ML16196A237 

UNITED STATES 

NUCLEAR REGULATORY COMMISSION 

OFFICE OF NUCLEAR MATERIAL SAFETY AND SAFEGUARDS 

WASHINGTON, DC 20555-0001 

December 26, 2017 

NRC REGULATORY ISSUE SUMMARY 2005-31, REVISION 1 

CONTROL OF SECURITY-RELATED SENSITIVE UNCLASSIFIED NONSAFEGUARDS 

INFORMATION HANDLED BY INDIVIDUALS, FIRMS, AND ENTITIES SUBJECT TO NRC 

REGULATION OF THE USE OF SOURCE, BYPRODUCT, 

AND SPECIAL NUCLEAR MATERIAL

ADDRESSEES

All radiation control program directors and State liaison officers. 

All licensees, certificate holders, applicants, and other entities (hereafter referred to as

“licensees and others”) subject to regulation by the U.S. Nuclear Regulatory Commission (NRC)

for the use of source, byproduct, and special nuclear material, excluding the following: 

 

• All holders of and applicants for an operating license or construction permit under 

Title 10 of the Code of Federal Regulations (10 CFR) Part 50, “Domestic Licensing of 

Production and Utilization Facilities,” and those licensees that have permanently ceased 

operations and have submitted certifications under 10 CFR 50.82(a)(1) or have 

submitted applications for license termination under 10 CFR 50.82(b)(1). 

• All holders of and applicants for a power reactor early site permit, combined license, 

standard design approval, or manufacturing license under 10 CFR Part 52, “Licenses, 

Certifications, and Approvals for Nuclear Power Plants.” All applicants for a standard 

design certification, including such applicants after initial issuance of a design 

certification rule. 

• All holders of and applicants for certificates for reactor designs. 

INTENT

The NRC is issuing this regulatory issue summary (RIS) to accomplish the following: 

• Inform licensees and others of the screening criteria that the NRC uses to identify and 

protect security-related sensitive information in documents generated by the NRC and in 

documents developed by licensees and others, particularly those received by the NRC. 

(Enclosure 2) 

• Encourage licensees and others to identify security-related sensitive information in 

documents submitted to the NRC by using the marking procedures in Enclosure 1 and the 

screening criteria in Enclosure 2. 
RIS 2005-31, Rev. 1 

Page 2 of 6 

• Encourage licensees and others that may possess security-related sensitive information 

to control the information in order to limit the risk that the information might fall into the 

hands of those who would use it for malevolent acts. 

No specific action or written response is required. 

BACKGROUND INFORMATION

The NRC traditionally has given the public access to a significant amount of information about 

the facilities and materials the agency regulates. Openness has been and remains a 

cornerstone of the NRC’s regulatory philosophy. The Atomic Energy Act of 1954, as amended; 

subsequent legislation; and various NRC regulations have given the public the right to 

participate in the licensing and oversight process for NRC licensees. To participate in a 

meaningful way, the public must have access to information about the design and operation of 

regulated facilities and use of nuclear materials. However, the NRC and other Government 

agencies have always withheld some information from public disclosure for reasons of security, 

personal privacy, or designation as proprietary information (commercial or trade secret 

protection). 

In the post-September 11, 2001, environment, the NRC has found it necessary to be more 

judicious in determining what information to voluntarily release so that it does not inadvertently 

provide assistance to those who might use certain information for malevolent acts. The NRC 

has issued orders, advisories, and rules; taken specific actions on the security of its licensed 

facilities; and assessed and revised its policies and practices for making information available to 

the public. As one such action, the NRC temporarily suspended public access to documents in 

its electronic Agencywide Documents Access and Management System (ADAMS) on 

October 25, 2004. Subsequently, the NRC screened those documents to determine whether 

they contained security-related sensitive information. Based on this screening, the NRC 

returned a large number of documents to public access in ADAMS. This screening process

continues as requests for specific documents are received and as new documents are created

by the NRC and received from licensees and other entities. 

The NRC has continued to presumptively withhold some categories of documents from routine 

public release. In SECY-04-0191, “Withholding Sensitive Unclassified Information Concerning 

Nuclear Power Reactors from Public Disclosure,” dated October 19, 2004 (ADAMS Accession 

No. ML043140175), and SECY-05-0101, “Withholding from Public Disclosure Sensitive 

Unclassified Information Concerning Materials Licensees and Certification Holders,” dated 

October 7, 2005, (ADAMS Accession No. ML051040407) (non-public) the staff proposed to 

withhold certain information on fire protection and emergency planning and response to ensure 

that information that could reasonably be expected to be useful to a potential adversary was not 

made public. The Commission approved the initial withholding of this information and the 

review of the information for release in response to requests such as those made under the 

Freedom of Information Act (FOIA). See Staff Requirements Memorandum SECY-04-0191 

dated Nov. 9, 2004 and Staff Requirements Memorandum SECY-05-0101 dated October 7, 

2005. In SECY-15-0032, “Reviewing Documents for Public Release Using Sensitive 

Unclassified Non-Safeguards Information Guidance,” dated March 6, 2015 (ADAMS Accession 

No. ML14352A172), the staff proposed to discontinue this policy and instead apply the NRC’s 

sensitive unclassified nonsafeguards information (SUNSI) policy to review, release, and 

withhold fire protection and emergency preparedness documents. The Commission approved 

this proposal in its staff requirements memorandum to SECY-15-0032, dated June 15, 2015 

(ADAMS Accession No. ML15167A090). The advice in this RIS reflects that change.
RIS 2005-31, Rev. 1 

Page 3 of 6 

To facilitate the screening process for the public release of information, the NRC developed 

screening criteria and issued two RISs that pertain to nuclear reactors for conducting its

reviews. On November 7, 2005, the NRC issued RIS 2005-26, “Control of Sensitive 

Unclassified Nonsafeguards Information Related to Nuclear Power Reactors,” (ADAMS 

Accession No. ML051430228) for assessing whether documents associated with reactor 

licensees should be made publicly available. On December 23, 2015, the NRC issued 

RIS 2015-17, “Review and Submission of Updates to Final Safety Analysis Reports, Emergency 

Preparedness Documents, and Fire Protection Documents,” (ADAMS Accession No. 

ML15321A400) to remind licensees of the review and submission requirements of 

10 CFR 2.390, “Public Inspections, Exemptions, Requests for Withholding,” on information that 

may be withheld from public disclosure. 

As part of related efforts in the nonreactor arena, the NRC has developed the enclosed criteria 

for identifying security-related sensitive information that the staff encourages licensees to 

screen out or to mark and protect as sensitive information, particularly before those licensees 

that handle source, byproduct, or special nuclear material submit documents to the NRC. 

The advice in this RIS and its enclosures does not apply to classified information, Safeguards 

Information, or Safeguards Information—Modified Handling, which by law must be withheld from 

the public. 

SUMMARY OF ISSUE

SUNSI includes information that, if lost, misused, or modified, can reasonably be foreseen to 

harm the public interest, the commercial or financial interests of an entity, the conduct of NRC 

and Federal programs, or the personal privacy of individuals. It also includes security-related 

information. If practical, licensees and others that submit documents to the NRC should avoid 

including any security-related sensitive information to permit the release of the document to the 

public in its entirety. However, if that is not practical, the following steps will help ensure that 

sensitive information is not released: 

(1) Screening of Licensee-Generated Documents 

 To ensure that any security-related sensitive information in submitted documents is not 

made publicly available in ADAMS, the NRC is encouraging licensees and other entities 

to screen submittals in accordance with the criteria in Enclosure 2. In addition, to ensure 

that licensees and other entities identify and control security-related sensitive information 

in their documents, the NRC is encouraging them to develop implementing procedures 

to screen documents that might have sensitive security-related information in order to 

identify and control the information appropriately. The goal is to limit the risk that the 

information might fall into the hands of those who would use it for malevolent acts. 

(2) Cover Letter 

 If a cover letter that does not itself contain sensitive information is used to transmit a 

 document(s) that contains security-related sensitive information, the cover letter should 

clearly state this. Furthermore, the cover letter should have a statement that indicates 

that once its sensitive attachments are removed, the cover letter itself may be handled 

as an uncontrolled document. However, if the cover letter itself contains security-related 

sensitive information, it cannot be decontrolled. 
RIS 2005-31, Rev. 1 

Page 4 of 6 

(3) Marking Documents That Contain Security-Related Sensitive Information 

 As shown in Section A of Enclosure 1, include the marking “Security-Related 

 Information—Withhold under 10 CFR 2.390” at the top center of every page. 

 

 If submitting both a public and a nonpublic version of the same document, licensees and 

other entities should “black out” the sensitive information in the public version or withhold 

the sensitive information with a notation that it was withheld on the basis that it is 

“security-related information.” 

 Alternately, security-related sensitive information may be segregated from the main 

 body of the document and included only in attachments to the submittal. In this 

scenario, only the attachments that contain security-related sensitive information would 

be marked for withholding from public disclosure. If this approach is used, the public 

version does not need to be marked as containing security-related sensitive information. 

Enclosure 1, Section B, contains additional information on suggested handling and 

methods of submitting security-related sensitive information. 

Protection of Security-Related Sensitive Information 

Documents that contain security-related sensitive information should be protected from public 

disclosure using methods similar to those for protecting proprietary information. To the extent 

practical, any existing documents that contain security-related sensitive information that 

licensees or other entities have previously made available to the public should be withdrawn 

from public access. Licensees and other entities should have sufficient internal controls to 

prevent release of information to limit the risk that sensitive security-related information could be 

released to someone with malevolent intent. In addition to the points enumerated above, other 

methods to prevent the inadvertent release of security-related sensitive information include 

(1) restricting access to electronic recordkeeping systems that contain such information, 

(2) controlling the reproduction, distribution, and destruction of potentially sensitive records, and 

(3) releasing sensitive information only to those individuals who have a need to know the 

information to perform their jobs and who are made aware of the security-related nature of the 

information. 

Certain categories of security-related sensitive information under 10 CFR Part 37, “Physical 

Protection of Category 1 and Category 2 Quantities of Radioactive Material,” must be protected 

pursuant to 10 CFR 37.43(d) and 37.77(f), as described in more detail in Section D, “Security 

Program Information,” of Appendix 3, “Reviews of Medical, Industrial, and Academic Users of 

Nuclear Materials,” to Enclosure 2.

Much of the NRC’s information is readily available to the public through the NRC’s Web site 

(http://www.nrc.gov) and ADAMS (http://www.nrc.gov/reading-rm/adams.html). In addition, the 

agency may release other information to the public in response to formal or informal requests. 

Although the NRC developed these security-related sensitive information screening criteria with 

the principles of FOIA in mind, a review for security-related sensitive information does not 

substitute for a FOIA review. The NRC will continue to review and process FOIA requests 

under 10 CFR 2.390(d)(1), independently from the security-related sensitive information review 

process. 
RIS 2005-31, Rev. 1 

Page 5 of 6 

BACKFIT DISCUSSION

This RIS informs addressees of the screening criteria that the NRC uses to identify and protect 

security-sensitive information, and to encourage licensees and others to identify and control 

such information. This RIS requires no action or written response beyond that already required 

by NRC regulations, and is, therefore, not a backfit under the backfitting provisions of 

10 CFR 70.76, 72.62, or 76.76, all titled “Backfitting.” Consequently, the NRC staff did not 

perform a backfit analysis.

FEDERAL REGISTER NOTIFICATION

A notice of opportunity for public comment was not published in the Federal Register because 

this RIS is informational and does not represent a departure from current regulatory

requirements and practice.

CONGRESSIONAL REVIEW ACT

This RIS is not a rule for purposes for purposes of the Congressional Review Act, 5 U.S.C. §§ 

801-808. 

PAPERWORK REDUCTION ACT STATEMENT

This RIS does not request any information collections and, therefore, is not subject to the

Paperwork Reduction Act of 1995 (44 U.S.C. 3501 et seq.).
RIS 2005-31, Rev. 1 

Page 6 of 6 

CONTACTS 

Please direct any questions about this matter to the technical contacts listed below.

 /RA Kevin Williams for/ 

Andrea L. Kock, Acting Director

Division of Material Safety, State, Tribal

 and Rulemaking Programs

 Office of Nuclear Material Safety 

 and Safeguards 

Technical Contacts: Paul Goldberg, NMSS/MSTR Raynard Wharton, NMSS/DSFM 

301-415-7842 301-415-7497 

E-mail: Paul.Goldberg@nrc.gov E-mail: Raynard.Wharton@nrc.gov

Kevin Ramsey, NMSS/FCSE Zahira Cruz, NMSS/DUWP 

 301-415-7506 301-415-3808

E-mail: Kevin.Ramsey@nrc.gov E-mail: Zahira.Cruz@nrc.gov

Gary Langlie, OIP 

301-287-9076

E-mail: Gary.Langlie@nrc.gov 

Enclosures:

1. Suggested Markings and Handling 

for Those Subject to NRC Regulation

2. Screening Criteria for Security-Related 

 Sensitive Unclassified Nonsafeguards 

 Information

Note: NRC generic communications may be found on the NRC public Web site, 

http://www.nrc.gov, under NRC Library/Document Collections.
RIS 2005-31, Rev. 1 

Page 6 of 6 

SUBJECT: CONTROL OF SECURITY-RELATED SENSITIVE UNCLASSIFIED NONSAFEGUARDS INFORMATION HANDLED BY INDIVIDUALS, FIRMS, AND 

ENTITIES SUBJECT TO NRC REGULATION OF THE USE OF SOURCE, 

BYPRODUCT, AND SPECIAL NUCLEAR MATERIAL 

 DATE: December 26, 2017

ML16196A237 CAC A34010 

OFC NMSS/MSTR NMSS/MSTR NMSS/MSTR OGC OGC NMSS/FCSE NMSS/DSFM/ 

Staff 

NAME PGoldberg SAtack AMcIntosh ACoggins CSafford KRamsey RWharton 

DATE 12/15/16 12/5/16 7/15/16 9/12/17 9/18/2017 1/24/17 2/14/17 

OFC NMSS/DUWP OE OCIO OCIO OIP NMSS/FSCE NMSS/DUWP 

NAME ZCruz DFurst Via e-mail 

DCullison 

RGagnon PHabighorst CErlanger JTappert 

DATE 1/26/17 1/23/17 9/18/17 6/30/16 2/09/17 2/13/17 1/26/17 

OFC NMSS/DSFM NSIR/DSO QTE NMSS/MSTR 

NAME MLayton MBailey CHsu KWilliams for 

AKock 

 

DATE 2/14/17 1/27/17 2/22/17 12/26/17 

 OFFICIAL RECORD COPY
RIS 2005-31, Rev. 1 

Enclosure 1 

Page 1 of 2 

SUGGESTED MARKINGS AND HANDLING FOR THOSE SUBJECT TO NRC REGULATION 

This enclosure provides information on markings suggested by the U.S. Nuclear Regulatory 

Commission (NRC) for pages of a document that contains security-related sensitive 

information (Section A) and suggested handling of such documents (Section B). 

Section A: Page Markings 

Place the overall page marking on the top 

and bottom of all pages of a document that 

contains security-related sensitive 

information. 

Note that a cover letter must include the 

marking if the letter or any attachment to 

the letter contains security-related 

information. If the cover letter itself is 

nonsensitive, add the following statement 

to the bottom of the letter: “Documents 

transmitted herewith contain sensitive, 

unclassified information. When 

separated from the sensitive information, 

this document is decontrolled.” 

Ensure that the subject line is 

nonsensitive. 

 

 Security-Related Information 

 Withhold under 10 CFR 2.390 

 

 

Security-Related Information

Withhold under 10 CFR 2.390
RIS 2005-31, Rev. 1 

Enclosure 1 

Page 2 of 2

Section B: Appropriate Controls for Handling Documents 

Access: Access is based on “need to know” to perform official licensee, 

applicant, or other entity functions. 

Storage: Documents can be stored openly within licensee, applicant, or 

other entity facilities but with electronic or other access controls 

(e.g., key cards, guards, alarms). 

Mail: Documents should be sent through U.S. Postal Service first class 

mail, registered mail, express mail, or certified mail in a single 

opaque envelope with no external markings to indicate contents 

covered by Title 10 of the Code of Federal Regulations

(10 CFR) 2.390, “Public Inspections, Exemptions, Requests for 

Withholding.” 

Electronic Transmission: Information can be handled over the telephone if the recipient is 

confirmed as being authorized to access the information, over 

facsimile if it is confirmed that a recipient who is authorized to 

access the information will be present to receive the transmission, 

or over encrypted computer e-mail (using computer software such 

as SecureZip). 

Note that the NRC uses SecureZip to encrypt electronic 

information before transmitting security-related sensitive 

information by e-mail to licensees and other entities. Users will be 

prompted for a password to access a free download of the reader. 
RIS 2005-31, Rev. 1 

Enclosure 2 

Page 1 of 23 

SCREENING CRITERIA FOR SECURITY-RELATED SENSITIVE 

U N C LASSIFIED NONSAFEGUARDS INFORMATION 

December 26, 2017 

INTRODUCTION

This enclosure provides the criteria that should be used to determine what information may be 

disclosed to the public and what information should be withheld to prevent inadvertent 

assistance to those who might wish to use security-related information for malevolent acts. As a 

reminder, the advice in this enclosure applies to all security-related information except for 

classified information, Safeguards Information, or Safeguards Information - Modified Handling. 

BACKGROUND

Historically, the U.S. Nuclear Regulatory Commission (NRC) has made large amounts of 

information, more than required by law, routinely available to the public. However, in the 

post-September 11, 2001, environment, the NRC, like many other agencies, has found it 

necessary to be more judicious in what it voluntarily releases so that it does not inadvertently 

provide assistance to those who might use this information for malevolent acts. 

The NRC developed guidance in SECY-04-0191, “Withholding Sensitive Unclassified 

Information Concerning Nuclear Power Reactors from Public Disclosure,” dated 

October 19, 2004, and advised licensees in NRC Regulatory Issue Summary (RIS) 2005-26, 

“Control of Sensitive Unclassified Non-Safeguards Information Related to Nuclear Power 

Reactors,” dated November 7, 2005, on the conduct of a broad security/sensitivity review to 

assess whether documents associated with reactor licensees should be made publicly available 

in the first instance as a matter of administrative discretion. The NRC has now developed the 

guidance in this enclosure, which addresses the criteria for screening from public disclosure 

certain types of information associated with various classes of materials licensees, applicants, 

certificate holders, and other entities. 

Consistent with the Commission’s Staff Requirements Guidance on SECY 05-0091, “Task 

Force Report on Public Disclosure of Security-Related Information,” dated June 30, 2005, the 

screening criteria in these guidelines “...should follow the principles for withholding 

security-related information under FOIA.” Although the NRC developed these security-related 

sensitive information screening criteria with the principles of the Freedom of Information Act 

(FOIA) in mind, a review for security-related sensitive information does not substitute for a FOIA 

review. The NRC will continue to review and process FOIA requests independently from the 

security-related sensitive information review process.
RIS 2005-31, Rev. 1 

Page 2 of 23 

ORGANIZATION OF THIS ENCLOSURE

Table 1 outlines the contents of this enclosure: 

• Section 1 indicates the criteria under which documents may be released to the public

without any further screening. However, Section 1 also notes specific requirements for

withholding documents in certain cases even if the documents meet the criteria. 

• Section 2 contains general criteria for screening documents that do not meet the criteria 

in Section 1. 

• Appendices 1–5 contain guidance, in addition to that in Section 2, for screening

documents specific to fuel cycle facilities; decommissioning and low-level waste sites;

medical, industrial, and academic uses of nuclear materials; spent fuel/transportation;

and export/import, respectively. 

Table 1 Stakeholders Using This Guidance and Applicable Sections of the Guidance1

STAKEHOLDER APPLICABLE SECTION AND APPENDIX 

Fuel cycle facilities, including milling,

conversion, enrichment, and fuel fabrication

facilities 

Sections 1 and 2 for general information and

Appendix 1 

Decommissioning and low-level waste sites Sections 1 and 2 for general information and

Appendix 2 

Medical, industrial, and academic uses of

nuclear materials 

Sections 1 and 2 for general information and

Appendix 3 

10 CFR Part 71 certificate holders and

registered users 

Sections 1 and 2 for general information and

Appendix 4, Parts A, B, and E 

Special attention should be given to the 

guidance on detailed design drawings and

control of the registered users list for

transportation packages. 

1 With regard to high-level waste, Subpart J, “Procedures Applicable to Proceedings for the Issuance of Licenses 

for the Receipt of High-Level Radioactive Waste at a Geologic Repository,” of Title 10 of the Code of Federal 

Regulations (10 CFR) Part 2, “Agency Rules of Practice and Procedure,” contains requirements that an applicant 

of the proposed geological repository at Yucca Mountain in Nevada must follow when making information publicly 

available through the Licensing Support Network. 
RIS 2005-31, Rev. 1 

Page 3 of 23 

 . 

STAKEHOLDER APPLICABLE SECTION AND APPENDIX 

10 CFR Part 71 quality assurance program 

(QA) holders 

Sections 1 and 2 for general information and 

Appendix 4, Parts A, B, and E 

Based on the NRC staff’s experience, most QA 

program holder submittals do not contain 

sensitive information as defined in this RIS. 

However, attention should be given to the 

guidance on detailed design drawings and 

control of the registered users list for 

transportation packages. 

10 CFR Part 72 certificate holders, general 

licensees, and specific licensees 

Sections 1 and 2 for general information and 

Appendix 4, Parts A, B, C, D, and E 

Export and Import Sections 1 and 2 for general information and 

Appendix 5 
RIS 2005-31, Rev. 1 

Page 4 of 23 

 . 

SECTION 1: GENERAL SCREENING CRITERIA FOR DOCUMENTS TO BE RELEASED TO THE 

PUBLIC

 

A. Low-Hazard Information Documents 

Documents that meet the following criteria may be released without the need for any 

further screening, except as specifically noted: 

(1) Documents that specify the quantities of radionuclides located in any single 

location if those quantities are below the International Atomic Energy Agency’s 

Category 3 quantities (as listed in Table 2 of these guidelines). However, the 

staff will withhold from public access the exact location of the material even if 

material levels are below the Category 3 threshold values. Thus, the staff will 

release a document if it indicates a general location (e.g., in a certain building), 

but if the document gives the exact location (e.g., “Room 12”), the staff will redact 

the exact location unless the location is intuitively obvious. 

(2) Documents from licensees (other than fuel cycle licensees) authorized to 

possess radionuclides that are not listed in Table 2. However, the staff will 

withhold information on the exact location of this radioactive material. 

(3) Uranium recovery documents describing or discussing yellow cake and mill 

tailings only. 

(4) Current information on decommissioning materials sites with diffuse 

contamination only. However, check for other active licenses or radioactive 

material at the site (e.g., high-activity reactor components and high-activity 

waste) and screen any related documents separately. 

(5) Documents concerning terminated licenses for which all radioactivity except 

diffuse contamination has been removed. However, screen old files for 

operational information that may contain sensitive information. 

B. Information Readily Available to the Public Elsewhere (Based on Reactor Criteria 

Approved by the Commission (SECY-04-0191)) 

 The following criteria apply to information on materials facilities: 

(1) If the information is available from open source literature such as text books, 

Web sites, or other sources, an NRC decision to withhold the information may 

decrease the openness of the agency’s regulatory programs without obstructing 

an adversary. 

(2) Information clearly visible from locations accessible to the public, including 

general (low-resolution) drawings of the site and adjacent areas, is generally 

released. 
RIS 2005-31, Rev. 1 

Page 5 of 23 

 . 

SECTION 2: GENERAL SCREENING CRITERIA FOR DOCUMENTS TO BE WITHHELD 

FROM PUBLIC RELEASE 

This section lists the general screening criteria that the NRC staff will use for withholding 

information from the public, as well as the information that the staff will release. 

A. Facilities Where Licensed Material May Be Located

(1) The NRC staff will withhold the following information related to locations and 

quantities of radioactive material that equal or exceed the threshold values listed 

in Table 2: 

(a) information for identifying the exact locations of radioactive material 

The staff will release a document if it indicates a general location (e.g., in 

a certain building), but if the document gives the exact location 

(e.g., “Room 12”), the staff will withhold it unless the location is intuitively 

obvious. 

 (b) information on possession limits or actual inventories of radionuclides 

 (c) manufacturers and model numbers of sealed sources and devices 

 (d) for fuel cycle facilities, information on possession limits and 

 inventories of enriched uranium and plutonium exceeding a critical mass 

(e) lists of licensees registered to use transportation packages approved by 

the NRC under 10 CFR Part 71, “Packaging and Transportation of 

Radioactive Material”

 (2) The NRC staff will release the following information: 

 

 (a) identification of radionuclides and form 

(b) 10 CFR Part 71 certificates and information under 10 CFR Part 72, 

“Licensing Requirements for the Independent Storage of Spent Nuclear 

Fuel and High-Level Radioactive Waste, and Reactor-Related Greater 

Than Class C Waste,” related to radionuclide form, content, quantities, 

model numbers, and locations of independent spent fuel storage 

installations regardless of the quantities 

(c) event reports involving lost, stolen, abandoned, or found radioactive 

material, regardless of whether the radioactive material equals or exceeds 

the quantities specified in Table 2 

B. Design of Structures/Equipment 

(1) The NRC staff will withhold the following information for design of structures and 

equipment (site specific):
RIS 2005-31, Rev. 1 

Page 6 of 23 

 . 

 (a) information related to security requirements, information from analyses 

 that could reveal vulnerabilities, reports of specific or predicted failures, 

 and any other information that could reasonably be expected to be 

 useful to potential adversaries 

(b) information related to predicted structural failures that could be useful to 

potential adversaries (see Appendix 1 for specific guidance on fuel cycle 

facilities) 

(2) The NRC staff will release the following information: 

Notwithstanding paragraph B(1)(b) above, the NRC staff will release information 

on the design of structures provided to the NRC, which typically consists of 

analyses to show that the design feature will withstand the combinations of 

forces associated with design-basis events and natural hazards. Such analyses 

do not typically provide realistic information on the failure of structural features

and, except for fuel cycle facilities, are not considered sensitive. 

C. Nearby Facilities 

The NRC staff will withhold information related to nearby facilities if the information 

might reasonably be helpful to those planning a malevolent act. 

D. Design Information: Spent Fuel Casks, Transportation Packages, and Other Information 

 

(1) The NRC staff will withhold information related to nonsite-specific spent fuel 

casks, transportation packages, sealed source and device catalog and files, and 

other such items, including the following types of information: 

 (a) drawings that show detailed design information 

 (b) design/performance information that indicates vulnerabilities that could 

 reasonably be expected to be useful to potential adversaries 

(2) The NRC staff will release text information describing how spent fuel casks, 

transportation packages and devices/sources are constructed. 

E. Emergency Planning/Fire Protection Information 

(1) In regard to emergency planning/fire protection information, the NRC staff will 

withhold the following information: 

 (a) the document in its entirety if it contains site-specific information that 

 would be useful to an adversary in planning a malevolent act 

The NRC staff will review any considerations or requests for release on a 

case-by-case basis. As part of the review, the staff will determine 

whether the State or local governments are withholding related 

information as sensitive.
RIS 2005-31, Rev. 1 

Page 7 of 23 

 . 

 (b) detailed information describing response capabilities (e.g., personnel and 

 resources available) 

(c) information and drawings identifying the locations of radioactive material 

and onsite routes and pathways to or from the locations of radioactive 

material, especially detailed descriptions of areas not normally visible to 

the public 

(d) information that State or local government agencies have designated as

sensitive 

F. Security Program Information 

Much information related to security programs at fuel cycle facilities and other materials

facilities with high risk sources has already been designated to be withheld as classified 

information, Safeguards Information, or proprietary information. In addition to 

withholding classified information, Safeguards Information, or proprietary information, 

the NRC staff will withhold any security information that could reasonably be expected 

to be useful to potential adversaries. In addition, certain categories of information are 

protected under 10 CFR Part 37, “Physical Protection of Category 1 and Category 2 

Quantities of Radioactive Material.” 

G. Vulnerability and Security Assessments, Accident Analyses, Safety Analyses, and Risk 

 Assessments 

 (1) The NRC staff will withhold the following information: 

(a) assessments that use a malevolent event as an initial condition

(e.g., vulnerability/security analysis) 

 (b) descriptions of structural features related to potential malevolent acts 

 (c) detailed information and drawings describing the specific locations of

equipment that is relied upon for safety or security 

(d) discussions of safety features or mitigation strategies within

vulnerability/security assessments 

(e) any analysis that identifies which events have significant consequences 

and which events do not 

(f) information related to security events and any information that could be

useful to an adversary as a result of the identification of vulnerabilities 

(2) The NRC staff will release typical accident analyses that involve conservative 

models to demonstrate a facility’s ability to respond to design-basis events 

(i.e., nonsecurity-related events), unless the analysis could reasonably be 

expected to be useful to an adversary. 
RIS 2005-31, Rev. 1 

Page 8 of 23 

 . 

APPENDICES 1–5: ADDITIONAL GUIDANCE FOR SECURITY-RELATED SENSITIVE

INFORMATION SCREENING REVIEWS

Appendices 1–5 contain additional guidance for screening documents for security-related

sensitive information specific to types of facilities and uses of materials. These appendices 

cover the following topics, respectively: 

(1) fuel cycle facilities, including milling, conversion, enrichment, and fuel fabrication

facilities 

(2) decommissioning and low-level waste sites 

(3) medical, industrial, and academic uses of nuclear materials 

(4) spent fuel/transportation (10 CFR Part 71 certificate holders and registered users;

10 CFR Part 71 QA program holders; and 10 CFR Part 72 certificate holders, general 

licensees, and site-specific licensees) 

(5) export/import licensing 
RIS 2005-31, Rev. 1 

Page 9 of 23 

 . 

APPENDIX 1 

FUEL CYCLE FACILITY REVIEWS 

NRC Contact: Division of Fuel Cycle Safety, Safeguards, and Environmental Review, Office of 

Nuclear Material Safety and Safeguards 

A. Descriptions of Facilities Where Licensed Material May Be Located 

(1) Withhold information on the quantity of enriched uranium or plutonium authorized 

in possession limits, or possessed in actual inventories, when the quantity 

exceeds a critical mass. Information identifying radionuclides and 

chemical/physical forms authorized may be released. 

(2) Withhold information related to military contract operations, even if it is publicly 

available elsewhere. 

(3) Withhold information that identifies the exact locations (e.g., detailed floor plans) 

of radioactive and hazardous material whose release or theft could allow 

adversaries to create a diversion for theft of material or result in a significant 

consequence. Planning a sabotage activity (e.g., bombing a building) would 

likely require less detailed information than planning a theft, for which exact 

locations would likely be necessary. 

(4) Withhold information about the design of structures that consists of analyses to 

show that design features will withstand the forces associated with both 

security-related scenarios and nonsecurity-related scenarios, such as tornadoes, 

high winds, and snow loads. Analyses indicating forces associated with 

nonsecurity regulatory requirements could be useful in planning terrorist 

activities. For example, information related to seismic loadings could be used to 

determine blast loads for bombs. 

(5) Withhold detailed design information, including diagrams showing dimensions, 

material properties, and descriptions of how the facility/equipment is constructed. 

Additionally, withhold process information that could potentially allow an 

adversary to access radioactive or hazardous materials or gain knowledge of 

detailed information or potential weaknesses of systems designed to ensure safe 

operations (necessary to prevent or mitigate accidents) at fuel cycle facilities. 

B. Nonsite-Specific Design Information 

There is no additional fuel cycle facility guidance for this category. 

C. Emergency Planning/Fire Protection Information 

(1) Withhold site-specific information that would be useful to an adversary planning a

malevolent act. This includes detailed information or potential weaknesses of 

systems designed to ensure safe operations (necessary to prevent or mitigate 

accidents) at fuel cycle facilities. Withhold detailed information and drawings of 

areas not normally visible to the public. This includes information identifying 

routes to or from the locations of radioactive and hazardous material whose 

release or theft could allow adversaries to achieve their goals. 
RIS 2005-31, Rev. 1 

Page 10 of 23 

 . 

(2) Withhold information that State or local government agencies have designated as 

sensitive. 

(3) Withhold any detailed accident analysis that identifies which accidents have 

significant consequences and which accidents do not. Accident analysis 

information can appear in many documents (e.g., an emergency plan, fire 

protection plan, integrated safety analysis summary, environmental report or 

assessment). General information may be releasable, but details should be 

withheld. 

(4) Withhold site-specific emergency action levels used to declare emergencies. 

(5) Withhold detailed information about response capabilities (e.g., personnel and 

resources available). 

D. Security Program Information 

(1) Much information related to security programs at fuel cycle facilities and other 

materials facilities with high-risk sources has already been designated to be 

withheld as proprietary information, classified information, or Safeguards 

Information. 

(2) Withhold information on security equipment and programs, descriptions of 

equipment and radioactive or hazardous materials, and accident studies that 

closely resemble programs, equipment, radioactive or hazardous materials, and 

studies at other active licensee sites if that information would reveal 

vulnerabilities or would be expected to be useful to adversaries at active licensee 

sites. 

E. Vulnerability and Security Assessments and Accident Analyses 

(1) Withhold detailed information and drawings describing the exact locations of 

radioactive or hazardous materials or that would allow adversaries to gain 

knowledge of detailed information or potential weaknesses of systems designed 

to ensure safe operations (necessary to prevent or mitigate accidents) at fuel 

cycle facilities. 

(2) Withhold any detailed accident analysis that contains accident sequences, 

identifies accident consequences, identifies systems and components that are 

relied upon for safety, or identifies which accidents have significant 

consequences and which accidents do not. Accident analysis information can 

appear in many documents (e.g., an emergency plan, fire protection plan, 

integrated safety analysis summary, environmental assessment). General 

information may be acceptable, but details should be withheld. 
RIS 2005-31, Rev. 1 

Page 11 of 23 

 . 

(3) Withhold information identifying the exact locations (e.g., detailed floor plans) of 

radioactive and hazardous material whose release or theft could allow 

adversaries to create a diversion for the theft of material or could result in a 

significant consequence. Planning a sabotage activity (e.g., bombing a building) 

would likely require less detailed information than planning a theft, for which 

exact locations would likely be necessary. 
RIS 2005-31, Rev. 1 

Page 12 of 23 . 

APPENDIX 2 

DECOMMISSIONING AND LOW-LEVEL WASTE SITE REVIEW 

NRC Contact: Division of Decommissioning, Uranium Recovery, and Waste Programs 

(DUWP), Office of Nuclear Material Safety and Safeguards 

DECOMMISSIONING AND LOW-LEVEL WASTE SITE CRITERIA 

Note that U.S. Nuclear Regulatory Commission (NRC) Regulatory Issue Summary 2005-26, 

“Control of Sensitive Unclassified Nonsafeguards Information Related to Nuclear Power 

Reactors,” dated November 7, 2005, informs licensees of the appropriate handling of sensitive 

unclassified nonsafeguards information for decommissioning reactors. 

The following criteria apply: 

(1) “Diffuse contamination” consists of soil, ground water, and surface contamination on and 

in buildings, including that which is on equipment, floors, walls, and other surfaces. It 

also could include volumetrically contaminated materials whose concentrations are 

sufficiently low. 

For determining whether only diffuse contamination is present at a decommissioning 

site, apply the following information derived from the International Atomic Energy 

Agency’s Code of Conduct on the Safety and Security of Radioactive Sources (Code of 

Conduct) (ADAMS Accession Number ML043270621) (see Table 2). Category 3 sources 

in the Code of Conduct are typically about 1 curie. (The NRC is developing a 

rulemaking to control the import and export of such sources.) At a concentration of 

2,000 picocuries per gram, which is well above the concentrations of plutonium typically 

found in soil at sites undergoing decommissioning, this equates to approximately 15,000 

cubic feet of material, which is well in excess of the amount a terrorist could reasonably 

use for malevolent purposes. For materials at the Class A limit for plutonium 

(10 nanocuries per gram) in Title 10 of the Code of Federal Regulations

(10 CFR) Part 61, “Licensing Requirements for Land Disposal of Radioactive Waste,” 

the volume of waste that would contain the Category 3 activity limit for plutonium would 

be 3,000 cubic feet, which is also in excess of the amount a terrorist could reasonably 

use. However, for cobalt-60, the amount of loose material or rubble at the Class A limit 

(700 curies per cubic meter) containing the Category 3 quantity (about 1 curie) would be 

less than 0.1 cubic foot, which is an amount that could easily be used for malevolent 

purposes because of its small volume. 

 

Reviewers should apply values taking into consideration the examples given above in 

determining whether a decommissioning site is within the threshold values. 
RIS 2005-31, Rev. 1 

Page 13 of 23 . 

GENERAL GUIDANCE FOR DECOMMISSIONING AND LOW-LEVEL WASTE SITES

Most sites undergoing decommissioning are expected to be below the threshold values in Table 

2, such that most licensing documents can be released. Sensitivity reviews must be conducted 

on documents related to low-level waste storage, safety, and security systems and procedures. 

Reviews should focus on determining whether the information contained in these documents 

could be useful to an adversary in planning a terrorist act. Examples include the location and 

security arrangements for high-activity waste, the location of highly activated components, or 

the transportation security arrangements for high-activity waste or activated components. 

For fuel cycle, materials, and spent fuel pool and independent spent fuel storage installation 

licensees that are undergoing decommissioning, issues that are not unique to decommissioning 

(e.g., descriptions of plant processes, vulnerability/security assessments) should be reviewed 

with regard to Appendices 1, 3, and 4, respectively. 

A. Descriptions of Facilities Where Licensed Material May Be Located 

(1) Withhold information identifying the exact locations of radioactive material 

(e.g., detailed drawings or maps of facilities, room numbers and locations, and 

specific locations of waste storage/processing operations). 

(2) Withhold design information that could reasonably be expected to be useful to 

potential adversaries. Examples include detailed drawings or maps showing the 

locations of security measures/operations and infrastructure, locations of critical 

site infrastructure (electrical or power systems), and the design of facilities that 

could be useful in developing approaches to breech the facility. 

(3) Withhold procedures for the receipt of low-level waste at a waste facility or 

processing site. 

(4) For transportation package information provided in connection with 

decommissioning or low-level waste disposal licensing, consider Appendix 4 for 

sensitivity of the information.
RIS 2005-31, Rev. 1 

Page 14 of 23 . 

APPENDIX 3 

REVIEWS OF MEDICAL, INDUSTRIAL, AND ACADEMIC USERS 

OF NUCLEAR MATERIALS 

NRC Contact: Division of Material Safety, State, Tribal, and Rulemaking Programs, Office of 

Nuclear Material Safety and Safeguards 

A. Descriptions of Facilities Where Licensed Material May Be Located (Equals or Exceeds 

the Threshold Values in Table 2) 

(1) Copies of Licenses and Mailing Lists 

(a) For copies of licenses, release authorized radionuclides and form. 

Withhold authorized quantities. Withhold manufacturers and model 

numbers of sealed sources and devices. Withhold information that 

identifies buildings or rooms where radioactive material is located. (This 

may be in the license condition that specifies the authorized location.) 

(b) Withhold mailing lists that are compiled for security purposes or that 

identify facilities that may have quantities of radioactive material that 

equals or exceeds the threshold values listed in Table 2 or vulnerable 

facilities such as those that possess material that equals or exceeds the 

threshold values in Table 2 but do not aggregate the material. 

(c) Release individual mailing addresses and the street address where 

material is located (normally included on licenses). 

(2) Locations of Radioactive Material 

(a) Withhold lists of authorized or actual inventories of radionuclides. 

(b) Withhold building numbers and room numbers (other than mailing 

addresses) or similar information that identifies the locations of material. 

(c) Withhold site drawings that identify individual buildings on the licensee 

site. 

(d) Withhold building drawings that identify the location of radioactive 

material or onsite pathways or routes to and from locations of radioactive 

material. 

(e) Release individual mailing addresses and street addresses.
RIS 2005-31, Rev. 1 

Page 15 of 23 . 

(3) Site-Specific Design/Description of Structures, Equipment, and Operating 

Procedures 

(a) Most descriptions of structures, equipment, and procedures may be 

released if they are not security related. 

(b) Withhold drawings of buildings, rooms, and devices in which radioactive 

material is located. 

(c) Withhold manufacturers and model numbers of sealed sources and 

devices. 

(d) Withhold information on security programs, guards, access controls, key 

cards, alarms, barriers, chains, and locks. 

B. Nonsite-Specific Design Information: Sealed Source and Device Catalog 

(1) Release information on addresses of manufacturers/distributors. 

(2) Establish a password system for sensitive information for users who have with a 

valid need to know and who have agreed to protect the information from 

unauthorized disclosure. 

C. Emergency Planning/Fire Protection Information 

(1) Release general descriptions of emergency procedures for safety-related events, 

such as radioactive material spills, releases, contamination, and fires. 

(2) Withhold information on routes to and from locations of radioactive material. 

(3) Withhold information related to responses to security events and malevolent 

events. 

(4) Withhold information on responses of offsite law enforcement officials. 

(5) Withhold information designated by State or local governments as sensitive. 

D. Security Program Information 

 

(1) For applicable licensees— 

(a) Under Title 10 of the Code of Federal Regulations (10 CFR) 37.43(d), 

licensees limit access to, and unauthorized disclosure of, their security 

plan, implementing procedures, and the list of individuals that have been 

approved for unescorted access. 
RIS 2005-31, Rev. 1 

Page 16 of 23 . 

(b) Under 10 CFR 37.77(f), individuals who receive schedule information 

related to shipments of Category 1 material, as identified in Appendix A, 

“Category 1 and Category 2 Radioactive Materials,” to 10 CFR Part 37, 

“Physical Protection of Category 1 and Category 2 Quantities of 

Radioactive Material,” are required to limit access to, and unauthorized 

disclosure of, that information. 

(2) Withhold any security information that is related to malevolent events or 

suspicious incidents or that could be useful to potential adversaries. Examples 

include information on guards, access controls, key cards, alarms, barriers, 

chains, and locks. 

E. Vulnerability and Security Assessments and Accident Analyses 

There is no additional guidance for medical, industrial, and academic users of nuclear 

material for this category. 
RIS 2005-31, Rev. 1 

Page 17 of 23 

 . 

APPENDIX 4 

SPENT FUEL/TRANSPORTATION REVIEWS 

NRC Contact: Division of Spent Fuel Management, Office of Nuclear Material Safety and 

Safeguards 

A. Descriptions of Facilities Where Licensed Material Is Located 

SUBJECT DISCUSSION AND TYPICAL CONTROLS

10 CFR Part 72 Specific Independent 

Spent Fuel Storage Installation (ISFSI)

Licenses and General Licenses 

- Text descriptions of the following: 

general description, site 

characteristics, principal design 

criteria, storage cask design, 

operations, waste management, 

radiation protection, accident 

analyses, conduct of operations, 

operating controls and limits, and 

quality assurance (QA) 

Release—Information provided to the U.S. Nuclear 

Regulatory Commission (NRC) for specific ISFSI 

licenses and general licenses that typically consists of 

analyses to show that the design feature will withstand 

the combinations of forces associated with 

design-basis events and natural hazards. The 

analyses do not typically provide realistic information 

on the failure of structural features and are not 

considered sensitive. 

10 CFR Part 72 Specific ISFSI 

Licenses and General Licenses 

- Drawings and locations of related 

hazards 

Potentially Withhold—Decisions on the control of 

information that shows the plant site and buildings are 

dependent on the level of detail. Information on 

aspects clearly visible from locations accessible to the 

public near the site is generally released. This 

includes general (low resolution) layout drawings of the 

site and adjacent areas. Drawings showing details 

such as the specific locations of equipment within 

buildings, doorways, stairways, storage areas, and 

other such areas are to be withheld under 

10 CFR 2.390(d). Drawings showing locations of 

hazards in relation to the ISFSI are also withheld. A 

text description of the hazards in relation to the ISFSI 

is uncontrolled and will not be reviewed. 

10 CFR Part 72 Specific ISFSI 

Licenses and General Licenses 

- Nearby industrial, transportation, 

and military facilities 

Withhold—Information related to nonnuclear facilities 

located near the ISFSI such as pipeline data (usually 

withheld per the U.S. Department of Transportation 

(DOT)) and chemical facilities (some data withheld per 

the U.S. Environmental Protection Agency (EPA)) is 

controlled. Other information may be protected by 

other Federal agencies (e.g., U.S. Department of 

Homeland Security, Federal Energy Regulatory 

Commission, EPA, DOT). 

10 CFR Part 72 Specific ISFSI 

Licenses and General Licenses 

Release—Information related to radionuclides, form, 

and quantities. 
RIS 2005-31, Rev. 1 

Page 18 of 23 

 . 

B. Nonsite-Specific Design Information: Transportation Packages and Spent Fuel Casks 

SUBJECT DISCUSSION AND TYPICAL CONTROLS

10 CFR Part 71 Transportation 

Package Descriptions 

- Text descriptions, including 

radionuclide form, content, and 

quantity 

Release—Information provided to the NRC typically 

consists of analyses to show that the design features will 

withstand the combinations of forces associated with 

design-basis events and natural hazards. The analyses do 

not typically provide realistic information on the failure of 

structural features and are not considered sensitive. 

Text descriptions on the design of transportation packages 

do not need to be controlled because (1) 10 CFR Part 71 

does not authorize possession of byproduct, source, or 

special nuclear material, (2) package design information is 

required for commerce both domestically and 

internationally, and (3) the information that “could 

reasonably be expected to be useful to terrorists in 

planning or executing an attack” for transportation 

packages containing large quantities of byproduct, source, 

or special nuclear material is controlled by other means 

(e.g., route controls, escort requirements, and other means 

in accordance with the Commission’s orders, interim 

compensatory measures, or other applicable 

requirements). 

10 CFR Part 71 Drawings Potentially Withhold—Withhold diagrams showing detailed 

design information. Do not withhold drawings that have 

already been made public through Freedom of Information 

Act (FOIA) requests, hearings, rulemakings, or other public 

forums. 

10 CFR Part 71 Transportation QA

Program Plan Descriptions 

Release—An entity wishing to use or fabricate an approved 

transportation package must submit a description of its QA 

program to the NRC. This submittal is assigned a 

10 CFR Part 71 docket and reviewed and approved by the 

staff. The QA program description typically does not 

contain the type of information found in the generic criteria 

that would cause it to be controlled. In addition, filing and 

approving a QA program description does not authorize 

possession of byproduct, source, or special nuclear 

material. 
RIS 2005-31, Rev. 1 

Page 19 of 23 

 . 

SUBJECT DISCUSSION AND TYPICAL CONTROLS

10 CFR Part 71 Package 

Information (as related to 

radionuclides and their form and 

quantities) 

Release 

10 CFR Part 71 Advance 

Notification of Shipments of 

Irradiated Reactor Fuel and 

Nuclear Waste 

Release unless waste shipment is Category 1 material 

subject to 37.77(f) -- Under 10 CFR 71.97, the NRC 

requires advance notifications to the governor of a State, or 

the governor’s designee, and to Tribal officials, of certain 

shipments of high-risk radioactive material. Notification of 

shipments of irradiated reactor fuel in quantities less than 

those subject to 73.37(f) has been moved to 73.35, which 

requires licensees to follow the requirements of Subpart D 

of Part 37. 

10 CFR Part 72 Dry Cask Storage 

Systems 

- Certificates of Compliance 

safety analysis report 

information 

Release—Information provided to the NRC typically 

consists of analyses to show that the design features will 

withstand the combinations of forces associated with 

design-basis events and natural hazards. The analyses do 

not typically provide realistic information on the failure of 

structural features and are not considered sensitive. 

 Text information in the safety analysis report, including 

design information, is not controlled because (1) the design 

of the casks are simple by nature, and the criteria for which 

they are designed are widely known, (2) most cask designs 

involve storage of the casks in open areas on concrete 

pads that are often readily seen from offsite locations, and 

(3) this information has been historically released to the 

public to support rulemaking for approved cask designs and 

other public outreach efforts. 

10 CFR Part 72 Dry Cask Storage 

Systems 

- Drawings 

Potentially Withhold—Withhold diagrams showing detailed 

design information. Do not withhold drawings that have 

already been made public through FOIA requests, hearings, 

rulemakings, or other public forums. 

10 CFR Part 72 Package 

Information (as related to 

radionuclides and their form and 

quantities) 

Release 
RIS 2005-31, Rev. 1 

Page 20 of 23 

 . 

C. Emergency Planning Information 

SUBJECT DISCUSSION AND TYPICAL CONTROLS

10 CFR Part 72 Specific ISFSI 

Licenses and General Licenses 

- Emergency planning 

Release—Most information related to emergency planning 

will not need to be designated as sensitive. Special 

attention is needed to determine whether information 

relates to the response by a licensee or Government 

agency to a terrorist attack. Note that some State and local 

governments consider parts of their emergency plans to be 

sensitive. 

D. Security Program Information 

SUBJECT DISCUSSION AND TYPICAL CONTROLS

10 CFR Part 72 Specific ISFSI 

Licenses and General Licenses 

- Security 

Potentially Withhold—Information related to security 

programs is generally designated as Safeguards 

Information or Safeguards Information—Modified Handling 

and is protected in a manner similar to classified 

confidential information. Security-related information within 

the inspection and oversight program is withheld from public 

disclosure under 10 CFR 2.390(d). 

E. Vulnerability and Security Assessments, Accident Analyses, and Risk Assessments 

SUBJECT DISCUSSION AND TYPICAL CONTROLS

Vulnerability/Security 

Assessments 

- 10 CFR Part 71 

 transportation package designs 

- 10 CFR Part 72 dry cask 

storage systems 

- 10 CFR Part 72 

 ISFSIs 

Withhold—Vulnerability/security assessments used to 

determine the ability of transportation packages, dry cask 

storage systems, or ISFSIs to withstand events from 

malevolent acts have been and will continue to be withheld 

from public disclosure. 
RIS 2005-31, Rev. 1 

Page 21 of 23 

APPENDIX 5 

EXPORT/IMPORT LICENSING 

NRC Contact: Office of International Programs 

(1) On a case-by-case basis that documents compelling reasons, withhold information on 

authorized quantities or actual inventories of radionuclides that equal or exceed the 

threshold values in Table 2, mixed-oxide materials, and enriched uranium above 

6 percent unranium-235. Release information identifying radionuclides and form. 

(2) For quantities that equal or exceed the threshold values in Table 2, withhold information 

on projected or actual shipment schedules, delivery dates, date required, mode of 

transport, storage arrangements, or any other related logistical information provided by 

the licensee in the application or added by the U.S. Nuclear Regulatory Commission. 
RIS 2005-31, Rev. 1 

Page 22 of 23 

Table 2 Radionuclide Screening Threshold Values 

RADIONUCLIDE QUANTITY OF CONCERN1 

(TBq) QUANTITY OF CONCERN2 (Ci)

Am-241 0.06 1.6 

Am-241/Be 0.06 1.6 

Cf-252 0.02 0.54 

Cm-244 0.05 1.4 

Co-60 0.03 0.81 

Cs-137 0.1 2.7 

Gd-153 1 27 

Ir-192 0.08 2.2 

Pm-147 40 1080 

Pu-238 0.06 1.6 

Pu-239/Be 0.06 1.6 

Ra-226 0.04 1.1 

Se-75 0.2 5.4 

Sr-90 (Y-90) 1 27 

Tm-170 20 540 

Yb-169 0.3 8.1 

Combinations of radioactive 

materials listed above3 See footnote below4

1 The activity of multiple aggregated sources should be included when the total activity exceeds the quantity of 

concern. 

2 Terabecquerel (TBq) values are the regulatory standard. Curie values are provided for convenience only and 

have been rounded to two significant figures. 

3 Radioactive materials are to be considered “aggregated” if breaching a common physical security barrier (e.g., a 

locked door at the entrance to a storage room) would allow access to the radioactive material or devices 

containing the radioactive material. See the definition of “aggregated” in 10 CFR Part 37 and related guidance in 

NUREG-2155, “Implementation Guidance for 10 CFR Part 37, ‘Physical Protection of Category 1 and Category 2 

Quantities of Radioactive Material, ’” Revison 1, January, 2015. 

4 For calculations concerning multiple sources or multiple radionuclides, the licensee must use the following 

sum-of-fractions methodology to evaluate combinations of multiple sources or multiple radionuclides when 

determining whether a location equals or exceeds the threshold values and, therefore, is subject to the guidance in 

this document:
RIS 2005-31, Rev. 1 

Page 23 of 23 

(1) If multiple sources of the same radionuclide or multiple radionuclides are aggregated at a location, 

the licensee must determine the sum of the ratios of the total activity of each of the radionuclides 

to verify whether the activity at the location is less than the values in Table 2. If the calculated 

sum of the ratios, using the equation below, is greater than or equal to 1.0, the applicable 

recommendations of this RIS apply. 

(2) First, determine the total activity for each radionuclide from Table 2 by adding the activity of each 

individual source, the material in any device, and any loose or bulk material that contains the 

radionuclide. Then, use the equation below to calculate the sum of the ratios by inserting the total 

activity of the applicable radionuclides from Table 2 in the numerator of the equation and the 

corresponding threshold values from Table 2 in the denominator of the equation. The licensee 

must perform the calculations in metric values (i.e., TBq); the numerator and denominator values 

must be given in the same units. 

݊

 1.0 ≤ ܴ݅ܣ ܴ݅/ ∑

݅=1 

where: 

R1 = total activity for radionuclide 1 

R2 = total activity for radionuclide 2 

Rn = total activity for radionuclide n 

AR1 = threshold value for radionuclide 1 

AR2 = threshold value for radionuclide 2 

ARn = activity threshold value for radionuclide n