a

GAO

United States Government Accountability Office

Report to Congressional Requesters

April 2005 NUCLEAR 

REGULATORY 

COMMISSION

NRC Needs to Do 

More to Ensure that 

Power Plants Are 

Effectively Controlling 

Spent Nuclear Fuel

GAO-05-339
What GAO Found

United States Government Accountability Office

Why GAO Did This Study

Highlights

Accountability Integrity Reliability

www.gao.gov/cgi-bin/getrpt?GAO-05-339.

To view the full product, including the scope 

and methodology, click on the link above. 

For more information, contact Jim Wells at 

(202) 512-3841 or wellsj@gao.gov. 

Highlights of GAO-05-339, a report to

congressional requesters 

April 2005

NUCLEAR REGULATORY COMMISSION

NRC Needs to Do More to Ensure that 

Power Plants Are Effectively Controlling 

Spent Nuclear Fuel 

Nuclear power plants’ performance in controlling and accounting for their 

spent fuel has been uneven. Most recently, three plants—Vermont Yankee and

Humboldt Bay (California) in 2004 and Millstone (Connecticut) in 2000—have 

reported missing spent fuel. Earlier, several other plants also had missing or 

unaccounted for spent fuel rods or rod fragments. 

NRC regulations require plants to maintain accurate records of their spent 

nuclear fuel and to conduct a physical inventory of the material at least once a 

year. The regulations, however, do not specify how physical inventories are to 

be done. As a result, plants differ in the regulations’ implementation. For 

example, physical inventories at plants varied from a comprehensive 

verification of the spent fuel to an office review of the records and paperwork 

for consistency. Additionally, NRC regulations do not specify how individual 

fuel rods or segments are to be tracked. As a result, plants employ various 

methods for storing and accounting for this material. Further, NRC stopped 

inspecting plants’ material control and accounting programs in 1988. 

According to NRC officials, there was no indication that inspections of these 

programs were needed until the event at Millstone. 

NRC is collecting information on plants’ spent fuel programs to decide if it 

needs to revise its regulations and/or oversight. In addition to reviewing 

specific instances of missing fuel, NRC has had its inspectors collect basic 

information on all facilities’ programs. It has also contracted with the 

Department of Energy’s Oak Ridge National Laboratory in Tennessee to 

review NRC’s material control and accounting programs for nuclear material, 

including spent fuel. It further plans to request information from plant sites 

and visit over a dozen of them for more detailed inspection. These more 

detailed inspections may not be completed until late 2005, over 5 years after 

the instance at Millstone that initiated NRC’s efforts. However, we believe 

NRC has already collected considerable information indicating problems or 

weaknesses in plants’ material control and accounting programs for spent fuel.

Source: Nuclear Energy Institute.

Nuclear fuel rods are filled with ceramic pellets of uranium and grouped into fuel assemblies, 

typically 5 to 10 inches square and 12 to 14 feet long.

Spent nuclear fuel—the used fuel 

periodically removed from reactors 

in nuclear power plants—is too 

inefficient to power a nuclear 

reaction, but is intensely 

radioactive and continues to 

generate heat for thousands of 

years. Potential health and safety 

implications make the control of 

spent nuclear fuel of great 

importance. The discovery, in 2004, 

that spent fuel rods were missing at 

the Vermont Yankee plant in 

Vermont generated public concern 

and questions about the Nuclear 

Regulatory Commission’s (NRC) 

regulation and oversight of this 

material. 

GAO reviewed (1) plants’ 

performance in controlling and 

accounting for their spent nuclear 

fuel, (2) the effectiveness of NRC’s 

regulations and oversight of the 

plants’ performance, and (3) NRC’s 

actions to respond to plants’ 

problems controlling their spent 

fuel. 

What GAO Recommends

GAO recommends that NRC (1) 

establish specific requirements for 

the control and accounting of loose 

rods and fragments and plants’ 

conduct of their physical 

inventories and (2) develop and 

implement appropriate inspection 

procedures to verify plants’ 

compliance with the requirements. 

Commenting on the draft report, 

NRC generally agreed with GAO’s 

conclusions and recommendations. 
Page i GAO-05-339 Nuclear Regulatory Commission

Contents

Letter 1

Results in Brief 3

Background 6

Nuclear Power Plants Have Had Unaccounted-For Spent Nuclear 

Fuel 11

NRC Regulations and Oversight Activities Are Insufficient to Ensure 

Control of All Spent Fuel 16

NRC Is Studying Spent Fuel Control and Accounting Problems but 

Has Yet to Revise Its Regulations or Oversight Policies 20

Conclusions 25

Recommendations for Executive Action 26

Agency Comments 27

Appendixes

Appendix I: Scope and Methodology 29

Appendix II: Summary Results of GAO Survey of NRC Senior/Lead 

Resident Inspectors 31

Appendix III: Comments from the Nuclear Regulatory Commission 35

Appendix IV: GAO Contacts and Staff Acknowledgments 38

GAO Contacts 38

Staff Acknowledgments 38

Figures Figure 1: Example of Fuel Rods in a Nuclear Power Reactor 7

Figure 2: Example of Dry Cask Storage 9

Abbreviations

DOE Department of Energy

ISFSI independent spent fuel storage installation

NRC Nuclear Regulatory Commission

OIG Office of the Inspector General

TI temporary instruction

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Page 1 GAO-05-339 Nuclear Regulatory Commission

United States Government Accountability Office

Washington, D.C. 20548

A

April 8, 2005 Letr

The Honorable James M. Jeffords

Ranking Minority Member

Committee on Environment and Public Works

United States Senate

The Honorable Patrick Leahy

United States Senate

The Honorable Bernie Sanders

House of Representatives

The Honorable John Olver

House of Representatives

Spent nuclear fuel—the used fuel periodically removed from reactors in 

nuclear power plants—is one of the most hazardous materials made by 

humans. Without protective shielding, the fuel’s intense radiation can kill a 

person within minutes if directly exposed to it or cause cancer in those 

exposed to smaller doses. The nation’s 103 operating nuclear power plants, 

which generate about 20 percent of U.S. electricity, annually produce over 

2,000 metric tons of spent fuel. Absent a national repository, these 

materials must be stored on site. Given the potential harm to human health 

and the environment, the Nuclear Regulatory Commission (NRC) requires 

licensees or operators of commercial nuclear power plants to strictly 

control and account for their spent fuel. However, several recent 

discoveries of missing or unaccounted-for spent fuel have raised concerns 

about nuclear power plants’ control over these materials and NRC’s 

oversight. The terrorist attacks of September 11, 2001, heightened these 

concerns by raising questions about whether these highly radioactive 

materials could be diverted or stolen and used maliciously.

A commercial nuclear power plant’s reactor is fueled by small ceramic 

pellets of uranium, roughly the size of the tip of one’s little finger. These 

pellets are placed end-to-end inside hollow metal tubes (made today of 

zirconium alloy), which are then gas pressurized and welded closed. The 

filled metal tubes are called fuel rods or pins. Rods are grouped together 

into fuel assemblies (also known as fuel bundles), typically about 5 to 10 

inches square and 12 to 14 feet long, and placed in the reactor core. 

Depending on the type of reactor, an assembly consists of 36 to 289 rods
Page 2 GAO-05-339 Nuclear Regulatory Commission

and the core contains from 150 to 800 assemblies.1 An assembly can weigh 

over half a ton. About every 12 to 18 months, the reactor must shut down 

for refueling. During this time, about one-fourth to one-third of the fuel 

assemblies are removed from the reactor core and replaced with new fuel 

assemblies. Removed assemblies are those that have become too 

inefficient to power the nuclear reaction (but which have become intensely 

radioactive and will continue to generate some amount of heat for tens of 

thousands of years).

When removed from the reactor, spent fuel assemblies are placed in racks 

in a spent fuel pool. Spent fuel pools are typically 40-foot deep, steel-lined, 

concrete vaults filled with water. Water is a natural barrier to radiation, and 

it allows the fuel to cool as it becomes less radioactive. Over the course of 

years, the spent fuel within the pools has been typically moved or 

rearranged to accommodate more spent fuel while maintaining safety. At 

some nuclear power sites, spent fuel has also been transferred to dry 

storage casks to await permanent disposition at a national repository for 

spent fuel, such as the deep underground repository planned at Yucca 

Mountain, Nevada. Spent fuel is typically cooled for 5 years before it can be 

moved to dry storage casks, which are extremely large and heavy 

containers made of steel or steel surrounded by additional concrete that 

can hold from 7 to 68 fuel assemblies. However, the majority of spent fuel 

at nuclear power plants remains within spent fuel pools. In addition, at a 

number of nuclear power plants, fuel assemblies have been disassembled 

or reconstituted2

 due to damaged or leaking fuel rods or for inspection and 

testing purposes. Disassembly or reconstitution is a delicate process 

involving heavy machinery. These individual fuel rods and, if broken, rod 

fragments are also stored in the spent fuel pool, either placed at the bottom 

or in special containers, repackaged, or in some cases, put back into the 

parent spent fuel assembly.

This report discusses (1) nuclear power plants’ performance in controlling 

and accounting for their spent nuclear fuel, (2) the effectiveness of NRC’s 

1

In the United States, there are two types of nuclear power reactors (boiling water and 

pressurized water) and several designs for each. With the inclusion of modifications over 

time, specifications regarding the number and length of fuel rods and the number of 

assemblies required to fuel a reactor core will vary. Specifications may also be influenced by 

the type of reactor design.

2

Reconstitution in this sense refers to the process by which fuel rods are removed from 

complete fuel assemblies and the replacement of these rods with good ones.
Page 3 GAO-05-339 Nuclear Regulatory Commission

regulations and oversight of nuclear power plants’ performance in 

controlling and accounting for spent nuclear fuel, and (3) actions that NRC 

is taking in response to licensees’ spent fuel control and accounting 

difficulties. In the context of this report, control and accounting for spent 

nuclear fuel refers to plants’ tracking of and record-keeping for the 

movement and storage of their spent nuclear fuel. We did not assess plants’ 

safety procedures for the handling or storage of spent fuel or plant security 

and the vulnerability of spent fuel to theft or terrorist attacks. 

To assess nuclear power plants’ performance in controlling and accounting 

for their spent nuclear fuel, we reviewed and analyzed relevant documents, 

including NRC and nuclear power plant licensees’ event reports, NRC 

studies and investigations of missing fuel rods, and other related 

documents. We also interviewed NRC and nuclear power plants officials. 

To assess NRC’s material control and accounting requirements for spent 

fuel stored at nuclear power sites, we reviewed and analyzed relevant 

regulations, NRC orders and policies, and interviewed NRC and industry 

officials to identify the key NRC requirements and how they are 

implemented. To determine how NRC performs oversight of nuclear power 

plant material control and accounting activities, we reviewed NRC 

inspection policies, instructions, and reports; analyzed relevant Inspector 

General reports and internal NRC analyses and studies; interviewed 

appropriate NRC program and regional officials; and conducted an e-mail 

survey of all NRC lead/senior inspectors located on site at plants about 

inspection practices, management controls, and suggestions for 

improvements, if viewed necessary. To determine the status of NRC actions 

and plans in response to licensees’ spent fuel control and accounting 

problems, we reviewed internal NRC memoranda, instructions, and reports 

and interviewed appropriate program officials.

A more detailed description of our scope and methodology is presented in 

appendix I. More detailed results of our survey of NRC resident inspectors 

is presented in appendix II. We performed our work between July 2004 and 

February 2005 in accordance with generally accepted government auditing 

standards.

Results in Brief Nuclear power plants’ performance in controlling and accounting for spent 

nuclear fuel has been uneven. Most recently, three nuclear power plants 

have reported missing or unaccounted-for spent nuclear fuel to NRC. These 

plants were the Millstone Nuclear Power Station in Connecticut in 2000, 

the Vermont Yankee plant in Vermont in 2004, and the Humboldt Bay Power 
Page 4 GAO-05-339 Nuclear Regulatory Commission

Plant in California in 2004. The Millstone and Vermont Yankee plants are 

still operating, while the Humboldt Bay plant has been shut down since 

1976. The unaccounted-for material from Millstone was never found, while 

the unaccounted-for material at Vermont Yankee was found 3 months later 

in its spent fuel pool but in a location other than that indicated by the 

inventory records. At Humboldt Bay, NRC and licensee officials are still 

investigating the plant’s missing spent nuclear material. In all three cases, 

the missing spent fuel was in loose fuel rods or segments of fuel rods that 

had been removed from the fuel assemblies. NRC is also aware of several 

earlier instances of lost or unaccounted-for spent fuel at other facilities. In 

1990, a nuclear power plant shipped one more spent fuel rod than planned. 

The licensee discovered the discrepancy in 1991, then notified NRC and 

corrected its records. On several occasions, licensees reported “lost” or 

“missing” spent fuel but, according to NRC, in each case, the spent fuel was 

known to be contained within the facility, either in the reactor coolant 

system, the spent fuel pool, or a refueling pathway. Moreover, information 

NRC has collected in response to the unaccounted-for spent fuel at 

Millstone indicates that spent fuel rods outside of fuel assemblies are an 

issue at additional nuclear power sites. NRC inspectors often could not 

confirm that containers that were designated as containing loose fuel rods 

in fact contained the fuel rods. The containers, in some cases, were closed 

or sealed and, in other cases, the contents were not visible when looking 

into the spent fuel pool. Thus, spent fuel may be missing or unaccounted 

for at still other plants.

Although NRC requires plants to maintain an accurate record of all their 

spent fuel and its location, NRC regulations do not specify how licensees 

are to conduct physical inventories nor how they are to control and 

account for loose spent fuel rods and fragments. NRC regulations require 

licensees to perform a physical inventory at least once every 12 months. 

However, NRC guidance for material control and accounting does not 

characterize what constitutes a physical inventory or how to conduct one. 

Consequently, implementation is inconsistent among the licensees. 

Physical inventories of spent fuel in spent fuel pools may include anything 

from comparing a map with the actual assembly racks in the pool to 

identify misplaced fuel assemblies to performing a comprehensive 

identification of fuel assemblies according to their serial numbers. 

Additionally, NRC regulations do not specifically require licensees to track 

individual fuel rods or fragments, and individual rods, fragments, or other 

controlled nuclear material may or may not be accounted for in the 

inventory. Licensees also employed various methods of storing and 

accounting for this material. In 1988, NRC decided to no longer conduct 
Page 5 GAO-05-339 Nuclear Regulatory Commission

routine inspections of plants’ compliance with material control and 

accounting regulations for spent fuel because it considered the potential 

risk for spent fuel to be lost or stolen from a plant to be very low. According 

to NRC officials, the agency viewed spent fuel assemblies as “self 

protecting” because of the extremely high level of radiation they emit and 

their large size and weight.

In light of the missing spent fuel rods at Millstone and subsequent 

concerns, NRC is re-assessing its decision to no longer conduct routine 

inspections of plants’ compliance with material control and accounting 

regulations for spent fuel. For example, NRC is using a three-phase 

approach under which its inspectors are collecting information on the 

status of material control and accounting programs at plants. It has also 

contracted with the Department of Energy’s Oak Ridge National Laboratory 

in Tennessee to review NRC’s material control and accounting programs 

for nuclear materials, including spent fuel. The third phase under which 

NRC inspectors will collect more detailed information at selected plants 

will not likely be completed until late in 2005, over 5 years after the spent 

fuel rods were discovered to be missing at Millstone. However, these 

efforts, along with the more recent instances of missing spent fuel at 

Vermont Yankee and Humboldt Bay as well as a 2003 NRC Office of the 

Inspector General report outlining weaknesses in NRC’s oversight of 

nuclear materials (including spent fuel), have already provided NRC with 

considerable information on nuclear power plant licensees’ control and 

accounting programs, and NRC officials anticipate that changes in NRC’s 

regulations and oversight activities will be necessary. According to NRC 

officials, this spring they plan to present the results of the Oak Ridge 

review and other information to the NRC Commissioners, who will decide 

whether the agency will take any action. 

We are making recommendations to NRC aimed at improving its regulation 

and oversight of spent fuel by defining how licensees are to conduct 

physical inventories, specifying control and accounting requirements for 

loose rods and rod fragments, and taking timely action to monitor 

licensees’ compliance with material control and accounting requirements. 

In commenting on a draft of this report, NRC generally agreed with the 

report’s conclusions and said that it will develop guidance concerning 

control and accounting of spent fuel rods and pieces and the conduct of 

physical inventories. NRC also said that it will revise its existing 

procedures for inspecting material control and accounting of spent nuclear 

fuel to include instructions on inspecting control and accounting of rods 

and pieces. NRC’s comment letter is included in appendix III. 
Page 6 GAO-05-339 Nuclear Regulatory Commission

Background NRC is an independent agency established by the Energy Reorganization 

Act of 1974 to regulate civilian uses of nuclear materials. It is responsible 

for ensuring that those who use radioactive material—in generating 

electricity, for experiments at universities, and for other uses such as in 

construction and medicine—do so in a manner that protects the public, the 

environment, and workers. NRC has issued licenses to the 103 operating 

nuclear power plants and the 7 facilities that produce fuel for these plants.3

In addition, NRC, or the 33 states that have agreements with NRC, regulates 

about 22,000 other entities that use nuclear materials. For example, in the 

medical field, nuclear material licensees annually perform millions of 

diagnostic and therapeutic procedures using radioactive material.

NRC is headed by a five-member commission appointed by the President 

and confirmed by the Senate. The President designates one commissioner 

as Chairman and official spokesperson. NRC has over 3,000 employees who 

work in its headquarters office in Rockville, Maryland, and its four regional 

offices. NRC is financed primarily by fees it imposes on commercial users 

of the nuclear material that it regulates. For fiscal year 2005, NRC’s 

appropriated budget of $669 million included approximately $540 million 

financed by these fees.

NRC regulates the nation’s commercial nuclear power plants by 

establishing requirements for plant owners and operators to follow in the 

design, construction, and operation of nuclear reactors. NRC also licenses 

the reactors and the people who operate them. To ensure that nuclear 

reactors are operated within their licensing requirements and technical 

specifications, NRC oversees them by inspecting activities at the plants and 

assessing plant performance. NRC’s inspections consist of both baseline 

inspections and supplemental inspections to assess particular licensee 

programs or issues that arise at a particular power plant. Inspections may 

also occur in response to a specific operational problem or event that has 

occurred at a plant. NRC maintains from two to three inspectors at every 

operating nuclear power site in the United States and supplements the 

inspections conducted by these resident inspectors with inspections 

conducted by staff from headquarters and/or its regional offices. Generally, 

3

NRC has licensed 104 commercial nuclear power plants to operate. One of these plants has 

been shut down since 1985. Other nuclear power plants are in the decommissioning phase. 

These decommissioning plants and a wet storage facility not associated with a nuclear 

power plant (GE Morris) also still have spent nuclear fuel and are licensed by NRC for these 

purposes.
Page 7 GAO-05-339 Nuclear Regulatory Commission

inspectors verify that the plant’s operator qualifications and operations, 

engineering, maintenance, fuel handling, security, emergency 

preparedness, and environmental and radiation protection programs are 

adequate and comply with NRC requirements. An important part of NRC’s 

regulatory strategy is that licensees have programs that include monitoring, 

maintenance, and inspection to ensure safe operations. 

In addition to the construction and operation of commercial nuclear power 

plants, NRC regulates the storage, transportation (together with the 

Department of Transportation), and disposal of spent fuel. Although 

nuclear power licensees ship a small amount of spent fuel off site for 

storage and some fuel is stored in dry casks on site, most spent fuel is taken 

from the reactor and moved directly to the nuclear power site’s spent fuel 

pool. 

Figure 1: Example of Fuel Rods in a Nuclear Power Reactor

Nuclear reactor

Coolant

Fuel rods

Uranium

fuel pellets

Fuel rod

Source: Nuclear Regulatory Commission.
Page 8 GAO-05-339 Nuclear Regulatory Commission

Spent fuel pools are constructed according to NRC requirements, typically 

with 4- to 6-foot thick steel-lined concrete walls and floors. Pools are 

typically 30 to 60 feet long, 20 to 40 feet wide, and 40 feet deep. The 

location of these pools is dependent on the type of reactor. Essentially, all 

commercial nuclear power reactors in the United States are one of two 

types, either a boiling water reactor or a pressurized water reactor.4 For 

most boiling water reactors, the pools are located close to the reactors, 

several stories above ground. For pressurized water reactors, the pools are 

located in structures outside the reactor building, on the ground or partially 

embedded in the ground. Regardless of reactor type, these pools are 

required by NRC to be constructed to protect the public against radiation 

exposure, even after a natural disaster, such as an earthquake. The water in 

the pool is constantly cooled and circulated, and the fuel assemblies are 

generally 20 feet below the surface of the water.

In 1982, under the Nuclear Waste Policy Act, the Congress directed the 

Department of Energy (DOE) to construct an underground repository for 

the disposal of spent fuel and other high-level radioactive waste. The 

Congress amended the act in 1987 and required DOE to only consider 

Yucca Mountain, Nevada, as a potential site for the repository. In 2002, the 

President recommended to the Congress, and the Congress approved, 

Yucca Mountain as a suitable site for the development of a permanent highlevel waste repository. For a variety of reasons, DOE is unlikely to open the 

repository in 2010 as planned. 

Lacking a long-term disposal option now, some nuclear utilities must move 

a portion of their spent fuel into dry storage or face shutting down their 

plants because their spent fuel pools are reaching capacity. The majority of 

dry storage facilities are located on site but licensed at a different time 

from the power plant. These facilities are known as independent spent fuel 

storage installations, or ISFSIs. Once dry storage is approved by NRC, 

spent fuel is loaded into dry storage casks, which are steel containers 

surrounded by additional steel, concrete, or other material meant to 

provide radiation shielding, and are backfilled with inert gas. The full casks 

are welded or bolted shut and placed either horizontally or vertically in 

4

A boiling water reactor uses radioactive steam that is generated in the reactor to drive a 

turbine that generates electricity. The water is returned to the reactor core where it is 

reheated to steam, driving the turbines as the cycle is repeated. Pressurized reactors send 

slightly radioactive pressurized water to a steam generator, which creates steam from 

nonradioactive water kept separated by tubes. The steam drives the turbine and the slightly 

radioactive water returns to the reactor where it is reheated and the cycle repeated.
Page 9 GAO-05-339 Nuclear Regulatory Commission

concrete vaults or on a concrete pad, depending on the design. Dry storage 

casks are very large. According to NRC, a vertical cask may be 20 feet tall 

and 9 feet in diameter and could weigh 125 tons fully loaded. Once in place, 

the fuel is cooled by air. NRC requires these storage systems to be capable 

of protecting against radiation exposure and surviving natural disasters. 

Because the move to dry storage is time consuming and expensive, utilities 

are, wherever possible, modifying wet pool storage capacity so they can 

store larger quantities of spent fuel in these pools.

Figure 2: Example of Dry Cask Storage

To ensure that all spent fuel is accounted for and that unauthorized acts 

such as theft or diversion are detected, NRC regulations require each 

licensee to (1) establish, maintain, and follow written procedures that are 

sufficient to enable the licensee to control and account for the material in 

storage; (2) conduct a physical inventory of the spent fuel; and (3) maintain 

records of receipt as well as records on the inventory (including location), 

disposal, and transfer of the material. The physical inventory is required to 

Bundle of used

fuel assemblies

Canister

Storage cask

Source: Nuclear Regulatory Commission.
Page 10 GAO-05-339 Nuclear Regulatory Commission

be performed at intervals not to exceed 12 months. Compliance with these 

requirements is a condition of each plant’s operating license. 

There is a high public perception and fear that spent nuclear fuel, if lost or 

stolen, could be used maliciously. According to NRC, the control of spent 

fuel is of great importance because of the potential health and safety 

implications. However, NRC stated that the very high radiation level of 

spent fuel makes its theft difficult, dangerous, and very unlikely. NRC also 

explained that individual spent fuel rods contain only a very small amount 

of nuclear material, making it unlikely that stolen rods could be used to 

manufacture a weapon. Theft of many rods would be necessary to acquire 

enough material to manufacture a weapon. To expose a large number of 

people to the harmful effects of radiation, the spent fuel would have to be 

released from its protective containers and dispersed over a wide or 

densely populated area. Unlike many other hazardous materials, spent fuel 

is neither explosive nor volatile.5

 Putting the material in a dispersible form 

would be a difficult and dangerous task involving extensive preparation 

using special equipment and radiation shielding. In the event of a dispersal, 

the most significant health effects would involve persons who inhaled very 

small particles. Such particles would be absorbed into the body and 

possibly remain there for many years. 

According to NRC officials, protective systems at nuclear power reactors 

are designed using the concept of “defense in depth.” The officials pointed 

out that it is very unlikely that pieces of spent fuel could be out in the 

public domain because power reactors have layers of protection and 

controls to detect and prevent spent fuel from leaving the spent fuel pool. 

Material control and accounting is one of these layers. Physical security, 

another layer, relies on measures such as portal radiation monitors, fences, 

guards, locks, and limited access. Additional layers relate to safety. For 

example, reactors store spent fuel under at least 20 feet of water because of 

the heat and radiation. If an item of spent fuel is raised out of the spent fuel 

pool, extremely sensitive detectors in the pool area alarm. The officials said 

that NRC requires licensees to respond to these alarms and keep records of 

them. All parties agree that it is very important to fully account for this 

material.

5

Spent fuel rods recently discharged from a reactor also contain some radioactive gases that 

are a by-product of the nuclear fission process—these gases account for a small fraction of 

the total quantity of radioactive material in spent fuel rods, but because of the short half 

lives of the material, the gases decay quickly and may not be present in older spent fuel.
Page 11 GAO-05-339 Nuclear Regulatory Commission

Nuclear Power Plants 

Have Had 

Unaccounted-For 

Spent Nuclear Fuel

Three nuclear power plants have recently reported the discovery of missing 

or unaccounted-for spent nuclear fuel to NRC. These plants were the 

Millstone Nuclear Power Station in Connecticut in 2000, the Vermont 

Yankee plant in Vermont in 2004, and the Humboldt Bay Power Plant in 

California in 2004.6

 NRC’s actions in response to the missing or 

unaccounted-for spent fuel at Millstone led directly to identifying the 

problems at Vermont Yankee and help identify the problems at Humboldt 

Bay. In all three cases, the missing or unaccounted-for spent fuel was in 

loose fuel rods or segments of fuel rods that had been removed from the 

fuel assemblies. Other plants have also identified possible instances of lost 

or unaccounted-for spent fuel.

Millstone At Millstone, two nuclear fuel rods were discovered to be missing when, in 

November 2000, the licensee, Northeast Utilities, was involved in a records 

reconciliation and verification effort to support preparations to move spent 

fuel into dry cask storage. The location of the two full-length fuel rods was 

not properly reflected in special nuclear material records. The licensee 

reported that in 1972, a fuel assembly was disassembled after it was 

removed from the reactor during a shutdown. In 1974 when the fuel 

assembly was reassembled, two rods that were damaged were not placed 

back into the assembly. Instead, they were placed in a container for 

individual rods and stored in the spent fuel pool. Records dated 1979 and 

1980 show the individual fuel rods in the container in the spent fuel pool. 

However, spent fuel pool map records after 1980 do not show either the 

fuel rods or the container. Records do not indicate what happened to these 

rods. The licensee’s investigations of the loss centered on the significant 

spent fuel pool activities that occurred between 1980 and 1992, which 

potentially related to the missing fuel rods. These activities included two 

re-racks, which modified the racks to accommodate more fuel assemblies, 

and several shipments to facilities licensed to receive irradiated nonfuel 

components. The unaccounted-for material from Millstone was never 

found; the licensee concluded that the rods were shipped to a low-level 

waste disposal facility in Barnwell, South Carolina. NRC undertook a 

special inspection to review the licensee’s efforts to locate the missing fuel 

rods and in February 2002 agreed with the licensee that the two missing 

rods were most likely shipped to the Barnwell facility. In June 2002, NRC 

6

The Millstone and Vermont Yankee plants are still operating, while the Humboldt Bay plant 

has been shut down since 1976. 
Page 12 GAO-05-339 Nuclear Regulatory Commission

took enforcement action against the licensee and fined the licensee 

$288,000 for failure to adequately account for the special nuclear material 

contained in the two fuel rods and for failure to report missing material to 

NRC in a timely manner.

Vermont Yankee Spent fuel at Vermont Yankee was discovered missing in April 2004, as the 

NRC resident inspectors at the plant conducted an inspection required by 

NRC headquarters in response to the lost spent fuel rods at Millstone. The 

resident inspectors found that although the licensee had been performing 

an annual physical inventory of the spent fuel pool, the inventory did not 

verify that two fuel rod segments contained in a special container stored on 

the bottom of the pool were still present in the container. In responding to 

the NRC senior resident inspector’s questions, the licensee determined that 

two spent fuel rod pieces, the product of a 1979 fuel reconstitution to 

replace corroded fuel rods that had failed, were not in the storage location 

identified in the inventory records. The two fuel rod pieces were 

approximately one-half inch in diameter by approximately 9 inches and 

17.75 inches in length.

The Vermont Yankee licensee formed an investigation team to search for 

the fuel rod pieces. According to the licensee, the investigation included 

inspecting the spent fuel pool, reviewing documents, interviewing past and 

present Vermont Yankee employees, and interviewing contractors that had 

been associated with spent fuel pool activities and radioactive waste 

operations at Vermont Yankee. In July 2004, after identifying an aluminum 

cylinder in the spent fuel pool as potentially containing the two fuel rod 

pieces, the licensee opened and inspected the cylinder, which in fact 

contained the two fuel rod pieces. The licensee concluded that the root 

causes of this event were that (1) the special nuclear material account 

devices used in inventorying the material had not been properly maintained 

and (2) the plant’s special nuclear material inventory and accountability 

procedures did not provide guidance for controlling pieces of special 

nuclear material as they do for whole fuel assemblies. According to a 

licensee representative, it cost the licensee several million dollars to locate 

the spent fuel rod pieces and review the plant’s material control and 

accounting procedures and activities to determine the root causes of this 

incident. The licensee representative also told us that the plant has already 

taken or is in the process of taking various corrective actions. For example, 

the plant has revised its material control and accounting procedures to 

reflect the findings of the root cause analysis. 
Page 13 GAO-05-339 Nuclear Regulatory Commission

NRC conducted a special inspection to review the results of the licensee’s 

investigation at Vermont Yankee, assess the licensee’s determination of the 

root cause, determine whether the licensee and its predecessor were in 

compliance with applicable regulations, and identify which findings or 

observations may have implications for other nuclear power plants. The 

inspection was performed from April through August 2004, and a report 

was issued to the licensee in December 2004.7

 NRC inspectors concluded 

that the licensee and its predecessor did not keep adequate special nuclear 

material inventory records of the two spent fuel rod pieces, did not follow 

the licensee’s written procedures when the two spent fuel rod pieces were 

moved to a fuel storage container, and did not conduct adequate periodic 

physical inventories of the two spent fuel rod pieces. NRC inspectors also 

concluded that because the two spent fuel rod pieces remained in the 

Vermont Yankee spent fuel pool the entire time the apparent violation 

existed, no actual safety consequence resulted from this apparent violation. 

Nevertheless, NRC considered the apparent violation a potentially 

significant failure of the licensee’s material control and accounting 

program. Enforcement action against the licensee for its apparent violation 

of material control and accounting regulations is currently under review by 

NRC management. A decision is expected sometime in 2005.

Humboldt Bay In July 2004, Humboldt Bay officials reported to NRC that in the process of 

reviewing records and verifying the contents of the spent fuel pool in 

preparation for dry storage operations, the licensee identified a 

discrepancy in plant records that questioned the location of three 18-inch 

fuel rod segments removed from a single spent fuel rod. A plant record 

from 1968 indicated that the three fuel rod segments were stored in the 

spent fuel pool in a small container. However, licensee spent fuel shipment 

records indicated that the entire fuel assembly, including the rod segments, 

had been sent off site for reprocessing in 1969. The licensee notified NRC 

of the record discrepancy in the records and the apparent loss of 

accountability records for the special nuclear material. The licensee 

implemented a program to search the spent fuel pool for the fuel rod 

7

In June 2004, NRC issued Information Notice 2004-12 to all holders of operating licenses for 

nuclear power reactors, research and test reactors, decommissioned sites storing spent fuel 

in a pool, and wet spent fuel storage sites. The notice’s purpose was to inform these 

licensees of the problems at Millstone and Vermont Yankee. Although no specific action or 

written response was required, NRC indicated that it expected the licensees to review the 

information for its applicability to their facilities and consider action, as appropriate, to 

avoid similar problems with their spent fuel inventories.
Page 14 GAO-05-339 Nuclear Regulatory Commission

segments, review additional plant records, and interview plant personnel 

who were on site during the 1968 to 1969 time period.

In November 2004, NRC officials initiated a special inspection that included 

a review of the licensee material control and accounting procedures. 

According to an NRC official, current material control and accounting 

procedures appear to be adequate, but there were some problems with past 

accounting practices. The licensee has completed its physical search of the 

spent fuel pool and other areas of the plant for the three rod segments and 

has not conclusively identified the missing three 18-inch segments. The 

licensee is continuing its review of plant records as well as interviewing 

plant personnel who may have knowledge of the whereabouts of the three 

fuel rod segments. The licensee issued an interim report of its search 

results and evaluations at the end of February 2005. NRC plans to issue an 

interim inspection report after reviewing the licensee interim report. A final 

inspection report will not be issued until the licensee completes its 

investigation, currently expected in May 2005.

Other Facilities Another example of an inaccurately accounted-for fuel rod occurred at a 

plant that is being decommissioned. The material from its spent fuel pool is 

being moved to dry cask storage. In 1974, a failed fuel assembly was being 

disassembled because it was leaking. A fuel rod from this assembly was 

found to be completely broken in two. The broken rod was supposed to 

have been put in a fuel rod storage basket in the spent fuel pool. In 1997, an 

attempt was made to verify the presence of the 16-inch fuel rod segment 

before the basket was placed into a dry storage cask. The attempt failed, 

and because the basket was too tall, it was not placed into the dry storage 

cask at that time. In October 2001, because of the case of the lost fuel rods 

at Millstone, the licensee decided to again inspect the basket to verify the 

presence of the fuel rod segment. While the licensee successfully examined 

the basket, it did not find the fuel rod segment. The licensee undertook a 

complete review of the site’s spent fuel records and concluded that the 

accounting failure resulted from (1) the poor visual clarity in the spent fuel 

pool at the time the fuel rod fragment was being placed in the basket and 

(2) inadequate care by the operators performing the task. The licensee also 

concluded that the fuel rod segment did not contain any fuel pellets 

because when the fuel rod broke, the pellets were ejected into the reactor 

cooling system and ultimately ground into powder. In January 2002, when 

NRC regional inspectors performed a special inspection at the plant 

concerning this issue, the inspectors did not take issue with the licensee’s 

conclusions concerning the missing fuel rod. However, they did find that—
Page 15 GAO-05-339 Nuclear Regulatory Commission

since the same procedures were being used at the other operating plants on 

site—the licensee should examine the fuel assembly and fuel rod storage 

baskets at these locations to determine that the fuel rods that are supposed 

to be in them are actually present. In February 2004, NRC inspectors 

reported that the licensee had inspected the baskets and determined that 

the existing inventory sheets were correct. NRC closed this matter.

NRC is also aware of additional instances of lost or unaccounted-for spent 

fuel. In 1990, a nuclear power plant shipped one more spent fuel rod than 

planned. The licensee discovered the discrepancy in 1991, then notified 

NRC and corrected its records. On several occasions, licensees reported 

“lost” or “missing” spent fuel, but, according to NRC, in each case, the spent 

fuel was actually known to be contained within the facility, either in the 

reactor coolant system, the spent fuel pool, or a refueling pathway. 

The potential exists for missing or unaccounted-for spent fuel rods to be 

discovered at additional plants. NRC’s inspections at plants in response to 

the Millstone incident revealed that many nuclear power sites (a site may 

consist of more than one plant) had removed spent fuel rods from fuel 

assemblies or had reconstituted fuel assemblies.8

 In performing these 

inspections, NRC inspectors were to obtain from the licensee a list of all 

irradiated or spent fuel rods that have been removed from their parent 

assembly. Using the current fuel pool map, the inspectors were to identify 

the presumed location of the separated rods. Then, by observing from the 

edge of the pool, the inspector was to answer whether there were rods in 

all of the locations on the map identified as containing separate rods. At 

some of these sites, this was not possible. Some containers where rods 

were presumably stored were closed or their contents were not visible. 

Even when containers were not closed, some contents were unverifiable 

because of poor water clarity and lighting and container design. According 

to NRC officials, the agency has preliminarily chosen these sites for further 

inspection. 

8

These 70 sites include 65 operating and 4 decommissioning nuclear reactor sites and 1 wet 

storage site.
Page 16 GAO-05-339 Nuclear Regulatory Commission

NRC Regulations and 

Oversight Activities 

Are Insufficient to 

Ensure Control of All 

Spent Fuel

Although NRC requires nuclear power plants to maintain an accurate 

record of their spent fuel and its location, agency regulations do not specify 

how licensees are to conduct physical inventories of this material nor how 

they are to control and account for loose or separated spent fuel rods and 

fragments. In addition, NRC oversight does not include routine monitoring 

of plants’ compliance with its material control and accounting regulations. 

NRC Regulations to Control 

and Account for Special 

Nuclear Materials Have 

Several Shortcomings

Under NRC regulations, reactor licensees are required to maintain and 

follow written procedures sufficiently to enable them to control and 

account for their special nuclear material. They are to keep records 

showing the receipt, inventory (including location), disposal, and transfer 

of all special nuclear material. Each record of receipt, acquisition, or 

physical inventory of special nuclear material must be retained as long as 

the licensee has possession of the material and for 3 years following any 

transfer of such material. Physical inventories of special nuclear material 

must be performed at least annually. However, NRC guidance for material 

control and accounting of spent nuclear fuel does not characterize what 

constitutes a physical inventory nor how to conduct one.

NRC regulations define physical inventory as the means to determine on a 

measured basis the quantity of special nuclear material on hand at a given 

time. The regulations also state that the methods of physical inventory and 

associated measurements will vary depending on the material being 

inventoried and the processes involved. As a result, licensees implement 

the physical inventory requirement in different ways. NRC resident 

inspectors found that inventories may include anything from comparing a 

map with the assembly racks in the spent fuel pool to performing a 

comprehensive identification of fuel assemblies according to their serial 

numbers. For example, at one site, the NRC resident inspector reported 

that the annual inventory is performed in a “piece counting” manner and 

does not specifically verify the bundle serial number and fuel pool location. 

At another site, the NRC resident inspector reported that the annual 

inventory is only conducted for special nuclear material that has been 

moved since the last audit. Further, according to an NRC program official, 

no definition of physical inventory is provided in NRC’s regulatory 

guidance for spent fuel because the concept of physical inventory is a 

simple “first course in accounting” term. That is, a physical identification of 

items for the purpose of determining the number of items physically on 

hand and for comparison with a “book” record, which is the listing of items 
Page 17 GAO-05-339 Nuclear Regulatory Commission

according to the accounting records. This NRC official also stated that it’s 

what large retailers do at least once a year, it’s a well-understood concept, 

and it has never been thought to require clarification until now. An NRC 

resident inspector at still another site told us that the annual physical 

inventory was an office paperwork review to ensure that all the “i’s were 

dotted and t’s were crossed” from past material movements and transfers. 

The resident inspector added that the licensee had never actually opened 

its storage container to visually verify the accuracy of the paperwork. In 

responding to our survey, several resident inspectors suggested that if 

licensees sealed their containers—for example, with tamper-safe sealing—

the containers would not have to be opened during the physical inventory. 

According to NRC officials, verification of items in spent fuel pools is 

difficult and time consuming, raises concerns about radiation exposure, 

and can be costly. 

Additionally, although NRC regulations state that licensees are to control 

and account for all special nuclear material, the regulations do not 

specifically require licensees to track individual fuel rods or fragments that 

may be stored in their spent fuel pools. Further, individual rods, fragments, 

or other controlled special nuclear material may or may not be specifically 

accounted for in licensees’ inventories.9

 As a result, licensees employed 

various methods of storing and accounting for this material. For example, 

according to an NRC resident inspector, at one plant the spent fuel rods are 

in a closed container in a designated area of the spent fuel pool. According 

to the licensee’s procedures, the canister is opened every 6 years and the 

presence of the correct number of rods is verified. At another plant, the 

licensee told the resident inspector that it was not sure how many fuel rod 

fragments are in two storage baskets or how the fragments might be 

divided up between the baskets. In responding to our survey, several NRC 

resident inspectors described current practices and offered suggestions for 

best practices for storing and controlling loose rods and segments. Several 

respondents described placing loose spent fuel in “dummy” or “skeleton” 

fuel assemblies, which are empty of fuel, or only in specially designed and 

approved containers placed in designated cells and racks in the spent fuel 

pool. In addition, one resident inspector suggested that given that fuel rod 

breaks are often the result of reconstitution, a best practice would be for 

the reconstitution of fuel assemblies to be done off site. 

9

Fuel rods may fail for a variety of reasons, such as corrosion or gases leaking from the 

tubes that hold the rods.
Page 18 GAO-05-339 Nuclear Regulatory Commission

Licensees of nuclear power plants also control and account for their 

inventories of spent fuel to help meet requirements relating to U.S. treaty 

obligations for the control of nuclear material. NRC regulations require 

power reactor licensees to submit a Nuclear Material Transaction Report to 

the Nuclear Materials Management and Safeguards System every time their 

facilities receive or transfer special nuclear material or make corrections to 

their material balances. At least once a year, licensees must also submit to 

the system material balance reports concerning special nuclear material 

received, produced, possessed, transferred, consumed, disposed of, or lost, 

and inventory composition reports. This system, which is managed by the 

DOE and partially supported by NRC, is operated by a DOE contractor. 

Because reporting to the system is done in the amount or weight of the 

nuclear material, such as plutonium, rather than the number of items of 

spent fuel, nuclear power plant licensees use complex computer programs 

to provide estimates of the amount of special nuclear material that these 

items contain. According to plant officials we spoke with, their sites send 

their annual inventory information to their corporate headquarters to be 

calculated and reported to the Nuclear Materials Management and 

Safeguards System contractor.

NRC Does Not Monitor 

Plants’ Compliance with Its 

Material Control and 

Accounting Regulations

Since 1988, NRC inspections of power reactor licensees’ compliance with 

material control and accounting requirements have been done on an 

exception-only basis—that is, if a particular problem or incident was 

reported by the licensee or identified by NRC that warranted investigating. 

Since 1988, NRC has not routinely monitored licensee compliance with 

material control and accounting regulations or verified that licensees’ 

inventories are complete and accurate.

In 1984, NRC’s overall inspection program for monitoring nuclear power 

plants’ compliance with their licenses had three parts: (1) a minimum 

program to be completed at all operating nuclear facilities without 

exception, (2) a basic program to be completed at all operating facilities, 

but under some circumstances parts did not have to be completed because 

of extraordinary demands on limited inspection resources, and (3) a 

supplemental program of additional inspections to be done on the basis of 

an assessed need or problems at a facility. According to NRC, the basic 

program included material control and accounting inspections to be 

conducted once every 3 years. In 1988, according to NRC officials, this 

requirement for the periodic inspections of material control and accounting
Page 19 GAO-05-339 Nuclear Regulatory Commission

was discontinued.10 Officials said that although there is no written 

documentation available, these inspections were discontinued because 

spent fuel stored in spent fuel pools was considered to be “self protecting;” 

that is, the fuel bundles are heavy, highly radioactive, and contained in 40-

foot deep pools of water. Spent fuel was viewed as a low-risk danger to 

public health and the environment and a low priority for use of NRC’s 

resources.

NRC substantially revised its nuclear reactor oversight process in 2000, but 

did not reinstitute routine material control and accounting inspections. 

According to NRC, the new process—called the Reactor Oversight 

Process—uses more objective, timely, and safety-significant criteria in 

assessing nuclear plant performance. NRC stated that the revised program 

includes baseline inspections common to all nuclear plants and focuses on 

activities and systems that are risk significant—that is, those activities and 

systems that have a potential to trigger an accident, increase the 

consequences of an accident, or mitigate the effects of an accident. The 

Reactor Oversight Process also allows for inspections beyond the baseline 

program if there are operational problems or events that NRC believes 

require greater scrutiny. Material control and accounting fall under this 

criteria. When the new process was being developed, NRC officials 

continued to believe that the material in spent fuel pools was self 

protecting and that it was appropriate to perform material control and 

accounting inspections on an exception-only basis. NRC officials told us 

that there were no indications prior to the discovery of missing fuel rods at 

Millstone that routine inspections were needed. 

According to NRC officials, a few Reactor Oversight Process inspections 

can indirectly involve NRC inspections of licensees’ material control and 

accounting programs. One of these inspections is of licensee operations 

during refueling of the reactor. This inspection includes verifying that the 

location of fuel assemblies is being tracked and that discharged fuel 

assemblies are placed in permissible locations in the spent fuel pool. To 

perform such an inspection, NRC inspectors observe the movement of a 

sample of fuel bundles between the reactor core and the spent fuel pool. 

NRC officials told us that material control and accounting problems with 

spent fuel may also be reviewed under plant status inspections. These 

inspections involve a number of activities surrounding NRC resident 

10Current NRC officials stated that the 1988 change was made because no problems with 

material control and accounting for spent fuel had been identified at that time. 
Page 20 GAO-05-339 Nuclear Regulatory Commission

inspectors’ efforts to be aware of emergent plant issues, potential adverse 

trends, equipment problems, and other ongoing activities that may impact 

the plant’s safety risks. These efforts include control room walkdowns, 

attending licensee meetings, and weekly plant tours. Inspectors generally 

would not learn of material control and accounting problems during one of 

these inspectors unless the licensee was aware of them and raised them 

during meetings with the inspectors. In addition, a few NRC resident 

inspectors that we surveyed mentioned some review of spent fuel records 

during the loading of dry storage fuel casks.

NRC Is Studying Spent 

Fuel Control and 

Accounting Problems 

but Has Yet to Revise 

Its Regulations or 

Oversight Policies

In light of the missing or unaccounted-for spent fuel at Millstone and 

subsequently at other locations, NRC has various activities under way to 

assess the need to revise its regulations and oversight of spent fuel. While 

final completion dates for these efforts have not been set, it will likely be 

late in 2005 before all of them will be completed. This date would be over 5 

years after the spent fuel rods were first found missing at Millstone in 2000. 

We believe that after the more recent instances of missing spent fuel at 

Vermont Yankee and Humboldt Bay, the 2003 NRC Office of the Inspector 

General report outlining weaknesses in NRC’s oversight of special nuclear 

materials (including spent fuel), and information collected during its 

ongoing efforts, NRC has considerable information that suggests the need 

to address nuclear power plants’ material control and accounting 

problems, including compliance with NRC regulations. According to NRC 

officials, they plan to submit the results of these activities to the NRC 

Commissioners in the spring of 2005. The Commissioners will decide what, 

if any, actions will be taken in response to the findings. 

NRC Is Using a 

Multifaceted, Phased 

Approach to Assess the 

Need to Revise Its 

Regulations and Oversight

NRC has three principal activities under way to assess the need to revise its 

regulations and oversight of spent fuel. These are (1) a three-phase project 

under which NRC inspectors are collecting information on the status of 

material control and accounting programs at individual plants; (2) a 

comprehensive program review of NRC material control and accounting 

programs for special nuclear materials, including spent fuel, through the 

contract with DOE’s Oak Ridge National Laboratory; and (3) a bulletin 

issued on February 11, 2005, to nuclear power plant licensees requesting 

information concerning their compliance with NRC material control and 

accounting regulations. 
Page 21 GAO-05-339 Nuclear Regulatory Commission

In November 2003, NRC issued a temporary instruction (TI) to its 

inspection manual.11 NRC’s overall objective in issuing the TI was to gather 

site-specific information on nuclear power plants’ material control and 

accounting programs to determine if the issues affecting the missing spent 

fuel rods at Millstone were present at other power plants. More specifically, 

NRC wanted to obtain enough information to determine if

• material control and accounting guidance for nuclear power plants 

should be modified to reduce the possibility of a licensee losing spent 

fuel rods in the future;

• licensees can account for all spent fuel, including any rods that have 

been separated from their parent assembly; and

• all items of spent fuel listed in the spent fuel inventory, including rods 

that have been separated from their parent assembly, can be located in 

the spent fuel pool.

The TI also called for obtaining site-specific data for the purposes of 

improving the plants’ material control and accounting programs. According 

to the TI, several inspection activities were aimed at identifying conditions 

for future program improvement rather than inspections for compliance 

with regulatory requirements.

NRC is carrying out the TI in three phases. Phases I and II have been 

completed. In phase I, NRC regional and/or resident inspectors determined 

if nuclear power plant licensees had ever removed irradiated (spent) fuel 

rods from an assembly or had reconstituted fuel assemblies. For licensees 

that had removed rods or reconstituted assemblies, phase II was 

conducted. During phase II, inspectors used inspections and interviews to 

fill out a questionnaire about the licensees’ material control and accounting 

programs. Among the questions were the following:

• Does the licensee have a program that tracks individual fuel rods from 

the point of removal from a fuel assembly to where they are stored in 

the spent fuel pool and to their final destination?

11NRC considers this instruction, Spent Fuel Material Control and Accounting at Nuclear 

Power Plants (Temporary Instruction 2515/154, Nov. 26. 2003), to be temporary because it 

provides for a one-time inspection and has a short-term expiration date, currently scheduled 

for November 2005. 
Page 22 GAO-05-339 Nuclear Regulatory Commission

• Are there rods in all of the locations identified on the spent fuel map (or 

equivalent) as containing separated rods? (The inspectors were 

instructed to obtain from licensees a list of all spent fuel rods that had 

been removed from their parent assembly and, to the extent possible, 

answer this question by observing from the edge of the spent fuel pool. 

If the rods were stored in a closed container, they were to report this 

under the “Comments” section of the questionnaire.)

• Does the licensee have written material control and accounting 

procedures approved by licensee management?

• Does the licensee have written procedures for the movement of 

individual spent fuel rods within the spent fuel pool?

• Does the licensee have procedures for performing oversight of all spent 

fuel pool operations?

• Does the licensee have records documenting spent fuel pool operations 

conducted by contractors or fuel vendors?

• Does the licensee perform an annual physical inventory of the spent fuel 

pool that includes resolution of all discrepancies?

The TI did not specify an approach to answering the questions but instead 

allowed the resident inspectors to use their best judgment and experience. 

Our survey of NRC’s senior resident inspectors identified some differences 

in what the inspectors did to answer the phase II questions. The inspectors 

generally interviewed licensee staff and reviewed licensees’ records and 

written procedures. For the most part, they also used the licensee’s map to 

verify materials in the spent fuel pool. About half used visual tools such as 

binoculars or underwater cameras to verify materials in the spent fuel pool. 

About one-fifth observed licensee activities.

Phase III, which has not begun, is to expand on the questions in phase II 

with more detailed inspection and review of site documentation to verify 

that procedures or controls are implemented and that they are adequate. 

For a sample of sites, including those for which “no” was answered to any 

of the phase II questions, personnel with material control and accounting 

expertise, rather than the regional and on-site inspectors, are to carry out 

the activities.
Page 23 GAO-05-339 Nuclear Regulatory Commission

The TI called for phases I and II to be completed within 6 months (by May 

2004) and phase III within 18 months (by May 2005). Phases I and II were 

carried out from January 2004 to May 2004. The phase I review at 70 sites—

all 103 operating nuclear power plants at 65 sites (a site may contain more 

than one nuclear power plant), decommissioning plants at 4 sites, and 1 

wet storage facility—identified 65 sites that had removed irradiated fuel 

rods from an assembly or had reconstituted fuel assemblies.12 Phase II was 

conducted for these sites. On the basis of the phase II results, NRC officials 

determined that at least 19 sites were candidates for more detailed phase 

III review because NRC inspectors identified that the site had two or more 

programmatic issues. As of February 2005, NRC officials told us that they 

are in the planning stages for phase III inspections. Because the TI expires 

2 years after its November 2003 issuance, if the phase III inspection were to 

be performed before this, it would be late 2005 before the project would be 

completed.

In September 2001, shortly after the terrorist attacks on the World Trade 

Center and the Pentagon, the Chairman of NRC directed the staff to 

undertake a comprehensive review of all the agency’s safeguards and 

security programs. NRC contracted with the Oak Ridge National 

Laboratory in August 2003 to review NRC’s material control and accounting 

programs for special nuclear materials at all NRC licensees. This contract, 

which according to an NRC official was for about $500,000, was part of a 

broader NRC effort. The Oak Ridge laboratory, which was chosen because 

of its expertise in material control and accounting, began the work under 

the contract in September 2003. Its four principal tasks were to (1) review 

NRC’s current material control and accounting requirements, (2) discuss 

material control and accounting with current and former employees 

involved in these activities, (3) visit selected facilities representing 

different types of special nuclear material licensees to explore current 

material control and accounting requirements and inspection practices at 

each site, and (4) develop a report that offers Oak Ridge’s views on NRC’s 

material control and accounting requirements across the range of NRClicensed facilities, discusses any concerns or deficiencies with the current 

regulations and inspection practices, and provides specific 

recommendations for programmatic changes. Oak Ridge submitted its 

report in August 2004 and concluded its work with a management briefing 

in October 2004. NRC is currently reviewing the report. According to NRC 

12The phase I review also included decommissioned power plants with wet storage and one 

wet storage facility.
Page 24 GAO-05-339 Nuclear Regulatory Commission

officials, the staff will complete its review of the report and consider the 

results of its review, as well as additional recommendations from the staff, 

in developing a paper to the NRC Commissioners. The paper is due to the 

Commissioners by spring 2005.

In February 2005, NRC issued a bulletin to holders of operating licenses for 

nuclear power plants, decommissioning nuclear power plants storing spent 

fuel in a pool, and wet spent fuel storage sites. The bulletin, which requests 

information about procedural controls and inventories, responds to issues 

involving accounting and control of spent (and other irradiated) nuclear 

fuel, which were first identified at Millstone and then at Vermont Yankee 

and Humboldt Bay. The purpose of the bulletin is to gather specific 

information from the licensees about the status of control and accounting 

of special nuclear material at power reactors and other facilities with wet 

storage of irradiated fuel. NRC officials told us that results from the 

bulletin will contribute to assessing the need to revise the current NRC 

material control and accounting regulations and inspection program. The 

results from the bulletin will also determine where phase III inspections 

will be conducted. 

NRC Has Considerable 

Information Indicating 

Problems with the Control 

and Accounting for Spent 

Fuel

The data collected by NRC inspectors during phases I and II of the TI 

identified material control and accounting problems or shortcomings. Of 

the sites that had removed fuel rods from their parent assemblies or had 

reconstituted fuel assemblies, the inspectors reported that some sites did 

not appear to be in compliance with all of NRC’s material control and 

accounting requirements or otherwise had questionable material control 

and accounting practices involving procedures, physical inventory, 

accounting records, or tracking and control. 

Additionally, in May 2003, NRC’s Office of the Inspector General (OIG) 

issued its report, Audit of NRC’s Regulatory Oversight of Special Nuclear 

Materials.

13 In its report, the OIG concluded that NRC’s oversight did not 

provide adequate assurance that all licensees properly control and account 

for special nuclear material. The OIG found that NRC performed limited 

inspections of licensees’ material control and accounting activities and 

could not assure the reliability of the tracking system for special nuclear 

material. It stated that NRC managers believed that most spent fuel is self13OIG-03-A-15, May 23, 2003.
Page 25 GAO-05-339 Nuclear Regulatory Commission

protecting from a health and safety point of view and that the risk of 

undetected loss, theft, or diversion of special nuclear material at power 

reactors is low. Therefore, according to the OIG, NRC trusts power reactor 

licensees to implement their material control and accounting activities 

effectively. The OIG further concluded that without adequate routine 

inspections of these activities, NRC cannot reasonably ensure that 

licensees are controlling and fully accounting for special nuclear material. 

The OIG recommended, among other things, that NRC conduct periodic 

inspections to verify that licensees comply with material control and 

accounting requirements, including, but not limited to, visual inspection of 

licensees’ special nuclear material inventories and validation of report 

information.

In its October 2003 response to the OIG recommendation, NRC said that its 

staff planned to perform a review of the agency’s material control and 

accounting program (which it did by commissioning the Oak Ridge study) 

as part of a comprehensive review of the agency’s safeguards and security 

program. NRC added that based on the results of the program review, the 

staff will determine what changes need to be made to the inspection 

program. According to NRC’s response, any decision to change the 

inspection program would be made during fiscal year 2005, following 

completion of the program review. In February 2004, the OIG responded by 

stating that delaying any decision to make changes to the material control 

and accounting inspection program until fiscal year 2005 was untimely and 

did not reflect the importance of ensuring licensee’s compliance with 

material control and accounting requirements. In March 2004, NRC replied 

that the staff considered the program review to be vital to developing and 

documenting the regulatory basis for subsequent permanent revisions to 

the inspection program. An NRC official told us that once the Oak Ridge 

study has been completed and its findings and recommendations have been 

addressed, the OIG’s recommendation can be closed. The staff currently 

anticipates that it will develop specific recommendations and submit them 

to the NRC Commissioners during the spring of 2005.

Conclusions The effectiveness of nuclear power plants’ efforts to control and account 

for their spent fuel is uneven. A number of plants have experienced 

instances of missing or unaccounted-for spent fuel, and NRC has identified 

weaknesses in the material control and accounting programs at various 

other plants. Contributing to this unevenness is the fact that NRC 

regulations do not specifically require plants to control and account for 

loose rods or segments of rods. Although loose spent fuel rods do not 
Page 26 GAO-05-339 Nuclear Regulatory Commission

appear to have been a concern when NRC developed its regulations, recent 

information collected by NRC indicates that most plants have removed 

rods from their fuel assemblies or reconstituted fuel assemblies. NRC data 

further indicate that plants are treating loose rods and segments differently 

under their material control and accounting programs. The absence of 

specific guidance in NRC regulations for how licensees should conduct 

physical inventories has also resulted in unevenness in licensees’ 

compliance with these important requirements.

Loose spent fuel rods and rod segments also were not an issue when NRC 

stopped inspecting licensees’ compliance with material control and 

accounting regulations. Spent fuel was generally viewed in terms of fuel 

assemblies, which NRC considered to be, in effect, self-protecting because 

of their high radioactivity and large size and weight. However, individual 

rods, and especially rod segments, are also highly radioactive and are much 

smaller and lighter than fuel assemblies. This issue was first raised in 2000, 

with the loss of spent fuel rods at Millstone. The occurrences of missing or 

unaccounted-for spent fuel rods and the unevenness in licensees’ 

compliance with material control and accounting requirements highlight 

the need for more effective oversight of these programs. In the aftermath of 

terrorist attacks on the United States, material control and accounting of 

spent nuclear fuel has become more important. Material control and 

accounting requirements are of great importance because of the potential 

health and safety consequences of failing to effectively account for and 

control spent nuclear fuel. While NRC’s multifaceted and phased approach 

to these issues may have been appropriate in the initial context of a single 

incident at Millstone, waiting longer to make a decision on changes in the 

agency’s regulations and oversight is—as the OIG stated in February 

2004—not timely and does not fully reflect the importance of ensuring that 

licensees comply with control and accounting requirements for spent fuel. 

We believe that NRC has sufficient information about problems with 

material control and accounting at nuclear power plants to proceed with 

revising NRC’s regulations and oversight.

Recommendations for 

Executive Action

To improve the effectiveness of nuclear reactor licensees’ material control 

and accounting programs for spent nuclear fuel, we recommend that the 

NRC Commissioners take action, in a timely manner, on the following two 

items:
Page 27 GAO-05-339 Nuclear Regulatory Commission

• Establish specific requirements for the control and accounting of loose 

spent fuel rods and rod segments and nuclear reactor licensees’ conduct 

of their physical inventories. 

• Develop and implement appropriate inspection procedures to verify 

compliance and assess the effectiveness of licensees’ material control 

and accounting programs for spent fuel.

Agency Comments We provided a draft of this report to NRC for review and comment. In its 

written comments (see app. III), NRC generally agreed with the report’s 

conclusions and stated that, overall, the report is well written and 

balanced. Regarding our recommendation that NRC establish specific 

requirements for the control and accounting of loose spent fuel rods and 

rod segments and nuclear reactor licensees’ conduct of their physical 

inventories, NRC stated that it will develop guidance concerning control 

and accounting of rods and pieces of spent nuclear fuel and the conduct of 

physical inventories. According to NRC, its current regulations are clear 

that licensees are required to keep complete records of and conduct annual 

physical inventories of all special nuclear material, but the implementation 

guidance does need to be enhanced. Regarding our recommendation that 

NRC develop and implement appropriate inspection procedures to verify 

compliance and assess the effectiveness of licensees’ material control and 

accounting programs for spent fuel, NRC said that it plans to revise its 

existing procedures for inspecting material control and accounting for 

spent nuclear fuel to include instruction on inspecting control and 

accounting of rods and pieces. 

In addition to comments directly relating to our recommendations, NRC 

offered a number of comments concerning the report’s context. For 

example, NRC said that its development and issuance of its temporary 

instruction was postponed by the need to devote NRC’s limited resources 

to areas requiring more immediate attention, especially the comprehensive 

security and radiological protection activities conducted after the 

September 11, 2001, terrorist attacks. NRC also said that the report needs 

to provide balance by giving credit to NRC for making prioritized decisions 

based on a variety of factors, including, but not limited to, risk of 

malevolent action, attractiveness of the material for potential malevolent 

activities, other controls, and available personnel resources. According to 

NRC, there is no reason to conclude that any of the missing fuel segments 

were removed for any malevolent purpose. NRC further stated that the 

report does not make sufficiently clear that the problems at Vermont 
Page 28 GAO-05-339 Nuclear Regulatory Commission

Yankee were identified as a direct result of NRC’s implementation of its 

temporary instruction and that implementation of the temporary 

instruction also helped identify the problems at Humboldt Bay. We believe 

that our report provides sufficient context for the issues relating to the 

instances of unaccounted-for spent nuclear fuel. It also devotes 

considerable attention to describing NRC’s actions in response to those 

instances, including efforts already under way when we began our review. 

We have added language to the report to emphasize that NRC’s actions in 

response to the Millstone incident led directly to identifying the problems 

at Vermont Yankee and helped identify the problems at Humboldt Bay. 

While we also agree that there is no evidence that any of the missing fuel 

segments were removed for malevolent purposes, we note that it is still not 

certain what happened to the missing spent fuel at Millstone and Humboldt 

Bay. 

As agreed with your offices, unless you publicly announce its contents 

earlier, we plan no further distribution of this report until 30 days from the 

date of its issuance. At that time, we will send copies of this report to 

interested congressional committees, the Chairman of NRC, and other 

interested parties. We will make copies available to others upon request. In 

addition, the report will be available at no charge on the GAO Web site at 

http://www.gao.gov.

If you or your staffs have any questions about this report, please call me at 

(202) 512-3841 or contact me at Wellsj@gao.gov. Key contributors to this 

report are listed in appendix IV.

Jim Wells

Director, Natural Resources and Environment
Page 29 GAO-05-339 Nuclear Regulatory Commission

Appendix I

Scope and Methodology ApApenednxidexiIs

To assess nuclear power plants’ performance in controlling and accounting 

for their spent nuclear fuel, we reviewed and analyzed relevant documents, 

including Nuclear Regulatory Commission (NRC) and nuclear power plant 

licensees’ event inquiry reports and NRC studies and investigations of 

missing spent fuel rods. We also interviewed NRC and nuclear power plant 

officials and conducted two site visits to nuclear power plants. In the 

context of this report, control and accounting for spent nuclear fuel refers 

to plants’ tracking of and recordkeeping for the movement and storage of 

their spent nuclear fuel. We did not assess plant safety procedures for 

handling or storage of spent fuel or plant security and the vulnerability of 

spent fuel to theft or terrorist attacks.

To assess NRC’s material control and accounting requirements for spent 

fuel stored at nuclear power sites, we reviewed and analyzed relevant 

legislation, regulations, and NRC orders and policies and we interviewed 

NRC and industry officials to identify the key NRC requirements and how 

they are implemented. 

To determine how NRC performs oversight of nuclear power plants’ 

material control and accounting activities, we reviewed NRC inspection 

policies, instructions, and reports; analyzed relevant NRC Inspector 

General reports and internal NRC analyses and studies; and interviewed 

appropriate NRC program and regional officials. To determine the status of 

NRC’s actions and plans in response to licensees’ spent fuel control and 

accounting problems, we reviewed internal NRC memorandums, 

instructions, and reports and interviewed appropriate program officials.

To further explore how NRC performs oversight of control and accounting 

activities for spent fuel at nuclear power plants, we conducted an e-mail 

survey of all NRC lead/senior inspectors located on site at the plants about 

NRC inspection practices, management controls, and the inspectors’ 

suggestions for improvements, if viewed necessary. There are no sampling 

errors because this was not a sample survey; rather, we sent and received a 

response from every lead/senior inspector at every site.

Nonetheless, the practical difficulties in developing and administering any 

survey may introduce errors, commonly referred to as nonsampling errors. 

For example, difficulties may arise in how a particular question is 

interpreted or from differences in experiences and information available to 

respondents when answering a question. We took steps in the development 

of the survey, its administration, and the data editing to minimize these 

nonsampling errors. We conducted three pretests of the survey instrument. 
Appendix I

Scope and Methodology

Page 30 GAO-05-339 Nuclear Regulatory Commission

The first pretest was with two inspectors at one location by telephone; the 

second and third pretests were with expert NRC officials, both by 

telephone. We modified the survey instrument to reflect questions, 

comments, and concerns received during the pretests. The instrument was 

also internally reviewed by one of our survey methodologists. In addition, 

we edited all completed surveys for consistency and contacted NRC 

inspectors to clarify responses whenever necessary. While our survey 

responses reflect the opinions of NRC resident inspectors, to ensure the 

reliability that our survey data was accurate and complete and that 

spreadsheet calculations were correct, 100 percent of the data entry and all 

formulas were internally and independently checked and verified. 

Through discussions with appropriate NRC officials, we determined in the 

course of developing our survey that although there are 103 plants 

currently in operation in the United States, some reactors are colocated on 

a total of 65 sites. Because only one of the two or three inspectors assigned 

to each site is designated as the lead NRC authority, we sent our survey to 

that person. Therefore, we sent our survey to a total of 65 senior/lead NRC 

inspectors. We expected that given their experience, the lead/senior 

inspector would obtain additional views and input from the other resident 

inspectors if they felt it was needed. For example, this additional input 

would be important if the other inspectors performed the requirements of 

the temporary instruction for inspection of material control and accounting 

at nuclear power sites, or if the senior resident was newer to and, 

therefore, less familiar with the practices and history of the material 

control and accounting program at the site. We received 67 responses to 

our survey. In one case, we received a response from the senior inspector 

and an additional resident inspector at the same site. We kept only the 

senior inspector’s response in our analysis and deleted the other response 

from that site. In the second instance where we received two responses 

from one site, special circumstances at that site provided for two senior 

resident inspectors, but one of those inspectors is primarily responsible for 

the recovery effort of one of the units at that site. We excluded that 

inspector’s response from our analysis, retaining only the response from 

the senior inspector with the more general role. This left us with 65 

responses for a 100 percent response rate. The detailed results of our 

survey of NRC resident inspectors are presented in appendix II. 

We performed our work primarily in Washington, D.C., between July 2004 

and February 2005, in accordance with generally accepted government 

auditing standards.
Page 31 GAO-05-339 Nuclear Regulatory Commission

Appendix II

Summary Results of GAO Survey of NRC 

Senior/Lead Resident Inspectors ApendxiI

Overall, we received 65 responses to our survey. Our detailed scope and 

methodology (Appendix 1) contains particulars regarding the development and 

administration of the survey. Not all of the respondents answered all questions. 

This may have been a result of either the respondent’s choice or they may have been 

instructed to skip a question according to their previous response. Throughout this 

appendix, we will note the number of respondents answering each question by 

noting “n=number of respondents to this question”. 

~~~~~~~~~~~~~~~~~~~~~~~~~~~~~~~~~~~~~~~~~~~~~~~

Introduction:

The Vermont congressional delegation, along with a member from a nearby 

Massachusetts district, has asked the U. S. Government Accountability Office to 

review the NRC’s oversight of licensees’ material control and accounting program for 

spent nuclear fuel at commercial nuclear power plants. 

As part of our review, we have met with NRC officials in headquarters and at the 

regional level. We have spent a day touring a nuclear power plant, discussing and 

reviewing licensee procedures. With this survey, we are gathering information on 

resident inspectors’ activities and views related to this issue. We are distributing the 

following survey to all NRC senior resident inspectors. 

Your contribution to our efforts is gratefully appreciated. The information you 

provide will assist us in responding to Congressional interest on this important issue. 

Please complete and return this survey by November 24, 2004 

Instructions:

Simply reply to this email by selecting "Reply to Sender (include message)" and then 

type in your responses by the return date. Although we are sending this to senior 

resident inspectors, please feel free to include other resident inspectors at your site 

in developing your answers. If you do include other inspectors, please provide the 

contact information of all inspectors contributing to the survey in Question 1. 

If you have any questions about this survey or have problems submitting your 

response, please contact Melissa A. Roye by phone at (202) 512-6426 or by email at 

RoyeM@gao.gov.

~~~~~~~~~~~~~~~~~~~BEGIN SURVEY~~~~~~~~~~~~~~~~~~~ 
Appendix II

Summary Results of GAO Survey of NRC 

Senior/Lead Resident Inspectors

Page 32 GAO-05-339 Nuclear Regulatory Commission

Page 2

Background Information:

1. In case we would like to clarify any of your responses, please provide the 

following information for ALL persons involved in submitting information requested 

in this survey (please copy and paste fields for Respondent 3+, if necessary): 

Respondent 1 (n=65) 

Name:

Title:

Phone number: 

Site Name/Location: 

Months at current site:

Months as SRI or RI at any site:

Months at NRC:

Respondent 2

Name:

Title:

Phone number: 

Site Name/Location: 

Months at current site:

Months as SRI or RI at any site:

Months at NRC:

Material Control and Accounting Related Activities:

2. What did you do to execute the requirements of “Spent Fuel Material Control and 

Accounting at Nuclear Power Plants,” Temporary Instruction (TI) 2515/154? 

Please mark all that apply. (n=65) 

[ 57 ] Interviews 

[ 54 ] Records review 

[ 53 ] Review of licensee's written procedures 

[ 14 ] Observation of licensee activities

[ 49 ] Verification of materials in the spent fuel pool using a map 

[ 30 ] Verification of materials in the spent fuel pool using visual aides such as 

binoculars or underwater cameras 

[ 12 ] Only Phase I of the TI was completed at this site 

[ 22 ] At this site, the TI was conducted by someone else. Name of Inspector(s):

 22 provided a name and some also included an explanation. 

[ 10 ] Other? Please explain: 10 provided explanation. 

3. Do you routinely inspect or verify the licensee’s material control and accounting 

program policies, records, or procedures for spent nuclear fuel? (n=65) 

[ 23 ] Yes. Please elaborate below, if you wish. 

[ 42 ] No. Please elaborate below, if you wish. 

[ 0 ] Don’t know (Please go to question 4).
Appendix II

Summary Results of GAO Survey of NRC 

Senior/Lead Resident Inspectors

Page 33 GAO-05-339 Nuclear Regulatory Commission

Page 3

Elaboration: Overall, 42 respondents provided an elaboration. 

 Of that 42, 23 responded yes and 19 responded no. 

4. Do you engage in inspection activities under the Reactor Oversight Process (ROP) 

that indirectly involve material control and accounting for spent fuel? (n=65) 

[ 53 ] Yes. Please elaborate below, if you wish. 

[ 12 ] No. Please elaborate below, if you wish. 

[ 0 ] Don’t know (Please go to question 5)

Elaboration: Overall, 53 respondents provided an elaboration. 

 Of that 53, 49 responded yes and 4 responded no. 

5. Do you engage in additional oversight activities (beyond the requirements of the 

ROP) that aid you in assessing the licensee’s abilities for material control and 

accounting of spent fuel? (n=65) 

[ 14 ] Yes. Please elaborate below, if you wish. 

[ 50 ] No. Please elaborate below, if you wish. 

[ 1 ] Don’t know (Please go to question 6)

Elaboration: Overall, 23 respondents provided an elaboration. 

 Of that 23, 13 responded yes and 10 responded no. 

6. Do you think that the NRC should be doing more with regard to the oversight of 

material control and accounting for spent fuel? (n=65) 

[ 24 ] Yes. Please elaborate below, if you wish, and then go to question 7. 

[ 28 ] No. Please elaborate below, if you wish, and then go to question 8. 

[ 13 ] Don’t know (Please go to question 8)

Elaboration: Overall, 38 respondents provided an elaboration. 

 Of that 38, 20 responded yes, 12 responded no, and 6 responded that 

they did not know. 

7. Would you need more training to perform oversight of the licensee’s material 

control and accounting program? (n=26) 

[ 7 ] Yes. Please elaborate below, if you wish.

[ 16 ] No. Please elaborate below, if you wish.

[ 3 ] Don’t know (Please go to question 8)

Elaboration: Overall, 13 respondents provided an elaboration. 

Of that 13, 5 responded yes and 8 responded no. 

In addition, there were 23 respondents who should have skipped this 

question based on their previous response but chose to answer it 

anyway. Of that 23, 8 also provided us with further elaboration; 3 

responded yes, 3 responded no, and 2 responded that they did not 

know.
Appendix II

Summary Results of GAO Survey of NRC 

Senior/Lead Resident Inspectors

Page 34 GAO-05-339 Nuclear Regulatory Commission

Page 4

8. With regard to the material control and accounting of spent fuel, do you have any 

best practices or lessons learned to share? For example, the transferring of fuel 

pellets from broken pins into new pins, the insertion of pins into skeleton assemblies, 

or any recordkeeping improvements. (n=65) 

[ 14 ] Yes. Please elaborate below, if you wish, and then go to question 9. 

[ 47 ] No. Please elaborate below, if you wish, and then go to question 10. 

[ 4 ] Don’t know (Please go to question 10)

Elaboration: Overall, 17 respondents provided an elaboration. 

 Of that 17, 14 responded yes and 3 responded no. 

9. Please indicate if these best practices or policies: (n=12; respondents could check 

all that could apply) 

[ 9 ] Are in place at your current site. Please elaborate below, if you wish.

[ 1 ] Were learned or practiced elsewhere. Please elaborate below, if you wish.

[ 5 ] Are just something you believe can improve procedures and the oversight 

process.

Please elaborate, if you wish: 3 respondents provided elaboration. Of those three, all 

described practices or policies in place at their current site and one respondent 

stated that it is something they believe can improve procedures and the oversight 

process.

[ 1 ] Other. Please explain: One respondent provided an explanation to discuss a 

best practice or policy. 

10. Please share with us any additional comments: (n=16) 

16 respondents provided an elaboration. 

~~~~~~~~~~~~~~~~~~~END SURVEY~~~~~~~~~~~~~~~~~~~ 

Thank you for your participation.
Page 35 GAO-05-339 Nuclear Regulatory Commission

Appendix III

Comments from the Nuclear Regulatory 

Commission ApendxiI
Appendix III

Comments from the Nuclear Regulatory 

Commission

Page 36 GAO-05-339 Nuclear Regulatory Commission
Appendix III

Comments from the Nuclear Regulatory 

Commission

Page 37 GAO-05-339 Nuclear Regulatory Commission
Page 38 GAO-05-339 Nuclear Regulatory Commission

Appendix IV

GAO Contacts and Staff Acknowledgments ApendxiIV

GAO Contacts Jim Wells, (202) 512-3841

Ray Smith, (202) 512-6551

Staff 

Acknowledgments

In addition to the individuals named above, Ilene Pollack and Melissa A. 

Roye made key contributions to this report. Also contributing to this report 

were John W. Delicath, Doreen Feldman, Judy K. Pagano, Keith A. Rhodes, 

and Barbara Timmerman.

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