuclear fuel located within the reactor site. 

These pools were the most common method to store spent fuel until the emergence of dry cask storage 

in the late 1980s.
Audit of NRC’s Oversight of ISFSI Security

ii

Following the terrorist attacks of September 11, 2001, NRC conducted a 

comprehensive review of its security policies and procedures, including 

those related to spent fuel storage. NRC recognized the need to 

reexamine basic assumptions underlying the civilian nuclear facility 

security and safeguards programs and embarked upon a comprehensive 

review of these programs. NRC issued advisories and orders to licensees 

possessing spent nuclear fuel that identified additional security measures 

and directed licensees to reevaluate the adequacy of their security 

programs, plans, and procedures. 

PURPOSE

The audit objective was to determine the adequacy of NRC’s oversight of 

ISFSI security.

RESULTS IN BRIEF

While NRC has taken steps to improve its oversight of ISFSI security, and 

the agency has not experienced any problems with ISFSI security, the 

Office of the Inspector General (OIG) identified the following opportunities 

to enhance management of the ISFSI security oversight program:

Define key ISFSI security office roles and responsibilities.

Update the ISFSI security inspection procedure.

Train inspectors assigned to assess ISFSI security.

Develop a centralized database of ISFSI security-related information.

OIG acknowledges the agency’s post-September 11, 2001, categorization 

of ISFSIs as a relatively low security risk and its decision to place security 

resources on higher risk programs; however, making certain basic 

improvements in program management will facilitate the continued 

success of ISFSI security and prevent lapses that could occur in the 

absence of such improvements.
Audit of NRC’s Oversight of ISFSI Security

iii

RECOMMENDATIONS

This report makes recommendations to improve the agency’s ISFSI 

security program. A list of these recommendations appears on page 14 of 

this report.

AGENCY COMMENTS

At an exit conference on April 13, 2011, agency management stated their 

general agreement with the findings and recommendations in this report. 

Agency management also provided supplemental information that has 

been incorporated into this report, as appropriate. As a result, the agency 

opted not to provide formal comments for inclusion in this report.
Audit of NRC’s Oversight of ISFSI Security

iv

ABBREVIATIONS AND ACRONYMS

ADAMS Agencywide Documents Access and Management System

ASM Additional Security Measures

FSME Office of Federal and State Materials and Environmental 

Management Programs

ICM Interim Compensatory Measures

ISFSI Independent Spent Fuel Storage Installation

NMSS Office of Nuclear Material Safety and Safeguards

NRC U.S. Nuclear Regulatory Commission

NSIR Office of Nuclear Security and Incident Response

OIG Office of the Inspector General
Audit of NRC’s Oversight of ISFSI Security

v

TABLE OF CONTENTS

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

ABBREVIATIONS AND ACRONYMS................................................... iv

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

II. PURPOSE......................................................................................5

III. FINDING.........................................................................................6

IMPROVEMENTS ARE NEEDED IN THE ISFSI SECURITY PROGRAM............6

IV. AGENCY COMMENTS.................................................................14

APPENDIX

SCOPE AND METHODOLOGY ..........................................................15
Audit of NRC’s Oversight of ISFSI Security

1

I. BACKGROUND

Independent Spent Fuel Storage Installations (ISFSI) are facilities licensed 

by the U.S. Nuclear Regulatory Commission (NRC) to store dry casks 

containing used nuclear reactor fuel, otherwise known as spent fuel.4 

These massive structures typically contain spent fuel assemblies within a 

sealed steel canister, which are located in a thick concrete and steel cask 

for shielding and protection, and then placed on thick concrete pads for 

added strength and stability. These casks can be stored either vertically 

or horizontally in concrete storage bunkers.

Figure 1. Horizontal dry cask storage at Susquehanna.

Source: NRC

ISFSIs can be located in three types of locations: (1) the “protected area,” 

which is located within the security fence that surrounds a nuclear reactor; 

(2) the “owner-controlled area,” which is the area immediately outside the 

security fence that surrounds a nuclear reactor; and (3) away from an 

operating reactor, as in a standalone facility or in a decommissioned 

reactor site. All ISFSIs, regardless of location, are required to meet 

certain security standards to protect the facility. 

 

4 NRC regulations allow the storage of spent fuel in both pool-type wet storage and dry casks. In 1971, 

the first ISFSI license was issued to a wet storage facility. This remains the only non-dry cask ISFSI in 

the United States.
Audit of NRC’s Oversight of ISFSI Security

2

Figure 2. Nuclear Plant Security Zones

Source: Nuclear Energy Institute

With the anticipated growth of nuclear power in the United States, and the 

uncertainty over the permanent storage of spent nuclear fuel at Yucca 

Mountain,5nuclear power plants have a growing need for additional spent 

fuel storage capacity to support continued plant operation. ISFSIs are 

generally regarded as a safe and practical means to store spent fuel as 

they are passive systems that do not require the maintenance of spent 

fuel pools.6

 

5

Yucca Mountain, Nevada, has been the leading candidate site for a spent nuclear fuel repository since 

the 1980s. However, in recent years, scientific and political concerns have emerged over the suitability of 

the location. 

6

Spent fuel pools are underwater storage facilities for spent nuclear fuel located within the reactor site. 

These pools were the most common method to store spent fuel until the emergence of dry cask storage 

in the late 1980s.
Audit of NRC’s Oversight of ISFSI Security

3

NRC, which regulates the safe and secure use of nuclear materials, 

issues licenses and oversees licensee compliance with regulations for 

ISFSI facilities. The first dry storage ISFSI was licensed by NRC in 1986. 

As of April 2011, there were ISFSIs storing spent nuclear fuel or preparing 

to store spent nuclear fuel in the near term at 57 different locations across 

the United States. Of these ISFSI sites, 47 were located at operating 

reactors and the remaining 10 were located away from an operating 

reactor. Figure 3 is a map of ISFSI locations within the United States.

Figure 3. U.S. ISFSI Map, April 2011

Source: NRC OIG

Security Requirements

Following the terrorist attacks of September 11, 2001, NRC conducted a 

comprehensive review of its security policies and procedures, including 

those related to spent fuel storage. NRC recognized the need to 

reexamine basic assumptions underlying the civilian nuclear facility 

security and safeguards programs, and embarked upon a comprehensive 

review of these programs. As part of this effort, NRC conducted 
Audit of NRC’s Oversight of ISFSI Security

4

assessments of the potential consequences and risks of terrorist attacks 

on a broad range of licensed facilities and activities, including spent fuel 

storage. These assessments helped NRC determine where efforts should 

initially be directed. This prioritization placed ISFSIs low on the priority list 

based on the robust structure of the ISFSI, and the fact that a majority of 

the ISFSIs are co-located with nuclear reactor facilities.7 

NRC also issued advisories and orders to licensees possessing spent 

nuclear fuel that identified additional security measures and directed 

licensees to reevaluate the adequacy of their security programs, plans, 

and procedures. In October 2002, NRC issued “Interim Compensatory 

Measures (ICM) for Dry Independent Spent Fuel Storage Installations” to 

all ISFSI licensees. This document served as the single security order for 

all ISFSI licensees until 2007, when it was replaced by “Additional Security 

Measures (ASM) for the Protection of Dry Independent Spent Fuel 

Storage Installations.” The ASM contains the same requirements as the 

ICM but was renamed to remove any connotation of a “temporary” status.

While licensees that originally received the ICM must comply with that 

particular order, all ISFSIs licensed subsequent to September 2007 must 

comply with the ASM.

NRC Office Responsibilities

The two primary offices involved in ISFSI security oversight are NRC’s 

Office of Nuclear Material Safety and Safeguards (NMSS) and the Office 

of Nuclear Security and Incident Response (NSIR).

NMSS is responsible for the oversight of safe storage, transportation, and 

disposal of high-level radioactive waste and spent nuclear fuel. As part of 

these responsibilities, NMSS implements a regulatory program that 

includes ISFSI licensing, inspection, and assessment of licensee 

performance. 

NSIR is the technical support office for the ISFSI security program. NSIR 

develops overall agency policy and provides management direction for 

evaluation and assessment of technical issues involving security at 

nuclear facilities. NSIR is also responsible for developing emergency 

preparedness policies, regulations, programs, and guidelines for both 

 

7

All nuclear reactors were deemed a high priority and therefore the co-located ISFSIs were already 

receiving additional security requirements by association. 
Audit of NRC’s Oversight of ISFSI Security

5

currently licensed nuclear reactors and potential new nuclear reactors. 

Related to ISFSI security, NSIR writes the security orders and the 

inspection guidelines and serves as the main point of contact for any 

technical questions related to the ISFSI security program. Furthermore, 

NSIR staff have traveled to NRC regional offices to provide training on 

ISFSI security as well as help conduct ISFSI security inspections.

Inspection Guidance

NRC conducts inspections to ensure licensee compliance with regulatory 

security requirements. ISFSI security inspections are primarily conducted 

by NRC’s four regional offices, in accordance with Temporary Instruction 

2690, “Inspection of Additional Security Measures for Dry Cask Storage at 

Independent Spent Fuel Storage Installation(s).” Temporary Instruction 

2690 is not part of the permanent inspection program and will expire in 

June 2011.

NRC is currently working to formalize the ISFSI security orders into a 

regulation through the rulemaking process. The goal of the rulemaking is 

to update and clarify the regulations to support the current regulatory 

environment, address insights gained from the previous ISFSI security 

assessments, and apply a consistent approach across all ISFSIs 

irrespective of their location. One NRC staff member heavily involved with 

this effort estimates that this rulemaking process will take an additional 5 

to 7 years for complete implementation of the regulation.

II. PURPOSE

The audit objective was to determine the adequacy of NRC’s oversight of 

ISFSI security. The report Appendix contains information on the audit 

scope and methodology. 
Audit of NRC’s Oversight of ISFSI Security

6

III. FINDING

Improvements Are Needed in the ISFSI Security Program 

While NRC has taken steps to improve its oversight of ISFSI security, and 

the agency has not experienced any problems with ISFSI security, the 

Office of the Inspector General (OIG) identified the following opportunities 

to enhance management of the ISFSI security oversight program:

Define key ISFSI security office roles and responsibilities.

Update the ISFSI security inspection procedure.

Train inspectors assigned to assess ISFSI security.

Develop a centralized database of ISFSI security-related information.

OIG acknowledges the agency’s post-September 11, 2001, categorization 

of ISFSIs as a relatively low security risk and its decision to place security 

resources on higher risk programs; however, making certain basic 

improvements in program management will facilitate the continued 

success of ISFSI security and prevent lapses that could occur in the 

absence of such improvements.

Structured and Efficient Programs 

According to Federal Government guidance, including the Government 

Accountability Office’s “Standards for Internal Control in the Federal 

Government,” a program’s efficiency is dependent on (1) clearly 

delineated roles and responsibilities of offices and individuals involved to 

avoid confusion and ensure that people understand their roles and 

responsibilities, (2) guidance documents to establish management 

expectations and ensure that all staff involved understand their roles, (3) 

training to ensure that employees have the skills needed to perform their 

work, and (4) data that is organized to facilitate use by staff and managers 

for decisionmaking.

Improvements in ISFSI Security Program Needed

NRC has made efforts to strengthen its oversight of ISFSI security since 

the terrorist attacks of September 11, 2001; however, the program lacks:
Audit of NRC’s Oversight of ISFSI Security

7

A. An overarching process document to ensure that the various offices and 

entities with ISFSI security program responsibilities are carrying out 

their responsibilities efficiently and effectively, especially given the 

number of different offices involved. 

B. A permanent ISFSI security inspection procedure.

C. Inspectors trained specifically on ISFSI systems and security.

D. A single database of ISFSI security information that is consistently 

organized and accessible to inspectors and program managers.

(A) Overarching Process Documentation Needed

NMSS, NSIR, and the Office of Nuclear Reactor Regulation, along with 

four regional divisions, have all played important roles in providing 

oversight of ISFSI security. NMSS is responsible for issuing the security 

requirements to ISFSI licensees and providing the resources to the 

inspectors who conduct the security inspections. NSIR developed and 

maintains the additional security requirements over ISFSIs and the 

technical guidance used by inspectors to ensure licensee compliance with 

security orders. The Office of Nuclear Reactor Regulation issued 

Inspection Procedure 81001, “Independent Spent Fuel Storage 

Installations.”

8

 Regional inspectors have the responsibility for ensuring 

licensee compliance; however, each NRC regional office determines 

which regional inspection group will conduct these inspections. Two 

regions utilize inspectors based within the Division of Nuclear Materials 

Safety, who have materials safety qualifications (primarily health 

physicists), and two regions utilize inspectors based within the Division of 

Nuclear Reactor Safety, who have reactor security qualifications. 

Although staff involved with ISFSI security oversight understand their 

roles, there is no process document that outlines the roles and 

responsibilities of all offices involved. Without this global perspective, 

there are no assurances that lapses do not occur with the shared 

responsibilities. The following examples illustrate some of the challenges 

and inefficiencies in program management based on the lack of an 

overarching process document.

 

8

This inspection procedure was issued in 1991 to establish security inspection procedures for ISFSIs.
Audit of NRC’s Oversight of ISFSI Security

8

Example 1: While NSIR developed the additional security requirements 

over ISFSIs after September 11, 2001, it was NMSS who issued these 

requirements to licensees through security orders. Licensees were 

required to submit responses on their implementation schedules, any 

compliance issues, and when compliance is achieved. These responses 

were returned to NMSS; however, NSIR staff, who are the technical 

experts on the details of the security requirements, were not involved with 

reviewing these responses. NSIR’s involvement with this type of licensee 

compliance verification only began after NSIR issued Temporary 

Instruction 2690 in 2008.

Example 2: Because the regional offices use different groups of 

inspectors to conduct ISFSI security inspections, there is no single forum 

for all counterpart ISFSI security inspectors to discuss their findings or 

concerns. While there are counterpart meetings and weekly telephone 

calls involving the four regional materials divisions and also involving the 

four regional reactor divisions, only two groups of ISFSI security 

inspectors attend either meeting. The two regions using reactor-based 

inspectors attend one set of meetings while the two regions using 

materials-based inspectors attend the other set of meetings. Therefore, 

all groups involved with ISFSI security do not regularly communicate. 

Example 3: During interviews conducted by OIG, one senior NSIR official 

and 26 percent of the 23 regional inspectors and managers interviewed 

referred to Inspection Procedure 81001 as being part of the ISFSI security 

program when, in fact, this inspection procedure was rescinded in 2001. 

Furthermore, it was not until November 2010 that an NSIR manager

discovered that the Office of Nuclear Reactor Regulation had rescinded 

this inspection procedure in 2001. NSIR managers said they were 

unaware this had occurred and that it had not been communicated to 

them. 

(B) Inspection Procedure Needed

The ISFSI security program lacks clear documentation of expectations for 

the security inspection program. Specifically, there is no inspection 

procedure related to current ISFSI security requirements. After the 

security orders were issued to licensees beginning in October 2002, NRC 

did not issue any updated inspection guidance to check licensee 

compliance until 2008. Currently, inspectors use Temporary Instruction 

2690, “Inspection of Additional Security Measures for Dry Cask Storage at 
Audit of NRC’s Oversight of ISFSI Security

9

Independent Spent Fuel Storage Installation(s),” to evaluate licensee 

compliance with the related security orders. This temporary instruction 

requires inspectors to conduct only an initial security inspection on all 

ISFSI licensees, but does not mandate any additional inspections or 

reviews to ensure compliance.

Furthermore, Temporary Instruction 2690 provides only basic information 

on how to conduct the inspection and does not clearly define what 

licensee measures would satisfy the security requirements. For example, 

it states that inspectors should “verify that the licensee performed 

sufficient analyses.” The use of “sufficient” is subjective and up to 

individual inspector interpretation to determine if a licensee’s actions 

address the intent of the security requirements. As a result, some 

licensees said that they have observed regional differences in how 

inspections are conducted and the level of review conducted by the 

inspectors.

One NSIR official and several inspectors commented that the temporary 

instruction lacks sufficient specificity. The NSIR official stated that the 

temporary instruction leaves too much to the inspector’s discretion. 

According to the NSIR official, the instructions are not descriptive or 

precise enough, which allows differing interpretations by inspectors with 

different backgrounds. A regional inspector told OIG he would like to see 

an established inspection frequency, as well as guidance, to help 

inspectors understand expectations. Two other inspectors stated that 

specific examples are needed in the inspection guidance to help 

inspectors determine if licensee actions meet the security requirements. 

NSIR has made significant strides toward developing more detailed 

guidance documentation. A long-term effort is underway to establish a 

regulation to formalize the security requirements over ISFSIs through the 

rulemaking process. In the meantime, NSIR has been working to reinstate

Inspection Procedure 81001 to provide more extensive, formal guidance 

for ensuring licensee compliance with ISFSI security orders. This 

reinstated inspection procedure will also establish a regular inspection 

frequency. NSIR anticipates this inspection procedure will be 

implemented in June 2011, when Temporary Instruction 2690 expires. 
Audit of NRC’s Oversight of ISFSI Security

10

(C) Formal Qualification Program Needed

There is no established qualification program to train and qualify 

individuals as “ISFSI security” inspectors. Each region makes 

determinations on who should conduct ISFSI security inspections. While 

the individuals selected to conduct ISFSI security inspections have been 

qualified as inspectors under at least one of NRC’s two inspector 

qualification programs, neither of the programs focuses specifically on 

ISFSI security. NRC’s two qualification programs focus on different 

aspects of regulation and inspection:

Inspection Manual Chapter 1246, “Formal Qualification Programs in 

the Nuclear Material Safety and Safeguards Program Area,” outlines 

training and qualification requirements for those inspecting materials 

safety.

Inspection Manual Chapter 1245, “Qualification Program for Operating 

Reactor Programs,” outlines training and qualification requirements for 

those inspecting reactor security.

Consequently, inspectors qualified under Inspection Manual Chapter 1246 

lack detailed training of the security environment related to ISFSIs. One 

inspector qualified under Inspection Manual Chapter 1246 stated that 

security is a very specialized area and that these inspections are not 

something that can just be added on to his duties as a materials inspector. 

The inspector said that security is too important an area to have 

unqualified people performing inspections as non-experts cannot identify 

security weaknesses or vulnerabilities. A different inspector with a 

materials background said that he is not completely comfortable with 

conducting inspections on ISFSIs located within the protected area 

because he feels he needs more training in that area. 

Inspectors qualified under Inspection Manual Chapter 1245 lack detailed 

training on ISFSI systems and equipment. Several inspectors qualified 

under Inspection Manual Chapter 1245 stated that having some sort of 

training course with basic information and guidance related to ISFSIs 

would be useful. 
Audit of NRC’s Oversight of ISFSI Security

11

Of the 23 regional inspectors and managers interviewed, 18 said they 

believe there should be some form of ISFSI security training. One 

regional manager remarked that there should be a formalized ISFSI 

security training program as ISFSIs are unique and do not fall exclusively 

under reactors or materials.

NSIR has recently initiated discussions to establish a formal “ISFSI 

security” inspector qualification program. One NRC manager involved 

with the project stated that NSIR plans to develop individual-based training 

requirements based on the inspectors’ previous qualifications. Those 

inspectors qualified under Inspection Manual Chapter 1246 would be 

required to take additional training courses that include different security 

aspects, while those inspectors qualified under Inspection Manual Chapter 

1245 would be required to take additional training courses that focus on 

the design and functionality of ISFSIs. This effort is in an early stage and 

an NSIR manager estimates that it will take approximately 2 years to 

establish any formal qualification program. 

(D) Centralized Repository Needed

There is no centralized database that contains ISFSI security-related 

information. Currently, ISFSI security-related information is located in 

multiple database systems. Specifically, security orders issued and 

individual licensee responses to these orders are located within the 

Agencywide Documents Access and Management System (ADAMS), one 

of NRC’s electronic recordkeeping systems. However, if any of this 

information is considered Safeguards Information,9it may not be stored 

within ADAMS, but instead must be stored in the agency’s new electronic 

Safeguards Information filing system. Furthermore, easy retrieval of ISFSI 

information within ADAMS is not always possible. ISFSI information is 

usually stored within ADAMS by the unique ISFSI license number; 

however, since a majority of ISFSIs are co-located with reactors, the 

related ISFSI information is sometimes stored under the reactor license 

number. One inspector stated that his region’s reports are filed under the 

reactor license number because the ISFSI inspection was performed in 

conjunction with a reactor security inspection.

 

9

Safeguards Information is a special category of sensitive unclassified information authorized by the 

Atomic Energy Act of 1954. Safeguards Information is protected similar to Government classified

confidential information and significantly more than other sensitive unclassified information (e.g., privacy 

and proprietary information).
Audit of NRC’s Oversight of ISFSI Security

12

Without a centralized repository, inspectors are unable to quickly and 

easily research information prior to performing security inspections. One 

NRC official stated that when conducting security inspections, it is 

important to do some prior research such as reviewing security orders 

issued to that site and the licensee’s response as to how the licensee will 

comply with these requirements. Because there is no organized way of 

finding such information, individual inspectors must take time to try to 

locate related information stored within multiple systems, including 

ADAMS and the electronic Safeguards Information filing system. Another 

headquarters employee stated that the Safeguards Information located in 

this system can be very difficult to find because it is not categorized well. 

Furthermore, a regional branch chief remarked that there have been 

instances where the licensee had documents or information related to 

their site that NRC should have had, but did not have, in its records. 

In October 2005, NMSS developed an office instruction, SFPO-17, 

“Issuance, Processing, and Tracking of Security-Related Orders,” that 

required NMSS to track the status of all security-related orders issued to 

materials licensees in a centralized database. This database was to help 

track the status of licensee compliance with security orders. However, 1 

year later, in October 2006, NMSS was divided to create an additional 

NRC office, the Office of Federal and State Materials and Environmental 

Management Programs (FSME). As a result, the responsibility of 

maintaining the new database shifted from NMSS to FSME. While the 

database contained some ISFSI information, no new ISFSI information 

was entered into the system after the database responsibility was 

transferred. 

While the 2005 effort to organize ISFSI security information was never 

completed, NSIR has begun a new effort to organize and centralize 

security-related ISFSI information. Specifically, NSIR has created a 

SharePoint site, which is an online centralized database for document 

sharing. However, the success of this database depends on the input and 

participation of the staff involved with the program.

ISFSI Security Program Has Been a Low Priority 

NRC lacks (a) a single entity to facilitate coordination among the various 

offices with roles pertaining to ISFSI security, (b) a permanent inspection 

procedure, (c) ISFSI security training for inspectors, and (d) a centralized 
Audit of NRC’s Oversight of ISFSI Security

13

database with ISFSI security information because the ISFSI security 

program has been a low priority. In the aftermath of September 11, 2001, 

NRC deemed ISFSI security to be a relatively low risk area, especially 

when compared to operating reactors. Steps were taken to increase the 

security requirements of ISFSI licensees; however, additional steps are 

needed to make this low priority program as efficient and effective as 

possible.

Agency managers also explained that the ISFSI security program has not 

developed further because of significant knowledge loss within NSIR due 

to staffing issues. In conducting numerous interviews with NRC staff and 

management, it was noted that the main individual involved with ISFSI 

security within NSIR unexpectedly passed away in 2009. This was a 

significant loss for the ISFSI security group as this individual was the 

subject matter expert and most of his knowledge and vision for the 

program had not been transferred or documented. Over the past couple 

of years, NSIR staff have attempted to replace the lost knowledge through 

educating new staff and better documenting and organizing policies and 

decisions made. However, the ISFSI security program has suffered 

additional staff turnover, which has further impeded the group’s progress.

Lack of Efficient Management 

By implementing several basic program management improvements, NRC 

will promote coordination and efficient management of the ISFSI security 

program. Without overarching program coordination, well-documented 

roles and responsibilities, inspection guidance, a comprehensive training 

program, and a centralized repository of security-related ISFSI 

information, there is no clear basis for timely and fully informed decisions 

which could result in licensee non-compliance with security requirements. 

This could negatively impact NRC’s mission to ensure adequate protection 

of public health and safety, promote the common defense and security, 

and protect the environment. 
Audit of NRC’s Oversight of ISFSI Security

14

Recommendations

OIG recommends that the Executive Director for Operations:

1. Develop and implement an overarching process document that 

defines and clearly documents the roles and responsibilities of all 

offices involved with ISFSI security.

2. Develop and implement a comprehensive ISFSI security inspection 

procedure which includes a defined frequency for inspections to 

occur.

3. Develop and implement a formal ISFSI security qualification program.

4. Develop and implement a centralized repository of relevant ISFSI 

security information.

IV. AGENCY COMMENTS

At an exit conference on April 13, 2011, agency management stated their 

general agreement with the findings and recommendations in this report. 

Agency management also provided supplemental information that has 

been incorporated into this report as appropriate. As a result, the agency 

opted not to provide formal comments for inclusion in this report.
Audit of NRC’s Oversight of ISFSI Security

15

Appendix

SCOPE AND METHODOLOGY

Auditors evaluated the adequacy of NRC’s oversight over ISFSI security. 

The audit team reviewed relevant criteria, including “Interim 

Compensatory Measures (ICM) for Dry Independent Spent Fuel Storage 

Installations”; “Additional Security Measures (ASM) for the Protection of 

Dry Independent Spent Fuel Storage Installations”; “Physical Protection of 

Dry Independent Spent Fuel Storage Installations”; Inspection Procedure 

81001, “Independent Spent Fuel Storage Installations”; and Temporary 

Instruction 2690, “Inspection of Additional Security Measures for Dry Cask 

Storage at Independent Spent Fuel Storage Installation(s).”

At NRC headquarters, in Rockville, MD, auditors interviewed NSIR and 

NMSS staff and managers to gain an understanding of their roles and 

responsibilities in the oversight of ISFSI security. Auditors also traveled to 

and interviewed NRC staff and management located in Region I (King of 

Prussia, PA), Region II (Atlanta, GA), Region III (Lisle, IL), and Region IV 

(Arlington, TX). Additionally, at Nuclear Energy Institute headquarters 

(Washington, D.C.), OIG interviewed representatives from the Nuclear 

Energy Institute and various licensees on their involvement within the

ISFSI security program. Furthermore, auditors observed an ISFSI security 

inspection at Palo Verde Nuclear Generating Station located outside 

Phoenix, AZ.

We conducted this performance audit at NRC headquarters and in the four 

NRC regional offices from September 2010 through January 2011 in 

accordance with generally accepted Government auditing standards. 

Those standards require that the audit is planned and performed with the 

objective of obtaining sufficient, appropriate evidence to provide a 

reasonable basis for any findings and conclusions based on the stated 

audit objective. OIG believes that the evidence obtained provides a 

reasonable basis for the report findings and conclusions based on the 

audit objective. Internal controls related to the audit objective were 

reviewed and analyzed. Throughout the audit, auditors were aware of the 

possibility or existence of fraud, waste, or misuse in the program. The 

work was conducted by Beth Serepca, Team Leader; Rebecca Underhill, 

Audit Manager; Maxinne Lorette, Senior Auditor; and Michael Blair, 

Management Analyst.