September 11, 2015 

MEMORANDUM TO: Chairman Burns COMSECY-15-0025

Commissioner Svinicki 

Commissioner Ostendorff 

Commissioner Baran 

FROM: Mark. A. Satorius /RA Michael Johnson Acting for/

Executive Director for Operations 

SUBJECT: PROPOSED REVISION TO THE NOTIFICATION PROCESS FOR 

FORCE-ON-FORCE INSPECTIONS 

The purpose of this memorandum is to propose to the Commission to revise the approach for 

notifying nuclear power plant licensees of upcoming U.S. Nuclear Regulatory Commission 

(NRC)-conducted force-on-force (FOF) exercises to align with the Reactor Oversight Process 

(ROP). Under the revised approach, the planned FOF inspection dates would be included in 

the 15-month inspection plan provided to licensees during Mid-Cycle and End-of-Cycle 

Assessments, consistent with Inspection Manual Chapter 0305, “Operating Reactor 

Assessment Program.”1

 

In SECY-04-0083, “Final Report on the Pilot Expanded Force-on-Force Exercise Program with 

Lessons Learned and Recommendations for Future Activities,” dated May 14, 2004, the staff 

recommended that licensees be given an 8-week, but no more than a 12-week notification prior 

to an NRC-conducted FOF inspection. The staff’s position at that time was that a longer 

notification window might not provide as accurate an assessment of typical security force 

readiness. In Staff Requirements Memorandum, SECY-04-0083, dated August 13, 2004, the 

Commission approved the staff’s recommendation, and stated that the staff should inform the 

Commission of their evaluation of the possibility of extending the licensee notification window 

following the transition from the FOF pilot program to evaluated triennial exercises. In 

SECY-04-0174, the staff committed to monitoring the 8-to-12-week notification window to 

determine if any adjustments were necessary. 

CONTACT: Clay Johnson, NSIR/DSO 

 (301) 287-3688 

 

1

 While the ROP does not apply to Category I fuel cycle facilities, they would be notified along timeframes similar to 

those for power reactor licensees.
The Commissioners -2- 

Since SECY-04-0083 was issued, the NRC has completed three triennial FOF inspection 

cycles. In that time, the NRC and licensees have identified issues with the current notification 

timeline that have created challenges in coordinating site activities with the FOF inspection 

schedule, such as outages, delivery schedules, training, and assistance visits. A longer 

notification window will minimize disruption to both NRC and licensee activities. Both 

headquarters and regional staff are often challenged by the FOF inspection schedule for 

potential conflicts with other NRC inspection activities because the FOF inspection dates are 

not currently included in the Reactor Program System (RPS), and are not noticed as far in 

advance as other at-facility NRC activities. The RPS Inspection Planning (IP) application 

integrates all site and inspection activities, including the Institute of Nuclear Power Operations’ 

activities and outages. Inclusion of FOF inspections into the IP application will increase the 

efficiency of the NRC inspection program. It will also allow licensees to budget more 

accurately, better coordinate support for work hour controls for personnel involved in exercise 

activities, and arrange for controllers coming from other sites. Finally, a notification window 

that is consistent with licensee notifications of other NRC activities will provide the NRC staff 

with greater flexibility to coordinate FOF inspections within the broader NRC inspection 

program, and in adjusting the FOF inspection schedule based upon those other activities, as 

appropriate, while still ensuring triennial NRC-conducted exercises. For example, if the FOF 

inspection schedule needs to be adjusted due to an unplanned event, such as severe weather, 

the NRC staff will be able to coordinate new proposed dates. Currently, this can be 

challenging because of the need to avoid informing licensees of a potential inspection date 

earlier than 8 to 12 weeks in advance. 

The staff believes that it has sufficient experience implementing the FOF inspection program to 

address the concerns presented in SECY-04-0083. Recent enhancements to the security 

inspection program have included NRC observation of licensee-conducted FOF exercises. 

These observations provide the NRC with additional insights to licensees’ security programs 

and provide additional confidence that the licensees’ security forces are being trained 

effectively. If the Commission approves this change to the licensee notification process, the 

staff will continue to monitor the FOF inspection program to ensure it accurately assesses 

licensee security force readiness and performance. 

The staff believes that changing the advanced notification period to licensees of FOF 

inspections from 8 to 12 weeks, to 9 to 15 months, consistent with the ROP, will minimize 

disruptions to the NRC and licensees without impacting the integrity of the inspection program, 

and will better align the FOF inspection program with the ROP. The staff intends to inform the 

Commission if it believes that any subsequent adjustments are needed. 

The Office of the General Counsel has reviewed this memorandum and has no legal objection. 

SECY, please track. 

cc: SECY 

 OGC 

 CFO 

 OPA 

 OCA 
The Commissioners -2- 

Since SECY-04-0083 was issued, the NRC has completed three triennial FOF inspection 

cycles. In that time, the NRC and licensees have identified issues with the current notification 

timeline that have created challenges in coordinating site activities with the FOF inspection 

schedule, such as outages, delivery schedules, training, and assistance visits. A longer 

notification window will minimize disruption to both NRC and licensee activities. Both 

headquarters and regional staff are often challenged by the FOF inspection schedule for 

potential conflicts with other NRC inspection activities because the FOF inspection dates are 

not currently included in the Reactor Program System (RPS), and are not noticed as far in 

advance as other at-facility NRC activities. The RPS Inspection Planning (IP) application 

integrates all site and inspection activities, including the Institute of Nuclear Power Operations’ 

activities and outages. Inclusion of FOF inspections into the IP application will increase the 

efficiency of the NRC inspection program. It will also allow licensees to budget more 

accurately, better coordinate support for work hour controls for personnel involved in exercise 

activities, and arrange for controllers coming from other sites. Finally, a notification window 

that is consistent with licensee notifications of other NRC activities will provide the NRC staff 

with greater flexibility to coordinate FOF inspections within the broader NRC inspection 

program, and in adjusting the FOF inspection schedule based upon those other activities, as 

appropriate, while still ensuring triennial NRC-conducted exercises. For example, if the FOF 

inspection schedule needs to be adjusted due to an unplanned event, such as severe weather, 

the NRC staff will be able to coordinate new proposed dates. Currently, this can be 

challenging because of the need to avoid informing licensees of a potential inspection date 

earlier than 8 to 12 weeks in advance. 

The staff believes that it has sufficient experience implementing the FOF inspection program to 

address the concerns presented in SECY-04-0083. Recent enhancements to the security 

inspection program have included NRC observation of licensee-conducted FOF exercises. 

These observations provide the NRC with additional insights to licensees’ security programs 

and provide additional confidence that the licensees’ security forces are being trained 

effectively. If the Commission approves this change to the licensee notification process, the 

staff will continue to monitor the FOF inspection program to ensure it accurately assesses 

licensee security force readiness and performance. 

The staff believes that changing the advanced notification period to licensees of FOF 

inspections from 8 to 12 weeks, to 9 to 15 months, consistent with the ROP, will minimize 

disruptions to the NRC and licensees without impacting the integrity of the inspection program, 

and will better align the FOF inspection program with the ROP. The staff intends to inform the 

Commission if it believes that any subsequent adjustments are needed. 

The Office of the General Counsel has reviewed this memorandum and has no legal objection. 

SECY, please track. 

cc: SECY 

 OGC 

 CFO 

 OPA 

 OCA 

Distribution: 

DSO R/F RidsNSIRMailCenterResource RidsEDOMailCenterRecource SECY 

ADAMS Accession No. ML15231A232 

OFFICE NSIR/DSO NSIR/DSO/SPEB NSIR/DSO NRR/DIRS OGC NSIR/OD EDO 

NAME M. Ralph via 

e-mail 

C. Johnson M. Layton S. Morris AGendelman 

NLO 

B. Holian M. Satorius 

(MJohnson 

for) 

DATE 8/18/15 8/6/15 8/20/15 8/21/15 09/01/15 09/04/15 09 / 11/15 

OFFICIAL RECORD COPY