UNITED STATES

NUCLEAR REGULATORY COMMISSION 

WASHINGTON, D.C. 20555-0001 

October 5, 2016 

MEMORANDUM TO: Victor M. McCree 

 Executive Director for Operations 

FROM: Annette L. Vietti-Cook, Secretary /RA/ 

SUBJECT: STAFF REQUIREMENTS – SECY-16-0073 – OPTIONS AND 

RECOMMENDATIONS FOR THE FORCE-ON-FORCE 

INSPECTION PROGRAM IN RESPONSE TO SRM-SECY-14-

0088 

The Commission has approved the staff's recommended Option 2, to conduct an assessment of 

the security baseline inspection program, including Force-on-Force (FOF), as limited and 

conditioned by the comments below. The Commission has also approved the staff's 

recommendation to terminate the FOF Tactics, Techniques, and Procedures Working Group 

and conduct any necessary follow-on activities within the program offices. 

In implementing the assessment called for in Option 2, the staff should avoid attempting a 

fundamental redesign of the program. Rather, the staff should conduct a review limited to those 

areas that are the most likely to yield improvements and efficiencies, considering both internal 

and external feedback. The staff should include the following issues in its evaluation to 

determine whether crediting of operator actions; the use of FLEX equipment; or response by 

local, State, and Federal law enforcement would make the FOF exercises more realistic. 

1. Evaluate how vulnerability assessments could be used to evaluate the effectiveness 

of licensee protective strategies, and whether credit could be given for operator 

actions or for the use of additional equipment such as "flex equipment," which was 

installed to enhance safety but can also provide a security benefit. 

2. Evaluate whether the NRC should provide any credit for local, State, or Federal law 

enforcement response to establish coping time for security events. This evaluation 

should be accompanied by a discussion of next steps for the existing integrated 

response program. 

Prior to any staff assessment of the industry proposal that rather than NRC conducting FOF 

exercises, the NRC should observe and evaluate licensee conducted FOF exercises, the Office 

of the General Counsel (OGC) shall complete a legal analysis on this matter. The legal analysis 

provided by OGC to the staff should also be provided to the Commission. 

The staff should submit a notation vote paper to the Commission within 12 months from the date 

of this Staff Requirements Memorandum with recommendations on improvements to the 

security inspection program. 

In implementing the NRC's regulatory program, either in developing new regulations, inspecting 

licensee compliance with regulations, or executing the FOF program, the staff should be mindful 
that the concept of “high assurance” of adequate protection found in our security regulations is 

equivalent to “reasonable assurance” when it comes to determining what level of regulation is 

appropriate. The NRC should not be applying a “zero risk” mentality to security any more than 

we should be doing so with respect to safety. The staff should operate under this paradigm and 

eliminate ambiguity on this point in its guidance documents or other internal directives, 

instructions, or training materials, to the extent such ambiguity exists.

The staff should not create a new NRC guidance document to house operating experience 

associated with the FOF program. Such operating experience is more traditionally and 

effectively housed in and disseminated through industry guidance, endorsed by the NRC. 

Consequently, FOF operating experience, to the extent not documented elsewhere, should be 

consolidated into existing industry guidance documents. 

cc: Chairman Burns 

 Commissioner Svinicki 

 Commissioner Baran 

 OGC 

 CFO 

 OCA 

 OPA 

ODs, RAs, ACRS, ASLBP (via E-Mail) 

PDR