POLICY ISSUE 

INFORMATION 

March 30, 2010 SECY-10-0036

FOR: The Commissioners 

 

FROM: Charles L. Miller, Director 

Office of Federal and State Materials 

 and Environmental Management Programs 

SUBJECT: UPDATE ON STAFF EFFORTS TO WORK WITH FEDERAL 

 PARTNERS ON VOLUNTARY SECURITY INITIATIVES FOR 

RADIOACTIVE MATERIALS 

PURPOSE:

The purpose of this paper is to respond in part to the Staff Requirements Memorandum (SRM) 

SECY-08-0184 “Strategy for the Security and Use of Cesium-137 Chloride (CsCl) Sources,” 

dated April 15, 2009. The SRM directed the staff to continue to work with the U.S. Nuclear 

Regulatory Commission’s (NRC’s) Federal partners to implement the voluntary hardening 

program for certain blood and research irradiators and to explore other possible Federallyfunded voluntary initiatives to augment the safety and security for these essential components 

of our Nation’s infrastructure. This paper provides updated information on staff efforts to 

support the national implementation of the In-Device Delay (IDD) Security Enhancement 

program for hardening CsCl irradiators, and provides information about additional federallyfunded voluntary security enhancement initiatives for Category 1 and 2 radioactive sources1

. 

This paper does not address any new commitments or resource implications. 

CONTACT: Sarenee C. Hawkins, FSME/MSSA 

 (301)415-7562 

 

1

 The United States has made a commitment to following the International Atomic Energy Agency Code of 

Conduct on the Safety and Security of Radioactive Sources. The Code identifies categories that are 

based upon the relative health hazards each radionuclide would present if not kept under adequate 

controls. The Category 1 and 2 quantities of radioactive sources listed in the Code are considered the 

most risk significant and have been the focus of Federal and State efforts to tighten security controls. 
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BACKGROUND:

Radioactive materials are a critical and beneficial component of global medical, industrial, and 

academic efforts. The NRC and the U.S. Department of Energy’s (DOE’s) National Nuclear 

Security Administration (NNSA) have partnered with state, local, and tribal governments, other 

federal agencies, and the private sector with a common goal of preventing radiological material 

from being used in a radiation exposure device (RED) or a radiological dispersal device (RDD). 

The NRC and state regulatory agencies have created a strong and effective regulatory 

framework that includes licensing, inspection, and enforcement of more than 70,000 Category 1 

and 2 radioactive sources. This framework provides a common baseline level of security to 

ensure adequate protection of public health and safety and the common defense and security. 

The ultimate responsibility for securing radioactive materials in the U.S. rests with the licensees 

who possess these materials. To assist in that effort, NNSA works with the NRC, the materials 

licensees, state, local and tribal governments, and other federal agencies, to build on the 

existing regulatory requirements by providing voluntary security enhancements. 

These voluntary security enhancements are supplementary to and do not replace the licensee’s 

obligation to meet NRC and Agreement State regulatory requirements. These efforts are an 

excellent example of federal, state, tribal, and local agencies working in cooperation with the 

private sector to further reduce the risks of terrorism involving radioactive materials in the U.S. 

DISCUSSION:

As part of NRC’s interagency activities, the NRC staff has been working with the NRC’s federal 

partners by supporting each agency’s unique role and initiatives in the security arena to ensure 

a comprehensive system of oversight, prevention, and protection of civilian radioactive sources. 

The possibility of an RDD attack has been of particular concern because of the widespread use 

and availability of radioactive materials by industry, hospitals, and academic institutions. Loss 

or theft of Category 1 or 2 quantities of such radioactive materials, could lead to their malicious 

use in an RDD. NNSA’s Global Threat Reduction Initiative (GTRI), in cooperation with NRC and 

the Agreement States, is implementing a program for utilizing voluntary security enhancements 

at licensee facilities with these materials. These enhancements include: 

• Elimination – Removing unwanted sources, 

• Delay – CsCl irradiator IDD kits (i.e., hardening), 

• Detection/Assessment – Detection systems upgrades (e.g. remote monitoring), 

• Response – Alarm response training, and; 

• Table Top Exercises (TTX) for first responders. 

Elimination – Removing unwanted sources 

The NRC and Agreement States support and coordinate with GTRI’s Off-Site Source Recovery 

Project (OSRP) to reduce the radiological risk by recovering and removing disused and 

unwanted sealed sources. GTRI, in coordination with NRC, developed recovery prioritization 

criteria based on risk reduction. As of February 28, 2010, GTRI has recovered over 24,700 

sources (totaling more than 772,700 curies). 
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Delay – CsCl irradiator IDD 

The IDD Security Enhancement program is a threat reduction effort begun by GTRI and the 

Department of Homeland Security’s (DHS’) Domestic Nuclear Detection Office (DNDO), in 

cooperation with the NRC and the major CsCl irradiator manufacturers. DNDO’s program was 

transferred to NNSA/GTRI in May 2009 to streamline the program and integrate it into GTRI's 

overall voluntary security enhancement program. The IDD hardening program aims to increase 

the security of CsCl irradiators in the United States through the installation of security plates that 

significantly increase the delay, or time required to illicitly gain access to the CsCl sources. In 

addition to the IDD hardening kits for CsCl irradiators, voluntary security enhancements also 

include other delay elements such as device tie downs, locks, hardened doors/windows, walls, 

cages, and safes. All of these elements increase the time it would take an adversary to gain 

access to and steal the radioactive source. 

Three private sector irradiator manufacturers are coordinating with GTRI to perform the 

installations. In addition to assisting in developing and installing the hardware improvements, 

these manufacturers have indicated to GTRI their intention to install security enhancements on 

all new CsCl irradiators that they produce starting in 2010, which will ensure that new irradiators 

are better protected as they come off the production line. The device registration certificates 

have been amended by the NRC and the cognizant Agreement States to reflect this change. 

Licensees have volunteered for both the voluntary security enhancement program as a whole, 

and the IDD effort. Communications from the NRC, including NRC Regulatory Issue 

Summaries (RIS 2008-17, “Voluntary Security Enhancements for Self-Contained Irradiators 

containing Cesium Chloride Sources”, dated July 18, 2008; and RIS 2010-02, “The Global 

Threat Reduction Initiative (GTRI) Federally Funded Voluntary Security Enhancements for HighRisk Radiological Material”, dated January 21, 2010), have helped to facilitate awareness 

among licensees of the voluntary security enhancement program, which includes the IDD 

hardening program. As of February 2010, 107 of the 847 devices within the program’s scope 

have been hardened. Offered at no cost to facility operators, GTRI is funding both the 

equipment and installation of these security enhancements, which represents a national 

investment of approximately $26 million. The domestic irradiator hardening program is 

expected be completed in 2016. 

Detection/Assessment – Detection systems upgrades 

GTRI’s voluntary security enhancements program also includes upgrades to detection systems. 

Detection upgrades include biometric access control devices, door alarms, motion sensors, 

cameras, electronic tamper indicating seals, and area radiation monitors. Each of these 

technologies provides access control and/or detection functions that, when integrated together 

and with delay, provides additional enhancements to physical security in a holistic manner. In 

some cases when warranted, GTRI provides remote monitoring systems which send critical 

alarms (e.g., tamper indication and high radiation levels) simultaneously to on-site and off-site 

monitoring centers to ensure response. 

According to GTRI, the voluntary security enhancements include a 3 to 5 year maintenance and 

warranty contract for each device installed. GTRI contacts each site quarterly to follow-up on 

the status of the enhanced security system and visits each site annually to determine if changes 

are warranted. GTRI estimates that there are about 2,200 buildings within the program’s scope 
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that house Category 1 or 2 quantities of radioactive materials. As of February 28, 2010, 113 

buildings had been completed with the remaining buildings to be complete by 2016. 

Response – Alarm Response Training 

The GTRI program will also provide security personnel and local law enforcement with tools 

(e.g. radios, repeaters, and personal detection devices) and additional training to respond to a 

security incident. To ensure that both on-site and off-site responders understand how to 

respond to enhanced security system alarms, GTRI developed an alarm response training 

course, which is held at the Y-12 National Security Complex in Oak Ridge, TN. NRC staff has 

observed this course to maintain awareness of all aspects of the enhancement program. This 

alarm response training also prepares responders to protect themselves and the public when 

responding to events involving radiological materials. The participants conduct hands-on 

training in a realistic setting using actual protection equipment and real radioactive sources. 

The courses include operational exercise scenarios that build on classroom instruction and 

allow response forces to exercise their own procedures during realistic alarm scenarios. As of 

February 28, 2010, GTRI had conducted 11 alarm response training sessions for 36 licensees 

and their immediate off-site responders. 

Table Top Exercises (TTX) 

The final component of the voluntary security enhancements program is table top exercises. 

NNSA and the Federal Bureau of Investigation (FBI) provide table top exercises upon request at 

materials licensees’ facilities that have volunteered for the security enhancements program, and 

have enhancements installed. These exercises are designed to provide a no-fault, site-specific 

scenario where senior managers from various federal, state, and municipal organizations can 

exercise their crisis management and consequence management skills in response to a 

simulated terrorist incident. The overall objectives are to: 

• Promote cross-sector communication, cooperation, and team-building among federal, 

state, local, and private sector first responders; 

• Exercise FBI lead responsibility for criminal investigation; 

• Examine newly developed tactics, techniques, and procedures resulting from voluntary 

security enhancements; 

• Promote attack prevention through intelligence sharing and coordinated approach to 

neutralize the threat; and 

• Prepare site-specific integrated response plans with federal, state, local, and private 

sector partners. 

As of February 28, 2010, NNSA had conducted 6 TTXs at materials licensee facilities, focused 

on RED/RDD events. NRC and Agreement State staff have observed several exercises. 

In summary, the IDD effort is planned and implemented in coordination with NNSA’s domestic 

radiological security enhancement program. While no additional security enhancements are 

needed at this time, NRC and Agreement States support NNSA’s work with the materials 

licensees and state, local, and tribal governments to supplement the existing security 

requirements with voluntary security enhancements, such as CsCl irradiator hardening and 

facility upgrades (e.g., access control, detection, delay, remote monitoring to ensure response, 

and sustainability). These security enhancements supplement and do not affect the licensee’s 

responsibility to meet the existing NRC and Agreement State regulatory requirements, and are 
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intended to further improve the effectiveness of security systems. If these enhancements are

used to meet regulatory requirements, then the licensee is obligated to assume all responsibility 

for functionality and maintenance of the enhancements. 

The NRC staff continues to work closely with its federal partners to coordinate with state and 

local agencies and the private sector on voluntary efforts to enhance source security. The staff 

routinely disseminates information to the Agreement States and materials licensees, 

coordinates the Radiation Source Protection and Security Task Force, and participates in 

meetings with the DHS-chaired Nuclear Sector Government Coordinating Council and Sector 

Coordinating Council, as well as routine trilateral meetings with senior management from DHS 

and DOE/NNSA to coordinate on radioactive source security issues. 

COORDINATION:

The Office of the General Counsel has reviewed this paper and has no legal objection. 

 /RA/ 

 Charles L. Miller, Director 

 Office of Federal and State Materials 

 and Environmental Management Programs 

 
The Commissioners 5 

intended to further improve the effectiveness of security systems. If these enhancements are

used to meet regulatory requirements, then the licensee is obligated to assume all responsibility 

for functionality and maintenance of the enhancements. 

The NRC staff continues to work closely with its federal partners to coordinate with state and 

local agencies and the private sector on voluntary efforts to enhance source security. The staff 

routinely disseminates information to the Agreement States and materials licensees, 

coordinates the Radiation Source Protection and Security Task Force, and participates in 

meetings with the DHS-chaired Nuclear Sector Government Coordinating Council and Sector 

Coordinating Council, as well as routine trilateral meetings with senior management from DHS 

and DOE/NNSA to coordinate on radioactive source security issues. 

COORDINATION:

The Office of the General Counsel has reviewed this paper and has no legal objection. 

 /RA/ 

 Charles L. Miller, Director 

 Office of Federal and State Materials 

 and Environmental Management Programs 

 

ML100670638 WITS200900242/ EDATS: SECY-2009-0198

OFFICE MSSA/SMPB MSSA/SMPB MSSA MSSA 

NAME SHawkins AMauer TReis RLewis 

DATE 03/15/10 03/19/10 03/22/10 03/ /10 

OFFICE NSIR OGC TechEd FSME 

NAME SMorris 

(with comments) for 

RCorreia 

TCampbell (NLO via 

email with comments) 

for BJones 

CPoland 

(and PTressler)

CMiller 

DATE 03/17/10 03/19/10 03/29/10 03/30/10 

OFFICIAL RECORD COPY