NUCLEAR 

NONPROLIFERATION

IAEA Has Made 

Progress in 

Implementing Critical 

Programs but 

Continues to Face 

Challenges

Report to Congressional Requesters

May 2013

GAO-13-139

United States Government Accountability Office
United States Government Accountability Office

Highlights of GAO-13-139, a report to 

congressional requesters 

May 2013 

NUCLEAR NONPROLIFERATION

IAEA Has Made Progress in Implementing Critical 

Programs but Continues to Face Challenges 

Why GAO Did This Study

IAEA plays a crucial role in supporting 

U.S. nuclear nonproliferation goals

through its safeguards and nuclear 

security programs. The Department of 

State (State) coordinates the United 

States’ financial and policy relationship 

with IAEA. IAEA’s safeguards program 

is designed to detect and deter the 

diversion of nuclear material for nonpeaceful purposes, while the agency’s 

nuclear security program assists 

countries in improving the physical 

protection of their nuclear material and 

facilities. IAEA plans to create an 

international fuel bank to guarantee the 

supply of fuel for civilian nuclear power

programs. GAO was asked to examine

(1) any challenges that IAEA faces in 

carrying out its safeguards program, 

(2) any limitations regarding the 

nuclear security program, and (3) the 

status of IAEA’s planned nuclear fuel 

bank. GAO reviewed relevant 

documents and interviewed officials 

from IAEA and U.S. federal agencies, 

15 nuclear nonproliferation experts, 

and representatives from 16 countries. 

What GAO Recommends

GAO recommends, among other 

things, that State work with IAEA to 

(1) clearly define and communicate 

how IAEA will implement the statelevel concept, (2) evaluate the nuclear 

security program’s long-term resource 

needs, and (3) prepare a plan for the 

long-term operation and funding of 

IAEA’s fuel bank. State agreed with 

several of the recommendations and

disagreed with two, including the one 

on the nuclear security program’s longterm resource needs. GAO continues 

to believe that implementing all of 

these recommendations would 

enhance the efficiency and 

effectiveness of IAEA’s programs.

What GAO Found

The International Atomic Energy Agency (IAEA) has taken several steps to 

strengthen its safeguards program since GAO’s 2005 report, including increasing 

the number of countries that are subject to a broader range of safeguards

measures, upgrading its analytical laboratories, and producing its first long-term 

strategic plan. However, the agency faces two critical challenges in further 

improving the effectiveness and efficiency of the safeguards program. First, 

several countries have raised concerns about IAEA’s plans to expand 

implementation of what it calls the “state-level concept” to all countries with 

safeguards agreements by 2014. The state-level concept is an approach in which 

the agency considers a broad range of information about a country’s nuclear 

capabilities and tailors its safeguards activities in each country accordingly. IAEA 

officials told GAO that broader implementation of this approach would allow the 

agency to better allocate resources by reducing safeguards activities where there 

is no indication of undeclared nuclear activities and to focus its efforts on any 

issues of safeguards concern. However, IAEA has not clearly defined and 

communicated how it will implement the state-level concept. As a result, several

countries are concerned that the state-level concept may be applied in a

subjective, potentially discriminatory manner or that it could allow IAEA to be too 

intrusive into their civilian nuclear operations. Second, the agency has not 

quantified the resources it may need to fully implement the state-level concept—

making it difficult to determine its long-term costs and benefits. 

IAEA has continued to support countries’ efforts to improve the security of their 

nuclear material and facilities, but three key issues limit the agency’s ability to 

ensure that its nuclear security resources are used efficiently and effectively. 

First, IAEA’s nuclear security program relies heavily on extra-budgetary 

contributions from donor countries, which makes it difficult to plan and implement 

projects, in part because these funds vary from year to year. Second, IAEA has 

not conducted a needs-based assessment of the resources required beyond its 

2-year budget cycle, which also hinders its ability to ensure that resources are 

directed to the greatest security needs. Third, the extent to which IAEA is 

meeting its nuclear security goals is unclear because IAEA does not 

systematically report on the results of measures used to assess the performance 

of the agency’s nuclear security program. 

IAEA is making progress in establishing an international nuclear fuel bank by 

2014 that is intended to provide eligible countries with a guaranteed supply of low 

enriched uranium (LEU) for civilian nuclear power programs in the event of a 

supply disruption. IAEA’s fuel bank is not intended to provide a routine supply of 

LEU. However, several experts and foreign officials told GAO that the fuel bank’s 

value is uncertain, causing some foreign officials to call it “a solution looking for a 

problem.” For example, the fuel bank may never be used, in part because there 

are already several stable suppliers on the international nuclear fuel market. In 

addition, IAEA does not have a plan in place for the long-term operation and 

funding of the bank, although agency officials told GAO they intend to complete 

such a plan in 2013. Furthermore, the IAEA bank is one of several guaranteed, 

multilateral fuel supply options—including banks established by the United States 

and Russia—for countries seeking an assured supply of nuclear fuel. 

View GAO-13-139. For more information, 

contact David C. Trimble at (202) 512-3841 or 

trimbled@gao.gov.
Page i GAO-13-139 Safeguards, Nuclear Security, and Fuel Bank Programs

Letter 1 

Background 6

IAEA Has Strengthened Its Safeguards Program in Recent Years, 

but Challenges May Limit Efforts to Further Improve 

Effectiveness 12

IAEA Has Continued to Support Nuclear Security, but Three Key 

Issues Limit the Agency’s Ability to Ensure That Its Resources 

Are Used Efficiently and Effectively 29

IAEA Is Making Progress in Implementing a Nuclear Fuel Bank, but 

Uncertainties Exist Concerning Its Value, Potential Market 

Impact, and Long-term Operation 36

Conclusions 47

Recommendations for Executive Action 49

Agency Comments and Our Evaluation 50

Appendix I Objectives, Scope, and Methodology 55

Appendix II Status of Countries’ Safeguards Agreements, Additional 

Protocols, and Small Quantities Protocols in Force with IAEA,

as of December 2012 60

Appendix III Comments from the Department of State 66

Appendix IV Comments from the National Nuclear Security Administration 70

Appendix V GAO Contact and Staff Acknowledgments 72

Table

Table 1: IAEA Safeguards and Nuclear Security Programs Budget 

for 2011 8

Contents 
Page ii GAO-13-139 Safeguards, Nuclear Security, and Fuel Bank Programs

Figures

Figure 1: Countries with or without an Additional Protocol in 

Force, from 2005 through 2012 14

Figure 2: Upgraded Equipment at IAEA’s Environmental Sample 

Laboratory in Seibersdorf, Austria 18

Figure 3: IAEA’s Process for Evaluating Countries’ Safeguards 

Compliance Using the State-Level Concept 23

Figure 4: Map of Kazakhstan Showing the Proposed IAEA Nuclear 

Fuel Bank Site at Ust-Kamenogorsk 37

Abbreviations

DOE Department of Energy

HEU highly enriched uranium

IAEA International Atomic Energy Agency

IPPAS International Physical Protection Advisory Service

LEU low enriched uranium

NNSA National Nuclear Security Administration

NPT Treaty on the Nonproliferation of Nuclear Weapons

USEC United States Enrichment Corporation

U.S. Mission U.S. Mission to the United Nations System 

Organizations in Vienna

This is a work of the U.S. government and is not subject to copyright protection in the 

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Page 1 GAO-13-139 Safeguards, Nuclear Security, and Fuel Bank Programs

441 G St. N.W.

Washington, DC 20548

May 16, 2013

The Honorable Thomas R. Carper

Chairman

Committee on Homeland Security and Governmental Affairs

United States Senate

The Honorable Ron Johnson

Ranking Member

Subcommittee on Financial and Contracting Oversight

Committee on Homeland Security and Governmental Affairs

United States Senate

For more than half a century, the International Atomic Energy Agency 

(IAEA) has played a crucial role in supporting the nuclear nonproliferation 

goals of the United States and the international community through its 

safeguards and nuclear security programs.1 IAEA’s safeguards role—to 

detect and deter the diversion of nuclear material for non-peaceful 

purposes—is particularly relevant in light of major challenges that IAEA 

continues to face with Iran, Syria, and North Korea. IAEA has found these 

three countries to be in non-compliance with their obligations under their 

safeguards agreements with the agency, which are pursuant to the Treaty 

on the Nonproliferation of Nuclear Weapons (NPT). As a result, IAEA 

cannot provide assurance that there are no undeclared nuclear activities 

in these three countries. The NPT, which came into force in 1970, 

requires non-nuclear weapon states that are party to the treaty—countries 

that had not manufactured and detonated a nuclear device before 

January 1, 1967—to agree not to acquire nuclear weapons.2 The NPT 

also requires these countries to subject all nuclear material used in 

 

1 IAEA is an autonomous international organization affiliated with the United Nations, 

established in Vienna, Austria, in 1957. The agency has the dual role of promoting the 

peaceful uses of nuclear energy by transferring nuclear science and technology through 

its nuclear science and applications and technical cooperation programs, and verifying, 

through its safeguards program, that nuclear material subject to safeguards is not diverted 

to nuclear weapons or other proscribed purposes.

2 Under Article II of the NPT, each non-nuclear weapon state party agrees, among other 

things, not to receive any transfer whatsoever of nuclear weapons or other nuclear 

explosive devices; not to manufacture or otherwise acquire nuclear weapons or other 

nuclear explosive devices; and not to seek or receive any assistance in the manufacture 

of nuclear weapons or other nuclear explosive devices.

 
 

Page 2 GAO-13-139 Safeguards, Nuclear Security, and Fuel Bank Programs

peaceful activities to IAEA safeguards.3 As of April 2013, 184 non-nuclear 

weapon states and 5 nuclear weapon states—China, France, Russia, the 

United Kingdom, and the United States—were parties to the NPT.4

In implementing the safeguards agreements required by Article III of the 

NPT, IAEA carries out several important safeguards activities to deter the 

proliferation of nuclear weapons and to ensure that nuclear material and 

facilities are used exclusively for peaceful purposes. As of December 

2011, IAEA reported that 1,209 nuclear facilities and other locations 

outside such facilities containing significant quantities of nuclear material 

were subject to safeguards activities.5 To carry out its safeguards 

activities, IAEA inspectors and analysts collaborate to verify that the 

quantities of nuclear material that non-nuclear weapon states have 

formally declared to the agency are correct and complete and have not 

been diverted for the manufacture of nuclear weapons, other nuclear 

explosive devices, or for unknown purposes. Most countries have 

negotiated an agreement with IAEA known as a comprehensive 

safeguards agreement, which covers all of their civilian nuclear activities 

and serves as the basis for the agency’s safeguards activities. 

Specifically, IAEA’s safeguards activities include on-site inspections, 

environmental sampling,6 remote monitoring, analysis of commercial 

satellite imagery, and analysis of publicly available (open source) 

documents. In addition, the agency installs containment and surveillance 

measures, such as video cameras, to detect the movement of nuclear 

 

3 Under Article III of the NPT, each non-nuclear weapon state party agrees, among other 

things, to accept IAEA safeguards on all source or special fissionable material in all 

peaceful nuclear activities within the territory of such state, under its jurisdiction, or carried 

out under its control anywhere.

4 Under Article IV of the NPT, all parties undertake, among other things, to facilitate the 

exchange of peaceful nuclear technology. Parties in a position to do so must cooperate in 

contributing to the development of nuclear energy for peaceful purposes, especially in the 

territories of non-nuclear weapon states. Under Article I, each nuclear weapon state 

undertakes, among other things, not to transfer to any recipient whatsoever nuclear 

weapons or other nuclear explosive devices.

5 These nuclear facilities and other locations outside facilities included, among other 

things, power reactors, reprocessing plants, and enrichment plants and were located in 

107 countries, plus Taiwan. As a United Nations-affiliated organization, IAEA does not 

officially recognize Taiwan as a state; however, IAEA applies safeguards there.

6 IAEA inspectors collect environmental samples from nuclear facilities and other 

locations, and IAEA’s safeguards analytical laboratories analyze these samples to detect 

traces, if any, of undeclared nuclear material.
 

Page 3 GAO-13-139 Safeguards, Nuclear Security, and Fuel Bank Programs

material and any tampering with agency equipment; as of November 

2012, IAEA had installed 27,000 tamper-proof seals and about 1,200 

cameras at nuclear facilities around the world. Pursuant to their 

safeguards agreements with IAEA, individual countries are obligated to 

implement specific safeguards activities, which vary from country to 

country based on the amount and type of nuclear material a country 

possesses and the type of nuclear facilities and fuel cycle activities a 

country operates. However, IAEA relies on the cooperation of individual

countries for certain safeguards activities that are not legal obligations 

under safeguards agreements, such as granting IAEA permission to 

conduct remote monitoring, which may be domestically sensitive. On an 

annual basis, IAEA draws a conclusion for each country about whether a 

country is compliant with its safeguards agreement. Specifically, IAEA 

draws a conclusion for a given year regarding whether a country’s 

declared nuclear material remained in peaceful activities and, where 

applicable, that there are no indications of undeclared nuclear material or 

activities.

In addition to its safeguards activities, IAEA’s nuclear security work also 

plays an important role internationally. IAEA’s nuclear security program—

which assists countries in enhancing the physical protection, control, and 

accounting of their nuclear and radiological material and nuclear 

facilities—has assumed a higher profile since the September 11, 2001, 

terrorist attacks on the United States. Whereas IAEA’s nuclear security 

program was previously housed within the Department of Safeguards, in 

2002 IAEA created its Office of Nuclear Security within the Department of 

Nuclear Safety and Security. Since then, IAEA’s role in nuclear security 

has grown, in concert with increased international efforts to strengthen 

nuclear security. For example, in March 2012, world leaders from more 

than 50 countries and international organizations met in Seoul, South 

Korea, for the second Nuclear Security Summit, where they renewed their 

political commitment to work toward strengthening nuclear security. To 

assist countries in strengthening nuclear security, IAEA offers, among 

other things, a variety of training courses that draw upon international 

obligations, recommendations, guidelines, and best practices.

To complement the agency’s efforts in its safeguards and nuclear security 

programs, IAEA’s Board of Governors—which provides overall policy 

direction and oversight—approved the creation of an international nuclear 

fuel bank in December 2010. This fuel bank is intended to provide a 
 

Page 4 GAO-13-139 Safeguards, Nuclear Security, and Fuel Bank Programs

guaranteed supply of low enriched uranium (LEU) for civilian nuclear 

power in the event of a supply disruption; it is not intended to provide a 

routine supply.7 As such, the establishment of an IAEA-owned and 

operated nuclear fuel bank is also intended to offer countries an 

alternative to developing their own indigenous fuel supplies, as the use of 

sensitive nuclear fuel enrichment technologies to develop fuel could also 

be used for a clandestine nuclear weapons program. Kazakhstan has 

volunteered to serve as the host state of the fuel bank.

In 2011, IAEA reported a regular budget of $433.1 million, of which the 

United States contributed $111.1 million, making it the largest 

contributor.8 IAEA also reported receiving $317.3 million in 2011 in extrabudgetary cash contributions that a number of countries provided on a 

voluntary basis, in addition to their contributions to the agency’s regular 

budget. According to the Department of State (State), the United States 

contributed $78 million in extra-budgetary cash contributions to the 

agency’s various programs that year. The United States has a strong 

interest in IAEA’s safeguards and nuclear security activities, as well as its 

implementation of the international nuclear fuel bank. We last reviewed 

IAEA’s safeguards and nuclear security programs in 2005 and found a 

number of issues that limited the effectiveness and efficiency of the 

agency’s efforts.9 We recommended, among other things, that State—

which coordinates the United States’ financial and policy relationship with 

IAEA—work with IAEA to consider (1) eliminating or reducing the number 

of agreements that limit IAEA’s authority to implement strengthened 

safeguards measures in countries with small quantities of nuclear 

material, (2) developing a systematic process that forecasts safeguards 

budgetary requirements and resources for the long-term, and (3) 

establishing better measures to evaluate the effectiveness of nuclear 

security activities. State agreed with these recommendations and has 

worked with IAEA to implement some of them. In this context, you asked 

 

7 LEU is uranium that contains the isotope uranium 235 in a concentration of less than 20 

percent and greater than 0.7 percent. Most commercial reactor fuel is enriched to between 

3 percent and 5 percent or less of uranium 235. 

8 Throughout this report, we used the exchange rate of $1.3893 = €1.00, as listed in 

IAEA’s annual report for 2011, to convert IAEA budget figures from euros to U.S. dollars. 

9 GAO, Nuclear Nonproliferation: IAEA Has Strengthened Its Safeguards and Nuclear

Security Programs, but Weaknesses Need to Be Addressed, GAO-06-93 (Washington, 

D.C.: Oct. 7, 2005).
 

Page 5 GAO-13-139 Safeguards, Nuclear Security, and Fuel Bank Programs

us to update information on the IAEA safeguards and nuclear security 

programs, as well as provide information regarding the status of the 

international nuclear fuel bank program. Accordingly, our objectives were 

to examine (1) changes that have occurred since 2005 and challenges, if 

any, that IAEA faces in carrying out its safeguards program; (2) changes 

that have occurred since 2005 and limitations, if any, regarding IAEA’s 

nuclear security program; and (3) the status of IAEA’s planned nuclear 

fuel bank.

To address these objectives, we reviewed documents from IAEA, 

including the agency’s biennial program and budget documents, annual 

reports, and long- and medium-term strategic plans. We also interviewed 

IAEA officials in Vienna, Austria, who are knowledgeable about the 

agency’s safeguards, nuclear security, and fuel bank programs. In 

addition, we collected documents from and interviewed officials from 

State, the Department of Energy’s National Nuclear Security 

Administration (NNSA),10 and national laboratories. We also interviewed 

officials from a nonprobability sample of 16 countries—Brazil, Canada, 

Chile, China, France, Germany, India, Israel, Japan, Pakistan, Russia, 

South Korea, Turkey, the United Arab Emirates, the United Kingdom, and 

the United States—to obtain their views on all three programs.11 We 

selected this diverse range of countries based on a number of factors, 

including, among other things, their civilian nuclear power capabilities, 

geographic location, and NPT status as nuclear weapon or non-nuclear 

weapon states. We also interviewed a nonprobability sample of 15 

nuclear nonproliferation experts, including 4 former senior IAEA officials, 

for their knowledge of IAEA’s safeguards, nuclear security, and/or fuel 

bank programs. We selected these experts based on several factors, 

including their recent prior work at IAEA, their relevant work at academic 

institutions or nongovernmental organizations, or referrals from other 

 

10 NNSA is a separate, semi-autonomous agency within the Department of Energy, with 

responsibility for the United States’ nuclear weapons and nonproliferation programs, 

among other things. NNSA conducts its activities at headquarters and at research and 

development laboratories, production plants, and other facilities. NNSA also provides 

technical assistance to IAEA’s safeguards and nuclear security programs. 

11 Results from nonprobability samples cannot be used to make inferences about a 

population, because in a nonprobability sample, some elements of the population being 

studied have no chance or an unknown chance of being selected as part of the sample. 

However, the results of such a sample can provide examples of individual countries’ views 

of the three IAEA programs.
 

Page 6 GAO-13-139 Safeguards, Nuclear Security, and Fuel Bank Programs

nuclear nonproliferation experts.12 Throughout this report, we distinguish 

between statements made by the U.S. Mission to the United Nations 

System Organizations in Vienna (U.S. Mission) and the 15 other countries 

(foreign missions), and we use the term “some” when referring to two or 

three experts or countries and “several” when referring to four or more 

experts or countries. To assess the reliability of budget data related to 

IAEA’s safeguards, nuclear security, and fuel bank programs, we 

compared data from different published sources, including the Federal 

Register, and we met with IAEA and U.S. officials to discuss these data in 

detail. Based on this work, we determined that data provided by IAEA and

State to be sufficiently reliable for presenting funding information for the 

safeguards, nuclear security, and fuel bank programs. Appendix I 

provides a more detailed discussion of our objectives, scope, and 

methodology.

We conducted this performance audit from January 2012 to April 2013 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 objectives.

This section outlines IAEA’s structure, budget, and the safeguards, 

nuclear security, and fuel bank programs.

IAEA’s governing bodies include the General Conference, composed of 

representatives of 159 countries that contribute to IAEA’s budget 

(member countries)13 and the 35-member Board of Governors, of which 

the United States is a de facto permanent member. A Secretariat, headed 

 

12 Although the information from such a sample cannot be generalized to all such experts, 

it can provide illustrative examples.

13 Throughout this report, we use the term “countries” to refer to states recognized by the 

United Nations. Although nearly all of IAEA’s 159 member countries are party to the NPT 

and are thus subject to its safeguards requirements, IAEA membership is not a 

prerequisite for a country being a party to the NPT, nor is being a party to the NPT a 

requirement for membership in the agency. IAEA may implement safeguards in member 

and non-member countries that are party to the NPT.

Background 

IAEA Structure
 

Page 7 GAO-13-139 Safeguards, Nuclear Security, and Fuel Bank Programs

by the Director General, is responsible for implementing the policies and 

programs of the General Conference and Board of Governors. U.S. policy 

regarding the agency is developed by an interagency process chaired by 

State. The U.S. Mission works closely with State in Washington, D.C., to 

promote the effective functioning of the agency, including management 

reform.

IAEA funds its programs primarily through (1) its regular budget, for which 

all member countries are assessed,14 and (2) extra-budgetary cash 

contributions. In 2011, IAEA reported that its regular budget was $433.1 

million, of which the safeguards program budget comprised $166.1 million 

and the nuclear security program comprised $5.3 million. The agency 

also receives extra-budgetary cash contributions from certain member 

countries, particularly the United States, and other donors on a voluntary 

basis, in addition to the agency’s regular budget and to meet critical 

needs.15 For example, in 2011, IAEA reported that the safeguards 

program received $39.3 million, and the nuclear security program 

received $25 million, in extra-budgetary cash contributions. Of these 

amounts, the United States made extra-budgetary cash contributions of 

$24.8 million and $13.4 million to these programs, respectively. (See 

table 1.) The agency has not used any regular budget funding for the fuel 

bank program but has received $159.4 million in extra-budgetary cash 

contributions and pledges toward the establishment of the fuel bank, of 

which the U.S. government contributed nearly $50 million in 2008, the 

largest single-country donation to the fuel bank.

 

14 Assessed contributions are payments made as part of the obligations that countries 

undertake as members of the United Nations. The current payment structure for assessed 

contributions to IAEA is based on the United Nations scale of assessment, adjusted for 

membership, with a maximum rate (25 percent) and a minimum rate (.001 percent). The 

scale for IAEA also includes a slight premium to cover the costs of the nuclear safeguards 

program. For 2012, the U.S. assessment scale rate for IAEA was 25.6 percent.

15 In addition, a number of member countries make in-kind contributions, such as 

equipment and expert services, to the agency’s various programs on a voluntary basis. 

For instance, according to State, the United States provided $12.7 million in in-kind 

assistance to IAEA’s safeguards program in 2011, including $2.3 million for environmental 

sample analysis. 

IAEA Budget
 

Page 8 GAO-13-139 Safeguards, Nuclear Security, and Fuel Bank Programs

Table 1: IAEA Safeguards and Nuclear Security Programs Budget for 2011

Dollars in millions

Program

Regular budget, as 

reported by IAEA

Extra-budgetary cash 

contributions, as 

reported by IAEA

U.S. extra-budgetary cash 

contributions, as 

reported by State

Safeguards program $166.1 $39.3 $24.8a

Nuclear security program $5.3 $25.0 $13.4b

Source: GAO presentation of IAEA and State budget data.

Note: Regular budget and extra-budgetary cash contributions were calculated at the average 

exchange rate used by the United Nations in 2011 of $1.3893 to €1.00.

a This figure includes extra-budgetary cash contributions from State ($24.2 million) and NNSA ($0.6 

million).

b This figure includes extra-budgetary cash contributions from State ($7.0 million), NNSA ($6.1 

million), and the Department of Homeland Security ($0.3 million).

IAEA has operated under a “zero-real-growth” budget policy environment 

for over 27 years,16 which has generally caused IAEA’s programs to 

experience minimal budgetary growth from year to year and to seek 

efficiencies on an ongoing basis. For example, IAEA reported in 2011 that 

inspectors spent fewer days in the field for certain safeguards activities, 

and the frequency of inspections was reduced, compared with the prior 

year. According to IAEA officials, those cost savings were offset by other 

measures to optimize safeguards activities, such as through remote 

monitoring or unannounced, random inspections.

IAEA derives its authority to establish and administer safeguards from its 

statute, the NPT and regional nonproliferation treaties, bilateral 

commitments between countries, and project agreements with countries. 

Article III of the NPT binds each of the treaty’s 184 non-nuclear weapon 

state parties to conclude an agreement with IAEA that applies safeguards 

to all source and special fissionable material in all peaceful nuclear 

 

16 In 1985, the United Nations imposed a policy of “zero real growth” in an effort to stem 

the upward growth of budgets and to improve the efficiency of the United Nations system 

across the board. The term “zero real growth” is defined as no growth in the budget 

beyond that needed to compensate for inflation. 

Safeguards Program
 

Page 9 GAO-13-139 Safeguards, Nuclear Security, and Fuel Bank Programs

activities within the state’s territory, under its jurisdiction, or carried out 

anywhere under its control.17

IAEA’s safeguards objectives, as traditionally applied, are to account for 

the amount of special fissionable material necessary to produce a nuclear 

weapon, and the time it might take a country to divert this material from 

peaceful use and produce a nuclear weapon. IAEA attempts to meet 

these objectives by using a set of activities by which it seeks to verify that 

nuclear material subject to safeguards is not diverted to nuclear weapons, 

other proscribed purposes, or for unknown purposes. For example, IAEA 

inspectors visit a facility at certain intervals to ensure that any diversion of 

nuclear material is detected before a country using that material has had 

time to produce a nuclear weapon. IAEA also uses “material accounting” 

measures to verify quantities of nuclear material declared to the agency 

and any changes in the quantities over time.

The safeguards program has evolved over the past two decades as IAEA 

has made several efforts to strengthen its effectiveness and efficiency. 

Starting in the early 1990s, in response to the 1991 discovery of a 

clandestine nuclear weapons program in Iraq, IAEA made a radical 

departure from its past practice of generally verifying only the peaceful 

use of a country’s declared nuclear material at declared facilities; at that 

time, IAEA expanded its safeguards efforts to detect potentially 

undeclared nuclear activities as well. Specifically, through its Department 

of Safeguards, the agency began exercising its existing authority under 

safeguards agreements with individual countries to obtain additional 

information about their nuclear and nuclear-related activities. However, 

IAEA recognized that these additional measures were not adequate. As a 

result, in 1997 the Board of Governors approved what it called the “Model 

Additional Protocol” (Additional Protocol)—which, when ratified or 

otherwise brought into force by a country, requires that country to provide 

the agency with a broader range of information on its nuclear and 

nuclear-related activities. It also gives the agency’s inspectors access to 

an expanded range of declared activities and locations, including 

buildings at nuclear sites, and locations where undeclared activities may 

be suspected. A country agrees separately to an Additional Protocol, 

 

17 Source material includes natural uranium, depleted uranium, and thorium; special 

fissionable material includes plutonium-239, uranium-233, and enriched uranium.
 

Page 10 GAO-13-139 Safeguards, Nuclear Security, and Fuel Bank Programs

which supplements the country’s existing safeguards agreement with 

IAEA.

At the time of our 2005 report, IAEA’s safeguards program was in the 

process of strengthening its capability to independently evaluate all 

aspects of a country’s nuclear activities through broader inspector 

access, collecting and analyzing environmental and nuclear material 

samples to verify that countries’ nuclear material declarations are correct 

and complete, and analyzing open source information.18 In addition, we 

reported that IAEA was trying to improve the efficiency of its efforts by 

applying a broader analytical approach—called “integrated safeguards”—

that could result in reduced inspections in those countries that had a 

proven record of compliance with their safeguards obligations. The 

concept of the integrated safeguards approach was for inspectors to 

expand on the traditional material accountancy approach by being “less 

checklist-oriented” and more analytical and, therefore, comprehensive in 

their country evaluations. IAEA’s implementation of integrated 

safeguards, however, is applicable only to countries that have both a 

comprehensive safeguards agreement and an Additional Protocol in force 

and for which IAEA has been able to draw a “broader conclusion.” A 

broader conclusion means that, for a given year, a country has 

demonstrated that all declared nuclear material remained in peaceful 

activities and there are no indications of undeclared nuclear activities. In 

our 2005 report, we also found that another safeguards protocol that 

applies to countries with small quantities of nuclear material—called the 

small quantities protocol—limited IAEA’s ability to detect undeclared 

nuclear material or activities.19 Specifically, this protocol holds in 

abeyance certain safeguards measures as long as a country meets 

specific eligibility requirements. Countries may request that the small 

quantities protocol, which is subject to Board of Governors approval, 

supplement their comprehensive safeguards agreement.

 

18 GAO-06-93. 

19 Under the small quantities protocol, the reference to small quantities of nuclear material 

means, among other things, up to 1 kilogram of special fissionable material, 10 metric tons 

of natural uranium and depleted uranium with an enrichment level above 0.5 percent, 20 

metric tons of natural uranium and depleted uranium with an enrichment level of 0.5 

percent or below, and 20 metric tons of thorium.
 

Page 11 GAO-13-139 Safeguards, Nuclear Security, and Fuel Bank Programs

According to IAEA’s Nuclear Security Plan 2010-2013, the risk that 

nuclear or other radioactive material could be used in malicious acts 

remains high and is regarded as a serious threat to international peace 

and security. For example, since the creation of IAEA’s Incident and 

Trafficking Database in 1995 (formerly called the Illicit Trafficking 

Database), member countries have reported over 2,300 incidents 

involving nuclear and other radioactive materials detected outside of 

regulatory control, including incidents of illicit trafficking. IAEA also 

projects a net increase in the number of nuclear reactors in operation by 

2030. As a result, IAEA has augmented its efforts for countries that 

request its assistance in protecting their nuclear and radiological 

materials and facilities.20 As we previously reported, in the hands of 

terrorists, these materials could be used to produce a simple and crude 

but potentially dangerous weapon, known as a dirty bomb, by packaging 

explosives with the radioactive material for dispersal. Through its Office of 

Nuclear Security, IAEA provides advisory services to member countries to 

establish the necessary infrastructure to protect nuclear and other 

radioactive materials from theft and diversion, protect nuclear installations 

and transport against sabotage and other malicious acts, and combat 

illicit trafficking in nuclear and other radioactive materials. IAEA also 

disseminates information about procedures for dealing effectively with 

nuclear threats through international conferences, training courses, and 

security guidance publications. In addition, IAEA assists member 

countries in implementing nuclear security measures at major public 

events, such as the 2011 Pan American Games in Mexico and the 2012 

European Football Championship in Poland and Ukraine.

IAEA’s international nuclear fuel bank is a relatively new program, in 

contrast to the safeguards and nuclear security programs. The purpose of 

the fuel bank is not to provide a routine supply of LEU fuel but to 

guarantee an international supply for civilian nuclear power in the event of 

 

20 Radiological material—encapsulated in steel or titanium and called a sealed source—is 

commonly found in equipment used by hospitals and medical facilities to treat cancer 

patients, among other things. See GAO, Nuclear Nonproliferation: Additional Actions 

Needed to Improve Security of Radiological Sources at U.S. Medical Facilities, 

GAO-12-925 (Washington, D.C.: Sept. 10, 2012). Radiation detection equipment is 

installed at border crossings and ports of entry, such as seaports and land border 

crossings to prevent nuclear smuggling. See GAO, Combating Nuclear Smuggling: DHS 

Has Developed Plans for Its Global Nuclear Detection Architecture, but Challenges 

Remain in Deploying Equipment, GAO-12-941T (Washington, D.C.: July 26, 2012).

Nuclear Security Program

Fuel Bank Program
 

Page 12 GAO-13-139 Safeguards, Nuclear Security, and Fuel Bank Programs

a supply disruption. As specified by the agency’s Board of Governors, the 

fuel may be purchased on a non-discriminatory, non-political basis by 

IAEA member countries that are meeting their nonproliferation obligations 

with the agency. These obligations include having a comprehensive 

safeguards agreement in force. The fuel bank is also meant to provide 

countries with a “credible alternative” to the pursuit of sensitive nuclear 

fuel enrichment activities that employ the same technology that can be 

used to produce nuclear material for nuclear weapons. One of the Board 

of Governors’ conditions for the fuel bank is that it not disrupt the 

international nuclear fuel market. Funding for the fuel bank has come 

from private and public sources. In addition to the U.S. government’s 

extra-budgetary cash contribution of nearly $50 million, a Washington, 

D.C.-based nongovernmental organization—the Nuclear Threat 

Initiative—has provided $50 million,21 and other donors have collectively 

contributed or pledged nearly $60 million.22 In December 2010, IAEA’s 

Board of Governors approved the establishment of the fuel bank with the 

support of 28 of the 35 board members, including the United States.

IAEA has taken four key steps to strengthen its safeguards program since 

we last reported on this in 2005: (1) successfully encouraged more 

countries to bring an Additional Protocol into force, giving IAEA expanded 

authority and tools to detect undeclared nuclear activities; (2) increased 

the number of countries subject to a broader range of safeguards 

measures; (3) started to upgrade its safeguards analytical laboratories in 

Austria with new equipment and facilities; and (4) produced its first longterm strategic plan for the Department of Safeguards to formally identify 

program objectives and goals. IAEA plans to further improve the 

effectiveness and efficiency of the safeguards program by expanding 

implementation of the “state-level concept” to all countries with 

safeguards agreements by 2014. The state-level concept is an approach 

in which the agency considers a broad range of information about a 

country’s nuclear capabilities and tailors its safeguards activities in each 

country accordingly. However, several member countries have raised 

 

21 The Nuclear Threat Initiative is a nongovernmental organization focused on 

strengthening global security by preventing the spread of nuclear, biological, and chemical 

weapons.

22 As of April 1, 2013, IAEA reported that the agency had received contributions or 

pledges to IAEA’s nuclear fuel bank from the European Union ($34.7 million), Kuwait ($10 

million), the United Arab Emirates ($10 million), and Norway ($5 million). 

IAEA Has 

Strengthened Its 

Safeguards Program 

in Recent Years, but 

Challenges May Limit 

Efforts to Further 

Improve Effectiveness
 

Page 13 GAO-13-139 Safeguards, Nuclear Security, and Fuel Bank Programs

concerns about the state-level concept that may hinder broader 

implementation. In addition, the agency has not quantified the resources 

that it may need to expand implementation of the state-level concept, 

making it difficult to determine the associated long-term costs and 

benefits.

Since 2005, 46 more countries have brought an Additional Protocol into 

force, which gives IAEA greater authority and tools to search for 

undeclared nuclear facilities and activities. Specifically, 119 countries had 

concluded an Additional Protocol as of the end of December 2012, 

compared with 73 countries at the end of December 2005.23 Moreover, 

since our 2005 report, the United States and Russia were the last of the 

five nuclear weapon states to bring an Additional Protocol into force, 

which agency officials told us has helped make IAEA’s outreach efforts to 

encourage other countries to conclude an Additional Protocol more 

effective and credible.24 As a result of more countries bringing an 

Additional Protocol into force, IAEA has significantly increased the 

number of countries for which the agency has been able to draw broader 

conclusions about both declared and undeclared activities over the past 7 

years. In 2011, IAEA drew broader conclusions for 58 non-nuclear 

weapon states, and evaluations regarding the absence of undeclared 

nuclear material were still ongoing for the other 51 countries that had both 

comprehensive safeguards agreements and Additional Protocols in force 

at that time.25 By comparison, at the end of 2005, IAEA had drawn 

broader conclusions for 24 non-nuclear weapon states and had such 

evaluations in progress for 46 other countries. A broader conclusion 

refers to the agency’s determination that, for a given year, a country has 

demonstrated that all declared nuclear material remained in peaceful 

 

23 In addition, Taiwan has implemented the measures of the Model Additional Protocol 

since October 1999. As noted earlier, IAEA does not officially recognize Taiwan as a state 

but applies safeguards there.

24 For more information on U.S. efforts regarding the Additional Protocol, see Managing 

Sensitive Information: Actions Needed to Prevent Unintended Public Disclosures of U.S. 

Nuclear Sites and Activities, GA0-10-251 (Washington, D.C.: Dec. 15, 2009). 

25 IAEA typically takes several years to reach an initial broader conclusion for a given 

country and thereafter reevaluates the conclusion on an annual basis. Although the five 

nuclear weapon states have Additional Protocols in force, IAEA cannot draw broader 

conclusions for the nuclear weapon states because they have more limited safeguards 

agreements in force, rather than comprehensive safeguards agreements.

More Countries Have 

Concluded an Additional 

Protocol, Giving IAEA 

Expanded Authority
 

Page 14 GAO-13-139 Safeguards, Nuclear Security, and Fuel Bank Programs

activities and there are no indications of undeclared nuclear activities. 

IAEA can draw a broader conclusion only for those countries that have 

both a comprehensive safeguards agreement and an Additional Protocol 

in force. By contrast, without an Additional Protocol in force, the agency 

cannot provide credible assurances regarding the absence of undeclared 

nuclear material and activities in the country as a whole. In such cases, 

IAEA reports its conclusion for a given year only with respect to whether 

declared nuclear material remained in peaceful activities. Figure 1 shows 

the number of countries with or without an Additional Protocol in force, by 

year, from 2005 through 2012. Appendix II lists the status of countries 

with safeguards agreements and an Additional Protocol in force as of the 

end of December 2012.

Figure 1: Countries with or without an Additional Protocol in Force, from 2005 

through 2012

Note: The total number of countries with or without an Additional Protocol in force from 2005 through 

2012 reflects the number of countries that had safeguards agreements in force with IAEA during 

those years. Data do not include North Korea, as IAEA has not been able to conduct all necessary 

safeguards activities in that country since 1994. Data also do not include Taiwan, although Taiwan 

has had a safeguards agreement in force since 1969 and has implemented the measures of the 

Model Additional Protocol since October 1999.
 

Page 15 GAO-13-139 Safeguards, Nuclear Security, and Fuel Bank Programs

To encourage more countries to bring an Additional Protocol into force, 

the agency continued to implement a plan of action, developed in 2001 

and updated every year, by intensifying its efforts to conclude Additional 

Protocols, especially with countries that have significant nuclear activities. 

In particular, IAEA has continued its efforts to hold training events and 

workshops at the national, regional, and international levels with countries 

to explain what their obligations would be under an Additional Protocol. 

For example, the agency held four outreach events in 2011, including a 

regional seminar for southeast Asian countries with significant nuclear 

activities and a number of bilateral briefings in New York and Geneva.

While universal adoption of the Additional Protocol remains a goal for the 

agency, many countries have not brought it into force. According to a 

public statement by the Head of IAEA’s Department of Safeguards, of the 

60 countries with safeguards agreements that have not concluded an 

Additional Protocol as of December 2012, 7 are engaged in significant 

nuclear activities: Algeria, Argentina, Brazil, Egypt, Iran, Syria, and 

Venezuela. Of those seven countries, Algeria received approval from 

IAEA’s Board of Governors for an Additional Protocol in September 2004 

but has not signed it or brought it into force, Iran signed an Additional 

Protocol in December 2003 but has not brought it into force, and the other 

countries have taken no official action concerning an Additional 

Protocol.26 As we reported in 2005, some countries may be hesitant to 

conclude an Additional Protocol due to (1) concerns about the financial 

costs associated with it; (2) an unwillingness to submit to an intrusive 

inspection regime; (3) their inadequate regulatory systems to collect 

information on all nuclear-related activities; or (4) political factors, such as 

the policies of neighboring countries or the time needed for national 

legislatures to approve an Additional Protocol. For instance, Brazil has 

continued to take the position that an Additional Protocol does not need to 

be universally applied to all countries and that inspections and IAEA 

requests for information are overly intrusive. Brazil has also stated that it 

will not undertake further nonproliferation obligations, including adoption 

of the Additional Protocol, until progress has been made by nuclear

weapon states on disarmament. In addition, Egypt will not bring an 

Additional Protocol into force until Israel signs the NPT, concludes a 

comprehensive safeguards agreement, and implements an Additional 

Protocol.

 

26 GAO-06-93. 
 

Page 16 GAO-13-139 Safeguards, Nuclear Security, and Fuel Bank Programs

Since our 2005 report, IAEA has (1) tightened the terms and conditions of 

a protocol brought by many countries into force concerning small 

quantities of nuclear material and (2) increased the number of countries 

that have comprehensive safeguards agreements in force. As a result, 

the agency has increased the number of countries to which it applies a 

broader range of safeguards measures. Specifically, in September 2005, 

IAEA’s Board of Governors approved revisions to the text of the small 

quantities protocol that, when in force, holds in abeyance certain 

safeguards measures as long as a country meets specific eligibility 

requirements. As revised in 2005, the small quantities protocol is no 

longer available to a country with either an existing or planned nuclear 

facility, and it has reduced the number of safeguards measures held in 

abeyance. For example, the revised small quantities protocol obligates 

countries to make initial declarations to IAEA on the nuclear materials 

they hold, no matter how small, and reinstates the agency’s right to 

conduct ad hoc and special inspections. Since 2005, IAEA has worked 

with countries to voluntarily amend or rescind their original small 

quantities protocols to increase the agency’s ability to detect undeclared 

nuclear material or activities. As of the end of December 2012, 46 

countries had brought the revised small quantities protocol into force, 

including 34 countries that amended their original small quantities 

protocols to reflect the revised text; 4 countries had rescinded their 

original small quantities protocols; and 52 countries still had the original 

small quantities protocol in force. (App. II lists the status of countries with 

small quantities protocols in force as of December 2012.) By contrast, as 

of July 2005, 76 countries had the original small quantities protocols in 

force.

In addition, IAEA has continued to promote the importance of 

comprehensive safeguards agreements through seminars, briefings, and 

other outreach efforts—resulting in 24 more countries bringing such 

agreements into force since our 2005 report. Specifically, as of December 

2012, 171 of the 184 non-nuclear weapon state parties to the NPT had 

brought comprehensive safeguards agreements into force,27 compared 

with 147 countries at the end of 2005. The NPT requires non-nuclear 

weapon states to conclude comprehensive safeguards agreements within 

 

27 The 13 non-nuclear weapon states that had not brought comprehensive safeguards 

agreements into force as of the end of December 2012 were: Benin, Cape Verde, Djibouti, 

Equatorial Guinea, Eritrea, Guinea, Guinea-Bissau, Liberia, Micronesia, Sao Tomé & 

Principe, Somalia, Timor-Leste, and Vanuatu.

IAEA Has Increased the 

Number of Countries That 

Are Subject to a Broader 

Range of Safeguards 

Measures
 

Page 17 GAO-13-139 Safeguards, Nuclear Security, and Fuel Bank Programs

18 months of becoming a party to it.28 However, as we previously 

reported, IAEA officials have indicated that several countries have not yet 

brought such agreements into force because they consider it to be a low 

priority compared with other national priorities or because of other factors.

To strengthen its capabilities to provide independent and timely analysis 

of environmental and nuclear material samples, IAEA embarked on an 

estimated $112 million project in 2007 to upgrade its safeguards 

analytical laboratories in Seibersdorf, Austria, with new equipment and 

facilities. These improvements are expected to result in higher-quality and 

faster analyses of samples collected by IAEA inspectors, particularly as 

the agency anticipates that its workload will rise with a projected 

expansion of civilian nuclear power in the next 30 years. As one of its 

measures to verify that countries’ nuclear material declarations are 

correct and complete, the agency relies on its facilities in Seibersdorf and 

other laboratories in a global network to analyze hundreds of samples 

annually. The modernization of IAEA’s Seibersdorf laboratories is the 

largest capital improvement project the agency has ever undertaken. 

IAEA’s public statements indicate that the project has involved forecasting 

and defining analytical and infrastructure needs, designing the 

laboratories, and site infrastructure and security improvements. In the first 

phase of this two-phase project, the agency expanded its Environmental 

Sample Laboratory in 2011 and installed additional equipment to enhance 

its ability to detect undeclared nuclear material or activities. According to 

IAEA, this equipment is capable of finding “a needle in a haystack” by 

measuring minute particles of uranium found in environmental samples. 

Figure 2 shows the upgraded equipment in service at IAEA’s newly 

expanded Environmental Sample Laboratory. In addition, when we visited 

the laboratory in June 2012, IAEA officials told us that the newly 

expanded facilities will significantly help prevent potential contamination 

of samples, which was a concern at the older facilities due to cramped 

 

28 For nuclear weapon states and for countries that are not party to the NPT, IAEA has 

more limited safeguards agreements. In particular, the agency has limited information 

concerning nuclear activities in North Korea, which withdrew from the NPT in January 

2003. In addition, IAEA has limited information and authority concerning nuclear activities 

in the five nuclear weapon states (China, France, Russia, the United Kingdom, and the 

United States) and three countries that are not parties to the NPT (India, Israel, and 

Pakistan). Specifically, safeguards are implemented in selected nuclear facilities in the five 

nuclear weapon states, and the three non-NPT party countries have only item-specific 

safeguards agreements in force and no Additional Protocol in force. 

IAEA Has Started to 

Upgrade Its Safeguards 

Analytical Laboratories
 

Page 18 GAO-13-139 Safeguards, Nuclear Security, and Fuel Bank Programs

workspace and inadequate air filtration. In the project’s second phase, 

construction for a new facility to house IAEA’s Nuclear Material 

Laboratory in Seibersdorf began in 2012 and is scheduled for completion 

in 2014. 

Figure 2: Upgraded Equipment at IAEA’s Environmental Sample Laboratory in 

Seibersdorf, Austria

Although the project is being partially funded by the agency’s regular 

budget ($32 million through 2013), IAEA also solicited and received 

significant extra-budgetary contributions from several member countries 

and the European Commission. As of early December 2012, the United 

States was the biggest donor, having contributed $21.0 million, and other 
 

Page 19 GAO-13-139 Safeguards, Nuclear Security, and Fuel Bank Programs

donors had collectively pledged or contributed $30.1 million.29 At that 

time, the agency planned to receive another $11.9 million in funding and 

still needed to raise $17.3 million to complete the project. Some experts 

told us the agency had made a compelling case for the project by 

demonstrating the need to member countries to replace facilities and 

equipment that were outdated and deteriorating, putting the agency’s 

ability to provide independent and timely analysis at risk.

In addition to modernizing its Seibersdorf facilities, IAEA has continued its 

efforts to increase the number of laboratories it has qualified to be part of 

its global Network of Analytical Laboratories. The expansion of the 

network is intended to improve the agency’s capacity to handle 

environmental and nuclear material samples and reduce processing 

times. The agency typically relies on two network laboratories to analyze 

a given sample to ensure accuracy, based on consistent results. In 2005, 

we reported that the network was being used beyond its capacity, 

resulting in untimely processing and reporting of results—averaging 2 to 3 

months and sometimes taking as long as 6 months. At that time, in 

addition to the agency’s own laboratories, there were 15 laboratories in 7 

member countries (including the United States) and the European 

Commission in the network. As of July 2012, the network had expanded 

to comprise 19 laboratories in 8 member countries and the European 

Commission, in addition to the agency’s own laboratories. IAEA also 

reported, as of July 2012, that it was in the process of reviewing 

qualifications for additional laboratories in Argentina, Belgium, China, 

Finland, France, Germany, Hungary, South Korea, and the United States 

to join the network.

In August 2010, after conducting an 18-month internal review, IAEA’s 

Department of Safeguards produced a long-term strategic plan for the 

safeguards program for 2012 through 2023. To date, this represents the 

first long-term strategic planning effort by any IAEA department. While the 

agency as a whole does not have a long-term strategic plan in place, 

officials from State and Brookhaven National Laboratory credited the 

Department of Safeguards for developing what they described as a 

 

29 As of early December 2012, the other donors were Canada, the Czech Republic, 

France, Germany, Greece, Ireland, Israel, Japan, Kazakhstan, Netherlands, Norway, 

South Korea, Spain, United Arab Emirates, the United Kingdom, and the European 

Commission.

Safeguards Department 

Produced Its First LongTerm Strategic Plan
 

Page 20 GAO-13-139 Safeguards, Nuclear Security, and Fuel Bank Programs

forward-thinking plan.30 According to a report by one expert we 

interviewed, “The exercise is unprecedented for the Agency and virtually 

unheard of in [United Nations]-related organizations.” 

IAEA has not publicly released the full long-term safeguards plan, 

therefore we did not evaluate it. However, agency officials have made 

presentations and released a 10-page summary of the plan. The 

summary identifies three objectives, seven strategies and goals, and 

dozens of supporting activities covering (1) the conceptual framework for 

safeguards implementation, (2) legal authority, (3) technical capabilities, 

(4) cooperation and partnerships, (5) human resources, (6) financial 

resources, and (7) communication. For example, to support the financial 

resources strategy and the goal of maintaining member countries’ 

confidence in the cost-effective implementation of the safeguards 

program, the plan states that the department will

• assess budgetary needs and seek sufficient and predictable funds 

and prepare for unexpected expenses;

• optimize the use of financial resources and seek further efficiencies 

through, for example, cost‐benefit analyses to guide decision‐making; 

and

• monitor and measure performance toward the achievement of desired 

results and increased transparency and accountability in reporting to 

member countries.

According to IAEA presentations, the expected benefits of the long-term 

safeguards plan include promoting strategic thinking and preparing the 

department for future challenges; unifying departmental planning, 

monitoring, and evaluation activities under one framework; supporting 

internal decision-making concerning priorities and resource allocation; 

and providing better information to member countries. Agency documents 

also indicate that the department will adjust the long-term safeguards plan 

every 2 years, if necessary, following a review of the external 

environment and a risk reassessment. In addition, the department is to 

update the long-term safeguards plan every 6 years, based on a 

 

30 Among other things, the Department of Energy’s Brookhaven National Laboratory 

manages U.S. technical assistance to IAEA’s safeguards program. 
 

Page 21 GAO-13-139 Safeguards, Nuclear Security, and Fuel Bank Programs

performance assessment, and will provide input to the development of the 

next agency-wide, medium-term strategy.

IAEA plans to further strengthen the effectiveness and efficiency of its 

safeguards program by expanding the implementation of an approach 

called the state-level concept to all countries with safeguards 

agreements. According to IAEA documents and officials, this next phase 

in the evolution of safeguards would allow the agency to apply a tailored 

set of safeguards activities and allocate resources for each country as 

appropriate, based on a range of factors about countries’ nuclear 

activities and capabilities as a whole. Such factors include a country’s 

nuclear fuel cycle facilities, knowledge and expertise, legal framework, 

domestic safeguards authority, and past research and development. The 

agency first introduced the state-level concept about 10 years ago under 

integrated safeguards—an approach that encouraged inspectors to be 

more analytical and comprehensive in their country evaluations. Since 

that time, IAEA has implemented the state-level concept only in those 

countries that have both a comprehensive safeguards agreement and an 

Additional Protocol in force and for which the agency has drawn a 

broader conclusion that all nuclear material remains in peaceful activities. 

As of mid-2012, the agency reported it had implemented state-level 

approaches for 53 such countries, plus Taiwan. However, IAEA 

documents indicate that broader implementation of the state-level 

concept would yield greater efficiencies in allocating more resources to 

any issues of safeguards concern. Consequently, the agency plans to 

apply the state-level concept to all countries under safeguards, regardless 

of whether they have a comprehensive safeguards agreement and 

Additional Protocol in force, by 2014.

Agency documents also indicate that broader implementation of the statelevel concept will affect IAEA’s planning, conduct, and evaluation of 

safeguards activities for each country. Specifically, IAEA indicates it will 

consider a complete range of factors about countries’ nuclear activities to 

determine the way in which the agency implements safeguards activities 

for each country and allocates resources in the field, where inspections 

are conducted, and at IAEA headquarters, where open-source, remote 

monitoring, and other analysis is conducted. For example, IAEA officials 

told us that the agency’s safeguards approach might differ for a country 

with few nuclear facilities and a strong domestic safeguards authority, 

compared with the approach used for a country with many facilities and a 

weaker safeguards authority. Ultimately, IAEA officials told us that 

broader implementation of the state-level concept would allow the agency 

IAEA Plans to Expand 

Implementation of the 

State-Level Concept by 

2014 to Better Allocate 

Safeguards Resources
 

Page 22 GAO-13-139 Safeguards, Nuclear Security, and Fuel Bank Programs

to better allocate resources by reducing safeguards activities in those 

countries for which the agency has been able to establish a complete 

picture of nuclear activities, including a determination that there is no 

indication of undeclared activities, thus allowing the agency to focus 

greater efforts and resources on any issues of safeguards concern. 

Furthermore, in contrast to the annual evaluation process used in the 

past—including under the integrated safeguards approach—the agency’s 

evaluations of a country under broader implementation of the state-level 

concept would be continuous and ongoing, and the safeguards 

approaches in a given country would be modified accordingly. According 

to agency documents, this approach would ensure the agency’s 

conclusions remain soundly based and up-to-date. Figure 3 shows IAEA’s 

process for evaluating countries’ safeguards compliance using the statelevel concept.
 

Page 23 GAO-13-139 Safeguards, Nuclear Security, and Fuel Bank Programs

Figure 3: IAEA’s Process for Evaluating Countries’ Safeguards Compliance Using 

the State-Level Concept

According to public statements by the Head of IAEA’s Department of 

Safeguards over the past 2 years, it is necessary to broaden 

implementation of the state-level concept because past safeguards 

approaches have been insufficient to detect undeclared activities, such as 

a clandestine nuclear weapons program in Iraq and covert supply 
 

Page 24 GAO-13-139 Safeguards, Nuclear Security, and Fuel Bank Programs

networks in Libya.31 In addition, the absence of an Additional Protocol in 

force in countries such as Iran and Syria has restricted the agency’s 

ability to look beyond declared facilities and activities, preventing the 

agency from drawing a conclusion on whether there is undeclared nuclear 

material or activities in those countries. The Head of Safeguards has also 

publicly stated that past safeguards approaches have been too “narrow, 

prescriptive, and criteria-driven”—based on the nature and quantity of 

nuclear material and focused on specific safeguards activities for different 

types of facilities within a given country—rather than looking at the 

country more comprehensively. As a result, the Head of Safeguards has 

said, “satisfying the criteria” is in danger of becoming the objective, rather 

than addressing the underlying purpose of the work—to determine 

whether there is any indication of nuclear proliferation. According to this 

senior IAEA official, previous cases of safeguards violations or 

clandestine nuclear weapons development occurred in countries believed 

to have limited nuclear fuel cycles and involved previously exempted or 

undeclared nuclear material.32 Given these previous cases, the Head of 

Safeguards has stated, the quantity of nuclear material in a country’s 

possession, or even the size of its fuel cycle, is not necessarily a 

sufficient indicator of proliferation risk. Instead, IAEA needs to implement 

safeguards in a more adaptable, less predictable manner that considers 

the country’s activities as a whole.

In addition to improving the effectiveness of its safeguards program, IAEA 

officials told us that broader implementation of the state-level concept 

would improve the program’s efficiency by reducing routine inspections 

where IAEA has found no indication of undeclared activities and by 

directing resources to any issues of safeguards concern. State-level 

concept proponents told us that even those countries where the 

integrated safeguards approach has been applied in recent years could 

benefit from a further reduced inspection burden, assuming those 

 

31 Herman Nackaerts, Deputy Director General and Head of the Department of 

Safeguards, IAEA, “The Future of Safeguards: Adapting to Change,” June 7, 2011, and 

“IAEA Safeguards: Cooperation as the Key to Change,” presented at the Institute of 

Nuclear Materials Management’s 52nd annual meeting, July 18, 2011, and published in the 

Journal of Nuclear Materials Management, Fall 2011.

32 A country is considered to have a limited nuclear fuel cycle if it does not possess all the 

capabilities of the fuel cycle, particularly the more sensitive capabilities of uranium 

enrichment and reprocessing, which could potentially be used for nuclear weapons 

development.
 

Page 25 GAO-13-139 Safeguards, Nuclear Security, and Fuel Bank Programs

countries remain compliant with their safeguards obligations. In particular, 

Japan, Germany, and Canada have traditionally comprised the bulk of 

IAEA safeguards inspections, in terms of time and cost, based on the 

number and type of declared nuclear facilities in those countries. The 

number of inspections has declined in those three countries under 

integrated safeguards since our 2005 report; for example, inspections in 

Canada declined from a peak of 1,337 person-days of inspection33 in 

2004 to 436 person-days of inspection in 2011. Japan, Germany, and 

Canada have expressed their support for the state-level concept.

Several member countries, including the United States, support IAEA’s 

plans to broaden implementation of the state-level concept, but other 

member countries—including some countries with significant nuclear 

activities—have raised concerns that the agency has not clearly defined 

and communicated how the state-level concept will be implemented or 

how it will stay within bounds of the agency’s existing legal authorities. 

Consequently, if these concerns are not resolved, IAEA may not be able 

to implement the state-level concept in all countries with safeguards 

agreements by 2014. For example:

• Officials from some foreign missions in Vienna, Austria, told us that 

they believe the state-level concept does not have objective criteria 

and therefore IAEA could implement it in an inconsistent, subjective, 

and potentially discriminatory manner. For instance, officials from one 

foreign mission told us that IAEA needs to better explain its vision for 

the state-level concept in a clear, transparent, and specific manner to 

obtain broader acceptance among member countries. Officials from 

another foreign mission told us that they are concerned about IAEA’s 

ability to draw safeguards conclusions without clearly defined criteria 

in place under the state-level concept.

• Officials from several foreign missions also told us that a number of 

countries are concerned that the state-level concept may give the 

agency too much latitude in gathering information or allow the agency 

to be too intrusive into a country’s civilian nuclear operations. For 

 

33 IAEA defines a person-day of inspection as a day during which a single inspector has 

access to a facility for a total of not more than 8 hours. This definition does not necessarily 

coincide with a calendar day, so if an inspection requires only a small portion of a calendar 

day, it still constitutes one person-day of inspection. This metric also does not include an 

inspector’s travel time to or from a facility.

Several Countries Have 

Raised Concerns That May 

Hinder Broader 

Implementation of the 

State-Level Concept
 

Page 26 GAO-13-139 Safeguards, Nuclear Security, and Fuel Bank Programs

example, officials from one foreign mission stated that it is important 

for IAEA to rely on verifiable information that is relevant only to 

safeguards, whereas IAEA has stated that it would use “all available 

sources of information” about a given country. Officials from another 

foreign mission emphasized that the state-level concept cannot be “a 

blank check for the agency to do whatever it wants” in a country and 

that it is important for the agency to avoid unnecessarily disrupting

nuclear power plant operations in a country “just because the agency 

has ill-defined criteria.” 

• Officials from one foreign mission also observed that a lack of clarity 

about the state-level concept could undermine the agency’s efforts to 

encourage more countries to conclude an Additional Protocol because 

those countries may be suspicious of how the agency would use the 

additional access and information granted by an Additional Protocol.

As of April 2013, IAEA had not developed the criteria or communicated 

specific details to countries about how the state-level concept would be 

implemented. Furthermore, IAEA officials told us they did not intend to 

communicate specific implementation details to countries. Officials from 

State, which coordinates the United States’ financial and policy 

relationship with IAEA, told us that IAEA has been transparent in 

developing the state-level concept and has repeatedly informed the Board 

of Governors about its progress. In addition, State maintains that, as a 

matter of principle, IAEA’s implementation of safeguards should remain 

impartial, objective, based on relevant information, and rooted in the 

agency’s existing legal framework. Nonetheless, due to the concerns 

raised by several countries, the General Conference passed a resolution 

in September 2012 that included a request for IAEA’s Secretariat to report 

to the Board of Governors on the conceptualization and development of 

the state-level concept. A senior IAEA official told us that the agency 

expects to report to the Board of Governors in 2013. In the meantime, 

according to agency officials, IAEA has continued its efforts to 

communicate the state-level concept with countries and other 

stakeholders through multiple forums, including conferences, 

presentations, and bilateral discussions. During our review, we also 

observed that IAEA modified its description of the state-level concept to 

address concerns. For example, in the agency’s annual report for 2010, a 

paragraph describing safeguards conclusions states that “the safeguards 

system being implemented is described as ‘information-driven.’” Since 

that time, IAEA has moved away from the term “information-driven 

safeguards” to avoid language that could suggest inappropriate 

information-gathering. In addition, IAEA officials have emphasized that 
 

Page 27 GAO-13-139 Safeguards, Nuclear Security, and Fuel Bank Programs

they are putting in place guidance to ensure consistency under the statelevel concept in how the agency (1) evaluates individual countries’ 

nuclear activities and (2) implements appropriate safeguards in each 

country. To ensure that IAEA’s evaluations of individual countries’ nuclear 

activities under the state-level concept are sound and independent of 

individual analysts’ judgment, officials from the Department of Energy’s 

Lawrence Livermore National Laboratory told us that IAEA’s internal 

review process appears to be placing greater emphasis on informationsharing, collaboration, and rigorous review than in the past.34

Nonetheless, IAEA officials stated that no matter how they articulate what 

the state-level concept is, certain countries may never support it.

IAEA reports annually on its progress in utilizing various resources to 

strengthen the safeguards program, but the agency has not quantified the 

additional human capital, technological, or other resources that may be 

needed to broaden implementation of the state-level concept. As a result, 

it is difficult to determine the long-term costs and benefits associated with 

the state-level concept, and the agency may not be able to build the 

necessary political and, potentially, financial support to implement the 

state-level concept in all countries with safeguards agreements by 2014. 

For example, in recent annual reports and other documents, IAEA has 

reported progress in training its inspectors and analysts and integrating its 

information systems to enhance the agency’s ability to evaluate a full 

range of information about countries’ nuclear activities and to draw 

soundly based conclusions about countries’ compliance with their 

safeguards obligations. However, the agency has not quantified the 

extent to which this integration has already been achieved or detailed 

how and when it will address any remaining expertise, technology, or 

other resource gaps. Similarly, IAEA reports annually on the number of 

cameras, unattended radiation monitors, and other remote monitoring 

systems it operates for safeguards activities; however, the agency does 

not indicate the cost or specific benefits associated with these items. A 

senior IAEA official told us that it is difficult, if not impossible, to quantify 

the long-term benefits of implementing the state-level concept, but that it 

 

34 Lawrence Livermore National Laboratory is one of the Department of Energy’s national 

laboratories that conduct various research and development and other activities. Among 

other things, Lawrence Livermore advises NNSA on matters pertaining to IAEA and is part 

of IAEA’s international network of safeguards analytical laboratories, which analyzes 

nuclear material samples collected by IAEA inspectors.

IAEA Has Not Quantified 

the Long-Term Costs and 

Benefits of Broadly 

Implementing the StateLevel Concept
 

Page 28 GAO-13-139 Safeguards, Nuclear Security, and Fuel Bank Programs

should result in (1) reduced safeguards activities in countries with little or 

no issues of safeguards significance and (2) increased efforts in countries 

with any such issues. This official added that IAEA’s safeguards activities 

for an individual country may change as issues and circumstances 

change from year to year.

Nonetheless, we and others have previously reported on the need for 

IAEA to identify costs and manage budget requirements. In IAEA’s 

financial statements for 2011, the agency’s external auditor also found 

that IAEA “has not been able to identify savings in a transparent and 

comprehensible manner” in the 10 years since the agency took additional 

steps to strengthen its safeguards program with the integrated safeguards 

approach. The external auditor stated that to measure improvements, the 

resources needed to launch and operate a project—as well as the 

benefits for member countries and the agency—should be measurable. In 

2005, we also reported that IAEA does not have a process in place to 

systematically evaluate its safeguards resource requirements over the 

long-term because the agency’s budget process and research and 

development plan (a document now called the development and 

implementation support program for nuclear verification) are designed to 

forecast resource needs on a 2-year basis.35 At that time, we 

recommended that State work with the agency to develop a systematic 

process to forecast long-term safeguards budget requirements beyond 

the 2-year budget cycle. State agreed with our recommendation, and 

IAEA has taken some steps to address it. During this review, we 

observed that the Department of Safeguards’ current development and 

implementation support program document for 2012-2013 identifies 24 

specific projects that the department wants to undertake and fund in the 

current, 2-year budget cycle, mostly through member countries’ extrabudgetary contributions. These projects are intended to meet specific 

objectives identified in the department’s Long-Term Strategic Plan 2012-

2023 and, according to a senior IAEA official, they involve tasks that are 

not addressed through the agency’s routine safeguards activities. 

However, the document does not identify monetary values for these 

various projects or take a longer-term approach to quantify the resources 

needed to broaden implementation of the state-level concept.

 

35 GAO-06-93. 
 

Page 29 GAO-13-139 Safeguards, Nuclear Security, and Fuel Bank Programs

Given the current zero-real-growth budget policy environment, IAEA 

officials stated that the state-level concept may not yield overall financial 

savings but would allow the more effective use of resources by shifting 

existing resources toward any issues of safeguards concern. 

Nonetheless, without a clear and concise assessment of the resources 

and the associated long-term costs and benefits, including trade-offs—

such as reduced inspections for increased analytical capabilities—

member countries and the international community at large may have 

difficulty understanding the benefits of the state-level concept. 

Furthermore, if the agency conducted an assessment of its long-term 

resource needs and determined that full implementation of the state-level 

concept warrants a greater investment than the current budget provides, 

the agency could present a credible foundation from which to request 

additional resources from member countries.

Since our last report in 2005, IAEA has continued to help countries 

improve the security of their nuclear material and facilities, but three key 

issues limit the agency’s ability to ensure that its nuclear security 

resources are used efficiently and effectively. First, IAEA’s heavy reliance 

on extra-budgetary contributions for its nuclear security activities makes it 

difficult to plan and implement projects because these funds vary from 

year to year and because donor countries often place conditions on their 

contributions. Second, IAEA has not conducted a needs-based 

assessment of the resources required beyond its 2-year budget cycle, 

which also hinders its ability to ensure that resources are directed to the 

greatest security needs. Third, IAEA does not systematically report the 

results of performance measures related to its nuclear security program, 

thus the extent to which the agency is meeting its nuclear security goals 

is unclear.

Since our 2005 report, IAEA’s role in nuclear security has gained 

increased prominence and has been reinforced through international 

Nuclear Security Summits held in 2010 and 2012. Specifically, 

participants at the 2010 Nuclear Security Summit in Washington, D.C., 

issued a statement recommending, among other things, that countries 

(1) work with IAEA to implement the agency’s guidance on nuclear 

security and (2) request the agency’s assistance in assessing the 

physical protection systems of civilian nuclear material and facilities. Two 

years later, participants at the 2012 Nuclear Security Summit in Seoul, 

South Korea, issued a statement that highlighted the importance of 

IAEA’s role in nuclear security, encouraging countries to contribute funds 

IAEA Has Continued 

to Support Nuclear 

Security, but Three 

Key Issues Limit the 

Agency’s Ability to 

Ensure That Its 

Resources Are Used 

Efficiently and 

Effectively 

IAEA Continues to Support 

Countries’ Nuclear 

Security Efforts through 

Its Nuclear Security 

Program
 

Page 30 GAO-13-139 Safeguards, Nuclear Security, and Fuel Bank Programs

toward the agency’s efforts and supporting the agency’s sponsorship of a 

conference in 2013 to coordinate nuclear security activities.

In addition, IAEA has enhanced its training activities and continued other 

activities since our 2005 report—such as providing advisory services and 

managing a database on incidents involving nuclear and other radioactive 

materials detected outside of regulatory control—to support countries’ 

efforts to improve the security of their nuclear material and facilities. While 

security of nuclear and radiological materials is first and foremost a 

national responsibility, IAEA responds to countries’ requests to participate 

in the agency’s voluntary nuclear security program. According to NNSA 

officials, one of IAEA’s most important functions in the area of nuclear 

security is the range of training activities it offers to countries on physical 

protection of nuclear facilities and materials. In particular, NNSA officials 

told us that training is an essential component to countries developing 

and sustaining a national nuclear security regime, as it helps build a 

cadre of capable personnel who are responsible for maintaining and 

enhancing a country’s nuclear security infrastructure. The Director of 

IAEA’s Office of Nuclear Security also told us that it is equally important 

for countries to have a minimum number of well-educated, trained people 

as it is to have radiation detection equipment. Therefore, IAEA offers a 

wide variety of international, regional, and national training courses and 

workshops. We reported in 2005 that IAEA had conducted almost 80 

training courses for about 1,500 participants from January 2001 through 

March 2005.36 In IAEA’s Nuclear Security Report 2012, the agency stated 

that it conducted 70 nuclear security training programs and workshops 

that reached over 1,750 people from July 2011 to June 2012—indicating 

that the agency is now reaching more people in a shorter period of time. 

In addition, since 2005, IAEA has sponsored several new training 

initiatives in support of nuclear security efforts, including

• completing a nuclear security training site in Obninsk, Russia—the 

agency’s largest project to date on physical protection—which offers 

in-field training and hands-on exercises in nuclear security;

 

36 GAO-06-93. 
 

Page 31 GAO-13-139 Safeguards, Nuclear Security, and Fuel Bank Programs

• developing the International Network for Nuclear Security Training 

and Support Centers, designed to facilitate human resource 

development and provide technical support services, and;

• creating the International Nuclear Security Education Network, which 

provides a forum for IAEA, educational institutions, and research 

bodies to collaborate on nuclear security education. The network is 

open to any educational and research institution already involved or 

that plans to be involved in nuclear security education in the future.

IAEA has also continued to provide International Physical Protection 

Advisory Service (IPPAS) missions to countries that request them. These 

voluntary missions assist countries in strengthening their national civilian 

nuclear security regimes by providing (1) guidance on the protection of 

nuclear material and facilities, as well as sealed radioactive sources and 

other radioactive material, (2) best practices in nuclear security, and (3) 

peer advice on implementing international agreements related to physical 

protection of nuclear material and facilities. The 2010 Nuclear Security 

Summit recognized the value of these missions, while the 2012 summit 

encouraged countries to enhance their physical protection and welcomed 

IAEA’s assistance in these efforts. The Director of the Office of Nuclear 

Security told us that, as of June 2012, the agency had conducted 57 

IPPAS missions in 37 countries and that the number of countries 

requesting these missions continues to grow. During an IPPAS mission, 

at the request of a country, IAEA assembles a team of international 

experts that assesses the country’s system of physical protection, 

compares it with international guidelines and best practices, and makes 

recommendations for improvements to correct any identified deficiencies. 

IAEA’s nuclear security guidelines establish the standard by which the 

United States and other countries generally classify the categories of 

physical protection that should be given to nuclear material, based on the 

type, volume, and disposition of the material. The results of IPPAS 

missions, which are contained in a report provided to each country, are 

confidential. According to NNSA officials, the agency believes it is 

obligated to keep the information confidential to respect countries’ 

concerns that security vulnerabilities in the reports could be made public. 

To promote the continued use of IPPAS missions, IAEA does not share 

the reports with the public or other countries. In addition, countries that 

agree to host an IPPAS mission are not required to implement any 

recommendations contained in the mission report. However, IAEA 

conducts follow-up visits to determine whether the country has 

implemented the agency’s recommendations.
 

Page 32 GAO-13-139 Safeguards, Nuclear Security, and Fuel Bank Programs

IAEA has also increased its efforts to assist countries in improving their 

capabilities to detect, track, and respond to illicit trafficking of nuclear and 

radiological materials. In 2005, we reported that IAEA was encouraging 

countries to contribute data to its Incident and Trafficking Database 

(formerly called the Illicit Trafficking Database) to help identify trends in 

incidents involving nuclear and radiological materials detected outside 

regulatory control.37 Since that time, the agency has increased the 

number of countries participating in the database by nearly 50 percent: 

from 81 countries in June 2005 to 121 countries as of February 2013. 

Using this data, the agency produces quarterly and annual reports to 

facilitate information exchange on trends related to incidents involving 

unauthorized acquisition, provision, possession, use, transfer, or disposal 

of nuclear and other radioactive materials. In addition, since 2007, IAEA 

has held 14 regional information meetings worldwide to, among other

things, (1) help raise awareness of the database, (2) improve the quality 

and accuracy of reporting in the database, and (3) highlight the support 

that IAEA can offer to countries to improve their nuclear security efforts. 

Participants from over 100 countries have attended one or more of these 

meetings. In July 2012, IAEA also held a meeting with representatives 

from 81 countries to discuss, among other things, how to use information 

from the database in ways that would further satisfy their security needs. 

IAEA’s nuclear security program faces three key issues that limit the 

agency’s ability to ensure that its resources are used efficiently and 

effectively:

• IAEA relies heavily on extra-budgetary contributions for funding its 

nuclear security activities.

38 Certain member countries, particularly the 

United States, and other donors provide IAEA with extra-budgetary 

contributions on a voluntary basis to supplement the agency’s regular 

budget and to meet critical needs. These extra-budgetary 

 

37 In December 2012, in response to a recommendation made by several countries, IAEA 

changed the name of this database to the Incident and Trafficking Database. To better 

reflect the nature of the incidents contained in the database, IAEA also redefined the 

database’s goal as “to track incidents of nuclear and other radioactive material not under 

regulatory control.”

38 In 2002, IAEA established a Nuclear Security Fund to support its nuclear program 

through extra-budgetary contributions. In 2011, the European Union and 16 member 

countries, including the United States, donated $25 million to the fund. 

Three Key Issues Limit 

IAEA’s Nuclear Security 

Program
 

Page 33 GAO-13-139 Safeguards, Nuclear Security, and Fuel Bank Programs

contributions vary from year to year and, according to the Director of 

the Office of Nuclear Security, are often subject to donors’ conditions. 

As a result, it is difficult for the agency to plan and implement projects 

where security needs may be greatest. This heavy reliance on extrabudgetary contributions is a long-standing challenge that we reported 

on in 2005. At that time, we reported that 89 percent of the agency’s 

total nuclear security funding came from extra-budgetary 

contributions, and the remaining 11 percent came from the agency’s 

regular budget and was used primarily for staff salaries. We 

recommended that IAEA consider determining whether the nuclear 

security program receives adequate regular budget funds.39 In 

February 2010, a State official reported that IAEA had made efforts in 

this regard by moving toward a model in which administrative 

overhead costs, such as salaries, are paid from the regular budget, 

and special projects are funded through extra-budgetary contributions. 

However, during this review, we found that IAEA continues to rely 

heavily on extra-budgetary contributions, accounting for $25 million or 

82.5 percent of its total $30.3 million funding for nuclear security in 

2011.40 The majority of this extra-budgetary funding is designated by 

the donor countries for specific projects. According to the Director of 

the Office of Nuclear Security, the conditions that donor countries 

often place on their extra-budgetary contributions limit the agency’s 

ability to establish its own priorities and ensure that the resources are 

directed to the areas of greatest need. For example, officials from one 

foreign mission told us that their country had contributed $8 million 

over the past 4 years and designated it for specific projects, such as 

improving the security of radiological materials at hospitals or 

providing nuclear security training, in certain countries.

• IAEA has not conducted a needs-based assessment of the resources 

required for the nuclear security program beyond the agency’s 2-year 

budget cycle. Consequently, IAEA has not identified how it will meet 

any long-term resource needs through the regular budget, extrabudgetary contributions, or both. The absence of such information 

hinders the agency’s ability to ensure that resources are directed to 

the greatest security needs. We have previously reported that good 

 

39 GAO-06-93. 

40 In addition, as noted earlier, a number of member countries make in-kind contributions, 

such as equipment and expert services, to the agency’s various programs on a voluntary 

basis.
 

Page 34 GAO-13-139 Safeguards, Nuclear Security, and Fuel Bank Programs

strategic planning practices include describing the relationship 

between long-term goals and budgetary needs.41 IAEA’s Director of 

the Office of Nuclear Security told us that the agency has been 

working for the past year to identify countries’ needs through 

individual nuclear security support plans. The objectives of these 

plans are to (1) identify and consolidate a country’s nuclear security 

needs into a single document that includes the necessary security 

improvements, as well as an appropriate framework for implementing 

these improvements, and (2) to quantify the resources needed and 

prioritize the agency’s activities to meet those needs. According to the 

director, these individual plans are designed to identify actions 

required and approved by both the country and IAEA to ensure that 

the country’s nuclear security regime is effective and sustainable. The 

director told us that the agency expects to have plans in place for over 

100 countries by July 2013 and intends to use this approach for 

short-, medium-, and long-term assessment of countries’ needs and 

the agency’s program and budget priorities. The director added that 

these plans would also inform the agency’s upcoming Nuclear 

Security Plan 2014-2017. Nonetheless, the agency does not have an 

overall long-term plan that incorporates the country-specific plans and 

looks comprehensively at nuclear security needs across all countries 

and identifies resources and priorities for the agency.

• IAEA does not systematically report the results of performance 

measures related to its nuclear security program. As a result, the 

extent to which the agency is achieving its nuclear security goals is 

unclear. IAEA has taken steps in recent years to develop measures 

for assessing the performance of its nuclear security efforts, but it 

does not systematically report on the results of these measures. State 

officials told us that if they had more performance-based information, 

they could more easily present justification for funding that the United 

States directs to IAEA by providing Congress more information about 

the results and impact of U.S. contributions to the program. In 2005, 

we reported that IAEA did not systematically measure the results of its 

nuclear security activities and recommended that State work with 

IAEA and its member countries through the agency’s Board of 

Governors to consider developing such measures.42 Since that time, 

 

41 GAO-06-93. 

42 GAO-06-93. 
 

Page 35 GAO-13-139 Safeguards, Nuclear Security, and Fuel Bank Programs

IAEA has developed the following two performance measures for the 

agency’s nuclear security efforts:

• number of countries that have established or improved national 

nuclear security systems on the basis of advice or assistance from 

the agency, and

• number of countries implementing national nuclear security 

systems on the basis of agency assistance.

The Director of IAEA’s Office of Nuclear Security told us that the agency 

is using these measures to assess the program’s performance. However, 

IAEA has not systematically reported on the results of these performance 

measures. For example, in the agency’s annual report for 2011, with 

regard to its nuclear security program, IAEA reported on the number of 

IPPAS missions undertaken annually and the number of training events 

facilitated related to nuclear security. However, IAEA did not report any 

results related to the two performance measures outlined in its program 

and budget report, and the Director of the Office of Nuclear Security could 

not provide any additional information documenting the results of the 

performance measures or how the agency used them to assess its 

progress in achieving the nuclear security program’s goals. In our 2005 

report, we stated that IAEA officials said that it is difficult for the agency to 

link nuclear security efforts, such as recommendations stemming from 

advisory missions, to results, such as whether recommendations were 

implemented.43 During this review, IAEA officials reaffirmed this point and 

attributed this difficulty to the agency’s limited advisory role, noting that 

countries are not obligated to follow its guidelines or implement its 

recommendations. Nonetheless, reporting on performance measures is 

important to ensure that IAEA can enhance the international community’s 

knowledge of the impact and effectiveness of the nuclear security 

program. Because IAEA has not systematically reported on the results of 

its performance measures, member countries and the international 

community at large cannot gauge the extent to which IAEA is meeting its 

goals or the nuclear security program’s impact and effectiveness.

 

43 GAO-06-93. 
 

Page 36 GAO-13-139 Safeguards, Nuclear Security, and Fuel Bank Programs

IAEA is making progress in establishing an international nuclear fuel bank 

containing LEU by 2014, but several experts and foreign officials told us 

they were uncertain about the fuel bank’s value, potential market impact, 

and long-term operation. Further, IAEA’s fuel bank is one of several 

guaranteed fuel supply options currently planned or in operation 

worldwide—including one in the United States—which raises questions 

about possible duplication of efforts.

Since IAEA’s Board of Governors approved in December 2010 the 

establishment of a nuclear fuel bank to provide a guaranteed fuel supply, 

the agency has made progress in its plans to operationalize the bank by 

2014. IAEA and U.S. officials told us they expect the bank to have two 

benefits: (1) to serve as an assured source of nuclear fuel for countries 

with civilian nuclear power programs in the event of a supply disruption 

and (2) to offer countries an alternative to the development of sensitive 

nuclear fuel enrichment technologies, as such technologies could also be 

used to produce nuclear material—including highly enriched uranium 

(HEU)—for nuclear weapons.

IAEA officials responsible for the fuel bank told us that, since April 2012, 

the fuel bank project has shifted from the design to the implementation 

phase. During this phase, the agency plans to (1) negotiate a host state 

agreement with Kazakhstan concerning, among other things, the physical 

security, legal status, and safety of the bank,44 (2) purchase 

approximately 60 metric tons of LEU for fuel, and (3) manage the bank’s 

budget. As part of this process, the agency is preparing a site 

assessment in Kazakhstan that includes a review of the proposed site—

the Ulba Metallurgical Plant, located in the city of Ust-Kamenogorsk—

which manufactured nuclear fuel for the Soviet Union. Figure 4 shows a 

map of Kazakhstan that includes the location of the proposed site at Ust-

 

44 Kazakhstan volunteered to host IAEA’s fuel bank 20 months prior to the Board of 

Governors’ vote in December 2010 to approve the bank. 

IAEA Is Making 

Progress in 

Implementing a 

Nuclear Fuel Bank, 

but Uncertainties 

Exist Concerning Its 

Value, Potential 

Market Impact, and 

Long-term Operation

Nuclear Fuel Bank Is 

Expected to Become 

Operational by 2014
 

Page 37 GAO-13-139 Safeguards, Nuclear Security, and Fuel Bank Programs

Kamenogorsk. IAEA has also moved oversight of the fuel bank from its 

Office of Nuclear Energy to the Director General’s Office for Policy. 

According to NNSA officials, this transfer was done to ensure that the 

project receives the highest level of attention by the agency and also to 

demonstrate its importance to IAEA’s member countries.

Figure 4: Map of Kazakhstan Showing the Proposed IAEA Nuclear Fuel Bank Site at 

Ust-Kamenogorsk

According to a statement issued by IAEA’s Director General in September 

2012, the agency is reviewing the necessary legislative and regulatory 

framework that is required to ensure that the bank will operate 

consistently with IAEA safety standards, security guidelines, and 

safeguards requirements. The statement also noted that the results of 

these reviews would be incorporated in early 2013 into a plan that will 

make the bank fully operational. In addition, IAEA officials also told us 

that the site assessment would indicate whether physical security 

upgrades are required to accommodate the proposed fuel bank.

According to IAEA officials, the agency’s Board of Governors has 

developed criteria for countries that could purchase LEU fuel from the 

bank. To be eligible to purchase fuel, a country has to meet the following 

criteria: (1) the country is experiencing a supply disruption of fuel for a 

nuclear power plant and is unable to obtain fuel by other means, (2) IAEA 

has concluded that there has been no diversion of declared nuclear 

material from the country and that there are no issues related to the 

country’s safeguards implementation that are under consideration by the 
 

Page 38 GAO-13-139 Safeguards, Nuclear Security, and Fuel Bank Programs

Board of Governors, and (3) the country has a comprehensive safeguards 

agreement in force. In addition, the country receiving fuel from the bank 

has to conclude a supply agreement with IAEA that contains the following 

additional criteria:

• The fuel can only be used for fuel fabrication for energy generation at 

a nuclear power plant;

• The fuel may not be used to manufacture any nuclear weapon or 

nuclear explosive device, or for any other military purpose;

• The country cannot further enrich, reprocess, retransfer, or re-export 

the fuel unless IAEA permits it to do so;

• The fuel is subject to applicable IAEA safeguards, safety standards, 

and physical protection measures; and

• The country must take responsibility for all liability for any nuclear 

damage that may be caused by a nuclear incident associated with the 

use, handling, storage, or transport of the fuel.

We identified several uncertainties about the international nuclear fuel 

bank’s value, potential impact on the international nuclear fuel market, 

and long-term operation, based on discussions with several experts and 

officials from State, NNSA, IAEA, and foreign missions. Specifically:

• The fuel bank may never be used, raising questions about its value. 

Officials from State, NNSA, and foreign missions, as well as some 

experts, told us that the fuel bank may never be used. For example, a 

senior State official told us that there are currently numerous countries 

that are willing and stable suppliers of LEU fuel; therefore, a country 

that needs fuel for civilian nuclear power plants already has willing 

suppliers from whom they can purchase it. NNSA officials told us that 

IAEA’s fuel bank is intended to be used only as a last resort and that it 

will likely never be used. In addition, officials from some foreign 

missions told us that they were uncertain about the bank’s true 

purpose, given that, in their view, there is a ready supply of LEU fuel 

worldwide and numerous suppliers. Officials from two of these foreign 

missions also described the bank as “a solution looking for a 

problem.” Notwithstanding these concerns, some experts and foreign 

mission representatives who support the fuel bank told us that a better 

measure of the bank’s success is in providing countries an assurance 

Uncertainties Exist about 

the Fuel Bank’s Value, 

Potential Market Impact, 

and Long-term Operation
 

Page 39 GAO-13-139 Safeguards, Nuclear Security, and Fuel Bank Programs

of supply, and one expert described the bank as a crisis avoidance 

tool.

In addition, officials from one foreign mission told us that the countries 

the bank is targeting—those that are considered a nuclear 

proliferation risk, such as Iran—are suspicious of the bank’s true 

purpose. As a result, those countries of greatest proliferation concern 

are not likely to use the bank under any circumstances. Furthermore, 

according to State officials, some countries, such as Iran, are not 

eligible to participate due to past safeguards violations. Therefore, as 

a former Head of IAEA’s Department of Safeguards told us, the bank 

does not solve the problem of Iran’s continued nuclear fuel 

enrichment activities. Moreover, officials from several foreign 

missions, including some who support the bank, told us that certain 

developing countries that are members of the Non-Aligned Movement 

and the Group of 7745 are concerned that the bank might be used to 

constrain, or at least discourage, countries’ rights to pursue peaceful 

uses of nuclear energy under Article IV of the NPT by developing their 

own enrichment facilities.46 Some experts we interviewed also stated 

that countries within the Non-Aligned Movement view the bank as 

IAEA’s attempt to deprive them of their rights of peaceful use of 

nuclear energy. Officials from a foreign mission that supports the bank 

told us that this concern still exists, despite the Board of Governors’ 

vote to approve the bank in 2010.47

• The bank’s potential impact on the international nuclear fuel market is 

uncertain. The conditions that IAEA’s Board of Governors has placed 

 

45 The Non-Aligned Movement is a group of 120 countries that consider themselves not 

aligned formally with or against any international power bloc. The Group of 77 is the 

largest intergovernmental organization of developing countries in the United Nations. 

Composed of 131 member countries, it provides the means for these countries to 

articulate and promote their collective economic interests and enhance their joint 

negotiating capacity on major international economic issues within the United Nations 

system. 

46 Article IV of the NPT states, among other things, “Nothing in this Treaty shall be 

interpreted as affecting the inalienable right of all the Parties to the Treaty to develop 

research, production and use of nuclear energy for peaceful purposes without 

discrimination... .” 

47 Of the 35 Board of Governors members at the time of the December 2010 vote to 

approve the bank, 28 voted in favor of the bank, including 10 members and 3 observers of 

the Non-Aligned Movement. Six members abstained from voting, all of which were NonAligned Movement members or observers, and one Non-Aligned Movement member was 

absent from voting.
 

Page 40 GAO-13-139 Safeguards, Nuclear Security, and Fuel Bank Programs

on the fuel bank include a stipulation that the use of the bank will not 

affect the international nuclear fuel market. IAEA plans to purchase 60 

metric tons of LEU to supply the bank in advance of its startup. 

According to NNSA officials, the greatest challenge is identifying the 

point at which IAEA’s fuel bank moves from serving as a safety net for 

countries in need of fuel to becoming a disruption to the nuclear fuel 

market. Similarly, a senior State official told us that some fuel supplier 

countries have expressed concern that the bank could disrupt the 

market and affect fuel prices. While IAEA has not released an 

assessment of the fuel bank’s potential market impact, other studies 

indicate that a new source of supply could impact the international fuel 

market. For example, a 2010 study by the Brookings Institution 

queried nuclear industry officials on the feasibility of multilateral 

nuclear approaches, including an IAEA-administered nuclear fuel 

bank. According to the study, commercial nuclear fuel vendors are 

concerned about the implications of a fuel bank on the current market 

system that has, to date, had no supply issues. The study also 

reported that nuclear industry officials are worried that a fuel bank 

would artificially force down prices to levels that are uncompetitive for 

private vendors. In addition, according to a 2006 report by the Pacific 

Northwest National Laboratory,48 the long-term impact of having 

assured fuel on the international nuclear market is unclear, including 

the effect that an assured fuel supply could have on the 

competitiveness of U.S. commercial fuel. For example, an influx of 

LEU on the market could affect market structure, potentially pushing a 

marginal supplier of uranium or enrichment out of the market, 

discouraging an existing supplier from making a necessary investment 

to upgrade its capacity, or depressing investment in mining and other 

operations. The report also stated that there has been significant 

discussion between industry and government regarding how much 

LEU can be introduced into the nuclear fuel market without causing a 

serious market disruption and added that a wide variety of variables 

can impact the market.

IAEA officials who are responsible for managing the fuel bank told us 

that the bank will not affect the international nuclear fuel market for 

two reasons: (1) the agency will replenish the bank’s inventory by 

procuring one reload of LEU for every reload of fuel that it supplies, 

 

48 Pacific Northwest National Laboratory, “Options for Creating a Nuclear Fuel Stockpile 

for Assured Nuclear Fuel Supply,” PNNL-SA-48328 (Richland, WA: February 2006). 
 

Page 41 GAO-13-139 Safeguards, Nuclear Security, and Fuel Bank Programs

making the bank market-neutral; and (2) the agency approved an LEU 

procurement plan in September 2011 that specifically addresses the 

avoidance of market impact during the initial inventory acquisition for 

the fuel bank. However, we have not reviewed the plan and its 

assessment of the bank’s potential impact on the market, as the plan 

is confidential and not publicly available. As a result, it is impossible to 

evaluate whether IAEA’s fuel bank could adversely affect the 

international market. Nonetheless, IAEA officials also told us that, in 

their view, the 60 metric tons of LEU the agency is planning to 

purchase is not enough to have a significant impact on the market 

worldwide.

• IAEA does not have a plan in place for the long-term operation and 

funding of the fuel bank. The nuclear fuel bank is the first project of its 

kind that IAEA has ever undertaken, is large in scope, and requires 

complex planning and coordination across different departments 

within the agency. While IAEA has given countries briefings about the 

fuel bank’s status, the agency has not yet developed a long-term plan 

that addresses key aspects of the project, although agency officials 

responsible for managing the bank told us that they intend to provide 

a detailed financial plan to the Board of Governors in 2013. Among 

other things, they stated that this plan would identify the long-term 

funding needs for the bank. We have previously reported that a longterm funding plan should include effective strategies to help set 

priorities and allocate resources, including staffing, to inform decisionmaking and help ensure accountability.49 Such priority-setting and 

resource allocation is especially important in a fiscally constrained 

environment, such as the one that IAEA faces, and should include 

information on the levels and sources of funding needed for the 

ongoing maintenance and operation of the fuel bank. IAEA officials 

told us that funding for the bank will be kept to a minimum and come 

solely from extra-budgetary contributions, with sufficient resources set 

aside to cover operation of the bank for a period of time to be 

determined by the Director General. The agency’s Board of 

Governors agreed to rely on extra-budgetary funds because of the 

zero-real-growth budget policy under which the agency generally 

operates and the resistance among countries to increase the agency’s 

 

49 See, for example, GAO, Combating Terrorism: Evaluation of Selected Characteristics in 

National Strategies Related to Terrorism, GAO-04-408T (Washington, D.C.: Feb. 3, 2004), 

and GAO, Rebuilding Iraq: More Comprehensive National Strategy Needed to Help 

Achieve U.S. Goals, GAO-06-788 (Washington, D.C.: July 11, 2006).
 

Page 42 GAO-13-139 Safeguards, Nuclear Security, and Fuel Bank Programs

regular budget to fund the project. As stated earlier, IAEA has 

received $159.4 million in extra-budgetary cash contributions and 

pledges from the United States and other donors toward the 

establishment of the fuel bank. However, without a long-term plan in 

place, it is unclear whether IAEA will need funding beyond the initial 

$150 million and, if so, how the agency would be able to financially 

support the bank’s ongoing maintenance and operation.

IAEA’s nuclear fuel bank is one of several guaranteed, multilateral fuel 

supply options that are currently available to countries seeking an 

assured LEU fuel source in the event of a supply disruption. Several 

countries, including the United States, have independently established a 

fuel bank or similar mechanism to provide eligible countries with a 

guaranteed fuel supply. The number of fuel banks raises questions about 

a potential duplication of effort among these similar options.

We identified three options available for countries seeking an assured 

supply of LEU fuel in the event of a supply disruption, in addition to 

IAEA’s planned nuclear fuel bank. These efforts have independently been 

undertaken by the United States, Russia, and the United Kingdom. Each 

of these initiatives is described below.

• United States. In addition to supporting IAEA’s nuclear fuel bank, the 

United States has created its own guaranteed fuel supply option, 

called the American Assured Fuel Supply, to serve as a backup fuel 

supply to eligible foreign or domestic recipients. In 2005, the 

Department of Energy (DOE) announced that 17.4 metric tons of U.S. 

surplus HEU from a former nuclear weapons plant would be 

downblended to LEU to be used as a U.S. fuel bank. NNSA officials 

told us that the U.S. fuel bank has been operational since 2011, 

although it had not been used as of February 2013. According to an 

announcement in the Federal Register on August 18, 2011, the 

purpose of the U.S. fuel bank is to provide an assured supply of LEU 

fuel in the event of a supply disruption where all other market options 

have been exhausted. This fuel bank is also intended to help 

countries pursue nuclear power without the burden of producing their 

own fuel, while curbing the spread of sensitive technology. To be 

eligible to purchase the fuel, recipients, through their governments, 

must meet certain nonproliferation criteria.

NNSA has made little information publicly available about the details 

of the U.S. fuel bank, apart from the Federal Register announcement 

and an accompanying press release. For example, NNSA has not 

IAEA’s Nuclear Fuel Bank 

Is One of Several 

Guaranteed Fuel Supply 

Options Available

Several Guaranteed Fuel 

Supply Options Are Available
 

Page 43 GAO-13-139 Safeguards, Nuclear Security, and Fuel Bank Programs

released key information about the U.S. fuel bank’s operations, such 

as whether the bank is being used, estimated demand, potential 

impact on the international nuclear fuel market, or any controls to 

mitigate such impacts. In May 2012, DOE issued a Secretarial 

Determination that stated, among other things, that certain planned 

DOE sales and transfers of excess uranium—including the transfer of 

60 metric tons of LEU to a contractor in creating the U.S. fuel bank—

would have no adverse material impact on the U.S. uranium mining, 

conversion, or enrichment industries.50 NNSA officials acknowledged 

that the analysis did not cover the potential impact of the U.S. fuel 

bank’s 230 metric tons of LEU on the international nuclear fuel 

market. As we noted in reference to the IAEA nuclear fuel bank, some

studies indicate that a new source of LEU fuel could affect the 

international fuel market, including the competitiveness of U.S. 

commercial fuel. NNSA officials told us that there were no 

requirements for the agency to conduct any studies that would provide 

this type of information. Nonetheless, without more information, the 

extent to which the U.S. fuel bank may be used, its potential impact 

on the international nuclear fuel market, or any controls to mitigate 

such impact is unclear.

In addition, during our review, we obtained some key information from 

NNSA officials about the U.S. fuel bank’s financial status that had not 

been previously reported. For example, NNSA officials told us that as 

of December 2012, Nuclear Fuel Services, a contractor in Erwin, 

Tennessee, had completed downblending 17.4 metric tons of HEU, 

yielding 290 metric tons of LEU. Of that amount, approximately 230 

metric tons of LEU have been made available for the U.S. fuel bank, 

which is stored at a fuel fabrication facility in Columbia, South 

Carolina, while the remaining 60 metric tons were used to 

compensate the contractor through what NNSA describes as a barter 

 

50 Secretarial Determination for the Sale or Transfer of Uranium (Washington, D.C.: May 

15, 2012). Before making any sales or transfers of LEU and natural uranium, DOE is 

required under the USEC Privatization Act to determine that the transactions will not have 

an adverse material impact on the domestic uranium industry. 
 

Page 44 GAO-13-139 Safeguards, Nuclear Security, and Fuel Bank Programs

arrangement.51 The value of this arrangement is approximately $145.3 

million, composed of (1) $105.3 million to cover the contractor’s 

downblending services and (2) approximately $40 million to cover the 

cost of diluent (natural uranium that is blended with HEU to produce 

LEU). As compensation for its storage of the LEU for the U.S. fuel 

bank, the contractor is also allowed to borrow a portion of the LEU for 

its ongoing business activities, provided the contractor meets certain 

conditions, including replacing any LEU it uses. The storage portion of 

the contract extends for 10 years, through June 2017, but there are 

also options to extend the contract in 5-year increments. However, 

NNSA has not published this information in publicly available 

documents, such as DOE’s Excess Uranium Inventory Management 

Plan.

52

In addition to NNSA’s $145.3 million contract, NNSA officials told us 

that the agency spent a total of $28.3 million in fiscal years 2002 

through 2012 to prepare the HEU for downblending and to support the 

project. Specifically, NNSA officials said these funds were used to 

retrieve the HEU from NNSA’s storage repository, perform

inspections, sample, process, pack, and ship the HEU to the 

contractor and, in later years, to provide program management 

support such as quarterly contract reviews. However, NNSA has not 

quantified the specific costs per year associated with this aspect of 

creating the U.S. fuel bank in its annual budget justification reports to 

 

51 We have previously analyzed transactions that DOE characterized as barters of 

uranium on two occasions. In both cases, we found that the transactions actually 

constituted sales of uranium that were authorized under the United States Enrichment 

Corporation (USEC) Privatization Act but violated the miscellaneous receipts statute. 

Because we found that the transactions were sales, we did not consider and did not 

decide whether barters are also authorized under the USEC Privatization Act. We also did 

not perform such an analysis in this case. See GAO, Excess Uranium Inventories: 

Clarifying DOE’s Disposition Options Could Help Avoid Further Legal Violations,

GAO-11-846 (Washington, D.C.: Sept. 26, 2011); and GAO, Department of Energy: 

December 2004 Agreement with the United States Enrichment Corporation, B-307137

(Washington, D.C.: July 12, 2006).

52 In December 2008, DOE published the Excess Uranium Inventory Management Plan

“to provide the general public and interested stakeholders more specific information and 

enhanced transparency with respect to DOE’s preliminary plans for its excess uranium 

transactions.” The plan identified excess uranium inventories and specific transactions 

that were planned or under consideration at that time, or that might be considered by DOE 

in the future, for disposition. In early March 2013, NNSA officials told us that DOE’s Office 

of Nuclear Energy was preparing an updated version of this plan.
 

Page 45 GAO-13-139 Safeguards, Nuclear Security, and Fuel Bank Programs

Congress or in other publicly available documents. We have 

previously reported that Federal Accounting Standards Advisory 

Board guidance calls for the identification of the full cost of federal 

programs and activities, and congressional requesters have 

emphasized that NNSA should establish budgets that reflect total 

program costs and that these budgets should be more transparent to 

oversight.53 Moreover, DOE’s 2008 Excess Uranium Inventory 

Management Plan states that the agency will manage its excess 

uranium inventory through controlled sales or transfers in a 

transparent manner that will result in the U.S. government’s receipt of 

reasonable value for any such transactions.

• Russia. In 2009, IAEA’s Board of Governors approved a Russianestablished fuel bank housed in Angarsk, Russia, that operates under 

the auspices of IAEA. Specifically, according to an IAEA report, a 

country facing a fuel supply cutoff would apply to IAEA to access the 

fuel bank, and IAEA’s Director General would then assess whether 

the applicant country meets the criteria for access. Similar to IAEA’s 

nuclear fuel bank, fuel from the Russian bank is available as a backup 

supply to any eligible IAEA member country that faces a noncommercial or technical disruption of fuel supply for its civilian nuclear 

power reactors. According to IAEA officials, this bank is funded 

entirely by Russia and uses Russian fuel, whereas IAEA’s fuel bank is 

being funded by the $150 million in extra-budgetary contributions from 

certain member countries and other donors.

• United Kingdom. In 2011, IAEA’s Board of Governors approved a 

proposal by the United Kingdom to create a nuclear fuel assurance 

program that would ensure the continued supply of nuclear fuel in the 

event a country’s supply is disrupted for political reasons. Unlike the 

IAEA, Russian, and U.S. fuel banks, this guaranteed fuel supply 

option does not call for a physical stockpile of fuel. Instead, it is 

intended to provide a contractual agreement between IAEA, a supplier 

country, and a recipient country to guarantee an uninterrupted supply 

of fuel. According to IAEA, the agency’s status as a co-signatory 

would play a central role in building confidence in such contracts.

 

53 GAO, Nuclear Weapons: Actions Needed to Identify Total Costs of Weapons Complex 

Infrastructure and Research and Production Capabilities, GAO-10-582 (Washington, D.C.: 

Jun. 21, 2010).
 

Page 46 GAO-13-139 Safeguards, Nuclear Security, and Fuel Bank Programs

We identified potential overlapping functions among the United States’ 

nuclear fuel bank and these other guaranteed fuel supply options, as they 

are all similar in purpose and intent.54 Although some of these options are 

better developed than others, they all have a common goal. Specifically, 

each one seeks to provide a guaranteed supply of nuclear fuel to eligible 

countries to reduce the risk of nuclear proliferation. Consequently, they all 

appear to be targeting a similar set of countries: those countries that are 

looking to develop or sustain civilian nuclear power programs without 

having to develop their own nuclear fuel enrichment capabilities. 

However, it is unclear how the existence of multiple guaranteed fuel 

supply options will directly reduce potential proliferation risks because 

those countries of greatest proliferation concern may not be likely—or 

eligible—to use these fuel supply options.

Notably, there is potential duplication between the U.S. nuclear fuel bank, 

which already exists, and the IAEA fuel bank, which is expected to begin 

operation by 2014. There may be significant financial implications 

associated with the United States’ supporting two nuclear fuel banks. 

Specifically, the United States has already expended resources with a 

total value of approximately $223.1 million on these two fuel banks 

through fiscal year 2012: $49.5 million for the IAEA bank and about

$173.6 million for the U.S. bank. Given the fiscal pressures that the 

United States currently faces, it is important for NNSA to review and 

assess the need for a U.S. fuel bank and report on the results of such an 

assessment. As we have reported in the past,55 consolidating programs 

 

54 In this report, and as we have done in previous reports, we use the term “overlap” to 

refer to circumstances when multiple agencies and programs have similar goals, engage 

in similar activities or strategies to achieve them, or target similar beneficiaries. The 

presence of overlap can suggest the need to look closer at the potential for unnecessary 

duplication. However, our review did not go to sufficient depth to determine whether and to 

what extent the programs are actually duplicative, which occurs when two or more 

agencies or programs are engaged in identical activities or provide the same services to 

the same beneficiaries. For more information on overlap and duplication in federal 

programs, see GAO, Opportunities to Reduce Potential Duplication in Government 

Programs, Save Tax Dollars, and Enhance Revenue, GAO-11-318SP (Washington, D.C.: 

Mar. 1, 2011); and GAO, Managing for Results: Using the Results Act to Address Mission 

Fragmentation and Program Overlap, GAO/AIMD-97-146 (Washington, D.C.: Aug. 29, 

1997). 

55 See GAO, 2012 Annual Report: Opportunities to Reduce Duplication, Overlap and 

Fragmentation, Achieve Savings, and Enhance Revenue, GAO-12-342SP (Washington, 

D.C.: Feb. 28, 2012) and GAO, Nuclear Nonproliferation: Action Needed to Address 

NNSA’s Program Management and Coordination Challenges, GAO-12-71 (Washington, 

D.C.: Dec. 14, 2011). 

Multiple Fuel Supply Options 

May Result in Duplication of 

Effort
 

Page 47 GAO-13-139 Safeguards, Nuclear Security, and Fuel Bank Programs

sharing common goals and implementing similar projects can maximize 

limited resources and may achieve potential cost savings or other 

programmatic and administrative efficiencies. In addition, we have 

reported that conducting an assessment to better understand the extent 

to which programs may overlap with each other is important to mitigate 

the risk of unnecessary duplication. However, as of February 2013, NNSA 

officials told us they had not formally assessed the extent to which the 

U.S. fuel bank may overlap with IAEA’s fuel bank. As a result, NNSA may 

lack information on the extent to which unnecessary duplication between 

the U.S. and IAEA fuel banks may exist.

NNSA and IAEA officials told us that having several backup fuel supply 

options increases the availability of LEU fuel worldwide to serve as a 

safety net in the event of a supply disruption or shortage. Thus, according 

to IAEA officials, the existence of multiple fuel assurance programs would 

help ensure that a country interested in developing or expanding its 

civilian nuclear power program would have ready access to fuel and not 

be dependent on one supplier but could choose from a number of fuel 

supply options. Furthermore, IAEA officials told us that the greater the 

number of these fuel supply options, the lesser the likelihood that a 

country will develop its own enrichment capability, thus reducing potential 

nuclear proliferation risks. These officials also stated that some element 

of duplication is inherent in the concept of assurance but noted that there 

is a point at which multiple efforts have diminishing returns. Moreover, 

having multiple safety net suppliers decreases the likelihood that any one 

of these options will ever be used.

IAEA has continued to strengthen its safeguards program since we last 

reported on it in 2005. In particular, IAEA has successfully encouraged 

more countries to conclude an Additional Protocol and, as appropriate for 

certain countries, to amend or rescind small quantities protocols, or to 

bring comprehensive safeguards agreements into force. Despite this 

progress, IAEA continues to face certain challenges that may limit its 

ability to further enhance the effectiveness and efficiency of the 

safeguards program. First, the agency has not clearly defined and 

communicated how it will implement the state-level concept, and several 

countries have raised concerns as to whether IAEA would implement it in 

an objective, nondiscriminatory manner that does not exceed its authority 

to collect information about countries’ nuclear activities. Without 

widespread acceptance among member countries, IAEA may not be able 

to implement this next phase in the evolution of safeguards in all 

countries with safeguards agreements by 2014. Second, the agency has 

Conclusions 
 

Page 48 GAO-13-139 Safeguards, Nuclear Security, and Fuel Bank Programs

not identified the human capital, technological, or other resources it needs 

to broaden implementation of the state-level concept—as well as the 

associated long-term costs and benefits of such resources. Without 

assessing and quantifying the long-term resource needs and the 

associated costs and benefits, it is unclear what expertise, technology, or 

other resource gaps may exist.

In addition, while IAEA has increased training and other efforts to build 

countries’ capacity to improve the physical security of their nuclear 

material and facilities, the agency continues to rely heavily on extrabudgetary contributions, which vary from year to year and are often 

designated by donors for specific projects in certain countries. As a result, 

it is difficult for the agency to plan and implement projects where security 

needs may be greatest. In this context, IAEA has not assessed its longterm resource needs for nuclear security activities and has not identified 

how it will meet those needs through the regular budget, extra-budgetary 

contributions, or both. Without more predictable long-term financial 

resources, the agency cannot adequately plan ahead and ensure that the 

greatest security needs are addressed in a timely manner. Further, while 

IAEA has developed performance measures for its nuclear security 

program since our 2005 report, the agency does not systematically report 

on the results of these performance measures. Without systematically 

reporting on these results, member countries and the international 

community at large cannot gauge the extent to which IAEA is achieving 

its goals or the nuclear security program’s impact and effectiveness.

The concept of an international nuclear fuel bank as a nonproliferation 

tool may have merit, but uncertainties exist about its value, potential 

market impact, and long-term operation. In particular, it is unclear what 

value the IAEA fuel bank adds to nuclear nonproliferation efforts 

worldwide. Furthermore, it is impossible to determine whether IAEA’s fuel 

bank would interfere with the operation of the international nuclear fuel 

market because the agency has not made publicly available its 

assessment of the bank’s potential market impact. Two years after IAEA’s 

Board of Governors voted to approve the nuclear fuel bank, the agency 

also has not yet developed a plan for the bank’s long-term operation and 

funding. Without a long-term plan that includes strategies to help set 

priorities and allocate resources to guide the bank beyond its first few 

years, the long-term prospects for the fuel bank’s viability are uncertain. 

In the event that IAEA needs funds beyond the initial $150 million, the 

United States—the largest single-country donor to the fuel bank—and 

other donors will likely expect additional information about the bank’s 

long-term operation before making further contributions.
 

Page 49 GAO-13-139 Safeguards, Nuclear Security, and Fuel Bank Programs

In addition to supporting IAEA’s nuclear fuel bank, the United States has 

created its own fuel bank to serve as a safety net fuel supply to eligible 

countries. However, it is unclear how the existence of multiple guaranteed 

fuel supply options will directly reduce potential proliferation risks because 

those countries of greatest proliferation concern may not be likely—or 

eligible—to use the U.S. fuel bank. Furthermore, NNSA has released little 

information about the U.S. bank’s operations, such as whether the bank is 

being used, estimated demand, potential impact on the international 

market, or any controls to mitigate the potential market impact. Moreover, 

NNSA has not released information on the financial status of the U.S. fuel 

bank—including a 10-year contract that transferred government assets 

worth approximately $145.3 million, plus $28.3 million in appropriated 

funds from fiscal years 2002 through 2012—in NNSA’s annual budget 

justification reports or other publicly available documents. Finally, given 

the overlapping purposes of IAEA’s and the United States’ fuel banks, 

there may be duplication of effort that could have significant financial 

implications. In light of the fiscal pressures the United States faces, and 

the United States’ financial support of IAEA’s fuel bank, it is important for 

NNSA to review and assess the need for a U.S. fuel bank and report on 

the results of such an assessment.

We are making nine recommendations in this report.

To ensure that safeguards and nuclear security resources are allocated 

and spent in the most effective and efficient manner, the Secretary of 

State should work with IAEA and its member countries through the 

agency’s Board of Governors to consider the following four actions:

• clearly define and communicate how the agency will implement the 

state-level concept in an objective, nondiscriminatory manner that 

does not exceed IAEA’s authority to collect information about 

countries’ nuclear activities;

• conduct an assessment of the human capital, technological, and other 

resources the agency may need to broaden implementation of the 

state-level concept—and the associated long-term benefits and costs;

• evaluate the nuclear security program’s long-term resource needs and 

assess whether the agency’s heavy reliance on extra-budgetary 

contributions is sufficient to plan and meet those needs; and

Recommendations for 

Executive Action
 

Page 50 GAO-13-139 Safeguards, Nuclear Security, and Fuel Bank Programs

• systematically report on the results of the agency’s performance 

measures for the nuclear security program to allow member countries 

and the international community at large to gauge the extent to which 

the agency is achieving its goals or the nuclear security program’s 

impact and effectiveness.

To ensure that IAEA’s nuclear fuel bank is implemented in the most 

effective and efficient manner, the Secretary of State should work with 

IAEA and its member countries through the agency’s Board of Governors 

to consider the following two actions:

• prepare a publicly available assessment of the potential impact of 

IAEA’s nuclear fuel bank on the international nuclear fuel market; and

• ensure that the agency’s plan for the long-term operation and funding 

of the nuclear fuel bank includes strategies to help set priorities and 

allocate resources for the viability of the fuel bank that include, for 

example, information on the levels and sources of funding needed for 

the ongoing maintenance and operation of the fuel bank.

To ensure the most effective, efficient, and transparent use of U.S. 

government resources, we recommend that the Administrator of NNSA 

take the following three actions:

• review and assess the need for the U.S. nuclear fuel bank, based on 

the United States’ financial support of IAEA’s fuel bank and the 

potential for duplication of efforts, and report on the results of this 

assessment; 

• report key information on the U.S. nuclear fuel bank’s operations, 

such as its use to date, estimated demand, potential impact on the 

international nuclear fuel market, or any controls to mitigate the 

potential market impact; and

• review and report on the financial status of the U.S. nuclear fuel bank, 

including its costs to date and any ongoing costs related to the bank, 

in NNSA’s annual budget justification reports or other publicly 

available documents.

We provided a draft of this report to State, NNSA, the Nuclear Regulatory 

Commission, and IAEA for review and comment. State and NNSA 

provided written comments, which are presented in appendixes III and IV, 

respectively. In its written comments, State noted that our report provides 

Agency Comments 

and Our Evaluation
 

Page 51 GAO-13-139 Safeguards, Nuclear Security, and Fuel Bank Programs

timely and useful information on several aspects of IAEA’s continuing 

work in the vital areas of safeguards and nuclear security. In addition, 

State commented that our report accurately recognizes that continued 

and focused work in the areas identified will require the United States to

work closely with IAEA and other member countries to achieve success. 

Of the six recommendations directed to it, State agreed with three 

recommendations, disagreed with two recommendations, and did not 

comment on our recommendation that it should work with IAEA to 

consider systematically reporting on the results of the agency’s 

performance measures for the nuclear security program. NNSA agreed 

with all three recommendations directed to it. The Nuclear Regulatory 

Commission and IAEA did not provide written comments. All three U.S. 

agencies, as well as IAEA, provided technical comments on our draft 

report, which we incorporated as appropriate.

In its written comments, State agreed with our recommendations that it 

should work with IAEA and other member countries to consider the 

following three actions: (1) clearly define and communicate how IAEA will 

implement the state-level concept in an objective, nondiscriminatory 

manner that does not exceed its authority to collect information about a 

country’s nuclear activities; (2) conduct an assessment of the human 

capital, technological, and other resources the agency may need to 

broaden implementation of the state-level concept—and the associated 

long-term benefits and costs; and (3) ensure that the agency’s plan for 

the long-term operation and funding of IAEA’s nuclear fuel bank includes 

strategies to help set priorities and allocate resources for the viability of 

the fuel bank, such as information on the levels and sources of funding 

needed for the ongoing maintenance and operation of the fuel bank.

However, State disagreed that it should work with IAEA and other 

member countries to consider the following two actions: (1) evaluate the 

nuclear security program’s long-term resource needs and whether the 

agency’s heavy reliance on extra-budgetary contributions is sufficient to 

plan and meet those needs, and (2) prepare a publicly available 

assessment of the potential impact of IAEA’s nuclear fuel bank on the 

international nuclear fuel market. Specifically, State commented that it 

believes a resource assessment or long-term planning for the nuclear 

security program is not possible because IAEA assists member countries 

by responding to specific requests that cannot be anticipated and then 

addresses those requests based on staffing and resource availability. 

State also noted that it does not believe IAEA should spend resources 

assessing whether extra-budgetary funding is sufficient because such 

funding is, by nature, voluntary, unpredictable, and often comes with 
 

Page 52 GAO-13-139 Safeguards, Nuclear Security, and Fuel Bank Programs

conditions. In addition, State indicated that IAEA will continue to rely 

heavily on extra-budgetary contributions for nuclear security, given the 

limited regular budget for the program.

Notwithstanding State’s comments, we continue to believe that long-term 

strategic and budgetery planning is important to identify priorities and 

needs and that the absence of such information hinders IAEA’s ability to 

ensure that resources are directed to the greatest nuclear security needs. 

Given IAEA’s extensive knowledge of nuclear security issues worldwide—

and after managing the program for more than 10 years—we believe it is 

reasonable to expect the agency to forecast, prioritize, and plan beyond 

the agency’s 2-year budget cycle. While IAEA has started to develop 

country-specific nuclear security support plans to identify individual 

countries’ needs, the agency does not have an overall plan that looks 

comprehensively at nuclear security needs globally and identifies longterm priorities and resource needs for the agency. In our view, such 

information would add a greater degree of transparency to IAEA’s nuclear 

security program and provide member countries with a clearer 

understanding of how they might assist the agency in achieving its longterm goals while maximizing limited resources. We agree with State that 

IAEA will likely continue to rely heavily on extra-budgetary contributions 

for nuclear security, which, as we have reported, exceeded 80 percent of 

IAEA’s total nuclear security funding both during our prior review in 2005 

and our current review. However, this may not be a sustainable long-term 

funding plan, and the agency may be missing opportunities to justify a 

potential increase to its limited regular budget and, therefore, to rely less 

on extra-budgetary contributions. As noted in our report, such extrabudgetary contributions typically fluctuate from year to year and may be 

designated by donors for projects that are not the agency’s highest 

priorities. We recognize that IAEA currently operates under a zero-realgrowth budget environment, but given the fiscal constraints faced by 

major donors, including the United States, IAEA cannot necessarily 

assume that donors will continue to make extra-budgetary contributions at 

the same levels as in the past.

Regarding our recommendation that IAEA should consider preparing a 

publicly available assessment of the potential impact of IAEA’s nuclear 

fuel bank on the international nuclear fuel market, State indicated that 

such an assessment “would be a questionable use of the Agency’s 

resources.” We disagree with State’s position because, as noted in our 

report, IAEA officials told us that they have already conducted such an 

assessment but have so far kept the assessment confidential. The point 

of our recommendation is for IAEA to publicly release the existing 
 

Page 53 GAO-13-139 Safeguards, Nuclear Security, and Fuel Bank Programs

assessment so that member countries and others in the international 

community can evaluate it and draw their own conclusions. We recognize 

that IAEA’s fuel bank is intended to be used only as a guaranteed supply 

option in the event of an unanticipated market failure. Nonetheless, some 

stakeholders have raised concerns, as noted in our report, about the 

potential market impact of such a multilateral nuclear fuel bank, 

regardless of its size. In fact, a senior State official told us that some fuel 

supplier countries have expressed concern that IAEA’s planned fuel bank 

could disrupt the market and affect fuel prices. In our view, unless IAEA 

publicly releases its assessment, there will likely continue to be debate 

about whether IAEA’s fuel bank could have unintended consequences. In 

addition, State commented that there is no danger the IAEA fuel bank 

would “flood” the international nuclear fuel market because the fuel would 

never be offered en masse or under a long-term supply contract. Our 

report does not suggest that IAEA’s fuel bank would flood the market but, 

rather, that its potential effect on the market is unclear. As stated in our 

report, one of the IAEA Board of Governors’ conditions for the bank is that 

its use will not affect the international nuclear fuel market. Thus we 

continue to believe that our recommendation for IAEA to publicly release 

its assessment of the fuel bank’s potential market impact has merit.

In its written comments, NNSA agreed with all three recommendations 

directed to NNSA to help ensure the most effective, efficient, and 

transparent use of U.S. government resources in reference to the U.S. 

nuclear fuel bank. Specifically, our recommendations are for NNSA to 

take the following three actions: (1) review and assess the need for the 

U.S. nuclear fuel bank, based on the United States’ financial support of 

IAEA’s fuel bank and the potential for duplication of efforts, and report on 

the results of this assessment; (2) report key information on the U.S. 

nuclear fuel bank’s operations, such as its use to date, estimated 

demand, potential impact on the international nuclear fuel market, or any 

controls to mitigate the potential market impact; and (3) review and report 

on the financial status of the U.S. nuclear fuel bank, including its costs to 

date and any ongoing costs related to the bank, in NNSA’s annual budget 

justification reports or other publicly available documents. Regarding the 

third recommendation, NNSA commented that “there are no future costs 

anticipated to NNSA, as the ongoing compensation for the storage of the 

[LEU] for the fuel bank is covered by barter arrangement whereby the 

contractor can use a portion of the LEU as working inventory.” Based on 

this comment and additional technical information provided by NNSA, we 

have added clarifying language in our report. Specifically, we added that 

the contractor is allowed to borrow a portion of the LEU fuel for its 

ongoing business activities, provided the contractor meets certain 
 

Page 54 GAO-13-139 Safeguards, Nuclear Security, and Fuel Bank Programs

conditions, including replacing any LEU it uses. In addition, we noted that 

the storage portion of the contract extends for 10 years, through June 

2017, and that there are options for extending the contract in 5-year 

increments. However, until NNSA extends the contract or potentially 

awards it to another party, it is premature to speculate, in our view, as to 

whether NNSA may incur additional storage or other costs related to the 

U.S. fuel bank in the future.

As agreed with your offices, unless you publicly announce the contents of 

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

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

Secretary of State, the Administrator of NNSA, the Chairman of the 

Nuclear Regulatory Commission, the appropriate congressional 

committees, and other interested parties. In addition, this report will be

available at no charge on the GAO website at http://www.gao.gov.

If you or your staff members have any questions about this report, please 

contact me at (202) 512-3841 or trimbled@gao.gov. Contact points for 

our Offices of Congressional Relations and Public Affairs may be found 

on the last page of this report. GAO staff who made key contributions to 

this report are listed in appendix V.

David C. Trimble

Director, Natural Resources and Environment
Appendix I: Objectives, Scope, and 

Methodology

Page 55 GAO-13-139 Safeguards, Nuclear Security, and Fuel Bank Programs

The objectives of our review were to examine: (1) changes that have 

occurred since 2005 and challenges, if any, that the International Atomic 

Energy Agency (IAEA) faces in carrying out its safeguards program; (2) 

changes that have occurred since 2005 and limitations, if any, regarding 

IAEA’s nuclear security program; and (3) the status of IAEA’s planned 

international nuclear fuel bank.

For all three objectives, we traveled to Vienna, Austria, in June 2012 and 

spoke with IAEA officials responsible for implementing the safeguards, 

nuclear security, and fuel bank programs. While in Vienna, we also 

conducted interviews with a nonprobability sample1 of officials from 15 

countries, in addition to the U.S. Mission to the United Nations System 

Organizations in Vienna (U.S. Mission), to obtain their views on these 

programs.

To select these countries, we identified criteria and selected countries 

that met at least three of the criteria we identified. The criteria for 

selection included IAEA member countries that:

• possess nuclear weapons,

• reprocess nuclear material,

• are members of the IAEA Board of Governors for 2011-2012,

• are members of the Non-Aligned Movement,

• have nuclear power or plan to have nuclear power reactors,

• brought an Additional Protocol into force, and

• consume the greatest share of IAEA safeguards resources.

Given the aforementioned criteria, we identified and invited 25 

geographically diverse countries to participate in interviews. Of the 25 

countries, 15 responded to our invitation. Therefore, we completed inperson interviews with officials from the following countries: Brazil, 

Canada, Chile, China, France, Germany, India, Israel, Japan, Pakistan, 

Russia, South Korea, Turkey, the United Arab Emirates, and the United 

Kingdom. Throughout this report, we distinguish between statements 

made by the U.S. Mission and other countries (foreign missions), and we 

 

1 Results from nonprobability samples cannot be used to make inferences about a 

population because in a nonprobability sample some elements of the population being 

studied have no chance or an unknown chance of being selected as part of the sample. 

However, in this case, the results of such a sample can provide examples of individual 

countries’ views of the three IAEA programs.

Appendix I: Objectives, Scope, and 

Methodology 
Appendix I: Objectives, Scope, and 

Methodology

Page 56 GAO-13-139 Safeguards, Nuclear Security, and Fuel Bank Programs

use the term “some” when referring to two or three countries and 

“several” when referring to four or more countries.

In addition, we interviewed 15 experts who specialize in nuclear 

nonproliferation issues and are knowledgeable about IAEA’s safeguards, 

nuclear security, and/or fuel bank programs. Specifically, we met with 11 

experts from 9 different academic think tanks and nongovernmental 

organizations—such as the Belfer Center for Science and International 

Affairs at Harvard University’s John F. Kennedy School of Government, 

the World Institute for Nuclear Security, and the Nuclear Threat 

Initiative—and 4 former senior IAEA officials. The four former senior IAEA 

officials consisted of the immediate past two Heads of the Department of 

Safeguards, the former Director of the Office of Nuclear Security, and the 

prior Head of the Department of Management. To select the experts we 

interviewed, we identified and prepared a list of nuclear nonproliferation 

experts based on several factors, including the following:

• their direct knowledge of IAEA from their recent prior work at the 

agency regarding the safeguards, nuclear security, and/or fuel bank 

programs;

• their extensive knowledge of IAEA’s safeguards, nuclear security, 

and/or fuel bank programs, based on their work at academic 

institutions or nongovernmental organizations;

• their prior experience in meeting with GAO as subject matter experts; 

and

• referrals from other nuclear nonproliferation experts (snowball 

sampling).

Throughout this report, we use the term “some” when referring to two or 

three experts and “several” when referring to four or more experts.

For all three objectives, we also collected documents from, and 

interviewed, officials from the Department of Energy’s (DOE) National 

Nuclear Security Administration (NNSA) and DOE national laboratories, 

including Brookhaven National Laboratory in New York, which manages 

U.S. technical assistance to IAEA’s safeguards program. Further, we 

obtained the views of officials from the U.S. Mission on the changes and 
Appendix I: Objectives, Scope, and 

Methodology

Page 57 GAO-13-139 Safeguards, Nuclear Security, and Fuel Bank Programs

any challenges they identified for the IAEA safeguards and nuclear 

security programs since we last reported on them in 2005, as well as their 

views on IAEA’s planned fuel bank.2 We also met with officials from the 

Department of State’s (State) Bureau of International Organization Affairs, 

Bureau of International Security and Nonproliferation, and Office of 

Multilateral Nuclear and Security Affairs in Washington, D.C., as well as 

officials from State who were knowledgeable about U.S. extra-budgetary 

contributions for each of the programs.

To examine the changes that have occurred since 2005 and challenges, if 

any, that IAEA faces in carrying out its safeguards program, we obtained 

and analyzed agency documentation related to the safeguards program, 

including the agency’s biennial program and budget documents, annual 

reports, and long- and medium-term strategic plans. In June 2012, we 

met with IAEA officials from the Department of Safeguards, including the 

directors and staff responsible for implementing the state-level concept in 

Vienna, Austria. We also toured IAEA’s Safeguards Analytical 

Laboratories in Seibersdorf, Austria, where environmental and nuclear 

material samples are analyzed. We also interviewed officials from DOE’s 

Lawrence Livermore National Laboratory in California, which, as part of 

IAEA’s international network of safeguards analytical laboratories, 

analyzes nuclear material samples collected by IAEA inspectors. 

Furthermore, we interviewed officials from the Nuclear Regulatory 

Commission and the Department of Defense, including a senior official 

from the U.S. Air Force Technical Applications Center, which operates 

one of the laboratories that conducts environmental sample analysis as 

part of IAEA’s international network of safeguards analytical laboratories. 

In addition, we attended a workshop in May 2012 on “evolving the statelevel concept” because it was dedicated to discussing IAEA’s plans for 

implementing the state-level concept for safeguards and because it 

included attendees from IAEA and U.S. government agencies. The 

workshop was hosted by the Institute of Nuclear Materials Management 

and held at the University of Virginia in Charlottesville, Virginia. To identify 

IAEA’s total regular budget and extra-budgetary cash contributions for the 

safeguards program in 2011, we indentified such information in the 

agency’s annual report for 2011 and gathered and reviewed data from 

IAEA officials. To identify the United States’ extra-budgetary cash 

 

2 GAO-06-93. 
Appendix I: Objectives, Scope, and 

Methodology

Page 58 GAO-13-139 Safeguards, Nuclear Security, and Fuel Bank Programs

contributions to the safeguards program in 2011, we gathered and 

reviewed data from State.

To examine the changes that have occurred since 2005 and limitations, if 

any, regarding IAEA’s nuclear security program, we collected and 

analyzed documentation, including IAEA’s yearly reports to its Board of 

Governors on its nuclear security program, as well as IAEA’s Nuclear 

Security Plan 2010-2013. We also met with officials from IAEA’s Office of 

Nuclear Security and the Office of Legal Affairs in Vienna, Austria. 

Moreover, we met with NNSA officials to obtain their views on IAEA’s 

security activities, budget, and management issues. In addition, we spoke 

with experts from nongovernmental organizations and academic think 

tanks, such as the Partnership for Global Security and Harvard 

University’s Belfer Center, to obtain their perspectives regarding IAEA’s 

nuclear security activities. To identify IAEA’s total regular budget and 

extra-budgetary cash contributions for the nuclear security program in 

2011, we reviewed such information in IAEA’s annual report for 2011. To 

identify the United States’ extra-budgetary cash contributions to the 

nuclear security program, we gathered and reviewed data from State.

To examine the status of IAEA’s planned nuclear fuel bank, we spoke 

with officials in the Director General’s Office for Policy in Vienna, Austria, 

to discuss IAEA’s progress toward implementing the fuel bank. We also 

met with officials from the Nuclear Threat Initiative, which, alongside IAEA 

and the U.S. government, contributed funding for the fuel bank. Further, 

we met with NNSA officials to obtain additional information regarding 

IAEA’s fuel bank, as well as the American Assured Fuel Supply (U.S. fuel 

bank). To identify IAEA’s total budget on the fuel bank program, we 

obtained documentation and met with IAEA officials involved in the 

budgeting process. We also obtained U.S. budget data related to the U.S. 

fuel bank from NNSA officials, as well as gathered other information 

related to the U.S. fuel bank published in the Federal Register. 

To assess the reliability of IAEA’s budget data related to the safeguards, 

nuclear security, and fuel bank programs, we compared data from 

different published sources, including the Federal Register, and we met 

with IAEA and U.S. officials to discuss these data in detail. We also 

obtained and reviewed responses from key officials from State that 

addressed such areas as data entry, data access, quality control 

procedures, and data accuracy and completeness regarding the data they 

provided on U.S. extra-budgetary cash contributions for each program. 

Further, we analyzed other documentation, such as the external auditor’s 

report on IAEA, as well as the agency’s strategic planning documents. In 
Appendix I: Objectives, Scope, and 

Methodology

Page 59 GAO-13-139 Safeguards, Nuclear Security, and Fuel Bank Programs

addition, we obtained written responses from IAEA and U.S. officials to 

clarify discrepancies in the data we received. Throughout this report, we 

calculated all monetary figures for IAEA’s safeguards, nuclear security, 

and fuel bank programs using the exchange rates published in the 

agency’s annual report for 2011, which was the average exchange rate 

used by the United Nations in 2011 of $1.3893 to €1.00. Based on this 

work, we determined that data provided by IAEA to be sufficiently reliable 

for presenting the overall amount of money budgeted for each program in 

2011. Additionally, we determined that the data on U.S. extra-budgetary 

cash contributions provided by State to be sufficiently reliable for 

presenting the overall amount of U.S. extra-budgetary cash contributions 

to IAEA in 2011. Finally, we determined that the data provided by NNSA 

and published in the Federal Register related to U.S. funding for IAEA’s 

planned fuel bank to be sufficiently reliable for presenting the amount of 

funding that IAEA’s fuel bank program has received to date from the 

United States.

We conducted this performance audit from January 2012 to April 2013 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 objectives.
Appendix II: Status of Countries’ Safeguards 

Agreements, Additional Protocols, and Small 

Quantities Protocols in Force with IAEA, as of 

December 2012

Page 60 GAO-13-139 Safeguards, Nuclear Security, and Fuel Bank Programs

Country

Comprehensive 

safeguards 

agreementa Additional 

Protocol 

Small 

quantities 

protocol

Non-nuclear weapon states 

Afghanistan X X X 

Albania X X 

Algeria X 

Andorra X X X 

Angola X X X 

Antigua and Barbuda X X 

Argentina X 

Armenia X X 

Australia X X 

Austria X X 

Azerbaijan X X X 

Bahamas X X 

Bahrain X X X 

Bangladesh X X 

Barbados X X 

Belarus X 

Belgium X X 

Belize X X 

Benin 

Bhutan X X 

Bolivia X X 

Bosnia and Herzegovina X 

Botswana X X 

Brazil X 

Brunei Darussalam X X 

Bulgaria X X 

Burkina Faso X X X 

Burundi X X X 

Cambodia X X 

Cameroon X X 

Canada X X 

Cape Verde 

Central African Republic X X X 

Appendix II: Status of Countries’ Safeguards 

Agreements, Additional Protocols, and Small 

Quantities Protocols in Force with IAEA, as of 

December 2012 
Appendix II: Status of Countries’ Safeguards 

Agreements, Additional Protocols, and Small 

Quantities Protocols in Force with IAEA, as of 

December 2012

Page 61 GAO-13-139 Safeguards, Nuclear Security, and Fuel Bank Programs

Country

Comprehensive 

safeguards 

agreementa Additional Protocol 

Small 

quantities 

protocol

Chad X X X 

Chile X X 

Colombia X X 

Comoros X X X 

Congo, Republic of the X X X 

Costa Rica X X X 

Côte d’Ivoire X 

Croatia X X X 

Cuba X X 

Cyprus X X 

Czech Republic X X 

Democratic People’s Republic of Korea (North Korea)b X 

Democratic Republic of the Congo X X 

Denmark X X 

Djibouti 

Dominica X X 

Dominican Republic X X X 

Ecuador X X X 

Egypt X 

El Salvador X X X 

Equatorial Guinea 

Eritrea 

Estonia X X 

Ethiopia X X 

Fiji X X X 

Finland X X 

Gabon X X X 

Gambia X X X 

Georgia X X 

Germany X X 

Ghana X X 

Greece X X 

Grenada X X 

Guatemala X X X 

Guinea 

Guinea-Bissau 
Appendix II: Status of Countries’ Safeguards 

Agreements, Additional Protocols, and Small 

Quantities Protocols in Force with IAEA, as of 

December 2012

Page 62 GAO-13-139 Safeguards, Nuclear Security, and Fuel Bank Programs

Country

Comprehensive 

safeguards 

agreementa Additional Protocol 

Small 

quantities 

protocol

Guyana X X 

Haiti X X X 

Holy See X X X 

Honduras X X 

Hungary X X 

Iceland X X X 

Indonesia X X 

Iran, the Islamic Republic of X 

Iraq X X 

Ireland X X 

Italy X X 

Jamaica X X 

Japan X X 

Jordan X X X 

Kazakhstan X X 

Kenya X X X 

Kiribati X X 

Korea, Republic of (South Korea) X X 

Kuwait X X X 

Kyrgyzstan X X X 

Laos X X 

Latvia X X 

Lebanon X X 

Lesotho X X X 

Liberia 

Libya X X 

Liechtenstein X 

Lithuania X X 

Luxembourg X X 

Macedonia, Republic of X X X 

Madagascar X X X 

Malawi X X X 

Malaysia X 

Maldives X X 

Mali X X X 

Malta X X 
Appendix II: Status of Countries’ Safeguards 

Agreements, Additional Protocols, and Small 

Quantities Protocols in Force with IAEA, as of 

December 2012

Page 63 GAO-13-139 Safeguards, Nuclear Security, and Fuel Bank Programs

Country

Comprehensive 

safeguards 

agreementa Additional Protocol 

Small 

quantities 

protocol

Marshall Islands X X 

Mauritania X X X 

Mauritius X X X 

Mexico X X 

Micronesia 

Moldova, Republic of X X X 

Monaco X X X 

Mongolia X X X 

Montenegro X X X 

Morocco X X 

Mozambique X X X 

Myanmar X X 

Namibia X X X 

Nauru X X 

Nepal X X 

Netherlands X X X 

New Zealand X X X 

Nicaragua X X X 

Niger X X 

Nigeria X X 

Norway X X 

Oman X X 

Palau X X X 

Panama X X X 

Papua New Guinea X X 

Paraguay X X X 

Peru X X 

Philippines X X 

Poland X X 

Portugal X X 

Qatar X X 

Romania X X 

Rwanda X X X 

St. Kitts and Nevis X X 

St. Lucia X X 

St. Vincent & the Grenadines X X 
Appendix II: Status of Countries’ Safeguards 

Agreements, Additional Protocols, and Small 

Quantities Protocols in Force with IAEA, as of 

December 2012

Page 64 GAO-13-139 Safeguards, Nuclear Security, and Fuel Bank Programs

Country

Comprehensive 

safeguards 

agreementa Additional Protocol 

Small 

quantities 

protocol

Samoa X X 

San Marino X X 

Sao Tomé and Principe 

Saudi Arabia X X 

Senegal X X 

Serbia X 

Seychelles X X X 

Sierra Leone X X 

Singapore X X X 

Slovakia X X 

Slovenia X X 

Solomon Islands X X 

Somalia 

South Africa X X 

Spain X X 

Sri Lanka X 

Sudan X X 

Suriname X X 

Swaziland X X X 

Sweden X X 

Switzerland X X 

Syrian Arab Republic (Syria) X 

Tajikistan X X 

Tanzania, United Republic of X X X 

Thailand X 

Timor-Leste 

Togo X X X 

Tonga X X 

Trinidad and Tobago X X 

Tunisia X 

Turkey X X 

Turkmenistan X X 

Tuvalu X X 

Uganda X X X 

Ukraine X X 

United Arab Emirates X X X 
Appendix II: Status of Countries’ Safeguards 

Agreements, Additional Protocols, and Small 

Quantities Protocols in Force with IAEA, as of 

December 2012

Page 65 GAO-13-139 Safeguards, Nuclear Security, and Fuel Bank Programs

Country

Comprehensive 

safeguards 

agreementa Additional Protocol 

Small 

quantities 

protocol

Uruguay X X 

Uzbekistan X X 

Vanuatu 

Venezuela X 

Vietnam X X 

Yemen X X 

Zambia X X 

Zimbabwe X X 

Nuclear weapon statesc Voluntary offer 

safeguards agreement

Additional 

Protocol 

Small 

quantities 

protocol

China X X 

France X X Xd

Russian Federation (Russia) X X 

United Kingdom X X Xd

United States X X Xd

Non-NPT signatory countriese Item-specific 

safeguards agreement

Additional 

Protocol 

Small 

quantities 

protocol

India X 

Israel X 

Pakistan X 

Source: GAO presentation of IAEA data. 

a As noted earlier, IAEA does not officially recognize Taiwan as a state, but IAEA applies safeguards 

in Taiwan under two agreements that entered into force in October 1969 and December 1971. 

Taiwan has also implemented the measures of the Model Additional Protocol since October 1999.

b Although North Korea concluded a comprehensive safeguards agreement with IAEA in 1992, the 

agency has not been able to conduct all necessary safeguards activities provided for in the 

agreement since 1994 and, in January 2003, North Korea announced its withdrawal from the Treaty 

on the Nonproliferation of Nuclear Weapons (NPT).

c As of the end of December 2012, the five nuclear weapon states had safeguards agreements in 

force, called voluntary offer agreements, in which safeguards were implemented with regard to 

declared nuclear material in selected facilities in all five states. In addition, the five nuclear weapon 

states had Additional Protocols in force at that time.

d As of the end of December 2012, France, the United Kingdom, and the United States had operative 

small quantities protocols in reference to their respective territories in Latin America. These operative 

small quantities protocols are associated with these three countries’ safeguards agreements pursuant 

to Additional Protocol I to the Treaty of Tlatelolco, which are different from their voluntary offer 

agreements under the NPT. 

e As of the end of December 2012, these three non-NPT signatory countries had what are called itemspecific safeguards agreements in force that require the application of safeguards to nuclear material, 

facilities, and other items specified in the relevant safeguards agreement.
Appendix III: Comments from the Department of 

State

Page 66 GAO-13-139 Safeguards, Nuclear Security, and Fuel Bank Programs

Appendix III: Comments from the 

Department of State
Appendix III: Comments from the Department of 

State

Page 67 GAO-13-139 Safeguards, Nuclear Security, and Fuel Bank Programs
Appendix III: Comments from the Department of 

State

Page 68 GAO-13-139 Safeguards, Nuclear Security, and Fuel Bank Programs
Appendix III: Comments from the Department of 

State

Page 69 GAO-13-139 Safeguards, Nuclear Security, and Fuel Bank Programs
Appendix IV: Comments from the National 

Nuclear Security Administration

Page 70 GAO-13-139 Safeguards, Nuclear Security, and Fuel Bank Programs

Appendix IV: Comments from the National 

Nuclear Security Administration
Appendix IV: Comments from the National 

Nuclear Security Administration

Page 71 GAO-13-139 Safeguards, Nuclear Security, and Fuel Bank Programs
Appendix V: GAO Contact and Staff 

Acknowledgments

Page 72 GAO-13-139 Safeguards, Nuclear Security, and Fuel Bank Programs

David C. Trimble, (202) 512-3841 or trimbled@gao.gov

In addition to the individual named above, Glen Levis, Assistant Director; 

Josey Ballenger; Antoinette Capaccio; Bridget Grimes; Alison O’Neill; 

Steven R. Putansu; and Emily Suarez-Harris made key contributions to 

this report.

Appendix V: GAO Contact and Staff 

Acknowledgments 

GAO Contact

Staff 

Acknowledgments 

(361375)
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