NEI 11-08 [Revision 0] 

Guidance on Submitting

Security Plan Changes 

August 2012 
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Nuclear Energy Institute, 1776 I Street N. W., Suite 400, Washington D.C. (202.739.8000) 

NEI 11-08 [Revision 0] 

Nuclear Energy Institute 

Guidance on Submitting

Security Plan Changes 

August 2012 
UACKNOWLEDGMENTS 

This document, Guidance for Submitting Security Plan Changes, NEI 11-08 was developed in a 

joint effort by NEI, NRC, and industry members of the Rulemaking Task Force who possess a 

broad range of experience in security and regulatory matters. NEI wishes to acknowledge the 

extensive review and comment by these industry members and personnel who shaped the final 

form of this document. 

UNOTICE

Neither NEI, nor any of its employees, members, supporting organizations, contractors, or 

consultants make any warranty, expressed or implied, or assume any legal responsibility for the 

accuracy or completeness of, or assume any liability for damages resulting from any use of, any 

information apparatus, methods, or process disclosed in this report or that such may not 

infringe privately owned rights. 
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i 

U

EXECUTIVE SUMMARY 

Nuclear Energy Institute (NEI) is issuing this guidance to provide information for licensees to 

consider when making a determination relative to the appropriate licensing action under which 

change(s) to the security plans required under the provisions of 10 CFR Part 50, sections 

50.34(c) and 50.34(d), can be made. The required security plans consist of the Physical security 

Plan (PSP), Training and Qualification Plan (T&QP), Safeguards Contingency Plan (SCP), and 

the Cyber Security Plan (CSP). This guidance is intended to assist the licensee in determining 

the appropriate licensing action for a specific security plan change and the types of information 

that should be identified, reviewed, and analyzed to support the determination or conclusion that 

the security plan change meets the provisions of 10 CFR 50.90 or 50.54(p), prior to submitting 

the security plan to the U.S. Nuclear Regulatory Commission (NRC). However, the guidance 

contained within this document does not determine for the licensee whether a 50.90 or a 50.54(p) 

is the appropriate licensing action. The licensee is responsible for making the final 

determination for what type of licensing action is submitted to the NRC for each plan change 

made. 

a. Licensees who submit a security plan change that would decrease the safeguards 

effectiveness of the PSP, T&QP, CSP, and/or SCP must submit an application for 

licensee amendment to the NRC for review and approval prior to implementing the 

security plan change in accordance with 10 CFR 50.90. 

b. Licensees who submit a security plan change that does not decrease the safeguards 

effectiveness of the PSP, T&QP, CSP, and/or SCP are required to submit a report 

containing a description of each security plan change within two months after the security 

plan change is implemented at the site, in accordance with 10 CFR 50.54(p)(2). 

This guidance provides analytical concepts and technical information that can be applied to all 

proposed security plan changes. The examples provided in this guidance and Attachment 1 

should be considered by licensees who choose to utilize ROWS technology as a component of 

their site protective strategy. 

In November 2011, the NRC endorsed Revision 7 of NEI 03-12 “Template for the Security Plan, 

Training and Qualification Plan, Safeguards Contingency Plan, [and Independent spent Fuel 

Storage Installation Security Program],” dated October 2011, hereafter referred to as the 

“Security Plan Template.” Revision 7 of the Security Plan Template contains generic language 

that, if applicable to the site-specific conditions, may be used by licensees choosing to implement 

ROWS as part of the site protective strategy. In addition to the generic language for ROWS 

provided in Revision 7 of the Security Plan Template, the licensee should also consider 

appropriate changes to the site CSP relative to the digital/cyber based features of ROWS. 

Regardless of the nature of the plan change the licensee makes, it is the responsibility of the 

licensee to ensure that all security plan changes are consistent with regulatory requirements and 

are described in the security plans. Where the generic language contained in the Security Plan 

Template is not applicable or does not adequately describe site-specific conditions, the licensee 
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should consider providing appropriate site-specific information to the security plan to ensure that 

the nature of the plan change is clearly described and how implementation of the security plan 

change will satisfy regulatory requirements. 

For those licensees who are considering a security plan change that will reduce the staffing levels 

for armed responders (AR) and/or armed security officers (ASO), or will add, modify, or remove 

a security measure, the licensee must submit information that is sufficient for the NRC to 

understand the nature of the change, the impacts that the change will have on the licensee’s 

security program, and the impact that the change will have on the continued ability of the 

licensee to meet regulatory and security plan requirements. Licensees should identify in their 

security plan change submittal, the purpose for the plan change, supporting information gained 

through the analysis conducted, and description/explanation of how the plan change (i.e., 

reduction in staffing levels or removal of a security measure associated with ROWS) does not 

reduce the safeguards effectiveness of the security plan(s). The submitted plan change should 

describe how actions required by the site protective strategy continue to be accomplished in 

conjunction with explaining how the reduction in staffing levels or removal of security measures 

continues to meet the requirements of 10 CFR 73.55, “Requirements for Physical Protection of 

Licensed Activities in Nuclear Power Reactors Against Radiological Sabotage” and other 

security plan requirements. 
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UTABLE OF CONTENTS 

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

1 0BSECURITY PLAN CHANGE ITEMS TO CONSIDER ...................................................... 1

1.1 ANALYZE CHANGE .........................................................................................................2

2 1BSECURITY PLAN CHANGE EVALUATION CRITERIA ................................................... 4

3 SECURITY PLAN CHANGE EVALUATION CRITERIA FOR ROWS ............................... 7

4 SECURITY PLAN CHANGE TEMPLATE ....................................................................... 8

ATTACHMENT 1: AREAS OF CONSIDERATION FOR ROWS IMPLEMENTATION ............ A-1
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UGUIDANCE ON SUBMITTING SECURITY PLAN CHANGES 

1 0BSECURITY PLAN CHANGE ITEMS TO CONSIDER 

A thorough review and analysis is necessary for each security plan change. Changes made 

to one section of a security plan may impact other sections of the security plan/plans, and/or 

the licensee’s continued ability to meet regulatory and security plan requirements. It is 

necessary that each licensee identify impacts through review and analysis to determine if a 

reduction of safeguards effectiveness is realized in other areas of the security program not 

specifically being addressed by the security plan change. 

The licensee should identify and consider the impacts that a change in strategy will 

ultimately have on existing site security programs and whether those programs continue to 

meet security plan and regulatory requirements. The licensee should provide as part of the 

security plan change submittal, an evaluation of the identified impacts to site security 

programs and an explanation of how these programs continue to meet regulatory and 

security plan requirements. 

Regardless of the licensing action that is determined to be appropriate for a given plan 

change, the licensee should provide, as part of the security plan change submittal package, a 

detailed explanation of what the plan change is trying to accomplish and the rationale 

supporting the licensee’s conclusion that the licensing action taken is appropriate. 

If the intent is to remain within the requirements of a 50.54(p), the licensee should provide a 

detailed explanation of what has been changed and how it does not decrease in the 

safeguards effectiveness of the security plan. For example, in the case of ROWS, items to 

consider include, but not limited to: 1) describe how a reduction in staffing levels and/or 

addition, modification or removal of a site security measure, does not reduce the 

effectiveness of the security plan or protective strategy, including how the functions that 

were previously required are absorbed, modified or no longer required, 2) in regards to 

staffing level reductions, whether the change involves a reduction in Armed Responders, 

Armed Security Officers, or both, and; 3) the licensee should explain as part of the security 

plan change submittal, how the security plan change continues to provide high assurance 

through the effective implementation of the security plans and site protective strategy. 

Where a licensee intends to make security plan changes such as the installation of new 

equipment (i.e., ROWS) the following areas or types of information should be identified, 

reviewed, and analyzed for impacts to determine the appropriate licensing action and a 

summary of the analysis should be included to support the licensee’s conclusion. 
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1.1 ANALYZE CHANGE

a. Identify the nature of the security plan change being made (e.g., installation or 

removal of equipment only; installation or removal of equipment with strategy 

changes; installation or removal of equipment with other physical changes; 

installation or removal of equipment with procedural changes; adding or subtracting 

responders; etc.) 

b. Identify and analyze impacts: The licensee should review and analyze all program 

areas to identify the impact the security plan change will have to related security 

program components, equipment, personnel and/or implementing procedures. Where 

impacts are identified, the licensee should ensure that appropriate corresponding 

changes are made to the affected security plans and procedures to account for the 

identified impacts, and to verify the continued ability to meet security plan and 

regulatory requirements in all program areas. If personnel are being moved or 

reduced, identify the functions that are or were performed by each position to ensure 

that all previously assigned functions are accounted for and can be effectively 

performed whether directly or indirectly related to the specific change being made. 

Where functions must be re-assigned, the licensee should also review and analyze the 

impact that this additional change will have on the affected program area or position. 

c. Summarize the analysis: The licensee should summarize the methodology used to 

review and analyze the change and explain the rationale supporting the basis for 

conclusions made. For example: The licensee installs a new physical barrier 

designed to funnel personnel to a designated area. The licensee re-locates one AR to 

the east to cover the funneling channel created by the new barrier and a camera is 

installed for surveillance of the new barrier. The AR was previously assigned to 

provide surveillance of an area to the west of the previous position concurrent with 

surveillance by an ASO positioned further to the west. This function is now 

reassigned to an ASO. The strategy is impacted because now only the ASO is able to 

engage in that area, however, the new barrier will force the adversary movement to 

the east along the funneling channel where the AR will engage. 

d. Compensatory measures: Identify what compensatory measures would be taken upon 

loss of the new equipment. Can compensatory measures be taken within appropriate 

time-lines and are new staffing numbers sufficient to support compensatory 

measures? If personnel staffing levels are reduced, are sufficient numbers of armed 

personnel available to ensure that all security plan and regulatory requirements are 

met for all other program areas to include when compensatory measures are used? 

e. The licensee should consider , as part of the review and/or analysis process, the 

licensing basis established by the licensee’s Final Safety Analysis report consistent 

with the requirements of 10 CFR 50.59, 50.90, and 50.54(p), to ensure that the 

licensing basis is maintained. This determination can have a direct impact on the 

licensee’s final determination regarding the appropriate type of licensing action to be 
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taken for the specific security plan change being considered/made. For example, 

licensees planning to implement ROWS should identify and analyze potential 

consequences to both on-site and off-site equipment, structures, and personnel. 

f. Describe how regulatory compliance, plan commitments, implementing procedures, 

and daily functions are maintained throughout incorporation of the change. For 

example; has the licensee performed a vehicle bomb blast analysis that considers the 

location of the new equipment as well as required personnel to ensure that the loss of 

the new equipment and specified personnel does not prevent an effective response? 
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2 1BSECURITY PLAN CHANGE EVALUATION CRITERIA 

The following information should be considered by the licensee when reviewing and 

analyzing a security plan change. Although these items are not all inclusive, they provide a 

general overview of the specific types of information that should be considered when 

conducting a security plan change review and analysis, as well as what information should 

be included in the written security plan change submittal package. The licensee should 

provide as part of the security plan change submittal, in-depth information and explanation 

of impact that the plan changes have on the safeguards effectiveness of the security plans. 

For example, those licensees who are considering a plan change specific to the 

implementation of ROWS, such as a reduction in staffing levels, the licensee should provide 

an in-depth explanation for how the specific functions that were previously performed by 

personnel are now being performed by the ROWS and/or are re-assigned to other personnel. 

The review and analysis process should consider, but is not limited to the following: 

1. Review the change against all requirements contained in 10 CFR 73.55. Pay particular 

attention to unintended impacts to the regulation. For example, will removing a fence 

impact the access control requirements as stated in the rule? Will a reduction in 

responder numbers adversely impact the ability to perform functions necessary for OCA 

vehicle checkpoint operations? 

 Protective strategy (e.g., minimum number of armed personnel, timelines, equipment 

or systems necessary to prevent significant core damage and spent fuel sabotage), 

 Blast analysis; determine the minimum stand-off distance and location of the vehicle 

barrier system to include the protection of ROWS hardware, ROWS supporting 

structures, ROWS operators, and personnel or equipment used to compensate for 

inoperable ROWS. 

 ROWS operator’s normal duties, as well as actions, capabilities, and timelines, etc., 

in the event that the ROWS become inoperable during a contingency event. 

 Access control measures used to control access to the various ROWS operator 

controls. 

 Testing and Maintenance of ROWS to include test firing from a representative 

facsimile using both stationary and moving targets. 

2. Review the change against all security plans and regulatory requirements to determine 

potential impacts across the document to include all appendices. If impacts are realized, 

determine if a reduction of safeguards effectiveness exists. 

3. Review the security plan change against the requirements of 10 CFR 73.58, 

“Safety/Security Interface Requirements for Nuclear Power Reactors.” 

 Locations of the ROWS systems, ensuring ROWS does not have a negative impact 

on plant equipment and operations. 
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 Type of safety measures or inherent safety features to minimize the potential for the 

ROWS to inadvertently transition to the firing mode or have an unintentional 

discharge. 

 ROWS fields of fire include lateral and elevation limitations that ensure safety 

components at the site are not adversely affected during the initiation of the 

protective strategy and firing of ROWS mounted weapons. 

 ROWS vendors’ commitment to safety features and controls recommended by 

Interagency ROWS Working Group (IROWS). 

4. Evaluation of compensatory measures for new equipment that is being committed to in 

the security plan. The licensee should determine that the compensatory measures that 

would be instituted for loss of new equipment do not have an adverse impact on: a) the 

site protective strategy; b) implementation of other plan requirements, and/or; c) 

implementation of regulatory requirements. For example, if ROWS is being 

implemented, compensatory measures for its loss should consider measures that were 

effectively implemented within previous site protective strategies. If the compensatory 

measures for the loss of ROWS do not equate to the same level of effectiveness as 

measures implemented within previous site protective strategies, a detailed review and 

analysis should be conducted to fully characterize the nature of the compensatory 

measures and the differences between the compensatory measures and the previous 

protective strategy. 

 Compensatory measures implementing procedures for partial or catastrophic system 

failures. 

 Communication capabilities provided to the ROWS operators that enable continuous 

communications with the alarm stations during the performance of duty. 

 Environmental impact on the ROWS components operation, function, and/or 

potential to degrade ROWS performance as a result of the site’s geographical 

location. 

 ROWS components and back-up power sources. 

5. Evaluation of training impacts for new equipment. An evaluation should be performed 

to ensure that the appropriate training and qualification criteria for new equipment are 

addressed in the training and qualification plan prior to the installation and/or 

implementation of new equipment. Each licensee should take into account the duties 

and responsibilities that are assigned to each position and the specific knowledge, skills, 

and abilities required to effectively use the new equipment in the performance of the 

assigned duties and responsibilities. 

 ROWS operators are provided training and qualification on all elements (weapons & 

tactical) identified in the 10 CFR Part 73, Appendix B VI. 
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 Firearms instructors are trained, qualified, and certified by a national or state 

recognized entity on the use of the firearm. 

 ROWS instructors are trained and qualified to operate ROWS and if applicable, 

certified, to instruct others to operate ROWS in accordance with the manufacturer 

specifications on the use of ROWS. 

 The use of ROWS and the actions required of ROWS operators are incorporated into 

Quarterly Shift Drills and Annual Force on Force exercises. 

 Personnel who perform maintenance, testing, calibration, and repairs to ROWS and 

ROWS firearms are qualified to perform these functions in accordance with the 

ROWS and firearms manufacturer’s specification and site procedures. 

 Armorer(s) are trained and qualified in accordance with Appendix B to 10 CFR Part 

73 and possess a current certification for the specific firearm utilized with the 

ROWS. 

 Law enforcement agency support and capabilities. 

6. For reduction of armed responders/armed security officers, the evaluation approach is 

much the same for those above. A breakout of the differences in numbers from previous 

commitments needs to show the change. A summary of how this aspect was evaluated 

needs to be included in sufficient detail to allow a reviewer to understand the details of 

the evaluation, and how the conclusion for the determination was reached. Examples 

would include: a) spelling out the number of tabletop drills, limited scope drills, and 

exercises that were conducted using the reduced number of personnel, and; b) describing 

the difference between internal responders vs. external responders used in the previous 

protective strategy, to include definitive reasons for why the change is not a reduction of 

effectiveness. 

7. For ROWS implementation the following should be analyzed and explained as part of 

the security plan change submittal: 

 Describe the duties and responsibilities of ROWS operators. Do ROWS operators 

continuously staff ROWS consoles or are they assigned other duties located away 

from the ROWS console? Describe under what conditions ROWS operators would 

be re-deployed. 

 State the ROWS to operator ratio (is this ratio greater than 1 ROWS per operator?) 

and how the ratio was determined. 

 Review and describe State Laws, local ordinance, and company policies and 

practices that govern the licensee response to incidents such as use of deadly force. 

Appendix C to Part 73, Section II, paragraph B.3.e. requires that this topic be 

described in the SCP. 
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3 SECURITY PLAN CHANGE EVALUATION CRITERIA FOR ROWS 

This guidance provides information pertinent to licensees in determining actions and 

implementation details that should be considered by licensees when considering ROWS 

technology for use and implementation at their site. 

Attachment 1 to this document provides detailed information that is pertinent to security 

plan changes resulting from the installation and implementation of ROWS. This 

information includes examples of items that should be considered and addressed within the 

security plans and/or the summary of changes submitted to the NRC for implementation of 

ROWS based on the guidelines in “NUREG 0800, “Standard Review Plan for the Review of 

Safety Analysis Reports for Nuclear Power Plants,” Chapter 13, “Conduct of Operations,” 

Section 13.6.1 ‘Physical Security – Combined License and Operating Reactors.”. 
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4 SECURITY PLAN CHANGE TEMPLATE 

The following recommended approach is suggested for use by the licensee when submitting 

security plan changes to the NRC. Licensees should retain all documentation used during 

the security plan change review and analysis process in accordance with the retention 

requirements of 10 CFR 50.90 or 50.54(p)(2). 

A. General description of the change 

B. Description of the evaluation process 

a. Refer to Section II “Security Plan Change Evaluation Criteria” 

C. Determination of continued ability to: meet regulatory requirements, meet security plan 

requirements, perform implementing procedures, and perform programmatic functions. 

a. Demonstrate reduction or non-reduction of effectiveness 

b. Explanation of how the change continues to provide high assurance of effective 

implementation of the site physical protection program. 

D. Conclusion 

a. Should include licensee’s reasoning on whether to submit a 50.90 or 50.54(p) based on 

information provided in Sections B and C above 
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ATTACHMENT 1: AREAS OF CONSIDERATION FOR ROWS 

IMPLEMENTATION 

Licensees who submit security plan changes for implementation of ROWS, should describe in 

the security plan how the change implements regulatory requirements and should provide a 

sufficiently detailed description of the changes within the summary of changes to ensure 

understanding of how ROWS is used and maintained within the security program, to include 

how the identified changes do not decrease the safeguards effectiveness of the security plans. 

Below are examples of items that should be considered and addressed within the affected 

security plans and or summary of changes for ROWS implementation based on the guidelines in 

NUREG 0800, “Standard Review Plan for the Review of Safety Analysis Reports for Nuclear 

Power Plants,’ Chapter 13, “Conduct of Operations,’ Section 13.6.1 ‘Physical Security – 

Combined License and Operating Reactors.” 

1. Provide a description within the affected security plan(s) which identifies the number of 

ROWS, the number of ROWS operators, as well as the categorization of ROWS and ROWS 

operators within the site physical protection program and protective strategy to include: 

training and qualification, testing and maintenance, duties and responsibilities, and 

certification, as appropriate. 

 Describe the number of ROWS employed at the site and the number of ROWS operators 

required to operate these systems (e.g., system to operator ratio) 

 Describe whether the ROWS that are deployed at the site are categorized as personnel, 

equipment or systems necessary to prevent significant core damage and spent fuel 

sabotage that require protection from the design basis threat of radiological sabotage 

vehicle bomb assault. 

 Describe whether ROWS operators are within the minimum numbers of those designated 

as armed responders or armed security officers who are components of the protective 

strategy as identified in the physical security plan (PSP)/safeguards contingency plan 

(SCP). 

 Describe how the protection of ROWS and ROWS operators has been accounted for 

within the blast analysis that determined the location of the vehicle barrier system. This 

description should also address the blast analysis considerations for the protection of 

ROWS in a deployed state. 

 Describe the primary duties and responsibilities of the ROWS operators. Describe any 

additional duties and responsibilities of the ROWS operators. Describe whether the 

duties and responsibilities of the ROWS operators require them to leave the immediate 

vicinity of the ROWS console. 
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 Describe the duties and responsibilities of ROWS operators during situations of 

heightened threat consistent with the graduated protective measures and actions of the 

site threat warning system. 

 Describe the communication capabilities provided to the ROWS operators that enable 

continuous communications with the alarm stations during the performance of duty. 

2. Provide a description within the PSP that identifies the access control measures used to 

control access to ROWS consistent with the implementation of the physical protection 

program. 

 Describe the access control measures are used to control access to the various ROWS 

operator controls. 

 Describe the measures that are implemented to ensure control of access control devices 

(e.g., keys, locks, combinations, passwords, etc.) associated with the various ROWS 

operator controls. 

3. Provide a description within the PSP of any OCA surveillance, observation, and monitoring 

duties and responsibilities of ROWS operators using ROWS video technology. 

 Describe whether the ROWS operators using ROWS video technology will be used for 

surveillance, observation, and monitoring of the OCA for the detection and deterrence of 

intruders and to ensure the integrity of physical barriers or other components and 

functions of the onsite physical protection program. 

 Describe whether the ROWS video technology is capable of viewing all areas of the 

OCA that have been identified for surveillance, observation, and monitoring consistent 

with the implementation of the physical protection program and protective strategy. 

 Describe how the integrity of physical barriers, or other components and functions of the 

onsite physical protection program are included within the OCA surveillance, 

observation, and monitoring responsibilities of ROWS operators using ROWS video 

technology. Describe any other surveillance, observation, and monitoring methodologies 

that support ROWS operators using ROWS video technology for the portions of the 

physical barriers, other components, and functions that are not within the field of vision 

of the ROWS video technology. 

 Describe how ROWS is equipped with alternative technology that enables the system 

operator to identify intruders and acquire adversarial targets during the implementation of 

the protective strategy under the loss of facility illumination or low light conditions. This 

description should also address the ROWS video technology capabilities for performing 

OCA surveillance, observation and monitoring during the loss of facility illumination or 

low light conditions. 

4. Provide a description within the PSP of how the ROWS and ROWS firearms are included in 

the site’s maintenance, testing, and calibration program. 
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 Describe how security maintenance, testing, and calibration implementing procedures 

specify the operational and technical details required to perform maintenance, testing, 

and calibration activities on the ROWS. Explain the testing intervals for the ROWS 

system functions (controls and operational mechanisms) to ensure the systems are 

maintained in an operable condition, and are capable of performing their intended 

functions. 

 Describe how the personnel who perform maintenance, testing, calibration and repairs to 

the site’s ROWS are qualified to perform these functions in accordance with 

manufacturers’ specifications and site procedures. 

 Describe how the site’s ROWS are tested in accordance with the site maintenance, testing 

and calibration procedures before being placed back in service after each repair or 

inoperable state. 

 Describe how the firearms that are mounted in the ROWS are included within the site’s 

firearm maintenance procedures. 

 Describe how the integrated accuracy of the ROWS and ROWS mounted firearms 

deployed at the site are validated upon firearm removal and replacement for maintenance 

or after exposure to extreme environmental conditions such as earthquakes or high 

velocity wind. 

 Describe the ROWS mounted firearms semi-annual test firing for accuracy and 

functionality. 

 Describe how the test firing of ROWS mounted firearms includes firing the ROWS 

weapons while mounted in a ROWS platform to ensure integrated accuracy and 

functionality. 

 Describe how ROWS mounted firearms are subject to the same cleaning schedules and 

requirements as the other duty firearms used to implement the site’s physical protection 

program and protective strategy. 

 Describe how the firearms maintenance activities for ROWS mounted firearms are 

documented in accordance with site procedures. 

 Describe how the armorer(s) who conduct armorer level disassembly, assembly, 

adjustments, modifications, and repairs to ROWS mounted firearms are trained and 

qualified and possess a current armorer certification for the specific ROWS firearm 

employed at the site. 

5. Provide a description within the PSP that details the implementation of compensatory 

measures associated with ROWS. 
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 Provide a description of compensatory measures that may be performed by ROWS 

operators using ROWS video technology for direct observation. This description should 

include confirmation that only compensatory measures that can be abandoned upon the 

initiation of the protective strategy would be assigned to ROWS operators using ROWS 

technology to prevent creating a vulnerability. 

 Describe the compensatory measure implemented when a ROWS becomes degraded or is 

inoperable. This description should include the timeframe for the implementation of the 

compensatory measure. 

 If the compensatory measure for ROWS is the addition of an armed responder, provide a 

description of the location of the armed responder’s duty post relative to the vicinity of 

the ROWS area of responsibility that enables a similar response timeline. This 

description should include any protected positions provided to the armed responder 

within the ROWS area of responsibility. 

 If the compensatory measure for ROWS is the addition of an armed responder, describe 

whether this armed responder will be a re-deployable within the protective strategy. If 

so, describe the resource(s) that replaces the field of fire abandoned by this armed 

responder upon re-deployment. 

 If the compensatory measure for ROWS is the addition of an armed responder, provide a 

description of this armed responders responsibilities and capabilities to perform OCA 

surveillance, observation, and monitoring. 

 If the compensatory measure for ROWS is the addition of an armed responder, provide a 

description of this armed responder’s responsibility to perform other compensatory 

measures normally assigned to ROWS operators using ROWS video technology. This 

description should include confirmation that only compensatory measures that can be 

abandoned upon the initiation of the protective strategy would be assigned to the armed 

responder acting as a compensatory measure for a degraded or inoperable ROWS to 

prevent creating vulnerability. 

6. Provide a description within the training and qualification plan (T&QP) of the firearms 

specifications for the firearms mounted in the ROWS. 

 Describe the firearm specifications of the firearms mounted in the ROWS (i.e., caliber, 

muzzle velocity, muzzle energy, magazine or belt fed with a load of (how many) rounds, 

operable in any environment in which it will be used. 

 Describe the duty amount of ammunition contained in the ROWS magazine or belt that is 

loaded in each ROWS mounted firearm. This description should also identify whether 

this amount of ammunition is maintained at all times. 

 Describe the amount of ammunition available onsite for each firearm mounted in ROWS 

(i.e., two times the capacity of the amount within each ROWS firearm magazine or 

ammunition belt). 
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7. Provide a description within the PSP that addresses the safety measures implemented at the 

site with regard to ROWS and confirm that the implementation of ROWS at the site was 

evaluated in accordance with the site’s safety/security interface processes. 

 Describe how the locations of the ROWS provide effective implementation of the ROWS 

systems and do not have a negative impact on plant equipment and operations. 

 Describe the type of safety measures implemented and/or inherent safety features of the 

ROWS that minimize the potential for the ROWS to inadvertently transition to the firing 

mode or have an unintentional discharge. 

 Describe each of the ROWS assigned fields of fire including any lateral and elevation 

limitations that ensure safety components at the site are not adversely affected during the 

initiation of the protective strategy and firing of ROWS mounted firearms. 

 Describe the implementation of other safety measures such as those prescribed by the 

manufacturer, vendor or other industry representatives (e.g., Interagency ROWS Working 

Group (IROWS) safety standards, DOE-STD-1047-2008 Safety Function and Other 

Features of Remotely Operated Weapons Systems, PRF IROWS-001, Performance 

Specification for IROWS, 2009). 

8. Provide a description within the T&QP that confirms that ROWS operators are provided 

training and are qualified within the elements identified in the site’s security training and 

qualification plan. This description should also address the instructor certifications of the 

firearms instructors who train and qualify ROWS operators. 

 Describe how ROWS operators are included within the site’s designation of armed 

members of the security organization that must be trained and qualified on the weapons 

they employ at the site. 

 Describe how ROWS operators are included in the site’s designation of armed 

individuals who are administered an annual written exam that includes the elements 

identified within Commission approved security plans and demonstrates the required 

knowledge, skills and abilities to carry out assigned duties and responsibilities as an 

armed member of the security organization. 

 Describe how the ROWS operators participate in annual firearms familiarization training 

prescribed by the regulation and the security training and qualification plan. 

 Describe how the ROWS operators are instructed on the use of deadly force as authorized 

by applicable state law. 

 Describe the site’s daylight and night fire firearm qualification courses that are 

administered to ROWS operators using the ROWS. 
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 Describe how the site’s firearms qualification courses for ROWS are consistent with the 

scoring criteria of the regulation and are in accordance with the ROWS qualification 

course standards of a law enforcement agency or a nationally recognized entity. 

 Describe how ROWS operators are required to participate in ROWS firearms requalifications annually. 

 Describe whether the tactical qualification course is an annual training and qualification 

requirement for ROWS operators at the site. 

 Describe whether the tactical qualification course administered to ROWS operators 

includes a stage of fire in which the ROWS is used to engage adversarial targets. 

 Describe how the tactical qualification course for ROWS operators includes operator redeployment from the ROWS console for ROWS operators who are assigned secondary 

duties within the protective strategy as re-deployable armed responders. 

 Describe how ROWS is used in the tactical qualification course to simulate the actual 

conditions under which ROWS operators are required to carry-out their assigned duties 

during a contingency event. 

 Describe how the firearms instructors who train and qualify ROWS operators are 

certified by a national or state recognized entity on the use of ROWS. This description 

should also include the identification of the certifying entity. 

 Describe how certified ROWS firearms instructors are recertified in accordance with the 

standards of the certifying entity. This description should include the recertification 

periodicity implemented for the recertification of ROWS firearms instructors. 

 Provide a description that explains how ROWS and ROWS operators will be 

incorporated into quarterly tactical response drills and annual force-on-force exercises. 

9. Provide a description within the safeguards contingency plan (SCP) of the integration of 

ROWS and ROWS operators within the protective strategy. 

 Describe whether ROWS operators are within the minimum numbers of those designated 

as armed responders or armed security officers who are components of the protective 

strategy as identified in the physical security plan (PSP)/safeguards contingency plan 

(SCP). 

 Describe the ROWS system to operator ratio (e.g., 2 ROWS per operator, etc.) and how 

the ratio was determined. 

 Describe the location of ROWS operators during normal operations and whether the 

ROWS operators continuously staff the ROWS consoles or are assigned other duties 

located away from the ROWS console. 
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 If ROWS operators perform duties away from the ROWS console explain how the 

displacement between the operator and the ROWS console was accounted for within 

ROWS operator timelines. 

 If ROWS operators perform duties away from the ROWS console describe the resource 

that assumes the OCA surveillance, observation, and monitoring responsibilities assigned 

to the ROWS operator using ROWS video technology. 

 Describe whether the site’s implementation of ROWS includes the re-deployment of 

ROWS operators armed with contingency weapons to facilitate response in areas that are 

beyond the capability of the statically mounted ROWS. This description should also 

describe the criterion for re-deployment (e.g., directed by security response team leader, 

security supervisor, etc. or pre-planned at the discretion of the armed responder based on 

adversary location, etc.) This description should also describe the resources that replace 

the fields of fire provided by the ROWS upon ROWS operator re-deployment. 

 Describe whether the ROWS mounted firearms remain loaded at all times, and if not, 

whether the protective strategy timelines account for loading ROWS mounted firearms. 

 Describe the measures that are implemented within the protective strategy for a ROWS 

mounted firearm that requires a re-load during a contingency event. 

 Describe the measures that are implemented within the protective strategy to account for 

ROWS mounted firearm malfunctions during a contingency event. 

 Describe whether the ROWS is capable of remaining operable during the loss of normal 

power and how the ROWS retains this capability (e.g., UPS, battery backup, diesel 

generator, etc.). 

 Describe the type of protection provided to the ROWS motive and power control cables 

and the ROWS operating mechanisms to include video technology when in the deployed 

state that ensures that the system is not susceptible to operational interruption resultant 

from adversary counter fire. 

 Describe the new fields of fire that include the integration of ROWS and the new 

interdiction capability resultant from ROWS implementation. 

 Describe the reconfiguration of the armed response organization and the implementation 

of ROWS. Provide a detailed description and any supporting diagrams of the new 

protective strategy which includes the ROWS and ROWS operators and the removal of 

any armed responders. 

 This description should include but is not limited to the following: 

 the number of ROWS added; 

 the location of all ROWS; 

 the number of ROWS operators; 
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 the location of ROWS operators; 

 the identification of ROWS assigned to the specific ROWS operators; 

 the location of armed responders and armed security officers who are not ROWS 

operators; 

 the previous protective strategy armed response locations that have been replaced 

by ROWS; 

 primary and secondary contingency response responsibilities for armed 

responders, armed security officers and ROWS operators including any ROWS 

operator re-deployment; 

 overview of the fields of fire provided by the new protective strategy; 

 calculations of the total time of adversary exposure to external fields of fire on 

each side of the plant starting at the protected area perimeter boundary (include 

breaching timelines/barrier delays, rate of travel (feet per second) accounting for 

the distance from isolation zones to the first available building or structure 

providing cover). 

 The description should address the implementation of the protective strategy 

starting from the outermost facility perimeter moving inward to target sets. 

10. Provide a description within the SCP that addresses the methodology used to determine the 

existence and level of a threat and the initiation of the protective strategy. This description 

should include the identification of the line of demarcation from which the protective 

strategy timelines are derived (e.g., protected area perimeter isolation zone, protected area 

perimeter intrusion detection equipment, etc.). 

 Describe the location (e.g., protected area perimeter isolation zone, protected area 

perimeter intrusion detection equipment, etc.), that was used to derive the protective 

strategy timelines including whether the ROWS are the contingency response assets 

within the closest proximity to this location. This description should address how the 

ROWS, being the most forward deployed response asset, satisfies the criterion for the use 

of deadly force (e.g., ability, opportunity, and jeopardy) in accordance with applicable 

state law without having a person directly exposed to the threat of imminent danger. This 

description should confirm that the methodology used to determine the existence and 

level of threat (to include satisfying the criterion for the use of deadly force) was 

considered in the establishment of protective strategy response timelines. 

 Describe how/what has been communicated or shared with LLEA and how the 

implementation of ROWS impacts LLEA response.