AUDIT REPORT

Audit of NRC’s Management of the Baseline Security Inspection Program

OIG-12-A-10 March 8, 2012

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

NRC’s Web site at: 

http:/www.nrc.gov/reading-rm/doc-collections/insp-gen/
UNITED STATES

NUCLEAR REGULATORY COMMISSION

WASHINGTON, D.C. 20555-0001

OFFICE OF THE

INSPECTOR GENERAL

March 8, 2012

MEMORANDUM TO: R. William Borchardt

Executive Director for Operations

FROM: Stephen D. Dingbaum /RA/

Assistant Inspector General for Audits

SUBJECT: AUDIT OF NRC’S MANAGEMENT OF THE BASELINE 

SECURITY INSPECTION PROGRAM (OIG-12-A-10)

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

Management of the Baseline Security Inspection Program. 

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

February 29, 2012, exit conference have been incorporated, as appropriate, into this 

report.

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

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

planned are subject to OIG follow-up in accordance with Management Directive 6.1.

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

audit. If you have any questions or wish to discuss anything prior to the exit conference, 

please call me at 415-5915 or Beth Serepca, Team Leader, at 415-5911.

Attachment: As stated

cc: N. Mamish, OEDO

K. Brock, OEDO

J. Arildsen, OEDO

C. Jaegers, OEDO 
Overview of NRC’s Management of the Baseline Security Inspection Program

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EXECUTIVE SUMMARY

BACKGROUND

Baseline Security Inspection Program

The Nuclear Regulatory Commission’s (NRC) baseline security inspection 

program is the agency’s primary means for ensuring that nuclear power 

plants across the United States are protected in accordance with Federal 

Government regulations.1 Specifically, the baseline security inspection 

program has six objectives:

1. To gather sufficient, factual information to determine with high 

assurance if a licensee’s security system and material control and 

accounting program2can protect against radiological sabotage, and 

the theft or loss of special nuclear material.

2. To determine a licensee’s ability to identify, assess, and correct 

security issues in proportion with the significance of these issues.

3. To determine if licensees, working with external agencies, are 

capable of deterring and protecting against the Design Basis 

Threat.3

4. To validate performance indicator data, which NRC uses in 

conjunction with inspection findings to assess the security 

performance of power reactor licensees.

5. To help NRC monitor plants’ security status and conditions.

 

1 Chapter 10 Part 73 of the Code of Federal Regulations (10 CFR 73) establishes security regulations for 

operating nuclear power plants. 

2

The basic objective of material control and accounting is to prevent the loss or misuse of Special 

Nuclear Material (i.e., enriched uranium or plutonium).

3

The Design Basis Threat describes the capabilities of adversaries, such as terrorist groups, that could 

attack a nuclear power plant. The Design Basis Threat is based on classified and other sensitive 

information, and NRC revises it periodically to reflect current security issues. An unclassified version 

appears in 10 CFR 73.1(a).

 
Overview of NRC’s Management of the Baseline Security Inspection Program

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6. To identify significant issues that may have generic or crosscutting 

applicability to the safe and secure operation of licensees’ facilities. 

To meet these objectives, NRC conducts routine inspections at nuclear 

power plants that focus on specific issue areas such as access controls, 

protective strategy, security training, and safeguards information (SGI) 

controls.4 

Significance Determination Process

The Significance Determination Process (SDP) is the process by which 

NRC staff assess the risks and potential effects of inspection findings. In 

following the SDP, NRC staff systematically analyze apparent violations 

and characterize them under the following color-code scheme:

Green = Very low safety significance.

White = Low to moderate safety significance.

Yellow = Substantial safety significance.

Red = High safety significance.

NRC staff close Green findings in their inspection reports without 

additional analysis, but White, Yellow, and Red findings require more indepth analysis using SDP assessment tools. Since 2004, NRC has 

created several assessment tools for different types of security violations. 

These tools and their respective issue areas are:

Physical Protection [Access Controls, Access Authorization, Physical 

Protection, Contingency Response].

Material Control and Accounting of Radiological Materials.

Unsecured Safeguards Information.

Significance Screen.

5

Force-on-Force Exercise Performance.

 

4

SGI is defined as information the disclosure of which could reasonably be expected to have a significant 

adverse effect on the health and safety of the public and/or the common defense and security by 

significantly increasing the likelihood of theft, diversion, or sabotage of material or facilities subject to 

NRC jurisdiction. This information is not classified as National Security Information or Restricted Data. 

5

The Significance Screen is used to assess violations such as security personnel sleeping on duty; pipes 

leading from outside a plant into the plant’s Protected Area without adequate barriers or monitoring; and 

unauthorized firearms brought inside a plant by employees or contractors. 
Overview of NRC’s Management of the Baseline Security Inspection Program

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PURPOSE

The objective of this audit was to evaluate NRC’s management of the 

baseline security inspection program, including specific program features 

such as the Significance Determination Process.

RESULTS IN BRIEF

NRC has appropriate management controls to ensure the baseline 

security inspection program meets its objectives. However, a more 

systematic approach to analyzing security findings data beyond the 

regional level can help NRC staff better identify licensee performance 

trends. Further, periodic reviews of SDP assessment tools and systematic 

testing of new and revised SDP assessment tools can help staff apply 

SDP assessment tools in a more transparent and consistent manner.

RECOMMENDATIONS

This report makes five recommendations to improve NRC’s management of 

the baseline security inspection program. A list of these recommendations 

appears on page 18 of this report. 

Agency Comments

At an exit conference on February 29, 2012, agency management 

provided informal comments on a draft of this report. The Office of the 

Inspector General incorporated some of these comments into the report 

as appropriate. As a result, the agency opted not to provide formal 

comments for inclusion in this report.
Overview of NRC’s Management of the Baseline Security Inspection Program

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ABBREVIATIONS AND ACRONYMS

ADAMS Agencywide Documents Access and Management 

System

CFR Code of Federal Regulations

FTE Full-Time Equivalents

FY Fiscal Year

IMC Inspection Manual Chapter

MD Management Directive

NRC Nuclear Regulatory Commission

OIG Office of the Inspector General

PIM Plant Issues Matrix

ROP Reactor Oversight Process

RPS Reactor Program System

SDP Significance Determination Process

SGI Safeguards Information 

SLES Safeguards Information Local Area Network and 

Electronic Safe
Overview of NRC’s Management of the Baseline Security Inspection Program

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TABLE OF CONTENTS

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

ABBREVIATIONS AND ACRONYMS........................................................ v

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

II. PURPOSE ...................................................................................... 8

III. FINDINGS....................................................................................... 8

A. NRC CAN IMPROVE INTERNAL CONTROL OVER BASELINE

SECURITY INSPECTION PROGRAM DATA......................................... 9

B. NRC LACKS CONSENSUS ON CONTENT AND APPLICATION 

OF SGI AND SIGNIFICANCE SCREEN TOOLS.................................. 15

IV. CONSOLIDATED LIST OF RECOMMENDATIONS ..................... 18

V. AGENCY COMMENTS................................................................. 19

APPENDIXES

A. POWER REACTOR SITES BY LICENSEE 

OPERATOR AND NRC REGION ............................................ 20

B. OBJECTIVE, SCOPE, AND METHODOLOGY........................ 21
Overview of NRC’s Management of the Baseline Security Inspection Program

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I. BACKGROUND

The Nuclear Regulatory Commission’s (NRC) baseline security inspection 

program is the agency’s primary means for ensuring that nuclear power 

plants across the United States are protected in accordance with Federal 

Government regulations.6 Specifically, the baseline security inspection 

program has six objectives:

1. To gather sufficient, factual information to determine with high 

assurance if a licensee’s security system and material control and 

accounting program7can protect against radiological sabotage, and 

the theft or loss of special nuclear material.

2. To determine a licensee’s ability to identify, assess, and correct 

security issues in proportion with the significance of these issues.

3. To determine if licensees, working with external agencies, are 

capable of deterring and protecting against the Design Basis 

Threat.8

4. To validate performance indicator data, which NRC uses in 

conjunction with inspection findings to assess the security 

performance of power reactor licensees.

 

6 Chapter 10 Part 73 of the Code of Federal Regulations (10 CFR 73) establishes security regulations for 

operating nuclear power plants. 

7

The basic objective of material control and accounting is to prevent the loss or misuse of Special 

Nuclear Material (i.e., enriched uranium or plutonium).

8

The Design Basis Threat describes the capabilities of adversaries, such as terrorist groups, that could 

attack a nuclear power plant. The Design Basis Threat is based on classified and other sensitive 

information, and NRC revises it periodically to reflect current security issues. An unclassified version 

appears in 10 CFR 73.1(a).

 
Overview of NRC’s Management of the Baseline Security Inspection Program

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5. To help NRC monitor plants’ security status and conditions.

6. To identify significant issues that may have generic or crosscutting

applicability to the safe and secure operation of licensees’ facilities. 

To meet these objectives, NRC conducts routine inspections at nuclear 

power plants that focus on specific issue areas such as access controls, 

protective strategy, security training, and safeguards information (SGI) 

controls.9 Personnel at NRC’s four regional offices plan and conduct 

baseline security inspections at nuclear power plants within their 

respective regions. Headquarters staff in NRC’s Office of Nuclear 

Security and Incident Response (NSIR) support baseline security 

inspections through policy and guidance development, licensee 

performance data review, and review of escalated licensee violations. 

NSIR staff also conduct Force-on-Force inspections—the only type of 

baseline security inspections conducted by headquarters staff with support 

from regional staff.10 In Fiscal Year (FY) 2012, NRC allocated 11.5 FullTime Equivalents (FTE) for headquarters activities in the baseline security 

inspection program, and 5.7 FTE for program activities at each of the four 

regions for a total of 34.3 FTE. NRC staff expect these resource levels to 

remain constant in FY 2013.

 

9

SGI is defined as information the disclosure of which could reasonably be expected to have a significant 

adverse effect on the health and safety of the public and/or the common defense and security by 

significantly increasing the likelihood of theft, diversion, or sabotage of material or facilities subject to 

NRC jurisdiction. This information is not classified as National Security Information or Restricted Data. 

10 Force-on-Force inspections require licensees to demonstrate their security capabilities through tactical 

exercises in which mock terrorist groups simulate attacks against nuclear power plants. Congress 

mandated triennial Force-on-Force inspections in the 2005 Energy Policy Act.
Overview of NRC’s Management of the Baseline Security Inspection Program

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Figure 1 shows NRC’s regions, as well as the locations of regional and 

headquarters offices, and the agency’s Technical Training Center.

Figure 1: Map of the United States and NRC Regions

Source: NRC
Overview of NRC’s Management of the Baseline Security Inspection Program

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Significance Determination Process

The Significance Determination Process (SDP) is the process by which 

NRC staff assess the risks and potential effects of inspection findings. In 

following the SDP, NRC staff systematically analyze apparent violations 

and characterize them under the following color-code scheme:

Green = Very low safety significance.

White = Low to moderate safety significance.

Yellow = Substantial safety significance.

Red = High safety significance.

NRC staff close Green findings in their inspection reports without 

additional analysis, but White, Yellow, and Red findings require more indepth analysis using SDP assessment tools. Since 2004, NRC has 

created several assessment tools for different types of security violations. 

These tools and their respective issue areas are:

Physical Protection [Access Controls, Access Authorization, Physical 

Protection, Contingency Response].

Material Control and Accounting of Radiological Materials.

Unsecured Safeguards Information.

Significance Screen.

11

Force-on-Force Exercise Performance.

 

11 The Significance Screen is used to assess violations such as security personnel sleeping on duty; 

pipes leading from outside a plant into the plant’s Protected Area without adequate barriers or monitoring; 

and unauthorized firearms brought inside a plant by employees or contractors. 
Overview of NRC’s Management of the Baseline Security Inspection Program

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Figure 2 shows security barriers, which are one of many security system 

elements that NRC staff inspect at nuclear power plants.

Figure 2: Security Barriers at a Nuclear Power Plant 

Source: NRC

White, Yellow, and Red findings require additional review by NRC staff. 

First, NRC notifies licensees of a finding, and licensees must then formally 

respond by either accepting the finding and committing to corrective 

actions, or by contesting the finding. Second, NRC management must 

review findings to ensure that their staff have applied SDP assessment 

tools correctly. Third, if licensees contest findings, they may provide 

mitigating information or other analysis to explain why they believe 

findings should be downgraded. NRC staff must factor this information 

into their final decision. Lastly, the technical complexity of a particular 

finding can impact the amount of time and effort needed by NRC staff and 

licensee personnel to support their respective positions. 
Overview of NRC’s Management of the Baseline Security Inspection Program

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Greater-than-Green findings are relatively uncommon in the baseline 

security inspection program. In 2010, for example, NRC issued 112 

Green findings, and 6 Greater-than-Green findings.

12

 

Correct and consistent application of SDP assessment tools is essential to 

the Reactor Oversight Process (ROP), which is NRC’s framework for 

regulating the nuclear power industry. The ROP is based upon principles 

of risk-informed decisionmaking and transparency. Accordingly, NRC 

should: 

Focus inspections on activities where the potential risks are greater.

Apply greater regulatory attention to nuclear power plants with 

performance problems.

Use objective measurements of performance of nuclear power plants.

Give both the public and the nuclear industry timely and 

understandable assessments of plant performance.

Respond to violations of regulations in a predictable and consistent 

manner that reflects the potential safety impact of the violations.

The ROP categorizes NRC’s oversight activities into seven distinct 

―cornerstones‖ of safe operation, one of which is physical protection. NRC 

also assesses licensee performance in the context of cross-cutting issues, 

such as problem identification and resolution, which may affect multiple 

ROP cornerstones. 

 

12 These do not include results of Force-on-Force inspections.
Overview of NRC’s Management of the Baseline Security Inspection Program

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Figure 3 illustrates the ROP cornerstones and their relation to key oversight 

areas and cross-cutting issue areas.

Figure 3: Reactor Oversight Process Framework

Source: NRC

The ROP is complemented by NRC’s enforcement program, which, in this 

context, focuses on violations that are caused by deliberate misconduct. 

NRC may pursue enforcement action against licensees while staff are 

determining a finding’s significance within the ROP framework. 

Enforcement action can result in the issuance of civil penalties against 

licensees. 
Overview of NRC’s Management of the Baseline Security Inspection Program

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II. PURPOSE

The audit objective was to evaluate NRC’s management of the baseline 

security inspection program, including specific program features such as 

the Significance Determination Process. Appendix B contains information 

on the audit scope and methodology. 

III. FINDINGS

NRC has appropriate management controls to ensure the baseline 

security inspection program meets its objectives. However, a more 

systematic approach to analyzing security findings data beyond the 

regional level can help NRC staff better identify licensee performance 

trends. Further, periodic reviews of SDP assessment tools and systematic 

testing of new and revised SDP assessment tools can help staff apply 

SDP assessment tools in a more transparent and consistent manner.
Overview of NRC’s Management of the Baseline Security Inspection Program

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A. NRC Can Improve Internal Control Over Baseline Security Inspection 

Program Data

Federal Government and NRC guidance on internal control13 recommend 

the use of data analysis to inform program operations and management. 

NRC maintains data on security inspection findings, but does not 

systematically analyze it to identify trends among NRC regions and 

licensee fleets.14 This occurs because NRC’s baseline security inspection 

program emphasizes analysis of individual licensee performance and 

performance of licensees within each of the four NRC regions. As a 

result, NRC may miss opportunities to improve monitoring and 

management of security issues, inspection procedures, and tools.

Effective Internal Control Is Key To Maintaining Visibility Over 

Program Operations and Results.

Federal Government and NRC internal control guidance recommend that 

program managers analyze appropriate information sources used in the 

baseline security inspection program to inform program operations and 

decisions and to ensure programs achieve intended results. Internal 

controls comprise the plans, methods, and procedures used to meet 

missions, goals, and objectives. These controls include managers at all 

levels analyzing trends and measuring results against targets. Controls 

must be developed as programs are initially implemented, as well as when 

they are reengineered. Additionally, managers should employ a variety of 

activities ensuring that edit checks are used in controlling data entry and 

that access to data and data systems is appropriately controlled. 

 

13 Standards for Internal Control in the Federal Government (GAO/AIMD-00-21.3.1) U.S. General 

Accounting Office, Washington DC: 1999 and NRC Management Directive 4.4,‖Management Controls,‖ 

May 18, 2004.

14 A fleet refers to a group of nuclear power plants operated by one licensee. Plants belonging to a 

licensee’s fleet can be located in one or more NRC regions.
Overview of NRC’s Management of the Baseline Security Inspection Program

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NRC Does Not Perform Systematic Cross-Regional or Cross-Fleet 

Analysis of Security Trends

NRC maintains and uses multiple information sources to monitor plant 

performance, but managers do not perform systematic analysis to assess 

trends across NRC regions or licensee fleets. For example, NRC 

maintains many information sources pertaining to inspection findings and 

has visibility over individual plant performance through the use of 

inspection reports stored in the Agencywide Documents Access and 

Management System (ADAMS),15 inspection reports stored in the 

Safeguards Information Local Area Network and Electronic Safe (SLES),16

mid- and end-of-cycle assessments, the Plant Issues Matrix (PIM), 

Reactor Program System (RPS) data, and annual reports to Congress. 

However, NRC does not perform systematic cross-regional or cross-fleet 

analysis of security inspection trends. Figure 4 shows information sources 

used in the baseline security inspection program.

 

15 ADAMS is the official recordkeeping system through which NRC provides access to vast "libraries" or 

collections of documents related to the agency’s regulatory activities.

16 SLES is NRC’s information repository for all SGI.
Overview of NRC’s Management of the Baseline Security Inspection Program

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Figure 4: NRC Baseline Security Inspection Program Information Sources

Information Source Description

Inspection Reports Inspection reports, written by NRC 

inspectors, provide NRC with all the 

details of the final disposition of 

findings uncovered during NRC 

inspections of power reactors. 

Details include the date of the 

inspection, the number and types of 

findings, and the safety significance 

(color designation of the finding).

SLES NRC’s repository for all inspection 

reports and other documents 

containing SGI. 

Mid/End Cycle Plant 

Assessment Reports

Reports issued at the beginning of 

March and September of each year 

for each reactor site. The reports 

state whether the plant is receiving

increased oversight and the number 

of planned inspections.

PIM The PIM provides a consolidated 

listing of individual plant issues (i.e., 

inspection findings) that NRC uses 

to assess plant performance.

RPS A system used by NRC to enter 

administrative data about inspection 

scheduling and limited data 

regarding inspection results.

Annual Report to Congress A report that provides a basic count 

of inspection findings for the year.

Source: Office of the Inspector General (OIG) analysis of information sources
Overview of NRC’s Management of the Baseline Security Inspection Program

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Additionally, regional branch chiefs stated that they can request that 

headquarters generate reports in response to individual staff requests, but 

reports focus on individual regions and requesters’ individual data needs. 

However, the headquarters representative responsible for responding to 

such requests told OIG that this type of analysis is labor intensive and 

requires piecing together data from the multiple sources listed above. 

Incidentally, it is important for NRC to perform cross-regional and crossfleet analysis for purposes of identifying areas that may need more 

regulatory emphasis. This analysis can also be used to make strategic 

program decisions, inform the tools and inspection procedures that are 

used to develop findings, and ensure the program is achieving its intended 

results. 

Likewise, comprehensive cross-regional and cross-fleet analysis is 

important because NRC performs baseline security inspection activities at 

104 reactor units within 65 reactor sites throughout NRC’s four regions 

(see Figure 5). Moreover, approximately 45 percent of power reactor 

licensees manage more than one reactor site, and approximately 20 

percent maintain reactor sites in more than one region. See Appendix A

for a table showing power reactor sites by licensee operator and their 

locations by NRC region. 

Figure 5: Breakdown of Regional Reactor Sites and Reactor Units 

Region 1 Region 2 Region 3 Region 4 Totals

Reactor 

Sites

17 18 16 14 65

Reactor 

Units

26 33 24 21 104

Source: OIG analysis of NRC data
Overview of NRC’s Management of the Baseline Security Inspection Program

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NRC Management Does Not Emphasize Trend Analysis Across 

Regions and Fleets

OIG found that NRC does not perform trend analysis across regions and 

fleets because program management emphasizes analysis of individual 

plant performance, and trends within each of the four regions. 

Additionally, NRC does not actively maintain and manage a centralized 

database for analyzing security inspection findings across regions and 

fleets as evidenced by OIG’s analysis of NRC’s current information 

sources.

Further, OIG could not determine if data in existing data systems is 

complete and accurate. Two of the data systems NRC headquarters staff 

use to access information may not be complete or accurate.

First, RPS is used to collect information about scheduling inspections 

and also collects basic data points about findings. NRC does not use 

a single, consistent process for data entry or define data management 

controls for users of this database. The headquarters official 

responsible for obtaining and analyzing data from this system stated 

that, up until very recently, the data could not be reconciled in this 

system because regional officials had not consistently included the 

official in their distribution of findings reports. 

Second, NRC maintains, in addition to the information stored in RPS, a 

separate secure database – SLES – that holds inspection finding 

reports containing SGI data. OIG found that, for various reasons, this 

information is not easy to obtain or analyze and, in some cases, was 

not obtainable at all. 

Improved Data Collection and Analysis Will Enhance NRC’s Ability 

To Regulate and Improve Program Operations, Program Tools and 

Procedures, and Program Results

Despite the lack of trending across regions and fleets, OIG found no 

material adverse effect on NRC operations. However, NRC may miss 

opportunities to improve monitoring and management of security issues, 

inspection tools and procedures, and program results. Additionally, 

improved data management and analysis can help NRC staff identify 

trends that merit additional oversight or regulatory emphasis. This, in turn, 
Overview of NRC’s Management of the Baseline Security Inspection Program

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can give NRC greater assurance that the inspection program is meeting 

its objective to conduct fact-based assessments of licensee security 

program performance. 

Recommendations

OIG recommends that the Executive Director for Operations:

1. Develop and maintain a centralized database of security findings data 

to be used for evaluating licensee performance trends, and 

communicating this information to NRC staff, industry, and appropriate 

public stakeholders.

2. Formalize and implement a process for maintaining current and 

accurate data within a centralized database.

3. Formalize and implement a process for ensuring SGI findings data is 

current and accessible for use in trending security findings issues.
Overview of NRC’s Management of the Baseline Security Inspection Program

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B. NRC Lacks Consensus on Content and Application of SGI and 

Significance Screen Tools

The ROP sets general standards for NRC’s oversight of power reactors, 

and emphasizes objectivity, transparency, and consistency in NRC’s 

assessments of licensee performance. NRC staff and industry 

representatives expressed concern about the technical basis and 

application of the SGI and Significance Screen tools.17 Although NRC 

solicited staff comments in developing these assessment tools, NRC did 

not test draft versions of the tools and, further, does not have procedures 

for systematically reviewing SDP assessment tools on a periodic basis. 

Staff consensus and understanding of SDP assessment tools is critical to 

ensuring that staff can apply these tools in accordance with ROP 

standards and avoid undue resource burdens on NRC and licensees. 

The ROP Emphasizes Transparent, Consistent Regulation

The ROP sets general transparency and consistency standards for NRC’s 

oversight of the nuclear power industry. Specifically, NRC should aim for 

objective measurements of licensee performance and translate those 

measurements into timely assessments that the public and licensees can 

understand. Moreover, NRC should respond to licensee violations in a 

consistent manner that reflects the potential safety impact of the 

violations.

NRC Staff and Industry Concerns and Questions Focus on SGI and 

Significance Screen Assessment Tools

Interviews and surveys of NRC staff and nuclear power industry 

representatives regarding the security SDP showed that two assessment 

tools—SGI and the Significance Screen—produced the greatest amount 

of critical feedback. OIG received a broad range of comments regarding 

the content and application of these tools. OIG also received suggestions 

about how to improve these assessment tools. Additionally, some 

comments reflected a lack of understanding of assessment tool features, 

as well as doubts regarding the reliability of assessment results. 

 

17 See the ―Background‖ section of this report for information on security SDP assessment tools.
Overview of NRC’s Management of the Baseline Security Inspection Program

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OIG could not reconcile divergent staff and industry comments on the SGI 

and Significance Screen tools, yet several points stand out. First, some 

staff questioned the technical basis of criteria used to escalate findings. 

For example, both the SGI and Significance Screen rely on time standards 

to measure exploitability, but the rationale for these metrics was not clear 

to some NRC and industry personnel. Second, respondents questioned 

how these tools weigh mitigating information, and whether this information 

is analyzed after a finding has been prematurely escalated. Third, 

respondents questioned how some SGI and Significance Screen findings 

can be coded as White or Yellow when violations appear unlikely to 

impact plant safety or security. Lastly, some staff and industry personnel 

questioned the potential for escalation bias in the Significance Screen. 

The tool focuses on several particular security issues, and uses time and 

consequence criteria that increase the likelihood of White or Yellow 

findings.

NRC Revises SDP Tools, but Does Not Systematically Test and 

Update Assessment Tools

In reviewing the history of security SDP development, OIG found that NRC 

has tested other SDP tools prior to implementation but did not do so with 

the SGI and Significance Screen tools. NRC solicited staff and industry 

comments on draft tools, but did not test the draft tools by analyzing past 

or hypothetical findings to determine how the draft tools would work in a 

practical context. This differs from NRC’s 2004 SDP pilot effort, during 

which headquarters and regional staff screened approximately 50 findings 

to determine whether the results would be reasonable. Similarly, NRC’s 

current effort to update the Force-on-Force SDP involves a findings 

screening analysis.

OIG’s review also showed that NRC updates SDP assessment tools on a 

circumstantial basis and does not have procedures to ensure that updates 

are performed consistently. The SGI and Significance Screen tools 

resulted from a 2007-2008 Enhancement Team effort that NRC initiated in 

response to staff concerns about particular security issues. Further, that 

Enhancement Team’s leader has since retired from NRC, thereby limiting 

the institutional knowledge necessary to guide future SDP updates in the 

absence of formal procedures or best practice guidance. 
Overview of NRC’s Management of the Baseline Security Inspection Program

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Consensus and Understanding of SDP tools Is Important for 

Regulatory Transparency

Consensus and understanding among NRC staff regarding SDP 

assessment tools is critical to ensuring that staff can apply these tools 

easily and consistently in accordance with Reactor Oversight Process 

standards. This does not preclude professional disagreement over 

particular findings. However, staff must understand the rationale for 

findings so they can present them logically to licensees and uphold NRC’s 

integrity as a fair and impartial regulator. Further, NRC staff should have 

confidence in the soundness of escalated findings, given that the SDP 

requires extra staff resources for review and final disposition, and also 

impacts licensees with costs for responding to NRC and taking 

compensatory measures.18 

Recommendations

OIG recommends that the Executive Director for Operations:

4. Formalize and implement procedures for testing draft SDP tools by 

staff to determine how draft tools would screen past violations and/or 

hypothetical security violations.

5. Formalize and implement a process for performing periodic review of 

existing security SDP tools to check for consistency of application and 

results.

 

18 Greater-than-Green (e.g., White) findings can take between 5 and 18 months to close, depending on 

the complexity of each case. Beyond the additional staff effort required to process these findings, 

licensees may need to conduct independent analysis to support their positions in enforcement 

conferences with NRC. Further, licensees may be obligated to upgrade plant infrastructure at 

considerable cost if NRC maintains its position on an escalated finding.

 
Overview of NRC’s Management of the Baseline Security Inspection Program

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IV. CONSOLIDATED LIST OF RECOMMENDATIONS

OIG recommends that the Executive Director for Operations:

1. Develop and maintain a centralized database of security findings data 

to be used for evaluating licensee performance trends, and 

communicating this information to NRC staff, industry, and appropriate 

public stakeholders.

2. Formalize and implement a process for maintaining current and 

accurate data within a centralized database.

3. Formalize and implement a process for ensuring SGI findings data is 

current and accessible for use in trending security findings issues.

4. Formalize and implement procedures for testing draft SDP tools by 

staff to determine how draft tools would screen past violations and/or 

hypothetical security violations.

5. Formalize and implement a process for performing periodic review of 

existing security SDP tools to check for consistency of application and 

results.
Overview of NRC’s Management of the Baseline Security Inspection Program

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V. AGENCY COMMENTS

At an exit conference on February 29, 2012, agency management 

provided informal comments on a draft of this report. The Office of the 

Inspector General incorporated some of these comments into this report 

as appropriate. As a result, the agency opted not to provide formal 

comments for inclusion in this report.
Overview of NRC’s Management of the Baseline Security Inspection Program

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Appendix A

POWER REACTOR SITES BY LICENSEE OPERATOR AND NRC 

REGION

Licensee Region 1 Region 2 Region 3 Region 4 Total

Ameren UE 1 1

Arizona Public Service Co. 1 1

Constellation Energy 3 3

Detroit Edison Co. 1 1

Dominion Generation 1 2 1 4

Duke Energy Power Company,

LLC 3 3

Energy Northwest 1 1

Entergy Nuclear Operations, Inc. 4 1 4 9

Exelon Generation Co., LLC 4 6 10

FirstEnergy Nuclear Operating Co. 1 2 3

Florida Power & Light Co. 1 2 1 4

FPL Energy Point Beach, LLC 1 1

Indiana/Michigan Power Co. 1 1

Nebraska Public Power District 1 1

Nuclear Management Co. 2 2

Omaha Public Power District 1 1

Pacific Gas & Electric Co. 1 1

PPL Susquehanna, LLC 1 1

Progress Energy 4 4

PSE&G Nuclear 2 2

South Carolina Electric & Gas Co. 1 1

Southern California Edison Co. 1 1

Southern Nuclear Operating Co. 3 3

STP Nuclear Operating Co. 1 1

Tennessee Valley Authority 3 3

TXU Generating Company LP 1 1

Wolf Creek Nuclear Operating 

Corp. 1 1

Total 17 18 16 14 65

Source: OIG analysis of NRC data
Overview of NRC’s Management of the Baseline Security Inspection Program

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Appendix B

OBJECTIVE, SCOPE, AND METHODOLOGY

OBJECTIVE

The audit objective was to evaluate NRC’s management of the baseline 

security inspection program, including specific program features such as 

the Significance Determination Process.

SCOPE

The audit focused on reviewing NRC’s oversight of the baseline security 

inspection program and the Significance Determination Process. We 

conducted this performance audit at NRC headquarters and at the four 

NRC regions, from July 2011 through January 2012. Internal control and 

ROP principles related to the audit objective were reviewed and analyzed. 

Throughout the audit, auditors were aware of the possibility or existence of 

fraud, waste, or misuse in the program.

METHODOLOGY

OIG reviewed relevant Federal regulations and internal guidance 

pertaining to NRC’s regulatory authorities to oversee security inspections, 

including Chapter 10 Part 73 of the Code of Federal Regulations. OIG 

also reviewed NRC inspection manual chapters (IMC), NRC management 

directives (MD), and internal control guidance pertaining to the oversight 

of baseline security inspections including:

IMC 0308 – Basis Document for Security Cornerstone of the Reactor 

Oversight Process.

IMC 0609 Appendix E, Part I – Baseline Security Significance 

Determination Process for Power Reactors.

MD 8.13 – Reactor Oversight Process.

MD 8.7 – Reactor Operating Experience Program.

MD 4.4 – Management Controls.

Standards for Internal Control in the Federal Government.

OIG also reviewed inspection reports housed in ADAMS and SLES, 

performed an electronic survey of regional inspectors, and conducted 

interviews with headquarters personnel (Rockville, MD), regional 
Overview of NRC’s Management of the Baseline Security Inspection Program

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personnel, industry representatives, and the Nuclear Energy Institute. 

These interviews were conducted to obtain insights into NRC’s oversight 

of baseline security inspections and the significance determination 

process. The audit team also observed inspection activities at Three Mile 

Island Nuclear Generating Station.

We conducted this performance audit in accordance with generally 

accepted Government auditing standards. Those standards require that 

we plan and perform the audit to obtain sufficient, appropriate evidence to 

provide a reasonable basis for our findings and conclusions based on our 

audit objectives. We believe that the evidence obtained provides a 

reasonable basis for our findings and conclusions based on our audit 

objective. 

The audit work was conducted by Beth Serepca, Team Leader; Paul 

Rades, Audit Manager; Melissa Schermerhorn, Senior Management 

Analyst; John Tornabane, Management Analyst; and Kevin Nietmann, 

Senior Technical Advisor.