AUDIT REPORT 

Audit of NRC’s Force-on-Force 

Inspection Program 

OIG-09-A-12 July 30, 2009 

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

NRC’s Web site at: 

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

NUCLEAR REGULATORY COMMISSION 

WASHINGTON, D.C. 20555-0001 

OFFICE OF THE 

INSPECTOR GENERAL 

 July 30, 2009 

MEMORANDUM TO: R. William Borchardt 

Executive Director for Operations 

FROM: Stephen D. Dingbaum /RA/ 

 Assistant Inspector General for Audits 

SUBJECT: AUDIT OF NRC’S FORCE-ON-FORCE INSPECTION 

PROGRAM (OIG-09-A-12) 

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

Force-on-Force Inspection Program.

The report presents the results of the subject audit. Agency comments provided during 

and subsequent to a July 21, 2009, exit conference have been incorporated, as 

appropriate, into this report. 

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

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

planned are subject to OIG followup as stated in Management Directive 6.1. 

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

audit. If you have any questions or comments about our report, please contact me at 

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

Attachment: As stated 
Electronic Distribution

Edward M. Hackett, Executive Director, Advisory Committee on Reactor 

 Safeguards 

E. Roy Hawkens, Chief Administrative Judge, Atomic Safety and 

 Licensing Board Panel 

Stephen G. Burns, General Counsel 

Brooke D. Poole, Jr., Director, Office of Commission Appellate Adjudication 

Jim E. Dyer, Chief Financial Officer 

Margaret M. Doane, Director, Office of International Programs 

Rebecca L. Schmidt, Director, Office of Congressional Affairs 

Eliot B. Brenner, Director, Office of Public Affairs 

Annette Vietti-Cook, Secretary of the Commission 

R. William Borchardt, Executive Director for Operations 

Bruce S. Mallett, Deputy Executive Director for Reactor 

 and Preparedness Programs, OEDO 

Martin J. Virgilio, Deputy Executive Director for Materials, Waste, Research, 

 State, Tribal, and Compliance Programs, OEDO 

Darren B. Ash, Deputy Executive Director for Corporate Management 

 and Chief Information Officer, OEDO 

Vonna L. Ordaz, Assistant for Operations, OEDO 

Kathryn O. Greene, Director, Office of Administration 

Cynthia A. Carpenter, Director, Office of Enforcement 

Charles L. Miller, Director, Office of Federal and State Materials 

 and Environmental Management Programs 

Guy P. Caputo, Director, Office of Investigations 

Thomas M. Boyce, Director, Office of Information Services 

James F. McDermott, Director, Office of Human Resources 

Michael R. Johnson, Director, Office of New Reactors 

Michael F. Weber, Director, Office of Nuclear Material Safety and Safeguards 

Eric J. Leeds, Director, Office of Nuclear Reactor Regulation 

Brian W. Sheron, Director, Office of Nuclear Regulatory Research 

Corenthis B. Kelley, Director, Office of Small Business and Civil Rights 

Roy P. Zimmerman, Director, Office of Nuclear Security and Incident Response 

Samuel J. Collins, Regional Administrator, Region I 

Luis A. Reyes, Regional Administrator, Region II 

Mark A. Satorius, Region III 

Elmo E. Collins, Jr., Regional Administrator, Region IV 
Audit of NRC’s Force-on-Force Inspection Program 

i

EXECUTIVE SUMMARY 

BACKGROUND

The Nuclear Regulatory Commission (NRC) conducts Force-onForce inspections at each of the Nation’s nuclear power plants on 

at least a triennial basis in accordance with the 2005 Energy Policy 

Act.1 A Force-on-Force inspection is a performance-based 

inspection designed to assess the ability of licensees’ security 

organizations to protect their facilities against sabotage.2 Any 

potentially significant deficiencies identified during these 

inspections are to be promptly corrected by the licensee. 

The Office of Nuclear Security and Incident Response (NSIR) 

manages the Force-on-Force inspection program. Force-on-Force 

inspections are part of NRC’s baseline physical protection 

inspection program, and are the only baseline inspections managed 

at the headquarters level.3

 Teams of headquarters-based 

inspectors and security risk analysts conduct inspections with 

support from physical security inspectors based in NRC’s four 

regional offices. These regional inspectors provide site-specific 

knowledge and represent their respective offices while on site with 

headquarters staff and licensee employees. U.S. military personnel 

serve as technical advisors to the NRC teams and assist with some 

inspection tasks. 

The Force-on-Force program budget for Fiscal Year (FY) 2009 is 

approximately $3.5 million, and composes about 6 percent of 

NSIR’s FY 2009 budget. Of the 251 Full Time Equivalents (FTE) 

allocated to NSIR in FY 2009, 14.8 FTE (6 percent) are assigned to 

the Force-on-Force program. NRC began the second triennial 

Force-on-Force inspection cycle in January 2008. NRC plans to 

conduct 25 Force-on-Force inspections during FY 2009. 

PURPOSE

The objective of this audit was to evaluate NRC’s Force-on-Force 

inspection program to determine if design and implementation of 

the program are thorough, consistent, and in accordance with NRC 

 

1 Pub L. No. 109-58, “The 2005 Energy Policy Act,” §651, August 8, 2005.

2

 NRC also conducts Force-on-Force inspections at other facilities that handle special nuclear materials, 

such as nuclear fuel cycle facilities. However, this audit focused on inspections at nuclear power plants. 

3

 Inspection Procedure (IP) 71130, “Baseline Physical Protection Program.”
Audit of NRC’s Force-on-Force Inspection Program 

ii

standards. The audit focused on the program’s development from 

the first triennial inspection cycle through the current second 

triennial inspection cycle.

 RESULTS IN BRIEF

NRC conducts Force-on-Force inspections to evaluate licensees’ 

ability to protect nuclear power plants against Design Basis Threat 

type adversaries. NRC meets its 2005 Energy Policy Act 

requirement to conduct Force-on-Force inspections on a triennial 

basis, and the program has adequate management controls to 

ensure that inspections are thorough and comply with NRC 

standards. In particular, the Office of the Inspector General found: 

 NSIR management assessed the Force-on-Force program early 

in the second inspection cycle, and subsequently undertook 

organizational and procedural changes to improve internal 

controls and program performance.

 NSIR and regional staff differ over interpretation of some NRC 

guidance and approaches to conducting Force-on-Force 

inspections. 

By taking steps to reach agreement between headquarters and 

regional staff regarding Force-on-Force inspection program 

guidance, objectives, and best practices, NRC can better ensure its 

credibility with licensees and foster positive working relationships 

among staff involved in the Force-on-Force inspection program.

RECOMMENDATIONS

All recommendations for this report appear at the end of Finding B.

AGENCY COMMENTS

At a July 21, 2009, exit conference, NRC senior managers agreed 

with the report contents and provided editorial suggestions. This 

final report incorporates revisions made, where appropriate, as a 

result of the agency’s suggestions. 
Audit of NRC’s Force-on-Force Inspection Program 

iii

ABBREVIATIONS AND ACRONYMS

CAF Composite Adversary Force 

CFR Code of Federal Regulations 

DBT Design Basis Threat 

FTE Full-Time Equivalent 

FY Fiscal Year 

IDS Intrusion Detection System 

NRC Nuclear Regulatory Commission 

NSIR Office of Nuclear Security and Incident Response
Audit of NRC’s Force-on-Force Inspection Program 

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Audit of NRC’s Force-on-Force Inspection Program 

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TABLE OF CONTENTS

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

ABBREVIATIONS AND ACRONYMS ....................................iii 

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

II. PURPOSE ..................................................................... 4 

III. FINDINGS ...................................................................... 5 

A. NSIR Management Has Assessed the Force-on-Force 

Program and Instituted Changes to Enhance 

 its Performance ...................................................... 5 

B. Headquarters and Regional Staff Differ Over 

 Guidance and Approaches to Force-on-Force 

 Inspections ............................................................. 8 

IV. AGENCY COMMENTS ................................................ 12 

APPENDICES 

A. TITLE 10, CODE OF FEDERAL REGULATIONS, 

 SECTION 73.1a AND b................................................ 13 

B. SCOPE AND METHODOLOGY ................................... 17 

 
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Audit of NRC’s Force-on-Force Inspection Program 

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I. BACKGROUND 

The Nuclear Regulatory Commission (NRC) conducts Force-onForce inspections at each of the Nation’s nuclear power plants on 

at least a triennial basis in accordance with the 2005 Energy Policy 

Act.4

 A Force-on-Force inspection is a performance-based 

inspection designed to assess the ability of licensees’ security 

organizations to protect their facilities against sabotage.5

 Any 

potentially significant deficiencies identified during these 

inspections are to be promptly corrected by the licensee. 

The Office of Nuclear Security and Incident Response (NSIR) 

manages the Force-on-Force inspection program. Force-on-Force 

inspections are part of NRC’s baseline physical protection 

inspection program, and are the only baseline inspections managed 

at the headquarters level.6

 Teams of headquarters-based 

inspectors and security risk analysts conduct inspections with 

support from physical security inspectors based in NRC’s four 

regional offices. These regional inspectors provide site-specific 

knowledge and represent their respective offices while on site with 

headquarters staff and licensee employees. U.S. military personnel 

serve as technical advisors to the NRC teams and assist with some 

inspection tasks. 

NRC conducts each Force-on-Force inspection in three phases. 

The first phase, target set7

 review, is performed by headquartersbased security risk analysts and generally occurs at least several 

weeks before onsite inspection work begins. Security risk analysts 

review plant operating procedures and documentation of plant 

operating systems in coordination with licensee security and 

engineering personnel. Following their evaluation, security risk 

analysts create a list of potential target sets to be used in planning 

the exercise portion of the inspection. 

 

4 Pub L. No. 109-58, “The 2005 Energy Policy Act,” §651, August 8, 2005.

5

 NRC also conducts Force-on-Force inspections at other facilities that handle special nuclear materials, 

such as nuclear fuel cycle facilities. However, this audit focused on inspections at nuclear power plants. 

6

 Inspection Procedure (IP) 71130, “Baseline Physical Protection Program.”

7

 A target set is a combination of equipment, which, if damaged or disabled, would likely result in significant 

reactor core damage. Target sets also include plant operator actions intended to prevent or mitigate damage 

to this equipment. 
Audit of NRC’s Force-on-Force Inspection Program 

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During the second phase, pre-exercise planning week, NRC 

inspection teams composed of headquarters and regional staff 

conduct onsite planning and inspection work in preparation for 

Force-on-Force exercises. For example, the inspection teams 

conduct tabletop drills with licensee personnel to evaluate plant 

security plans against a series of possible attack scenarios. In 

addition to tabletop drills, the NRC inspection teams physically test 

plant intrusion detection systems,8 and observe a sample of plant 

security personnel perform tactical demonstrations. 

The exercise week is the last portion of the inspection. During this 

week, a composite adversary force (CAF) playing the role of a 

mock adversary group simulates attacks against the power plant.9

The CAF is trained and equipped to approximate the capabilities of 

a design basis threat (DBT) adversary. The DBT reflects NRC’s 

intelligence analysis of the type, composition, and capabilities of 

potential adversaries.10 The CAF attempts to simulate destroying 

enough plant equipment to damage the power reactor’s core or 

spent fuel pool, thereby triggering a release of radiation into the 

environment. The licensee’s security personnel seek to interdict 

the CAF and prevent damage to plant equipment. 

NRC gives plant operators 8 to12 weeks advance notice of Forceon-Force inspections for safety and logistical purposes. Plant staff 

must coordinate the efforts of two sets of security officers: one for 

maintaining site security during exercises, and another for 

participating in the exercises. In addition, plant staff must assemble 

and train a group of individuals, typically plant employees, to control 

and monitor exercises. 

 

8

 NRC regulations require detection of penetration or attempted penetration of a power plant’s protected 

area to ensure that the plant’s security organization can adequately respond. A perimeter intrusion 

detection system generally consists of one or more sensors, electronic processing equipment, a power 

supply, signal transmission media, an alarm monitor with display, and a means for maintaining and providing 

an alarm history. See NRC Regulatory Guide 5.44, pp.1-2.

9

 The CAF is composed of security officers from various nuclear power plants, and is managed by a private 

company that provides security services for a number of U.S. nuclear power plants. Although NRC does not 

oversee CAF teams, NRC inspectors monitor CAF performance with assistance from U.S. military personnel 

assigned to inspection teams. NRC requires a separation of functions between the CAF and licensee 

security forces to ensure an independent, reliable, and credible mock adversary force. 

10 DBT details are classified; however, Title 10 Section 73.1 of the Code of Federal Regulations (CFR) 

prescribes general DBT adversary characteristics. See Appendix A for 10 CFR 73.1 a (Purpose) and b 

(Scope).
Audit of NRC’s Force-on-Force Inspection Program 

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The Force-on-Force program budget for Fiscal Year (FY) 2009 is 

approximately $3.5 million, and composes about 7 percent of 

NSIR’s FY 2009 budget. Of the 251 Full Time Equivalents (FTE) 

allocated to NSIR in FY 2009, 14.8 FTE (6 percent) are assigned to 

the Force-on-Force program. Table 1 shows program budget and 

FTE data for FY 2005 through FY 2009. 

Table 1: Force-on-Force Program Annual Budgets and FTE

 FY 2005 FY 2006 FY 2007 FY 2008 FY 2009 

Budget

$1,878,397 $1,911,088 $1,395,392 $2,049,530 $3,500,00011

FTE

9.3 14.6 17.2 15.4 14.8

Source: OIG analysis of NSIR data. 

NRC began the second triennial Force-on-Force inspection cycle in 

January 2008. NRC plans to conduct 25 Force-on-Force 

inspections during FY 2009. Auditor analysis of historical data 

found that inspector workload varies from site to site, depending on 

variables such as the amount of followup needed after each site’s 

inspection. Graph 1 shows median annual inspection hours per 

site from FY 2005 through FY 2008. 

 

11 The program budget increase in FY 2009 reflects costs of upgrading Multiple Integrated Laser 

Engagement System equipment used to simulate gunfire in Force-on-Force exercises, as well as the 

purchase of a new truck and trailer to transport this equipment. 

 

Licensee security 

personnel preparing for a 

Force-on-Force exercise. 

Source: NRC 
Audit of NRC’s Force-on-Force Inspection Program 

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Graph 1: Median Annual Force-on-Force Inspection Hours Per Site

Median Force-on-Force Inspection Hours per Site

FY 2005 through FY 2008

0

100

200

300

400

500

600

700

FY05 FY06 FY07 FY08

Year

Hours

Median Regular

Hours

Median Overtime

Hours

Median Total Hours

 Source: OIG analysis of NSIR data.

II. PURPOSE 

The objective of this audit was to evaluate NRC’s Force-on-Force 

inspection program to determine if design and implementation of 

the program are thorough, consistent, and in accordance with NRC 

standards. The audit focused on the program’s development from 

the first triennial inspection cycle through the current second 

triennial inspection cycle. 
Audit of NRC’s Force-on-Force Inspection Program 

5

III. FINDINGS 

NRC conducts Force-on-Force inspections to evaluate licensees’ 

ability to protect nuclear power plants against DBT-type 

adversaries. NRC meets its 2005 Energy Policy Act requirement to 

conduct Force-on-Force inspections on a triennial basis, and the 

program has adequate management controls to ensure that 

inspections are thorough and comply with NRC standards. In 

particular, the Office of the Inspector General found: 

 NSIR management assessed the Force-on-Force program early 

in the second inspection cycle, and subsequently undertook 

organizational and procedural changes to improve internal 

controls and program performance.

 NSIR and regional staff differ over interpretation of some NRC 

guidance and approaches to conducting Force-on-Force 

inspections. 

By taking steps to reach agreement between headquarters and 

regional staff regarding Force-on-Force inspection program 

guidance, objectives, and best practices, NRC can better ensure its 

credibility with licensees and foster positive working relationships 

among staff involved in the Force-on-Force inspection program. 

A. NSIR Management Has Assessed the Force-on-Force Program and 

Instituted Changes To Enhance Its Performance 

As a best practice, management should periodically assess 

programs and apply the results to improve program performance. 

In response to industry concerns regarding the consistency of 

inspections, NSIR staff assessed the Force-on-Force program in 

summer 2008. Following this assessment, NSIR management 

implemented several organizational and procedural changes 

designed to improve program performance. Some of these 

changes were instituted through revision of the Force-on-Force 

inspection procedure.12

 

12 The current version of IP 71130.03 took effect in February 2009.
Audit of NRC’s Force-on-Force Inspection Program 

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Branch Reorganization

NSIR management created the Security Training and Support 

Branch to manage inspection scheduling, development of new 

guidance, staff training, and other support tasks. These tasks were 

previously performed by the Security Performance Evaluation 

Branch, which also runs Force-on-Force inspections. The new 

organization enables the Security Performance Evaluation Branch 

to focus on inspections, and divides management duties between 

the respective branch chiefs. 

Standardization of Training Requirements 

Headquarters-based Force-on-Force inspectors are now required 

to satisfy full qualification standards prescribed in Inspection 

Manual Chapter 1245. This aligns the program with qualification 

standards for regional-based physical security inspectors. 

Previously, Force-on-Force inspectors were not subject to 

Inspection Manual Chapter 1245 standards and thus were not 

required to undergo training and demonstrate proficiency in basic 

inspection skills. 

Increased Recruitment and Training of Force-on-Force 

Personnel

NSIR management has increased recruiting and training of security 

risk analysts and Force-on-Force inspectors to add rotational depth 

and distribute workload more evenly among staff. These efforts 

respond to workload and inspection schedule pressures, as well as 

reportedly high staff turnover problems during the first inspection 

cycle. Though Force-on-Force team members rated morale as 

high, several acknowledged that the frequent travel and long work 

days required for inspections are significant sources of stress. 

Revised Target Set Review Procedures and Standards 

NSIR management introduced new target set review procedures 

and adopted new standards for the types of actions plant operators 

could take to protect critical plant equipment. Previously, NSIR 

security risk analysts conducted site visits during the pre-exercise 

planning week, which limited target set review time and increased 

the chance of unresolved issues impacting subsequent exercises. 

Security risk analysts now review target set information and visit 

licensees’ sites before Force-on-Force inspections begin. In 

addition, the new inspection procedure enhances criteria that 
Audit of NRC’s Force-on-Force Inspection Program 

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licensees must meet to receive credit for actions that plant 

operators would take during a contingency, such as a terrorist 

attack, to protect target set equipment. Specifically, licensees must 

demonstrate that their operators are properly trained and equipped, 

and are physically capable of performing planned protective actions 

while their plant is under attack.13 

Escalation Process

The revised inspection procedure provides licensees a formal 

escalation process for resolving disputes with NRC about 

inspection planning and conduct. The process is designed to 

resolve disputes at the lowest NSIR management level necessary, 

and progressively elevate matters as higher management 

involvement is warranted. This enables Force-on-Force inspection 

team leaders to focus on inspection tasks while NSIR managers 

work directly with licensee managers to address their concerns, 

thereby reducing the impact of disputes on inspection schedules. 

Exercise Lessons Learned 

The revised inspection procedure establishes a formal process for 

capturing lessons learned and applying them to program guidance. 

According to NSIR staff, this previously occurred informally as staff 

shared observations about inspections verbally among themselves. 

The new procedure includes a template to be used in documenting 

lessons learned during inspections. Moreover, this new guidance 

requires managers to document cases in which lessons learned 

could serve as the basis for revising program guidance. 

 

Because these organizational and procedural changes have only 

recently been implemented, it is too early for OIG to evaluate the 

effectiveness of each change in meeting its intended goals. 

However, based on feedback received from industry and NRC staff, 

OIG believes these changes have the potential to enhance the 

efficiency, transparency, and rigor of the Force-on-Force inspection 

program. 

 

13 For instance, licensees cannot claim credit if high radiation or other environmental hazards would prevent 

operators from carrying out protective actions. Additionally, plant operators must be capable of accessing 

target set equipment without risking their own safety by confronting adversaries or passing through areas 

controlled by adversaries.
Audit of NRC’s Force-on-Force Inspection Program 

8

B. Headquarters and Regional Staff Differ Over Guidance and 

Approaches to Force-on-Force Inspections

Improved coordination of headquarters and regional inspection 

activities would result from a shared understanding of policies and 

procedures, and open communication among staff. Headquarters 

and regional staff differ over interpretation of some inspection 

guidance, and over approaches to conducting Force-on-Force 

inspections. This has occurred in part because the program has 

undergone substantial changes in a short period of time, but 

procedural changes have not been effectively communicated to 

regional staff in a systematic fashion. Additionally, differences 

among headquarters and regional staff with respect to professional 

backgrounds and skillsets are an additional factor. These issues 

have not compromised Force-on-Force inspections; however, 

disagreements between headquarters and regional staff regarding 

procedures and policy can undermine NRC’s credibility with 

licensees and degrade staff morale. 

Coordination of Headquarters and Regional Efforts Benefits 

From Shared Understanding of Policies and Procedures

Improved coordination of headquarters and regional inspection 

activities would result from a shared understanding of policies and 

procedures, and open communication among staff. Internal control 

principles applicable to NRC recommend that agency managers 

communicate openly about policies and procedures, both internally 

with their staff and externally with licensees. In addition, agency 

managers should be conscious of issues affecting their agency’s 

internal control environment, including: 

 Organizational structure and delegation of authority. 

 Human capital policies and practices. 

 Employee morale, competence, and discipline. 

Headquarters and Regional Staff Differ Over Inspection 

Guidance and Approaches

Headquarters and regional staff differ over interpretation of some 

inspection guidance, and over approaches to conducting Force-onForce inspections. First, auditors found disagreements among 

some staff regarding NRC’s process for determining ownership of 

findings resulting from Force-on-Force inspections. Specifically, 

staff said NRC lacked clear direction regarding the scope of 

headquarters and regional responsibilities for developing and 

following up on findings. In addition, some regional staff expressed 
Audit of NRC’s Force-on-Force Inspection Program 

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concern that headquarters was assuming more responsibility for 

non-Force-on-Force baseline security issues, which have 

traditionally been the responsibility of NRC’s regional offices. This 

issue was eventually resolved during a May 2009 counterpart 

meeting involving headquarters and regional staff, and NSIR 

management agreed to clarify the inspection guidance. 

Second, headquarters and some regional staff differ in their 

interpretations about procedural standards for Intrusion Detection 

System (IDS) testing. These standards determine how Force-onForce teams “challenge test” licensees’ systems during the preexercise planning week. Challenge testing entails broader goals 

and fewer constraints than operational tests performed by 

licensees; thus, interpretation of NRC’s standards affects staff and 

licensee perceptions about whether Force-on-Force teams conduct 

challenge testing with an appropriate level of rigor.14 

Headquarters and some regional staff expressed differing views 

about headquarters teams' approaches to conducting Force-onForce inspections. The majority of regional staff interviewed 

characterized these inspections as excessively adversarial, and 

attributed this to what they perceive as an overly aggressive 

mentality among headquarters staff and the CAF. Further, a few 

regional staff believed Force-on-Force exercise scenarios 

developed by the headquarters based teams exaggerate real-world 

threats to power plants. In contrast, headquarters-based Force-onForce staff who expressed an opinion felt that that the exercises 

fairly test licensee security programs and appropriately fulfill NRC's 

regulatory15 and statutory16 requirements to evaluate licensees 

using credible, challenging scenarios reflecting DBT 

characteristics.17 

 

14 Force-on-Force teams conduct operational testing during the pre-exercise planning week to ensure 

licensees’ IDS equipment functions as designed and complies with standards in NRC Regulatory Guide 

5.44. Teams also conduct challenge testing, which probes the IDS for vulnerabilities that an adversary might 

exploit. According to IP 71130.03, challenge testing is to simulate DBT-adversary actions and is not 

bounded by NRC Regulatory Guide 5.44 Option 1 or 2 standards. 

15 NRC guidance requires inspection team leaders to select scenarios that challenge licensees’ protective 

strategies, and to ensure that scenarios target site-specific vulnerabilities. See IP 71130.03, p.31.

16 According to the 2005 Energy Policy Act, NRC shall conduct exercises that “to the maximum extent 

practicable, simulate security threats in accordance with any design basis threat applicable to a facility.” 

See Pub L. No. 109-58, “The 2005 Energy Policy Act,” §651, August 8, 2005. 

17 NRC Regulatory Guide 5.69 provides Force-on-Force teams guidance for planning and conducting 

exercises. IP 71130.03 includes an addendum, or “tactics guide,” to help inspection teams apply DBTadversary characteristics to exercise scenarios.
Audit of NRC’s Force-on-Force Inspection Program 

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Staff Differences Result From Rapid Program Change, Lack of 

Systematic Communication, and Other Factors

Differences between headquarters and regional staff interpretations 

of inspection guidance have resulted primarily from rapid program 

change and lack of systematic communication. The professional 

backgrounds of staff and team dynamics are additional factors. 

First, the Force-on-Force inspection program has undergone 

significant organizational and procedural changes since August 

2008. NSIR staff have briefed licensee personnel and industry 

representatives on these changes and their implications, yet policy 

and procedural changes have not been effectively communicated to 

regional staff in a systematic fashion. Regional managers said they 

communicate with NSIR management on an as-needed basis. 

Regional security inspectors learn of new policies and procedures 

by memos, e-mail, and their respective regional managers. Some 

information is communicated by headquarters-based staff to 

regional inspectors on site during Force-on-Force inspections. 

Counterpart meetings are another means of sharing information; 

however, several regional staff suggested that these meetings 

would be more beneficial if held on a routine basis. 

Second, regional and headquarters staff have different professional 

backgrounds, which influences team dynamics and inspection 

conduct. Regional physical security inspectors tend to have greater 

depth of experience with inspections and NRC’s regulatory 

processes. Both headquarters and regional staff consider on-thejob training important for developing key skills such as 

communicating with licensees and documenting findings. In 

contrast, most headquarters-based Force-on-Force team members 

have less than 2 years of experience conducting Force-on-Force 

inspections.18 However, all of the current Force-on-Force 

inspectors have previous military and/or law enforcement 

experience, which has some applicability to evaluating licensee 

security programs and planning offensive missions for exercises. 

This mix of personnel with different backgrounds, skills, and lengths 

 

18 The Force-on-Force program instituted formal training program for inspectors in the first quarter of FY 

2009. As of April 2009, 9 of 12 Force-on-Force inspectors were certified basic inspectors; one inspector 

was fully certified. 
Audit of NRC’s Force-on-Force Inspection Program 

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of service—which is inherent in Force-on-Force team 

composition—impacts inspection planning and conduct as Forceon-Force team leaders try to leverage individuals’ skills and apply 

lessons learned in conducting their work.19 

Staff Differences Can Undermine NRC’s Credibility With 

Licensees and Degrade Morale

Although the Force-on-Force program has management controls in 

place to ensure the consistency and transparency of inspections, 

lack of agreement on policy and procedures between regional and 

headquarters staff can undermine NRC’s credibility with licensees. 

Regional staff told auditors that they need clear understanding of 

agency policy so they can explain NRC’s actions to licensees. 

Otherwise, they risk contradicting their colleagues or misinforming 

licensee personnel, which can undermine the image of inspectors 

as competent, impartial regulators. Moreover, auditors found that 

unresolved disagreements between headquarters and regional staff 

can degrade morale by raising staff concerns about NSIR 

management’s receptiveness to their ideas and concerns. 

Recommendations 

OIG recommends that the Executive Director for Operations: 

1. Develop and implement a plan for routine communications 

between headquarters management and regional staff 

involved in the Force-on-Force program. 

2. Encourage cross-training and rotational opportunities for 

headquarters and regional staff involved in the Force-on-Force 

program. 

 

19 Based on interview feedback, auditors found that the role of regional inspectors in Force-on-Force 

inspections depends upon various factors such as inspection team needs, team leader prerogative, and 

regional inspectors’ seniority and expectations. 
Audit of NRC’s Force-on-Force Inspection Program 

12

IV. AGENCY COMMENTS 

At a July 21, 2009, exit conference, NRC senior managers agreed 

with the report contents and provided editorial suggestions. This 

final report incorporates revisions made, where appropriate, as a 

result of the agency’s suggestions. 
Audit of NRC’s Force-on-Force Inspection Program 

13

Appendix A 

Title 10, Code of Federal Regulations, Section 73.1a and b 

(a) Purpose. This part prescribes requirements for the 

establishment and maintenance of a physical protection system 

which will have capabilities for the protection of special nuclear 

material at fixed sites and in transit and of plants in which special 

nuclear material is used. The following design basis threats, where 

referenced in ensuing sections of this part, shall be used to design 

safeguards systems to protect against acts of radiological sabotage 

and to prevent the theft or diversion of special nuclear material. 

Licensees subject to the provisions of §73.20 (except for fuel cycle 

licensees authorized under Part 70 of this chapter to receive, 

acquire, possess, transfer, use, or deliver for transportation formula 

quantities of strategic special nuclear material), § 73.50, and 

§73.60 are exempt from § 73.1(a)(1)(i)(E), §73.1(a)(1)(iii), 

73.1(a)(1)(iv), §73.1(a)(2)(iii), and §73.1(a)(2)(iv). Licensees subject 

to the provisions of §72.212 are exempt from §73.1(a)(1)(iv). 

(1) Radiological sabotage. 

(i) A determined violent external assault, attack by stealth, or 

deceptive actions, including diversionary actions, by an adversary 

force capable of operating in each of the following modes: A single 

group attacking through one entry point, multiple groups attacking 

through multiple entry points, a combination of one or more groups 

and one or more individuals attacking through multiple entry points, 

or individuals attacking through separate entry points, with the 

following attributes, assistance and equipment: 

(A) Well-trained (including military training and skills) and 

dedicated individuals, willing to kill or be killed, with sufficient 

knowledge to identify specific equipment or locations necessary for 

a successful attack; 

(B) Active (e.g., facilitate entrance and exit, disable alarms and 

communications, participate in violent attack) or passive (e.g., 

provide information), or both, knowledgeable inside assistance; 

(C) Suitable weapons, including handheld automatic weapons, 

equipped with silencers and having effective long range accuracy; 

(D) Hand-carried equipment, including incapacitating agents and 

explosives for use as tools of entry or for otherwise destroying 

reactor, facility, transporter, or container integrity or features of the 

safeguards system; and 
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(E) Land and water vehicles, which could be used for transporting 

personnel and their hand-carried equipment to the proximity of vital 

areas; and 

(ii) An internal threat; and 

(iii) A land vehicle bomb assault, which may be coordinated with 

an external assault; and 

(iv) A waterborne vehicle bomb assault, which may be coordinated 

with an external assault; and 

(v) A cyber attack. 

(2) Theft or diversion of formula quantities of strategic special 

nuclear material. 

(i) A determined violent external assault, attack by stealth, or 

deceptive actions, including diversionary actions, by an adversary 

force capable of operating in each of the following modes: a single 

group attacking through one entry point, multiple groups attacking 

through one or more groups and one or individuals attacking 

through multiple entry points, or individuals attacking through 

separate entry points, with the following attributes, assistance and 

equipment: 

(A) Well-trained (including military training and skills) and 

dedicated individuals, willing to kill or be killed, with sufficient 

knowledge to identify specific equipment or locations necessary for 

a successful attack; 

(B) Active (e.g., facilitate entrance and exit, disable alarms and 

communications, participate in violent attack) or passive (e.g., 

provide information), or both, knowledgeable inside assistance; 

(C) Suitable weapons, including handheld automatic weapons, 

equipped with silencers and having effective long range accuracy; 

(D) Hand-carried equipment, including incapacitating agents and 

explosives for use as tools of entry or for otherwise destroying 

reactor, facility, transporter, or container integrity or features of the 

safe-guards system; 

(E) Land and water vehicles, which could be used for transporting 

personnel and their hand-carried equipment; and 

(ii) An internal threat; and 
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(iii) A land vehicle bomb assault, which may be coordinated with 

an external assault; and 

(iv) A waterborne vehicle bomb assault, which may be coordinated 

with an external assault; and 

(v) A cyber attack. 

(b) Scope

(1) This part prescribes requirements for: 

(i) The physical protection of production and utilization facilities 

licensed under parts 50 or 52 of this chapter, 

(ii) The physical protection of plants in which activities licensed 

pursuant to part 70 of this chapter are conducted, and 

(iii) The physical protection of special nuclear material by any 

person who, pursuant to the regulations in part 61 or 70 of this 

chapter, possesses or uses at any site or contiguous sites subject 

to the control by the licensee, formula quantities of strategic special 

nuclear material or special nuclear material of moderate strategic 

significance or special nuclear material of low strategic significance. 

(2) This part prescribes requirements for the physical protection of 

special nuclear material in transportation by any person who is 

licensed pursuant to the regulations in parts 70 and 110 of this 

chapter who imports, exports, transports, delivers to a carrier for 

transport in a single shipment, or takes delivery of a single 

shipment free on board (F.O.B.) where it is delivered to a carrier, 

formula quantities of strategic special nuclear material, special 

nuclear material of moderate strategic significance or special 

nuclear material of low strategic significance. 

(3) This part also applies to shipments by air of special nuclear 

material in quantities exceeding: (i) 20 grams or 20 curies, 

whichever is less, of plutonium or uranium-233, or (ii) 350 grams of 

uranium-235 (contained in uranium enriched to 20 percent or more 

in the U-235 isotope). 

(4) Special nuclear material subject to this part may also be 

protected pursuant to security procedures prescribed by the 

Commission or another Government agency for the protection of 

classified materials. The provisions and requirements of this part 

are in addition to, and not in substitution for, any such security 

procedures. Compliance with the requirements of this part does 
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not relieve any licensee from any requirement or obligation to 

protect special nuclear material pursuant to security procedures 

prescribed by the Commission or other Government agency for the 

protection of classified materials. 

(5) This part also applies to the shipment of irradiated reactor fuel 

in quantities that in a single shipment both exceed 100 grams in net 

weight of irradiated fuel, exclusive of cladding or other structural or 

packaging material, and have a total radiation dose in excess of 

100 rems per hour at a distance of 3 feet from any accessible 

surface without intervening shielding. 

(6) This part prescribes requirements for the physical protection of 

spent nuclear fuel and high-level radioactive waste stored in either 

an independent spent fuel storage installation (ISFSI) or a 

monitored retrievable storage (MRS) installation licensed under part 

72 of this chapter, or stored at the geologic repository operations 

area licensed under part 60 or part 63 of this chapter. 

(7) This part prescribes requirements for the protection of 

Safeguards Information (including Safeguards Information with the 

designation or marking: Safeguards Information—Modified 

Handling) in the hands of any person, whether or not a licensee of 

the Commission, who produces, receives, or acquires that 

information. 

(8) This part prescribes requirements for advance notice of export 

and import shipments of special nuclear material, including 

irradiated reactor fuel. 

(9) As provided in part 76 of this chapter, the regulations of this 

part establish procedures and criteria for physical security for the 

issuance of a certificate of compliance or the approval of a 

compliance plan. 
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Appendix B 

SCOPE AND METHODOLOGY 

The objective of this audit was to evaluate NRC’s Force-on-Force 

inspection program to determine if design and implementation of 

the program are consistent, thorough, reasonable, and in 

accordance with NRC standards. The audit focused on the 

program’s development from the first triennial inspection cycle 

through the current second triennial inspection cycle. 

Auditors reviewed Federal Government laws and regulations 

applicable to the Force-on-Force inspection program, including: 

 The 2005 Energy Policy Act, Section 651. 

 10 Code of Federal Regulations, Sections 73.1 and 73.55. 

Auditors also reviewed NRC guidance governing baseline security 

inspection procedures, regulatory processes, employee training 

standards, and regulatory implementation guidance issued to 

licensees. Guidance included: 

 Inspection Procedure 71130.03: Contingency Response.

 Inspection Procedure 71130.04: Equipment Performance, 

Testing, and Maintenance. 

 Inspection Procedure 71130.05: Protective Strategy Review. 

 Inspection Manual Chapter 0609, Appendix E: Baseline Security 

Significance Determination Process for Power Reactors. 

 Inspection Manual Chapter 1245, Qualification Program for the 

Office of the Nuclear Reactor Regulation Program. 

 Regulatory Guide 5.44, Perimeter Intrusion Alarm Systems. 

 Regulatory Guide 5.69, Guidance for the Application of the 

Radiological Sabotage Design-Basis Threat in the Design. 

 Development, and Implementation of a Physical Security 

Program that Meets 10 CFR 73.55 Requirements. 

Auditors interviewed NSIR managers, Force-on-Force inspectors, 

security risk analysts, and security inspectors and managers from 

all four NRC regional offices to identify their respective roles 

responsibilities in the program. Staff with experience in both the 

first and second inspection cycles were asked to compare and 

contrast the two cycles, and to comment on programmatic changes 

undertaken since the first inspection cycle. Auditors reviewed email correspondence and observed a secure video-teleconference 

involving headquarters and regional staff to corroborate interviews 
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and better understand internal deliberations over policy and 

procedure. Auditors interviewed industry representatives and 

licensee personnel to gather external perspectives on program 

performance and NRC management’s receptivity to industry 

concerns. In addition, auditors observed two Force-on-Force 

inspections and one industry outreach conference. 

Auditors reviewed staff training records to verify NRC’s new training 

and qualification tracking mechanism for Force-on-Force staff. 

Auditors analyzed budget and FTE data to measure program 

resource trends, and also analyzed time and attendance data to 

measure workload associated with Force-on-Force inspections. 

OIG conducted this audit between January 2009 and June 2009 in 

accordance with generally accepted Government auditing 

standards. Those standards require that we plan and perform the 

audit to obtain sufficient, appropriate evidence to provide a 

reasonable basis for our findings and conclusions based on our 

audit objectives. We believe that the evidence obtained provides a 

reasonable basis for our finding and conclusions based on our audit 

objective. 

Major contributors to this report were: Beth Serepca, Team Leader; 

Paul Rades, Audit Manager; Jaclyn Storch, Senior Analyst; and 

Maxinne Lorette, Senior Auditor.