ML25195A005

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CA Note - Revised Force-on-Force Inspection Manual Documents Issuance
ML25195A005
Person / Time
Issue date: 08/19/2025
From: Martin J
NRC/EDO, NRC/NSIR/DSO/SOSB
To: Alysia Bone, Suzanne Dennis, Patricia Jimenez, Janet Lepre, Mcleod J, Amy Powell, Champa Rajapakse
NRC/OCM/BRC, NRC/OCM/DAW, NRC/OCM/MJM
Shared Package
ML25223A142 List:
References
SRM-CMSY-19-0006
Download: ML25195A005 (1)


Text

ML25195A005 NOTE TO COMMISSIONERS ASSISTANTS OCM/DAW OCM/BRC X

Suzanne Dennis X

Amy Powell Charles Kreuzberger Andrea Silvia Travis Jones David Brown Jonathan Marcano Lozada Caty Nolan Michael Benson X

Jan Lepre Mandy Mauer Kimberly Lora Jacylyn Storch X

Champa Rajapakse X

Joelysa McLeod OCM/MJM X

Alysia Bone Rebecca Susko Hector Rodriguez Michelle Bales Sophie Holiday X

Patty Jimenez FROM:

Jody C. Martin Associate Director for Operations, OEDO

SUBJECT:

PENDING ISSUANCE OF REVISED FORCE-ON-FORCE INSPECTION MANUAL DOCUMENTS PER SRM-COMSECY-19-0006 The purpose of this note to Commissioners Assistants is to inform the Commission of the staffs completion of the revised Force-on-Force (FOF) inspection framework and the pending issuance of the associated inspection manual documents, as directed by the Commission in SRM-COMSECY-19-0006, Revised Security Inspection Program Framework (Option 3) in Response to SRM-17-0100, dated May 17, 2024 (Agencywide Documents Access and Management System (ADAMS) Accession No. ML24138A045).

Implementation In SRM-COMSECY-19-0006, the Commission formally approved a revised framework for the U.S. Nuclear Regulatory Commissions (NRC) FOF inspection program. Following the August 19, 2025 Signed by Martin, Jody on 08/19/25 Commissions direction, the staff has completed revisions1 to the relevant inspection manual documents, specifically inspection procedure (IP) 71130.03, Contingency Response - Force-on-Force Testing (Enclosure 1), IP 71130.05, Protective Strategy Evaluation and Performance Evaluation Program (Enclosure 2), Inspection Manual Chapter (IMC) 0609, Appendix E, Part II, Force-on-Force Significance Determination Process (Enclosure 3), and IMC 0308, Attachment 6, Basis Document for Security Cornerstone of the Reactor Oversight Process (Enclosure 4). The draft inspection manual documents are attached for Commission awareness, per Management Directive 8.13, Reactor Oversight Process.

Track changes shown in the enclosed IPs and IMCs show changes from the currently effective version.

The staff held public meetings on June 24, 2024 (ML24183A175), March 3, 2025 (ML25073A022), May 21, 2025 (ML25156A163), and July 2, 2025 (ML25183A314), during the revision process to gather external comments for consideration. All internal and external comments received by the staff have been assessed for relevance and appropriately considered.

The staff highlights one revision to IP 71130.05 from what was presented to the Commission in SRM-COMSECY-19-0006. Following the Commission's direction in SRM-COMSECY-19-0006, the staff reviewed the draft inspection procedures for any changes since the draft versions were provided. The staff determined that inspecting the maintenance and testing of licensee Multiple Integrated Laser Engagement System (MILES) equipment does not align with the direction given to the NRC in Executive Order (EO) 14300, Ordering the Reform of the Nuclear Regulatory Commission. Specifically, the staff reviewed the IPs to ensure that security inspections focus on risk-significant inspection and oversight activities. Consequently, the NRC inspection of licensee MILES equipment was removed from the inspection procedure. The removal of this inspection item is consistent with external stakeholder feedback received. The remaining revisions proposed within SRM-COMSECY-19-0006, specifically those related to licensee scenario planning and development, and adversary planning and preparation, will remain in the IP.

The revised inspection manual documents are expected to be implemented at the beginning of the 8th triennial FOF cycle on January 1, 2026.

The staff is exploring further FOF program revisions as part of its response to EO 14300. It is likely that resultant changes to the program would be implemented during the 8th triennial cycle.

The staff will seek Commission review and approval of these additional enhancements when available.

Enclosures:

As stated 1 SRM-COMSECY-19-0006 directed the staff to update the Inspection Manual to implement this framework, taking into account intervening changes to the inspection procedures and the significance determination process since the provision of the draft versions with SRM-COMSECY-19-0006.

cc: M. King, Acting EDO SECY S. Atack, Acting DEDO OGC J. Martin, ADO OCA D. Lewis, DADO OCAA S. Makor, ETA OIP OCFO OCIO OPA EDO

ML25223A142 (Pkg.)

EDO-006 OFFICE NSIR/DSO/SOSB NSIR/DSO/SOSB NSIR/DSO NAME JBream CPantalo, Acting TInverso DATE 7/14/25 7/15/25 7/15/25 OFFICE OGC NSIR OEDO/ADO NAME JMaltese CErlanger JMartin DATE 7/28/25 7/31/25 8/19/25