Issue Date: 08/22/05 - 1 - 0320

NRC INSPECTION MANUAL NSIR

MANUAL CHAPTER 0320

OPERATING REACTOR SECURITY ASSESSMENT PROGRAM

0320-01 PURPOSE

01.01 The Reactor Oversight Process (ROP) integrates the NRC’s inspection,

assessment, and enforcement programs. As part of the ROP, the Operating Reactor

Security Assessment Program evaluates performance of operating commercial nuclear

power reactor licensees in implementing their security programs and communicates the

results to licensee managers, NRC managers, and certain other stakeholders.

01.02 The assessment program collects information from inspections and performance

indicators (PIs) to enable the agency to arrive at objective conclusions about the licensee’s

performance in security. Based on this assessment information, the NRC determines the

appropriate level of agency response, including supplemental inspection and pertinent

regulatory actions ranging from management meetings to orders for plant shutdown. The

assessment information and agency response are then communicated to the licensee and

to certain external stakeholders with the need to know the information. Followup agency

actions, as applicable, are conducted to ensure that the licensee’s corrective actions for

performance weaknesses were effective.

01.03 This Inspection Manual Chapter (IMC) describes the relation of security

assessment to the ROP, the processes common to both assessment programs, and

processes and procedures for specifically assessing the security of operating nuclear

power reactors. The security assessment process is part of the ROP, but security is

assessed and reported separately from other ROP areas to keep adversaries from

obtaining information that could be useful to them.

0320-02 OBJECTIVES

02.01 To collect information from inspection findings and PIs.

02.02 To arrive at an objective assessment of licensee security performance using PIs

and inspection findings.

02.03 To assist NRC management in making timely and predictable decisions regarding

appropriate agency actions used to oversee, inspect, and assess licensee performance.
0320 - 2 - Issue Date: 08/22/05

02.04 To provide a method for informing certain stakeholders and obtaining their

feedback on the NRC’s assessment of licensee performance in security.

02.05 To provide a process to follow up on areas of concern.

0320-03 APPLICABILITY

This IMC applies to all operating commercial nuclear reactors, except those under

IMC 0350, “Oversight of Reactor Facilities in a Shutdown Condition Due to Significant

Performance Or Operational Concerns.” Nothing in this manual chapter prohibits the NRC

from taking any necessary actions to fulfill its responsibilities under the Atomic Energy Act

of 1954, as amended.

This IMC specifically supplements the guidance in IMC 0305, “Operating Reactor

Assessment Program,” for the security cornerstone. If this chapter is silent on a topic, then

the guidance in IMC 0305 should be followed.

0320-04 DEFINITIONS

The definitions in IMC 0305 apply to this chapter, with one exception. The phrase “multiple

degraded cornerstones” does not apply to the assessment of the security cornerstone. The

following definition is in addition to the definitions in IMC 0305.

04.01 Significant Inspection Finding|Performance Indicator. An inspection finding with a

significance greater than green (as determined by the physical protection significance

determination process) or a security performance indicator that is greater than green.

0320-05 RESPONSIBILITIES AND AUTHORITIES

The following responsibilities are in addition to those listed in IMC 0305.

05.01 Deputy Executive Director for Reactor and Preparedness Programs (DEDR).

Approves deviations from the security action matrix. 

05.02 Director, Office of Nuclear Security and Incident Response (NSIR)

a. Implements the requirements of this inspection manual chapter within NSIR.

b. Develops policies and procedures for the security assessment program.

c. Ensures uniform program implementation and effectiveness.

d. Concurs in regional requests to deviate from the security action matrix.
Issue Date: 08/22/05 - 3 - 0320

05.03 Director, Division of Nuclear Security (DNS), NSIR

a. Oversees implementation of the requirements in this chapter and ensures

consistent implementation across the regions.

b. Recommends, develops, and implements improvements to the Operating Reactor

Security Assessment Program.

05.04 Director, Nuclear Security Operations Directorate (NSO, DNS, NSIR)

a. Develops assessment program guidance.

b. Collects feedback from the regional offices and assesses execution of the

Operating Reactor Security Assessment Program to ensure consistent application.

c. Provides oversight of the mid-cycle and end-of-cycle review meetings.

d. Concurs on proposals by the regional office to extend an inspection finding in the

assessment process beyond the normal four quarters in accordance with

IMC 0305, Section 06.06.d.

e. Concurs on proposals by the regional office to initiate a parallel inspection finding

in accordance with IMC 0305, Section 06.06.d.

f. Concurs on the supplemental inspection plan for plants in the Repetitive Degraded

Cornerstone column of the security action matrix.

g. Concurs in a region’s use of a security-related cross-cutting finding in making a

determination of an overall substantive cross-cutting finding.

05.05 Regional Administrators

a. Conduct assessment reviews and direct allocation of security inspection resources

within the regional offices based on the security action matrix and other program

guidance.

b. Assure that annual discussions of security performance with licensees are

conducted in nonpublic meetings.

05.06 Regional Directors of Division of Reactor Safety

a. Approve proposals by the regional office to extend a security inspection finding in

the assessment process beyond the normal four quarters in accordance with

IMC 0305, Section 06.06.d.

b. Approve proposals by the regional office to initiate a parallel inspection finding in

accordance with IMC 0305, Section 06.06.d.
0320 - 4 - Issue Date: 08/22/05

c. Approve the supplemental inspection plan for plants in the Repetitive Degraded

Cornerstone column of the security action matrix.

d. Approve the use of a security-related cross-cutting finding in making a

determination of a substantive cross-cutting finding.

0320-06 BASIC REQUIREMENTS

06.01 Overall Assessment Process. Security performance is reviewed over a 12-month

period, using the ROP’s processes and schedules (IMC 0305, Exhibits 3 and 4). An

overview of the security cornerstone with its key attributes and applicable inspectable areas

is displayed on the diagram of Exhibit 1. The diagram shows that material control and

accountability will be added as a new key attribute in a future revision to this inspection

manual chapter.

A significant inspection finding is carried forward for four calendar quarters or until

appropriate licensee corrective actions have been completed, whichever is longer.

Therefore, an inspection finding will no longer be considered in the assessment process

after four calendar quarters unless the region has justification to keep the finding open in

accordance with IMC 0305, Section 06.06.d. Keeping active for assessment any force-onforce findings that are not closed by headquarters within 12 months (four quarters) of their

issuance, requires the concurrence of Director, NSO, DNS, NSIR as specified in

Section 06.06a.3.

The inspectors normally use the SDP to evaluate inspection findings for significance. In

addition, the NRC’s enforcement policy may apply to issues which the SDP process can

not evaluate for significance (e.g., violations that involve willfulness, including

discrimination). These issues should be considered when determining the range of agency

actions within the appropriate column of the security action matrix. Additionally, if

applicable the underlying technical issue should be separately evaluated using the Physical

Protection Significance Determination Process and the results considered in the

assessment process.

06.02 Performance Reviews. The assessment process consists of a series of reviews

that result in the issuance of various assessment letters. The content of security

assessment letters should be below the level of safeguards information. Descriptions of

security inspection findings or issues in the letters should be at the level used in the

Reactor Program System–official use only. The security-related assessment actions for

each review are described below.

a. Continuous Review. The DRS branch chief responsible for security ensures the

continuous review of security performance is accomplished. Any anticipated

change in security performance indicators should be reported to the region’s DRS

branch chief responsible for security.

The region may issue a security assessment followup letter (Exhibit 3) to address

a security issue, in accordance with the security action matrix, between the normal

quarterly assessments if (1) a security significant inspection finding is finalized or
1

Security-related assessment letters should be treated as official use only documents described in Management

Directive 12.6, “NRC Sensitive Unclassified Information Security Program,” with the exception of the markings.

Issue Date: 08/22/05 - 5 - 0320

(2) a performance indicator, based on current inputs, will cross a performance

threshold at the end of the quarter. The security letters will be prepared,

designated, and marked as “exempt from public disclosure in accordance with

10 CFR 2.390.”1

 The letters shall contain the same type of information required of

similar ROP assessment letters.

b. Quarterly Review. The quarterly review uses the PI data submitted by licensees

and inspection findings compiled over the previous 12 months. This review is

conducted within 5 weeks of the end of each quarter of the annual assessment

cycle (see IMC 0305, Exhibit 4). Performance indicators and applicable inspection

findings for the most recent quarter are considered in determining agency actions

using the security action matrix (Exhibit 2).

The DRS branch chief responsible for security ensures that the most recently

submitted PIs (which should be submitted no more than 21 days after the end of

the quarter) and the inspection findings in the Reactor Program System (RPS) are

reviewed to identify any performance trends in security. The branch chief shall use

the security action matrix to help identify any NRC actions that should be

considered that are not already included in the existing inspection plan.

Assessment followup letters are normally issued by the DRS branch chief within

2 weeks of the quarterly review for any new significant PIs or inspection findings.

The letter shall follow the guidance in Section 06.02a and conform to Exhibit 3.

On determining that a plant will be in the Repetitive Degraded Cornerstone column,

the regional office should issue an assessment letter stating that the changes to

the planned actions are consistent with the Repetitive Degraded Cornerstone

column in the security action matrix.

c. Mid-Cycle Review. The security cornerstone will be discussed during any regional

assessment meetings to discuss performance in the other six cornerstones of

safety. DRS members responsible for security will typically assemble the items

needed for discussing security at the assessment meetings. The DRS branch chief

responsible for security, or a designee, should attend the mid-cycle review

meetings. The discussion of security should be at the official use only level unless

the venue can support controlling safeguards information.

The output of this review is a mid-cycle letter that addresses the security

cornerstone. The mid-cycle letters should follow the format in Exhibit 4. The midcycle review and subsequent mid-cycle letters should only discuss issues from

inspections that were completed before the end of the mid-cycle assessment

period. Additional activities include planning inspection activities for the next 18-

month period, and discussing any insights into potential substantive cross-cutting

issues (problem identification and resolution, human performance, and safetyconscious work environment). The security action matrix is used to determine the

scope of agency actions in response to the assessment inputs. The mid-cycle
0320 - 6 - Issue Date: 08/22/05

review will be completed within 6 weeks of the end of the second quarter of the

annual assessment cycle.

The regional offices will develop a plant performance summary for plants with a

degraded security cornerstone (two or more white inputs or 1 yellow input). If the

meeting agenda (IMC 0305, Exhibit 6) or plant performance summary (IMC 0305,

Exhibit 7) discuss security issues, the documents, as a minimum, should be clearly

marked as “official use only” to ensure that the document is handled properly and

not inadvertently released to the public. (See MD 12.6.)

The mid-cycle security letters shall be issued on the same schedule as the ROP

letters. The security letters will be prepared, designated, and marked as “exempt

from public disclosure in accordance with 10 CFR 2.390.” The letters shall contain

the same type of information required of ROP assessment letters. The ROP

assessment letters should contain a brief statement that the security assessment

was completed and will be reported in a separate letter.

An inspection plan of security activities, covering approximately 18 months from the

issuance of the mid-cycle letter, will be included with the mid-cycle security letters.

The inspection plan is report 24 from the RPS. The schedule for force-on-force

exercises are not to be included unless first coordinated with the Security

Performance Evaluations Section of NSIR.

d. End-of-Cycle Review. The security cornerstone will be discussed along with the

other ROP cornerstones during the regional office’s end-of-cycle review. Regional

DRS members responsible for security will typically assemble the items needed for

discussing security at the assessment meetings. The output of this review is a

security assessment letter for each plant (Exhibits 5, 6, 7, 8, and 9). The end-ofcycle review and subsequent annual assessment letters should only discuss issues

from inspections that were completed before the end of the assessment period.

Additional activities include planning security inspection activities for the next 18-

month period, discussing any potential substantive cross-cutting issues, and

developing an input (if applicable) to support the Agency Action Review Meeting.

The security assessments will follow the same schedule and guidance as the ROP

assessments. The security action matrix will be used to determine the scope of

agency actions in response to assessment inputs.

The RPS listing of security inspection findings will accompany the Plant Issues

Matrix (PIM) reports produced for the end-of-cycle assessments. The regional

offices shall develop a plant performance summary (see IMC 0305, Exhibit 7) for

those plants whose security performance has been in the Degraded Cornerstone

column, Repetitive Degraded Cornerstone column, or Unacceptable Performance

column of the security action matrix during any quarter of the previous 12 months.

The content of the plant performance summaries will follow the guidance of

IMC 0305 as it applies to the security performance being documented.

If the meeting agenda (IMC 0305, Exhibit 6) or plant performance summary

(IMC 0305, Exhibit 7) discuss security issues, the documents shall, as a minimum,
2

The NRC’s and industry’s actions in security may be discussed in general at the public meeting, but should only include

information that the agency has already made public on the topic.

Issue Date: 08/22/05 - 7 - 0320

be clearly marked as “official use only” to ensure that the document is handled

properly and not inadvertently released to the public. (See MD 12.6.)

The DRS branch chiefs responsible for security are expected to participate in their

region’s end-of-cycle review meetings. The discussions of security performance

or issues should be kept at the official-use-only level. If safeguards information

must be discussed, the necessary measures should be taken to protect the

information.

The output of the end-of-cycle review is an annual security assessment letter for

each facility (Exhibits 5, 6, 7, 8, and 9). The letters will be designated and marked

as “exempt from public disclosure in accordance with 10 CFR 2.390.” The letters

shall be issued on the same schedule as the ROP assessment letters. The

signature authority for each annual security assessment letter is determined by the

most significant column of the security action matrix that the plant has been in over

the four quarters of the assessment cycle. The letters shall contain the same type

of information required of ROP assessment letters, and include a schedule of

security inspections as discussed in 06.02c, above. The ROP assessment letters

should contain a brief statement that the security assessment was completed and

will be reported in a separate letter.

06.03 Program Reviews. Plants with significant performance weaknesses in security will

be discussed at the Agency Action Review Meeting. Those are the plants that are in the

Repetitive Degraded Cornerstone or Unacceptable Performance columns of the security

action matrix.

06.04 Annual Meeting With Licensee. Performance in the security cornerstone will not

be discussed during the public assessment meeting with licensees.2 If the plant’s

performance in security is in the Licensee Response column of the security action matrix,

than the licensee should be offered the opportunity to discuss their performance in a

nonpublic meeting coincident the public meeting. If the region’s assessment places a

plant’s security performance beyond the Licensee Response column of the security action

matrix, the region will schedule a closed meeting with the licensee to discuss the

performance and agency actions. The meeting can be held the same day as the public

annual meeting and be led by the same NRC attendees if the appropriate level of

management is involved. The appropriate level of management is the level indicated on

the Regulatory Performance Meeting row of the security action matrix.

If performance in the security cornerstone is significantly degraded (i.e., Degraded

Cornerstone column in the security action matrix or worse) and performance of the other

ROP cornerstones is in the Licensee Response or Regulatory Response column in the

ROP action matrix, then a security performance meeting must be held with the licensee

within 16 weeks of the annual security assessment letter if the public meeting is scheduled

later, as is allowed by IMC 0305, Section 06.04.
3

Reference memo from Roy Zimmerman to regional administrators, subject “Providing State Officials Security Related

Documents,” dated April 19, 2005, ML050630069

0320 - 8 - Issue Date: 08/22/05

The purpose of the meeting is to allow the licensee an opportunity to respond to the

information in the annual security assessment letter and to ensure the licensee

understands the bases for our assessment and planned actions. It is also an opportunity

for the NRC to fully understand the licensee’s position and corrective actions.

06.05 NRC Responses to Licensee Performance

a. Security Action Matrix. The security action matrix (Exhibit 2) is based on the ROP

action matrix. Therefore, the security action matrix takes a graded approach to

addressing performance issues. The terms in the IMC 0305 discussion of the ROP

action matrix also apply to the security action matrix. The next two sections

describe aspects of the security action matrix that differ from the ROP action

matrix.

1. Regulatory Performance Meetings. Such meetings to discuss securityrelated issues are not open to the public.

2. Communication. Communication between the licensee and the NRC and

between the NRC and external stakeholders uses a graded approach. For

declining licensee performance, higher levels of agency management will

review and sign the assessment letters and conduct the annual assessment

meeting. Also for declining performance, the NRC’s assessment letter will

be sent to selected external stakeholders with a need to know the

information.3

b. Expected Responses for Each Action Matrix Column. The range of expected

licensee and NRC actions in the security action matrix is similar to the range in the

ROP action matrix. The following sections describe aspects of the security matrix

that are specific to the security cornerstone.

1. Regulatory Response Column. Assessment inputs result in no more than

one white input; the cornerstone objective is met with minimal reduction in

security performance. Regulatory performance meetings for security are not

open to the public.

2. Degraded Cornerstone Column. Assessment inputs result in multiple white

inputs or 1 yellow input; the cornerstone objective is met with moderate

degradation in security performance. Regulatory performance meetings for

security are not open to the public.

A regulatory action that the region may consider in response to performance

in this column is to stop announcing baseline and supplemental security

inspections to the licensee. That is, an assessment letter sent to the licensee

will not include the RPS report 24 inspection schedule for security, or specific

security inspections would not be listed on report 24. In addition, the region
Issue Date: 08/22/05 - 9 - 0320

needs to consider if a confirmatory action letter is warranted based on the

collection of inputs that determined performance at this level.

3. Repetitive Degraded Cornerstone. Assessment inputs result in a repetitive

degraded cornerstone (2 or more white inputs or a yellow input for five or

more consecutive quarters), multiple yellow inputs, or a red input. If the only

greater than green finding in the fifth quarter has been held open greater than

four quarters, the repetitive degraded cornerstone does not apply. If,

however, one of the greater than green findings is still within the original four

quarters and one or more findings has been held open greater than four

quarters, the repetitive degraded cornerstone does apply. In this instance,

the plant would stay in the Repetitive Degraded Cornerstone column until

there was only one greater than green finding, regardless of the length of

time the findings have been opened. The inspection plan for supplemental

Inspection Procedure 95003, “Inspection for Repetitive Degraded

Cornerstones, Multiple Degraded Cornerstones, Multiple Yellow Inputs, or

One Red Input,” must be approved by the Director, DRS, with the

concurrence of the Director, NSO, DNS, NSIR.

After the supplemental inspection, the EDO or the EDO’s designee, in

conjunction with the regional administrator and the Director, NSIR, will decide

whether additional agency actions are warranted. Regulatory performance

meetings for security shall not be open to the public.

4. Unacceptable Performance Column. Overall unacceptable performance;

unacceptable margin for security.

06.06 Additional Action Matrix Guidance. The guidance in IMC 0305 applies to the

security cornerstone and the security action matrix, with the following exceptions.

Note: If the agency determines that a licensee’s performance

is unacceptable, a shutdown order may be issued. 

Note: The confirmatory action letter (CAL) for this column of

the action matrix is not mandatory, but the regional office

should consider issuing a CAL when significant information on

licensee performance becomes available.

Note: Other than the CAL, the regulatory actions listed in this

column of the action matrix are not mandatory. However, the

regional office should consider each of these regulatory

actions when significant new information on licensee

performance becomes available.
0320 - 10 - Issue Date: 08/22/05

a. Approvals and Concurrences

1. Items in IMC 0305 requiring approval or concurrence by the Chief, Inspection

Program Branch, NRR, will require the approval or concurrence of the

Director, NSO, NSIR, for security-related issues.

2. Items in IMC 0305 requiring approval or concurrence by the Director, NRR,

will require the approval or concurrence of the Director, NSIR, for securityrelated issues.

3. Extending security-related inspection findings for consideration in

assessments beyond four calendar quarters will follow the same process

specified in IMC 0305, Section 06.06.d. However, certain force-on-force

findings are the responsibility of headquarters to close. Extending any of

those findings needs to be coordinated with the Security Performance

Evaluations Section, DNS, NSIR, the approval of the Director, DRS, and the

concurrence of the Director, NSO, DNS, NSIR. The affected licensee will be

notified by letter of any such extensions.

b. Substantive Cross-Cutting Issues. Substantive cross-cutting issues in the security

cornerstone are to be handled as described in Section 06.06 of IMC 0305.

Security-related cross-cutting issues are not normally considered in conjunction

with cross-cutting issues in the other six cornerstones to arrive at a finding of

substantive. However, if the region needs to use a security issue to make such a

finding, then the use of the security-related finding needs the approval of a regional

division director with the concurrence of the Director, NSO, NSIR. Any such finding

and resultant agency actions that are based on input from the security cornerstone

must be treated as security-related information and may not be made publicly

available.

c. Problem Identification and Resolution (PI&R) Inspections. The security

cornerstone will continue to be considered along with the other six cornerstones for

inclusion in the biannual PI&R team inspections conducted at each power reactor

site. A security specialist may be added to the PI&R team as a full-time or parttime member. Any inspection results derived from security-related PI&R

inspections will not be made public. The security-related inspection information

may be included in (1) a nonpublic attachment to the team inspection report, (2) the

next-issued security inspection report, or (3) a separate, nonpublic inspection

report on the security-related findings. The publicly available PI&R inspection

report should include a brief statement that the inspection included the security

cornerstone.

d. Deviations from the Security Action Matrix. In the rare instance when the

regulatory action specified in the security action matrix is not appropriate for the

issue, the region may request to deviate from the matrix. The request is made as

specified in IMC 0305, section 06.06.f, with the following change. The request is

to be made to the Deputy Director for Reactor and Preparedness Programs

(DEDR) with the concurrence of the Director, NSIR.
Issue Date: 08/22/05 - 11 - 0320

Indeterminate losses of target sets during a force-on-force exercise that are

evaluated with the Baseline Physical Protection Significance Determination

Process and result in a green finding are not considered deviations from the action

matrix.

END

EXHIBITS:

1. Overview of the Security Cornerstone

2. Security Cornerstone Action Matrix

3. Sample Security Cornerstone Assessment Followup Letter Based on Quarterly

Review or Issuance of Final SDP Letter

4. Sample Security Cornerstone Mid-Cycle Letter

5. Sample Security Cornerstone Annual Security Assessment Letter for Plants in the

Licensee Response Column During the Entire Assessment Cycle

6. Sample Security Cornerstone Annual Assessment Letter for Plants in the Licensee

Response Band Column That Were in Other Action Matrix Columns During the

Assessment Cycle

7. Sample Security Cornerstone Annual Assessment Letter for Plants in the

Regulatory Response Column

8. Sample Security Cornerstone Annual Assessment Letter for Plants in the Degraded

Cornerstone Column

9. Sample Security Cornerstone Annual Assessment Letter for Plants in the

Repetitive Degraded Cornerstone Column
0320 - 12 - Issue Date: 08/22/05
Issue Date: 08/22/05 E1-1 

Security

Response to

Contingency

Events

Access Control

Physical Protection

System

Protected Areas - Barriers - Alarms - AssessmentPI = PARII

K

Provide assurance that the licensee’s security system

 and material control and accounting program use a defense-in-depth approach

 and can protect against (1) the design basis threat of radiological sabotage from

 external and internal threats, and (2) the theft or loss of radiological materials

SearchRII

PersonnelScreeningPI = AARII

IdentificationRII

July 18, 2005

Vital Areas - Barriers - Alarms - AssessmentRII

Access

Authorization

BehaviorObservationsRII

Fitness forDutyPI = FFDRII

ProtectiveStrategyRII

Implementationof ProtectiveStrategyRII

Verify PIINSPECTIABLE AREAS: PI&R

Access Authorization

 Security Plan Changes

Verify PIINSPECTIABLE AREAS: PI&R Fitness for Duty Program Security Plan Changes

INSPECTABLE AREAS: PI&R Access Control Security Plan Changes

INSPECTABLE AREAS: PI&R Access Control Security Plan Changes

INSPECTABLE AREAS: PI&R Security Plan Changes Response to Contingency Events

Protective Strategy Evaluation

 Security Training

INSPECTABLE AREA PI&R Security Plan Chang Response to Conting

Protective Strategy E

INSPECTIABLE AREAS: PI&R Security Plan Changes

INSPECTIABLE AREAS: PI&R Access Authorization Security Plan Changes

Verify PIINSPECTIABLE AREAS: PI&R Security Plan Changes

Equipment Performance,

 Testing, Maintenance Owner Controlled Area Controls

PI = PerformaPA = Protected AA = Access AFFD = Fitness fRII = Risk InfoPI&R = Problem 

EXHIBIT 1

Overview of the Security Cornerstone

4Other than a CAL, the regulatory actions for plants in the Repetitive Degraded Cornerstone column are not mandatory agency actions. Howev

consider each of these regulatory actions when significant new information on licensee performance becomes available. In the Degraded Cornerstone co

and should only be considered if other performance information warrants a CAL.

0320 E2-1 I

EXHIBIT 2

Security Cornerstone Action Matrix

Response Bands

Licensee Response Regulatory Response Degraded Cornerstone Repetitive Degraded Cornerstone 

RESULTSAll assessment inputs (performance indicators and inspection findings) green; cornerstone objectives fully met One white input; cornerstone objective met with minimal reduction in security performance Multiple white inputs or 1 yellow input; cornerstone objective met with moderate degradation in security performance Multiple yellow inputs or 1 

input; cornerstone object

met with longstanding iss

or significant degradation 

security performance 

RESPONSE

Regulatory

Performance

Meeting

None

Branch chief (BC) or division

director (DD) meets with

licensee

DD or regional administrator

(RA) meets with licensee

RA (or EDO) meets wit

senior licensee managem

Licensee Action Licensee corrective action

Licensee root cause

evaluation and corrective

action with NRC oversight

Licensee cumulative root

cause evaluation with NRC

oversight

Licensee performance

improvement plan with N

oversight

NRC Inspection Risk-informed baseline inspection program Baseline and supplemental Inspection Procedure 95001 Baseline and supplemental Inspection Procedure 95002 Baseline and supplemen

Inspection Procedure 950

Regulatory

Actions4 None Supplemental inspection only 

Supplemental inspection

Consider: CAL; unannounced

inspections

10 CFR 2.204 DFI 

10 CFR 50.54(f) letter

CAL/order

COMMUNICATION

Assessment

Letters

BC or DD reviews, signs

assessment report

(w/inspection plan)

DD reviews, signs assessment

report (w/inspection plan)

RA reviews, signs assessment

report (w/inspection plan)

RA reviews, signs assessm

report (w/inspection pla

Annual Assessment

Meeting SRI or BC meets with licensee BC or DD meets with licensee RA (or designee) discusses performance with licensee RA or EDO discusses performance with senio

licensee management 

External

Stakeholders None State Governors State Governors, DHS, Congress State Governors, DHS

Congress 

Commission

Involvement None None None Plant discussed at AAR

INCREASING SIGNIFICANCE

Issue Date: 08/22/05 0320 E3-1

Exhibit 3

Sample Security Cornerstone Assessment Followup Letter

Based on Quarterly Review or Issuance of Final SDP Letter

Licensee distribution designate

Licensee name/address

SUBJECT: Assessment Followup Letter for Security—(Official Plant Name)

Dear (Mr./Ms. last name of addressee)

[Mark the top and bottom of each page of the letter with “Exempt from Public

Disclosure in Accordance With 10 CFR 2.390"]

[Use the following paragraph for documenting QUARTERLY REVIEW if the plant

moved to a more significant column of the security action matrix]

On (date) the NRC staff completed, as part of our (continuous|quarterly) review of

security performance, our assessment of (official plant name). The assessment

evaluated performance indicators (PIs) and inspection results. The purpose of this

letter is to inform you of your security performance during this period and our plans for 

future inspections at your facility. This letter supplements, but does not supercede, our

latest annual or mid-cycle assessment letter issued on (date of annual or mid-cycle

assessment letter).

[Use the following paragraphs, as appropriate.]

1. Changing action matrix actions based on performance indicators

Our review of (official plant name) indicated that you have crossed the threshold from

(color) to (color) for the (name of performance indicator) performance indicator.

[Provide additional details as necessary.]

[Briefly discuss other significant security performance indicators or inspection

findings that will influence the level of supplemental inspection effort.]

As a result, we assessed (plant name)’s performance to be in the (Regulatory

Response, Degraded Cornerstone, or Repetitive Degraded Cornerstone) column of

the NRC’s security action matrix. We therefore plan to conduct supplemental Inspection

Procedure (95001, 95002, 95003) during the week of (date). [If the performance is in

the Degraded or Repetitive Degraded Cornerstone column and the inspection will

be unannounced, then use the following sentence in lieu of the previous

sentence.] We therefore plan to conduct supplemental Inspection Procedure

(95001,95002, 95003) in the near future. [Add description of the objectives of the

supplemental inspection procedure.]1
0320 Issue Date: 08/22/05 E3-2

2. Changing action matrix actions based on inspection findings

On (date), the NRC staff forwarded a letter on the final significance determination of a

(white, yellow, red) inspection finding in the security cornerstone. [Provide additional

details as necessary.]

[Briefly discuss other security-significant performance indicators or inspection

findings that will influence the level of supplemental inspection effort.]

As a result of our review, we have found (plant name)’s performance to be in the

(Regulatory Response, Degraded Cornerstone, or Repetitive Degraded

Cornerstone) column of the NRC’s security action matrix. We therefore plan to

conduct supplemental Inspection Procedure (95001, 95002, 95003) during the week of

(date). [If the performance is in the Degraded or Repetitive Degraded

Cornerstone column and the inspection will be unannounced, then use the

following sentence in lieu of the previous sentence.] We therefore plan to conduct

supplemental Inspection Procedure (95001, 95002, 95003) in the near future. [Add a

description of the objectives of the supplemental inspection procedure.]1

Please contact (DRS branch chief) at (telephone number) if you have any questions

about this letter.

While we are fully committed to our goal of ensuring openness in our regulatory

process, we must balance that goal with the more immediate need of ensuring the

continued safety and secure operation of nuclear facilities and the protection of nuclear

materials in our country. Thus due to the security-related concerns contained in this

correspondence, and in accordance with 10 CFR 2.390, a copy of this letter and its

enclosure will not be available for public inspection in either the NRC Public Document

Room or the Publicly Available Records (PARS) component of NRC's document system

(ADAMS).

(Name), Director 2

Division of Reactor Safety

Docket Nos. 50-ABC, 50-XYZ

License Nos. NPF-0, NPF-0

cc:

Nonpublic cc list

Distribution:

Nonpublic distribution list

Chief, NSIR/DNS/RSS

Chief, NSIR/DNS/SOS

RidsNsirDns@nrc.gov
Issue Date: 08/22/05 0320 E3-3

Note 1: Summary of supplemental inspection objectives

IP 95001

To provide assurance that the root causes and contributing causes of significant

performance issues are understood, the extent of condition is identified, and the

corrective actions will prevent recurrence.

IP 95002

To provide assurance that the root and contributing causes for the individual and

collective significant performance issues are understood, to independently assess the

extent of condition, and to provide assurance that the corrective actions will prevent

recurrence.

IP 95003

1. To provide additional information on whether the continued operation of the facility is

acceptable and whether additional regulatory actions are necessary to arrest declining

performance,

2. To provide an independent assessment of the extent of significant issues to help

determine whether an unacceptable margin of safety exists.

3. To independently assess the adequacy of the programs and processes the licensee

uses to identify, evaluate, and correct performance issues.

4. To independently evaluate the adequacy of programs and processes in the relevant

strategic performance areas.

5. To provide insight into the overall root and contributing causes of identified

performance deficiencies.

Note 2: See the security action matrix for the proper signature authority.
0320 Issue Date: 08/22/05 E3-4
Issue Date: 08/22/05 0320 E4-1

Exhibit 4

Sample Security Cornerstone Mid-Cycle Letter

Licensee distribution designee

Licensee name/address

SUBJECT: Mid-Cycle Security Performance Review and Inspection Plan—(Official

Plant Name)

Dear (Mr./Ms. last name of addressee)

[Mark the top and bottom of each page of the letter with “Exempt from Public

Disclosure in Accordance With 10 CFR 2.390"]

On (date), the NRC staff completed its performance review of (official plant name) for

the first half of the calendar year 200(X) assessment cycle. Our technical staff reviewed

performance indicators (PIs) for the most recent quarter and inspection results over the

previous 12 months. The purpose of this letter is to inform you of our assessment of

your security performance during this period and our plans for future security

inspections at your facility so you can inform us of any planned inspections that may

conflict with your plant activities.

[Use one of the two paragraphs below as applicable, using the sentences that are

appropriate for each plant’s situation.]

[1] Plant performance for the most recent quarter was within the Licensee Response

column of the NRC’s security action matrix on the basis that all inspection findings have

very low security significance (Green) and all PIs show that no additional NRC oversight

(Green). [Add the following if needed.] However, (insert finding) is still being

reviewed under the physical protection significance determination process. When

finalized, the finding may change our assessment of your plant’s security performance. 

(Give additional details as necessary.) Therefore, we will conduct only security

baseline inspections at your facility through March 31, 200X. We will also conduct

several non-ROP security inspections, which include [insert appropriate inspections].

[2] Plant performance for the most recent quarter was within the (Regulatory

Response, Degraded Cornerstone, or Repetitive Degraded Cornerstone) column of

the NRC’s security action matrix for the following reasons. [Enumerate the securitysignificant performance indicators and inspection findings and briefly discuss

their significance].

[Provide additional information as necessary, including current and proposed

NRC and licensee actions. Do not provide detailed information on NRC or

licensee actions already discussed in the previous annual assessment letter.]

[Add the following paragraph for any non-SDP Severity Level III or greater

enforcement action taken from January 1–June 30, 200X, if applicable.]
0320 Issue Date: 08/22/05 E4-2

Additionally, on (month day, year), the staff issued a Severity Level (I, II, or III) notice

of violation in accordance with the NRC’s Enforcement Policy. [Provide additional

details including followup actions as necessary. Do not provide detailed

information on NRC or licensee actions already discussed in the previous end-ofcycle letter.]

[Add either of the following two paragraphs, as applicable.]

The enclosed inspection plan lists the security inspections scheduled through

March 31, 200X. [The inspection schedule should be planned 18 months out from

the date of issuance of the annual assessment letter. Also briefly mention

infrequent inspections or inspections that are unusual to the plant, except forceon-force inspections, which will be announced by headquarters]. The inspection

plan is provided to minimize disruptions to your staff and to allow scheduling conflicts

and personnel availability issues to be resolved well before our inspectors arrive onsite. 

[If some security inspections are unannounced, add the following sentence.]

Several of our planned inspections do not appear on the attached plan because they

are being conducted as unannounced inspections in response to plant performance in

the Repetitive Degraded Cornerstone column of the security action matrix. The

inspections in the last 9 months of the inspection plan are tentative and the plan may be

revised at the end-of-cycle review meeting. Routine force-on-force inspections are

conducted approximately every 3 years. You will be notified by separate correspondence

8 to 10 weeks in advance of any force-on-force inspections scheduled for your facility.

Normally we would advise you of our planned security inspections for the next

18 months. However, we are not announcing our security inspections at (plant name)

because the plant’s performance in security is in the Repetitive Degraded Cornerstone

column of the NRC’s security action matrix. An inspection plan may be forthcoming with

the next end-of-cycle security assessment letter.

If we change the inspection plan, we will contact you to discuss the change as soon as

possible. Please contact (DRS branch chief, me) at (telephone number) if you have

any questions about this letter.

While we are fully committed to our goal of ensuring openness in our regulatory

process, we must balance that goal with the more immediate need of ensuring the

continued safety and secure operation of nuclear facilities and the protection of nuclear

materials in our country. Thus due to the security-related concerns contained in this

correspondence, and in accordance with 10 CFR 2.390, a copy of this letter and its

enclosure will not be available for public inspection in either the NRC Public Document

Room or the Publicly Available Records (PARS) component of NRC's document system

(ADAMS).

(Name), Chief 1

(Branch)

Division of Reactor Safety

Docket Nos. 50-ABC, 50-XYZ

License Nos. NPF-0, NPF-0
Issue Date: 08/22/05 0320 E4-3

Enclosure: (Plant name) Inspection Plan [if a plan is enclosed]

cc.

Nonpublic cc list

Distribution:

Nonpublic distribution list

Chief, NSIR/DNS/RSS

Chief, NSIR/DNS/SOS

RidsNsirDns@nrc.gov

Note 1: Refer to the security action matrix for the proper signature authority. Signature

authority is determined by the most significant column of the action matrix that the plant

has been in over the first two quarters of the assessment cycle.
0320 Issue Date: 08/22/05 E4-4
Issue Date: 08/22/05 0320 E5-1

Exhibit 5

Sample Security Cornerstone Annual Assessment Letter

 for Plants in the Licensee Response Column

During the Entire Assessment Cycle

Licensee distribution designee

Licensee name/address

SUBJECT: Annual Security Assessment Letter—(Official Plant Name) (Report XXXXXX)

Dear (Mr./Ms. last name of addressee)

[Mark the top and bottom of each page of the letter with “Exempt from Public

Disclosure in Accordance With 10 CFR 2.390"]

On (date), the NRC staff completed its performance review of (official plant name) for

the calendar year 200(X) assessment cycle. Our technical staff reviewed performance

indicators (PIs) for the most recent quarter and inspection results for the period from

January 1 through December 31, 200X for (plant name). The purpose of this letter is to

inform you of our assessment of your security performance during this period and our

plans for future security-related inspections at your facility so you can inform us of any

planned inspections that may conflict with your plant activities.

[Use the following sentences as appropriate]

Overall, (plant name) was operated in a manner that preserved public health and

safety, promoted the common defense and security, and fully met the cornerstone

objective. Plant performance for the fourth quarter, as well as for the first three quarters

of the assessment cycle, was within the Licensee Response column of the NRC’s

security action matrix because all inspection findings had very low safety significance

(Green) and all PIs indicated that no additional NRC oversight was required (Green). 

[Add the following if needed.] However, (insert finding) is still being reviewed under

the physical protection significance determination process. When finalized, the finding

may change our assessment of your plant’s security performance. (Give additional

details as necessary.) Therefore, we will conduct only security baseline inspections at

your facility through September 30, 200X. We will also conduct several non-ROP

security inspections, including [insert appropriate inspections. Do not include

force-on-force exercises, which will be announced by headquarters].

[Add the following paragraph for any non-SDP Severity Level III or greater

enforcement action taken from January 1–December 31, 200X, if applicable.]

Additionally, on (month day, year), the staff issued a Severity Level (I, II, or III) notice

of violation in accordance with the NRC’s Enforcement Policy. [Provide additional

details, including followup actions as necessary; however, do not provide

detailed information on NRC or licensee actions already discussed in the

previous mid-cycle letter.]
0320 Issue Date: 08/22/05 E5-2

The enclosed inspection plan lists the security-related inspections scheduled through

September 30, 200X. [The inspection schedule should be planned 18 months out

from the date of issuance of the annual assessment letter. Also mention

infrequent inspections or inspections that are unusual for the plant. However, do

not include force-on-force exercises, which are announced by headquarters.] The

inspection plan is provided to minimize disruptions to your staff and to allow scheduling

conflicts and personnel availability issues to be resolved well before our inspectors

arrive onsite. The inspections in the last 9 months of the inspection plan are tentative

and the plan may be revised at the mid-cycle review meeting. Routine force-on-force

inspections are conducted approximately every 3 years. You will be notified by separate

correspondence 8 to 10 weeks in advance of any force-on-force inspections scheduled for your

facility.

If we change this inspection plan, we will contact you to discuss the change as soon as

possible. Please contact me at (telephone number) if you have any questions about

this letter or the inspection plan.

While we are fully committed to our goal of ensuring openness in our regulatory

process, we must balance that goal with the more immediate need of ensuring the

continued safety and secure operation of nuclear facilities and the protection of nuclear

materials in our country. Thus due to the security-related concerns contained in this

correspondence, and in accordance with 10 CFR 2.390, a copy of this letter and its

enclosure will not be available for public inspection in either the NRC Public Document

Room or the Publicly Available Records (PARS) component of NRC's document system

(ADAMS).

(name), Chief 

(Branch)

Division of Reactor Safety

Docket Nos. 50-ABC, 50-XYZ

License Nos. NPF-0, NPF-0

Enclosure: (Plant name) Inspection Plan

cc.

Nonpublic cc list

Distribution:

Nonpublic distribution list

Chief, NSIR/DNS/RSS

Chief, NSIR/DNS/SOS

RidsNsirDns@nrc.gov
Issue Date: 08/22/05 0320 E6-1

Exhibit 6

Sample Security Cornerstone Annual Assessment Letter for Plants

in the Licensee Response Band Column That Were in Other Action Matrix

Columns During the Assessment Cycle

Licensee distribution designee

Licensee name/address

SUBJECT: Annual Security Assessment Letter—(Official Plant Name)

Dear (Mr./Ms. Last name of addressee)

[Mark the top and bottom of each page of the letter with “Exempt from Public

Disclosure in Accordance With 10 CFR 2.390"]

On (date), the NRC staff completed its performance review of (official plant name) for

the calendar year 200(X) assessment cycle. Our technical staff reviewed performance

indicators (PIs) for the most recent quarter and inspection results for the period from

January 1 through December 31, 200X for (plant name). The purpose of this letter is to

inform you of our assessment of your security performance during this period and our

plans for future security-related inspections at your facility so you can inform us of any

planned inspections that may conflict with your plant activities.

[Use the following sentences as applicable.]

Overall, (plant name) was operated in a manner that preserved public health and

safety, promoted the common defense and security, and met the security cornerstone

objective. Security performance for the most recent quarter was within the Licensee

Response column of the NRC’s security action matrix because all inspection findings

had very low safety significance (Green) and the PIs for the latest quarter indicated no

additional NRC oversight (Green). However, (insert finding) is still being reviewed

under the physical protection significance determination process. [Give additional

details, as necessary]. Therefore, we will conduct only security baseline inspections at

your facility through September 30, 200X. We will also conduct several non-ROP

security inspections, including [insert appropriate inspections. Do not include

force-on-force exercises, which will be announced by headquarters].

While plant security performance for the most recent quarter is within the Licensee

Response column of the security action matrix, there were security significant

(inspection findings|performance indicators) during the first three quarters of the

assessment cycle. [Give a brief summary of the significant inspection findings

and performance indicators from the first three quarters of the cycle, including

agency and licensee actions.]

[Add the following paragraph for any non-SDP Severity Level III or greater

enforcement action taken from January 1–December 31, 200X, if applicable.]
0320 Issue Date: 08/22/05 E6-2

Additionally, on (month day, year), the staff issued a Severity Level (I, II, or III) notice

of violation in accordance with the NRC’s Enforcement Policy. [Provide additional

details including followup actions as necessary. However, do not provide

detailed information on NRC or licensee actions already discussed in the

previous mid-cycle letter.]

The enclosed inspection plan lists the security-related inspections scheduled through

September 30, 200X. [The inspection schedule should be planned 18 months out

from the date of issuance of the annual assessment letter. Also mention

infrequent inspections or inspections that are unusual for the plant. However, do

not include force-on-force exercises, which are announced by headquarters.] The

inspection plan is provided to minimize disruptions to your staff and to allow scheduling

conflicts and personnel availability issues to be resolved well before our inspectors

arrive onsite. The inspections in the last 9 months of the inspection plan are tentative

and the plan may be revised at the mid-cycle review meeting. Routine force-on-force

inspections are conducted approximately every 3 years. You will be notified by separate

correspondence 8 to 10 weeks in advance of any force-on-force inspections scheduled for your

facility.

If we change this inspection plan, we will contact you to discuss the change as soon as

possible. Please contact (DRS branch chief) at (telephone number) if you have any

questions about this letter or the inspection plan.

While we are fully committed to our goal of ensuring openness in our regulatory

process, we must balance that goal with the more immediate need of ensuring the

continued safety and secure operation of nuclear facilities and the protection of nuclear

materials in our country. Thus due to the security-related concerns contained in this

correspondence, and in accordance with 10 CFR 2.390, a copy of this letter and its

enclosure will not be available for public inspection in either the NRC Public Document

Room or the Publicly Available Records (PARS) component of NRC's document system

(ADAMS).

(Name), Director1

Division of Reactor Safety, Region [I, II, III, IV]

Docket Nos. 50-ABC, 50-XYZ

License Nos. NPF-0, NPF-0

Enclosure: (Plant name) Security Inspection Plan

cc.

Nonpublic cc list

Distribution:

Nonpublic distribution list

Chief, NSIR/DNS/RSS
Issue Date: 08/22/05 0320 E6-3

Chief, NSIR/DNS/SOS

RidsNsirDns@nrc.gov

Note 1: Refer to the security action matrix for proper signature authority. Signature

authority is determined by the most significant column of the action matrix that the plant

has been in over the four quarters of the assessment cycle. 
0320 Issue Date: 08/22/05 E6-4
Issue Date: 08/22/05 0320 E7-1

Exhibit 7

Sample Security Cornerstone Annual Assessment Letter for Plants in the

Regulatory Response Column

Licensee distribution designee

Licensee name/address

SUBJECT: Annual Security Assessment Letter—(Official Plant Name)

Dear (Mr./Ms. last name of addressee)

[Mark the top and bottom of each page of the letter with “Exempt from Public

Disclosure in Accordance With 10 CFR 2.390"]

On (date), the NRC staff completed its performance review of (official plant name) for

the calendar year 200(X) assessment cycle. Our technical staff reviewed performance

indicators (PIs) for the most recent quarter and inspection results for the period from

January 1 through December 31, 200X for (plant name). The purpose of this letter is to

inform you of our assessment of your security performance during this period and our

plans for future security-related inspections at your facility so you can inform us of any

planned inspections that may conflict with your plant activities.

[Use the following sentences as applicable.]

Overall, (plant name) was operated in a manner that preserved public health and

safety, promoted the common defense and security, and met the cornerstone objectives

with only minimal degradation in security performance. Security performance for the

most recent quarter was within the Regulatory Response column of the NRC’s security

action matrix for the following reasons. [Enumerate the security-significant

inspection findings and Pis and briefly state their significance]. However, (insert

finding) is still being reviewed under the physical protection significance determination

process. [Give additional details as necessary.]

[Describe the security-significant inspection findings and performance indicators

including agency and licensee responses to the issues.]

Although plant performance for the most recent quarter was within the Regulatory

Response column of the security action matrix, there were security significant

(inspection findings|performance indicators) during the first three quarters of the

assessment cycle. [Summarize security-significant inspection findings and

performance indicators from the first three quarters of the assessment cycle,

including agency and licensee actions.]

[Add the following paragraph for any non-SDP Severity Level III of greater

enforcement action taken from January 1–December 31, 200X, if applicable.]

Additionally, on (month day, year), the staff issued a Severity Level (I, II, or III) notice

of violation in accordance with the NRC’s Enforcement Policy. [Provide additional

details, including followup actions as necessary. Do not provide detailed
0320 Issue Date: 08/22/05 E7-2

information on NRC or licensee actions already discussed in the previous midcycle letter]

The enclosed inspection plan lists the security-related inspections scheduled through

September 30, 200X. [The inspection schedule should be planned 18 months out

from the date of issuance of the annual assessment letter. Also mention

infrequent inspections or inspections that are unusual for the plant. However, do

not include force-on-force exercises, which are announced by headquarters.] The

inspection plan is provided to minimize disruptions to your staff and to allow scheduling

conflicts and personnel availability issues to be resolved well before our inspectors

arrive onsite. The inspections in the last 9 months of the inspection plan are tentative

and the plan may be revised at the mid-cycle review meeting. Routine force-on-force

inspections are conducted approximately every 3 years. You will be notified by separate

correspondence 8 to 10 weeks in advance of any force-on-force inspections scheduled for your

facility.

If we change this inspection plan, we will contact you to discuss the change as soon as

possible. Please contact (DRS branch chief) at (telephone number) if you have any

questions about this letter or the inspection plan.

While we are fully committed to our goal of ensuring openness in our regulatory

process, we must balance that goal with the more immediate need of ensuring the

continued safety and secure operation of nuclear facilities and the protection of nuclear

materials in our country. Thus due to the security-related concerns contained in this

correspondence, and in accordance with 10 CFR 2.390, a copy of this letter and its

enclosure will not be available for public inspection in either the NRC Public Document

Room or the Publicly Available Records (PARS) component of NRC's document system

(ADAMS).

(Name), Director1

Division of Reactor Safety, Region [I, II, III, IV]

Docket Nos. 50-ABC, 50-XYZ

License Nos. NPF-0, NPF-0

Enclosure: (Plant name) Security Inspection Plan

cc.

Nonpublic cc list

Distribution:

Nonpublic distribution list

Chief, NSIR/DNS/RSS

Chief, NSIR/DNS/SOS

RidsNsirDns@nrc.gov
Issue Date: 08/22/05 0320 E7-3

Note 1: Refer to the security action matrix for proper signature authority. Signature

authority is determined by the most significant column of the action matrix that the plant

has been in over the four quarters of the assessment cycle.
Issue Date: 08/22/05 0320 E8-1

Exhibit 8

Sample Security Cornerstone Annual Assessment Letter for Plants in the

Degraded Cornerstone Column

Licensee distribution designee

Licensee name/address

SUBJECT: Annual Security Assessment Letter—(Official Plant Name) (Report XXXXXX)

Dear (Mr./Ms. last name of addressee)

[Mark the top and bottom of each page of the letter with “Exempt from Public

Disclosure in Accordance With 10 CFR 2.390"]

On (date), the NRC staff completed its performance review of (official plant name) for

the calendar year 200(X) assessment cycle. Our technical staff reviewed performance

indicators (PIs) for the most recent quarter and inspection results for the period from

January 1 through December 31, 200X for (plant name). The purpose of this letter is to

inform you of our assessment of your security performance during this period and our

plans for future security inspections at your facility so you can inform us of any planned

inspections that may conflict with your plant activities.

Overall, (plant name) was operated in manner that preserved public health and safety,

promoted the common defense and security, and met the cornerstone objective with

only moderate degradation in performance. Security performance for the most recent

quarter was within the Degraded Cornerstone column of the NRC’s security action

matrix for the following reasons. [Enumerate the security-significant inspection

findings and PIs and briefly state their significance. Add the following sentence,

if necessary.] However, (insert finding) is still being reviewed under the physical

protection significance determination process. When finalized, the finding may change

our assessment of your plant’s security performance. [Give additional details as

necessary.]

[Describe the security-significant inspection findings and performance indicators,

including agency and licensee responses to the issues.]

Although plant performance for the most recent quarter is within the Degraded

Cornerstone column of the security action matrix, there were additional securitysignificant (inspection findings or performance indicators) during the first three

quarters of the assessment cycle. [Summary the security-significant inspection

findings and performance indicators from the first three quarters of the

assessment cycle, including agency and licensee actions.]

[Add the following paragraph for any non-SDP Severity Level III or greater

enforcement action taken from January 1–December 31, 200X, if applicable.]
0320 Issue Date: 08/22/05 E8-2

Additionally, on (month day, year), the staff issued a Severity Level (I, II, or III) notice

of violation in accordance with the NRC’s Enforcement Policy. [Provide additional

details including followup actions as necessary. Do not provide detailed

information on NRC or licensee actions already discussed in the previous midcycle letter.]

[Add either of the following two paragraphs as applicable.]

The enclosed inspection plan lists the security inspections scheduled through

September 30, 200X. [The inspection schedule should be planned 18 months out

from the date of issuance of the annual assessment letter. Also briefly mention

infrequent inspections or inspections that are unusual for the plant, except forceon-force inspections, which will be announced by headquarters.] The inspection

plan is provided to minimize the disruption to your staff and to allow scheduling conflicts

and personnel availability issues to be resolved well before our inspectors arrive on site. 

Several of our planned inspections do not appear on the attached plan because they

are being conducted as unannounced inspections in response to plant performance in

the Degraded Cornerstone column of the security action matrix. The inspections in the

last 9 months of the inspection plan are tentative and the plan may be revised at the

mid-cycle review meeting. Routine force-on-force inspections are conducted

approximately every 3 years. You will be notified by separate correspondence 8 to 10 weeks

in advance of any force-on-force inspections scheduled for your facility.

If we change this inspection plan, we will contact you to discuss the change as soon as

possible. Please contact (DRS branch chief) at (telephone number) if you have any

questions about this letter.

While we are fully committed to our goal of ensuring openness in our regulatory

process, we must balance that goal with the more immediate need of ensuring the

continued safety and secure operation of nuclear facilities and the protection of nuclear

materials in our country. Thus due to the security-related concerns contained in this

correspondence, and in accordance with 10 CFR 2.390, a copy of this letter and its

enclosure will not be available for public inspection in either the NRC Public Document

Room or the Publicly Available Records (PARS) component of NRC's document system

(ADAMS).

(Name)

Regional Administrator,1

 Region [I, II, III, IV]

Docket Nos. 50-ABC, 50-XYZ

License Nos. NPF-0, NPF-0

Enclosure: (Plant name) Inspection Plan [if enclosed]

cc.

Nonpublic cc list

Distribution:
Issue Date: 08/22/05 0320 E8-3

Nonpublic distribution list

Chief, NSIR/DNS/RSS 

Chief, NSIR/DNS/SOS

RidsNsirDns@nrc.gov

Note 1: Refer to the security action matrix for proper signature authority. Signature

authority is determined by the most significant column of the action matrix that the plant

has been in over the four quarters of the assessment cycle.
0320 Issue Date: 08/22/05 E8-4
Issue Date: 08/22/05 0320 E9-1

Exhibit 9

Sample Security Cornerstone Annual Assessment Letter for Plants in the

Repetitive Degraded Cornerstone Column

Licensee distribution designee

Licensee name/address

SUBJECT: Annual Security Assessment Letter—(Official Plant Name) (Report XXXXXX)

Dear (Mr./Ms. last name of addressee)

[Mark the top and bottom of each page of the letter with “Exempt from Public

Disclosure in Accordance With 10 CFR 2.390"]

On (date), the NRC staff completed its performance review of (official plant name) for

the calendar year 200(X) assessment cycle. Our technical staff reviewed performance

indicators (PIs) for the most recent quarter and inspection results for the period from

January 1 through December 31, 200X for (plant name). The purpose of this letter is to

inform you of our assessment of your security performance during this period and our

plans for future security inspections at your facility so you can inform us of any planned

inspections that may conflict with your plant activities.

Overall, (plant name) was operated in manner that preserved public health and safety

and promoted the common defense and security. Although (plant name) met the

security cornerstone objectives, it remained within the Repetitive Degraded Cornerstone

column of the security action matrix with longstanding issues or significant degradation

in security performance. The plant’s performance is in this column for the following

reasons. [Enumerate the security-significant inspection findings and PIs, and

briefly state their significance]. However, (insert finding) is still being reviewed

under the physical protection significance determination process. [Give additional

details as necessary.]

[Describe the security-significant inspection findings and performance indicators,

including agency and licensee responses to the issues.]

[Summarize the security-significant inspection findings and performance

indicators from the first three quarters of the assessment cycle, including agency

and licensee actions].

[Add the following paragraph for any non-SDP Severity Level III or greater

enforcement action taken from January 1–December 31, 200X, if applicable.]

Additionally, on (month day, year), the staff issued a Severity Level (I, II, or III) notice

of violation in accordance with the NRC’s Enforcement Policy. [Provide additional

details including followup actions as necessary. Do not provide detailed

information on NRC or licensee actions already discussed in the previous midcycle letter.]
0320 Issue Date: 08/22/05 E9-2

[Include the following paragraph if applicable.]

You are requested to provide our office with a copy of any performance improvement

plan that you have developed so that we can coordinate our inspection activities

accordingly. Because the security cornerstone (has been/was) degraded for an

extended period, we believe a meeting between the Executive Director for Operations

and your senior management is appropriate. I will be contacting you to arrange for a

mutually agreeable time and location for a meeting to discuss your declining

performance and your proposed actions to correct the deficiencies.

In accordance with IMC 0305, “Operating Reactor Assessment Program,” we will

discuss your plant at the upcoming Agency Action Review Meeting. We will notify you

by separate correspondence if any agency actions change as a result of the meeting.

[Add either of the following two paragraphs as applicable.]

The enclosed inspection plan lists the security inspections scheduled through

September 30, 200X. [The inspection schedule should be planned 18 months out

from the date of issuance of the annual assessment letter. Also briefly mention

infrequent inspections or inspections that are unusual for the plant, except forceon-force inspections, which will be announced by headquarters.] The inspection

plan is provided to minimize disruptions to your staff and to allow scheduling conflicts

and personnel availability issues to be resolved well before our inspectors arrive on site. 

The inspections in the last 9 months of the inspection plan are tentative and the plant

may be revised at the mid-cycle review meeting. Routine force-on-force inspections are

conducted approximately every 3 years. You will be notified by separate correspondence

8 to 10 weeks in advance of any force-on-force inspections scheduled for your facility.

Normally we would advise you of our planned security inspections for the next

18 months. However, we are not announcing our security inspections at (plant name)

because the plant’s security performance is in the Repetitive Degraded Cornerstone

column of the NRC’s security action matrix. An inspection plan may be enclosed with

the next mid-cycle security assessment letter.

If we change this inspection plan, we will contact you to discuss the change as soon as

possible. Please contact (DRS branch chief) at (telephone number) if you have

questions about this letter.

While we are fully committed to our goal of ensuring openness in our regulatory

process, we must balance that goal with the more immediate need of ensuring the

continued safety and secure operation of nuclear facilities and the protection of nuclear

materials in our country. Thus due to the security-related concerns contained in this

correspondence, and in accordance with 10 CFR 2.390, a copy of this letter and its

enclosure will not be available for public inspection in either the NRC Public Document

Room or the Publicly Available Records (PARS) component of NRC's document system

(ADAMS).

(Name)

Regional Administrator,1

 Region [I, II, III, IV]

Docket Nos. 50-ABC, 50-XYZ
Issue Date: 08/22/05 0320 E9-3

License Nos. NPF-0, NPF-0

Enclosure: (Plant name) Inspection Plan [if enclosed]

Nonpublic cc list

Distribution:

Nonpublic distribution list

Chief, NSIR/DNS/RSS

Chief, NSIR/DNS/SOS

RidsNsirDns@nrc.gov

Note 1: Refer to the security action matrix for the proper signature authority. The

signature authority is determined by the most significant column of the action matrix that

the plant has been in over the four quarters of the assessment cycle.