UNITED STATES 

NUCLEAR REGULATORY COMMISSION 

WASHINGTON, D.C. 20555-0001 

August 11, 2010 

CHAIRMAN 

The President 

The White House 

Washington, D.C. 20500 

Dear Mr. President: 

In accordance with Section 651(d) of the Energy Policy Act of 2005 (Public Law 109-58), 

I am providing the enclosed report documenting the efforts of the Radiation Source Protection 

and Security Task Force (Task Force). 

The Energy Policy Act charged the Task Force with 1) evaluating and providing 

recommendations relating to the security of radiation sources in the United States from potential 

terrorist threats, including acts of sabotage, theft, or use of a radiological source in a radiological 

dispersal device; and 2) providing, within 1 year of enactment, and not less than every 4 years 

thereafter, reports containing its recommendations, including recommendations for appropriate 

regulatory and legislative changes, to the Congress and the President. 

On August 15, 2006, the Task Force submitted the first report. At that time. the Task 

Force found no significant gaps that were not already being addressed, nor made any 

recommendations for legislative changes. The Task Force identified a number of near-term 

actions planned or underway to further strengthen regulatory controls and made several 

recommendations to enhance the overall security of risk-significant radioactive sources. 

Over the last 4 years, the Task Force, which includes membership from 14 Federal 

agencies and 2 State organizations, has made significant progress in ensuring that the United 

States continues to be a world leader in applying the International Atomic Energy Agency's 

"Code of Conduct on the Safety and Security of Radioactive Sources (Code of Conduct)." 

published in 2003, through strengthening the system of regulatory controls. The United States 

is committed to the Code of Conduct through the development. harmonization and 

implementation of national policies, laws and regulations, and through the fostering of 

international co-operation. Domestically, we maintain a high level of safety and security of 

risk-significant radioactive sources, as discussed in the 2006 Task Force report, as well as 

addressed in the enclosed quadrennial Task Force report, and we will continue to set the 

example to other nations for the security of these sources. 
-2­

If you have any questions, please feel free to contact me. I may be reached by phone 

at (301) 415-1750. 

Respectfully, 

Enclosure: 

Radiation Source Protection and 

Security Task Force Report 
Identical letters sent to: 

The President 

The White House 

Washington, D.C. 20500 

The Honorable Joseph R. Biden, Jr. 

President of the United States Senate 

Washington, D.C. 20510 

The Honorable Nancy Pelosi 

Speaker of the House of Representatives 

Washington, D.C. 20515 

The Honorable Jeff Bingaman 

Chairman, Committee on Energy 

and Natural Resources 

United States Senate 

Washington, D.C. 20510 

cc: Senator Lisa Murkowski 

The Honorable Barbara Boxer 

Chairman, Committee on Environment 

and Public Works 

United States Senate 

Washington, D.C. 20510 

cc: Senator James M. Inhofe 

The Honorable Henry A. Waxman 

Chairman, Committee on Energy 

and Commerce 

United States House of Representatives 

Washington, D.C. 20515 

cc: Representative Joe Barton 

The Honorable Edward J. Markey 

Chairman, Subcommittee on Energy 

and Environment 

Committee on Energy and Commerce 

United States House of Representatives 

Washington, D.C. 20515 

cc: Representative Fred Upton 

The Honorable Thomas R. Carper 

Chairman, Subcommittee on Clean Air 

and Nuclear Safety 

Committee on Environment and Public Works 

United States Senate 

Washington, D.C. 20510 

cc: Senator David Vitter 
-2­

The Honorable Joseph I. Lieberman 

Chairman, Committee on Homeland Security 

and Governmental Affairs 

United States Senate 

Washington, D.C. 20510 

cc: Senator Susan Collins 

The Honorable Bennie G. Thompson 

Chairman, Committee on Homeland Security 

United States House of Representatives 

Washington, D.C. 20515 

cc: Representative Peter T. King 

i 

Key Accomplishments, Challenges, and Recommendations 

Established by the Energy Policy Act of 2005 (EPAct), the Interagency Task Force on Radiation 

Source Protection and Security (Task Force) has made important progress since its 2006 report 

to the President and Congress to improve the security of domestic radioactive sources given the 

enduring threat of terrorists seeking radioactive materials to attack the United States. The Task 

Force is pleased to note in this 2010 report the many accomplishments achieved over the past 4 

years, including the closeout of a number of significant recommendations from the 2006 report. 

As was the case with the 2006 report, this report is limited to issues relating to the security of 

radiation sources and does not address issues relating to other radioactive material, such as 

spent nuclear fuel and high-level waste. 

Key Accomplishments since 2006

The Task Force and interagency group have accomplished the following key actions: 

√ Since 2006, interagency preparedness has increased. Also, interagency coordination 

and the interagency group’s ability to communicate with the public during an emergency

have improved with regard to assessing security programs, making risk-significant 

radioactive sources more secure, and mitigating consequences—thereby reducing the 

potential risk of use by terrorists. For example, the Task Force devised a plan of action 

for a comprehensive public education campaign with the goals of increasing public 

understanding of radiological threats and reducing fears, thereby diminishing the impact 

of a radiological attack and improving response and recovery in its aftermath. The plan 

includes a comprehensive compendium of existing educational resources and material 

that can be used to facilitate a public education campaign. As an outcome of 

coordination efforts between the interagency, it was agreed to transfer all of the public 

education outreach initiatives to the Federal Emergency Management Agency (FEMA), 

the lead for the U.S. Government in public communication on issues related to radiation 

and other hazards. However, the Task Force will continue to support FEMA’s progress 

on this campaign and will stay apprised of its developments. 

√ In 2007–2009, the Task Force reevaluated the list of risk-significant radioactive sources 

and the associated threshold quantities warranting enhanced security and protection to 

assess their adequacy in light of the evolving threat environment. The analysis was 

based on considerations such as the economic and social consequences of an attack 

using a radiological dispersal device. It concluded that no changes should be made to 

the list of existing 16 radionuclides and associated established threshold quantities, but 

7 additional radionuclides may be considered for enhanced control in some limited 

situations. Also, the Task Force achieved Federal concurrence on the definitions of a 

significant radiological dispersal device and a significant radiation exposure device. The 

definitions are intended to provide the foundations for identifying and assessing potential 

hazards, determining the levels of relative risk that can be adequately managed, and 

prioritizing and allocating resources to prevent and protect against radiological incidents. 

√ Since 2007, existing security was improved by (1) requiring fingerprinting and Federal 

Bureau of Investigation criminal history records checks of all individuals with unescorted 

access to risk-significant quantities of radioactive materials to further improve the tools 

available to determine trustworthiness and reliability, and (2) providing voluntary security 

enhancements and specialized training to sites and local law enforcement agencies. 
ii 

√ In January 2009, the U.S. Nuclear Regulatory Commission (NRC) deployed a major 

security initiative—the National Source Tracking System. This computer system, 

mandated in the EPAct [EPAct 2005], tracks the possession and transfers of more than 

70,000 risk-significant radioactive sources over the life cycle of those sources. The 

system improves the ability of regulators to detect and act upon inventory anomalies, 

respond to emergencies, and verify legitimate import, export, ownership, and use of 

sources. Similarly, the U.S. Department of Energy (DOE) has successfully initiated the 

Radiological Source Registry and Tracking System (RSRT) within DOE, and DOE sites 

are now reporting approximately 2,300 risk-significant radioactive materials to RSRT, a 

centralized system. 

√ In 2007–2009, the Task Force conducted a study to assess the feasibility of phasing out 

the use of cesium-137 in a highly dispersible form (cesium chloride (CsCl)). Considering 

the results of the study and other input received, the Task Force concluded that 

immediate phase-out would not be feasible because the sources are extensively used in 

a wide range of applications in medicine, industry, and research with significant health 

benefits to patients. However, a gradual, stepwise phase-out could be feasible as 

alternatives become technologically and economically viable and if disposal pathways 

are identified. Also, the security of these sources has substantively improved with the 

implementation of security requirements, such as the increased controls, and voluntary 

facility and device hardening measures. The study identified a path forward that 

involves a comprehensive multipart approach for further improving the security of and 

reducing the risks associated with these sources. The Task Force deemed that 

sufficient time is required for the development of replacement technologies for certain 

applications and for the identification of disposal pathways for disused sources. In the 

interim, measures such as enhancing the physical security of existing devices provide 

more effective protection of the CsCl sources currently in use. For example, the NRC is 

cooperating with the DOE/National Nuclear Security Administration (NNSA) to provide, 

on a voluntary basis, physical protection upgrades to existing CsCl irradiators to 

complement the security afforded through regulatory requirements. 

√ In 2008–2010, the Task Force evaluated alternative technologies for the seven most 

common risk-significant radioactive devices. It assessed financial incentives, research 

needs, and the costs and benefits of potential alternative devices. The analysis found 

that while alternatives exist for some applications, the viability, relative risk reduction 

achievable, and stage of development of these alternatives vary greatly. Although 

alternative forms and radionuclides were assessed, further risk reduction might be 

achieved through alternative technology research and development that focuses on 

non-radioactive replacement (e.g., x-ray). X-ray technologies were found to be 

cost-competitive with radionuclide technologies on an annualized cost basis. However, 

technological concerns remain with x-ray devices—specifically, product throughput and 

downtime of the x-ray devices. The study concluded that successful replacement of the 

radionuclide technologies with alternatives will require different timetables for each 

application, will need to be incentivized, and will require a coordinated effort among a 

wide range of stakeholders. As further discussed, the availability of disposal pathways 

for radioactive sources should be considered before widespread replacement of 

radioactive sources with alternative technologies occurs. 
iii 

√ By 2010, 100 countries had made a political commitment to follow the International 

Atomic Energy Agency Code of Conduct on the Safety and Security of Radioactive 

Sources (Code of Conduct) [IAEA 2004]. This is a substantial increase from the 86 

countries that made the commitment by 2006. Internationally, the United States has a 

lead role in building global recognition and observance of this non-binding standard for 

the life-cycle control of radioactive sources and was instrumental in gaining endorsement 

of the Code of Conduct by leaders at the Group of Eight (G-8), U.S.–European Union, 

Asia-Pacific Economic Cooperation, and Organization for Security and Co-operation in 

Europe summits. 

Key Challenges and Recommendations

In addition to its many accomplishments, the Task Force identified two major challenges that 

require attention at higher levels and developed the following recommendations: 

(1) Disposal of Disused Radioactive Sources1

Challenge: By far the most significant challenge identified is access to disposal for disused 

radioactive sources. Under the Low-Level Radioactive Waste Policy Amendments Act of 1985 

(LLWPAA), States must provide disposal capability for commercial Class A, B, and C low-level 

radioactive waste [LLRWPAA 1985]. The Act encouraged the States to enter into regional 

compacts that would allow them to dispose of waste at a regional disposal facility and exclude 

wastes from States outside that compact. Disposal access, already a challenge before 2006, 

has diminished substantially since that time and a comprehensive change is needed to 

overcome current barriers in the disposal framework. In July 2008, the commercial low-level 

radioactive waste disposal site near Barnwell, SC closed to out-of-compact waste, leaving 

licensees in the 36 States outside of the Atlantic, Rocky Mountain, and Northwest Compacts 

without disposal access for Class A, B, and C low-level radioactive waste. In addition, because 

of its relatively low activity limits, the Barnwell facility does not accept most sealed sources as 

Class B and C low-level radioactive waste even from Atlantic Compact States. Also, many of 

the risk-significant sealed sources qualify as greater than Class C (GTCC) low-level radioactive 

waste, for which there is no current disposal capability. Under current regulations, GTCC waste 

would be disposed of in a geologic repository unless alternative methods of disposal are 

proposed to and approved by the NRC. DOE is responsible for developing the capability to 

dispose of GTCC wastes from NRC and Agreement State licensees in accordance with the 

LLWPAA. 

                                                           

1 Every year, thousands of sources become disused and unwanted in the United States. While secure 

storage is a temporary measure, the longer sources remain disused or unwanted the chances increase that 

they will become unsecured or abandoned. These sources have been the focus of much interagency 

attention from a national security standpoint since the publication of the 2006 report. However, in many 

cases, disposal pathways are not currently available for disused sealed sources (and there are restricted 

options for storage of no-disposal-pathway waste). Continued coordinated effort is needed to make sure 

that comprehensive, sustainable disposal pathways for all disused sealed sources are developed in the 

interest of national security. These concerns are specific to disposal of radiation sources and do not relate 

to the storage and disposal of other radioactive materials, such as spent nuclear fuel and high-level waste.
iv 

As a result, most licensees now have no commercial disposal option and must instead 

implement on-site long-term storage of their disused or unwanted sealed sources. While 

current Federal and State regulations and inspection programs provide assurance that these 

disused sources remain secure while in long-term storage, disposal is considered the most 

secure management approach. 

In response to the challenge of diminishing disposal capacity, some progress has been made in 

pursuing solutions. However, final implementation of these ongoing efforts may ultimately 

require the highest levels of government involvement, including congressional action. 

• Notably, DOE has initiated the development of an environmental impact statement to 

evaluate potential disposal options for GTCC waste. DOE is developing a draft 

environmental impact statement (EIS) and expects to issue the final EIS in 2011. Under 

EPAct Section 631(b), before DOE can issue a final decision on a disposal alternative, it 

must first issue a report to Congress describing the disposal alternatives under 

consideration and await congressional action. 

• In addition, DOE determined that some sealed sources recovered by the DOE/NNSA 

Global Threat Reduction Initiative Offsite Source Recovery Program can be disposed of 

as DOE waste at existing DOE facilities. This reduced the backlog of recovered sealed 

sources in storage. However, there are similar sources registered with the program for 

recovery from U.S. owners that contain foreign-origin radioactive material (e.g., 

Russian-origin americium-241) which do not currently have a disposal path and recovery 

is severely constrained until a disposal path is available. 

• Finally, in September 2009, the State of Texas licensed the construction of a new facility 

to provide a disposal capability for certain classes of low-level radioactive waste, 

including disused sealed sources for licensees in the Texas Compact (Vermont and 

Texas). This will be the first new facility to serve as a regional compact site since the 

passage of the LLWPAA. Also in September 2009, the State of Texas licensed the 

construction of a facility for the disposal of Federal low-level radioactive waste and 

mixed low-level radioactive waste. It is expected that both facilities will be operational in 

2011. 

Recommendations: To address these difficulties, the Task Force recommends that (1) DOE 

continue its ongoing efforts to develop GTCC disposal capability subject to required 

congressional action, (2) the U.S. Government and States continue to evaluate waste disposal 

options for disused radioactive sealed sources, and (3) Federal and State governments 

investigate options such as providing short-term secured storage of sources recovered from 

U.S. owners that contain foreign-origin americium-241 radioactive material so these sources 

can be recovered now and increase efforts to investigate options for disposal of these sources. 

(2) Alternative Technologies 

Challenge: A second major area that the Task Force has devoted considerable effort to is the 

examination of alternatives to certain risk-significant radioactive sources (americium-241, 

cesium-137, cobalt-60, and iridium-192 sources). The replacement of these sources with a 

lower risk alternative would reduce the security concerns associated with these sources. Three 

types of alternatives could serve as replacements for risk-significant radionuclides: (1) 

technologies that use the same radionuclide with a different chemical or physical form (e.g., 

replacing cesium-137 salt with less dispersible cesium-137 ceramic), (2) technologies that use a 
v 

different radionuclide (e.g., replacement of cesium-137 salt with cobalt-60 metal), and (3) 

technologies that do not use a radionuclide (e.g., x-ray technology). Although alternative forms 

and radionuclides were assessed, further risk reduction might be achieved through alternative 

technology research and development that focuses on non-radioactive replacement (e.g., 

x-ray). While alternatives exist for some applications, financial, logistical, functional, relative 

risk, and disposal issues can impede the deployment of alternatives and their replacement of 

current operating technology.

Recommendations: To promote the replacement of risk-significant radioactive sources, the 

Task Force recommends that the U.S. Government should enhance support of short-term and 

long-term research and development for alternative technologies to replace current technologies 

that use americium-241, cesium-137, cobalt-60, and iridium-192 in risk-significant quantities. 

Contingent upon the availability of viable alternative technologies and taking into consideration 

the availability of disposal pathways for disused sources, the U.S. Government should 

investigate options such as a voluntary prioritized, Government-incentivized program for the 

replacement of devices containing risk-significant quantities of radioactive material with effective 

alternatives. While it is prudent to continue to look for viable alternative technologies and 

sources, a decision on whether to discontinue NRC and Agreement State licensing or export of 

CsCl sources containing risk-significant quantities of radioactive material should be contingent 

on the existence of viable alternative technologies, and take into consideration the availability of 

disposal capacity and the changes in the threat environment. On June 29, 2010, the NRC 

published a draft policy statement on the protection of CsCl sources in the Federal Register for 

public comment [NRC 2010c]. The detailed principles of the policy statement are provided in 

Chapter 4 and are reflected in the direction proposed in the recommendations of this report. 
vi 

Contents

Key Accomplishments, Challenges, and Recommendations.............................. i 

Background ................................................................................................ 1

Chapter 1 Coordination and Communication Improvements .......................... 3

 Governmental Coordination and Public Education ....................................... 3

 Accomplishments ....................................................................... 3

 2010 Recommendations .............................................................. 6

Chapter 2 Advances in the Security and Control of Radioactive Sources ........ 7

I. Reevaluation of Radioactive Source Lists ........................................ 7

 Accomplishments ............................................................. 8

 2010 Recommendations ................................................... 12

II. Security Measures and Initiatives ................................................. 12

 Accomplishments ............................................................ 12 

 Security Requirements ........................................... 12 

 Voluntary Security Enhancements ............................ 13

 2010 Recommendations ................................................... 17 

III. Improvements to the Licensing Process ........................................ 17

 Accomplishments ............................................................ 18 

 2010 Recommendations ................................................... 19 

IV. Tracking of Sources .................................................................. 19

 Accomplishments ............................................................ 20 

 2010 Recommendations ................................................... 22

V. Transportation Security .............................................................. 22 

 Accomplishments ............................................................ 22 

 2010 Recommendations ................................................... 26 

VI. Import and Export Controls ......................................................... 26 

 Accomplishments ............................................................ 26 

 2010 Recommendations ................................................... 29 

Chapter 3 Status of the Recovery and Disposition of Radioactive Sources .... 31

 Management of Disused Sources .......................................................... 31 

 Accomplishments ..................................................................... 33

 2010 Recommendations ............................................................ 37 

Chapter 4 Progress in the Area of Alternative Technologies ........................ 40

 Alternative Technologies ...................................................................... 40 

 Accomplishments ..................................................................... 41

 2010 Recommendations ............................................................ 45

Summary Table of 2006 Recommendations and Actions and 2010 

Recommendations ..................................................................................... 46 

References ................................................................................................ 61 
vii 

Appendices

A Acronyms and Abbreviations ................................................................. 66

B Glossary ........................................................................................... 68 

Tables

Table I Seven Projects of the Public Education Action Plan .................................... 5 

Table II Radionuclides that Warrant Enhanced Security and Protection ..................... 11 

Table III Radionuclides that Should Be Considered for Enhanced Controls ................. 11 

Figure

Figure I LLRW Sealed Source Disposal .............................................................. 33
1 

Background 

Given the enduring threat of terrorists seeking radioactive materials to attack the United States, 

the U.S. Government continues to participate in efforts to address radioactive source protection 

and security. The ability of terrorists to carry out such an attack has been of particular concern 

because of the widespread availability of radioactive materials in the United States and abroad 

for beneficial use by industry, hospitals, and academic institutions. The loss or theft of such 

materials could lead to their diversion for malicious use in a radiological dispersal device (RDD) 

or a radiation exposure device (RED).

The Energy Policy Act of 

2005 (Public Law 109-58) 

[EPAct 2005], hereafter called 

the EPAct, established an 

interagency task force on 

radiation source protection 

and security under the lead of 

the U.S. Nuclear Regulatory 

Commission (NRC) to 

evaluate and provide 

recommendations to the 

President and Congress 

relating to the security of 

radiation sources in the 

United States from potential 

terrorist threats, including acts 

of sabotage, theft, or use of a 

radiation source in an RDD or 

RED. The EPAct named 12 

Federal agencies to the Task 

Force and named the NRC 

Chairman (or his designee) as 

its chair. The NRC also 

invited the U.S. Department of 

Health and Human Services 

and the Office of Science and Technology Policy to participate on the Task Force. A 

representative from the Organization of Agreement States and Conference of Radiation Control 

Program Directors was also asked to participate as a nonvoting member. The EPAct mandated 

that not later than 1 year after the date of the legislative’s enactment, and not less than once 

every 4 years thereafter, the Task Force shall submit to the President and Congress a report 

providing recommendations, including possible regulatory and legislative changes, on several 

specific topics related to the protection and security of radiation sources. 

The Task Force provided its first report to the President and Congress on August 15, 2006 

(hereafter referred to as the “2006 report”) [NRC 2006c]. The Task Force concluded in the 2006 

report that there are no significant gaps in the area of radioactive source protection and security 

that are not already being addressed. However, it did identify areas that need focused 

attention. As a result, the Task Force proposed 10 recommendations that would either require a 

policy, rule, or procedural change to implement, or require additional evaluation or study before 

a final recommendation could be made. The Task Force also identified 18 actions that did not 

Members of the Task Force 

• Chairman of the Nuclear Regulatory Commission 

(Chair)

• Secretary of Homeland Security

• Secretary of Defense

• Secretary of Energy

• Secretary of Transportation

• Attorney General 

• Secretary of State

• Director of National Intelligence

• Director of the Central Intelligence Agency

• Administrator of the Federal Emergency Management 

Agency

• Director of the Federal Bureau of Investigation

• Administrator of the Environmental Protection Agency

Other Invited Agencies

• Department of Health and Human Services

• Office of Science and Technology Policy

• Organization of Agreement States and Conference of 

Radiation Control Program Directors (non-voting 

member)
2 

rise to the level of recommendations because they were underway or planned in the near term, 

but that were important to track and complete. 

Following the issuance of the 2006 report and in an effort to continue the cooperation and 

coordination among Federal and State partners, the Task Force met periodically to discuss 

topics of interest, receive updates on activities being conducted by member agencies, and 

obtain status reports on the implementation of the recommendations and the actions listed in 

the 2006 report. In addition, the Task Force formed specific subgroups to address a number of 

recommendations and actions outlined in the 2006 report, including five studies in the areas of 

public education, alternative technologies, financial assurance for disused sources, feasibility of 

phasing out cesium-137 chloride salt, and reevaluation of radionuclides and threshold levels 

warranting enhanced protection. These analyses form the basis for many of the new 

recommendations, actions, and legislative changes proposed in this report. 

The 2006 report presented the detailed background information that provides the basis for 

efforts that were established to address and resolve the issues it raised. The Task Force 

developed this 2010 report to provide an update on the progress made since the 2006 report 

and to propose new recommendations, including possible legislative and regulatory changes, in 

an effort to continue to improve the security of radioactive sources in the United States. This 

2010 report offers a concise summary of activities, accomplishments, and new 

recommendations since the 2006 report. Similar to its process for developing the 2006 report, 

the Task Force formed 10 subgroups to evaluate progress made and identify any new 

recommendations in each of the topic areas specified in the EPAct. 

This 2010 report is divided into four main topical areas: (1) coordination and communication 

improvements, (2) advances in the security and control of radioactive sources, (3) status of the 

recovery and final disposition of radioactive sources, and (4) progress in the area of alternative 

technologies. Within each of the topic areas, the “Accomplishments” section provides a detailed 

account of the key programmatic activities since 2006 and a status of the recommendations and 

actions from the 2006 report for each of the 10 topics identified in the EPAct. The “2010 

Recommendations” section within each of the topical areas provides any new 

recommendations, including proposed legislative or regulatory changes, and explains the gaps 

these changes may fill in current processes or programs. Stakeholder interactions have played 

a key role in the Task Force’s analysis and development of certain recommendations, and the 

report highlights them when applicable. Lastly, a summary table at the end of this report 

compiles the 2006 recommendations and actions and the new 2010 recommendations. As the 

summary table indicates, 13 of the 2006 recommendations and actions have been completed. 

One additional 2006 recommendation is considered an “ongoing” activity, but has been 

completed for this 4-year cycle. Also, the activities associated with another 2006 

recommendation will no longer be led by the Task Force due to a decision to transition those 

activities to another agency. Therefore, this recommendation could be considered completed 

even though the Task Force plans to follow progress made with regard to this recommendation. 

This report maintains the numbering scheme for the 2006 recommendations and actions; 

however, because this report is structurally different from the 2006 report (4 main topical areas 

rather than 10 as in the 2006 report), the 2010 recommendations employ a new numbering 

scheme. This numbering scheme is intended to be much simpler because it does not associate 

the recommendations and actions by topic areas. Also, for simplicity sake, the Task Force is 

calling all the new activities highlighted in this 2010 report “recommendations” rather than 

differentiating between “actions” and “recommendations.” The Task Force intends to continue 

to meet to implement and monitor the progress of these recommendations and actions and to 

identify any additional gaps that may arise in the years to come. 
3 

Chapter 1 

Coordination and Communication Improvements 

Government Coordination and Public Education 

Since 2006, coordination efforts among Federal agencies, State governments, and international 

partners have significantly improved in assessing security programs and making risk-significant 

radioactive sources more secure and less vulnerable to use by terrorists. A number of forums 

for enhancing communication and fostering good working relationships on radioactive source 

security issues have been established or have bolstered their efforts. The enhanced 

interagency relationships have allowed for the successful implementation of a number of 

activities. 

Accomplishments 

√ Task Force activities have been the primary vehicle for advancing issues relating to the 

domestic security of radioactive sources from potential terrorist threats. Over the past 4 

years, the Task Force has routinely met, at least twice a year, to monitor and discuss the 

progress made on the recommendations and actions presented in the 2006 report.

√ Through the U.S. Department of Homeland Security (DHS), the Nuclear Government 

Coordinating Council (NGCC) and the Nuclear Sector Coordinating Council (NSCC) 

have established three sealed source security focus groups under the auspices of the 

Critical Infrastructure Partnership Advisory Council to provide a forum for interagency 

and public-private sector interactions on sealed source security. These focus groups are 

on the topics of (1) transportation of radioactive materials, (2) tracking of radioactive 

sources, and (3) removal and disposition of disused sources.

√ The trilateral agencies (U.S. Nuclear Regulatory Commission (NRC), DHS, and the U.S. 

Department of Energy (DOE)/National Nuclear Security Administration (NNSA)) conduct 

periodic meetings with senior management to enhance coordination.

√ Several Federal agencies collaborated to develop classification guidelines for studies, 

exercises, and real-world incidents involving radiological dispersal devices (RDDs) and 

radiation exposure devices (REDs). The guidelines address RDD/RED design, 

materials used, contamination patterns, economic and other impacts, cleanup, and 

long-term recovery and provide consistent guidance across the Government on the 

classification of information about RDDs and REDs.

√ In cities and communities across the nation, U.S. Government agencies, first 

responders, law enforcement personnel, and health agencies coordinate and participate 

in various response exercises to test, evaluate, and improve their ability to investigate 

and respond to terrorist attacks, including those involving nuclear/radiological materials. 

Thousands of Federal, State, territorial, and local responders engage in these types of 

exercises as part of a robust, full-scale, simulated response to a multifaceted threat. On 

a smaller scale, exercises at selected facilities, which are cosponsored by the Federal 

Bureau of Investigation (FBI) and DOE/NNSA, provide no-fault, site-specific scenarios 

where senior managers from various Federal, State, and local organizations can practice 
4 

their crisis and consequence management skills in response to a simulated terrorist 

incident.

√ In coordination with the NRC and Agreement State regulatory bodies, FBI has initiated 

visits across the Nation to certain possessors of risk-significant radioactive sources. 

These visits establish communications and give an understanding of the current security 

arrangements and how and when law enforcement should be engaged if there was a 

threat or event at these sites.

√ Agencies have conducted public meetings and outreach efforts since 2006 on major 

topical areas addressed in this report, such as cesium chloride and the National Source 

Tracking System. 

√ The interagency Nuclear Security Subcommittee facilitates communication and 

coordination within the U.S. Government on nuclear security issues and activities being 

carried out by the International Atomic Energy Agency.

√ The Nuclear Smuggling Outreach Initiative (NSOI) and related Preventing Nuclear 

Smuggling Program (PNSP) were established to enhance international cooperation to 

combat smuggling of nuclear or highly radioactive materials. NSOI works with key 

countries around the world to develop joint action plans to enhance their capabilities to 

prevent, detect, and respond to incidents of illicit trafficking of such materials. NSOI also 

works with the international community of donors to secure and coordinate assistance to 

support implementation of the joint action plans. The PNSP focuses on increasing 

foreign governments’ capability to respond to incidents of illicit trafficking in nuclear and 

radioactive materials by ensuring that all of a country’s agencies involved follow a single 

set of well-exercised national operating procedures. The PNSP is also dedicated to 

promoting nuclear forensics, which plays a critical role in helping governments address a 

range of national security priorities (e.g., investigating and prosecuting illicit uses of 

nuclear or radioactive material) and provides a basis for international cooperation.

 

2006 Recommendation 4-1: The Task Force recommends that there be a coordinated public 

education campaign (Federal, State, and industry) to reduce fears of radioactivity, diminish the 

impact of a radiological attack if one were to occur, and provide a deterrent to attackers 

considering the use of radiological materials.

Status: Transitioned from the Task Force to the Federal Emergency Management Agency 

(FEMA).

In 2007, the Task Force formed the Public Education Subgroup to examine the issues related to 

educating the public on various radiation and RDD topics. The results of the examination were 

translated into an action plan that was endorsed by the Task Force. 

The goal of the action plan was to achieve the following objectives: increase public safety in the 

event of a radiological attack, diminish the impact of a radiological attack, and speed recovery 

after a radiological attack. After a broad review of radioactive materials, consultations with 

experts, and considerable deliberation, the subgroup formulated 10 recommendations and 

identified seven projects, listed in Table I, to carry out the public education program.
5 

Table I: Seven Projects of the Public Education Action Plan 

Project 

Number

Title

1 Assessing and Improving Public Awareness of Radiological Terrorism

2 Comprehensive Guide to Existing RDD Public Education Resources

3 Identify, Prepare Resources for, and Train Regional and Local-Level Spokespersons

4 Identify and Prepare Resources for National-Level Spokespersons

5 Prepare a Generic RDD Annex for Crisis Communication Plans

6 Engage the Public, Emergency Planners, and Responders in a Discussion of 

Radiation and Risk in the Context of the Protective Action Guides

7 Peer Review of the Products of Projects 1 through 6

In 2009, the Task Force established the interagency Public Education Steering Committee to 

oversee the implementation of these projects. Progress has been made on two of the projects. 

Project 2, which is viewed as the first step in the public education campaign, was completed in 

January 2010 with the delivery of a comprehensive compendium of existing resources suitable 

for use in a public education campaign. Project 6 has been initiated and is expected to be 

completed in October 2010. Beyond the established seven projects, the Task Force recognized 

that since the 2007 timeframe, Federal and State agencies have made progress on other 

initiatives that support public education outreach, but that are not directly related to the plan. 

Federal and State agencies have completed research, written policy and planning documents, 

established communications networks, provided outreach to responders on the DHS Protective 

Action Guides for RDD and improvised nuclear device events, and developed communications 

material and messages for use by all levels of government to prepare for and respond to a 

radiological or nuclear emergency. 

As an outcome of coordination efforts between the Task Force and FEMA, it was agreed to 

transfer all of the public education outreach initiatives to FEMA, the lead for the U.S. 

Government in public communication on issues related to radiation and other hazards. The 

Task Force’s Public Education Steering Committee disbanded upon transfer of the public 

education outreach initiatives to FEMA. Therefore, the Task Force will no longer pursue the 

projects outlined in the plan; however, FEMA will consider them as they are pursuing their own 

mission in this regard. The Task Force continues to support FEMA’s progress on this campaign 

and desires to stay apprised of developments.

2006 Recommendation 4-2: The Task Force recommends that the Federal agencies and 

States continue efforts to improve coordination and communication of their ongoing activities in 

the area of radiation protection and security for Category 1 and 2 sources.

Status: Ongoing.

As stated above in the list of accomplishments, significant improvement in interagency, State, 

and stakeholder communication and cooperation has been achieved. However, the Task Force 
6 

will continue to monitor these cooperative efforts, such as progress made by the DHS NGCC 

and NSCC sealed source security focus groups and trilateral agencies, to ensure coordination 

continues. 

2010 Recommendations

None. 
7 

Chapter 2 

Advances in the Security and Control of 

Radioactive Sources

The regulatory authority and oversight of radioactive materials in 

the United States continues to expand due to the potential use 

of these materials by terrorists and thus more focused attention 

on security and control of these materials. Several U.S. 

Government agencies have various roles regarding the security 

and control of Category 1 and 2 quantities of radioactive 

material. 

I. Reevaluation of Radioactive Source Lists

In 2007, the U.S. Department of Homeland Security (DHS) 

requested that the Task Force reevaluate the list of 

risk-significant radioactive sources and the associated threshold 

quantities that warrant enhanced security and protection 

[Chertoff 2007]. Also, in 2008, the National Academies 

recommended that “[f]or prioritizing efforts to reduce risks from 

malicious use of radiation sources, the U.S. Nuclear Regulatory 

Commission (NRC) should consider radiation sources’ potential 

to cause contamination of large areas resulting in economic and 

social disruption (area denial) to determine what, if any, 

additional security measures are needed” [NA 2008]. The Task 

Force reevaluation considered consequences of concern 

beyond prompt fatalities and deterministic effects (based on the 

Code of Conduct) to include economic, social, and 

psychological consequences, with consideration of radioactive 

materials worldwide. The reevaluation was also integrated with 

the actions of the DHS National Infrastructure Protection Plan 

(NIPP) [DHS 2009c].  The purpose of this analysis was to 

reevaluate and identify radionuclides and their associated 

quantities that pose a significant risk if used malevolently in a 

radiation exposure device (RED) or radiological dispersal device 

(RDD) attack. This analysis purposely did not evaluate whether 

additional security and protection are needed above the existing 

regulatory requirements and voluntary enhanced security and 

protection measures that are already in place or being 

implemented. 

IAEA Category 1 and 2

Radioactive Sources

The United States, along with 100

other nations, has made a political

commitment to following the

International Atomic Energy

Agency (IAEA) Code of Conduct on

the Safety and Security of

Radioactive Sources (Code of

Conduct) [IAEA 2004].  The nonlegally binding Code of Conduct

contains basic principles for the

safe and secure management of

radioactive sources throughout

their lifecycle.  It lists 26

radionuclides and identifies three

threshold activity levels for each,

referred to as Categories 1, 2, and

3.  These levels are based upon the

relative health hazards each

radionuclide would present if not

kept under adequate controls.  

Sixteen of these radionuclides are

commonly used in radioactive

sources; the other 10 are unlikely

to be used in individual sealed

sources with activity levels that

would place them within

Categories 1–3.  The Category 1

and 2 quantities of radioactive

sources listed in the Code of

Conduct are considered the most

risk significant and have been the

focus of Federal and State efforts to

place tighter controls for security.  

Unless otherwise noted, throughout

this report, the terms Category 1

and Category 2 sources refer to the

16 radionuclides listed in Table II.  

Note that the table provides the

associated Category 2 quantities

for the radionuclides.  The

Category 1 quantities are 100

times the quantities listed in the

table.   
8 

Accomplishments 

2006 Recommendation 3-1: The Task Force recommends that the U.S. Government 

periodically reevaluate the list of radioactive sources that warrant enhanced security and 

protection to assess their adequacy in light of the evolving threat environment [and consistent 

with current national consequences of concern in order to provide a consistent level of 

protection with other critical infrastructure].

Status: Ongoing; reassessed in 2009 as part of periodic reevaluations, with consideration of 

amended bracketed text. 

The Task Force’s reevaluation of the list of radioactive sources that warrant enhanced security 

and protection focused primarily on economic consequences and expanded its scope to 

address all radioactive materials worldwide. The Task Force evaluated consequences 

consistent with the NIPP Strategic Homeland Infrastructure Risk Assessment consequences 

[DHS 2008, 2009a]. Changes in the consequences of concern can affect not only protective 

strategies but also the list of radioactive materials and quantities of concern. Therefore, for 

consistency with other critical infrastructure sectors, the Task Force modified 2006 

Recommendation 3-1 to align with NIPP methodology. 

The Radiation Sources Subgroup analysis achieved three objectives: defining a significant RED 

and RDD, identifying radionuclides of greatest concern, and defining radioactive material 

quantities of concern sufficient to create a significant RDD and a significant RED. 

Significant RED and RDD Definitions: The Task Force achieved Federal concurrence on the 

definitions of a significant RED and RDD. 

These definitions of a significant RED and RDD are intended to provide the foundations for 

identifying and assessing potential hazards, determining what levels of relative risk can be 

adequately managed, and prioritizing and allocating resources to prevent and protect against 

radiological incidents. The reevaluation also supports the Federal risk-informed framework for 

the assessment of risk and management of homeland security activities, including decisions 

about when, where, and how to invest in resources that eliminate, control, or mitigate risks. 

Significant RED: An object used to maliciously expose people, equipment, and/or the 

environment to ionizing radiation, without dispersal of the radioactive material, that could 

cause debilitating injury to people exposed for a period of minutes to hours, or could be fatal 

to people exposed for a period of minutes to days. 

The definition indicates that of paramount concern is the need to protect people against 

exposure to doses that are life threatening or that could cause a permanent injury that would 

reduce the quality of life. It aligns with the Code of Conduct Categories 1 and 2.2

Significant RDD: The combination of radioactive material and the means (whether active or 

passive) to disperse that material with malicious intent, without a nuclear detonation, that 

could (1) impact national security, national economy, national public health and safety, or 

                                                           

2

 It could possibly be fatal to be close to Category 2 quantities of unshielded radioactive material for a period 

of hours to days. Larger sources could create similar exposures at longer distances and/or in shorter times. 
9 

any combination thereof or (2) require a robust, coordinated Federal response to save lives, 

minimize damage, and/or provide the basis for long-term community and economic recovery 

(which includes the cost for decontamination and environmental cleanup efforts).3

 

The definition includes impacts that could affect the national security, national economy, and 

national public health and safety. The definition also includes significant economic costs that 

could be incurred by Federal response efforts needed to save lives, as well as for 

decontamination and environmental cleanup needed to restore the community and local 

economy. The analysis considered the principal consequence of an RDD to be economic loss, 

the amount of which is primarily driven by time-consuming and costly decontamination and 

environmental cleanup efforts, which are highly dependent on the cleanup level selected. In 

responding to and recovering from radiological incidents, the Federal Government will provide 

assistance when needed, through the Robert T. Stafford Disaster Relief and Emergency 

Assistance Act [Stafford Act 2007], to support State and local efforts. The need for a robust, 

coordinated Federal response to support State and local efforts in providing for long-term 

community and economic recovery is indicative of significant economic consequences. 

With the above definitions, Federal policy makers will have a common understanding of what 

constitute nationally significant4

 consequences and the quantities of radioactive material needed 

to achieve those significant consequences from an RED or RDD attack. The definitions are to 

be used as guidance for prioritizing and allocating Federal resources in developing appropriate 

protective strategies to prevent and protect against malevolent radiological incidents. 

Radionuclides of Greatest Concern: The Task Force identified, through a five-step, 

down-selection process applied to 3,715 known nuclides, a list of 14 radionuclides of greatest 

concern for RDDs. These 14 radionuclides are commercially available to end users in 

quantities that could potentially be used in a significant RDD and are a subset of the 

radionuclides covered in the Code of Conduct. They are americium (Am)-241, californium 

(Cf)-252, curium (Cm)-244, cobalt (Co)-60, cesium (Cs)-137, iridium (Ir)-192, polonium 

(Po)-210, plutonium (Pu)-238, Pu-239, radium (Ra)-226, selenium (Se)-75, strontium (Sr)-90, 

thulium (Tm)-170, and ytterbium (Yb)-169. While Po-210 was identified through the 

down-selection process because it is commercially available to end users in quantities that 

could potentially be used in a significant RDD (i.e., greater than 0.1 Ci for alpha sources), 

Po-210 is listed below the dotted line in Table I of the Code of Conduct because it is very 

unlikely to be used in individual radioactive sources with activity levels that would place it within 

Categories 1 or 2. Therefore, Po-210 was included in Table III rather than in Table II. 

Through this analysis, the Task Force also found that seven additional radionuclides could be of 

concern in limited situations when aggregated or in bulk quantities (e.g., at major and secondary 

suppliers and manufacturers). These seven additional radionuclides are iron (Fe)-55, carbon 

(C)-14, Sr-82, iodine (I)-125, I-131, tungsten (W)-188, and gadolinium (Gd)-153. Of these 

seven, C-14, I-125, I-131, Sr-82, and W-188 are not listed in the Code of Conduct. Although 

                                                           

3

 For the purposes of this report, this means a device with sufficient radioactive materials to contaminate 

approximately 1 square kilometer (approximately 250 acres, or 0.386 square miles) of the environment to 

both the U.S. Environmental Protection Agency (EPA) and DHS/Federal Emergency Management Agency 

(FEMA) Protective Action Guides relocation guideline of 2 rem in the first year [EPA 1992; DHS/FEMA 

2008]. 4

 The use of the term “significant” is not meant to imply that any loss of life or economic damage would be 

considered “insignificant.” Nor is its use intended to prejudge whether Federal response would be provided 

in any particular event. 
10 

Po-210 may be commercially available to end users only in small quantities, it could be of 

concern in limited situations when aggregated or in bulk quantities. Therefore, Po-210 was 

included in Table III rather than in Table II. Gd-153 is listed “above the line” in Table I of the 

Code of Conduct, but was eliminated in the last step of the down-selection process because it is 

not normally available to end users in large quantities. For consistency with the Code of 

Conduct, Gd-153 and promethium (Pm)-147 were retained in Table II.

Quantities of Concern: Through the consideration of a variety of studies, the Task Force 

assessed the quantities of radioactive material (i.e., identify consequences of concern) sufficient 

to create a significant RDD and a significant RED, with consideration of social, economic, and 

psychological consequences.

The Task Force determined that a significant RED is a concern because of its deterministic 

health effects (i.e., the ability to cause death or permanent injury). For this reason, it used the 

Category 2 levels as the threshold values above which (i.e., Category 1 and 2 quantities) 

radioactive material should receive enhanced protection to reduce the likelihood of being used 

in a significant RED. 

The Task Force determined that a significant RDD is a concern because of its economic 

consequences since it has the potential to contaminate large areas of the environment and incur 

large cleanup costs. However, an RDD is unlikely to cause many prompt fatalities. The 

quantities of radioactive material sufficient to create a significant RDD are comparable to 

Category 1 and 2 quantities. The reevaluation concluded that the Category 2 threshold values 

are valid for determining the quantities of radionuclides that warrant enhanced security and 

protection to reduce the likelihood of a significant RDD. By warrants enhanced security and 

protection is meant enhanced in comparison to the security and protection applied to radioactive 

sealed sources before September 11, 2001.

In conclusion, based on the definitions, assumptions, and parameters used, the Task Force 

found that the Category 1 and 2 quantities remain valid for sealed and unsealed sources as the 

list and threshold levels of radionuclides that could result in a significant RED or RDD event and 

therefore warrant enhanced security and protection (Table II). Furthermore, because the 

reevaluation included unsealed material, the Task Force identified seven additional 

radionuclides (Table III) that may be of concern when aggregated; however, because they are 

infrequently shipped or possessed in quantities likely to cause a significant RDD event, at this 

time the Task Force proposes no recommendation about these radionuclides and enhanced 

security and protection. 
11 

Table II: Radionuclides that Warrant Enhanced Security and Protection

Radionuclide IAEA Category 2 Threshold 

(TBq) (Ci) 

Am-241 0.6 16

Am-241/Be* 0.6 16

Cf-252 0.2 5

Cm-244 0.5 14

Co-60 0.3 8

Cs-137 1.0 27

Gd-153 *** 10.0 270

Ir-192 0.8 22

Pm-147 ** 400.0 11,000

Pu-238 0.6 16

Pu-239/Be* 0.6 16

Ra-226 0.4 11

Se-75 2.0 54

Sr-90 (Y-90) 10.0 270

Tm-170 200.0 5,400

Yb-169 3.0 81

* The Code of Conduct lists Am-241/beryllium (Be) and Pu-239/Be as distinct sources. The down-selection 

 considered only the radioactive material. 

** The down-selection did not identify promethium (Pm)-147 because it is not commercially available to end 

users in quantities that could potentially be used in a significant RDD (i.e., greater than 1 curie (Ci) (0.04 

TBq) for beta/gamma sources). The reevaluation retained Pm-147 because it is included in the Code of 

Conduct.

*** Identified in the down-selection as not commercially available to end users in quantities that could potentially 

 be used in a significant RDD, but could be of concern in limited situations when aggregated or in bulk 

 quantities. 

Table III: Radionuclides that Should Be Considered for Enhanced Controls 

Radionuclide IAEA Category 2 Threshold 

(TBq) (Ci) 

Fe-55 * 8000.0 220,000 

Po-210 ** 0.6 16 

C-14 * 500.0 14,000

Sr-82 * 0.6 16

I-125 * 2.0 54

I-131 * 2.0 54

W-188 * 10.0 270

* Identified in the down-selection as not commercially available to end users in quantities that could potentially 

be used in a significant RDD. However, they are very unlikely to be used in activity levels that would place 

them within IAEA Categories 1 or 2, but could be of concern in limited situations when aggregated or in bulk 

quantities.

** The down-selection process identified Po-210 because it is commercially available to end users in quantities 

that could potentially be used in a significant RDD (i.e., greater than 0.1 Ci (0.004 TBq) for alpha sources). 

However, it is very unlikely to be used in individual radioactive sources with activity levels that would place 

them within IAEA Categories 1 or 2, but could be of concern in limited situations when aggregated or in bulk 

quantities.
12 

2010 Recommendations 

2010 Recommendation 1: The Task Force recommends that U.S. Government agencies use 

the radionuclides and the associated Category 2 threshold quantities in Table II, “Radionuclides 

that Warrant Enhanced Security and Protection” (as shown on page 11 of this report), as the 

appropriate framework for considering which sources warrant enhanced security* and that they 

adopt the definitions for a significant RED and a significant RDD (as shown on page 8 of this 

report) for prioritizing and allocating resources to eliminate, control, or mitigate risks of 

malevolent radiological incidents. * By warrants enhanced security and protection is meant 

enhanced in comparison to the security and protection applied to radioactive sealed sources 

before September 11, 2001.

II. Security Measures and Initiatives

The NRC continues to strengthen security and controls for the risk-significant radioactive 

sources. These activities are founded in and consistent with the U.S. Government’s political 

commitment to follow the Code of Conduct. In these activities, the NRC continues to coordinate 

in partnership with the Agreement States that regulate the possession and use of certain 

radioactive material pursuant to agreements between the NRC and the Governor of each State. 

The Agreement States regulate approximately 80 percent of the radioactive materials licensee 

community. Of the approximately 23,000 radioactive materials licenses in the United States, 

fewer than 10 percent (approximately 1,400 licenses) authorize possession of at least Category 

2 quantities of radioactive materials. 

Accomplishments

Security Requirements

√ Since the initial issuance of the increased controls requirements in 2005 [NRC 2005b] to 

those licensees that are authorized to possess at least Category 2 quantities of 

radioactive materials, the Agreement States and the NRC have performed nearly 1,630 

inspections. The increased controls have required licensees to upgrade their facilities 

and procedures to ensure detection and prevention of unauthorized access, advance 

coordination with local law enforcement, enhance security during transportation, and 

enhance accounting of applicable radioactive material. The increased controls also 

require licensees to establish trustworthiness and reliability standards in determining 

who should have unescorted access to the applicable radioactive material. The first 

round of inspections was completed within the original 3-year schedule, which ended in 

June 2009. The performance of the NRC and Agreement States in prioritizing and 

conducting the increased controls inspections continues to be verified through the 

routine Integrated Materials Performance Evaluation Program reviews. To date, the 

NRC and Agreement State Programs that have been evaluated have been found to be 

adequate and compatible. 

√ From 2007–2008, the increased controls were enhanced by additional requirements for 

fingerprinting and Federal Bureau of Investigation (FBI) criminal history records checks

of all individuals with unescorted access to at least Category 2 quantities of radioactive 

material [NRC 2007a] to further improve the tools available to determine trustworthiness 

and reliability. 
13 

√ The Transportation Security Administration (TSA) is proposing regulations for the 

transport worker identification credential under Title 49 of the Code of Federal 

Regulations (49 CFR) Part 1570, “General Rules,” and 49 CFR Part 1572, “Credentialing 

and Security Threat Assessments” [DHS/TSA 2006], which would apply a systemwide, 

common credential for use across all transportation modes (air, land, and water). 

√ In January 2010, the NRC issued the “Non-Manufacturing and Distribution (non-M&D) 

Service Providers Security Order” [NRC 2010a] to resolve an inequity that this small 

community of licensees had identified following the issuance of the increased controls 

requirements. The NRC issued this new order to non-M&D service provider licensees in 

order to give them an opportunity to have the same unescorted access privileges as 

those M&D licensees that have complied with the M&D order. This new order provides 

non-M&D licensees the opportunity to perform similar trustworthiness and reliability 

determinations as the M&D licensees, as stipulated in the M&D order, allowing them to 

have unescorted access privileges at clients’ facilities. 

√ The NRC and Agreement States have jointly initiated a new rulemaking for materials 

security regulatory requirements that reflects the experience gained through 

implementation of the increased controls and fingerprinting requirements. The objective 

of the proposed rule is to provide reasonable assurance of preventing the theft or 

diversion of Category 1 and 2 quantities of radioactive material for malevolent use. New 

requirements are proposed for background investigations and an access authorization 

program to ensure that individuals who have access to these materials are determined 

to be trustworthy and reliable. The proposed requirements would also establish physical 

protection systems to detect, assess, and respond to unauthorized access to at least 

Category 2 quantities of radioactive material. For transport of the radioactive materials, 

the new requirements would include recipient license verification; preplanning and 

coordination of shipments; advance notification of shipments; notification of shipment 

delays, schedule changes, and suspected loss of a shipment; and control and 

monitoring of shipments. The NRC will capture these new regulatory requirements in 

Title 10 of the Code of Federal Regulations (10 CFR) Part 37 and will supersede the 

existing requirements imposed by orders, such as the increased controls and 

fingerprinting orders. The NRC made draft regulatory text available for public review 

[NRC 2009c]. The proposed rule was submitted to the Commission on December 14, 

2009 [NRC 2009d]. On May 13, 2010, the Commission approved the proposed rule for 

publication in the Federal Register [NRC 2010d]. On July 14, 2010, the NRC published 

the draft guidance documents in the Federal Register for public comment [NRC 2010b]. 

Voluntary Security Enhancements

√ The U.S. Department of Energy (DOE) National Nuclear Security Administration (NNSA)

and DHS/Domestic Nuclear Detection Office (DNDO) (DHS/DNDO turned this effort over 

to DOE/NNSA in May 2009) initiated a new domestic security effort that further mitigates 

the potential threat of terrorists acquiring and deploying an RDD by building on the 

existing regulatory requirements and providing voluntary security enhancements. Under 

its Global Threat Reduction Initiative (GTRI) program and in cooperation with the NRC, 

DHS, and FBI, DOE/NNSA offers federally funded security upgrades based on best 

practices. When requested by a licensee, the GTRI works to assess existing security 

conditions, provide recommendations on security enhancements, and, when warranted, 

fund the procurement and installation of jointly agreed-upon security best practices, 
14 

including biometric access controls, door alarms, motion sensors, video assessment, 

remote monitoring systems, tamper-indicating seals, and area radiation monitors. These 

voluntary security enhancements complement and do not replace the NRC’s increased 

controls requirements. These voluntary security enhancements are sound and provide 

best practices that further improve security above regulatory requirements. As of May 

2010, the GTRI has completed voluntary security enhancements at 127 buildings 

containing radioactive materials. 

√ DOE/NNSA offers specialized training for local law enforcement so they can better 

protect themselves and their communities when responding to alarms at facilities with 

radioactive materials. As of May 2010, the program has conducted 15 courses with 523 

students for 50 licensees and their immediate off-site responders. 

√ DOE/NNSA partnered with the FBI and coordinated with the NRC and Agreement States 

to host table-top exercises at selected facilities. The purpose was to provide no-fault, 

site-specific scenarios where senior managers from various Federal, State, and local 

organizations could practice their crisis and consequence management skills in 

response to a simulated terrorist incident. As of May 2010, 8 table-top exercises have 

been completed. 

√ DOE/NNSA and DHS/DNDO worked with the principal manufacturers of cesium chloride 

(CsCl) irradiators to develop specialized in-device delay (IDD) hardening kits for the 

most widely used models of CsCl blood and research irradiators. The IDD kits make it 

more difficult for an adversary to illicitly access and steal the radiological source. The 

GTRI funds CsCl irradiator manufacturers to provide these hardening kits in coordination 

with the GTRI domestic security effort. As of May 2010, GTRI-funded CsCl IDD kits 

have been installed on 167 of the 834 devices within the scope of the initiative. 

√ The NRC and Agreement States approved revisions to the Sealed Source and Device 

Registrations that permit installation of hardening at the point of fabrication. The 

manufacturers voluntarily committed to distribute new units in such hardened 

configuration beginning in the fall of 2009. 

√ DOE/NNSA, under its GTRI Well-Logging Security Initiative, has partnered with the 

oilfield services industry to provide specific guidelines (“Best Practices”), “Security and 

Control of High-Activity Well Logging Sources Guidelines” [DOE, et al. 2008c], to 

enhance the security of well-logging devices, including deterrence, detection, delay, 

assessment, and response. The guidelines focus on sources stored at base camps, 

during transportation and in use at drill sites. A number of industry partners have 

voluntarily agreed to enhance the security of their well-logging sources to meet the 

recommendations in the guidelines and allow occasional visits by GTRI staff to review 

progress toward meeting the guidelines’ recommendations. 

2006 Action 3-1: The NRC should evaluate the need to reissue the Orders to the 

Manufacturing and Distribution Licensees to make sure no security issues have been introduced 

from the use of different units of radioactivity.

Status: Complete.
15 

In October 2006, the NRC issued “Order Imposing Fingerprinting and Criminal History Check 

Requirements for Unescorted Access to Certain Radioactive Materials, and Modification of the 

Order Imposing Additional Security Measures to Manufacturing and Distribution Licensees” 

[NRC 2006b]. This order amended/updated some of the security measures imposed by a 

previous order to reflect that the primary values used for compliance with the security 

requirements are in terabecquerels to make sure no security issues have been introduced from 

the use of different units of radioactivity. 

2006 Action 6-1: The NRC should expeditiously complete its implementation of the 

fingerprinting provisions of the EPAct for those applicants for and licensees with Category 1 and 

2 quantities of radioactive material. The NRC should place a high priority on completing the 

EPAct Section 652 rulemaking. As part of the rulemaking, the NRC should require fingerprinting 

for any individual who could have access to Category 2 or above quantities of radioactive 

materials. The NRC should also require periodic reinvestigations of such persons.

Status: Ongoing. 

The NRC has implemented its new fingerprinting authority provided by the Energy Policy Act of 

2005 (EPAct) through the issuance of orders requiring fingerprinting and FBI criminal history 

records checks for access to Safeguards Information (SGI) and unescorted access to at least 

Category 2 quantities of radioactive materials for M&D licensees, large panoramic and 

underwater irradiators, and licensees transporting Category 1 quantities of radioactive material. 

The NRC and Agreement States issued requirements to other licensees requiring fingerprinting 

and criminal history records check for unescorted access to radioactive materials in quantities of 

concern. The NRC has completed revisions to 10 CFR 73.21, “Protection of Safeguards 

Information: Performance Requirements” [NRC 2008d] for access to SGI by a broad class of 

individuals as mandated by EPAct Section 652(B)(ii) which requires that no person may have 

access to SGI unless (1) there is “need to know,” (2) the applicant has undergone an FBI 

criminal history check, and (3) the licensee has established the person’s trustworthiness and 

reliability based on a background investigation of work history, education history, references, 

and credit history. 

The NRC is in the process of completing the implementation of EPAct Section 652(B)(i)(II) 

through the proposed 10 CFR Part 37 rulemaking. This rule will establish the requirements for 

fingerprinting of individuals permitted unescorted access to radioactive material or other 

property that the NRC determines to be of such significance to public health and safety or the 

common defense and security as to warrant fingerprinting and background checks. In addition, 

the rule will incorporate a reinvestigation provision as part of the background investigation 

requirements. The finalization of this rulemaking, anticipated by 2013, will complete this action. 

In implementing the EPAct’s fingerprinting provisions for unescorted access to radioactive 

materials, the NRC developed procedures to implement a program in which a licensee 

designates an individual (a reviewing officer) who is responsible for reviewing the 

trustworthiness and reliability information (which includes the FBI criminal history records 

checks) to grant unescorted access to other licensee employees. In some cases, such as for 

human resources personnel, this reviewing officer does not require, or is not permitted, 

unescorted access as part of his or her job duties. As a result, the NRC’s fingerprinting 

authority, as granted by the EPAct, does not extend to these reviewing officers. The importance 

to security of the positions filled by these reviewing officers makes it logical to give the NRC the 

legal authority to make them subject to fingerprinting requirements and the FBI criminal history 

records check. A proposed legislative amendment was submitted to Congress by letter from the 
16 

NRC in June 2008 to authorize the NRC to require such individuals to submit to fingerprinting 

requirements such as those applicable to individuals who have unescorted access to radioactive 

material or access to SGI [Klein, 2008]. This legislative proposal was not enacted; however, as 

noted in the Commission direction in SRM-SECY-09-0181 [NRC 2010d], the proposed 10 CFR 

Part 37 rulemaking is to include the Commission’s requested statutory changes to the Atomic 

Energy Act of 1954 [AEA 1954] that would permit fingerprints of reviewing officials without 

unescorted access to radioactive material or to SGI.

2006 Action 6-2: The NRC should evaluate the feasibility of establishing a national database 

for materials licensees that would contain information on pending applications and information 

on individuals cleared for unescorted access.

Status: Ongoing. 

The NRC has initiated a two-part analysis to evaluate the recommendation of a national 

database. The first part involves reviewing the current program and obtaining all related 

methods and tools for tracking personnel access status for applicants or licensees that may 

possess Category 1 and 2 materials, then establishing the current proposed process/system as 

the standard. The second part of the analysis will involve looking forward to recommend 

improvements to the standard and anticipating how such a proposal would contribute to 

deploying a system that is more robust, efficient, and inclusive for all licensees, Agreement 

States, and Federal entities to have access to such a database. Currently, the NRC is 

developing the Web-Based Licensing (WBL) system for the regulatory oversight of the licensing 

life cycle that includes applications, issuances, amendments, and terminations. This system 

may fulfill part of 2006 Action 6-2 by evaluating the feasibility of being able to provide licensees 

with information on pending applications. While completing this action, the NRC is in the 

process of evaluating current systems under development, like the WBL. 

2006 Action 6-3: The NRC and DHS should enter into a memorandum of understanding to 

cover access to the SAVE database for materials licensees.

Status: Complete. 

DHS administers the Systematic Alien Verification for Entitlements (SAVE) Web-based 

computer program [DHS 2009b]. The DHS SAVE program has two databases. One is the 

Basic Pilot Program, which verifies the identity of citizens and noncitizens. Users can query 

Social Security Administration and DHS databases by using an automated system to verify the 

employment authorization of all newly hired employees. Participation in the Basic Pilot Program 

is voluntary and free to participating employers. 

DHS requires a memorandum of understanding (MOU) to access the Verification Information 

System portion of the SAVE program. The NRC executed a SAVE-related MOU with DHS in 

August 2003. The MOU established the terms and conditions for the participation of the NRC 

power reactor licensees in the SAVE program for verifying the immigration status of alien 

applicants for unescorted access to NRC-licensed reactor facilities. In 2008, the agencies 

revised the MOU to also provide NRC materials licensees with a vehicle to access the SAVE 

database. Agreement States may also implement MOUs with DHS to access the Verification 

Information System portion of the SAVE program for their materials licensees. However, this 

database does not provide materials licensees the more in-depth background check information 
17 

needed on individuals for trustworthiness and reliability determinations in accordance with 

current security requirements, such as the increased controls. 

2010 Recommendations 

2010 Recommendation 2: The Task Force recommends that the U.S. Government agencies 

should reevaluate their protection and mitigation strategies to protect against significant RED or 

RDD attack using both potential severe immediate or short-term exposure and contamination 

consequences to public health, safety, and the environment as the consequences of concern. 

Agencies should use the Task Force-endorsed definitions, radionuclides, and thresholds for a 

significant RED and RDD and the associated assumptions and parameters as common 

guidance in the assessment of risk and management of homeland security activities.

The Task Force completed an assessment developed in response to 2006 Recommendation 

3-1 and described in Section I of this chapter. The assessment identified radionuclides and 

quantities that pose a significant risk if used malevolently in an RED or RDD attack based upon 

deterministic health effects and economic consequences. The new focus of the reevaluation 

was on economic consequences, consistent with the NIPP framework that assesses risk as a 

function of consequences, vulnerability, and threat. The economic consequences of an RDD 

are primarily driven by the costs to clean up the contaminated area. The Task Force did not 

evaluate whether additional security and protection are needed to protect against contamination 

and resultant economic consequences. It is now proposed that U.S. Government agencies 

should reevaluate their current strategies for protecting against a significant RED or RDD attack 

to also consider economic consequences (or economic losses).

III. Improvements to the Licensing Process

In December 2006, through the collaborative efforts of the NRC and Agreement States, the 

NRC issued final pre-licensing guidance for the possession of radioactive materials. However, 

in early 2007, the U.S. Government Accountability Office (GAO) completed a covert operation, 

wherein GAO posed as a legitimate company and applied for and received a NRC materials 

license using falsified information. GAO then altered the possession limits on the license using 

commercially available software and placed an “intent to purchase” order for moisture density 

gauges containing Cs-137 and Am-241, totaling 2.7 Ci (0.01 TBq) (Category 3 in aggregate) 

from two portable gauge distributors. Although the purchases were not actually made, GAO 

attorneys were satisfied that the transactions could have been completed. Concurrently, GAO 

attempted to obtain a similar license from an Agreement State, but withdrew the application 

request after the State expressed intent to perform a prelicense visit as part of its licensing 

protocol. 

Following this event as well as other assessments identifying vulnerabilities in the NRC’s 

licensing of the possession and use of radioactive material, the NRC took immediate steps to 

address these vulnerabilities. These steps included the NRC immediately suspending its 

licensing program until additional measures could be put in place to ensure the validity of 

requests from new applicants to possess radioactive materials and performing a retroactive 

review of all licenses issued in the previous 18 months to ensure the validity of the requests.

In a July 2007 testimony [GAO 2007], GAO made three recommendations for the NRC to 

improve its radioactive materials licensing process: (1) improved pre-licensing guidance, 

including consideration of mandatory site visits for new applicants, (2) periodic oversight of 
18 

license application reviewers, and (3) improved measures to prevent license counterfeiting. In 

conjunction with the hearing, the Permanent Subcommittee on Investigations identified four 

additional recommendations to improve the NRC’s materials program. The recommendations 

called for NRC to: (1) reexamine its apparent “good-faith” presumption, which assumes that 

applicants do not harbor malicious motives, in the licensing process; (2) physically inspect 

applicants’ facilities before issuing licenses for Category 3 radioactive sources; (3) consider 

including Category 3 sources in the proposed National Source Tracking System (NSTS); and (4) 

quickly establish the planned WBL system.  Based on the results of this event and these 

assessments, NRC took the actions described below. 

Accomplishments 

√ The NRC developed a comprehensive action plan to address needed changes in the 

process for issuing licenses for radioactive sources. The action plan was transmitted to 

the Commission on August 25, 2007 [NRC 2007b], and the Commission approved the 

action plan, with comments, on September 18, 2007 [NRC 2007c]. The NRC 

established three groups to assist in implementing the action plan and developing 

additional recommendations for improving the materials regulatory infrastructure. These 

groups are the Prelicensing Guidance Working Group, the Independent External Review 

Panel (IERP), and the Materials Program Working Group (MPWG). The action plan 

addresses the recommendations listed above and one recommendation that call for an 

external panel of experts (the IERP) to perform a comprehensive review of the NRC’s 

licensing program. 

√ In March 2008, the IERP made eight recommendations centered around three key 

themes: (1) suspension of the good-faith presumption, (2) elevation of the security 

program to be equal to the materials program in regard to health, safety, and the 

environment, and (3) development of an electronic means of license verification for use 

by the NRC, Agreement States, and licensees [NRC 2008c]. 

√ In September 2008, the Prelicensing Guidance Working Group revised existing 2006

prelicensing guidance [NRC 2006a] to require site visits for all “unknown” applicants and 

for all requests for authorization to possess Category 2 and above quantities of material. 

The guidance also calls for investigations into the legitimacy of all applicants through 

readily available means, such as Internet searches and business listings. This guidance 

was intended to determine the legitimacy of applicants and uses. 

√ In October 2008, the MPWG identified strategies to mitigate security vulnerabilities and 

evaluated the efforts of the IERP.

√ The NRC initiated the development of an Integrated Source Management Program that 

will include information on all NRC and Agreement State licensees and more than

70,000 risk-significant radioactive sources (not managed by DOE) possessed by 

approximately 1,400 licensees. Integrating the three systems (the NSTS, WBL system, 

and License Verification System (LVS)) will provide the following benefits: 

• It will make national radioactive source authorization, possession, and transaction 

information available to other government agencies with a role in the protection of 

the Nation from nuclear and radiological threats. 
19 

• It will provide licensees with the secure automated means to verify license 

information and possession authorization before initiating radioactive material 

transfers.

• It will enable users to monitor the location, possession, transfer, and disposal of their 

applicable risk-significant radioactive sources throughout the country.

• It will improve source accountability and give better information to decisionmakers, 

and it will detect and alert regulators to tracking discrepancies.

• It will modernize NRC licensing and inspection management systems. 

√ As an integral part of the action plan, the NRC initiated the General License Rulemaking 

to reduce the chances for aggregation of generally licensed material into risk-significant 

quantities. The proposed rule (74 FR 38372, August 3, 2009) calls for limiting the 

quantity of radioactive material allowed in a generally licensed device [NRC 2009a].

2006 Action 4-1: The NRC should consider imposing additional measures to verify the validity 

of licenses, before transfer of risk-significant radioactive sources, on all licensees authorized to 

possess Category 1 and 2 quantities of radioactive material.

Status: Ongoing. 

The NRC is committed to implementing the recommendations and strategies of the IERP and 

MPWG, as described above, in a manner that maintains a balance between enabling the safe 

use of radioactive material and a risk-informed, graded approach to establish appropriate 

controls for the possession of radioactive material. With the completion of the activities 

indicated in the action plan milestones, the NRC will accomplish its goal in addressing the 

vulnerabilities identified in its radioactive materials program. 

2010 Recommendations 

None. 

IV. Tracking of Sources

Since 2004, the NRC has maintained an interim inventory of nationally tracked radioactive 

sources, which was an annual accounting of licensees’ Category 1 and 2 sources. The EPAct 

required establishment of the NSTS, which supersedes the interim inventory. This computer 

system tracks the possession and transfers of risk-significant radioactive sources over the life 

cycle of the sources. The system improves the ability of regulators to detect and act upon 

inventory discrepancies, respond to emergencies, and verify legitimate import, export, 

ownership, and use of sources. The NSTS was deployed for licensee and regulator use in 

January 2009. The deployment of the NSTS is a major accomplishment in ensuring a greater 

accountability for risk-significant sources. The NRC’s regulation in 10 CFR Part 20.2207, 

“Reports of Transactions Involving Nationally Tracked Sources,” requires licensees to do the 

following: 
20 

• Have reported the licensee’s initial inventories of Category 1 and Category 2 sources, 

as defined in Appendix E, “Nationally Tracked Source Thresholds,” to 10 CFR Part 20, 

“Standards for Protection against Radiation,” by January 31, 2009.

• Have begun reporting all related transactions (manufacture, transfer, receipt, 

disassembly, or disposal of sources of interest) to the NSTS by January 31, 2009.

• Verify (on an annual basis) the records in the NSTS and reconcile that information 

with the licensees’ records.

Accomplishments 

√ Approximately 1,400 licensees reported their initial inventories. On average, the system 

processes 150 transaction reports daily.

√ The NRC has done extensive outreach with Agreement States and licensees to ensure 

adherence to reporting requirements. Outreach included speaking at industry meetings, 

holding NSTS training sessions and workshops, launching an NSTS Web site and a blog 

for communications and feedback, and setting up a help desk to address user questions 

about reporting to the NSTS. 

√ DOE established a policy in February 2008 for the reporting of certain radioactive sealed 

source information to a centralized system, the DOE Radiological Source Registry and 

Tracking (RSRT) system. This new DOE policy supports the U.S. policy to work toward 

implementing the Code of Conduct and the development and implementation of the 

NSTS. DOE Notice 234.1, “Reporting of Radioactive Sealed Sources,” (expired but 

extended by DOE Notice 251.76) assigns roles and responsibilities for the reporting of 

radioactive sealed sources that are in the custody or possession of DOE, and 

establishes requirements for the inventory and transaction reporting of certain 

radioactive sealed sources to the RSRT with data verification [DOE 2008a]. DOE Notice 

234.1 (expired but extended by DOE Notice 251.76) also establishes DOE agency 

responsibilities for inventory and transaction reporting of certain radioactive sealed 

sources to the NSTS. DOE transaction reporting to the RSRT commenced in 2009. 

2006 Action 11-1: The Task Force encourages the NSTS Interagency Coordinating Committee 

to develop a procedure/policy with guidelines on how to handle both Government and 

non-Government requests for information in the NSTS. 

Status: Complete. 

A procedure for handling the Government and non-Government requests for NSTS information 

was developed. The NSTS Interagency Coordinating Committee was inactivated following 

deployment of the NSTS.

Given the sensitive nature of the information contained in the NSTS, the system is categorized 

at the highest level of information security according to U.S. Government guidelines for civilian 

information technology systems (as a Level 4 system according to the National Institute of 

Standards and Technology security categorization). Data is only provided to those persons who 

have established that they have a need to know and can protect the information. Guidelines 

were created for providing information to licensing agencies (for their licensees) and to 

licensees for their own data in the NSTS. The NRC processes requests from a licensee or a 
21 

member of the public for data for another licensee as a request under the Freedom of 

Information Act. For requests from other Government agencies, the NRC will provide the 

appropriate data on a need-to-know basis. 

 

2006 Action 11-2: The NRC should consider programming the NSTS to provide automatic 

daily information to [U.S.] Customs [and Border Patrol] on import/export shipment notifications.

Status: Completion expected in 2011. 

Because of the large number of system requirements, the NRC separated NSTS development 

into two software versions. NSTS Version 1 was deployed for use in January 2009. This 

version has the basic functionality for licensees to report transactions involving source 

manufacture, import, export, transfer, and receipt. In addition, licensees can update information 

on the source, including changing the location of use. Regulators can verify pending records, 

such as locations of use, license information, and make and model information. Reporting 

capability is limited; regulators have the ability to view and report inventory for their licensees. 

NSTS Version 2, which is currently in development and planned for deployment in 2011, will 

include import/export consents and notifications, event-triggered alerts, extended licensee 

functions, automated system interfaces, full reporting and query capabilities, and the ability to 

download data for other Federal agencies. Before deployment of Version 2, the NRC will work 

with DHS/U.S. Customs and Border Patrol to ensure their objectives and needs are achieved. 

As the NRC develops the WBL system and the LVS, the NRC plans to also include input from 

U.S. Customs and Border Patrol about its needs for accessing licensing information at a 

national level. 

2006 Action 11-3: The Task Force suggests that a comprehensive analysis be conducted on 

the inclusion of Category 3 sources in the NSTS.

Status: Complete. 

In 2008, the NRC proposed [NRC 2008b] to amend its regulations (10 CFR Part 20 and 10 CFR 

Part 32, “Specific Domestic Licenses to Manufacture or Transfer Certain Items Containing 

Byproduct Material”) to expand the NSTS to include additional licensees that possess sealed 

sources containing greater than or equal to one-tenth of Category 3 radioactive sources. This 

rulemaking effort, which included the development of a draft final rule, contained a 

comprehensive analysis of inclusion of Category 3 sources into the NSTS. Numerous public 

comments, including comments from the Agreement States, were received on the draft rule. A 

large number of comments objected to the expansion of the NSTS to include even Category 3 

material. The main reason expressed in the comments for this objection was that this decision 

was premature since the NSTS had not yet been implemented and experience was needed on 

operation of this system before deciding to expand the system to include sources other than 

Category 1 and 2 sources. Another view expressed by the commenters was the inclusion of 

Category 3 sources would more than double the number of sources in the system and could 

deflect attention from the Category 1 and 2 sources. After consideration of the public comments 

and deliberation, the Commission did not proceed with issuance of the final rule to expand the 

NSTS. The findings from the analysis appear on the NSTS public Web site: 

http://www.nrc.gov/security/byproduct/nsts/nsts-expansion.html [NRC 2009b]. Although the 

NSTS is currently functional, significant changes are being developed to the system. As the 
22 

NSTS continues to operate and users gain more experience with the system, the NRC will 

assess the scope and functioning of the NSTS on an ongoing basis. 

2010 Recommendations 

None. 

V. Transportation Security

Since 2006, a number of initiatives have been completed or are well underway to improve the 

transport security of radioactive sources. 

Accomplishments 

√ In June 2008, TSA provided motor carriers and shippers with voluntary security 

measures pertaining to highway transportation of specific hazardous materials defined 

as highway security-sensitive materials, including Category 1 and 2 materials, and 

highway route controlled quantities as defined in 49 CFR 173.403, “Definitions”

[DHS/TSA 2010].

√ In response to two industry petitions from the Council on Safe Transportation of 

Hazardous Articles and the American Trucking Associations for rulemaking, the U.S. 

Department of Transportation’s Pipeline and Hazardous Materials Safety Administration 

(PHMSA) initiated a project to reconsider and refine the list of hazardous materials for 

which security plans are currently required. The industry petitioners asked PHMSA to 

amend the security plan regulations (HM-232F, 73 FR 52558; September 9, 2008) to 

create a distinction between hazardous materials that “present a significant security risk 

while in transportation and the vast majority of hazardous materials that pose no 

significant security risk in transportation.” On September 9, 2008, PHMSA published a 

notice of proposed rulemaking [DOT/PHMSA 2008b] suggesting revisions to the list of 

materials for which security plans are required.

√ In November 2008, PHMSA, in collaboration with the Federal Railroad Administration 

and TSA, published a final rule [DOT/PHMSA 2008a] adopting provisions to enhance the 

safety and security of rail shipments of certain high-risk hazardous materials (HM-232E, 

73 FR 72181; November 26, 2008).

 

√ In November 2008, TSA published a final rule [DHS/TSA 2008] affecting freight rail 

shippers, receivers, and carriers of rail security-sensitive materials that include a rail car 

containing a highway route controlled quantity of a Class 7 (radioactive) material. The 

rule requires freight rail carriers and certain facilities handling rail security-sensitive 

materials to designate a rail security coordinator, report tank car location and shipping 

information to TSA upon request, report significant security concerns, and implement 

custody and control requirements in transit and at the shipping and receiving facilities. 

TSA considered Category 1 and 2 thresholds, but found them not to be the amount of 

radioactive material typically transported via the rail transportation system. Because of 

the higher quantities of radioactive material transported via rail per typical shipment, the 

more applicable highway route controlled quantities of Class (7) of radioactive materials 

were used as thresholds in the rulemaking. 
23 

Further, the existing hazardous materials transportation regulations required a notation 

on the shipping document that a shipment met the threshold for highway route controlled 

quantity, thus providing the rail carrier with a positive way to identify shipments that 

require special handling as a “rail security-sensitive material." 

2006 Action 3-2: The Department of Transportation (DOT) should examine the use of the 

Code of Conduct Category 1 and 2 thresholds in domestic transportation regulations.

Status: Complete. 

In September 2006, DOT published an advance notice of proposed rulemaking [DOT/PHMSA 

2006] seeking public comment on its security plan requirements. On November 30, 2006, DOT 

hosted a public meeting to invite further comments and information concerning the types and 

quantities of materials that should be covered by the security plan rule. In September 2008, 

DOT issued a notice of proposed rulemaking [DOT/PHMSA 2008b] to modify its current security 

plan requirements governing the commercial transportation of hazardous materials by air, rail, 

vessel, and highway. For radioactive material, the notice proposed adoption of the security 

thresholds recommended by the Code of Conduct and contained in the Nuclear Security Series 

Guide, ‘‘Security in the Transport of Radioactive Material” [IAEA, 2008]. DOT, in consultation 

with TSA, developed a final rule to revise the list of materials subject to security planning. DOT 

published this final rule [DOT/PHMSA 2010] in March 2010. 

2006 Recommendation 5-1: The Task Force recommends development of a Transport 

Security Memorandum of Understanding to serve as the foundation for cooperation in the 

establishment of a comprehensive and consistent transport security program for risk-significant 

sources.

Status: Completion expected in 2010. 

The purpose of this memorandum is to delineate clear lines of authority and responsibility and 

promote communications, efficiency, and non-duplication of effort through cooperation and 

collaboration between the parties in the area of transportation security based on existing legal 

authorities and core competencies. The MOU has program elements that consist of: 1) risk 

assessments, 2) strategic planning, 3) standards, regulations, guidelines, advisories, orders, 

and directives, 4) technical support, 5) sharing information during emergency response, 

6) legislative matters, 7) budget, 8) communications, 9) intelligence and information sharing, 

10) background investigations, 11) research and development, and 12) coordination meetings. 

DHS, DOT, and the NRC expect to sign the MOU before December 31, 2010. 

2006 Recommendation 5-2: The Task Force recommends that the U.S. Government evaluate 

the feasibility of using new and existing technologies to detect and discourage the theft of 

risk-significant radioactive material during transport. The evaluation should include the findings 

of operational testing of existing technologies offering enhanced security of motor carrier 

shipments of hazardous material; shipment tracking, including communication systems; 

radio-frequency identification; vehicle disabling technologies; and mobile and stationary 

radiation detection systems.

Status: Ongoing. 
24 

At DOE/NNSA, the GTRI and the Office of Nonproliferation Research and Development have 

established a transportation security test bed to evaluate the reliability, accuracy, and 

compatibility/interoperability of commercially available technologies. DOE established the test 

bed because experience with three GTRI pilot shipments highlighted problems with 

commercially available systems. Transportation security systems and components that provide 

enhanced tracking (truck, trailer, and package), communication, intrusion detection, and 

package condition (intact or not) are being evaluated for deployment on GTRI and commercial 

shipments to demonstrate their capabilities to commercial shippers and carriers. In the interim, 

the GTRI/Offsite Source Recovery Project has taken steps to voluntarily increase the security of 

its source recovery shipments beyond those required by regulation, such as a dedicated truck, 

near-real-time tracking, redundant communications, “run-flat” tires, secure transportation 

overpacks, and a driver duress button. 

In July 2008, the Nuclear Sector Coordinating Council (NSCC) requested participants in a 

Sealed Source Security Workshop to prioritize and identify areas on which to focus the energy 

and resources of the Radioisotopes Subcouncil. In September 2008, the Workshop identified 

the transportation of sealed sources as one of three priority concerns. 

In December 2008, the Nuclear Government Coordinating Council (NGCC) and NSCC, working 

under the auspices of the Critical Infrastructure Partnership Advisory Council framework, 

endorsed the creation of focus groups to coordinate research and report findings back to the 

NGCC and NSCC for further action, as appropriate. The objective of the Tracking of 

Radioactive Sources Focus Group, which includes members from both government and 

industry, is to assess various existing technologies that may be employed to track radioactive 

sources. The NGCC and NSCC also established the Removal and Disposition of Disused 

Sources and the Transportation of Radioactive Materials Focus Groups, which include 

representatives from across the radioactive sealed-source stakeholder community, including 

manufacturers, distributors, users, regulators, and other Federal, State, and local officials.

The Tracking of Radioactive Sources Focus Group’s findings will be used to establish a 

common understanding of the relevant issues and capabilities, so as to facilitate further 

partnership among Federal, State, local, and private-sector stakeholders in the development 

and ultimate deployment, if appropriate, of practical, effective technologies to track radioactive 

sources during transport. Focus group members are presently developing a paper describing 

the pros, cons, and costs of relevant technologies that may be used for tracking conveyances, 

packages, or individual radioactive sources. 

2006 Recommendation 5-3: The Task Force recommends that the U.S. Government 

immediately develop a strategy and take actions to address the security of international 

shipments of Category 1 and 2 radioactive sources that transit or are transshipped through the 

land territory of the United States.

Status: Ongoing. 

As described in the 2006 report several Federal agencies have regulatory jurisdiction for 

transportation security of transshipments, including the NRC, U.S. Customs and Border 

Protection, DOT, TSA, the U.S. Coast Guard, and the U.S. Department of State. The 

Transshipment Transit Security Working Group was formed to evaluate this specific area and to 

develop a U.S. position that can be used in international negotiations. 
25 

In December 2008, the NGCC and NSCC established the Transportation of Radioactive 

Materials Focus Group with the following objectives: 

• Develop a clear, concise, single message on the potential national security concerns 

associated with the transportation of Category 1 and 2 sources. 

• Identify the relevant regulatory authorities and associated security regulations integral to 

the transportation of Category 1 and 2 sources. 

• Reconcile and analyze, as appropriate, overlaps, gaps, and potentially inconsistent 

Federal transportation security regulations. 

• Develop a clear, concise, single message on the potential national security concerns 

associated with the transshipment of Category 1 and 2 sources. 

• Define the term “transshipment” and identify the relevant regulatory authorities and 

respective security regulations applicable to the transshipment of Category 1 and 2 

sources. 

The Transportation of Radioactive Materials Focus Group began meeting in February 2009 to 

develop a paper on all current transportation security regulations that the Nuclear Sector can 

use to inform stakeholders. The focus group is developing a commonly accepted definition of 

transit and transshipment and assessing the adjustments that may be warranted in Federal 

approaches to shipments of radioactive sources transiting or undergoing transshipment through 

the United States. The definitions of transit and transshipment have been established and the 

group has agreed on draft criteria to facilitate the analysis of overlaps, gaps, and potentially 

inconsistent Federal transportation security regulations between the various Federal agencies. 

In addition, the focus group has enabled the development of a MOU among the NRC, DOT, and 

TSA on roles and responsibilities in the regulation of radioactive materials transport. 

2006 Action 5-1: The Transportation Security Subgroup should review the findings and 

conclusions of all research conducted on securing “high hazard” hazardous materials transport 

to determine if any of the measures should be applied to transport of risk-significant radioactive 

sources.

Status: Ongoing. 

Learning from the results of the DOT Federal Motor Carrier Safety Administration's (FMCSA) 

Hazardous Materials Safety and Security Field Operational Test 

(http://www.fmcsa.dot.gov/safety-security/hazmat/fot/index.htm) [DOT/FMCSA 2010] and a 

series of DOE/NNSA security technology evaluation shipments, DOE/NNSA established the 

transportation security technologies test bed in 2009 at Oak Ridge National Laboratory. Also in 

2009, DHS sponsored a demonstration of developing container tracking technologies at Sandia 

National Laboratories. As existing and emerging technologies are assessed, the Transportation 

Security Subgroup will consider measures needed to implement them as Federal requirements 

as appropriate. 
26 

2006 Action 5-2: DOT should evaluate the best practices from the high-threat urban area 

corridor assessments to determine whether it should incorporate any of the best practices into 

the requirements for security plans for high-risk radioactive material. DOT should also evaluate 

whether transport of lower risk radioactive material warrants a security plan or whether the 

transport could be exempted from some of the requirements.

Status: Complete.

DOT and TSA have completed their assessment of the vulnerabilities of transporting hazardous 

materials in high-threat urban areas. These assessments resulted in railroad companies 

voluntarily agreeing to implement 27 action items designed to improve the security of rail 

movements of hazardous materials in these areas. The action items address system security 

and access control as well as en-route security. 

2010 Recommendations 

None. 

VI. Import and Export Controls

Since the 2006 report, the U.S. Government has continued to work actively to fulfill its G-8 

Summit commitment and its political commitment to the IAEA Director General to act in 

accordance with the IAEA “Guidance on the Import and Export of Radioactive Sources” 

(Import/Export Guidance), issued March 2005 [IAEA 2005]. The U.S. Government was 

instrumental in developing this guidance, which represents the first international export control 

framework for radioactive sources, and in promoting its adoption. Successful implementation of 

the Import/Export Guidance has received considerable attention internationally because it 

provides the basis for improving the security of cross-border transfers of sources and preventing 

diversion, by means other than theft, of materials potentially usable in an RDD. 

Accomplishments 

√ As of 2010, 58 nations have made a political commitment to act in accordance with the 

Import/Export Guidance, up from 20 nations in 2006. 

√ Several large international meetings convened with a focus on the Import/Export 

Guidance and on harmonizing the implementation of export controls. The United States

convened an ad hoc meeting of the major supplier countries to consider what actions 

suppliers could take to further strengthen the international export control framework. 

√ IAEA General Conference resolutions included provisions that urged countries to

implement the Import/Export Guidance, discouraged the export of sources as a means 

of disposal, and pressed countries to address obstacles to the return of disused sources 

to the supplier country. 

√ The NRC incorporated the Import/Export Guidance through a rulemaking [NRC 2005a], 

that became effective in 2005. Likewise, DOE issued an order [DOE 2008b] in 

November 2008 that is consistent with relevant guidance contained in the Code of 
27 

Conduct and Import/Export Guidance and outlines responsibilities and procedures for 

DOE elements and contractors conducting imports and exports of radioactive sources. 

√ The U.S. Government has been instrumental in helping to develop and encourage the 

use of universal forms to streamline communication between importing and exporting 

countries.

√ In 2006, a U.S. interagency group established a process to assess whether a proposed 

export of Category 1 or 2 radioactive sources to a particular country will be inimical to 

the common defense and security. 

√ The NRC issued a final rule in the summer of 2010 that eliminates specific licenses for 

the import of Category 1 and 2 radioactive sources (specific licenses are still required for 

exports), in light of enhancements made to the NRC’s domestic regulatory framework. 

√ The NRC established a memorandum of cooperation with the Canadian Nuclear Safety 

Commission and with the National Nuclear Energy Commission of Brazil for the import 

and export of radioactive sources. The NRC engaged with a number of other countries 

to develop similar approaches to carrying out export controls. 

√ The NRC launched the NSTS in January 2009, to improve the tracking of sources that 

are imported into or exported from the United States. 

2006 Action 10-1: The U.S. Government should continue the efforts to promote international 

harmonization of import and export controls for Category 1 and 2 radioactive sources.

Status: Ongoing. 

As mentioned above, since 2006 the U.S. Government has made significant strides in 

promoting the establishment of an international export control regime for radioactive sources 

consistent with the Import/Export Guidance. The implementation and harmonization of this 

global framework is a major undertaking that will require ongoing attention and support from the 

U.S. Government. Sustained efforts are needed as countries around the world continue to 

establish and strengthen their regulatory infrastructure for the control of radioactive sources. 

2006 Action 10-2: The U.S. Government should encourage suppliers to provide arrangements 

for the return of disused sources and examine means to reduce regulatory impediments that 

currently make this option unavailable.

Status: Ongoing. 

One of the obstacles to returning disused radioactive sources to suppliers is the application of 

national laws that forbid the importation of radioactive waste. If the sources become designated 

as waste, these laws prohibit their reentry into the supplier country. The United States and 

many other countries do not declare a disused source to be waste until it has reentered the 

territory and has been determined to be waste (i.e., the source cannot practically or 

economically be reused or recycled). The United States is pressing for supplier countries 

whose national laws prevent the return of sources to a supplier to examine means to reduce 

these regulatory impediments. 
28 

Another obstacle includes the loss of Type B packaging status. Many of the Category 1 and 2 

sources must be transported in Type B packages. In the United States, many of the Type B 

packages were designed several decades ago and do not meet new international standards. 

Internationally, the grandfathering clause for old designs expired in 2001. In the United States, 

Type B packages did not have to meet the new design standards until October 1, 2008. After 

that date, many of the existing Type B packages could no longer be used. While Type B 

packages that meet the new standards are available, they are expensive to either lease or buy, 

or are available only in limited quantities. In special circumstances when certificate holders 

have demonstrated that compensatory measures enable an existing Type B package to meet a 

level of safety at least equal to that required by regulation to ensure that radioactive material 

can be transported safely, the NRC and DOT allow limited continued use of such packages, 

while NRC staff complete the review and approval of replacement package designs. However, 

this is considered an interim solution until new Type B packages are certified and available. 

2010 Recommendation 8 addresses this challenge. 

The U.S. Government has succeeded in bringing broad attention to this issue through a number 

of interactions with the international community. For example, in September 2009, the U.S. 

Government successfully introduced a provision in the IAEA 53rd General Conference 

Resolution on Nuclear Security, Including Measures To Protect against Nuclear and 

Radiological Terrorism [IAEA 2009b] that “calls upon all States to identify secure storage and 

disposition pathways for disused radioactive sealed sources so that such sources in their 

territories remain under regulatory control, unless exempted from regulatory control, and further 

calls upon States to address obstacles to the return of disused sources to the supplier State.” 

The United States also contributed to a similar provision in the Resolution on Measures To 

Strengthen International Cooperation in Nuclear, Radiation, Transport, and Waste Safety [IAEA 

2009a] that calls for related measures, “particularly those encouraging States to facilitate the 

return of disused sources to suppliers, [and] to develop central storage or disposal facilities for 

disused or orphan sources which cannot be returned to suppliers....” Also, in May 2010, the 

United States convened a meeting of 12 supplier countries in Vienna, Austria to begin dialogue 

on their successes and challenges with regard to source repatriation. However, the action 

requires continued efforts to further examine the domestic regulatory landscape that hinders the 

return of disused sources to foreign suppliers and the loss of Type B packaging status. Chapter 

3 of this report further discusses this challenge. 

2006 Action 10-3: The Task Force suggests the use of education and the creation of 

incentives to discourage the export of used Category 1 and 2 radioactive sources as an 

alternative to disposal.

Status: Ongoing. 

The implementation of export controls for radioactive sources has allowed for considerable 

progress on this action by permitting the NRC and regulatory bodies in other countries greater 

ability to screen sources to ensure that they are not being exported abroad as an alternative to 

disposal. Specifically, under the NRC’s export licensing program, the importing country must 

consent to the import of a Category 1 source or device before shipment; pertinent 

documentation is required to demonstrate that the recipient has the necessary authorization to 

receive and possess the material; and NRC regulations exclude disused sources from the 

regulatory definition of radioactive waste and facilitate their return by allowing applicants to 

import using a general license to encourage the return of sources to the U.S. supplier. 
29 

To further these efforts, the NRC should evaluate, as part of its outreach efforts, raising this 

concern with its primary trading partners. 

2006 Action 10-4: The U.S. Government should improve the interagency evaluation of 

recipient authorization and recipient country controls to prevent the fraudulent acquisition of 

risk-significant sources exported from the United States.

Status: Complete. 

Since 2006, the process for interagency evaluation of recipient authorization and recipient 

country controls has been substantially refined and streamlined. On an annual basis, the NRC 

has sought views from the executive branch on proposed NRC procedures for addressing 

license applications from U.S. companies seeking to export Category 1 and 2 quantities of 

radioactive material abroad. Such requests are consistent with the NRC rulemaking on the 

export and import of radioactive material [NRC 2005a] that calls for the Commission, as 

appropriate, to seek the advice of the executive branch in assessing whether a proposed export 

of a Category 1 or Category 2 quantity of radioactive material would be inimical to the U.S. 

common defense and security. The finding of no inimicality is relevant to both the nuclear 

proliferation significance of exports and the related security concerns that potentially harmful 

radioactive material could be used for malicious purposes. The NRC license review process 

considers executive branch views when, among other things, establishing the duration of 

licenses issued for U.S. exports of radioactive materials. License authorizations are valid for 

varying periods, but they do not exceed 10 years duration. 

The executive branch reviews now include clearances from a wide range of offices. The 2009 

review included 16 offices within the interagency group, bringing additional expertise to the 

process and making greater use of U.S. Government resources to better understand the 

recipient country’s security environment, the adequacy of its regulatory controls, and any 

potential security concerns that may arise during transport or at the end-use location. Executive 

branch views are based only on information currently available and views on exports to any 

particular country are susceptible to change as additional information becomes available. 

2006 Action 10-5: [The] NRC should consider reevaluating the need for a specific license to 

allow the import of Category 1 and 2 radioactive sources to a U.S.-licensed user.

Status: Complete. 

Since 2006, in light of enhancements made to the NRC’s domestic regulatory framework, the 

agency reevaluated the need for a specific license for the import of Category 1 and 2 quantities 

of radioactive material to a U.S. licensed user. The NRC issued a final rule in the summer of 

2010 that eliminates specific licenses for the import of radioactive sources. A specific license 

for the export of Category 1 and 2 quantities of radioactive material will still be required. 

2010 Recommendations 

2010 Recommendation 3: Contingent upon the availability of alternative technologies, the 

Task Force recommends that the NRC evaluate whether the export licensing for Category 1 and 

2 CsCl sources should be discontinued, taking the availability of disposal capacity and the threat 

environment into consideration. 
30 

As a result of a 2-year study to evaluate the feasibility of phasing out the use of dispersible 

forms of CsCl in Category 1 and 2 quantities, in response to 2006 Recommendation 12-2, a 

comprehensive five-part approach was identified. One element of this approach addresses the 

import and export of radioactive sources. In particular, it recommends that the NRC initiate a 

rulemaking or other stakeholder outreach processes to discontinue authorizing the export of 

Category 1 and 2 CsCl sources as replacement sources and/or technologies become available. 

It also recommends that the NRC, in cooperation with the Agreement States and DHS initiate a 

dialogue with stakeholder communities to obtain their input. An example of such an outreach 

was the public workshop that the NRC held in September 2008 to solicit public input on major 

issues associated with the use of CsCl. The stakeholder feedback received indicated that 

near-term replacement of devices or CsCl sources in existing blood, research, and calibration 

irradiators is not practicable and would be disproportionately detrimental to patient health, 

longstanding research, and emergency response capabilities. Given the range of uses of CsCl, 

one solution cannot apply to all applications or to all licensees uniformly. 

The NRC has found that the security of Category 1 and 2 CsCl sources is adequately protected 

under the current NRC and Agreement State requirements. In the event that the current threat 

environment changes such that the NRC and Agreement States would issue additional security 

requirements to apply appropriate limitations for the use of CsCl in its current forms or for its 

replacement with suitable alternatives, discontinuing export of these sources may be 

considered. 

Any actions to discontinue export of these sources should be taken only after any actions taken 

in response to 2010 Recommendation 11 (dealing with discontinuing licensing) are considered. 
31 

Chapter 3 

Status of the Recovery and Disposition of Radioactive Sources 

Management of Disused Sources

The disposition of risk-significant radioactive sources that have reached the end of their useful 

service lives and have no economic value to their current owner (or for various reasons do not 

have a readily identifiable owner) is an important consideration in ensuring the protection and 

security of this material. Disposition options include storage, recycling, reuse, and disposal.

The ability to dispose of disused risk-significant radioactive sources in the United States is a 

complicated matter. Radioactive sources are either considered commercial or Federal, and are 

classified as low-level radioactive waste (LLRW). Pursuant to the Low-Level Radioactive Waste 

Policy Amendments Act of 1985 [LLRWPAA 1985], States or State Compacts must provide 

disposal capability for commercial Class A, B, and C LLRW (as defined by U.S. Nuclear 

Regulatory Commission (NRC) regulations), including sealed sources, generated within their 

borders. The U.S. Department of Energy (DOE) is responsible for the disposal of LLRW 

(including sealed sources) owned or generated by DOE. DOE is also responsible for disposal 

of GTCC LLRW (including sealed sources classified as GTCC LLRW) resulting from activities 

licensed by the NRC or Agreement States.5

 DOE sources or sources resulting from certain 

Federal activities can be disposed of at certain DOE radioactive waste disposal facilities in 

accordance with DOE policies and orders. Commercial sources (including discrete radium and 

accelerator-produced isotope sources) are regulated by either the NRC or Agreement States 

and face a somewhat more complex path to disposal, in part because of the different levels of 

radioactivity of the sources. Four other factors affecting the disposal of commercial sources are 

restrictions associated with the LLRWPAA, waste classification requirements, waste acceptance 

criteria, and cost. Also, as discussed in Chapter 2, the limited availability of certified Type B 

packages is another obstacle to the shipment of disused sources. 

                                                           

5

   Every year, thousands of sources become disused and unwanted in the United States. While secure 

storage is a temporary measure, the longer sources remain disused or unwanted the chances increase that 

they will become unsecured or abandoned. These sources have been the focus of much interagency 

attention from a national security standpoint since the publication of the 2006 report. However, in many 

cases, disposal pathways are not currently available for disused sealed sources (and there are restricted 

options for storage of no-disposal-pathway waste). Continued coordinated effort is needed to make sure 

that comprehensive, sustainable disposal pathways for all disused sealed sources are developed in the 

interest of national security. These concerns are specific to disposal of radiation sources and do not relate 

to the storage and disposal of other radioactive materials, such as spent nuclear fuel and high-level waste.
32 

Removal and Disposition of Disused Sources—

Problem Statement*

The lack of disposal pathways for radioactive

sealed sources, which make up less than 1 percent

of all low­level radioactive waste by volume and

activity, poses a national security concern.  During

their service lives, these sources have numerous

essential and beneficial medical, industrial, and

research applications.  However, due to their high

activity and portability, some of these sources could

be used either individually or in aggregate in

radiological dispersal devices commonly referred to

as “dirty bombs,” resulting in economic impacts in

the billions of dollars and significant social

disruption.  Every year, thousands of sources

become disused and unwanted in the United States.  

While secure storage is a temporary measure, the

longer sources remain disused or unwanted the

chances increase that they will become unsecured

or abandoned.  Thus, permanent disposal is

essential.  However, only 14 States currently have

commercial LLRW sealed source disposal access,

and there are significant political, statutory, and

regulatory challenges associated with the creation

of commercial disposal access for the remaining 36

States.   

*Sealed Source Disposal and National Security:  

Problem Statement and Solution Set, Deliverable 

(Part 1) of the Removal and Disposition of 

Disused Sources Focus Group of the Radioisotopes 

Subcouncil of the NGCC and NSCC, December 9, 

2009. 

Disposal access, already a challenge before 

2006, has diminished substantially since that 

time, and a comprehensive policy change is 

needed to overcome current barriers in the 

disposal framework. In July 2008, the 

commercial LLRW disposal site near 

Barnwell, SC closed to out-of-compact 

States, leaving licensees in the 36 States 

outside of the Atlantic, Rocky Mountain, and 

Northwest Compacts6

 without disposal 

access for Class A, B, and C disused 

radioactive waste (see Figure I on page 33). 

In addition, because of its relatively low 

activity limits, the Barnwell facility does not 

accept most Class B and C LLRW sealed 

sources even from Atlantic Compact States. 

Also, many of the risk-significant sealed 

sources qualify as greater than Class C 

(GTCC) LLRW, for which there is no current 

disposal capability. Under current 

regulations, GTCC waste would be disposed 

of in a geologic repository unless alternative 

methods of disposal are proposed to and 

approved by the NRC. DOE is responsible 

for developing the capability to dispose of 

these GTCC wastes from NRC licensees, in 

accordance with the LLWPAA. 

Radioactive sources make up less than 1 

percent of all LLRW by activity and volume. 

However, they represent a significant 

concern because most licensees now have 

no commercial disposal option other than 

indefinite storage of their disused or 

unwanted sealed sources. Each year, 

thousands of radioactive sources become 

disused. Although current Federal and State 

programs provide assurance for long-term 

storage, disposal is considered the most secure management approach. 

The closure of the Barnwell waste facility to out-of-compact waste has also increased demands 

on Federal and State programs for the recovery of excess or unwanted sealed sources (i.e., the 

National Nuclear Security Administration (NNSA) Global Threat Reduction Initiative’s (GTRI) 

Offsite Source Recovery Project (OSRP) and the GTRI-funded, Conference of Radiation Control 

Program Directors (CRCPD)-managed Source Collection and Threat Reduction (SCATR) 

Program) [CRCPD 2007]. Despite the increased demands on these effective programs, the 

                                                           

6

 States within the Atlantic, Northwest and Rocky Mountain Compacts include: Alaska, Colorado, 

 Connecticut, Hawaii, Idaho, Montana, Nevada, New Jersey, New Mexico, Oregon, South Carolina, Utah, 

 Washington, and Wyoming. 
33 

national system for the recovery of lost and stolen sources continues to be a cooperative and 

well-coordinated effort among the Federal Government, States, and private sector. As an 

example of the effectiveness of the national system for the recovery of lost and stolen sources, 

all of the of 23 Category 1–3 sources (zero Category 1, 17 Category 2, and 6 Category 3) lost 

during calendar years 2006–2009 were promptly recovered. The data revealed no identifiable 

patterns indicating the collection of radioactive sources for criminal uses. 

Figure I. LLRW Sealed Source Disposal

In response to the challenges of diminishing disposal capacity, some progress has been made 

in pursuing solutions. Final implementation of these ongoing efforts may ultimately require the 

highest levels of Government involvement, including congressional action. 

Accomplishments 

√ DOE determined that some sealed sources recovered by the GTRI/OSRP meet the 

criteria for disposal as DOE waste at existing DOE facilities. This reduced the backlog of 

recovered sealed sources in storage. However, there are some sources registered with 

the GTRI for recovery from U.S. owners that contain foreign-origin radioactive material 

(americium (Am)-241) that do not currently have a disposal path and recovery is 

severely constrained until a disposal path is available. This disposal challenge is 

exacerbated by the fact that the number of U.S. manufactured sources containing 

foreign-origin Am-241 radioactive material is increasing. 

 

√ In 2009, the State of Texas licensed the construction of a new disposal facility to provide 

a disposal capability for certain classes of LLRW, including disused sealed sources for 

licensees in the Texas Compact (Vermont and Texas). This will be the first new facility 

to serve as a regional compact site since the passage of the LLRWPAA. Also in 

September 2009, the State of Texas licensed the construction of a facility for the 

disposal of Federal LLRW and mixed LLRW. It is expected that both facilities will be 

operational in 2011. 
34 

√ In September 2009, the GTRI, the DOE Office of Environmental Management, and the 

U.S. Navy successfully completed a multi-year effort to recover and dispose of all of the 

Navy’s disused radioisotope thermoelectric generators.

√ Communication on the issue of sealed source disposition has been reenergized. In 

2008, under the U.S. Department of Homeland Security (DHS) Nuclear Government 

Coordinating Council (NGCC) and Nuclear Sector Coordinating Council (NSCC), 

stakeholders across the sealed-source community, including manufacturers, distributors, 

users, storage providers, and disposal companies; regulators; other Federal, State, and 

local officials; and LLRW compact members convened to address the lack of commercial 

disposal options for sealed sources in the context of national security. Through the 

group’s assessment and identification of disposal/management alternatives, ranging 

from recycle and decay in storage to a number of options involving existing and new 

Federal and commercial disposal facilities, the group concluded that secure storage 

provides a temporary measure; however, the longer sources remain disused or 

unwanted, the more chances increase that they will become unsecured or abandoned, 

as discussed in the Removal and Disposition of Disused Sources—Problem Statement 

at the beginning of this chapter.

√ Partly in response to the lack of disposal capabilities, Federal and State agencies and 

licensees have taken a number of actions to strengthen the security of sealed sources in 

storage. These actions include: reporting Category 1 and 2 sources to the NSTS; 

implementing security requirements for Category 1 and 2 materials (i.e., increased 

controls); implementing measures to minimize the production of LLRW for which there is 

no disposal option before considering extended storage in accordance with NRC 

Regulatory Issue Summary 2008-12, “Considerations for Extended Interim Storage of 

Low-Level Radioactive Waste by Fuel Cycle and Materials Licensees,” issued May 2008 

[NRC 2008e]; and implementing voluntary physical protection upgrades to certain 

devices, funded by the GTRI. These initiatives were created in part so that radioactive 

sources with no current disposal pathway are not lost or mishandled. Chapter 2 of this 

report provides a more detailed listing of related accomplishments.

√ CRCPD launched SCATR in 2006 based on funding from DOE. This program is 

designed to reduce the amount of unused radioactive material stored by radioactive 

material licensees. SCATR provides a financial incentive for licensees to remove 

unwanted radioactive material from long-term storage (see the “Long-term Storage” box 

on page 35) to proper dispositioning to reduce the risk of these sources being used for 

malicious intent. In addition, the GTRI has continued its source recovery activities 

implemented under the GTRI/OSRP. The total number of SCATR-eligible sources (i.e., 

beta/gamma sources less than 10 Ci) registered in fiscal year 2008 was 3,700, whereas 

in fiscal year 2009, 11,600 new SCATR-eligible sources were added. Overall, there are 

nearly 15,800 sources in the GTRI/OSRP database that would be SCATR-eligible if they 

were in States with access to commercial disposal. Although CRCPD, States, industry, 

and the GTRI have been engaged in efforts to facilitate the recycle or reuse of sources, 

the vast majority of sources registered in the database are not eligible for recycle or 

reuse. The GTRI/OSRP also received verbal requests for the recovery of approximately 

2,000 small beta-gamma sources, which are yet to be registered, in fiscal year 2009. In 

addition, the GTRI/OSRP received several requests from State regulators to assist with 

either orphan sources or sources of regulatory concern. To date, the GTRI and its 
35 

partners have been able to recover more than 24,000 sources (more than 10,000 since 

2006 alone) from more than 700 sites in the United States.

2006 Recommendation 9-1: The Task Force recommends that the U.S. Government further 

evaluate the waste disposal options as outlined in the GAO reports on LLRW.

Status: Complete. 

The Government Accountability Office (GAO) reported to the Senate in June 2004 [GAO 2004] 

on LLRW disposal availability. In this report, GAO identified the following three legislative 

options for addressing a potential shortfall in LLRW disposal availability that still apply to the 

current situation: 

(1) Allow the current compact system under existing Federal legislation to adapt to the 

 changing LLRW situation (i.e., maintain the status quo). 

(2) Repeal the existing Federal legislation to allow market forces to respond to the changing 

 LLRW situation. 

(3) Use DOE disposal facilities for commercial waste. 

GAO acknowledged the severe challenges to pursuing these three legislative options, even to 

the point of making the options untenable. The Task Force evaluated these recommendations 

and concluded that the current compact system is not providing adequate commercial disposal 

options for disused radioactive sources. Because the regional compacts were founded in 

Federal and State statutes, solutions must be fostered at the highest levels of Federal and State 

Government. 

The GAO report and options informed the development of the list of options discussed in the 

Removal and Disposition of Disused Sources Focus Group. The focus group is still developing 

a messaging strategy and specific recommendations on potential solutions to the sealed source 

disposal concern to ultimately present to the DHS NGCC and NSCC. The Task Force will follow 

the progress made by and associated activities of the focus group. Likewise, the NRC is also 

gathering information to assess the effect of a lack of access to LLRW disposal facilities on 

those who use radioactive sources or materials in conducting research, such as universities and 

Long­Term Storage

Sources continue to remain in long­term storage because of a lack of a disposal path, particularly as a

result of the limitations on disposal at compact facilities, or high costs.   

With the combination of direct regulations concerning source storage, personnel protection regulations,

guidance, and security requirements, along with the inspection and enforcement program and voluntary

physical protection upgrades, there is  reasonable assurance that the Category 1 and 2 sources in

storage at facilities licensed by the NRC and Agreement States and at DOE facilities are safe and secure.

However, disposal is considered the most secure long­term management approach.
36 

hospitals. The NRC will use the information gathered from the various assessments in future 

decisionmaking on this issue. 

2006 Recommendation 9-2: The Task Force recommends that the NRC evaluate the financial 

assurance required for possession of Category 1 and 2 radioactive sources to assure that 

funding is available for final disposition of the sources.

Status: Complete. 

The NRC completed its evaluation of its financial assurance requirements, in consultation with 

Federal and State partners, in January 2010. The following options are being considered by 

NRC management in order to make a decision of whether to pursue rulemaking and the 

concomitant public consultation process. If a decision is made to pursue additional financial 

assurance, a rulemaking working group will be formed to develop a rulemaking plan and 

proposed rule. This initiative is being internally tracked by the NRC, outside of the Task Force. 

Options considered in the evaluation include the following: 

• Continue initiatives under the LLRWPAA that among other things, encourage regional 

compacts to site additional disposal facilities.

• Implement NRC risk-informed financial assurance requirements with lower financial 

assurance thresholds, where financial assurance would be required for smaller 

quantities of material than those stated in the NRC’s current requirements. Additionally, 

update the dollar amount requirements for financial assurance to represent current 

disposal costs.

• Continue efforts among CRCPD, the States, and licensees that possess sources that 

are no longer in use to assist these licensees in locating other licensees that may be 

interested in accepting the disused sources as donations (e.g., academic institutions).

• Assess the appropriate enforcement actions such as determining the appropriate fines 

for licensees who do not properly dispose of sources; such efforts serve as a deterrent 

to licensees abandoning sources.

• Establish a “bottle deposit” system, where vendors would require a deposit before 

shipping radioactive material. When the source is no longer of use to the licensee, the 

licensee would return the source to the vendor. Upon receipt, the vendor would return 

the deposit. This system would act as an incentive for the licensee to return, rather than 

abandon, the disused source. Additionally, this would reduce the number of shipping 

containers needed.

2006 Action 9-1: The DOE should continue its ongoing efforts to develop GTCC disposal 

capability.

Status: Ongoing.

DOE has initiated the preparation of an environmental impact statement (EIS) to evaluate 

potential disposal options for GTCC LLRW. It issued a notice of intent to prepare the EIS in July 

2007, followed by nine public scoping meetings from July through September 2007 to inform the 
37 

public and seek comments from communities that may host potential disposal alternatives. 

Background information about this effort can be found at http://www.gtcceis.anl.gov/ [DOE 

2010]. DOE expects to issue the draft EIS in 2010 and will take into account any comments the 

Blue Ribbon Commission on America’s Nuclear Future may provide on the draft in developing 

the final EIS. DOE expects to issue a final EIS in 2011. Pursuant to EPAct Section 631, before 

DOE can issue a final decision on its preferred disposal alternative for GTCC LLRW, it must first 

issue a report to Congress describing the disposal alternatives under consideration and await 

congressional action. Some alternatives may require legislative action to implement. 

2006 Action 7-1: The NRC should evaluate requiring licensees to review and document the 

reasons for storage of risk-significant sources longer than 24 months and the feasibility of 

establishing a maximum time limit on the long-term storage of risk-significant sources not in use.

Status: Complete. 

The NRC incorporated this action into its evaluation for 2006 Recommendation 9-2 in 

consultation with Federal and State partners. The evaluations will factor into the NRC’s 

decision whether to pursue rulemaking and the public consultation process. 

2010 Recommendations 

2010 Recommendation 4: The Task Force recommends that the U.S. Government, regional 

compacts, and States continue to evaluate disposal options for disused radioactive sources, 

including options for handling a potentially large number of disused cesium chloride sources that 

may be replaced once viable alternatives are available.

The current compact disposal system is not providing disposal options for all generators. 

Potential disposal solutions will likely involve the highest levels of Federal and State 

Government, and could include actions by Congress to modify the existing legislative framework 

or actions within the existing legislative framework (e.g., States and licensees without disposal 

access requesting compact commissions and States hosting existing disposal facilities to grant 

an out-of-compact exemption for disposal of disused sources). 

This recommendation follows on to 2006 Recommendation 9-1. 

2010 Recommendation 5: The Task Force recommends that Federal and State Governments 

investigate options such as providing short-term secured storage of sources recovered from 

U.S. owners that contain foreign-origin americium-241 radioactive material, so that these 

sources can be recovered now, and increase efforts to investigate options for disposal of these 

sources. 

An increasing number of U.S.-manufactured sealed sources (e.g., moisture gauges, oil 

well-logging devices) contain foreign-origin Am-241. These sources, when declared a waste, 

fall within the scope of the GTCC LLRW disposal project. These sources are currently stored 

securely at licensee sites, however, until a GTCC LLRW disposal capability is available, disused 

sources that contain foreign-origin radioactive material and are registered for recovery by the 

GTRI/OSRP have not been recovered because a disposal path has not been identified. The 

GTRI/OSRP's ability to store the sources it recovers is directly linked to the availability of 

disposal pathways. Both Federal and commercial storage facilities have been reluctant to 
38 

receive sealed sources recovered by GTRI/OSRP that have no disposal pathway. Therefore, 

this recommendation would help alleviate issues related to this type of material. 

2010 Recommendation 6: The Task Force recommends that the NRC incorporate procedures 

to review the status, such as the date of, the reason for, and location of sources in long-term 

storage, in the current inspection program.

The intent of incorporating this review into the current inspection program is to be able to 

ascertain when a source goes from being an economic asset to a licensee to being disused and 

unwanted, with limited or expensive disposition options. Incorporating this review into the 

inspection program would provide a more accurate account of those sources in long-term 

storage and also give assurance that disused and unwanted sources are being adequately 

protected and secured.

2010 Recommendation 7: The Task Force recommends that the U.S. Government, in 

collaboration with responsible State agencies, evaluate and develop a plan to improve, as 

necessary, processes for dealing with unwanted, abandoned, or impounded sources, including 

storage, reuse, recycling, or other disposition methods.

In November 2009, CRCPD conducted an Internet survey of its members on topics related to 

the storage and disposal of sealed sources in the States. Twenty States responded to the 

survey. The survey provides initial data to understand the sealed source storage situation in the 

Nation. The respondents identified a variety of storage conditions. Most States reported that 

licensees store sources on site. Eight States reported that licensees are requesting licenses for 

the storage of sources only. Most States have had to deal with licensees that have abandoned 

sources or went into bankruptcy. Nine States responded that they have storage for orphan or 

impounded sources, but only one State reported that it had a facility to accept unwanted 

sources. 

2010 Recommendation 8: The Task Force recommends that the U.S. Government enhance 

support of short-term and long-term research and development of certified Type B containers for 

use in domestic and international source recovery efforts. 

As discussed in Chapter 2, many of the Category 1 and 2 sources must be transported in a 

Type B package. On October 1, 2008, a significant number of older design specification and 

performance-oriented Type B package certifications expired as the U.S. Government 

harmonized with international transport regulations. As a result, beginning in October 2008, 

only a very limited number of certified Type B packages were available for specific applications. 

To provide for an orderly transition, the U.S. Government has provided special permits and 

authorizations for continued use of the decertified packages on an as-needed basis where 

efforts include a good faith effort to transition to currently certified packages in the near future 

and an adequate safety case has been demonstrated. For example, the current special permit 

authorizing the extended use of the 20WC container was granted until June 30, 2010. This 

container is particularly critical to source recovery operations because it has broad application 

as a result of its non-device specific design. 

For the long-term, the U.S. Government has procured vendor services for the design, 

development, testing and certification of a new Type B package to support the transportation of 

irradiators, teletherapy heads, or sources removed from these devices using remote handling 

capabilities such as the International Atomic Energy Agency’s (IAEA) mobile hot cell. The 
39 

design of this new Type B container will be available to any company in the United States or 

abroad. Ideally, the broad availability of this design will foster a more competitive market and 

drive down transportation costs when it becomes available in 2013/2014. 

In the short term, each year approximately 50 cesium-137 or cobalt-60 sources containing about 

18,000 Ci are added to the list of unwanted sources needing recovery that require the use of a 

certified Type B package. This is in addition to the 126 sources totaling 75,600 Ci already 

registered as disused. This means that between June 30, 2010, when the 20WC special permit 

expired and 2014, when many new Type B packages are expected to be available, there could 

be about 240 sources totaling 93,000 Ci that will not be recovered unless other short-term 

options are identified. 
40 

Chapter 4 

Progress in the Area of Alternative Technologies 

Alternative Technologies

Radionuclides are used in a variety of beneficial and lifesaving applications in medicine, 

industry, and research. Concerns about the possible misuse of those radionuclides in malicious 

acts have led to the exploration of lower risk alternative technologies that could replace those 

radionuclides. While alternatives exist for some applications, financial, logistical, functional, 

relative risk, and disposal issues can impede the deployment of some alternatives and providing 

a replacement of the current operating technology. 

Three types of alternatives could serve as replacements for risk-significant radionuclides: 

(1) technologies that use the same radionuclide with a different chemical or physical form (e.g., 

replacing cesium (Cs)-137 salt with less dispersible Cs-137 ceramic), (2) technologies that use 

a different radionuclide (e.g., replacement of Cs-137 salt with cobalt (Co)-60 metal), and 

(3) technologies that do not use a radionuclide (e.g., x-ray technology). Although alternative 

forms and radionuclides were assessed, further risk reduction might be achieved through 

alternative technology research and development that focuses on non-radioactive replacement 

(e.g., x-ray). 

Cesium chloride (CsCl) has long received increased attention from both a safety and security 

perspective because of its potential dispersibility if removed from an irradiator or source 

capsule. Approximately 550 licensees in the United States possess about 1,100 self-contained 

CsCl irradiators, which contain at least a Category 2 quantity of radioactivity. The increased 

controls required by the U.S. Nuclear Regulatory Commission (NRC) and Agreement States 

and implemented by licensees, along with voluntary additional facility and device hardening 

measures, have substantively improved the security of these sources. 

Since 2006, a number of initiatives helped direct the study of alternatives and alternative forms 

for Category 1 and 2 radioactive sources and the evaluation of the feasibility of phasing out 

CsCl in a highly dispersible form. Notably, in the National Academies’ 2008 report entitled, 

“Radiation Source Use and Replacement,” the National Academies examined a range of 

radionuclides and their applications [NA 2008]. Preparation of the report involved a number of 

public meetings and input from a wide range of stakeholders on radiation source use and 

replacement. The report’s key recommendations include the following: 

• Urge that the replacement of radionuclides with alternatives be implemented with caution 

to ensure that the essential functions are preserved. 

• Implement, through U.S. Government action, the replacement of radioactive CsCl 

sources through options such as discontinuing the import and licensing of new CsCl 

irradiator sources, putting in place incentives for decommissioning existing sources, and 

prohibiting the export of CsCl sources to other countries, except for purposes of disposal 

in an appropriately licensed facility. 

• Put in place, through U.S. Government action, incentives for research and development 

on alternative technologies. 
41 

• Develop a comprehensive, systematic approach across the U.S. Government to 

implement the recommendations. 

In addition, the Federal Government took a number of actions, as described below. 

Accomplishments 

√ The U.S. Environmental Protection Agency (EPA) continued its voluntary Alternative 

Technologies Initiative that examines non-radionuclide alternatives. In October 2007 

and July 2008, EPA held stakeholder meetings with the well-logging industry to 

understand the challenges and opportunities for alternatives in that application. 

√ Between December 2007 and April 2008, the NRC conducted a series of visits to the 

manufacturers of CsCl irradiators and sources. A cohesive set of conclusions emerged 

from the manufacturers, including that, for development of high-activity sources using 

less soluble and dispersible forms of Cs-137, a significant research effort is needed; 

scaling up from current small activity levels may not be technologically successful; and, if 

security is to be enhanced, the NRC should work with the industry to identify 

cost-effective, feasible enhancements.

√ In September 2008, the NRC held a stakeholder workshop on security and the use of 

CsCl, during which, stakeholders indicated that replacement of devices or CsCl sources 

in existing blood, research, and calibration irradiators is not practicable in the near term 

and would be disproportionately detrimental to patient health, longstanding research, 

and emergency response capabilities. Details about the stakeholder workshop can be 

found at http://www.nrc.gov/materials/miau/licensing.html [NRC 2008a].

√ The NRC developed a strategy, regulatory options, and a recommended option for the 

security and future use of CsCl sources based on information gathered from staff 

analysis, stakeholder inputs, a public workshop, site visits, and other sources, which was 

transmitted to the Commission on November 24, 2008 [NRC 2008f]. The Commission 

approved the option to enhance security and issue a Commission policy statement, with 

comments, on April 15, 2009 [NRC 2009e]. Elements of the approval included working 

with Federal agencies on a comprehensive approach to improve the security of CsCl 

sources (with monitoring of the threat environment and implementation of physical 

security upgrades), the development of a strategy for end-of-life management of CsCl 

sources, short-term and long-term research, and development of alternative forms of 

Cs-137 and a definition of dispersibility. 

On June 29, 2010, the Commission published the draft policy statement in the Federal 

Register for public comment [NRC 2010c]. It is the policy of the Commission that its 

mission of ensuring adequate protection of public health and safety, common defense 

and security, and the environment while enabling the use of radioactive materials for 

beneficial civilian purposes is best accomplished with respect to CsCl by implementing 

or promoting the following principles: 

• The safety and security of risk-significant sources is an essential part of the 

NRC’s mission; 
42 

• Licensees have the primary responsibility to securely manage and to protect 

sources in their possession from misuse, theft, and radiological sabotage; 

 

• Adequate protection of public health and safety is maintained if CsCl sources are 

managed in accordance with the security requirements of the NRC and the 

Agreement States. These requirements are based on vulnerability assessments 

of the various sources and follow the principles of the Code of Conduct; 

• While these sources are adequately protected under the current NRC 

requirements, design improvements could be made that further mitigate or 

minimize the radiological consequences; 

• The development and use of alternative forms of Cs-137, while not required for 

adequate protection, is prudent and the NRC intends to monitor these 

developments closely. In addition the NRC recognizes that measures to verify 

effectiveness of the alternatives for solubility and dispersibility must be 

established to support future decision-making on this matter; 

• CsCl enables three specific classes of applications that benefit society: (a) blood 

sterilization, (b) bio-medical and industrial research, and (c) calibration of 

instrumentation and dosimetry; 

 

• The NRC recognizes that currently there is no disposal capability for such 

commercial sources. The NRC considers it imperative to develop a pathway for 

the long term storage and disposal of these sources whether or not there are 

alternatives developed; and 

• The NRC monitors the threat environment and maintains awareness of 

international and domestic security efforts. In the event that changes in the 

threat environment necessitate regulatory action, the NRC is ready to issue 

additional security requirements to apply appropriate limitations for the use of 

CsCl in its current form. 

√ In 2009, the National Nuclear Security Administration (NNSA) began research on 

non-radioactive alternative technologies for radioactive source applications. NNSA is 

fully coordinating research with the interagency and is carrying it out through the national 

laboratories and through the NNSA Small Business Innovation Research program. 

Projects for neutron generation well logging alternatives, development of 

non-radionuclide-based sources of high energy gamma rays and development of x-ray 

alternatives to Cs blood irradiators are currently the focus of NNSA’s research and 

development efforts. 

√ In 2009, NNSA completed an initial study to evaluate and quantify the relative risk 

reduction achievable by replacing current forms of radioactive materials with other forms 

or with other radionuclides. Federal policymakers may use the conclusions drawn to 

examine investment options/tradeoffs for determining whether to fund research and 

development on alternative radioactive materials/forms. Preliminary results suggest that 

risk reduction achieved from alternative forms or alternative radionuclides as 

replacements may not be enough to offset the cost to develop the new alternatives, and 
43 

the alternatives need to be weighed against other options in more detailed cost-benefit 

analyses.

√ The U.S. Department of Homeland Security (DHS) Domestic Nuclear Detection Office 

(DNDO) is supporting research on non-radioactive alternative technologies through its 

Small Business Innovation Research Program. In particular, this program evaluates a 

neutron generator that could replace americium-beryllium sources currently used in the 

well-logging industry. This program also aims to design and produce a compact linear 

electron beam accelerator that is capable of producing radiation that mimics the 

radiation from the most common radionuclide sources but poses no security risks.

2006 Recommendation 12-1: The Task Force recommends that the Alternatives Technology 

Subgroup evaluate financial incentives; research needs for both alternative technologies and 

alternative designs, including financial support; and the cost-benefit of potential alternatives for 

Category 1 and 2 radioactive sources.

Status: Complete. 

In 2008–2010, an evaluation of alternative technologies was conducted for seven applications 

involving the most risk-significant radioactive materials. The evaluation included an assessment 

of financial incentives, research needs, and the life cycle operational costs of potential 

alternatives. The evaluation did not attempt to quantify the total cost to complete research and 

development of new alternatives or the recovery and disposal costs to remove the replaced 

sources. As part of this initiative, discussions were held with industry and government 

stakeholders and a lifecycle operational cost analysis of technologies was performed based on 

input from a small sample of stakeholders in each technology area reviewed. In-person focus 

groups for three industry practices (blood irradiator, industrial radiography, and well logging) 

were assembled in an effort to provide input to the evaluation. These focus group meetings 

proved effective, providing an opportunity to obtain the perspectives of both those who use the 

technologies and those who develop and manufacture them, such as researchers, developers 

and suppliers. 

Generally, the analysis found that alternatives exist for some of the seven applications but that 

the viability, relative risk reduction, and stage of development of these alternatives vary. No 

alternative currently exists that is able to meet all user needs for any of the seven applications. 

Replacement of industrial sources (americium (Am)-241, Cs-137, Co-60, iridium (Ir)-192) must 

be addressed in terms of the field of application. Specifically, replacement may be feasible but 

requires further technological development for blood irradiation by x-ray technology and 

industrial radiography by ultrasound and x-ray technology. Further research is needed to 

establish feasibility for calibration irradiators, research irradiators, well logging, and panoramic 

irradiators. Although alternative forms and radionuclides were assessed, further risk reduction 

might be achieved through alternative technology research and development that focuses on 

non-radioactive replacement (e.g., x-ray). X-ray technologies were found to be cost competitive 

with radionuclide technologies on an annualized cost basis. Recent developments in x-ray 

technology may lead to mature and desirable alternatives in the near future. The study 

concluded that the successful replacement of the radionuclide technologies with alternatives will 

require different timetables for each application, need to be incentivized in many cases, and 

require a coordinated effort among a wide range of stakeholders. As mentioned previously, the 

availability of disposal pathways for radioactive sources must be considered before the 

widespread replacement of radioactive sources with alternative technologies can occur. 
44 

2006 Recommendation 12-2: The Task Force recommends that high priority be given to 

conducting a study within 2 years to assess the feasibility of phasing out the use of CsCl in a 

highly dispersible form. This study should consider the availability of alternative technologies for 

the scope of current uses, safe and secure disposal of existing material, and international safety 

and security implications.

Status: Complete. 

In 2007–2009, a study was conducted to assess the feasibility of phasing out the use of CsCl in 

a highly dispersible form. Considering the results of the study and other input received, the 

Task Force concluded that an immediate phase-out of CsCl would not be feasible because the 

sources are used extensively in a wide range of applications in medicine, industry, and 

research, with significant health benefits to patients, and in the calibration of the national and 

international systems of radiation measurements. However, a gradual, stepwise phase-out 

could be feasible as alternatives become technologically and economically viable and if disposal 

pathways are identified. A number of challenges must be overcome to successfully implement 

this path forward, and the sequences and timeframes of implementation are critical. Sufficient 

time is required to develop replacement technologies for certain applications and to evaluate, 

consider, and where appropriate establish disposal pathways. Interim measures, such as 

enhancing the physical security of existing devices, would provide more effective protection of 

CsCl sources currently in use.

The path forward based on the study involves a comprehensive five-part approach for improving 

the security of and reducing the risks associated with sealed sources containing Category 1 and 

2 quantities of dispersible CsCl for the short term as well as for the long term, including: 

• Continue to implement security upgrades to supplement existing requirements and 

establish a process for determining additional future upgrades. The ongoing NNSA 

domestic voluntary security enhancement program, which includes the in-device delay 

effort, is already addressing this element. As such, this element does not appear as a 

separate action item in this report. 

• Initiate rulemaking or other processes, which should include stakeholder input to 

(1) eliminate further licensing, and (2) ban the export of CsCl sources. The Task 

Force notes that, while it is prudent to continue to look for viable alternative 

technologies and sources, a decision on whether to discontinue NRC and Agreement 

State licensing or export of new CsCl sources containing risk-significant quantities of 

radioactive material should be based primarily on the existence of viable alternative 

technologies and disposal capacity. Therefore, the Task Force concludes that it is 

premature to recommend initiating rulemaking or other processes to eliminate further 

licensing and export of CsCl sources. The NRC has found that current security of 

these risk-significant sources is adequate based on the actions taken to enhance 

security to date. 

• Consider developing a Government-facilitated disposal pathway. 2006 Action 9-1 

contains this element. 

• Investigate options such as prioritized Government-incentivized replacement of 

devices with existing, effective alternatives. 2010 Recommendation 10 contains this 

element. 
45 

• Support short-term and long-term research and development for alternative 

technologies. 2010 Recommendation 9 contains this element. 

 

2010 Recommendations 

The Task Force has identified a number of recommendations to achieve risk reduction by using 

alternative technologies in place of radioactive sources. 

2010 Recommendation 9: The Task Force recommends that the U.S. Government enhance 

support of short-term and long-term research and development for alternative technologies.

The Task Force recommends that the technology and user communities collaborate closely to 

determine the viability of using existing or developing technologies as replacements for 

International Atomic Energy Agency (IAEA) Category 1 and 2 quantity sources of Am-241, 

Cs-137, Co-60, and Ir-192. 

2010 Recommendation 10: The Task Force recommends that the U.S. Government, 

contingent upon the availability of alternative technologies and taking into consideration the 

availability of disposal pathways for disused sources, investigate options such as a voluntary 

prioritized, Government-incentivized program for the replacement of Category 1 and 2 sources 

with effective alternatives, with an initial focus on sources containing CsCl.

The Task Force recommends that the U.S. Government investigate options such as a program 

to incentivize the early decommissioning and replacement of Category 1 and 2 sources with 

viable alternatives, where available. The availability of a disposal pathway for existing Category 

1 and 2 sources is an important consideration for the secure replacement of these sources. If 

such a program is implemented, the Task Force recommends that the Government conduct it in 

a prioritized fashion with targeted replacements. For example, the Task Force suggests putting 

urban, densely populated areas at a higher priority. 

2010 Recommendation 11: Contingent upon the availability of viable alternative technologies, 

the Task Force recommends that the NRC and the Agreement States review whether the 

licensing for new Category 1 and 2 CsCl sources should be discontinued, taking the threat 

environment into consideration.

The NRC has found that the security of Category 1 and 2 CsCl sources is adequately protected 

under the current NRC and Agreement State requirements. While it is prudent to continue to 

look for viable alternative technologies and sources, a decision on whether to limit the further 

use of these sources should be based primarily on the existence of viable alternative 

technologies. The NRC should continue to work with its Federal and State partners to ensure 

the safety and security of CsCl sources. In the event that changes in the threat environment 

necessitate regulatory action, the NRC and Agreement States should issue additional security 

requirements to apply appropriate limitations for the use of CsCl in its current forms or for its 

replacement with suitable alternatives. 
46 

Summary Table of 2006 Recommendations and Actions and 2010 Recomme

The following table presents the Task Force 2006 recommendations and actions and the new 2010 recommendindicates the type of action that may be necessary to implement the recommendation—legislative change, regu

recommendations that would require a policy, rule, or procedure change or development in order to implement) recommendations that do not involve a change in law or regulation). The table also indicates the status of the raction and a reference to the applicable page and chapter in the 2006 and/or 2010 reports where the initiative is 

Recommendations and Actions

Legislative Change

Regulatory Change

Status 

2006 Recommendation 3-1

The Task Force recommends that the U.S. Government periodically reevaluate the list of radioactive sources that warrant enhanced security and protection to assess their adequacy in light of the evolving threat environment [and consistent with current national consequences of concern in order to provide a consistent level of protection with other critical infrastructure].

Ongoinreassesin 2009 part of periodic reevaluwith consideof amenbrackettext

2006 Action 3-1 The NRC should evaluate the need to reissue the 

Orders to the Manufacturing and Distribution Licensees to make sure no security issues have been introduced from the use of different units of radioactivity. 

 Comple
47 

Recommendations and Actions

Legislative Change

Regulatory Change

Status 

2006 Action 3-2 The Department of Transportation (DOT) should 

examine the use of the Code of Conduct Category 1 and 2 thresholds in domestic transportation regulations. 

 Comple

2006 Recommendation 4-1 

The Task Force recommends that there be a coordinated public education campaign (Federal, State, and industry) to reduce fears of radioactivity, diminish the impact of a radiological attack if one were to occur, and provide a deterrent to attackers considering the use of radiological materials. 

 Transiti

from the Task Foto FEM

2006 Recommendation 4-2 

The Task Force recommends that the Federal agencies and States continue efforts to improve coordination and communication of their ongoing activities in the area of radiation protection and security for Category 1 and 2 sources. 

 Ongoin
48 

Recommendations and Actions

Legislative Change

Regulatory Change

Status 

2006 Action 4-1 The NRC should consider imposing additional 

measures to verify the validity of licenses, before transfer of risk-significant radioactive sources, on all licensees authorized to possess Category 1 and 2 quantities of radioactive material. 

 Ongoin

2006 Recommendation 5-1 

The Task Force recommends development of a Transport Security Memorandum of Understanding to serve as the foundation for cooperation in the establishment of a comprehensive and consistent transport security program for risk-significant sources.

 Comple

expecte2010 
49 

Recommendations and Actions

Legislative Change

Regulatory Change

Status 

2006 Recommendation 5-2

The Task Force recommends that the U.S. Government evaluate the feasibility of using new and existing technologies to detect and discourage the theft of risk-significant radioactive material during transport. The evaluation should include the findings of operational testing of existing technologies offering enhanced security of motor carrier shipments of hazardous material; shipment tracking, including communication systems; radio-frequency identification; vehicle disabling technologies; and mobile and stationary radiation detection systems.

Ongoin

2006 Recommendation 5-3

The Task Force recommends that the U.S. Government immediately develop a strategy and take actions to address the security of international shipments of Category 1 and 2 radioactive sources that transit or are transshipped through the land territory of the United States.

Yes Ongoin

2006 Action 5-1 The Transportation Security Subgroup should review 

the findings and conclusions of all research conducted on securing “high hazard” hazardous materials transport to determine if any of the measures should be applied to transport of risk-significant radioactive sources. 

 Ongoin
50 

Recommendations and Actions

Legislative Change

Regulatory Change

Status 

2006 Action 5-2 DOT should evaluate the best practices from the 

high-threat urban area corridor assessments to determine whether it should incorporate any of the best practices into the requirements for security plans for high-risk radioactive material. DOT should also evaluate whether transport of lower risk radioactive material warrants a security plan or whether the transport could be exempted from some of the requirements. 

 Comple

2006 Action 6-1 The NRC should expeditiously complete its 

implementation of the fingerprinting provisions of the EPAct for those applicants for and licensees with Category 1 and 2 quantities of radioactive material. The NRC should place a high priority on completing the EPAct Section 652 rulemaking. As part of the rulemaking, the NRC should require fingerprinting for any individual who could have access to Category 2 or above quantities of radioactive materials. The NRC should also require periodic reinvestigations of such persons. 

Likely Ongoin

2006 Action 6-2 The NRC should evaluate the feasibility of 

establishing a national database for materials licensees that would contain information on pending applications and information on individuals cleared for unescorted access. 

 Ongoin
51 

Recommendations and Actions

Legislative Change

Regulatory Change

Status 

2006 Action 6-3 The NRC and DHS should enter into a memorandum 

of understanding to cover access to the SAVE database for materials licensees. 

 Comple

2006 Action 7-1 The NRC should evaluate requiring licensees to 

review and document the reasons for storage of risk-significant sources longer than 24 months and the feasibility of establishing a maximum time limit on the long-term storage of risk-significant sources not in use. 

 Comple

2006 Recommendation 9-1

The Task Force recommends that the U.S. Government further evaluate the waste disposal options as outlined in the GAO reports on LLRW.

Comple
52 

Recommendations and Actions

Legislative Change

Regulatory Change

Status 

2006 Recommendation 9-2 

The Task Force recommends that the NRC evaluate the financial assurance required for possession of Category 1 and 2 radioactive sources to assure that funding is available for final disposition of the sources.

 Comple

2006 Action 9-1 The DOE should continue its ongoing efforts to 

develop GTCC disposal capability. 

Possibly Ongoin
53 

Recommendations and Actions

Legislative Change

Regulatory Change

Status 

2006 Action 10-1 The U.S. Government should continue the efforts to 

promote international harmonization of import and export controls for Category 1 and 2 radioactive sources. 

 Ongoin

2006 Action 10-2 The U.S. Government should encourage suppliers to 

provide arrangements for the return of disused sources and examine means to reduce regulatory impediments that currently make this option unavailable. 

 Ongoin

2006 Action 10-3 The Task Force suggests the use of education and 

the creation of incentives to discourage the export of used Category 1 and 2 radioactive sources as an alternative to disposal. 

 Ongoin
54 

Recommendations and Actions

Legislative Change

Regulatory Change

Status 

2006 Action 10-4 The U.S. Government should improve the interagency 

evaluation of recipient authorization and recipient country controls to prevent the fraudulent acquisition of risk-significant sources exported from the United States. 

 Comple

2006 Action 10-5 [The] NRC should consider reevaluating the need for 

a specific license to allow the import of Category 1 and 2 radioactive sources to a U.S.-licensed user. 

 Comple

2006 Action 11-1 The Task Force encourages the NSTS Interagency 

Coordinating Committee to develop a procedure/policy with guidelines on how to handle both Government and non-Government requests for information in the NSTS. 

 Comple
55 

Recommendations and Actions

Legislative Change

Regulatory Change

Status 

2006 Action 11-2 The NRC should consider programming the NSTS to 

provide automatic daily information to [U.S.] Customs [and Border Patrol] on import/export shipment notifications. 

 Comple

expecte2011 

2006 Action 11-3 The Task Force suggests that a comprehensive 

analysis be conducted on the inclusion of Category 3 sources in the NSTS. 

 Comple

2006 Recommendation 12-1 

The Task Force recommends that the Alternatives Technology Subgroup evaluate financial incentives; research needs for both alternative technologies and alternative designs, including financial support; and the cost-benefit of potential alternatives for Category 1 

 Comple
56 

Recommendations and Actions

Legislative Change

Regulatory Change

Status 

and 2 radioactive sources. 

2006 Recommendation 12-2 

The Task Force recommends that high priority be given to conducting a study within 2 years to assess the feasibility of phasing out the use of CsCl in a highly dispersible form. This study should consider the availability of alternative technologies for the scope of current uses, safe and secure disposal of existing material, and international safety and security implications. 

 Comple

2010 Recommendation 1 

The Task Force recommends that U.S. Government agencies use the radionuclides and the associated Category 2 threshold quantities in Table II, “Radionuclides that Warrant Enhanced Security and Protection” (as shown on page 11 of this report), as the appropriate framework for considering which sources warrant enhanced security* and that they adopt the definitions for a significant RED and a significant RDD (as shown on page 8 of this report) for prioritizing and allocating resources to eliminate, control, or mitigate risks of malevolent radiological incidents. * By warrants enhanced security and protection is meant enhanced in comparison to the security and protection applied to radioactive sealed sources before September 11, 2001. 

Possibly 

2010 Recommendation 2 

The Task Force recommends that the U.S. Government agencies should reevaluate their protection and mitigation strategies to protect against significant RED or RDD attack using both potential 

Possibly 
57 

Recommendations and Actions

Legislative Change

Regulatory Change

Status 

severe immediate or short-term exposure and contamination consequences to public health, safety, and the environment as the consequences of concern. Agencies should use the Task Force-endorsed definitions, radionuclides, and thresholds for a significant RED and RDD and the associated assumptions and parameters as common guidance in the assessment of risk and management of homeland security activities. 

2010 Recommendation 3 

Contingent upon the availability of alternative technologies, the Task Force recommends that the NRC evaluate whether the export licensing for Category 1 and 2 CsCl sources should be discontinued, taking the availability of disposal capacity and the threat environment into consideration. 

Yes 

2010 Recommendation 4 

The Task Force recommends that the U.S. Government, regional compacts, and States continue to evaluate disposal options for disused radioactive sources, including options for handling a potentially large number of disused cesium chloride sources that may be replaced once viable alternatives are available. 

Possibly Possibly 

2010 Recommendation 5 

The Task Force recommends that Federal and State Governments investigate options such as providing short-term secured storage of sources recovered from U.S. owners that contain foreign-origin americium-241 radioactive material, so that these sources can be recovered now, and increase efforts to investigate options for disposal of these sources. 

 
58 

Recommendations and Actions

Legislative Change

Regulatory Change

Status 

2010 Recommendation 6 

The Task Force recommends that the NRC incorporate procedures to review the status, such as the date of, the reason for, and location of sources in long-term storage, in the current inspection program. 

 Yes 

2010 Recommendation 7 

The Task Force recommends that the U.S. Government, in collaboration with responsible State agencies, evaluate and develop a plan to improve, as necessary, processes for dealing with unwanted, abandoned, or impounded sources, including storage, reuse, recycling, or other disposition methods. 

 

2010 Recommendation 8 

The Task Force recommends that the U.S. Government enhance support of short-term and long-term research and development of certified Type B containers for use in domestic and international source recovery efforts. 

 

2010 Recommendation 9 

The Task Force recommends that the U.S. Government enhance support of short-term and long-term research and development for alternative technologies. 

 

2010 Recommendation 10 

The Task Force recommends that the U.S. Government, contingent upon the availability of alternative technologies and taking into consideration the availability of disposal pathways for disused 

 Yes 
59 

Recommendations and Actions

Legislative Change

Regulatory Change

Status 

sources, investigate options such as a voluntary prioritized, Government-incentivized program for the replacement of Category 1 and 2 sources with effective alternatives, with an initial focus on sources containing CsCl. 

2010 Recommendation 11 

Contingent upon the availability of viable alternative technologies, the Task Force recommends that the NRC and the Agreement States review whether the licensing for new Category 1 and 2 CsCl sources should be discontinued, taking the threat environment into consideration. 

 Yes 
60 

Three of the above recommendations and actions either highlight or may necessitate legislative 

changes. The following provides further information on how the recommendations and actions, 

if carried out, may impact legislation: 

• 2006 Action 6-1: In implementing the Energy Policy Act of 2005 (EPAct) fingerprinting 

provisions for unescorted access to radioactive materials, the U.S. Nuclear Regulatory 

Commission (NRC) developed procedures to implement a program in which a licensee 

designates an individual (a reviewing officer) who is responsible for reviewing the 

trustworthiness and reliability information (which includes the Federal Bureau of 

Investigation (FBI) criminal history records checks) to grant unescorted access to other 

licensee employees. In some cases, such as for human resources personnel this 

reviewing officer does not require, or is not permitted, unescorted access as part of his 

or her job duties. As a result, the NRC’s fingerprinting authority, as granted by the 

EPAct, does not extend to these reviewing officers. The importance to security of the 

positions filled by these reviewing officers makes it logical to give the NRC the legal 

authority to make them subject to fingerprinting requirements and the FBI criminal 

history records check. A proposed legislative amendment was submitted to Congress 

by letter from the NRC in June 2008 to authorize the NRC to require such individuals to 

submit to fingerprinting requirements such as those applicable to individuals who have 

unescorted access to radioactive material or access to Safeguards Information. This 

legislative proposal was not enacted; however, as noted in the Commission direction in 

SRM-SECY-09-0181 [NRC 2010d], the proposed 10 CFR Part 37 rulemaking is to 

include the Commission’s requested statutory changes to the Atomic Energy Act of 1954 

[AEA 1954] that would permit fingerprints of reviewing officials without unescorted 

access to radioactive material or to SGI.

• 2006 Action 9-1: Pursuant to EPAct Section 631, before the U.S. Department of Energy 

can issue a final decision on a disposal alternative for greater than Class C low-level 

radioactive waste, it must first issue a report to Congress describing the disposal 

alternatives under consideration and await congressional action. Some alternatives may 

require legislative action to implement. 

• 2010 Recommendation 4: The current compact disposal system is partially working as 

intended, but not providing disposal options for all generators of low-level radioactive 

waste. Potential disposal solutions must be fostered at the highest levels of Federal and 

State Government, and could include actions by Congress to modify the existing 

legislative framework or actions within the existing legislative framework (e.g., States 

and licensees without disposal access requesting compact commissions and States 

hosting existing disposal facilities to grant an out-of-compact exemption for disposal of 

disused sources). 

The Task Force will continue to maintain and update an implementation plan for all of these 

recommendations and actions. The implementation plan was developed as a living document 

following the issuance of the first report. The implementation plan includes timelines for 

completion and tracks achievements towards completion of these activities. 
61 

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Safety Administration. “Hazardous Materials: Risk-Based Adjustment of Transportation 

Security Plan Requirements: Notice of Proposed Rulemaking.” Federal Register, Vol. 73, No. 

175, September 9, 2008, pp. 52558–52572. 

[DOT/PHMSA 2010] Department of Transportation (U.S.), Pipeline and Hazardous Materials 

Safety Administration. “Hazardous Materials: Risk-Based Adjustment of Transportation 

Security Plan Requirements: Final Rule.” Federal Register, Vol. 75, No. 45, March 9, 2010, pp. 

10974–10989. 

[EPA 1992] Environmental Protection Agency (U.S.). EPA 400-R-92-001, “Manual of 

Protective Action Guides and Protective Actions for Nuclear Incidents.” 1992. 

[EPAct 2005] Energy Policy Act of 2005. Pub. L. 109-58, Sec. 170H.f. August 8, 2005. 

[GAO 2004] Government Accountability Office (U.S.). GAO-04-604, “Disposal Availability 

Adequate in the Short Term, but Oversight Needed to Identify Any Future Shortfalls.” June 

2004. 

[GAO 2007] Government Accountability Office (U.S.). GAO-07-1038T, “Testimony Before the 

Permanent Subcommittee on Investigations, Committee on Homeland Security and 

Governmental Affairs, United States Senate, ‘Actions Taken by NRC to Strengthen Its Licensing 

Process for Sealed Radioactive Sources Are Not Effective.’” July 12, 2007. 

[IAEA 2004] International Atomic Energy Agency. “Code of Conduct on the Safety and Security 

of Radioactive Sources.” January 2004. 
63 

[IAEA 2005] International Atomic Energy Agency. “Guidance on the Import and Export of 

Radioactive Sources.” March 2005. 

[IAEA 2008] International Atomic Energy Agency. Nuclear Security Series No. 9, “Security in 

the Transport of Radioactive Material.” September 2008. 

[IAEA 2009a] International Atomic Energy Agency. “Measures to Strengthen International 

Cooperation in Nuclear, Radiation, Transport and Waste Safety (GC(53)/RES/10).” September 

18, 2009. 

[IAEA 2009b] International Atomic Energy Agency. “Nuclear Security, Including Measures to 

Protect Against Nuclear and Radiological Terrorism (GC(53)/RES/11).” September 18, 2009. 

[Klein 2008] Klein, Dale, Chairman of the U.S. Nuclear Regulatory Commission, letter to Nancy 

Pelosi, Speaker of the House of Representatives. June 9, 2008. (ADAMS Accession 

No. ML081550569) (publicly available) 

[LLRWPAA 1985] Low-Level Radioactive Waste Policy Amendments Act (LLRWPAA) of 1985, 

as amended. Pub. L. 99-240. 1985. 

[NA 2008] National Research Council of the National Academies. “Radiation Source Use and 

Replacement, Abbreviated Version.” 2008. 

[NRC 2005a] Nuclear Regulatory Commission (U.S.). “Export and Import of Radioactive 

Materials: Security Policies: Final Rule.” Federal Register, Vol. 70, No. 126, July 1, 2005, pp. 

37985–37994. 

[NRC 2005b] Nuclear Regulatory Commission (U.S.). “In the Matter of All Licensees 

Authorized To Possess Radioactive Material Quantities of Concern, Order Imposing Increased 

Controls (Effective Immediately).” Federal Register, Vol. 70, No. 230, December 1, 2005, 

pp. 72128–72132. 

[NRC 2006a] Nuclear Regulatory Commission (U.S.). FSME-06-114, “Implementation of PreLicensing Guidance.” December 21, 2006. (ADAMS Accession No. ML063560340) (publicly 

available) 

[NRC 2006b] Nuclear Regulatory Commission (U.S.). “In the Matter of Holders of Material 

Licenses Authorized To Manufacture or Distribute Items Containing Radioactive Material of 

Concern; Order Imposing Fingerprinting and Criminal History Records Check Requirements for 

Unescorted Access to Certain Radioactive Material and Modification of the Additional Security 

Measures (Effective Immediately).” Federal Register, Vol. 71, No. 208, October 27, 2006, pp. 

63046–63050. 

[NRC 2006c] Nuclear Regulatory Commission (U.S.). “Radiation Source and Protection Task 

Force Report.” August 15, 2006. 

[NRC 2007a] Nuclear Regulatory Commission (U.S.). “In the Matter of: Licensees Authorized 

To Possess Radioactive Material Quantities of Concern; Order Imposing Fingerprinting and 

Criminal History Records Check Requirements for Unescorted Access To Certain Radioactive 

Material (Effective Immediately).” Federal Register, Vol. 72, No. 239, December 13, 2007, pp. 

70901–70905. 
64 

[NRC 2007b] Nuclear Regulatory Commission (U.S.). SECY-07-0147, “Response to U.S. 

Government Accountability Office Recommendations and Other Recommendations to Address 

Security Issues in the U.S. Nuclear Regulatory Commission Materials Program.” August 25, 

2007. 

[NRC 2007c] Nuclear Regulatory Commission (U.S.). SRM-SECY-07-0147, “Staff 

Requirements—SECY-07-0147—Response to GAO Recommendations and Other 

Recommendations to Address Security Issues in the NRC Materials Program.” September 18, 

2007. 

[NRC 2008a] Nuclear Regulatory Commission (U.S.). “Cesium Workshop 2008.” 

December 16, 2008. http://www.nrc.gov/materials/miau/licensing.html. 

[NRC 2008b] Nuclear Regulatory Commission (U.S.). “Expansion of the National Source 

Tracking System: Proposed Rule.” Federal Register, Vol. 73, No. 71, April 11, 2008, 

pp. 19749–19761. 

[NRC 2008c] Nuclear Regulatory Commission (U.S.). “Final Report of the Independent 

External Review Panel to Identify Vulnerabilities in the U.S. Nuclear Regulatory Commission’s 

Materials Licensing Program.” March 11, 2008. (ADAMS Accession No. ML080700957) 

(publicly available) 

[NRC 2008d] Nuclear Regulatory Commission (U.S.). “Protection of Safeguards Information: 

Final Rule.” Federal Register, Vol. 73, No. 207, October 24, 2008, pp. 63545–63582. 

[NRC 2008e] Nuclear Regulatory Commission (U.S.). Regulatory Issue Summary 2008-12, 

“Considerations for Extended Interim Storage of Low-Level Radioactive Waste by Fuel Cycle 

and Materials Licensees.” May 9, 2008. 

[NRC 2008f] Nuclear Regulatory Commission (U.S.). SECY-08-0184, “Strategy for the Security 

and Use of Cesium-137 Chloride Sources.” November 24, 2008.

[NRC 2009a] Nuclear Regulatory Commission (U.S.). “Limiting the Quantity of Byproduct 

Material in a Generally Licensed Device.” Federal Register, Vol. 74, No. 147, August 3, 2009, 

pp 38372–38381. 

[NRC 2009b] Nuclear Regulatory Commission (U.S.). “No NSTS expansion at this time.” 

October 9, 2009. http://www.nrc.gov/security/byproduct/nsts/nsts-expansion.html. 

[NRC 2009c] Nuclear Regulatory Commission (U.S.). “Physical Protection of Byproduct 

Material: Availability of Preliminary Draft Rule Language.” Federal Register, Vol. 74, No. 83, 

May 1, 2009, pp. 20235–20236. 

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Physical Protection of Byproduct Material (RIN 3150-AI12).” December 14, 2009. 

[NRC 2009e] Nuclear Regulatory Commission (U.S.). SRM-SECY-08-0184, “Staff 

Requirements—SECY-08-0184—Strategy for the Security and Use of Cesium-137 Chloride 

Sources.” April 15, 2009. 
65 

[NRC 2010a] Nuclear Regulatory Commission (U.S.). “Certain Licensees Requesting 

Unescorted Access to Radioactive Material; Order Imposing Trustworthiness and Reliability 

Requirements for Unescorted Access to Certain Radioactive Material (Effective Immediately).” 

Federal Register, Vol. 75, No. 1, January 4, 2010, pp. 160–166. 

[NRC 2010b] Nuclear Regulatory Commission (U.S.). “Implementation Guidance for Physical 

Protection of Byproduct Material; Category 1 and Category 2 Quantities of Radioactive 

Material.” Federal Register, Vol. 75, No. 134, July 14, 2010, pp. 40756-40757. 

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Policy Statement on the Protection of Cesium-137 Chloride Sources and Notice of Public 

Meeting.” Federal Register, Vol. 75, No. 124, June 29, 2010, pp. 37483–37488. 

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Requirements—SECY-09-0181—Proposed Rule: Physical Protection of Byproduct Material 

(RIN 3150-AI12).” May 13, 2010. 

[Stafford Act 2007] Robert T. Stafford Disaster Relief and Emergency Assistance Act, Pub. L. 

No. 93-288 (2007). 

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[10 CFR Part 32] U.S. Code of Federal Regulations, “Specific Domestic Licenses to 

Manufacture or Transfer Certain Items Containing Byproduct Material,” Part 32, Chapter I, 

Title 10, “Energy.” 

[10 CFR Part 61] U.S. Code of Federal Regulations, ”Licensing Requirements for Land 

Disposal of Radioactive Waste,” Part 61, Chapter I, Title 10, “Energy.” 

[10 CFR Part 73] U.S. Code of Federal Regulations, “Physical Protection of Plants and 

Materials,” Part 73, Chapter I, Title 10, “Energy.” 

[49 CFR Part 173] U.S. Code of Federal Regulations, “Shippers—General Requirements for 

Shipments and Packaging,” Part 173, Chapter I, Title 49, “Transportation.” 

[49 CFR Part 1570] U.S. Code of Federal Regulations, “General Rules,” Part 1570, Chapter XII, 

Title 49, “Transportation.” 

[49 CFR Part 1572] U.S. Code of Federal Regulations, “Credentialing and Security Threat 

Assessments,” Part 1572, Chapter XII, Title 49, “Transportation.” 
66 

Appendix A

Acronyms and Abbreviations 

Am americium 

Be beryllium 

Cf californium 

C carbon 

Ci curie 

CIPAC Nuclear Critical Infrastructure Partnership Advisory Council 

Cm curium 

Co cobalt 

CFR Code of Federal Regulations, U.S.

CRCPD Conference of Radiation Control Program Directors 

Cs cesium 

CsCI cesium chloride 

DHS Department of Homeland Security, U.S. 

DNDO Domestic Nuclear Detection Office (DHS) 

DOE Department of Energy, U.S. 

DOT Department of Transportation, U.S. 

EIS environmental impact statement 

EPA Environmental Protection Agency, U.S. 

EPAct Energy Policy Act of 2005 

FBI Federal Bureau of Investigation 

Fe iron 

FEMA Federal Emergency Management Agency 

FMCSA Federal Motor Carrier Safety Administration 

FR Federal Register 

G-8 Group of Eight 

GAO Government Accountability Office 

Gd gadolinium 

GTCC greater than Class C 

GTRI Global Threat Reduction Initiative 

I iodine 

IAEA International Atomic Energy Agency 

IDD in-device delay 

IERP Independent External Review Panel 

Ir iridium 

LLRW low-level radioactive waste 

LLRWPAA Low-Level Radioactive Waste Policy Amendments Act of 1985 

LVS License Verification System 
67 

M&D manufacturing and distribution 

MOU memorandum of understanding 

NGCC Nuclear Government Coordinating Council 

NIPP National Infrastructure Protection Plan 

NNSA National Nuclear Security Administration (DOE) 

NRC Nuclear Regulatory Commission, U.S. 

NSCC Nuclear Sector Coordinating Council 

NSOI Nuclear Smuggling Outreach Initiative 

NSTS National Source Tracking System 

OSRP Offsite Source Recovery Project 

PHMSA Pipeline and Hazardous Materials Safety Administration 

Pm promethium 

PNSP Preventing Nuclear Smuggling Program 

Po polonium 

Pu plutonium 

Ra radium 

RCRA Resource Conservation and Recovery Act 

RDD radiological dispersal device 

RED radiation exposure device 

RSRT Radiological Source Registry and Tracking 

SAVE Systematic Alien Verification for Entitlements 

SCATR Source Collection and Threat Reduction Program 

Se selenium 

SGI Safeguards Information 

Sr strontium 

Task Force Interagency Task Force on Radiation Source Protection and Security 

Tm thulium 

TSA Transportation Security Administration 

U.S. United States 

U.S.C. United States Code 

W tungsten 

WBL Web-Based Licensing system 

Y yttrium 

Yb ytterbium 
68 

Appendix B

Glossary 

Agreement State 

An Agreement State is a State that has signed an agreement with the U.S. Nuclear Regulatory 

Commission (NRC) under which the State regulates the use of byproduct, source, and small 

quantities of special nuclear material within that State. There are currently 37 Agreement 

States. 

Becquerel (Bq) 

One of three units used to measure radioactivity, which refers to the amount of ionizing radiation 

released when an element (such as uranium) spontaneously emits energy as a result of the 

radioactive decay (or disintegration) of an unstable atom. Radioactivity is also the term used to 

describe the rate at which radioactive material emits radiation, or how many atoms in the 

material decay (or disintegrate) in a given time period. As such, 1 Bq represents a rate of 

radioactive decay equal to 1 disintegration per second, and 37 billion (3.7 x 1010) Bq equals 1 

curie (Ci). 

Prefixes may be added to Bq, e.g., kBq (kilobecquerel, 103

 Bq), MBq (megabecquerel, 106 Bq), 

GBq (gigabecquerel, 109

 Bq), TBq (terabecquerel, 1012 Bq), and PBq (petabecquerel, 1015 Bq). 

Blue Ribbon Commission on America’s Nuclear Future 

Established by President Obama in January 2010, the Blue Ribbon Commission on America’s 

Nuclear Future was formed to provide recommendations for developing a safe, long-term 

solution to managing the Nation’s used nuclear fuel and nuclear waste. The Commission is 

being co-chaired by former Congressman Lee Hamilton and former National Security Advisor 

Brent Scowcroft and is made up of 15 members who have a range of expertise and experience 

in nuclear issues, including scientists, industry representatives, and respected former elected 

officials. The Commission will produce an interim report within 18 months and a final report 

within 24 months that will provide advice and recommendations on issues including alternatives 

for the storage, processing, and disposal of civilian and defense spent nuclear fuel and nuclear 

waste. 

Compact 

A group of two or more States that have formed business alliance to dispose of low-level 

radioactive waste on a regional basis, as authorized by the Low-Level Radioactive Waste Act of 

1980, as amended. 

Curie 

One of three units used to measure the intensity of radioactivity in a sample of material. This 

value refers to the amount of ionizing radiation released when an element (such as uranium) 

spontaneously emits energy as a result of the radioactive decay (or disintegration) of an 

unstable atom. Radioactivity is also the term used to describe the rate at which radioactive 

material emits radiation, or how many atoms in the material decay (or disintegrate) in a given 

time period. As such, 1 Ci is equal to 37 billion (3.7 x 1010) disintegrations per second, so 1 Ci 

also equals 37 billion (3.7 x 1010) Bq. A curie is also a quantity of any radionuclide that decays 

at a rate of 37 billion disintegrations per second (1 gram of radium (Ra-226), for example). The 

curie is named after Marie and Pierre Curie, who discovered radium in 1898. 
69 

Deterministic Effect 

A deterministic effect is a health effect of radiation for which a threshold level of dose generally 

exists, above which the severity of the effect is greater for a higher dose. Such an effect is 

described as a “severe deterministic effect” if it is fatal or life threatening or results in a 

permanent injury that decreases the quality of life. 

Disposal

Disposal is the emplacement of radioactive sources in an appropriate facility without the 

intention of retrieval. 

Disused Source

A disused source is a radioactive source that is no longer used, and is not intended to be used, 

for the practice for which an authorization has been granted. 

Freedom of Information Act, Public Law No. 110-175 

It was signed into law by President Lyndon B. Johnson on September 6, 1966 (Public Law 89-

554, 80 Stat. 383; Amended 1996, 2002, 2007), and went into effect the following year. This act 

allows for the full or partial disclosure of previously unreleased information and documents 

controlled by the United States Government. The act defines agency records subject to 

disclosure, outlines mandatory disclosure procedures and grants nine exemptions to the statute. 

General License

A general license grants authority to a person for certain activities involving byproduct material 

without filing an application for a specific license. The general license allows the person to 

receive and use the device. Certain general licenses may require registration with the NRC. 

Greater than Class C Radioactive Waste

Greater than Class C (GTCC) radioactive waste is defined in the Low-Level Waste Policy 

Amendments Act of 1985 as low-level waste that exceeds the Class C limits in Title 10 of the 

Code of Federal Regulations (10 CFR) 61.55, “Waste Classification.” This section classifies 

low-level waste as Classes A, B, or C, according to concentration of specific short- and longlived radionuclides; this section also sets varying requirements on waste forms for disposal. 

GTCC waste is generally unacceptable for near-surface disposal. 

Highway Route Controlled Quantity

A highway route controlled quantity means a quantity of radioactive material within a single 

package that exceeds (1) 3,000 times the A1 value of the radionuclides as specified in 

49 CFR 173.435, “Table of A1 and A2 Values for Radionuclides,” for special form radioactive 

material, (2) 3,000 times the A2 value of the radionuclides as specified in 49 CFR 173.435 for 

normal form radioactive material, or (3) 1,000 terabecquerels (27,000 curies), whichever is 

least. 

Improvised Nuclear Device 

Improvised nuclear devices are illicit nuclear weapons bought, stolen, or otherwise originating 

from a nuclear state, or a weapon fabricated by a terrorist group from illegally obtained fissile 

nuclear weapons material that produces a nuclear explosion. 

Inimicality

In this report, “inimical to” means adverse, detrimental, or unfavorable to the common defense 

and security. Noninimicality to the common defense and security of the United States of an 
70 

export or import of radioactive material from or into the United States is a principal criterion for 

the NRC to determine whether to approve the export or import. 

License 

A permit, granted by an appropriate governmental body, allowing an entity to carry on some 

authority subject to regulation by the governmental body. The NRC issues licenses subject 

forth in Title 10 CFR, or an Agreement State issues a license under its equivalent regulations. 

The NRC and Agreement States issue about 21,000 specific licenses for medical, academic, 

and industrial uses of nuclear materials. Reactor-produced radionuclides are used extensively 

throughout the United States for civilian and military industrial applications, basic and applied 

research, the manufacture of consumer products, civil defense activities, academic studies, and 

medical diagnostics, treatment and research. The regulatory programs of the NRC and 

Agreement States are designed to ensure that licensees safely use these materials and do not 

endanger public health and safety nor cause damage to the environment. 

Long-Term Storage

Long-term storage refers to storage with little or no limits on its duration. This type of disposition 

mechanism can be used while arrangements are made for final disposition because of (1) a lack 

of a final disposal option, (2) a lack of available funds, (3) a need for time to complete an 

amended or new authorization, or (4) a need for time to establish a new disposition pathway. It 

can also be used while the availability of transportation to a new disposition location is pending. 

Long-term storage can be an effective mechanism to alleviate a health and safety or security 

risk posed by a source. However, long-term storage may not permanently alleviate the risk 

associated with the source. 

Mixed Waste 

Mixed waste contains both hazardous waste [as defined by the Resource Conservation and 

Recovery Act (RCRA) and its amendments] and radioactive waste (as defined by Atomic 

Energy Act and its amendments). It is jointly regulated by NRC or NRC's Agreement States and 

the U.S. Environmental Protection Agency (EPA) or EPA's RCRA Authorized States. 

Orphan Source

An orphan source is a radioactive source that is not under regulatory control, either because it 

has never been under regulatory control or because it had been abandoned, lost, misplaced, 

stolen, or transferred without proper authorization. 

Radiation Exposure Device

An object used to maliciously expose people, equipment, and/or the environment to ionizing 

radiation without dispersal of radioactive material. 

Radioactive Source 

A radioactive source is radioactive material that is permanently sealed in a capsule or closely 

bonded, in a solid form, and which is not exempt from regulatory control. It does not mean 

material encapsulated for disposal, or nuclear material within the nuclear fuel cycles of research 

and power reactors. 

Radiological Dispersal Device

The combination of radioactive material and the means (whether active or passive) to disperse 

that material with malicious intent without a nuclear explosion. 

 
71 

Risk-Significant Source

A risk-significant source refers to Category 1 and 2 sources as defined in the International 

Atomic Energy Agency’s (IAEA) Code of Conduct. 

Risk-Significant Quantity

A risk-significant quantity refers to aggregated radioactive material that together meets or 

exceeds the Category 1 or 2 thresholds from the IAEA Code of Conduct. 

Safeguards Information

Safeguards Information means information not otherwise classified as National Security 

Information or Restricted Data which specifically identifies a licensee’s or applicant’s detailed 

control and accounting procedures for the physical protection of special nuclear material in 

quantities determined by the NRC Commission through order or regulation to be significant to 

the public health and safety or the common defense and security; detailed security measures 

(including security plans, procedures, and equipment) for the physical protection of source, 

byproduct, or special nuclear material in quantities determined by the NRC Commission through 

order or regulation to be significant to the public health and safety or the common defense and 

security; security measures for the physical protection of and location of certain plant equipment 

vital to the safety of production or utilization facilities; and any other information within the scope 

of Section 147 of the Atomic Energy Act of 1954, as amended, the unauthorized disclosure of 

which, as determined by the NRC Commission through order or regulation, could reasonably be 

expected to have a significant adverse effect on the health and safety of the public or the 

common defense and security by significantly increasing the likelihood of sabotage or theft or 

diversion of source, byproduct, or special nuclear material. 

Source Collection and Threat Reduction (SCATR) Program 

The Conference of Radiation Control Program Directors (CRCPD) launched the SCATR 

Program in 2006, based on funding from the U.S. Department of Energy. This program is 

designed to reduce the amount of unused radioactive material stored by radioactive material 

licensees. SCATR provides a financial incentive for licensees to remove unwanted radioactive 

material from long-term storage to proper dispositioning to reduce the threat of these sources 

being used for malicious intent. 

Special Nuclear Material

Special nuclear material is defined by Title I of the Atomic Energy Act of 1954 as (1) plutonium, 

uranium enriched in the isotope 233 or in the isotope 235, and any other material which the 

Commission, pursuant to the provisions of section 51, determines to be special nuclear material, 

but does not include source material; or (2) any material artificially enriched by any of the 

foregoing, but does not include source material.

Spent Nuclear Fuel

Spent nuclear fuel means fuel that has been withdrawn from a nuclear reactor following 

irradiation, the constituent elements of which have not been separated by reprocessing. 

Storage

Storage refers to the holding of radioactive sources in a facility that provides for their 

containment with the intention of retrieval. 
72