July 25, 2016 

MEMORANDUM TO: Chairman Burns 

Commissioner Svinicki 

Commissioner Baran 

FROM: Victor M. McCree /RA/ 

Executive Director for Operations 

SUBJECT: PROPOSED REVISION TO THE NOTIFICATION PROCESS FOR 

FORCE-ON-FORCE INSPECTIONS 

The purpose of this memorandum is to request Commission approval to revise the process for 

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

(NRC)-conducted force-on-force (FOF) exercises to maintain alignment with the Reactor 

Oversight Process (ROP).1 Specifically, the staff is requesting that the Commission approve 

adjusting the 9 to 15 month FOF inspection notification window to 24 months, consistent with 

recent revisions to the ROP notification process, as described in Inspection Manual Chapter 

(IMC) 0305, “Operating Reactor Assessment Program” (Agencywide Documents Access and 

Management System (ADAMS) No. ML15317A147) dated December 23, 2015. 

In COMSECY-15-0025, “Proposed Revision to the Notification Process for Force-on-Force 

Inspections” dated September 11, 2015 (ADAMS Accession No. ML15231A232), the staff 

recommended that the Commission approve revising the notification window for FOF 

inspections from 8 to 12 weeks to 9 to 15 months. This recommendation was intended to 

make FOF notifications consistent with the ROP, minimize potential disruptions to the NRC and 

licensees without impacting the integrity of the inspection program, and better align the FOF 

inspection program with the ROP. The Commission approved this recommendation in 

SRM-COMSECY-15-0025, dated October 6, 2015 (ADAMS Accession No. ML15279A468). 

On December 23, 2015, the Office of Nuclear Reactor Regulation issued a change to 

IMC 0305. This change increased the ROP inspection planning notification timeframe from 18 

months to 24 months following the end of the ROP assessment period. 

CONTACT: Jefferson Clark, NSIR/DSO 

 (301) 287-3666 

 

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.

COMSECY-16-0016

PLEASE RESPOND BY: 

August 10, 2016 
The Commissioners -2- 

As articulated in COMSECY-15-0025, the staff requested Commission approval to align the 

FOF notification window with the ROP notification process because both headquarters and 

regional staff were challenged when FOF inspections were not noticed as far in advance as 

other at-facility NRC activities and, therefore, not included in the Reactor Program System 

(RPS). The RPS Inspection Planning (IP) application integrates all site and inspection 

activities, including the Institute of Nuclear Power Operations’ activities and outages. When 

the FOF notifications are not included in the RPS IP application, the NRC staff has limited 

flexibility to coordinate FOF inspections with other NRC inspections and onsite activities. 

Inclusion of FOF inspections into the RPS IP application increases the efficiency of the NRC 

inspection program and provides the NRC staff with greater flexibility to coordinate FOF 

inspections within the broader NRC inspection program by using the RPS IP application. The 

staff believes that changing the advanced notification period for FOF inspections to 24 months 

to maintain consistency with the ROP will not have a negative impact to the FOF inspection 

program. The staff will engage the Commission if it identifies any subsequent adjustments 

needed to the FOF notification process. 

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

SECY, please track. 

cc: SECY 

 OGC 

OCA 

 OPA 

 CFO 

 
The Commissioners -2- 

As articulated in COMSECY-15-0025, the staff requested Commission approval to align the 

FOF notification window with the ROP notification process because both headquarters and 

regional staff were challenged when FOF inspections were not noticed as far in advance as 

other at-facility NRC activities and, therefore, not included in the Reactor Program System 

(RPS). The RPS Inspection Planning (IP) application integrates all site and inspection 

activities, including the Institute of Nuclear Power Operations’ activities and outages. When 

the FOF notifications are not included in the RPS IP application, the NRC staff has limited 

flexibility to coordinate FOF inspections with other NRC inspections and onsite activities. 

Inclusion of FOF inspections into the RPS IP application increases the efficiency of the NRC 

inspection program and provides the NRC staff with greater flexibility to coordinate FOF 

inspections within the broader NRC inspection program by using the RPS IP application. The 

staff believes that changing the advanced notification period for FOF inspections to 24 months 

to maintain consistency with the ROP will not have a negative impact to the FOF inspection 

program. The staff will engage the Commission if it identifies any subsequent adjustments 

needed to the FOF notification process. 

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

SECY, please track. 

cc: SECY 

 OGC 

 OCA 

 OPA 

CFO 

DISTRIBUTION: 

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SECY 

ADAMS Accession No. ML16167A168 

OFFICE NSIR/DSO NSIR/DSO/SPEB NSIR/DSO/SOSB NSIR/DSO 

NAME M. Ralph J. Willis D. Huyck M. Layton (D. Pretzello for) 

DATE 06/15/16 06/15/16 06/16/16 06/16/16 

OFFICE NRR/DIRS OGC NSIR/OD EDO 

NAME C. Miller (via email) N. StAmour (via email) B. Holian V. McCree 

DATE 06/23/16 7/14/16 7/20/16 7/24/16 

OFFICIAL RECORD COPY