10 CFR Part 52, Licenses, Certifications, and Approvals for Nuclear Power Plants

U.S. NUCLEAR REGULATORY COMMISSION
DRAFT REGULATORY GUIDE DG-5072
Proposed new Regulatory Guide 5.90
Issue Date: July 2024
Technical Lead: Beth Reed

Guidance for Alternative Physical Security Requirements for
Small Modular Reactors and Non-Light-Water Reactors
Purpose

A. INTRODUCTION

This regulatory guide (RG) describes methods and approaches the staff of the U.S. Nuclear
Regulatory Commission (NRC) consider acceptable for use by licensees of small modular reactors
(SMRs), as defined in Title 10 of the Code of Federal Regulations (10 CFR) 171.5, “Definitions” (Ref.
1), and non-light-water reactors (non-LWRs) to comply with requirements in 10 CFR 73.55(s),
“Alternative physical security requirements” (Ref. 2)
This RG provides an acceptable method that applicants and licensees may use in determining if
they are eligible to use one or more of the alternative physical security requirements in 10 CFR 73.55(s).
It also provides guidance on implementation of these requirements. This guidance should assist applicants
in the design of a physical protection program that meets NRC regulatory requirements. This guidance is
not intended to be all-inclusive. Licensees and applicants may employ alternative methods, after receiving
NRC approval, that satisfy compliance with the requirements in 10 CFR Part 73 (Ref. 3). Each licensee
should account for and determine the measures needed for compliance with the applicable requirements in
•
•
•

10 CFR Part 50, “Domestic Licensing of Production and Utilization Facilities” (Ref. 4),
10 CFR Part 52, “Licenses, Certifications, and Approvals for Nuclear Power Plants” (Ref. 5),
10 CFR Part 73, “Physical Protection of Plants and Materials.”

The licensee bears sole responsibility for developing a physical protection program that will ensure that
activities involving special nuclear material are not inimical to the common defense and security and do
not constitute an unreasonable risk to the public health and safety.
Applicability
This RG is for use by applicants and holders of an operating license (OL) or a combined license
(COL) for SMRs, as defined in 10 CFR 171.5 and non-LWRs licensed under the provisions of 10 CFR
Part 50 or 10 CFR Part 52 to satisfy the requirements of 10 CFR 73.55, “Requirements for physical
protection of licensed activities in nuclear power reactors against radiological sabotage.” Use of this RG
will assist such applicants and licensees in developing and maintaining, or alternatively submitting to the
NRC when required, complete and accurate information that sufficiently describes the alternative physical
security requirements being implemented and the technical basis supporting the use of such requirements.
These alternative physical security requirements should be documented in the facility’s physical security
plan (PSP) submitted to the NRC for review and approval. The technical analysis supporting the use of an

DG 5072, Page 2

alternative physical security requirement need not be submitted to the NRC but must be maintained and is
subject to inspection.
Applicable Regulations
•

10 CFR Part 50 provides regulations for licensing production and utilization facilities.
o

o
•

•

10 CFR 50.34(c), “Physical Security Plan”, requires an applicant for an OL for a
production or utilization facility that will be subject to the requirements of 10
CFR 73.50 to have a physical security plan, a training and qualification plan that
meets the criteria in Appendix B “General Criteria for Security Personnel,” to 10
CFR Part 73, and a cyber security plan that complies with the criteria in 10 CFR
73.54.

•

10 CFR 50.34(d)(2) requires an applicant for an OL for a utilization facility that
will be subject to the requirements of 10 CFR 73.55 to have a safeguards
contingency plan (SCP) that meets the criteria in 10 CFR Part 73, Appendix C,
“Licensee Safeguards Contingency Plans.”

10 CFR 50.54(p)(5) requires a licensee that makes changes to its facility to consider the
effect of the changes on its site-specific analysis prepared under 10 CFR 73.55(s)(1)(iv).

10 CFR Part 52 governs the issuance of early site permits, standard design certifications,
combined licenses, standard design approvals, and manufacturing licenses for nuclear power
facilities.
o

•

50.34, “Contents of applications; technical information,” requires applications for a
construction permit to have a preliminary and a final safety analysis report.

10 CFR 52.79, “Contents of applications; technical information in final safety analysis
report,” requires an applicant to provide a final safety analysis report describing the
facility, design bases, limits or operation, and its structures, systems, and components
(SSCs) of the facility as a whole. Specifically,
•

10 CFR 52.79(a)(35)(i) requires an applicant to submit a PSP.

•

10 CFR 52.79(a)(35)(ii) requires an applicant to submit a description of the
implementation of the PSP .

•

10 CFR 52.79(a)(36)(i) requires an applicant to submit a SCP.

10 CFR Part 73 provides the requirements for the establishment and maintenance of a physical
protection system that will have capabilities for the protection of special nuclear material at fixed
sites and in transit and of plants in which special nuclear material is used.
o

10 CFR 73.50, “Requirements for physical protection of licensed activities,” requires
licensees to establish a security organization, physical barriers, access requirements,
detection aids, communications, testing, maintenance, and SCP.

o

10 CFR 73.55 requires licensees to establish and maintain physical protection programs
to provide high assurance that activities involving special nuclear material are not

inimical to the common defense and security and do not constitute an unreasonable risk
to the public health and safety.
o

10 CFR 73, Appendix B, Section VI.A.1 requires licensees to ensure that all individuals
who are assigned duties and responsibilities required to prevent significant core damage
and spent fuel sabotage, implement the Commission-approved security plans, licensee
response strategy, and implementing procedures, meet minimum training and
qualification requirements to ensure individuals possess the knowledge, skills, and
abilities required to effectively perform the assigned duties and responsibilities.

Related Guidance
Applicants or licensees may consider the following related guidance when using this RG. The list
of related guidance may assist applicants or licensees in the implementation of an elected alternative
physical security requirement found in 10 CFR 75.55(s)(2). It may also assist in the preparation of design
and licensing basis information to support an application to the NRC. Some of the related guidance
documents referenced below are written mainly for light-water nuclear power reactors (LLWRs). These
documents were developed to provide guidance for LLWRs and focus on protecting against the design
basis threat (DBT) or radiological sabotage by preventing significant core damage and spent fuel
sabotage. However, applicants or licensees may find the information, methods or approaches described in
these related guidance documents to be useful in their design of physical security engineered and
administrative controls and management systems for implementing alternative requirements. They may
also be useful in developing methods or approaches for analyzing security-initiated events, characterizing
source terms, and determining radiological consequences of those events. The staff may use the guidance
as applicable in the review of the applicants’ or licensees’ approaches for the design of the facility and the
physical protection system.
•

RG 1.145, “Atmospheric Dispersion Models for Potential Accident Consequence Assessments at
Nuclear Power Plants,” (Ref. 6) provides criteria for characterizing atmospheric dispersion
conditions for evaluating the consequences of accidental radiological releases to the exclusion
area boundary and outer boundary of the low population zone for nuclear power plants.

•

RG 1.183, “Alternative Radiological Source Terms for Evaluating Design Basis Accidents at
Nuclear Power Reactors,” (Ref. 7) provides guidance on design basis accident radiological
consequence analyses for light-water nuclear power reactors, including the development of design
basis accident radiological source terms used in siting and safety analyses.

•

RG 1.194, “Atmospheric Relative Concentrations for Control Room Radiological Habitability
Assessments at Nuclear Power Plants,” (Ref. 8) provides guidance on determining atmospheric
relative concentration (χ/Q) values in support of design basis control room radiological
habitability assessments at nuclear power plants.

•

RG 1.233, “Guidance for a Technology-Inclusive, Rick-Informed, and Performance-Based
Methodology to Inform the Licensing Basis and Content of Applications for Licenses,
Certifications, and Approvals for Non-Light-Water Reactors,” (Ref. 9) provides guidance on
using a technology-inclusive, risk-informed, and performance-based methodology to inform the
licensing basis and content of applications for non-light-water reactors (non-LWRs), including,
but not limited to, molten salt reactors, high-temperature gas-cooled reactors, and a variety of fast
reactors at different thermal capacities. This RG may be used by non-LWR applicants applying
for permits, licenses, certifications, and approvals under 10 CFR Part 50, “Domestic Licensing of

Production and Utilization Facilities,” and 10 CFR Part 52, “Licenses, Certifications, and
Approvals for Nuclear Power Plants.”

•

•

RG 5.69, “Guidance for the Application of the Radiological Sabotage Design-Basis Threat in the
Design, Development, and Implementation of a Physical Security Protection Program that Meets
10 CFR 73.55 Requirements,” (SGI) (Ref. 10) describes the safeguards details for the DBT of
radiological sabotage, including the attributes, characteristics, and capabilities of the DBT
adversary. These attributes, characteristics, and capabilities assist a licensee in the design,
development, and implementation of a physical security system and associated programs.

•

RG 5.71, “Cyber Security Programs for Nuclear Facilities,” (Ref. 11) provides an approach that
the NRC staff considers acceptable for complying with the NRC regulations for the protection of
digital computers, communications systems, and networks from a cyber-attack, to include that
associated with the DBT of radiological sabotage.

•

RG 5.74, “Managing the Safety/Security Interface,” (Ref. 12) provides a method of compliance
for managing the interface between safety and security.

•

RG 5.75, “Training and Qualification of Security Personnel at Nuclear Power Reactor Facilities,”
(Ref. 13) provides an approach that the NRC staff considers acceptable for complying with the
NRC regulations for the training, equipping, testing, qualifying, and requalifying armed and
unarmed security personnel, watchpersons, and other members of the licensee’s security
organization to ensure that these individuals possess and maintain the knowledge, skills, and
abilities required to carry out their assigned duties and responsibilities effectively.

•

RG 5.76, “Physical Protection Programs at Nuclear Power Reactors,” (SGI) (Ref. 14) provides
approaches on meeting the requirements of 10 CFR 73.55 for licensee design and implementation
of a physical protection program.

•

RG 5.77, “Insider Mitigation Program,” (SGI) (Ref. 15) describes an acceptable approach for an
insider mitigation program for protecting nuclear power reactors against malicious acts.

•

RG 5.81, “Target Set Identification and Development for Nuclear Power Reactors,” (Official Use
Only (OUO), not publicly available) (Ref. 16) describes approaches and methodologies that the
NRC considers acceptable for meeting the requirements of 10 CFR 73.55.

NUREG-0800, “Standard Review Plan for the Review of Safety Analysis Reports for Nuclear Power
Plants: LWR Edition” (Standard Review Plan) (Ref. 17) provides guidance to NRC staff in performing
safety reviews of construction permit or OL applications under 10 CFR Part 50 and early site permit,
design certification, COL, standard design approval, or manufacturing license applications under 10 CFR
Part 52. Specifically:
o

Section 13.6.1, “Physical Security - Combined License and Operating Reactors,”
provides the staff guidance for the review of engineered physical security systems,
hardware, and features; the administrative controls; and management systems for
operations and organization.

o

Section 13.6.2, “Physical Security - Review of Physical Security System Designs Standard Design Certification and Operating Reactor Licensing Applications,” provides
guidance for the physical security review of designs of physical security systems.

•

NUREG/CR-7145, “Nuclear Power Plant Security Assessment Guide,” (Ref. 18) describes an
acceptable approach for performing security assessment to demonstrate that the physical
protection system design of a new reactor facility provides assurance of protection against the
DBT of radiological sabotage.

•

NUREG-1964, “Access Control Systems: Technical Information,” (Ref. 19) provides technical
details applicable on the application, use, function, installation, maintenance, and testing
parameters for access control and search equipment and the implementation of protective
measures that support access control.

•

NUREG/CR-7201, “Characterizing Explosive Effects on Underground Structure,” (Ref. 20)
provides technical guidance on characterizing the effects that explosions close to the ground
surface or in contact with the ground surface have on underground structures, for design to
protect against the explosives.

•

NUREG/CR-6190, “Protection Against Malevolent Use of Vehicles at Nuclear Power Plants:
Vehicle Barrier System Siting Guidance for Blast Protection,” Vols. 1 and 2 (Ref. 21) provides a
simplified procedure for selecting land vehicle barriers that will stop the design basis vehicle
threat.

•

U.S. Department of Energy, Sandia National Laboratory, SAND99-2168, “Access Delay
Technology,” (Ref. 22) provides technical guidance on access delay systems to impede a group of
well-equipped and dedicated adversaries for a length of time to enable the response force
opportunities to interdict and neutralize.

•

U.S. Department of Energy, Sandia National Laboratory, SAND2008-5644, “Vital Area
Identification for U.S. Regulatory Nuclear Power Reactor Licensees and New Reactor
Applicants,” (Ref. 23) describes a systematic process involving logic models for the identification
of the minimum set of areas that must be designated as vital areas in order to ensure that all
radiological sabotage scenarios are prevented.

•

U.S. Department of Energy, Sandia National Laboratory, SAND2007-5591, “Security
Assessment Technical Manual,” (Ref. 24) provides conceptual and specific technical guidance
for the development of the layout of a facility to enhance protection against sabotage and
facilitate the use of physical security features, design the physical protection system to be used at
the facility, and analyze the effectiveness of the physical protection system against the DBT.

Purpose of Regulatory Guides
The NRC issues RGs to describe methods that are acceptable to the staff for implementing
specific parts of the agency’s regulations, to explain techniques that the staff uses in evaluating specific
issues or postulated events, and to describe information that the staff needs in its review of applications
for permits and licenses. RGs are not NRC regulations and compliance with them is not required.
Methods and solutions that differ from those set forth in RGs are acceptable if supported by a basis for the
issuance or continuance of a permit or license by the Commission.
Paperwork Reduction Act
This RG provides voluntary guidance for implementing the mandatory information collections in
10 CFR Part 50, 10 CFR Part 52, and 10 CFR Part 73 that are subject to the Paperwork Reduction Act of
1995 (44 U.S.C. 3501 et. seq.). These information collections were approved by the Office of

Management and Budget (OMB), approval numbers 3150-0011, 3150-0151, and 3150-0002. Send
comments regarding this information collection to the FOIA, Library, and Information Collections Branch
((T6-A10M), U.S. Nuclear Regulatory Commission, Washington, DC 20555 0001, or by e-mail to
Infocollects.Resource@nrc.gov, and to the Desk Officer, Office of Information and Regulatory Affairs,
NEOB-10202 (3150-0011, 3150-0015 and 3150-0002) Office of Management and Budget, Washington,
DC, 20503.
Public Protection Notification
The NRC may not conduct or sponsor, and a person is not required to respond to, a collection of
information unless the document requesting or requiring the collection displays a currently valid OMB
control number.

B. DISCUSSION
Reason for Issuance
This new guidance addresses the requirements for an applicant for, or holder of a license for an
SMR, as defined in 10 CFR 171.5, or non-LWR licensed under the provisions of 10 CFR Part 50 or 10
CFR Part 52 to apply select alternatives to requirements in 10 CFR 73.55 for physical security of
advanced reactors, which, for purposes of this RG, are SMRs and non-LWRs.
Background
The current fleet of operating reactors are Generation III LWRs. It is likely that the NRC will
receive applications to license advanced reactors, either non-LWRs or SMRs under 10 CFR Part 50 or 10
CFR Part 52. Before approving these applications and issuing a license, the NRC must make the
following findings:


The applicable standards and requirements of the Atomic Energy Act of 1954, as amended (also
referred to as the Act) (Ref. 25), and the NRC’s regulations are met.



The facility will operate in conformity with the license as amended, the provisions of the Act, and
the NRC’s regulations.



There is reasonable assurance that
(i)
the activities authorized by the OL can be conducted without endangering the health and
safety of the public, and
(ii)
such activities will be conducted in compliance with the regulations of 10 CFR Part 50 or
10 CFR Part 52.



Issuance of the license is not inimical to the common defense and security or to the health and
safety of the public.

Advanced reactors licensed under 10 CFR Part 50 or 10 CFR Part 52 would be subject to the regulatory
framework and security requirements in 10 CFR 73.55. This regulatory framework provides high
assurance 1 that activities involving special nuclear material are not inimical to the common defense and
security and do not constitute an unreasonable risk to the public health and safety. Consistent with this
regulatory framework, licensees must develop, implement, and maintain a physical protection program
that protects against the DBT of radiological sabotage. This physical protection program is implemented
through a licensee’s PSP which details how the licensee will meet the performance objective and
implement the security requirements in § 73.55.
Typically, a Part 50 or Part 52 license contains a license condition requiring the licensee to operate in
accordance with its NRC approved security plans. Accordingly, an applicant’s or licensee’s PSP contains
information that becomes a part of the licensing basis for the facility (required by 10 CFR 50.34(c)(1)-(3),
10 CFR 50.34(d), 10 CFR 50.34(e), 10 CFR 52.79(a)(35)(i), 10 CFR 52.79(a)(36)(i), and 10 CFR
1

The Commission stated in staff requirements memorandum (SRM) “SRM-SECY-16-0073 – Options and
Recommendations for the Force-On-Force Inspection Program in Response to SRM-SECY-14-0088,” dated October 5,
2016, that “the concept of ‘high assurance’ of adequate protection found in the NRC security regulations is equivalent
to ‘reasonable assurance’ when it comes to determining what level of regulation is appropriate.” The Commission reiterated this point in “SRM-SECY-18-0076 – Options and Recommendation for Physical Security for Advanced
Reactors,” dated November 19, 2018.

52.79(a)(36)(ii)). The PSP must be maintained until the certifications required by 10 CFR 50.82(a)(1) or
10 CFR 52.110(a) have been submitted by the licensee.
Many future advanced reactor designs may rely on passive safety features to perform safety functions
without any human action. Based on inherent design features, including these passive safety features and
small reactor sizes, some applicants for OLs or COLs under 10 CFR Part 50 or 10 CFR Part 52 may seek
alternative physical security requirements rather than implementing certain existing security requirements
in 10 CFR 73.55. These alternative physical security requirements would be documented in the
applicant’s or licensee’s PSP’s and become a part of the licensing basis of the facility.
The NRC will approve PSPs if they contain sufficient detail to enable the NRC to determine that
the applicant or licensee will meet all applicable requirements in 10 CFR 73.55 and therefore be able to
protect against the DBT of radiological sabotage. The NRC staff uses the Standard Review Plan (SRP),
Section 13.6.1, “Physical Security - Combined License and Operating Reactors,” as guidance during its
review of license application, including the applicant’s security plans, and any security plan amendments
submitted for NRC review and approval. The SRP is not a substitute for the NRC’s regulations, and
compliance with it is not required. However, the SRP provides guidance that may be useful to an
applicant or licensee in its preparation of the security plan or security plan amendments to ensure that
they contain the detailed information necessary to demonstrate how regulatory requirements (e.g.,
selected alternative security requirements) will be met.
Consideration of International Standards
The International Atomic Energy Agency (IAEA) works with member states and other partners to
promote the safe, secure, and peaceful use of nuclear technologies. The IAEA has established a series of
security guides to address nuclear security issues relating to the prevention and detection of, and response
to, theft, sabotage, unauthorized access, and illegal transfer or other malicious acts involving nuclear
material and other radioactive substances and their associated facilities. IAEA security guides present
international good practices and increasingly reflect best practices to help users striving to achieve high
levels of security. To inform its development of this RG, the NRC considered IAEA Safety Requirements
and Safety Guides pursuant to the Commission’s International Policy Statement (Ref. 26) and
Management Directive and Handbook 6.6, “Regulatory Guides” (Ref. 27).
RG:

Pertinent to this RG, the following IAEA documents were considered in the development of this

•

IAEA Nuclear Security Series No. 13, “Nuclear Security Recommendations on Physical Protection of
Nuclear Material and Nuclear Facilities (INFCIRC/225/Revision 5)” (Ref. 28), issued January 2011,
contains recommended operational guidance for the protection of nuclear facilities from the threat of
radiological sabotage, along with training and operational readiness of security personnel.

•

IAEA Nuclear Security Series No. 27-G, “Physical Protection of Nuclear Material and Nuclear
Facilities (implementation of INFCIRC/225/Revision 5)” (Ref. 29), issued April 2018, contains
guidance on implementing recommendations found in INFCIRC/225/Revision 5 in establishing,
strengthening, and sustaining physical protection systems.

C. STAFF REGULATORY GUIDANCE
This section describes the process an applicant or licensee of an SMR, as defined in 10 CFR 171.5, or a
non-LWR, that is licensed under the provisions of 10 CFR Part 50 or 10 CFR Part 52, should use to
determine eligibility and the capability to implement the alternative requirements identified in 10 CFR
73.55(s)(2).
Figure 1 provides a high-level flow chart of the process for determining an applicant’s or licensee’s
eligibility to use the alternative security requirements and document compliance with the performance
objective in 10 CFR 73.55(b), with the alternatives applied.
Figure 1

1.

Conditions for applying selected alternatives in accordance with 10 CFR 73.55(s)(1)(i),
“Applicability”
10 CFR 73.55(s)(1)(i) allows an applicant or licensee of an SMR or non-LWR licensed under the
provisions of 10 CFR Part 50 or 10 CFR Part 52 to elect to use one or more of the alternatives to
certain security requirements as specified in 10 CFR 73.55(s)(2), if the applicant or licensee
determines it is eligible as specified in 10 CFR 73.55(s)(1)(ii).

1.1

An applicant or licensee that is not an SMR, as defined in 10 CFR 171.5, or non-LWR, that is
licensed under the provisions of 10 CFR Part 50, or is not a holder of a COL for an SMR or nonLWR, under the provisions of 10 CFR Part 52:
1.1.1

may not elect to use one or more of the alternatives to certain security requirements as
specified in 10 CFR 73.55(s)(2).

1.1.2

2.

may request authorization to meet one or more of the alternatives described in 10 CFR
73.55(s)(2) by submitting an application to the NRC under the provisions of 10 CFR
73.55(r), “Alternative measures.” When necessary, applications should also request an
exemption(s) from specific requirements of 10 CFR 73.55 under the provision of 10 CFR
73.5, “Specific exemptions.”

Eligibility to use selected alternatives in accordance with the 10 CFR 73.55(s)(1)(ii),
“Eligibility”
The requirements in 10 CFR 73.55(s)(1)(ii) state that an applicant or licensee that elects to use
one or more of the alternatives in 10 CFR 73.55(s)(2) must “demonstrate that the consequences of
a postulated radiological release that could result from a postulated security-initiated event do not
exceed the offsite dose reference values defined in 10 CFR 50.34(a)(1)(D) and 10 CFR
52.79(a)(1)(vi) ….”

2.1

To demonstrate eligibility, an applicant or licensee may rely on information from the safety
analysis and the target set identification process to inform the radiological dose consequence
determination.

2.2

While the safety analysis information is based on accident scenarios, security-initiated events
could have similar results. The licensee or applicant would have to verify a security event would
not cause the formation of additional release pathways or cause a higher release fraction than a
safety event may release.

3.

Identifying and documenting selected alternatives in accordance with 10 CFR
73.55(s)(1)(iii), “Identification and documentation”
The requirements in 10 CFR 73.55(s)(1)(iii) state that an applicant or licensee that elects to use
one or more of the alternatives in 10 CFR 73.55(s)(2) must “identify the specific alternative
physical security requirement(s) it intends to implement as part of its physical protection program
and demonstrate how the requirements set forth in 10 CFR 73.55 are met when the selected
alternative(s) is used.”

3.1

3.2

A licensee or applicant electing to implement one or more of the alternatives found in 10 CFR
73.55(s)(2) should describe the following in its security plans (i.e. PSP, Training and
Qualification Plan (TQ&P), SCP, or Cyber Security Plan (CSP), as applicable):
3.1.1

how it intends to implement the alternative physical security requirement(s), and

3.1.2

how the general performance objective and requirements in 73.55(b) are met.

The descriptions in the security plans mentioned in section 3.1 should be sufficiently detailed to
allow the NRC to determine a that the alternative physical security requirement, combined with
all other requirements, provides reasonable assurance that the DBT of radiological sabotage can
be defeated.
3.2.1

For example, if an applicant or licensee elected to implement the alternative offsite
secondary alarm station (SAS) requirement in 10 CFR 73.55(s)(2)(iv), it would have to
describe in its security plans how the offsite SAS would meet the requirements in 10 CFR
73.55(i), such as how it will ensure that intrusion detection system alarms and assessment

videos will annunciate and display concurrently in the central alarm station and the
offsite SAS (as required by 10 CFR 73.55(i)(2)), and how it would meet the requirements
in 10 CFR 73.55(i)(4) and other requirements in 10 CFR 73.55.
3.3

The full descriptions in these security plans must address how the alternative as applied,
integrated with other requirements in 10 CFR 73.55 for design of a physical protection program
and/or stand alone, meets the performance goal and requirements of 10 CFR 73.55(b).
3.3.1

For example, the PSP, in accordance with 10 CFR 73.55(c)(1), should describe how the
licensee will implement the requirements in 10 CFR 73.55, which includes how the
licensee will design and/or implement the selected alternative and use it to meet a
required security function(s) and the performance objective and requirements of 10 CFR
73.55(b).

3.4

Applicants or licensees wishing to request additional alternatives not found in 10 CFR 73.55(s)(2)
should use the exiting processes found in 10 CFR 73.5 and 10 CFR 73.55(r).

3.5

The physical protection program should be designed to protect against the DBT for radiological
sabotage with the characteristics, capabilities and attributes described in 10 CFR 73.1, “Purpose
and scope.” In accordance with 10 CFR 73.1, the licensees must design their physical protection
systems to protect against:
•
violent external assaults and methods (10 CFR 73.1(a)(1)),
•
assailants who are well-trained and dedicated, willing to kill or be killed, knowledgeable,
active, and equipped (10 CFR 73.1(a)(1)(i)(A) through 10 CFR 73.1(a)(1)(i)(E)),
•
internal threats (10 CFR 73.1(a)(1)(ii)),
•
land vehicle bomb assaults (10 CFR 73.1(a)(1)(iii)),
•
waterborne vehicle bomb assaults (10 CFR 73.1(a)(1)(iv)), and
•
cyber-attacks (10 CFR 73.1(a)(1)(v)).

3.6

Licensees should refer to RG 5.69, “Guidance for the Application of the Radiological Sabotage
Design-Basis Threat in the Design, Development, and Implementation of a Physical Security
Protection Program that Meets 10 CFR 73.55 Requirements” (SGI), for detailed information
regarding the Commission-determined characteristics, attributes, and capabilities of the DBT
adversary that licensees must design their physical protection programs to protect against to
prevent radiological sabotage as required by 10 CFR 73.55(b)(2).

4

Demonstrating Eligibility in accordance with 10 CFR 73.55(s)(1)(iv), “Analysis”
10 CFR 73.55(s)(1)(iv) requires that an applicant or licensee that elects to use one or more of the
alternatives in 10 CFR 73.55(s)(2) must perform a technical analysis demonstrating how it meets
the criteria in 10 CFR 73.55(s)(1)(ii).

4.1

This analysis must be maintained until the certifications required by 10 CFR 50.82(a)(1) or 10
CFR 52.110(a) have been submitted by the licensee.

4.2

If applicable, a licensee or applicant may utilize the analysis described in RG 5.81, “Target Set
Identification and Development for Nuclear Power Reactors” (Official Use Only (OUO), not
publicly available), to determine eligibility. This analysis provides a more flexible approach with
different criteria to determine eligibility.

4.2.1

If the SMR or non-LWR licensee or applicant does not have any achievable target sets at
the end of the target set evaluation, then it is eligible to elect to use some or all of the
alternative security measures found in 10 CFR 73.55(s)(2).

4.2.2

If a licensee or applicant does have achievable target sets at the end of the target set
evaluation, then they could use an offsite radiological consequence analysis (hereafter
referred to as a consequence analysis) to determine eligibility.

4.3

The consequence analysis should evaluate potential radiological releases from DBT-initiated or
security-related events and ensure they are below 0.25 sievert (Sv) (25 rem) at the exclusion area
boundary for the worst 2-hour period after the release and at the low population zone during the
entire passage of the radioactive cloud and are within the site’s security bounding time (SBT).
See Appendix C for additional information regarding SBT, including how to calculate it.

4.4

For determining eligibility, a consequence analysis is an acceptable method to perform the
analysis required by 10 CFR 73.55(s)(1)(iv).

4.5

4.4.1

A consequence analysis is performed by the applicant or licensee to determine potential
radiation doses from exposure to the postulated radiological release plume at the
exclusion area boundary for any two-hour period after initiation of the release and at the
outer boundary of the low population zone for the duration of the passage of the plume.

4.4.2

The consequence analysis will evaluate DBT-initiated or security-related event scenarios
based on achievable target sets.

A licensee or applicant wishing to demonstrate eligibility to use some or all of the alternative
security measures found in 10 CFR 73.55(s)(2) should develop security-related scenarios that
examine the capability to prevent or mitigate an offsite release from exceeding reference values
defined in 10 CFR 50.34(a)(1)(ii)(D)(1) and (2) and 10 CFR 52.79(a)(1)(vi)(A) and (B). Some
scenarios to evaluate could include, but are not limited to the following:
4.5.1

Some or all achievable target sets are compromised by an adversary, resulting in a release
of radionuclides from any source in excess of the reference values defined in 10 CFR
50.34(a)(1)(ii)(D)(1) and (2) and 10 CFR 52.79(a)(1)(vi)(A) and (B).

4.5.2

Some or all achievable target sets can be compromised by an adversary, resulting in a
release of radionuclides from any source, but the release can be mitigated before offsite
doses exceed the reference values defined in 10 CFR 50.34(a)(1)(ii)(D)(1) and (2) and 10
CFR 52.79(a)(1)(vi)(A) and (B). Actions to mitigate a release can involve both onsite and
offsite resources to interdict the adversary force and/or mitigate the release.

4.6

Licensees or applicants should discuss the inherent features, engineered features, or operator
actions employed at the facility that would allow the radiological release to be delayed,
minimized, or prevented for the evaluated security-related event scenarios, and the basis for the
assumptions in the consequence analysis.

4.7

The consequence analysis should determine the type and amount of radioactivity potentially
released to the environment and the potential for offsite consequences, if any. For each release
scenario for which doses are assessed, a quantitative radiological source term should be
developed by specifying atmospheric release characteristics such as the time dependent isotopic

release rates to the atmosphere, release durations, release locations, physical/chemical form
(including particle size), and plume buoyancy.
4.7.1

4.8

The radiological source terms should be estimated for the specific facility using accepted
analysis methods and codes, such as those used for the accident and radiological
consequence analyses in the safety analysis report for the facility or in probabilistic risk
assessment, justified for the conditions considered in the DBT-initiated or securityinitiated event scenarios.

The physical properties of the source term and released radioactive material should be described
(e.g., particle sizes, respirable fractions, heat load) for the specific evaluated DBT-initiated or
security-related event scenarios.
4.8.1

The analysis should also address potential changes to these physical properties from
actions that could be taken by the DBT adversary during an attack (e.g., large explosions
or fires, or incendiary devices) and how radionuclide transport may or may not be
affected.

4.8.2

Physical and chemical processes affecting the timing, composition and magnitude of the
release should be addressed, such as convective or conductive cooling, radioactive decay
and in-growth corrections, and radionuclide removal or retention processes.

4.9

The analysis should describe any and all scenarios that could result in releases of radionuclides
from any source. For the purposes of this analysis, a release from any source should not exceed
the dose reference values defined in 10 CFR 50.34(a)(1)(ii)(D)(1) and (2) and 10 CFR
52.79(a)(1)(vi)(A) and (B).

4.10

The analysis should evaluate atmospheric release and direct dose contributors to doses at the
exclusion area boundary and the outer boundary of the low population zone considering the site
characteristics for the specific facility.
4.10.1 The atmospheric release may be modeled as a neutral density plume that does not
undergo chemical or physical transformations after release to the atmosphere, with
corrections for radioactive decay and in-growth, wet or dry deposition (or both), and
plume rise due to buoyancy or momentum (or both), as appropriate.
4.10.2 If the chemical or physical form of the atmospheric release requires more complex
atmospheric transport modeling due to varying fuel types, materials, and facility design
or specifics of the evaluated event scenario, then additional analyses may be needed.

4.11

An atmospheric transport model appropriate for the range of distances under consideration should
be identified.
4.11.1 The applicant or licensee should consider using a straight-line Gaussian plume segmenttype atmospheric dispersion model to estimate short-term atmospheric concentrations,
with modifications as needed to account for near field dispersion phenomena.
4.11.2 Acceptable atmospheric dispersion models for accidents as used in safety analyses are
given in RG 1.145, “Atmospheric Dispersion Models for Potential Accident Consequence
Assessments at Nuclear Power Plants,” and RG 1.194, “Atmospheric Relative
Concentrations for Control Room Radiological Habitability Assessments at Nuclear

Power Plants.” Such models are generally most suitable for relatively simple transport
situations, such as open and level terrain, relatively steady meteorology, and relatively
close distances (<10 kilometers). For models of these types, dispersion parameters
appropriate to the characteristics of the area and distance ranges under consideration
should be identified, and conceptual approaches for the treatment of wind shifts during
the release and near field effects such as elevated releases, building wake effects, plume
meander, and plume rise should also be identified.
4.11.3 Should an applicant or licensee determine that a Gaussian model is not ideal or
practicable for the consequence analysis, they may choose to employ a different type of
dispersion model with supporting technical basis.
4.11.4 Any assumptions made in the atmospheric transport model should be identified so that
the analyst can evaluate the suitability of the model for their particular application.
4.12

Exposure parameters (e.g., shielding factors, breathing rates, exposure durations) should be
characterized. The development of such parameters should not assume any credit for preplanned
protective actions such as evacuation or sheltering.

4.13

Dose calculations should determine the total effective dose equivalent (TEDE), as defined in 10
CFR 50.2, “Definitions.”

4.14

The dose estimation is carried out by combining the results of the release, transport, and potential
exposure from a source term.
4.14.1 A recognized source of dose conversion factors should be used to estimate the TEDE to
an individual at any point of the exclusion area boundary and any point on the outer
boundary of the low population zone for comparison to the dose reference values defined
in 10 CFR 50.34(a)(1)(ii)(D)(1) and (2) and 10 CFR 52.79(a)(1)(vi)(A) and (B).
4.14.2 Applicants may find guidance on offsite accident dose assessment considerations in RG
1.183, “Alternative Radiological Source Terms for Evaluating Design Basis Accidents at
Nuclear Power Reactors” to be helpful. Although the source term information in RG
1.183 is specific to LWR safety analysis, RG 1.183 provides useful information on
calculation of offsite doses for accidents in general.
Alternative requirement for armed responders
In accordance with 10 CFR 73.55(s)(2)(i), a licensee that meets 10 CFR 73.55(s)(1) is relieved
from the requirement for the minimum number of armed responders in 10 CFR 73.55(k)(5)(ii).

5

5.1

This alternative gives an advanced reactor licensee the flexibility to determine and use the
number of onsite armed responders necessary to meet the requirements of 10 CFR 73.55(b)(3).
Licensees may use existing methods, such as those employed by large, light-water reactor
licensees, for determining the necessary number of onsite armed responders.

5.3

Under this proposal, a licensee would be permitted to design its physical protection program to
potentially have fewer than ten onsite armed responders, including no onsite armed responders, if
appropriate.

5.4

The number of onsite armed responders may be reduced to zero if the licensee also implements
the alternative requirements in 10 CFR 73.55(s)(2)(ii) and relies on LE or other offsite armed
responders to fulfill the interdiction and neutralization functions to protect against the DBT of

radiological sabotage. For a licensee that designs its physical protection system to rely on onsite
armed responders to perform interdiction and neutralization to achieve the performance objective
and requirements of 10 CFR 73.55(b), the physical security alternative provides relief only from
the prescriptive requirement for the minimum number of armed responders; all other existing
requirements associated with onsite armed personnel continue to apply.
6.

Alternative requirements for interdiction and neutralization, relying on law enforcement
(LE) or other offsite armed responders to fulfill the interdiction and neutralization
capabilities
In accordance with 10 CFR 73.55(s)(2)(ii) and (s)(2)(ii)(A), a licensee that meets 10 CFR
73.55(s)(1) and has no armed response personnel onsite whose primary duty is to respond to,
interdict, and neutralize acts of radiological sabotage may rely on law enforcement or other
offsite armed responders to fulfill the interdiction and neutralization functions required by 10
CFR 73.55(b)(3)(i).
Section 10 CFR 73.55(b)(3)(i) requires that the licensee’s physical protection program must
ensure that the capabilities to detect, assess, interdict, and neutralize threats up to and including
the DBT of radiological sabotage, as stated in 10 CFR 73.1, are maintained at all times. The
alternative for relying on LE or other offsite armed responders to carry out the interdiction and
neutralization capabilities is acceptable when the following are met by design of the licensee’s
physical protection system:

6.1

Intrusion detection - The capability to detect is met and maintained by the physical security SSCs
relied on for interior and exterior intrusion detection functions and designed to provide reasonable
assurance of detecting unauthorized access into vital and protected areas.
6.1.1 The licensee or applicant should design its intrusion detection systems to detect threats
using the principle of diversity necessary for the reliability and availability of intended
intrusion detection functions.
6.1.2

6.2

Intrusion assessment - The capability to assess is met and maintained by the physical security
SSCs relied on for intrusion assessment functions and designed to provide assurance of rapid
remote assessment for determining cause and initiating appropriate security responses.
6.2.1

6.3

The licensee or applicant should utilize multiple, complementary intrusion detection
systems to maximize the likelihood that at least one sensor system is operating during any
environmental disturbance and minimize the possibility that an intruder will be able to
use a single defeat method (e.g., running, walking, crawling, jumping, rolling, bridging,
tunneling) to traverse a detection zone or portal without being detected.

The licensee or applicant should apply to the design of a physical protection system the
principle of diversity necessary for the reliability and availability of systems and
components to achieve the intended intrusion assessment functions.

Security delay - The capability of security delay is met and maintained by SSCs relied on for
delay functions and designed to provide assurance of necessary and sufficient time for offsite
security response (i.e., licensee proprietary or contract personnel, LE, or combination of licensee
and LE) to carry out tactical operations to interrupt (i.e., interdict or neutralize) the DBT
adversary from causing radiological sabotage.
6.3.1

The licensee or applicant should design the security delay systems to be appropriately
layered for defense-in-depth to achieve the required delay.

6.4

6.5

6.3.2

Where 10 CFR 73.55(s)(1)(ii) is satisfied for applying the alternative requirement in 10
CFR 73.55(s)(2)(ii), licensees or applicants should incorporate security delay systems in
the design of a physical protection system to provide sufficient time for LE or other
offsite armed responders to interdict and neutralize threats up to and including the DBT
of radiological sabotage.

6.3.3

To provide adequate delay, licensees or applicants should design their security systems to
be able to delay the DBT for a time equal to or greater than a site’s SBT, based on the
process described in Appendix C, “Security Bounding Time and Adversary Interference
Precluded Time,” of this guidance.

Delay system and protecting against DBT coordinated vehicle bomb assault - 10 CFR
73.1(a)(1)(iii) and (a)(1)(iv) establish the DBT capability of land and waterborne vehicle bomb
assault, which may be coordinated with an external assault.
6.4.1

The licensee or applicant should design its physical protection program relying on LE or
other offsite armed contingency response to protect the plant from the DBT coordinated
vehicle bomb assault.

6.4.2

If security responders are not available on site to prevent the DBT from defeating typical
barrier systems that are installed at a minimum safe stand-off distance, and if engineered
delay systems do not provide sufficient delay for an offsite response force to arrive before
the DBT can complete its tasks, then the licensee or applicant should design and
configure the structures housing the reactor, spent fuel, and other inventory of
radiological material to withstand the effect of the DBT vehicle bomb.

6.4.3

The facility SSCs required for safety and barriers containing radiation hazards should
have a hardened structural design to protect against blast pressures and/or be located
sufficiently below ground to withstand DBT vehicle bomb blast effects.

6.4.4

Applicants should refer to NUREG/CR-7201, “Characterizing Explosive Effects on
Underground Structure,” for methods of characterizing the effects of explosions on
underground structures resulting from explosive charges located close to and on the
ground surface.

Memorandum of understanding (MOU)
6.5.1

A licensee relying on LE should document and maintain agreements with applicable LE
agencies that are willing and capable of providing armed response. The MOU agreement
should establish the mutually agreed upon commitments and the LE agency’s acceptance
of performing interdiction and neutralization functions to defend the licensed facility. The
safeguards details of how LE will response to contingency events should be described in
the license’s safeguards contingency plan. The MOU should include the following:
6.5.1.1

The mutually agreed upon commitments should include both the licensee and
LE’s activities to plan, train, drill, and exercise contingency response to
ensure LE can respond to interdict and neutralize the DBT at all times.

6.5.1.2

6.6

The mutually agreed upon commitments should identify the planning and
preparedness activities to ensure reliability and availability of LE responses
to interdict and neutralize the DBT.

6.5.2

The following activities should be considered for LE contingency responses:
•
Familiarize and walkdown site and facility, structures and systems, plant hazards,
and operations
•
Plan specific security tactical missions
•
Test communication systems
•
Conduct tabletop exercises
•
Perform limited and field tactical response exercises
•
Capture, track, and disposition lessons learned from drills and exercises

6.5.3

The MOUs should include specific commitments of LE resources (people and
equipment) that will be available and the minimum response times needed for LE to
respond and successfully interdict and neutralize the DBT adversary.

6.5.4

The MOUs should include mutually agreed upon frequencies for LE-related activities in
support of licensee drills and exercises. Licensees must meet the frequency of tactical
response drills and force-on-force exercise requirements in Appendix B, section
VI.C.3.(l)(1) to 10 CFR Part 73.

6.5.5

The licensee MOU with LE should capture response contingencies that may affect the
availability of LE to respond, such as LE budgetary constraints, events that would likely
compete for resources, or ongoing responses other than to a licensee plant.

6.5.6

The licensee should identify any mutual aid agreements for sharing resources between
LEs that may be applied in such contingencies in the MOU.

6.5.7

The licensee should establish additional MOU with any mutual aid LE agencies that may
be relied on to respond to a DBT attack.

6.5.8

To maximize the likelihood that the required LE assistance will be available and reliable
at all times, a licensee should consider establishing MOUs with at least two LE agencies
that have not entered into a mutual aid agreement with each other and that are
independently capable of interdicting and neutralizing the DBT.

Management measures crediting LE response
6.6.1

A licensee applying the alternative requirement in 10 CFR 73.55(s)(2)(ii)(A) remains
responsible for assuring that the capability to interdict and neutralize the DBT for
radiological sabotage is maintained.

6.6.2

For the reliance on LE agency or agencies, the physical protection program should
establish policies, processes, procedures, and an organization for implementing the
committed activities mutually agreed to in MOUs with all LEs.

6.6.3

A licensee should document in its PSP and SCP the security licensing basis for how LE
response will be relied on to perform interdiction and neutralization functions.

6.6.4

The PSP and SCP should describe how the LE agency or agencies will provide the
necessary response to implement contingency responses to achieve the performance
objectives and meet the requirements of 10 CFR 73.55(b).
6.6.4.1

6.7

The descriptions should capture specific LE capabilities, including but not
limited to, the minimum number and positions (i.e., patrol officer, tactical team
member) of available responding LE officers, response equipment, tactical
capabilities, and response times, and the relevant plant structures and systems
required for providing delay.

Licensee’s Safeguards Contingency Plan
10 CFR 73.55(c)(5), “Safeguards Contingency Plan,” states, “The licensee shall establish,
maintain, and implement a Safeguards Contingency Plan that describes how the criteria set forth
in appendix C, section II, to this part, ‘Nuclear Power Plant Safeguards Contingency Plans,’ will
be implemented.”
6.7.1

A licensee applying the alternative requirement in 10 CFR 73.55(s)(2)(ii)(A) of relying
on LE or other offsite armed responders to fulfill the interdiction and neutralization
functions required by 10 CFR 73.55(b)(3)(i) must meet the requirement of 10 CFR
73.55(c)(5) for a (SCP) and is not relieved from the requirements in appendix C, section
II except for the requirement in section II.B.3.c.(iv).

6.7.2

The licensee must document and describe how LE or other (i.e., licensee proprietary or
contract) offsite armed response personnel will implement the licensee’s physical
protection program to defend against threats to its facility, up to and including the DBT
of radiological sabotage.

6.7.3

The SCP should describe in sufficient detail how the alternative of relying on LE or other
offsite armed responders to perform interdiction and neutralization functions, in lieu of
onsite licensee personnel, will achieve the goals of the licensee SCP to:
(1) organize the response effort using LE or licensee personnel,
(2) provide predetermined, structured response by LE and licensees to safeguards
contingencies,
(3) ensure the integration of the LE and licensee response and other offsite entities, and
(4) achieve a measurable performance in response capability.

6.7.4

The SCP should describe the planning and organizing of the LE and the licensee’s
resources in such a way that the LE responders (i.e., participants) will be identified, their
responsibilities specified, and the responses coordinated. The SCP should also describe
what constitutes a timely LE response, indicate LE responders and licensee contingency
response personnel training and qualification, and detail how coordination between LE
responders and licensee contingency response personnel will be accomplished.

6.7.5

The SCP should describe how the requirements set forth in 10 CFR 73, appendix C,
section II, will be implemented when relying on LE or other offsite armed responders to
fulfill the interdiction and neutralization functions in 10 CFR 73.55(b)(3).

6.7.6

The licensee should provide descriptions of how the LE agency or other offsite armed
responders will fulfill interdiction and neutralization of threats up to and including the
DBT of radiological sabotage in the SCP. These descriptions should be maintained as the

licensing basis justifying the alternative of relying on LE, instead of licensee onsite
armed responders, to fulfill interdiction and neutralization functions.
6.7.7

The licensee should provide descriptions in the SCP in sufficient detail to address how
plant systems and components and facility configurations are designed to provide
security delay functions and integrated with the law enforcement contingency response
plan (LECR). 2 These systems, components and facility configuration must ensure that LE
has sufficient time to respond to a site and conduct the tactical operations required to
interrupt the DBT adversary tasks before the adversary can defeat or circumvent the
licensee’s established delay systems.

6.7.8

In order to meet the requirements of 10 CFR 73.55(c)(5), the SCP should include
descriptions of the activities described in the licensee’s MOU with the LE agency and the
LE agency’s LECR. The LECR should be maintained independent of the licensee
security plan (i.e., physical protection, training and qualification, safeguards contingency,
and cyber security) to establish process and procedures necessary to maintain and
implement the contingency response and assure integration of necessary licensee
personnel and LE for detection, assessment, and interdiction and neutralization functions
of the physical protection program designed to prevent the DBT sabotage of the plant to
cause release of radiation hazards that would endanger the public.

6.7.9

The licensee should describe management measures and controls in the SCP to include
the management and control of changes to the MOU with any LE agency that is relied
upon to fulfill the interdiction and neutralization functions.

6.7.10 The licensee should establish measures and controls to assure the identification, tracking,
and disposition of corrective actions and lessons learned associated with the performance
of LE-related activities.
6.7.11 A licensee should maintain LE records in the possession of the licensee for a period of no
less than 3 years.
6.8

Contingency response planning and implementation
6.8.1

A licensee should establish appropriate frequencies for conduct of planning and
implementation of contingency responses activities with LE agencies for assuring the
capabilities to carry out interdiction and neutralization functions as committed to through
the MOU.

6.8.2

The licensee should ensure that tactical response drills and force-on-force exercises are
conducted in accordance with the requirements of Appendix B, Section VI.C.3.(l)(1) to
10 CFR Part 73.
6.8.2.1 When the licensee relies on LE to perform the interdiction and
neutralization function, the licensee should ensure that the activities,
tactical response drills and force-on-force exercises are planned and

2

A LECR is a law enforcement-developed and -controlled plan. For awareness, LECR is just one label for the plan, or
set of plans, that law enforcement may develop to guide its contingency response to a power reactor site. When a
licensee relies on law enforcement to interdict and neutralize the DBT adversary, the licensee should align its
Safeguards Contingency Plan with whatever law enforcement calls its response plan(s).

conducted in a manner to make them available to the LE agency. The
licensee should conduct a sufficient number of security drills and
exercises to enable LE armed responders who may implement
contingency response and licensee protective strategy to participate in
the licensee-conducted drills and exercises.
6.8.2.2 When the licensee relies on other (i.e., licensee proprietary or contract)
offsite armed responders to perform the interdiction and neutralization
function, the licensee should ensure that all armed responders who may
implement contingency response and licensee protective strategy
participate in licensee-conducted security drills and exercises.
6.8.2.3 Licensee conducted security drills and exercises are performed at the
following minimum frequencies:
•
•
6.8.3

Tactical response drills – quarterly
Force-on-Force exercise – annually

The licensee should conduct the following emergency response preparedness activities
with a minimum frequency as indicated below:
•

Provide plant familiarization and walkdown – once a year, or more frequently for
responders who are unable to identify and self-navigate to all areas of the facility
associated with their security contingency plan or protective strategy
implementation duties and responsibilities.

•

Test communications – twice daily, morning and afternoon.

6.8.4

These frequencies are important because they help to establish reasonable assurance that
the LE will be reliable and prepared to respond to a DBT attack. The licensee should
incorporate these frequencies into applicable site policies, processes, and implementing
procedures.

6.8.5

Consistent with Section 5, “Performance Evaluation Program,” of RG 5.75, “Training
and Qualification of Security Personnel at Nuclear Power Reactor Facilities,” the tactical
response drills may include tabletop exercises, limited-scope tactical response drills, and
timeline verifications that provide a structured process to train response personnel and
evaluate key elements of the safeguards contingency response implementing the
protective strategy by focusing on specific aspects of the strategy without conducting a
fully integrated FOF exercise.

6.8.6

Appendix B, Section VI.C.3.(a) to 10 CFR Part 73, requires that licensees shall develop,
implement and maintain a Performance Evaluation Program that is documented in
procedures and describes how the licensee will demonstrate and assess the effectiveness
of their physical protection program implementing the safeguards contingency response
(i.e., protective strategy), including the capability of the armed response relied on to carry
out interdiction and neutralization functions during safeguards contingency events.

6.8.7

6.9

Acceptable methods for conducting tactical response drills and FOF exercises for
assuring and demonstrating the effectiveness of LE responders to interdict and neutralize
the DBT adversary are described in the following appendices of this guidance:
•

Appendix A, “Conduct of Law Enforcement Contingency Response Drills”

•

Appendix B, “Conduct of Law Enforcement Contingency Response Force-onForce Exercise”

No licensee security responders for interdiction and neutralization
6.9.1

A licensee that satisfies the requirements in 10 CFR 73.55(s)(1) may design its physical
protection program to adequately perform the required security detection, assessment,
and delay functions and then rely on LE to interdict and neutralize the DBT.

6.9.2

A licensee that adopts such an approach should establish the necessary and sufficient
management system and controls, including security organization, to oversee all of these
security functions, including the LE response.

6.9.3

The licensee, having satisfied the requirements in 10 CFR 73.55(s)(1), is relieved of the
requirements in 10 CFR 73.55(k)(3) through (7) relating to armed response personnel,
and because the licensee is relying on LE to interdict and neutralize the DBT, is relieved
from the requirement in 10 CFR 73.55(k)(8)(ii).

6.10 Licensee with onsite or other (i.e., licensee proprietary or contract) offsite security responders for
interdiction and neutralization
6.10.1 Except for relief from 10 CFR 73.55(k)(5)(ii), the licensee must comply with the
requirements in 10 CFR 73.55(k)(3) through (7) and 10 CFR 73.55(k)(8)(ii) for the
licensee’s onsite security personnel and/or other (i.e., licensee proprietary or contract)
offsite security responders who implement its physical protection program.
6.10.2 When a licensee relies on offsite proprietary or contract armed responders to interdict and
neutralize the DBT adversary, the licensee should house the full number of responders
who are needed to adequately defend against the DBT in at least two separate offsite
locations. This arrangement will provide defense in depth and ensure the continuous
availability and reliability of the offsite response.
6.10.2.1

The licensee should establish standards for adequate security of the offsite
facilities that house armed responders and these standards should be included
in its arrangement for proprietary and contract offsite security responders. If
the licensee leases offsite facilities, the lease should include standards for the
adequate protection of these facilities.

6.10.2.2

Considerations should include protection against:
•
Unauthorized access by personnel or vehicles,
•
Disruption of communications,
•
Delay or blockage of the facilities’ egress routes.

6.10.3 In accordance with the provisions of 10 CFR 73.55(c), the descriptions of how
requirements are implemented must be documented in the licensee’s security plans (i.e.,
the PSP , training, and qualification plan, SCP , and cyber security plan).
7.

Compensatory measures for a degradation or absence of law enforcement or other offsite
armed responders
10 CFR 73.55(s)(2)(ii)(A)(5) states that the licensee must identify criteria and measures to
compensate for the degradation or absence of law enforcement or other offsite armed responders
and propose suitable compensatory measures that meet the requirements of paragraphs (o)(2)
and (3) of this section to address this degradation.

7.1

The licensee should develop compensatory measures for the degradation or absences of LE or
other offsite armed responders to fulfill the interdiction and neutralization functions to be
consistent with 10 CFR 73.55(o)(2) to ensure that the compensatory measures will provide an
equivalent level of protection.
7.1.1

7.2

7.3

One straightforward method to meet the equivalency requirement when relying on LE to
fulfill the interdiction and neutralization functions, is for a licensee to coordinate, plan,
and train with at least two LE agencies that independently have sufficient capabilities to
interdict and neutralize threats up to and including the DBT within the time provided by
the licensee facility’s security delay features. Preparing for a security contingency event
in this manner, a licensee should be able to orchestrate support more easily from the
secondary LE agency when the licensee becomes aware that the support needed from the
primary LE agency is degraded or unavailable.

Consistent with 10 CFR 73.55(o)(3), a licensee should have compensatory measures to be
implemented within the specific timeframe needed to ensure that the situations resulting from the
degradation or loss of capabilities from absence of offsite safeguards contingency responses
cannot be exploited.
7.2.1

A licensee should identify possible situations that could result in the unavailability of its
LE or other offsite armed responders. The licensee’s compensatory measures should
include identification of the alternative measures and the timeframe for implementation
of those measures to prevent loss of interdiction and neutralization functions and should
be described in the PSP

7.2.2

The licensee should establish criteria for when to implement the compensatory measures
addressing the possible situations where the LE or other offsite armed responders may be
unavailable or only capable of providing a limited response to fulfill the interdiction and
neutralization functions of contingency responses.

To ensure that equivalent protection is provided by compensatory measures, the licensee should
evaluate the appropriate compensatory measures they would employ.
7.3.1

The evaluation should identify how the degradation affects the ability of LE or offsite
armed responders to fulfill the interdiction and neutralization functions to protect the
plant against threats up to and including the DBT of radiological sabotage, with the most
security significance attributed to the degradation or loss of capability to interdict and
neutralize the DBT adversary.

7.4

7.3.2

The considerations of how adversely the degraded situations affect interdiction and
neutralization functions should determine the equivalent compensatory measure that the
licensee must implement. One acceptable approach could be to provide response by
licensee’s available assets and staffing necessary to provide equivalent capability to
compensate for the degradation. Use of other LE or other offsite armed responders could
also provide an acceptable approach.

7.3.3

Procedures for evaluating the measures should take into consideration the safety/security
interface requirements of 10 CFR 73.58, including plant configurations and facility
conditions.

7.3.4

This evaluation should be focused on specific degradations and the implementation of
compensatory measures that would provide equivalent functions, to include consideration
of changes in plant safety operations, conditions, and/or configurations that may
compensate for the degradation (e.g., safe shutdown, reduce radiological hazards, change
material configurations, additional barriers, increase delay, etc.).

The degradation that should be considered in the evaluation may range from individual
degradation to multiple degradation or complete loss of interdiction and neutralization functions
(i.e., absence of LE or other offsite armed responders).
7.4.1

During this evaluation, the staffing or assets to compensate for multiple degradations
should be considered.

7.4.2

Then, the overall interdiction and neutralization functions should be reviewed to
determine the impact of applied compensatory measures with respect to compensating the
LE or other offsite armed responder capability to perform security operations and execute
the required actions to interdict and neutralize threats up to and include the DBT
adversary.

7.5

The purpose of a compensatory measure evaluation is to ensure that the integrity of the licensee’s
physical protection program is not reduced beyond acceptable standards and that the contingency
response capabilities are maintained to achieve the physical protection program’s overall
performance objective and meet the requirements of 10 CFR 73.55(b).

7.6

Using a compensatory measures evaluation, licensees may develop a reference of pre-determined
actions or measures applicable to their site, which identifies potential degradations and predetermined measures to compensate for the degradations.

7.7

7.6.1

Licensee should be aware that, as a general policy, armed security personnel serving as a
compensatory measure for functions other than interdiction and neutralization functions
should not be considered simultaneously available for the compensatory measure
intended to compensate for security response to implement interdiction and
neutralization.

7.6.2

For example, a licensee’s capabilities to assess, detect, delay, interdict and neutralize
should be maintained through the implementation of compensatory measures.

In determining the proper application of appropriate compensatory measures in a situation of
degradation of LE or other offsite armed responders, the licensee should consider the use and
application of all security assets with the minimum standard complement of security staffing.

7.7.1

7.8

The results of a compensatory measures evaluation may demonstrate the need for additional
staffing at a certain time or during certain situations.
7.8.1

7.9

This approach would provide continued assurance that the integrity of the licensee’s
physical protection program will be maintained by verifying that the measures the
licensee employs to compensate for degradation in a situation do not reduce the site’s
overall physical protection capabilities.

The licensee should consider this additional staffing during workforce planning so that it
does not create vulnerabilities or degradation in the required capabilities to perform
interdiction and neutralization functions.

Immediate measures provide a level of response to a degradation or loss of functions to minimize
the possible exploitation until longer term measures can be taken.
7.9.1

Consistent with 10 CFR 73.55(o)(2), compensatory measures must provide an equivalent
level of protection until the degradation or loss of f interdiction and neutralization
functions is corrected.

7.9.2

Consistent with 10 CFR 73.55(o)(3), compensatory measures must be implemented
within specific time frames necessary to meet the requirement of 10 CFR 73.55(b).

7.9.3

To satisfy these requirements, the compensatory measure that provides an equivalent
level of protection should be in place within the appropriate time frame based on the
licensee’s evaluation of the significance of the degradation.

7.10

When degradation consisting of the absence of LE or other offsite armed responders to perform
interdiction and neutralization functions is identified or discovered, licensee must, as soon as
possible, initiate corrective actions and restore functions in a graded timeframe appropriate and
commensurate with the significance of the degradation.

8.

Alternative requirements for physical barriers
10 CFR 73.55(s)(2)(iii) states that a licensee that meets 10 CFR 73.55(s)(1) may utilize means
other than physical barriers and barrier systems to satisfy the physical protection program
design requirements of 10 CFR 73.55(e). Acceptable means can be any method(s) that
accomplishes the delay and access control functions necessary to allow the licensee to implement
its physical protection program.

8.1

Engineered passive or active barrier systems
8.1.1

Alternative means of providing security delay or access control functions that meet the
performance objective and requirements of 10 CFR 73.55(b) may be in the form of active
and passive engineered systems other than the physical barriers defined in 10 CFR 73.2,
which specifies the design of fences and the construction of building walls, ceilings, and
floors.

8.1.2

Consistent with the definition in 10 CFR 73.2 for physical barrier that “any other physical
obstruction constructed in a manner and of materials suitable for the purpose for which

the obstruction is intended,” the alternative means for physical barriers should be
constructed of material suitable to achieve the security delay and access control.
8.1.3

Examples of engineered active or passive systems that may be used to perform delay
functions include, but are not limited to, those described in SAND2007-5591, Security
Assessment Technical Manual (e.g., sticky foam, obscurant and deployable barriers,
munition-based access denial systems, gabion-filled walls, Silent Defender, Virtual
Presence and Extended Defense system, etc.), engineered barrier systems (e.g., gates,
vault type doors, turnstiles, etc.) currently deployed at currently operating power reactors,
and new technologies (e.g., millimeter wave, long range acoustic device, etc.).

8.1.4

The capability to implement an appropriate security delay should be met and maintained
by the design of a physical protection system to achieve the performance criteria where
the design of SSCs relied on for delay functions provides assurance of necessary and
sufficient time for licensee security responders, LE, or a combination of licensee security
responders and LE to interdict and neutralize the DBT before it achieves radiological
sabotage.

8.1.5

8.1.4.1

To provide adequate delay, licensees or applicants should design their
security systems to be able to delay the DBT adversary for a time equal to or
greater than a site’s SBT, based on the process described in Appendix C,
“Security Bounding Time and Adversary Interference Precluded Time,” of
this guidance.

8.1.4.2

The design of security delay systems should be appropriately layered for
defense-in-depth.

8.1.4.3

Design of security delay systems may include passive barriers that obstruct
or physically delay the passage of person, vehicles, and material.

8.1.4.4

Acceptable delay, where appropriately designed, may include physical space
that provides delay by means of physical separations, which are evaluated
and considered in developing response timelines for security or LE response.

The alternative means of a physical barrier for security delay may also consider
engineered active systems (e.g., remotely operated weapon systems, munition-based
access denial systems, counter sniper remotely operated system) that can perform
neutralization functions, which could successfully prevent the DBT adversary from
performing or completing tasks.
8.1.5.1 The design of engineered physical security SSCs that perform neutralization of
the DBT adversary should take into consideration their potential impact on
security responders and the effectiveness of the security response. Licensees may
take credit for the required security delay functions performed by such physical
security SSCs if appropriate.
8.1.5.2 For example, the design of engineered physical security SSCs that perform
neutralization functions, engineered fighting positions relied upon for protecting
engineered systems, and components relied upon to perform neutralization
functions should provide overlapping fields of fire.

8.1.5.3 The design configuration should provide layers of opportunities for security
response, with each layer assuring that a single failure does not result in the loss
of capability to neutralize the DBT adversary.
8.1.6

A licensee should design physical barriers to satisfy the requirements of 10 CFR
73.55(e). The licensee may use the acceptance criteria in SRP Sections 13.6.1 and 13.6.2
to assist in the design of physical barriers.

8.1.7

In order to satisfy the analysis requirement in 10 CFR 73.55(s)(1)(iv) the licensee should
describe in sufficient detail the specific use, type, function, and placement of physical
barriers needed in a physical protection system designed to protect against the DBT
adversary to achieve the requirements in 10 CFR 73.55(b) and needed to implement
elements of a physical protection program in accordance with requirements in 10 CFR
73.55.

8.1.8

In order to satisfy the requirements of 10 CFR 73.55(c), the licensee should describe and
capture the design and implementation of an alternative physical barrier system as part of
the facility security licensing basis.

8.1.9

The licensee should describe in sufficient detail in the security plans how the engineered
and administrative controls, management systems, and organization meet the
requirements in 10 CFR 73.55.

8.1.10 The licensee should design its physical barrier system for automated access control to
include anti-piggybacking, anti-tailgating, and anti-pass back functions for control of
personnel and material.
8.1.11 NUREG-1964, “Access Control Systems: Technical Information,” provides physical
barrier configurations that may be considered in a licensee’s design of protected area
personnel access control portals.
8.1.12 The licensee should design the configuration of physical barrier systems for access
controls to satisfy the requirements of 10 CFR 73.55(g). The licensee may use the
acceptance criteria in Standard Review Plan Sections 13.6.1 and 13.6.2 to assist in the
design of access control measures.
8.1.13 Physical vehicle barrier system designs, typically installed at currently operating power
plants, are designed and installed to prevent vehicles from entering (or leaving) and may
consist of passive (fences, walls, concrete blocks, concrete and sand barriers, shallow
vehicle barriers, etc.) and active (pop-up vehicle barrier, hydraulic barriers, etc.) systems.
Vehicle physical barriers may also use natural terrain (e.g., rocks, mountains, rivers, thick
forests, ravines, etc.). The vehicle control measures (passive and active barrier systems)
to deny land or waterborne vehicle bomb assaults should be located at a bounding
minimum safe stand-off distance to adequately protect all SSCs required for safety and
security from an explosion based on the maximum DBT quantity of explosives.
8.1.14 In accordance with 10 CFR 73.55(e)(1)(ii), the use of alternative physical security
requirements using means other than physical barriers as defined in 10 CFR 73.2 must be
described in the PSP. In accordance with 10 CFR 73.55(e)(2), the licensee is required to
retain, in accordance with 10 CFR 73.70, “Records,” all analyses and descriptions of the
physical barriers and barrier systems used to satisfy the physical protection program

design requirements of 10 CFR 73.55(e). The descriptions of how physical barriers are
applied in the design of a physical protection program to provide delay functions (i.e., the
details of analyses supporting the design of the alternative means to achieve the intended
delay functions, the locations, and specific details, including implementing procedures)
are considered safeguards information and must be protected in accordance with the
requirements of 10 CFR 73.21, “Protection of Safeguards Information: Performance
Requirements.”
9.

Alternative requirements for secondary alarm station

10 CFR 73.55(s)(2)(iv) states a licensee that meets paragraph (s)(1) of this section:
(A) May have one alarm station located offsite notwithstanding the requirement in paragraph
(i)(2) of this section to have at least two alarm stations located onsite. The central alarm
station must remain onsite.
(B) With a secondary alarm station located offsite, is relieved from the requirement in (i)(4)(iii)
of this section to construct, locate, and protect the offsite alarm station to the standards
for the central alarm station. The licensee is not relieved from the requirement in
(i)(4)(iii) that both alarm stations shall be equipped and redundant, such that all
functions needed to satisfy the requirements of paragraph (i)(4) of this section can be
performed in both alarm stations.
9.1

9.2

This alternative requirement permits a licensee that meets 10 CFR 73.55(s)(1) to design a
physical protection program with a secondary alarm station located offsite.
9.1.1

The alternative requirement provides relief from compliance with the construction,
location, and protection requirements in 10 CFR 73.55(i)(4)(iii) for an offsite secondary
alarm station.

9.1.2

In addition, the requirements in 10 CFR 73.55(i)(4)(i)(D) and 10 CFR 73.55(i)(4)(ii)(A)
related to constructing, locating, and protecting an offsite secondary alarm station would
not be applicable for a secondary alarm station that is located offsite.

The licensee’s design of its secondary alarm station is required to be equal and redundant with all
functions performed in a secondary alarm station located onsite.
9.2.1

The licensee should identify the required security functions of the secondary alarm
station for implementing the physical protection program and meeting the applicable
requirements in 10 CFR 73.55.

9.2.2

An offsite secondary alarm station should be capable of performing the following alarm
station functions:
•
receiving and monitoring signals for intrusion detection,
•
receiving and monitoring video image signals to assess intrusion,
•
provide command and control of the licensee security response,
•
summoning offsite local, state, and federal LE assistance, and
•
communicating with onsite/offsite security to assist implementing the security
response.

9.2.3

Equipment in the central and secondary alarm stations does not have to be identical.
However, both alarm stations must have the same functional capabilities.

9.3

Where a licensee has designed its physical protection program to include remote capabilities to
control access, activate delay barriers, or operate a security interdiction/neutralization system, the
design of the secondary alarm station offsite should include the systems and components for
assuring reliable remote operation and control of access, delay barriers, and security systems.

9.4

The licensee’s secondary alarm station should consider the design for communications where the
SSCs dedicated or plant operations systems relied on for communications provide assurance of
continuity and integrity of alarms, video, voice, and text, and where applicable, instrument and
control communications between the secondary alarm station and the site’s central alarm station
and LE agencies or other offsite armed responders.

9.5

9.4.1

Communications and control systems should be designed to be designed to address the
ability of the DBT adversary to interrupt or interfere with the continuity or integrity of
communications.

9.4.2

The design should apply the principles of redundancy and diversity.

A licensee may use a monitoring service to fulfill the security functions that should be performed
by a secondary alarm station.
9.5.1

The monitoring service should be certified by an independent testing and certifying
organization promulgating for such services to ensure that the service is reliable,
available, and capable of implementing the licensee’s physical protection program that is
designed to meet the objectives and requirements of 10 CFR 73.55(b).

9.6

For a secondary alarm station that is designed to serve more than one plant site (i.e., supports the
implementation of multiple physical protection programs), the alarm station should be equipped
and sufficiently staffed to provide the capability of monitoring and responding to multiple alarms,
performing simultaneous assessments, initiating multiple security systems responses, providing
command and control of the responses, and summoning for offsite assistance for all serviced
sites.

9.7

The descriptions in the design and security licensing bases should capture the application and
implementation of the alternative requirement that permits a secondary alarm station to be located
offsite.
9.7.1

10.

The descriptions of the offsite secondary alarm station should satisfy the requirement in
10 CFR 73.55(c), where the security plans (consisting of a PSP, T&QP, SCP, and CSP)
adequately describe in sufficient detail how engineered and administrative controls,
management systems, and organization meet the requirements in 10 CFR 73.55.

Alternative requirements for vital areas

10 CFR 73.55(e)(9)(v) states that at a minimum, the following shall be considered vital areas:
(A) The reactor control room;
(B) The spent fuel pool;
(C) The central alarm station; and
(D) The secondary alarm station in accordance with § 73.55(i)(4)(iii).
10 CFR 73.55(e)(9)(vi) states that at a minimum, the following shall be located within a vital area:

(A) The secondary power supply systems for alarm annunciation equipment; and
(B) The secondary power supply systems for non-portable communications equipment.
10 CFR 73.55(s)(2)(v) states that a licensee that meets 10 CFR 73.55(s)(1):
•
is relieved from the requirement in paragraph (e)(9)(v)(D) of this section to designate an
offsite secondary alarm station as a vital area.
•
is relieved from the requirement in paragraph (e)(9)(vi) of this section to locate the
secondary power supply systems for an offsite secondary alarm station in a vital area.
Clarifications:
10.1

In addition to being relieved of the requirement to designate the offsite secondary alarm station as
a vital area [per 10 CFR 73.55(e)(9)], the prescribed vital area protection requirements would no
longer be applicable to a secondary alarm station located offsite.

10.2

A licensee would no longer be required to comply with the prescriptive requirements for physical
barriers, target sets, access controls, and detection and assessment that would normally be
associated with a secondary alarm station vital area pursuant to subsections 10 CFR 73.55(e), 10
CFR 73.55(f), 10 CFR 73.55(g), and 10 CFR 73.55(i), respectively.

11.

10 CFR 73, Appendix B, Section VI, “Nuclear Power Reactor Training and Qualification
Plan for Personnel Performing Security Program Duties”

10 CFR 73, Appendix B, Section VI.A.1. states:
For light-water reactors, other than small modular reactors, as defined in 10 CFR 171.5
of this chapter, the licensee shall ensure that all individuals who are assigned duties and
responsibilities required to prevent significant core damage and spent fuel sabotage,
implement the Commission-approved security plans, licensee response strategy, and
implementing procedures, meet minimum training and qualification requirements to
ensure each individual possesses the knowledge, skills, and abilities required to
effectively perform the assigned duties and responsibilities.
For small modular reactors, as defined in 10 CFR 171.5 of this chapter, or for non-lightwater reactors, the licensee shall ensure that all individuals who are assigned duties and
responsibilities required to prevent a significant release of radionuclides from any
source, implement the Commission-approved security plans, licensee response strategy,
and implementing procedures, meet minimum training and qualification requirements to
ensure each individual possesses the knowledge, skills, and abilities required to
effectively perform the assigned duties and responsibilities.
11.1

A licensee training and qualification program for licensee security personnel should conform to
RG 5.75.

11.2

On the basis that LE responders are trained and qualified at a level that is equivalent to or greater
than that required by Appendix B, the requirements do not apply to LE personnel who a licensee
relies on to perform interdiction and neutralization functions.

D. IMPLEMENTATION
The NRC staff may use this RG as a reference in its regulatory processes, such as licensing,
inspection, or enforcement. However, the NRC staff does not intend to use the guidance in this RG to
support NRC staff actions in a manner that would constitute backfitting as that term is defined in 10 CFR
50.109, “Backfitting,” and as described in NRC Management Directive 8.4, “Management of Backfitting,
Forward Fitting, Issue Finality, and Information Requests,” (Ref. 30), nor does the NRC staff intend to
use the guidance to affect the issue finality of an approval under 10 CFR Part 52, “Licenses,
Certifications, and Approvals for Nuclear Power Plants.” The staff also does not intend to use the
guidance to support NRC staff actions in a manner that constitutes forward fitting as that term is defined
and described in Management Directive 8.4. If a licensee believes that the NRC is using this RG in a
manner inconsistent with the discussion in this Implementation section, then the licensee may file a
backfitting or forward fitting appeal with the NRC in accordance with the process in Management
Directive 8.4.

ACRONYMS/ABBREVIATIONS
The following abbreviations are used in this RG:
ADAMS

Agencywide Documents Access and Management System

AIPT

Adversary Interference Precluded Time

CAS

central alarm station

CFR

Code of Federal Regulations

CSP

cyber security plan

COL

combined license

DBT

design basis threat

DE

dose equivalent

DG

draft regulatory guide

FOF

force on force

FSAR

final safety analysis report

IAEA

International Atomic Energy Agency

LE

law enforcement

LECR

law enforcement contingency response plan

LLEA

local law enforcement agency

LWR

light-water reactor

MAF

mock adversary force

MILES

Multiple Integrated Laser Engagement System

MOU

memorandum of understanding

NRC

U.S. Nuclear Regulatory Commission

OMB

Office of Management and Budget

OL

operating license

PRA

probabilistic risk assessment

PSP

physical security plan

RG

regulatory guide

SAR

safety analysis report

SAS

secondary alarm station

SCP

safeguards contingency plan

SBT

security bounding time

SGI

safeguards information

SMR

small modular reactor

SRP

Standard Review Plan

TEDE

total effective dose equivalent

T&QP

training and qualification plan

Appendix A to DG 5072
Conduct of Law Enforcement
Contingency Response Drills
1
1.1

OVERVIEW
Regardless of whether licensees elect to rely on LE or other offsite armed responders to interdict and
neutralize the DBT adversary, licensees are required to establish, implement, and maintain a
performance evaluation program consistent with the requirements in Section VI.C.3 of Appendix B to
10 CFR Part 73. A performance evaluation program is a critical tool that licensees use to demonstrate
and assess the effectiveness of their physical protection programs and protective strategies, including
the capabilities of armed responders to carry out their assigned duties and responsibilities during
safeguards contingency events.
1.1.1

When relying on proprietary or contract armed security responders to interdict and neutralize
the DBT adversary, licensees should follow the security drill and exercise guidance in the
Performance Evaluation Program Section (i.e., Section 5) of RG 5.75.
1.1.1.1

1.1.2

When relying on LE responders to interdict and neutralize the DBT adversary, licensees
should follow the guidance in Appendices A and B of this publication.
1.1.2.1

1.2

Licensees should also consider the guidance in Appendices A and B of this
publication when that guidance would be suitable for drilling and exercising with
licensee security personnel who are normally positioned off site.

The guidance in Appendices A and B is similar to that in RG 5.75, but it has been
modified to account for the different considerations that will exist when relying
upon LE responders rather than licensee-controlled security personnel.

This guidance establishes performance objectives and provides an overview of one recommended
method for the planning and execution of both a Tabletop Exercise (TTX) and Limited Exercise (LX)
addressing the site-specific LE agency contingency response at an operating nuclear power reactor.
1.2.1

Consistent with Section 1.4 below, LE TTXs and LXs are two acceptable methods that
licensees can use to satisfy the quarterly tactical response drill requirement in Section
VI.C.3.l.(1) of Appendix B to 10 CFR Part 73.

1.3

The objectives and outcomes of exercising the protective strategies in the law enforcement
contingency response (LECR) plan should be to ensure that the capabilities to interdict and neutralize
the DBT adversary are met, thereby protecting against the DBT of radiological sabotage. The
performance objectives typically describe the expected results from effective implementation of the
LECR.

1.4

The types of LECR drills may include the following:
1.4.1

Tabletop drills are performed to demonstrate the protective strategy using a mockup of the
facility. Tabletop drills allow security force members to demonstrate their understanding of
the protective strategy and their individual role in implementing response to contingency
events. This type of drill may also be used as an evaluation tool for determining the
effectiveness of the licensee protective strategy that relies on LE response to contingency
events.

DG-5072, Appendix A, Page 1

Appendix A to DG 5072
Conduct of Law Enforcement
Contingency Response Drills

1.7

1.4.2

Timeline drills are performed to demonstrate the response timelines established for the armed
response personnel implementing the LECR to interdict and neutralize the DBT adversary.
Drills can be used to test either the validity of the timelines established within the LECR or to
test the ability of the LECR’s tactical operations to be performed within established timelines
to interrupt DBT adversary tasks prior to defeat of licensee delay systems.

1.4.3

Limited scope tactical response drills are performed to evaluate the ability of one or more LE
or security response force members to effectively implement their protective strategy
responsibilities. These drills are conducted as needed for each individual, group, or shift to
validate and test the protective strategy.

1.4.4

This is guidance for conducting the LX. The LE LX provides an opportunity to practice the
response to a hostile action directed against the licensee’s nuclear power plant. An LX should
be conducted on a recurring periodic basis to ensure the continued capability to effectively
implement the LECR. The frequency of LX recurrence should be agreed upon by the licensee
and LE agency (or agencies) in accordance with the minimum required frequencies in Section
VI, paragraph C.3.(l)(1) of Appendix B to 10 CFR Part 73.

1.4.5

The licensee SCP should include a description of the activities described in the licensee’s
MOU with the LE agency and the activities described in the LE agency’s LECR. The LECR
describes how LE will perform interdiction and neutralization of the DBT adversary. The
licensee, in conjunction with the LE agency, should review the description of these activities
at least annually or when plant changes warrant review and update. Significant organizational
changes, either at the licensee or within the LE agency, may warrant additional reviews.
Licensees may elect to include this activity as part of their periodic interactions with LE
agency.

While an LE LX has many elements in common with regulatory required security drills and exercises
typically involving licensee onsite security forces, there are important differences. To aid in
understanding these differences, the key attributes of an LX are listed below.
1.7.1

The LX utilizes as its base document a fully complete, signed, and issued LECR developed
through the combined efforts of the licensee and LE agency or agencies, which may include
State and Federal agencies.

1.7.2

The licensee should be prepared to provide information, plant and operations overview with
prominent buildings identified, structural drawings including the location of any safety,
security, and emergency preparedness significant SSCs for LE operational planning and
contingency responses to interdict and neutralize threats.

1.7.3

The LX scenario will postulate responses to threats, with the goal of testing the contingency
response strategy to ensure that it can successfully protect against threats up to and including
the DBT of radiological sabotage.

1.7.4

The tactical responses may be simulated with outer and inner-plant navigational and
communication exercises. Full tactical response is not required to be performed in the field.
The licensee may consider the addition of elements into their LECR exercise designed to
provide a more interactive exercise. See Attachment C, Exercise

DG-5072, Appendix A, Page 2

Appendix A to DG 5072
Conduct of Law Enforcement
Contingency Response Drills
Benefits/Challenges/Limitations, for further information regarding the benefits, challenges,
and limitations of various exercise formats.
1.8

Licensee operational personnel may be necessary to simulate any safety and security measures and
functions (e.g., Main Control Room, Central Alarm Station), and on-shift safety/security actions.

1.9

Licensee’s operations personnel should provide information on any plant safety and security priorities
(which will lead to specific LE response) or support LE response related to the planning of on-site
tactical operations.

1.10

The conduct of an LX should include actual or simulated activation and operation of an on-site or
near-site Tactical Operations Center (TOC). Depending upon LECR protocols, other facilities defined
within the licensee’s SCP should be activated or have their activation simulated.

1.11

Licensee personnel, local, State and/or Federal LE agencies should demonstrate the ability to
coordinate initial response actions including implementation of plant safe shutdown measures, security
delay systems, any autonomous interdiction/neutralization systems, including any coping/mitigation
actions, and protection services in both a pre-, active, and post-attack environment.

1.12

To ensure opportunities for demonstration of certain LECR defined capabilities, it will be necessary
for the scenario to employ an adversary force with at least the attributes and characteristics of the
DBT. In addition, LX constraints may require that certain events, consequences, or response actions be
embellished or presented in a time-compressed fashion. LX participants should be made aware of
these stipulations, and of the expectation to assess, and respond to, the events as presented.

1.13

LX scenarios should be developed with the goal of testing the licensee’s contingency response strategy
to ensure that it can successfully protect against the DBT adversary force. Further, performance in
these exercises should demonstrate the licensee’s ability to successfully implement the PSP and SCP.

1.14

The NRC recognizes the LE response will be site-specific and the local and state law enforcement
agencies and jurisdictions surrounding different nuclear power plants have varying protocols in
implementing the National Incident Management Systems (NIMS). NIMS-related facilities beyond
those for on-scene incident command directly located at or near the site should not be needed by the
licensee as part of an LX.

2

LECR LIMITED EXERCISE OBJECTIVES
2.1.

To ensure the continued viability of the LECR, the NRC recommends that a licensee maintain
a set of LX Objectives for its facility. These objectives should guide the periodic
demonstration of response functions described in the licensee’s SCP. The set of objectives
should include those functions uniquely performed in response to a hostile action targeting the
site.

2.2.

The primary and overarching objectives of an LX should include:

DG-5072, Appendix A, Page 3

Appendix A to DG 5072
Conduct of Law Enforcement
Contingency Response Drills
2.2.1.

Ensuring an understanding of the tactical integration components of the LECR,
including a review of the expected process for Identifying Friend or Foe (IFF) 3 and
accessing the plant (e.g., owner controlled area (OCA), protected area (PA), vital
areas (VA)).

2.2.2.

Providing an opportunity for LE tactical teams to self-navigate within the OCA or PA,
particularly to and from the VA, including those inside the Radiological Controlled
Area (RCA) inside the power block.

2.2.3.

Demonstrating the communication systems, components, processes, and procedures
anticipated to be used to support LE tactical operations under actively hostile
conditions, including a radiation hazards environment.

2.3

Additionally, Attachment 1 to this Appendix, Recommended LECR Limited Exercise
Objectives, presents generic guidance that a site should use to develop a set of LX objectives.
Each Recommended Objective has an associated description or listing of Performance
Attributes; these attributes define successful objective performance and should be used to
develop evaluation criteria for each objective.

2.4

The development of objectives and evaluation criteria should be informed by the site-specific
LECR as well as applicable law enforcement agencies (local, state, and federal) and licensee
support personnel implementing a potential contingency response.
The planning for subsequent LX performance should include a review of past performance
objectives and outcomes.

2.5

3

The licensee, with LE participation, should critique TTX and LX performance to identify
opportunities for improvement and as appropriate specific lessons learned should be captured
in the licensee’s’ corrective action program or with other appropriate methods identified by
participating LE agencies.

LECR LIMITED EXERCISE PREPARATION

This section highlights preparation tasks and support needs unique to an LX. Each item should be
reviewed, and identified actions incorporated into the appropriate LX preparation, process, and schedule.
3.1

GENERAL
3.1.1

3

An Exercise Manager should clearly communicate expectations to the scenario developers and
controllers concerning the handling and forwarding of materials used to prepare for and
conduct the LX. More specifically, personnel must observe all Safeguards Information (SGI)
and 10 CFR 2.390, “Public inspections, exemptions, requests for withholding,” requirements.
The Exercise Manager should identify the site resources necessary to conduct the LX and
ensure that they are scheduled and reserved. Consider items such as the licensee’s safety and
security personnel and equipment, offsite response personnel and equipment, etc.

Identifying Friend or Foe (IFF) - A system developed and recognized between the licensee site personnel and response forces
to distinguish themselves from enemy forces.

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3.1.2

3.2

EXERCISE SUPPORT FROM SECURITY
3.2.1

3.3

Based upon the anticipated level of personnel and their equipment participating in the LX
response, the licensee may notify local news media companies that the site will be conducting
an LX. These contacts are intended to preclude unexpected, and possibly inaccurate or
alarming, coverage. This section highlights preparation tasks and support needs unique to an
LX. Each item should be reviewed, and identified actions incorporated into the appropriate LX
preparation, process, and schedule.

Licensee safety and security is critical to the successful development and execution of the LX.
Safety and security personnel provide valuable direction and assistance to exercise participants
in the following areas.
(1)

Verifying protection of Safeguards Information in LX materials or during the LX.

(2)

Assuring knowledge of safety and security-related procedures, equipment, and
timelines.

(3)

Developing credible DBT attack sequences, and related reports and indications.

(4)

Devising methods to simulate response actions and communications with safety and
security facilities and licensee personnel.

(5)

Facilitating LX planning and preparation with LE (local, State, and Federal)
personnel.

(6)

Providing knowledgeable controllers for safety and security facilities/functions.

(7)

Verifying no plant safety operational impact from LX performance.

(8)

Establishing credible operational objective for LX contingency response planning.

(9)

Validating LE agency site familiarity.

TACTICAL OPERATIONS CENTER
3.3.1

Within the Incident Command System (ICS), the Incident Commander (IC) assigns
responsibility for establishing a TOC for implementing security operations. The TOC IC is
responsible for command and control of contingency response to interdict and neutralize the
DBT. A primary and alternate TOC location should be identified within the SCP and the
LECR. The selected locations should have the resources and capabilities needed to facilitate
performance of TOC functions either in place or readily available as defined within the
licensee’s SCP.

3.3.2

The LX TOC should be established in a location that would actually be used during a real
event, and not one selected primarily to facilitate LX performance. LX focused TOC
placement may mask challenges to logistics, communications, and security or preclude the

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need for important discussions (e.g., how to respond when the TOC is located within an area
that must be evacuated).
3.4

COMMUNICATIONS
3.4.1

Equipment, resources, and protocols should be in place to facilitate communications among
responders at the TOC, security facilities (including licensee alarm station, main control room,
and simulated facility locations), tactical teams, and in-fields/on-scene locations. These
communications paths should be clearly defined and verified (i.e., test communication
compatibilities and capabilities prior to the LX). The conduct of communications systems
testing prior to the LX is preferred so that the exercise can be conducted within the limitations
expected in an actual response condition.

3.4.2

Additional considerations regarding communications are listed below.
(1)
(2)
(3)

If a communications capability is dependent upon site personnel and offsite armed
responders trading radios with one another, ensure that this action can be performed
given the security situation created by the LX scenario.
If available, evaluate deployment and use of designated offsite response
communications vehicles (e.g., a mobile command post) to provide and validate
communications interoperability and to provide training to responders.
Confirm testing alternate means of communication (e.g., by simulating a loss of
cellular phone service) at some point.

3.5 PRE-EXERCISE BRIEFINGS AND LEARNING OPPORTUNITIES

3.5.1
3.6

LECR TABLETOP EXERCISE
3.6.1

4

The licensee should provide key exercise participants with a thorough briefing on the
proposed LX scenario, to include the scope, extent-of-play, and performance expectations.

The licensee should perform an LE TTX with the participating LE agency or agencies
identified in the LECR prior to the initial LX and on a periodic basis not longer than every
three years. A TTX provides LE personnel with an opportunity to review and discuss their
respective roles, priorities, and response actions as described in the licensee’s SCP and in the
LECR. Refer to Section 6.0, LECR Tabletop Exercise Implementation, and Attachment 2,
Tabletop Exercise Guidelines, of this Appendix for information on conducting an LECR TTX.

SCENARIO DEVELOPMENT
This section highlights preparation tasks and support needs unique to development of DBT level
hostile attack scenarios. Each item should be reviewed, and identified actions incorporated into the
appropriate scenario preparation process and schedule. Scenarios should be developed with the goal of
testing the licensee’s contingency response strategy, including LE response activities relied upon by
the licensee to perform interdiction and neutralization of the DBT adversary

4.1

SCENARIO TEAM

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4.1.1

4.2

4.3

A team of representatives of the licensee, LE agency, and other applicable agencies should be
used. This should include decision-makers of the local, State, and Federal responds agencies.
The licensee should engage LE personnel early in the scenario development process to define
and discuss scenarios, events, and challenges and to confirm LE agency participation in the
upcoming exercise.

SAFEGUARDS/SECURITY SENSITIVE INFORMATION
4.2.1

LE drills and exercise scenario materials have the potential to contain safeguards information
(SGI). Due to their potential information value, scenario materials should be reviewed and
designated as SGI when appropriate. Licensees should share experiences and insights with LE;
however, caution should be used to ensure that SGI is protected and not released to
unauthorized personnel.

4.2.2

The licensee should take steps to prevent information, such as details of delay features and
systems, complete “target set” descriptions, or other plant design and features that would
reveal information for DBT sabotage, from being specified in the scenario. If defeat or delay
systems and security features and the destruction of a complete target set is necessary to
describe exercise objectives, then the scenario should specify other damaged or out-of-service
equipment such that the descriptions do not reveal safeguards information. Failure to observe
these precautions could result in the release of sensitive information to unauthorized
personnel.

SCENARIO DEVELOPMENT AND KEY ATTRIBUTES
4.3.1

When developing an LX scenario, the first decision to be made is whether the attack will
consist of a standalone insider, cyber attack, a standalone vehicle borne explosive, a landbased or waterborne coordinated attack or an attack consisting of a combination of these
elements. The scenario team must also determine which primary and, if appropriate, alternate
facilities and/or staging areas will be used, as this will likely affect the actual or assumed
exercise date and time.

4.3.2

Figure 4-1, Framework for an Offsite Law Enforcement Agency Contingency Response
Limited Exercise, presents recommended frameworks for developing an LX scenario. The
scenario should consist of two phases, with proposed attributes for each phase. The
timeframes for certain actions may be compressed relative to what would be experienced
during an actual hostile action. This compression may be necessary in order to conduct the
exercise within a reasonable period.

4.3.3

Licensees should ensure that the scenario reflects realistic timelines and notification
procedures. With respect to the attacking force, the scenario may only specify a number of
attackers and associated weaponry in accordance with that defined by the DBT of radiological
sabotage. The scenario is expected to address the outcomes resulting from a hostile action
executed by a force representative of the current DBT. To be an effective test of the licensee’s
contingency response strategy, the scenario events should be designed to challenge the
capabilities of the armed responders and be expected to cause, or threaten to cause, damage to
irradiated fuel and other sources that could result in significant radiological release. The
damage, or threat of damage, may be directed towards irradiated fuel in the reactor core,
radiological material inventory in systems interconnected to the reactor, or the spent fuel pool.

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Contingency Response Drills
4.3.4

The scenario events must create a “sense of urgency” in the assessment of plant conditions,
response strategies, and dispatch of teams to perform three primary mission types below:


Locate, interdict, and neutralize the DBT adversary,



Retake and defend the plant from the DBT adversary, and



Either (1) or (2) with the additional responsibility of licensee response.

4.3.5

The scenario should present conditions which could, absent mitigating actions, lead to a
radiological release. The scenario may be structured such that a radiological release is
prevented if exercise players take appropriate and timely mitigating actions.

4.3.6

A LECR exercise scenario should address the following elements:

4.3.7

•

Scenario messages containing detail sufficient to ensure that LE responders (e.g.,
incident command and control, tactical operations, facilities, etc.) fully understand the
nature and consequences of the attack.

•

During or immediately following a hostile action, the scenario may allow for
demonstration of the ability to dispatch licensee personnel to perform time-sensitive
actions. The dispatching of licensee personnel in this environment should be
coordinated with the LE agency and the IC.

•

The scenario should not postulate a condition which enables unchallenged or
uncontrolled movement of on-site or LE agency personnel. Rather, the scenario
should cause the IC to assess the active- or post-attack conditions and security/safety
in a deliberate and prioritized manner. Example strategies supporting response include
use of designated routes and tactical response.

•

Ensure that the events and cues necessary to drive decision-making concerning the
site-specific contingency responses are well integrated into the scenario timeline and
related materials. The number and location of required actions described in the
scenario should be commensurate with the nature of the postulated attack.

Options for scenario developers may include the following:

•

The exercise’s initial conditions may specify that certain equipment is out-of-service
(e.g., undergoing maintenance). These out-of-service components may compound the
results of the adversary attack. . This approach may also assist with the masking of a
complete target set, e.g., a critical component is out-of-service, not affected by the
attack, and later returned to service to mitigate the event.

•

An “insider” may be used to facilitate an attack or exacerbate its effects. Scenarios
using an “insider” should include the additional information necessary to play the
insider role (e.g., the individual’s name, badge number, location and areas traversed).

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4.4

4.5

4.6

•

Use of diversionary actions, threats, or attacks at offsite locations.

•

Consider response capabilities that support responding tactical teams. Examples
include bomb squads, canine units, and aerial delivery assets.

SCENARIO TIME PROGRESSION
4.4.1

The scenario framework may “accelerate” through the initial attack phase to a point where
deployment of licensee and offsite agency response assets and implementation of the LECR
are assured. Exercise messages, or instructions from a controller, should be used to inform
participants of the actions which were completed during this time-compressed period (e.g.,
description of observed initial assault force, suspected hostile locations, mitigative actions
attempted, etc.). This will allow the IC, in conjunction with key security and operations
decision-makers, to demonstrate the ability to plan for, and direct, the deployment of offsite
response assets.

4.4.2

Notwithstanding the time compression discussed above, the exercise should be run in real time
or as near real time as feasible. More specifically, time jumps should be avoided as these can
be a source of confusion to exercise participants. Applicable Federal, State, and local response
organizations should be made fully aware of any potential adverse impacts that a time jump or
time compression may have on offsite decisions and actions.

MINI-SCENARIOS / MASTER SCENARIO EVENTS LIST DETAIL DESCRIPTIONS
4.5.1

The following information is typically placed in a stand-alone “mini-scenario” or included in
the Master Scenario Events List (MSEL).

4.5.2

To support implementation of DBT adversary task (e.g., coordinated land-based or
waterborne) attack timeline, scenario developers should create a detailed description of
adversary force movements and actions and related events occurring during the initial attack
phase. This timeline may include intrusion detection alarms, camera observations, security
system actuations, and other information that can be provided by a controller to describe the
progress of the attack (e.g., number and location of observed casualties and fires, etc.). The
DBT adversary attack timeline shall not use actual attack progression timing as described in
security program documents; however, the selected event sequence and times should be
credible.

EXERCISE SCENARIO CONFIDENTIALITY
4.6.1

The planning, scheduling, and logistical arrangements necessary to conduct a LECR exercise
will challenge the normal expectations for scenario confidentiality. For example, a TTX will
be conducted prior to an LX. In addition, prior reviews and approvals by various licensee and
LE personnel may be needed to pre-stage and pre-clear LE responders and vehicles normally
associated with contingency response.

4.6.2

Players should not know any details of the scenario (i.e., specific event timeline and related
information). The scenario used for an LX should be sufficiently different from that used in
the immediately preceding TTX and/or LX. Specifically, the elements and consequences of

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Appendix A to DG 5072
Conduct of Law Enforcement
Contingency Response Drills
the hostile action (attack) should be varied between the scenarios, e.g., attack type or direction,
number of attackers, attack timeline, damage and casualties, offsite consequences, etc.
4.6.3

Provided that the above confidentiality of scenario planning is met, the same “players” may
participate in both a tabletop and/or limited exercise, and the subsequent exercise.

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Appendix A to DG 5072
Conduct of Law Enforcement
Contingency Response Drills
FIGURE 4-1
Framework for an Offsite Law Enforcement Agency Contingency Response Limited Exercise
Initial Response Phase

Continued Response Phase

• LE agencies and licensee discuss the attack and
review immediate response needs

• On-site protective measures – “hunker down” –
remain in effect

• Control Room may request immediate support for
limited movement of personnel to support plant
stabilization

• IC advised of immediate Control Room needs and
directs appropriate support (e.g., armed escorts)

• LE and other offsite armed responders continue
staging; await response direction from IC

• IC undertakes discussion and decision-making
necessary to support deployment of offsite
response assets

• Licensee personnel may move in accordance with

directions from IC and Security. Dependent on
plant conditions this movement may require offsite
response escort

• Site liaison personnel report to the TOC
• IC develops situation report

• Responding tactical teams utilize the site-specific

SCP and any additional response tools if developed
and available for use

• Responding tactical teams should consider

simulating some mission planning without the aid
of the response tools

• Additional mutual aid LE agencies should be

dispatched to perform event mitigation actions prior
to exercise termination

• Communications established between IC, Site,
TOC, and Teams, including Team to Team

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Conduct of Law Enforcement
Contingency Response Drills
5

LECR LIMITED EXERCISE IMPLEMENTATION
5.1

This section describes the actions necessary to implement a successful LX; these actions may
be applicable to players or controllers. Included are items the NRC has identified from a
review of industry operating experience and observed good practices. Exercise managers
should carefully consider each item and incorporate applicable recommendations into the
exercise and related implementation processes.
5.1.1

An LX should demonstrate a coordinated response by LE personnel. To effectively
demonstrate this objective, a simulated Central Alarm Station (CAS) and Secondary
Alarm Station (SAS) can be established (i.e., a control cell) for initiating LE response.
Licensee personnel familiar with the operation of these facilities, and capable of
simulating their responses, should be assigned as exercise participants. Likewise, a
knowledgeable individual should be designated to simulate the licensee’s operations
response.

5.1.2

The events of the postulated attack should be presented to the LE response personnel,
sequentially and in real time, by an exercise controller. Such presentation may include
use of messages, scripts, or graphics to relay information such as officer reports,
camera observations, intrusion/door alarms, etc.

5.1.3

If personnel are pre-staged, develop appropriate time delay criteria to be used before
allowing individuals to begin “play.” Delayed individuals should wait in an area away
from any active “play” activities and related communications. Where possible, actual
communication methods should be used to communicate with pre-staged individuals.

5.1.4

The IC should direct measures to control access and protect the TOC.

5.1.5

The site should dispatch to the TOC a liaison from security and operations to interface
with the IC, and representatives from local and regional LE. The conduct of escortbased missions may require added support from operations and/or security.

5.1.6

Actions directed by the IC and/or LE, such as road closures, evacuation of the public
located near the site, and augmentation of resources, should be simulated.

5.1.7

Ensure that drivers of responding vehicles from offsite agencies know site access routes,
entry requirements and destinations. These should reflect procedural guidance or agreed
upon protocols (including Identify Friend or Foe), unless the exercise scenario extentof-play dictates otherwise.

5.1.8

Exercise play should include a mission to simulate movement from the TOC to the
OCA and PA.

5.1.9

In-field/on-scene controllers must be knowledgeable in the functions that they are
controlling (e.g., security actions being controlled by security personnel). Field
controllers should have a means to communicate with the Exercise Manager and other
required locations/individuals.

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5.1.10 Controllers should closely monitor the formulation and delivery of instructions to the
plant staff and offsite armed responders (e.g., plant page announcements, pager text
messages, etc.). These are the messages that provide direction concerning movement
of personnel, and associated cautions and constraints. Messages contained in
procedures may be modified as needed to reflect the exercise extent-of-play.
Controllers should be prepared to direct or deliver messages as necessary to ensure
exercise continuity.
6

LECR TABLETOP EXERCISE IMPLEMENTATION
6.1

Prior to conducting an initial LECR LX, a TTX should be conducted. Representatives from the
licensee and responding LE agency, State, and Federal agencies should be invited to attend the
tabletop. The TTX is beneficial for identifying potential problem areas, defining protocols,
and achieving aligned expectations. Typical TTX participants are the key personnel from
various disciplines (e.g., site security, operations, emergency preparedness, and radiation
protection; LE command, tactical teams, and dispatch) and levels within the organizations
(e.g., executives, mid-level supervision, first-line supervision, and some rank-and-file
members).

6.2

Licensee should utilize Attachment 2, Tabletop Exercise Guidelines, for preparation and
execution of a TTX. The frequency of TTX recurrence should be agreed upon by the LE
agency or agencies relied on for contingency response, including any supporting LE agencies.

6.3

TTX participants should include, at a minimum: (i) LE executives (e.g., Chiefs, Sheriffs, FBI
Field Office Special Agents in Charge) or their designated representatives (e.g., Operations
Commanders, Chief Deputies, FBI Field Office Assistant Special Agents in Charge) for
agencies that would provide tactical teams or incident command staff to a significant, realworld event at the site; (ii) LE tactical team commanders; and (iii) licensee personnel who are
the subject matter experts on security, emergency preparedness, operations, and radiation
protection.

6.4

The licensee should ensure that a TTX is conducted: (i) at the implementation of a LECR , or
when more than 25% of LE executive participants change (e.g., due to retirement, promotion,
etc.), whichever occurs first and (ii) in accordance with drill and exercise requirements
established in Section VI, paragraph C.3.(l)(1) of Appendix B to 10 CFR Part 73.

6.5

The licensee should ensure that a TTX is designed to: (i) validate whether existing policies,
procedures, and interagency/inter-jurisdictional agreements are sufficient for contingency
response; (ii) familiarize responding LE personnel with important concepts (e.g., implications
of site focus changing from individual safety to public health and safety, how LE response fits
into contingency response, and applicability of LE response paradigms, deadly force
considerations, etc.) and current or expected capabilities or actions related to a sabotage
attack; and (iii) identify the appropriate tactical teams, focus areas, and resources necessary for
future information transfers and familiarization and exercise activities under the licensee’s
contingency response plan.
TTX and LX action items are tracked, dispositioned, and captured as lessons learned when
appropriate. Results from the tabletop exercises are used to update and validate the LECR. The
licensee should ensure LE tactical teams have sufficient, accurate information for planning

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Conduct of Law Enforcement
Contingency Response Drills
and executing tactical missions to interdict and neutralize the DBT adversaries in the plant
OCA, PA, and power block. The LE tactical teams identify and test viable primary, secondary,
and tertiary communications systems and protocols for drills and exercises.

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Appendix A to DG 5072
Attachment 1
LECR Limited Exercise Objectives
LECR Limited Exercise Objectives
Objective

Performance Attributes

1. Demonstrate the ability to implement the LECR for Timely implementation of on-site LECR response
responding to a DBT attack.
actions.
2. Demonstrate the ability to make initial
Timely notifications are made to LE agencies as
notifications to LE agencies during a LECR event. specified within the LECR.
3. Within the Tactical Operations Center (TOC),
demonstrate the ability of security personnel to
coordinate response actions among themselves
and with the Incident Commander (IC) and LE
personnel.

Discussion, decision-making and communication
related to:
•
•
•
•
•
•

•
4. Demonstrate the ability of site personnel to
coordinate with the IC for deployment of on-site
personnel and offsite tactical response in an
active- or post-attack environment.

Threat type, location, progression, and changes
to protective strategies
Dissemination of appropriate protective
measure instructions to licensee on-site
personnel
Entry and/or staging areas for LE
Coordination and deployment of LE resources
Plant status, damage assessments, personnel
casualties, and tactical response priorities
Movement of licensee personnel to perform
Credited Operator Actions, Damage Control
Measures, or other critical tasks in the activeor post-attack environment
Identifying Friend or Foe (IFF)

Discussion, decision-making and communication
related to:

• Initial accident assessment and mitigation
• Use of staging areas for tactical response
•

personnel and vehicles
Deployment of tactical response personnel.

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Appendix A to DG 5072
Attachment 1
LECR Limited Exercise Objectives
Objective

Performance Attributes

5. Demonstrate the ability to implement appropriate
radiation protection measures for offsite armed
responders.

Discuss and/or implement appropriate radiation
protection measures.

6. Demonstrate the ability of the site to support
operation of a TOC.

Discussion, decision-making and communication
related to:

• Activation of a TOC
• Accessibility by offsite armed responders
• Dispatch of site personnel to the TOC to serve
•

•
7. Demonstrate the ability to assess the impact of the •
attack on the plant physical security, and to
identify and implement compensatory measures if
needed.

as liaisons to site security personnel
Availability of the contingency response tool or
other site and plant layouts or other aids that the
TOC staff might need to effectively manage the
LE responses
Communications with response teams.
Security management should assess the effects
of the attack on the ability to control access (to
both the site and the protected area), maintain
defensive positions (officer casualties, damage
to protective enclosures, etc.), and operate
security-related equipment.

• Measures should be developed to restore

physical security, including use of local LE
agency personnel and resources. These measures
should be coordinated with the TOC.

8. Demonstrate the ability to mobilize the tactical
response teams in an active- or post-attack
environment.

Discussion, decision-making and communication
related to:

• Status of the plant and potential for core
•
•

•

damage/threat to public
Selection of a method(s) to protect operations
movement/safe passage
Mobilization instructions provided to responders
(e.g., routes, escorts, and exclusion areas;
proceed directly to facilities; do not detour to
inspect damage, etc.)
Crime scene preservation.

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Appendix A to DG 5072
Attachment 1
LECR Limited Exercise Objectives
Recommended Objective

Performance Attributes

9. Demonstrate the ability of the IC to coordinate in- •
plant and on-site response actions with site
security and within the TOC.

•

Effective interface between security supervision
and the IC, including their roles, responsibilities
and authorities as conditions change.
Response personnel adhere to movement and
other restrictions imposed by the IC, safety, and
LE decision-makers, (e.g., stay clear of
perimeter zones, definition of free movement
areas, special identification, two-person line-ofsight rule, use of escorts, etc.).

10. Demonstrate the ability of the TOC to utilize a
•
coordinated offsite response to support the
conduct of Credited Operator Actions in both an •
active- or post-attack environment (Supports
Adversary Interference Precluded Time (AIPT)
analysis)
•

Effective coordination between on-site and
offsite response capabilities.
IC effectively utilizes the TOC to plan and
execute Credited Operator Action based
missions.
Effective coordination between site operations
and both on-site and offsite armed responders in
execution of operations-based missions.

11. Identify and implement improvements based upon •
exercise-based learnings.

Effective utilization of the site-based corrective
action process
Effective use of the interface between the on-site
security force and offsite response agencies for
capture and address of exercise-based
improvement opportunities.

•

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Appendix A to DG 5072
Attachment 2
Tabletop Exercise Guidelines
Tabletop Exercise Guidelines

1. INTRODUCTION

2.

1.1

The LECR Tabletop Exercise (TTX) provides a facilitated learning environment for key
licensee personnel, and offsite LE agencies, to review and discuss their respective roles and
responsibilities. The TTX helps ensure the practicality and effectiveness of the licensee’s
LECR plan. In particular, it permits the various organizations to gain an understanding of each
other’s needs and priorities when responding to a hostile action which would require
activation of the LECR. For example, the TTX can provide LE armed responders with a
perspective on the plant operations, including delay systems and security features for
protecting immediate access to target sets and providing sufficient time for LE response,
immediate radiation hazard concerns, and protection of equipment important to safety.
Likewise, the licensee will gain an appreciation for LE response requirements and the
operational aspects of the Incident Command Structure (ICS). Therefore, it is important that
the structure and conduct of the TTX encourage a free exchange of viewpoints and concerns
among the participants.

1.2

In order to enrich the learning environment, scenarios used in a TTX should be sufficiently
different from previous TTX scenarios. A TTX facilitator(s) will use a scenario to lead
participants through a series of postulated attack and post-attack events in a logical sequence.
The TTX facilitator should pause after each event to elicit discussion from the participating
decision-makers. For example, after presentation of the initial attack event, station security
would explain its responses. The facilitator will then seek input from, in order, site personnel,
offsite LE armed responders, and finally other offsite response personnel.

1.3

Details concerning implementation of a TTX are presented below.

DISCUSSION TOPICS
2.1

The overarching objective of the TTX is for the participants to achieve mutual understanding
of each organization’s roles, responsibilities, priorities, and actions when responding to an
LECR-based event. This understanding should contribute to a successful response during the
LX. The Exercise Manager should consider the following topics for inclusion in the tabletop
agenda.
(1)

Method(s) used by the site to notify offsite first responders of a threat and/or attack.

(2)

Method(s) for subsequent dissemination of this information among offsite response
organizations.

(3)

Initial site safety/security actions in response to the DBT event.

(4)

Initial offsite LE armed responder actions upon notification:
(a)
(b)
(c)

Site access requirements for offsite LE armed responders
Staging and/or reporting location(s) of LE armed responders
Communications and coordination with Incident Commander (IC) and site
security
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Appendix A to DG 5072
Attachment 2
Tabletop Exercise Guidelines

2.2

3

Establishment of the Tactical Operations Center (TOC):

(1)

Who oversees the overall response, and how would transitions in command and
control take place as the scenario evolves?

(2)

Key support personnel reporting to the TOC and their respective functions

(3)

How would offsite armed responders obtain turnover from, and integrate with, the site
response?

(4)

How will IC communicate and coordinate with on-site decision-makers?

2.3

Radiation protection provisions for offsite LE armed responders to the site

2.4

Primary and backup means of communications between and among licensee safety/security
personnel, the operation staff, LE, and any other emergency responders in the field and the
TOC.

2.5

Coordination and decision-making related to:

(1)

Ensuring that the TOC understands operational priorities for operation of functional
equipment or restoration of damaged plant equipment

(2)

Prompt movement of on-shift personnel to support plant stabilization, implementation
of coping strategies, and/or cool down

2.6

Crime scene preservation

2.7

Coordination and addressing national media that may not be familiar with the local emergency
preparedness plans/procedures/processes including FBI establishing temporary no-fly zones as
defined within the site’s SCP.

PREPARATION
3.1

The licensee should involve representatives from LE agencies and other first-responder
organizations in the planning for the TTX. The offsite official who will serve in the capacity
of the IC should have a role in preparation activities, including selecting participants,
establishing discussion topics and objectives, and designing the scenario

3.2

The following TTX planning elements should be jointly determined:

(1)

Date, time, and location

(2)

What individuals from the site and key offsite response organizations will be invited
to participate in the TTX

(3)

Method(s) and responsibilities for inviting identified participants

DG-5072, Appendix A, Page 19

Appendix A to DG 5072
Attachment 2
Tabletop Exercise Guidelines

3.3

4

Develop a simple, straightforward scenario that postulates an attack on the plant and
consequences that require offsite LE response and supporting resources. Review the scenario
with representatives of key offsite response organizations to ensure that it promotes the
desired range of participation. Suggested outcomes from this activity are:

(1)

Given the scenario, determine what the agencies perceive as their role and extent-ofplay

(2)

Determine what the agencies want to learn from the TTX as a guide for the facilitator

(3)

Determine which LE agencies and supporting agencies will have a lead and
supporting role at different stages of the timeline

(4)

Provide the LE and other agencies the opportunity to think about their individual
extents-of-play as the tabletop scenario evolves and how the command structure may
change

(5)

Establish ownership, among key offsite participants, of respective roles in the tabletop

3.4

Determine the room layout for the TTX. Thought should be given to locating the various
organizations in the room to achieve maximum interaction and communication among key
participants. For example, the IC and other key first response organization representatives will
be located together at one table to represent the TOC. The room arrangement should facilitate
communication between this location and initial on-site response personnel (i.e., site security).
Site liaison personnel should be located at the TOC table to facilitate communication and
understanding of plant information.

3.5

Set up the TTX area prior to the participants’ arrival. Each table should have a sign, readable
by all participants, that identifies the represented organization. A name and position placard
should identify individual participants.

3.6

Observers and other non-participants should be in peripheral areas of the room so as not to
interfere with participant interaction. A nearby break-out location may be designated for
security personnel in the event safeguards discussions become necessary.

3.7

Depending on the size of the room and how far participants are situated from one another, a
sound system and microphones may aid discussion.

CONDUCT
4.1

Each participant should be provided with a diagram of the TTX facility layout that identifies
the participating organizations. They should also be provided a list of all participants, their
titles, and the organizations they represent. Designate a non-participant to take notes of the
discussion, and record key points and “parking lot” issues.

DG-5072, Appendix A, Page 20

Appendix A to DG 5072
Attachment 2
Tabletop Exercise Guidelines

5

4.2

The lead facilitator should have the participants introduce themselves - participants should
state their name, organization, and a brief statement of their role. The lead facilitator should
review the rules for discussion of Safeguards Information (SGI).

4.3

The lead facilitator initiates the scenario by stating the initiating conditions and events and
soliciting expected response actions from site personnel. This segment would include the
process of threat identification and initial notifications to licensee on-site personnel and offsite
LE first responders. A short break may follow this segment to allow the notified organizations
to review their response actions (at their respective tables) and prepare to present them to all
TTX participants.

4.4

The facilitator(s) advances the timeline of the scenario segment by segment, soliciting
response actions of each participating organization. As necessary, the facilitator(s) should
prompt discussion concerning:

(1)

Information requirements of each organization and how communications will occur
among facilities and organizations.

(2)

Active- and post-attack coordination necessary to allow movement of on-shift
personnel and deployment of offsite response assets.

CRITIQUE AND FOLLOWUP
5.1

At the conclusion of the TTX, the lead facilitator should request that each table conduct its
own critique and identify a summary of lessons learned and any items requiring further review
and/or corrective action. In particular, participants should be asked to focus on issues that may
have impeded effective LECR implementation. The lead facilitator should then ask the lead
individual from each table to present the critique results to all tabletop participants. The
designated note taker should record critique items and issues on a display visible to everyone.
After presentation of each table’s critique, observations should be solicited from any observer.

DG-5072, Appendix A, Page 21

Appendix A to DG 5072
Attachment 2
Tabletop Exercise Guidelines
Response Validation
Options
Tabletop Exercise

Benefits
•

•

•

•

•

•

Challenges/Limitations

Can validate whether existing policies,
procedures or interagency/inter-jurisdictional
agreements are sufficient for and
complementary to the implementation of the
LECR; if they aren’t, a TTX can facilitate
revisions or the development of new policies,
procedures, or agreements.
Having a TTX would be consistent with the
Homeland Security Exercise and Evaluation
Program (HSEEP) building-block approach.
Discussion-based event that enables participants
to determine whether the LECR works
conceptually, before actual resources are
applied.
Valuable for familiarizing site and responding
LE personnel with concepts and current or
expected capabilities or actions
Helps to identify strengths and shortfalls and
achieve changes in approaches or methods,
when necessary
Participants can discuss issues in detail and
develop decisions through a slow-paced
problem-solving process.

•

•
•
•
•

•

•

•

Outside influences that would be present during an actual event,
or operational-based exercise, may not be addressed (e.g., onsite
environmental conditions and hazards, diversionary events,
human performance issues).
Primarily focuses on strategic, policy-oriented issues.
Provides only a high-level estimate of the current potential for
success of the LECR.
Not all relevant personnel, especially actual operational elements,
will take part in the exercise.
Because participation is limited, and actions are notional,
operational or tactical considerations and lessons learned are not
realized; considerable uncertainty remains regarding the skills,
available resources, and actual capabilities necessary for
executing the plan(s).
Outcomes and lessons learned may be limited to the participants
and participating agencies, which could limit the benefit or utility
of the TTX to other representatives from the broader offsite
incident management system elements (e.g., emergency
preparedness, fire, medical, radiation protection).
May need to clear all participants for access to Safeguards
Information and ensure only cleared individuals and equipment
are allowed in the TTX venue
Success of the event usually based on the skill and effectiveness
of the facilitator

DG-5072, Appendix A, Page 22

Appendix A to DG 5072
Attachment 2
Tabletop Exercise Guidelines
Discussion topics involve multiple functions and
considerations (e.g., communications, staging
areas, coordination, command and control,
public health and safety priorities, paramilitary
tactics, use of force, casualties, etc.).
• Participants are key personnel from various
disciplines (e.g., site security, operations,
emergency preparedness, and radiation
protection; LE command, tactical teams, and
dispatch; and potentially even fire and medical)
and levels within the organizations (e.g.,
executives, mid-level supervision, first-line
supervision, some rank-and-file members).
• Relatively inexpensive and simple to plan and
execute; lasts 4-6 hours; can be conducted at an
offsite location
•

DG-5072, Appendix A, Page 23

Response Validation
Options
Limited Exercise

Benefits

•

•

•

•
•

•

•

•

•

Appendix A to DG 5072
Attachment 2
Tabletop Exercise Guidelines
Challenges/Limitations

Validates plans, policies, agreements, and
procedures validated conceptually during the
TTX
Operations-based event that can help to clarify
roles and responsibilities, identify gaps in
resources needed to implement plans and
procedures, and improve individual and team
performance
Improves tactical teams’ familiarization with
sites’ power blocks, especially locations of
safety-related equipment
Facilitates joint tactical planning and
coordination
Tactical teams will gain some familiarity with
dosimetry since they will need to enter the
Radiological Controlled Area to familiarize
them with safety-related equipment therein.
Induces LE to review site-specific information
(e.g., the Contingency Response Tool) to plan
and execute tactical operations
Enables tactical teams to conduct the three
basic types of missions: defend, recapture and
escort
Exposes tactical teams to several real-world
stressors inside sites’ power blocks in a
permissive environment (e.g., heat, noise,
radiation, interior complexity of site,
communications challenges)
Provides opportunities for site escorts to engage
in dialogue with LE tactical operators while
moving through the plants (e.g., to point out
security features, environmental hazards,

•

•

•
•
•

•

Exercise environment does not simulate several important
conditions that would likely be present within the first 2-4 hours
of an attack
o Lack of adversaries to create the non-permissive
environment in which site and LE personnel would be
expected to operate
o Lack of interaction with broader incident management
system elements (e.g., incident command; non-law
enforcement entities like fire, medical and radiation
protection)
o Lack of a Tactical Operations Center and accompanying
elements, such as command and control and
communications
More effective when tactical teams have access to information
while they are inside the power blocks, which can lead to
artificialities (i.e., having site staff accompany teams when no
plans exist to do that during an actual response) or the need to
issue portable electronic devices
Requires access to OCA, PA, VA and the Radiological
Controlled Area, the latter of which necessitates additional
training and can increase the length of the training day
Can involve significant site resources to provide escorts for LE
at a 5-to-1 ratio (assuming LE enters vital areas for
familiarization)
Involves pre-planning with the Contingency Response Tool
(i.e., Safeguards Information (SGI)) or other site-specific
information, which may require more SGI-accredited computer
equipment than is normally available
Need to clear all participants for access to SGI, ensure the event
includes only cleared individuals and equipment, and that
participants always maintain control of SGI or portable devices

DG-5072, Appendix A, Page 24

Appendix A to DG 5072
Attachment 2
Tabletop Exercise Guidelines
convey tactical lessons learned during site
• Potential for participant injury during physically demanding
contingency response training events, etc.)
tactical training which could result in liability to the owning
• May be able to test the same communications
utility
capabilities that would be employed during a
• Actions/behaviors by LE personnel, with minimal to no nuclear
real-world event (i.e., site radios used when
power plant experience, could inadvertently result in disruption
offsite radios are not permitted or are not
of, or damage to, electrical generation or critical equipment,
effective)
resulting in a plant shutdown.
• Need exercise evaluation guides and a limited number of
exercise controllers (from the site) and evaluators (from LE) to
ensure plant safety and derive the most benefit from this event
• Involves 1-3 hours of participant briefings (e.g., plant status,
Safeguards Information, radiation safety, etc.) that can reduce
the amount of time available for the exercise; if moved to the
day prior to the exercise, participants and support staff would
need to make an additional commitment.

DG-5072, Appendix A, Page 25

Appendix A to DG 5072
Attachment 2
Tabletop Exercise Guidelines
Response Validation
Options
Full-Scale Exercise with
laser engagement
equipment

Benefits
•
•

•
•
•

•
•

•

Challenges/Limitations

Includes elements from the LX Benefits
Involves a larger number of incident management
system elements (e.g., fire, medical, Incident
Command Post, Tactical Operations Center, a site’s
primary or alternate Emergency Operations Facility)
Involves actual mobilization of resources (e.g., mobile
command posts, tactical teams in full gear)
Decisions and actions occur in real time.
Exposes tactical teams to the maximum number of
real-world stressors inside sites’ power blocks (e.g.,
adversary and LE weapons fire, heat, noise, radiation,
interior complexity of site, communications
challenges)
Necessitates sound tactical plans and movements
Laser engagement equipment provides the realistic
tactical stimuli to which LE team members can
respond, instead of responding to verbal information
or a written inject.
Can identify potential incidences of fratricide or
lessons learned on how to avoid them in the future

•
•
•

•

•

•

•

•
•

DG-5072, Appendix A, Page 26

Includes appropriate elements from the LX
Challenges/Limitations
Adds additional layers of complexity to the
exercise
Using controllers as adversaries vice an adversary
team to maximize the training value for LE
participants (i.e., minimize the win-lose mindset
individual adversary players may exhibit)
Having controllers or adversaries who are
flexible enough to know when to engage LE to
accomplish training/learning objectives (e.g., to
slow progress and maintain the exercise timeline,
to penalize poor tactical movement)
Requires exercise controllers (from the site),
evaluators (from LE), and possibly role players,
and specialized training for each group to ensure
plant safety and to maximize the benefit from this
event
Significant exercise documentation (e.g., exercise
evaluation guides, master scenario events list,
communications plan, controller/evaluator, and
player handbooks)
Has a significant logistics component, dealing
with everything from exercise venue locations
and security; to participant transportation,
sustenance, and screening; to communications
networks and protocols
May involve a Simulation Cell
Incorporating laser engagement equipment
training, issue, testing and turn-in into an already
full schedule

Appendix A to DG 5072
Attachment 2
Tabletop Exercise Guidelines

•

•

DG-5072, Appendix A, Page 27

Involves 2-4 hours of participant briefings (e.g.,
laser engagement equipment operation, plant
status, Safeguards Information, radiation safety,
etc.) that can reduce the amount of time available
for the exercise; if moved to the day prior to the
exercise, participants and support staff would
need to make an additional commitment.
Finding enough laser engagement equipment to
outfit LE participants and select controllers

Appendix B to DG 5072
Conduct of Law Enforcement Contingency Response
Force-On-Force Exercises
1.

Performance Evaluation Program

1.1

Section VI, paragraph C.3.(a) of Appendix B to 10 CFR Part 73, requires that licensees shall
develop, implement and maintain a Performance Evaluation Program that is documented in
procedures and describes how the licensee will demonstrate and assess the effectiveness of their
physical protection program implementing the safeguards contingency response (i.e., protective
strategy), including the capability of the LE response relied on to carry out interdiction and
neutralization functions during safeguards contingency events. Acceptable methods for
conducting tactical response force-on-force (FOF) exercises for assuring and demonstrating the
effectiveness of LE responders to interdict and neutralize the DBT adversary are described in this
guidance.

1.2

To satisfy the requirements of Section VI, paragraph C.3 of Appendix B to 10 CFR Part 73, a
licensee that relies upon LE to interdict and neutralize the DBT adversary should conduct tactical
response FOF exercises designed to demonstrate and assess the effectiveness of the licensee’s
physical protection program that includes LE response to contingency events . These drills and
exercises are vital components of a comprehensive training program that enables the LE
responders to gain experience and demonstrate performance of tactics to effectively interdict and
neutralize the DBT adversary and perform LE response tasks and activities within the
contingency response plan.

2.

Tactical Response Force-on-Force Exercises

2.1

The objectives should be: (a) provides opportunities, within a permissive environment, for LE
tactical teams (or elements) to plan contingency response, conduct tactical operations with
differing environments inside the plant’s owner controlled, protected, vital, and radiological
controlled areas; (b) introduces LE tactical teams to several real-world stressors (e.g., hostile
environment, heat, noise, radiation, interior complexity of site, communications challenges); and
(c) identifies and documents LE command and control and communications capabilities and
incorporates those depictions into the LECR.

2.2

Consistent with Section VI, paragraph C.3.(d) of Appendix B to 10 CFR Part 73, licensee FOF
exercises (fully integrated, tactical, and limited scope exercises) must be designed to challenge
the site protective strategy against elements of the DBT and ensure that each participant
demonstrates the requisite knowledge, skills, and abilities. Therefore, licensees relying on LE to
carry out the interdiction and neutralization of the DBT adversary should ensure that exercises
meet these objectives. Participation in tactical response drills and FOF exercises are training
activities that focus on maintaining and improving the knowledge, skills, and capabilities of the
LE individuals or tactical response teams and they are part of the ongoing training to assure
effectiveness of the licensee's SCP and the LECR.

2.3

In accordance with Section VI, paragraph C.3.(f) of Appendix B to 10 CFR Part 73, the scope of
exercises conducted for training purposes shall be determined by the licensee and LE; must
address physical protection system and programmatic elements (e.g., detection and assessment,
communications, delay) capabilities; and may be limited to specific portions of the LECR
implementing the site protective strategy.
Exercise plans and documentation must clearly identify the elements to be evaluated. The
exercises provide a structured process to train personnel and evaluate key elements of the LE

DG-5072, Appendix B, Page 1

Appendix B to DG 5072
Conduct of Law Enforcement Contingency Response
Force-On-Force Exercises
response by focusing on specific aspects of the strategy without conducting a fully integrated
FOF exercise.
2.4

The structure of the exercise must ensure that it provides a credible, realistic, and comprehensive
test of the elements of the LECR objectives that the exercise was designed to achieve. LE tactical
response FOF exercises and associated contingency response training should be conducted under
conditions that simulate, as closely as practicable, the site-specific conditions under which each
member of the security organization will, or may be, required to perform assigned duties and
responsibilities. The exercise and scenarios used should ensure the satisfaction of the key
contingency response elements addressed in this section of the RG. Other licensee physical
protection program elements, such as insider mitigation, cyber security, access authorization, and
inspection, testing, and maintenance of physical security SSCs should also be considered in the
development of exercise plans and scenarios to test, evaluate, and improve these areas. Section 5
of this appendix gives examples of these elements.

2.5

FOF exercises are an integrated response exercise that includes the participation of the LE
personnel executing the tactical operations against an opposing force with the characteristics and
attributes of the DBT. FOF exercises are designed to train and/or evaluate LE responders on the
complete implementation of interdiction and neutralization functions of the licensee’s
contingency response and the evaluation and improvement of that LECR against the
characteristics and attributes of the DBT adversary.

2.6

FOF exercises may be characterized as: (a) a fully integrated FOF exercise, (b) a tactical response
FOF exercise, and (c) a limited scope FOF exercise. The FOF exercises should be used to
exercise both licensee and the LE personnel identified in the LECR to perform interdiction and
neutralization functions. For each FOF exercise, the licensee should document all participants,
including LE armed responders.

2.7

(1)

Fully integrated FOF exercises. These exercises consist of a planned response
effort across various plant disciplines (e.g., local law enforcement agency
(LLEA)), security, plant operations, and emergency preparedness) to minimize or
mitigate the threat.

(2)

Security response FOF exercises. These exercises involve the full security
response force and a mock adversary force without a planned response effort
across various plant disciplines (e.g., LLEA, plant operations, and emergency
preparedness) and focus primarily on security response.

(3)

Limited scope FOF exercises. These exercises focus on the security response by
using the minimum number of members of the response force and the mock
adversary team sufficient to execute the scenario being tested. These should be a
credible, realistic, and thorough test of a portion of the site protective strategy
and evaluate the key security program performance elements bounded by the
DBT. The exercise provides scenario controls and exercise controllers and
includes a post-exercise critique and required exercise documentation.

The licensee should ensure that at least one fully integrated FOF exercise is conducted annually
or more frequently, where the need is indicated, to ensure licensee and LE armed responder
DG-5072, Appendix B, Page 2

Appendix B to DG 5072
Conduct of Law Enforcement Contingency Response
Force-On-Force Exercises
proficiency in implementing the LECR for an actual safeguards contingency event. This would
include LE’s ability to interdict and neutralize the DBT adversary. The following are
consideration of the benefits and challenges/limitations of a fully integrated FOF exercise:

DG-5072, Appendix B, Page 3

Appendix B to DG 5072
Conduct of Law Enforcement Contingency Response
Force-On-Force Exercises
Response Validation
Options
Full-Scale Exercise with
laser engagement
equipment

Benefits
•
•

•
•
•

•
•

•

Challenges/Limitations

Includes elements . from the LX Benefits
Involves a larger number of incident management
system elements (e.g., fire, medical, Incident
Command Post, Tactical Operations Center, a site’s
primary or alternate Emergency Operations Facility)
Involves actual mobilization of resources (e.g., mobile
command posts, tactical teams in full gear)
Decisions and actions occur in real time.
Exposes tactical teams to the maximum number of
real-world stressors inside sites’ power blocks (e.g.,
adversary and LE weapons fire, heat, noise, radiation,
interior complexity of site, communications
challenges)
Necessitates sound tactical plans and movements
Laser engagement equipment provides the realistic
tactical stimuli to which LE team members can
respond, instead of responding to verbal information
or a written inject.
Can identify potential incidences of fratricide or
lessons learned on how to avoid them in the future

•
•
•

•

•

•

•

•

DG-5072, Appendix B, Page 4

Includes elements from the LX
Challenges/Limitations
Adds additional layers of complexity to the
exercise
Using controllers as adversaries vice an
adversary team to maximize the training
value for LE participants (i.e., minimize the
win-lose mindset individual adversary
players may exhibit)
Having controllers or adversaries who are
flexible enough to know when to engage LE
to accomplish training/learning objectives
(e.g., to slow progress and maintain the
exercise timeline, to penalize poor tactical
movement)
Requires exercise controllers (from the site),
evaluators (from LE), and possibly role
players, and specialized training for each
group to ensure plant safety and to maximize
the benefit from this event
Significant exercise documentation (e.g.,
exercise evaluation guides, master scenario
events list, communications plan,
controller/evaluator, and player handbooks)
Has a significant logistics component, from
exercise venue locations and security; to
participant transportation, sustenance, and
screening; to communications networks and
protocols
May involve a Simulation Cell

Appendix B to DG 5072
Conduct of Law Enforcement Contingency Response
Force-On-Force Exercises
• Incorporating laser engagement equipment
training, issue, testing and turn-in into an
already full schedule
• Involves 2-4 hours of participant briefings
(e.g., laser engagement equipment operation,
plant status, Safeguards Information,
radiation safety, etc.) that can reduce the
amount of time available for the exercise; if
moved to the day prior to the exercise,
participants and support staff would need to
make an additional commitment.
• Finding enough laser engagement equipment
to outfit LE participants and select
controllers

DG-5072, Appendix B, Page 5

Appendix B to DG 5072
Conduct of Law Enforcement Contingency Response
Force-On-Force Exercises

2.9

2.10

Defining Participation
2.9.1

As described in Section VI, paragraph C.3.(l)(1) of Appendix B to 10 CFR Part
73, licensee personnel assigned duties and responsibilities required to implement
the SCP and licensee protective strategy must participate in at least one tactical
response drill quarterly and one FOF exercise annually. In addition, as described
in 10 CFR 73.55(s)(2)(ii)(A)(3) a licensee relying on LE to implement the SCP
and fulfill the physical protection interdiction and neutralization functions must
make available periodic training to LE armed responders who will fulfill the
interdiction and neutralization functions for threats up to and including the DBT
of radiological sabotage. Licensees should ensure that tactical response drills and
FOF exercises reflect the LECR and role of responding LE armed response
personnel and make these ongoing training opportunities available to LE
personnel to assure effectiveness of the licensee’s SCP and the LECR.

2.9.2

In accordance with 10 CFR 73.55(d)(3), the licensee may not permit any
individual to implement any part of the physical protection program unless the
individual has been trained, equipped, and qualified to perform required
interdiction and neutralization functions. As described in Section VI, paragraph
C.3.(h) of Appendix B to 10 CFR Part 73, licensees shall document the scenarios
and participants for all tactical response drills and annual FOF exercises.
Licensees are relieved from the qualification requirements of Appendix B,
Section VI, Paragraph D to 10 CFR Part 73, for LE armed responders; however
for LE armed responders that participate in tactical response drills and FOF
exercises, licensees should document those LE participants.

2.9.3

When planning drills and exercises, personnel should be identified to fill each of
the roles and response team duty positions and duty functions required to support
the selected scenario and the type of drill or exercise being conducted.

Key Program Elements
2.10.1 For licensees that rely upon LE to interdict and neutralize the DBT adversary the licensee
should use, but is not limited to, the following elements of the LECR in developing
scenarios for tactical response drills and FOF exercises to demonstrate an effective
response.

(1)

Responding with the number of LE personnel. The LE agency on which
the licensee relies should have the required number of LE response
personnel to effectively implement the contingency response.

(2)

Responding within the plant delay systems and appropriate LE timelines.
LE response personnel have adequate time to perform tasks and activities
DG-5072, Appendix B, Page 6

Appendix B to DG 5072
Conduct of Law Enforcement Contingency Response
Force-On-Force Exercises
to interrupt, interdict and neutralize the DBT adversary in advance of the
adversary timeline to complete defeat of plant delay systems.

(3)

Responding to implement tactical operations to defeat DBT adversary
blocking measures and impeding force to prevent or delay LE personnel
to plant areas. LE personnel use appropriate protection and cover.

(4)

Responding LE personnel can protect the site from an adversary attack in
accordance with the DBT and protect loss of target set components from
sabotage by the DBT adversary force. Identifying potential tactical
considerations along routes (e.g., DBT blocking force, improvised
explosives, environmental hazards).

(5)

Responding LE personnel with appropriate armament. LE personnel are
equipped or have readily available the weapons and equipment necessary
to execute their tactical operations.

(6)

Responding LE command and control structure. LE personnel have
appropriate communication capabilities to ensure that decisions and
actions are coordinated and communicated in a timely manner to facilitate
response. LE communications equipment used to the maximum extent
practical; LE Tactical Operations Center (TOC) established to document
LE radio communications capabilities and facilitate interoperable
communications and route navigation.

2.10.2 To be an effective evaluation tool, each tactical response drill and exercise should include
at least one of the program elements identified above. A FOF exercise should include all
the elements described above. The following additional elements also contribute to the
successful demonstration of the key elements:
(1)
(2)
(3)
(4)
(5)
(6)
(7)
(8)
(9)
(10)
(11)
(12)

coordination and planning.
command and control.
communications.
individual responder tactics.
team response tactics.
use of deadly force.
alarm assessment and intrusion detection.
weapons handling and proficiency.
controller participation.
post-drill briefing and critiques.
integrated response (plant operations, Emergency Preparedness).
deployment of responders and equipment.

2.10.3 Exercise Scenario Development
2.10.3.1

The effectiveness of a drill or exercise as an evaluation tool largely
depends on the scenario development phase. To satisfy the
requirements of Section VI, paragraph C.3.(d) of Appendix B to

DG-5072, Appendix B, Page 7

Appendix B to DG 5072
Conduct of Law Enforcement Contingency Response
Force-On-Force Exercises
10 CFR Part 73, the proposed scenario must be designed to ensure
that it adequately challenges the selected program elements. With a
properly planned scenario, the critique and evaluation can provide
meaningful insights into the effectiveness of the protective strategy
and any enhancements or corrections that may be needed. In
accordance with Section VI, paragraph C.3 of Appendix B to 10
CFR Part 73, the licensee must develop a scenario to support the
conduct of each drill or exercise.
2.10.3.2

The scenarios should be designed to encourage open decisionmaking consistent with the protective strategy. In some cases, the
scope of a drill may be more narrowly focused and not involve an
adversary team. In those cases, only the relevant planning elements
need be included. During scenario planning, attention to the key
program elements is essential to the effectiveness of the drill or
exercise as an evaluation tool. The design of the scenarios must
ensure that they evaluate the effectiveness of the licensee’s
protective strategy. Since drills or exercise scenarios are developed
based upon the licensee’s protective strategy, they are typically
considered Safeguards Information and controlled in accordance
with 10 CFR 73.21.

2.10.3.3

The licensee should implement a process that ensures changes to the
configuration of established equipment and systems related to target
set components are considered in the licensee’s scenarios developed
for drills and FOF exercises. The scenario package(s) should ensure
that the licensee has designed and developed drills and exercises that
consider all modes of operation (i.e., operating at power, refueling,
or other major maintenance activities). In addition, the licensee
should consider the impact that various modes of operation have on
the LE response, specifically, the impact that these modes of
operation have in the following areas:

(1)
(2)
(3)
(4)
(5)

LE responder timelines and positioning;
impact of changes in the configuration of delay barriers;
temporary modifications to the security plan to support activities
that impact the safety/security interface;
effects on fields of fire; or
changes to target sets.

2.10.4 Identification of Target Sets

2.10.4.1

Drill and exercise scenarios should also be developed with the objective of
interdicting and neutralizing the DBT adversary to prevent radiological
sabotage by protecting target sets as a basis for the scenario. Target sets
selected for a drill or exercise should pose the greatest challenge to the LE

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armed response. Target sets that have a small number of components, that are
easily accessible, or whose component locations are in close proximity to
each other should be an optimal choice for a drill or exercise scenario.
Scenarios involving target sets generally can be the basis of improvements to
physical protection systems and contingency response implementing the
licensee’s protective strategies that rely on the LECR.

2.10.4.2

The licensee may take credit for plant delay systems that function to delay
DBT adversary access to the plant areas containing target sets that, if
destroyed or disabled, would lead to radiological sabotage. The licensee
identification of target sets is described in 10 CFR 73.55(f), and guidance is
described in RG 5.81.

2.10.5 Simulations and Artificialities
2.10.5.1

Drill and exercise scenarios should be developed to challenge the
execution of the protective strategy during a variety of environmental
and plant conditions. To replicate these conditions, it may be
necessary to incorporate certain artificialities into the drill or exercise
scenarios. Plant conditions identified in the scenario may range from
operating at power to refueling or other major maintenance activities.

2.10.5.2

Environmental conditions identified in the scenarios should include
time of day or night, and, if possible, the drill or exercise should be
conducted during the time identified to address relative daylight or
darkness and various conditions of security readiness. If no
acceptable artificialities are available for use or it is unsafe to
incorporate the conditions into the drill or exercise scenario, a
tabletop method may be used to simulate that condition, consistent
with the licensee’s site-specific analysis for how that specific
condition affects implementation of NRC requirements.

2.10.5.3

The scenario may also need to include other artificialities to simulate
actions and activities that cannot be performed for reasons of
practicality and the safety of personnel and plant equipment. During
scenario development, activities such as the use of firearms with
blank ammunition and the use of mock explosive devices, and the
presence of drill or exercise participants in certain areas, should be
considered to ensure the continued safe operation of the plant and the
safety of personnel. Drill and exercise scenarios should be developed
to accommodate overall safety through the incorporation of
acceptable artificialities to simulate the occurrence of these actions
and activities (e.g., the inclusion of task times, timeouts, tabletop
exercises). Additional discussion may be found in RG
5.74“Managing the Safety/Security Interface.”

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2.10.5.4

Simulations and artificialities may apply to both licensee and LE
responders and mock adversaries and should be thoroughly
integrated and accounted for during the planning process. To enable
controllers to properly inject simulations and artificialities into the
scenario and oversee the actions resulting from them, the licensee’s
drill and exercise scenario matrix should incorporate specific
guidance for simulations and artificialities. The licensee should
minimize the number of simulations and artificialities in the
development of scenarios to ensure that each scenario provides an
accurate performance standard.

2.10.6 Cautions and Restrictions
Certain areas of the plant, such as the control room and areas where work is ongoing may
be considered off limits to drill or exercise activity. Participants should receive this
information at the drill or exercise briefing along with details of how the activities will be
simulated or affected by these areas being off limits to drill or exercise activity. In
addition, the following should be treated with special awareness during drill and exercise
planning:
(1)
areas with sensitive plant equipment;
(2)
personnel safety;
(3)
radiological controls;
(4)
foreign material exclusion areas; and
(5)
confined space areas.
2.10.7 Communications
The means of communication for the drill or exercise activity should be designated
during the preparation phase. Planning for communication needs should consider plant
operations, the on-duty plant personnel, the LE participants, the controllers, and the mock
adversaries, as well as communicating the conduct of the drill or exercise to onsite and
offsite personnel.
2.10.8 Scheduling and Planning
2.10.8.1

As described in Section VI, paragraph C.3.(l)(2) of Appendix B to 10
CFR Part 73, planners must ensure that the drill or exercise scenario
maintains consistency with the DBT of radiological sabotage. The
mock adversary force used in either FOF or licensee exercises must
replicate, as closely as possible, the adversary attributes,
characteristics, and capabilities of the DBT, and be capable of
exploiting and challenging the licensee’s protective strategy,
personnel, command and control, and implementing contingency
response.

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2.10.8.2

The licensee should consider developing and maintaining a schedule
that supports the drill or exercise plan to ensure the efficiency and
productivity of drills and exercises. In schedule development, the
licensee should consider factors such as projected station outage
schedules, LE responders’ availability, and FOF tactical exercise
requirements.

2.10.8.3

An effective program schedule would provide a detailed listing of
the following:

•
•
•
•
2.10.8.4

type of drills/exercises to be conducted;
when the drills/exercises will be conducted;
key contingency response elements or evaluation standards
to be satisfied by the planned evolution; and
the participants in the evolution.

The licensee should consider use of a structured plan to assist in the
coordination, execution, and documentation of activities associated
with the drill and exercise process. The plan can provide consistency
to the process and help ensure satisfaction of key contingency
response elements or evaluation standards for implementing the
performance assessment program requirements. The plan is also the
foundation of the remainder of the drill or exercise documentation.
The drill or exercise plan should address the following:

1) drill or exercise specifics (number, date, shift/personnel
involved, location).

2) pre-notifications (operations, radiation protection, station

management, etc.).
3) safety briefings.
4) radiological briefings.
5) specific drill objectives or key elements evaluated.
6) participants (players, controllers, adversaries).
7) adversary characteristics (equipment, tactics, actions taken,
target, etc.).
8) scenario being used.
9) sequence of events (event description, anticipated response,
estimated timelines).
10) development of a controller matrix (written scenario for
controllers) to outline scenario events.
11) simulations and artificialities to be considered or integrated into
the evolution safety review.
12) adversary briefings (providing details of the scenario, equipment
used, routes, targets, etc., and allowing for intelligence gathering
from an insider).
13) controller/evaluator briefings (scenario, assignments,
simulations, cautions, concerns, etc.).
14) equipment consideration.
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15) initial plant/security status; and
16) what LECR personnel tasks and activities are being tested.
2.10.8.5

In planning the drill or exercise, it is important that the licensee
maintain the integrity of the process and the confidentiality of the
scenario.

2.10.9 Command and Control of Drills and Exercises
2.10.9.1

Industry experience in the conduct of tactical drills and exercises as well as
emergency preparedness exercises has demonstrated the need for a structured
command and control process. A system of command and control is necessary to
ensure maintenance of an environment free of the recognized hazards associated with
tactical drills and exercises. The command and control system helps to ensure that the
rules of engagement are followed, and hazards and safety concerns are appropriately
addressed. This structure includes the reporting relationship of all controllers to the
lead controller.

2.10.9.2

All tactical drills and exercise activities must be conducted by exercise controllers
and the exercise controllers should be under the guidance and supervision of a lead
controller.

2.10.9.3

An exercise command and control system depends on a cadre of qualified personnel
selected and specifically trained to conduct tactical drills and exercises. In addition to
being trained to oversee exercises, controllers should receive training commensurate
with the scope, complexity, and special nature of the activity. A controller’s primary
responsibility is ensuring safety during drill or exercise engagement. The controller
organization should be structured in a manner that facilitates the control of all
affected locations and the control and coordination of all events to be initiated during
an exercise.

2.10.10

Controller Training and Qualification Process
2.10.10.1

As described in Section VI, paragraph C.3.(l)(4) of Appendix B to 10 CFR
Part 73, drill and exercise controllers must be trained and qualified to ensure
that each controller has the requisite knowledge and experience to control
and evaluate exercises. The following sections provide a basic overview of
an acceptable process to ensure consistent development and implementation
of controller training and qualification. These sections also describe the
training feedback process to ensure continual improvement in both industrywide and site-specific training programs.

2.10.10.2

The goals of the process are the following:
1) establish a common baseline of controller knowledge, skills, and
abilities.
2) identify and respond to station and industry controller performance gaps.

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3) facilitate peer sharing of controller resources for exercise activities; and
4) provide a feedback loop to support continual improvement in controller
performance.
2.10.11

Controller Knowledge and Experience
2.10.11.1

As described in Section VI, paragraph C.3.(l)(4) of Appendix B to 10 CFR
Part 73, each controller shall have the knowledge and experience to control
and evaluate exercises/drills. This includes the ability to:

(1)

Provide timely and accurate information to drill players and participants to
ensure consistent and orderly continuation of the drill or exercise in line with the
scenario.

(2)

Evaluate the application of the no-play area (to include radiation boundaries) and
control measures.

(3)

Evaluate tactical decisions and movements made by the LECR and the mock
adversary force to include, as applicable, alternate avenues of approach, entry
points, targets of opportunity, and control measures and tools required to
facilitate entry.

(4)

Evaluate the application of the use of cover and concealment to include natural
and fabricated defensive positions by all exercise players. This includes
defensive positions and/or re-deployment, if required by the exercise.

(5)

Evaluate the tactical use of exercise weapons comprising their effective range
and capabilities, including fields of fire.

(6)

Evaluate the application of target identification, acquisition, and engagement by
players.

(7)

Evaluate the tactical use of hand-carried explosive devices on equipment and
personnel and their effects upon detonation.

(8)

Evaluate the effectiveness of body armor employed by players and its ballistic
protection during the exercise.

(9)

Evaluate the effectiveness of gas masks, or other supplemental gear, employed
during the conduct of the exercise.

2.10.11.2

All controllers need to be aware of the entire exercise scenario, including the
actions expected of the participant they are monitoring. The controller should
evaluate actions that deviate from the expected scenario to ensure that the
intent of the exercise scenario is being realized. In addition, licensees should
also consider requiring that controllers have knowledge and experience in the
following areas:

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2.10.12

(1)

the use and understanding of the dispersal and effects of chemical agents and
smoke grenades.

(2)

the gas mask used and its limitations.

(3)

the overall procedure for conducting FOF exercises, including the use of Multiple
Integrated Laser Engagement System (MILES) equipment.

(4)

applicable site-specific delay barriers and movement timelines.

(5)

the site’s policy on use of deadly force; and

(6)

exercise and site safety procedures.
Training Design, Development, and Implementation

2.10.12.1

As described in Section VI, paragraphs C.1.(b) and C.3.(l)(4) of Appendix B
to 10 CFR Part 73, all controllers shall complete controller training before
participating as a controller in any drill or FOF exercise. As described in
Section VI, paragraph D.2 of Appendix B to 10 CFR Part 73, controllers
shall be requalified at least annually.

2.10.12.2

Licensees should develop controller training lesson plans and learning
objectives for initial and refresher controller training. The controller training
program should include, but not be limited to, the following:

(1)
(2)
(3)
(4)
(5)
(6)
(7)
(8)
(9)
(10)
(11)
(12)
(13)
(14)
(15)
(16)
(17)
(18)

procedures, guidelines, and references.
introduction/history.
safety and safe drill play.
communication (primary and alternate).
terminology.
command and control.
providing acquired information to players.
controller knowledge.
position and exercise pace.
rules of engagement and the use of force.
use and effects of explosives.
rules of conduct.
MILES equipment and limitations.
site exclusion areas.
temporary breaks in drill execution.
response team duties.
critique process; and
use and control of safeguards information.

2.10.12.3

The training should include site-specific information (e.g., industrial safety
requirements, weapons handling safety requirements, radiological safety,
delay barrier movement timelines, and use of deadly force). It should also
include, but not be limited to, the following example scenarios and practical
demonstrations related to controller activities and calls:
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(1)
(2)
(3)
(4)
(5)
(6)
(7)
(8)
(9)
(10)
(11)

drill timeline coordination (situational awareness and proper cue injects).
cover and concealment assessment.
MILES equipment usage and safety.
red (training) gun equipment usage, application, and safety.
use of assigned equipment.
target set equipment.
licensee protective strategy.
simulations related to gas masks.
simulations related to smoke or other chemical agents.
weapons/explosives capabilities and simulation methods; and
safety control.

2.10.12.4

Controllers should maintain proficiency by routine participation in station
FOF exercises. In addition to the described training, the selection of
controllers for specific assignments should consider previous experience,
skills, and physical abilities. For example, an adversary controller for a FOF
exercise should have previously functioned in that position and have the
physical capabilities to remain with the adversary force. The controller
briefing for FOF exercises should include just-in-time training to remind
controllers of specific situational calls, safety issues, and critical
communications that they could encounter during the scenario.

2.10.12.5

The level of support needed for the conduct of a drill will typically be
significantly less than for an exercise, depending on the complexity of the
drill. The licensee may consider the following positions of responsibility and
personnel when planning for drills and exercises:

2.10.12.5.1

Lead Controller - the exercise leader with an overall knowledge of security
shift operations. This individual may be selected from the security staff or
other organization as appropriate.

2.10.12.5.2

Controllers - designated individuals assigned to specific participants or
areas that have the necessary training to observe, evaluate, and control the
drill or exercise activities of their assigned participant or control area.

2.10.12.5.3

Mock Adversary Force (MAF) - replicates, as closely as possible,
adversary attributes, characteristics, and capabilities of the DBT of
radiological sabotage as described in 10 CFR 73.1(a) and is capable of
exploiting and challenging the licensee’s protective strategy, LE response,
personnel, command and control, and implementing procedures.
Appropriately equipped and trained mock attackers with the required
physical abilities to engage the licensee exercise participants in an armed
attack to test the licensee’s ability to defend against the DBT. Within the
control and safety parameters established for the exercise, the mock
adversary team will perform the normal physical and tactical activities (i.e.,
movement, communication, and carrying of simulated explosives and
equipment) required to accomplish their assigned mission. To execute such
operations and tactics, it is essential that mock adversary team members are
trained in small-unit tactics and scenario planning. In addition, the mock
adversary team should be provided with sufficient time to prepare for the
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mission (this includes scenario planning and rehearsal opportunities).
Typically, the mock adversary force is from the licensee’s security force,
from other nuclear plants, or from local LE tactical response units.
2.10.12.5.4

DBT Insider - a knowledgeable individual who provides inside intelligence
information to the mock adversaries. This individual could be a member of
the plant technical staff, operations staff, or the security force. Before a
drill or exercise, sufficient time should be allotted for the adversary team to
gain intelligence information from the insider.

2.10.12.5.5

On-duty non-drill plant personnel, - plant personnel who are used during an
FOF tactical exercise to ensure that the exercise meets all requirements
identified in the site-specific PSP and procedures.

2.10.12.5.6

Central Alarm Station (CAS)/Secondary Alarm Station (SAS) Participants
– plant personnel stationed in the alarm stations who will perform
CAS/SAS duties as drill participants during the drills and exercises. They
will be briefed on drill conditions as required.

2.10.12.5.7

Security Drill or Exercise Players – LE responders who respond to the
mock contingency event.

2.10.12.5.8

Plant Operations Participant(s) - individual(s) who would normally be
assigned to a command and control function. Plant operations personnel
should participate when significant simulated plant operations are expected
from the scenario. Only plant operator actions listed in a target set should
be used in determining whether an entire target set was compromised. If
credit is taken for plant operator actions, an evaluation must be conducted
to ensure that the actions can appropriately be credited under the postulated
attack scenario and anticipated plant and environmental conditions.

2.10.12.6
2.10.13

Licensees should ensure that sufficient documentation has been retained to
demonstrate that training has been completed for exercise controllers.

Mock Adversary Force Member Training and Qualification Process
2.10.13.1

Tactical response drills, force-on-force exercises, and associated contingency
training must simulate as closely as possible those site-specific conditions
under which each member of the security force will be expected to carry out
assigned duties. Licensees should use the following training performance
standards to help ensure that the mock adversary force (MAF) performance is
credible and sufficiently well-trained. These standards facilitate successful
MAF participation in realistic challenges as a basis for effective evaluation of
a licensee’s contingency response performance capabilities during FOF
exercises. This section provides a basic overview of an acceptable process to
ensure consistent development and implementation of MAF training and
qualification. This section also describes the training feedback process to
ensure continual improvement in both industry wide and site-specific training
programs.

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2.10.13.2

The goals of the process are:
(1)
(2)
(3)
(4)

establish a common baseline for MAF knowledge, skills, and abilities.
identify and respond to site and industry MAF performance gaps and
generic issues.
facilitate peer sharing of MAF resources for exercise activities; and
support continual improvement in controller performance.

2.10.13.3
The following physical qualifications should be maintained by MAF
members:

2.10.14

(1)

Annual medical examination by a licensed physician to certify that
the individual is physically fit and able to perform under high levels
of stress in inclement weather and/or during strenuous physical
exertions without undue foreseeable medical risks.

(2)

Each MAF member should report any known or suspected change in
health or physical capabilities that might impair his or her mental or
sensory capacity and/or agility or otherwise impact their safe and
effective performance.

(3)

The MAF member should possess the mental, sensorial, and motor
skills required to perform all assigned tasks safely and effectively.
Medical qualifications should include (1) mental alertness and
reliable judgment; (2) acuity of senses and ability of expression
sufficient to allow accurate communication by written, spoken,
audible, or other signals; and (3) motor power, range of motion,
neuromuscular coordination, and dexterity.

(4)

After medical certification by a licensed physician, each MAF
candidate should meet the physical fitness standards of being able to
run (1) a mile in a maximum qualifying time of 8.5 minutes and (2) a
40-yard prone-to-run dash with a maximum qualifying time of
8 seconds.

(5)

The MAF should be physically capable of performing or simulating
the characteristics and capabilities of the DBT adversary in an
effective and timely manner.

Mock Adversary Force Member Knowledge, Skills, and Abilities
2.10.14.1

As described in Section VI, paragraph C.3.(l)(2) of Appendix B to 10 CFR
Part 73, the MAF replicates, as closely as possible, adversary characteristics
and capabilities of the DBT and is capable of exploiting and challenging the
licensee’s protective strategy, personnel, command and control, and
implementing procedures.

2.10.14.2

Each MAF member should have the knowledge, skills, and abilities to do the
following:
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(1)

Demonstrate a thorough understanding of DBT weapons, including handheld
automatic weapons, incapacitating agents, explosives, and hand-carried
equipment, and their capabilities. Demonstrate qualifications consistent with the
requirements applicable to an Armed Responder as provided in Section VI of
Appendix B to 10 CFR Part 73. The licensee should ensure that site-specific
requirements needed to ensure individual MAF member performance or
participation in site activities have been completed prior to performance or
participation in any site activity.

(2)

Demonstrate competency in individual and team tactical movement under both
day and night conditions and in various environmental conditions.

(3)

Demonstrate tactical communication skills (e.g., radio discipline, use of hand
signals) that include providing timely and accurate information to the controllers
to ensure consistent and orderly continuation of the drill or exercise in line with
the scenario. This includes demonstration of techniques for authenticating human
assets (e.g., authentication code, color-coded identification).

(4)

Understand the entire exercise scenario up to and including the DBT. This
includes positioning and exercise/drill pace (timelines).

(5)

Understand the application of the no-play area (to include radiation boundaries),
areas described in Section 2.10.6 in Appendix B of this RG, and control
measures.

(6)

Implement adversary tactics, techniques, and tactical decisions to include
alternate avenues of approach, entry points, targets of opportunity, and control
measures and tools required to facilitate entry. This should include door
breaching and dynamic room entries.

(7)

Demonstrate the application of the use of topographical analysis (water,
woodland, industrial) and tactical maneuvers in each of these environments,
taking advantage of cover and concealment opportunities. This may include the
use of smoke.

(8)

Demonstrate the tactical use of drill/exercise equipment and weapons, including
their effective range and capabilities (including specialized equipment and
weapons).

(9)

Understand target identification, acquisition, and engagement by players,
including rules of engagement.

(10)

Demonstrate the tactical use of hand-carried explosive devices and grenades on
equipment and personnel and their effects upon detonation. This should include
the placement of door charges and equipment charges.

(11)

Understand the effectiveness of body armor employed by players and its ballistic
protection during the exercise.

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(12)

Understand the rapid, violent, individual, and small-unit movement, maneuver,
and attack characteristics.

(13)

Understand the techniques to test/defeat detection and assessment sensors and
barriers, including microwave (mono and biostatic), E-field, buried sensors (e.g.,
seismic), infrared (active and passive), and video motion detector.

(14)

Understand the use, effects, and dispersal characteristics of chemical agents and
smoke grenades.

(15)

Understand the features of any gas mask being used and its limitations in a
stressful environment.

(16)

Understand operational planning including the analysis of a site protective
posture and in planning a mission with available resources (e.g., collusion with
an insider).

(17)

Understand the differences between the various types of insiders and how to use
each type of insider effectively to obtain intelligence information and collect
data.

(18)

Understand the use of MILES equipment.

(19)

Understand red gun equipment usage, application, and safety.

(20)

Demonstrate a thorough understanding of DBT firearms knowledge, including
safety, marksmanship, and manipulation skills with all weapons described in the
DBT, or that might reasonably be expected to be deployed. Training should
include a course of fire to enhance proficiency to shoot on the move and while
wearing a gas mask. Firearms training should also include manipulation and
malfunction-clearing techniques, fire discipline, and precision-shooting
techniques.

(21)

Demonstrate firearms proficiency with all types of weapons that might
reasonably be employed during FOF drills or exercises.

(22)

Understand the function, design, and capabilities of applicable plant delay
systems and delay capabilities and defeat task times.

(23)

Understand the use of deadly force.

(24)

Understand exercise and site safety procedures including procedures, guidelines
and references, and the procedures for the use and control of safeguards
information.

2.10.14.3

Mock Adversary Force Member Training Design, Development, and Implementation

2.10.14.3.1

The site adversary training program should build upon the following
learning objectives:

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(1)
(2)
(3)

The adversary force training, knowledge, and skills as described in 10
CFR 73.1(a).
Rules of engagement; and
Adversary characteristics as described in RG 5.69.

2.10.14.3.2

Licensees should develop MAF member training lesson plans and
learning objectives for initial and refresher MAF training.

2.10.14.3.3

MAF training should include site-specific information, industrial safety
requirements, weapons safety requirements, radiological safety, delay
systems and associate delay and use of deadly force. It should also
include example scenarios and/or practical demonstrations related to
MAF activities such as the following:
(1)
(2)
(3)
(4)
(5)
(6)
(7)
(8)
(9)

drill timeline coordination (situational awareness and proper cue
injects).
cover and concealment assessment.
individual and team tactical movement.
physical security systems and barriers.
any specialized equipment.
MILES equipment usage and safety.
red gun equipment usage and safety.
weapons/explosives capabilities and simulation methods; and
safety control.

2.10.14.3.4

All MAF members should complete this basic MAF training before
participating in a FOF exercise. Completion of the training should be
documented. To ensure currency of MAF knowledge and familiarity with
industry and station controller issues, MAF members should complete
documented initial or refresher training within the 12 months preceding
their participation in an annual FOF exercise. Additionally, MAF
members should maintain proficiency by routine participation in station
FOF exercises.

2.10.14.3.5

In addition to the described training, the selection of MAF members for
specific assignments should consider previous experience, skills, and
physical abilities. For example, a MAF member for an FOF exercise
should have previously functioned in that position and should have the
physical capabilities to remain with the MAF. The MAF briefing for
FOF exercises should include just-in-time training to remind MAF
members of specific situational calls, safety issues, and critical
communications that they could encounter during the scenario.

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2.10.15

Conduct of Drills and Exercises

2.10.15.1

Safety during the conduct of drills and exercises is a significant element of the
security-training program. Regardless of the scale of the evolution, preparation,
coordination, and control are key elements to the effectiveness of a drill or exercise.
To ensure exercise safety and provide consistent and effective performance, the
licensee should consider the following criteria when conducting drills or exercises:

(1)

Weapons/Ammunition Safety—Weapons and ammunition safety is paramount. It is
crucial that proper attention is given during exercise planning and performance to ensure
that drill participants do not carry or have available live-fire weapons or ammunition. The
adversaries and the response force team should use training weapons that are easily
identifiable as such. Weapons should be marked so they can be easily identified as
training weapons. Live-fire weapons should not be used during drills or exercises. If a
live-fire weapon is used, it should be rendered safe and incapable of firing.

(2)

Exercise Participant Safety—The following criteria should be part of the safety briefing
for exercise participants:

(3)

(a)

Physical contact should occur only after a participant has been disabled,
surrendered, or neutralized and only with the approval of a controller.

(b)

No attempt should be made to disarm an opponent in any way.

(c)

All ascents and descents from elevated positions will involve a ladder, stairway,
or other safe method.

(d)

There should be no jumping from one elevation to another.

(e)

All exercise controllers and participants will be briefed on the radiological and
industrial safety restrictions and concerns.

(f)

Participants should monitor their own condition for overexertion.

(g)

Anyone who observes an injured or ill participant should immediately call a
timeout, render assistance, and notify a controller/evaluator or call the CAS or
SAS.

(h)

The lead controller should discuss plant and weather conditions before the start
of each exercise and address limitations on running, jogging, or walking.

(i)

All participants should use personal protective equipment unless otherwise
determined by a controller.

Initiation and Termination - The lead controller should initiate the exercise with the
concurrence of the on-duty security supervisor and operations shift manager/supervisor,
if applicable. The initiation of the exercise should be communicated on appropriate radio
frequencies and/or the plant paging system. The lead controller should conduct radio
checks as appropriate to ensure that all controllers are prepared for the initiation or

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Appendix B to DG 5072
Conduct of Law Enforcement Contingency Response
Force-On-Force Exercises
resumption of the drill or exercise. The exercise will be terminated by the lead controller
when one or more of the following occur:
(a)
(b)
(c)
(d)
(e)
2.10.15.2

all adversaries are neutralized or have given up the mission.
a complete target set has been destroyed.
the lead controller determines that an actual condition exists that cannot be
quickly corrected or is of such magnitude as to preclude the continuation of the
drill.
the lead controller determines a condition adverse to personnel or plant safety
exists; or
the lead controller directs that the exercise stops.
Participant Responsibilities - The licensee’s briefing for participants on their duties
and responsibilities associated with the exercise should include, but is not limited to
the following criteria:

(1)

Each participant is personally responsible for his or her safe conduct.

(2)

Each participant should monitor his or her condition.

(3)

Participants who hear an announcement to stop the exercise should immediately stop all
exercise activity and maintain their position until they receive additional instructions.

(4)

Participants will comply with all plant operations, security, and radiation protection
requirements. The pre-exercise safety briefing will address radiation protection entry and
exit procedures.

(5)

All participants should follow controller commands and requests. Participants should
maintain contact with their assigned controller. If during the conduct of the drill or
exercise the participant identifies that there is no longer a controller monitoring the drill
or exercise activity, then they should stop and contact the lead controller. The postexercise critique should address differences in interpretations of scenario evolutions.

(6)

After the conclusion of the drill or exercise and before the critique, all participants should
have an opportunity to document their participation in the drill or exercise so that their
actions may be discussed and reviewed in the critique process.

2.10.15.3

Rules of Conduct - The licensees should consider including the following rules of
conduct as part of the briefing for participants on the conduct of the drill or
exercise:

(1)

Safety is paramount. The safety of participants, controllers/evaluators, plant personnel,
and the plant should never be compromised.

(2)

If identifying clothing or items such as armbands are assigned, participants should wear
them at all times during the drill or exercise.

(3)

Participants will follow all instructions given by a controller.

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Appendix B to DG 5072
Conduct of Law Enforcement Contingency Response
Force-On-Force Exercises
(4)

Any participant may stop the drill or exercise for safety reasons and should ensure that
information is promptly communicated to the lead controller. The lead controller should
determine the resumption of the drill or exercise.

(5)

If the drill or exercise is temporarily halted, all participants should stop at their locations,
cease all firing and movement, and wait for direction.

(6)

Once neutralized, a participant should immediately cease all firing, movement, and
communications. The participant should remain in place until the drill or exercise is
terminated or the controller directs otherwise.

(7)

Alarm station operators and/or participants may not engage in pre-drill or pre-exercise
intelligence gathering. Participants who attempt to circumvent the rules will be removed
from the drill or exercise.

(8)

The controllers/evaluators observing and evaluating the activity should determine all
neutralizations. Training equipment, such as MILES gear, can be used to assist in this
determination.

(9)

At the conclusion of each drill or exercise, participants should ensure that all radiological
boundary controls are intact and that security doors involved in the drill or exercise are
secure.

(10)

The announcement “this is a drill” should be transmitted immediately preceding the first
drill activity once the drill window is opened. This announcement should also be
transmitted periodically throughout the drill and before any drill event after a long period
of inactivity.

(11)

To be successful during an exercise, the MAF should perform or simulate all actions
necessary (including placing simulated explosives at doors, gates, and inside the target
areas). If possible, the MAF should perform or simulate all actions necessary (including
placing explosives) at the specific location where the equipment damage is intended to
occur. If the actual equipment cannot be reached, the MAF may provide specific detail as
to exactly where it intended to perform the action (or place the explosive and the amount
to be placed).

(12)

On-duty security force personnel should not assist or impede the participants in any
fashion unless the circumstance pertains to a safety-related issue or to a real security
situation or response.

(13)

Participants should observe the deadly force rules of engagement as authorized by federal
or state law and as defined by station policy. In addition, Section 8.13 of RG 5.75,
provides further guidance regarding the proper use of force within the force continuum.

(14)

At no time should drill or exercise participant(s) manipulate any plant component. It
should be stressed that extreme caution is to be used near plant equipment. Backpacks,
mock weaponry, and associated drill or exercise equipment should be kept clear of plant
equipment.

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Appendix B to DG 5072
Conduct of Law Enforcement Contingency Response
Force-On-Force Exercises
(15)

Controllers/evaluators ensure that drill or exercise participants do not voluntarily or
accidentally touch plant equipment, controls, or instrumentation. If at any time
inadvertent contact is made with plant equipment, controls, or instrumentation, the
controller/evaluator should immediately notify operations of the incident.

(16)

The MAF and the insider must replicate, as closely as possible, the specific
characteristics or requirements detailed in the DBT.

(17)

Sufficient time should be allotted for the MAF to gain intelligence information from the
insider.

(18)

The MAF’s familiarity with the plant should consist of only what the force has developed
through information obtained from the insider or from other sources of public
information about the facility, such as tours of the facility, or observations from publicly
accessible roadways and areas adjacent the site boundary.

(19)

The MAF should begin the exercise from the point where they would first have the
potential for identification by or interaction with the licensee’s security program
measures.

(20)

The MAF must replicate as closely as possible the adversary characteristics and
capabilities of the DBT in 10 CFR 73.1(a)(1). This means that the MAF will adhere to the
equipment and explosive weight limitations detailed in the DBT.

(21)

When penetrating barriers (i.e., fences, doors, walls, etc.), the mock adversaries’ entire
task time (e.g., set time, time to achieve stand-off distance, time to recover the stand-off
distance, and traverse the barrier) should be factored into the act. Proper care should be
given to personal safety and protection when making entry. If portable blast protection is
used, this equipment may be considered as part of the equipment carried in by the
adversary team.

(22)

Incapacitation criteria detailed in the DBT for weapons such as fragmentation devices,
smoke grenades, and distraction devices will be followed during the exercise.

3.

Critique and Evaluation

3.1

When the licensee relies upon LE to provide the capability to interdict and neutralize the
adversary, the licensee’s reliance on LE response may be considered successful or effective if the
adversary is detected, assessed, interdicted, and neutralized before causing radiological sabotage
by successfully disabling all target set components within a single target set. A licensee may not
take credit for actions or equipment that are outside of the predetermined target set for the
purpose of determining the effectiveness of the LE armed responders to carry out their tactical
operations to interdict and neutralize the DBT adversaries. Pursuant to 10 CFR 73.55(b)(10), the
licensee shall enter identified drill or exercise deficiencies that adversely affect or decrease the
LE response and the physical protection program into the plant’s corrective action program or
training program and correct the identified deficiencies. Licensees should review the
programmatic deficiencies for information that meets the protection requirements of 10 CFR
73.21 and 10 CFR 73.22, “Protection of Safeguards Information: Specific Requirements.”

DG-5072, Appendix B, Page 24

Appendix B to DG 5072
Conduct of Law Enforcement Contingency Response
Force-On-Force Exercises
3.2

Members of the LE response team should be evaluated on all aspects of response, including but
not limited to timeliness, use of cover and concealment, tactical movement and firing techniques,
assessment, and communication. Alarm station personnel should be evaluated for assessment,
communication, coordination, including LE notification/coordination, and other aspects of their
operations under contingency events. The LE response team leader should be evaluated for
performance in demonstrating command and control and making sound and timely decisions for
direction of LE response personnel to interdict and neutralize the DBT threat. Controllers should
be evaluated for accurately assessing the individual and overall licensee and LE response to a
contingency event.

3.3

The critique process is a crucial aspect of the drill and exercise program. This process involves
evaluation of participant performance through specific critique criteria, participant selfassessment, and observations by controllers/evaluators. The critique criteria should support the
evaluation standards and performance criteria identified for the scenario.

4.

Critique and Evaluation Material

4.1

As described in Section VI, paragraph C.3.(g) of Appendix B to 10 CFR Part 73, each tactical
response drill and FOF exercise shall include a documented post-exercise critique in which
participants identify failures, deficiencies, or other findings in performance, plans, equipment,
and strategies. In accordance with Section VI, paragraph C.3.(i) of Appendix B to 10 CFR Part
73, findings, deficiencies, and failures identified during tactical response drills and FOF exercises
that adversely affect or decrease the effectiveness of the protective strategy and physical
protection program shall be entered into the licensee’s corrective action program to ensure that
timely corrections are made to the appropriate program areas.

4.2

The following criteria should be considered when developing critique material for drill or
exercise evaluation purposes:
(1)

Each position and participant should be evaluated.

(2)

The ability of each participant to satisfy the performance criteria associated with his or
her position should be evaluated.

(3)

Criteria not evaluated should be indicated on the critique. Evaluators should consider
using “NE” (not evaluated) instead of “NA” (not applicable).

(4)

The form should indicate whether the individual satisfied the performance criteria.

(5)

Any issues identified because of the individual’s performance should be documented.
Issues should be correlated to their respective evaluation standards.

(6)

Controller/evaluator performance evaluation comments should be solicited.

(7)

The critique material should give participants the opportunity to critique their own
actions and to provide feedback on the drill or exercise.

(8)

The critique should include an overall assessment of the success of the drill or exercise in
meeting the key program elements identified.

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Appendix B to DG 5072
Conduct of Law Enforcement Contingency Response
Force-On-Force Exercises
(9)
4.3

Security equipment performance and security system performance should be evaluated as
it relates to the licensee’s protective strategy.

At the conclusion of a drill or exercise, the lead controller should facilitate the critique. All
controllers/evaluators, adversaries, and participants should normally participate. These critiques
give the participants the opportunity to receive direct feedback from the controllers/evaluators. In
addition, they allow the participants to provide direct input to the critique process.
(1)

(2)

Structured critiques allow the participants to provide direct input to the critique process.
The following format can be an effective means of performing critiques. The structure of
the drill or exercise critique should ensure:
(a)

All participants in the drill or exercise are in attendance.

(b)

The scenario, including goals and objectives, is thoroughly reviewed with the
participants as a group.

Each participant and corresponding controller/evaluator who had an engagement during
the drill or has pertinent feedback will summarize his or her actions and should consider
the following when providing an action summary:
(a)

If a participant took action that resulted in his or her neutralization or the
neutralization of an adversary or adversaries, then the participant and controller
report should provide specific details of the actions taken. The
participant/controller information should include engagement distance, number
of adversaries engaged, number of rounds fired and number of seconds, the
probability of neutralizing the adversary (high, medium, or low), and if the
neutralization(s) resulted from MILES.

(b)

If a participant took action that resulted in friendly fire, then the participant and
controller report should provide specific details of the actions.

(c)

A controller/evaluator whose participant had no interaction with the adversary
force and had no effect on the outcome of the drill or exercise should participate
(provide lessons learned feedback) to the extent of his or her direct observation
of the exercise or drill.

(d)

A controller/evaluator whose participant was actively involved in the outcome of
the drill or exercise and who interdicted the adversaries should concur with the
player’s comments if applicable. If the controller/evaluator does not concur, he or
she should provide details.

(e)

At the conclusion of critiques, the lead controller should review the results of the
drill or exercise and discuss the positive and negative aspects of the activities.

(f)

During the review of the results, participants should be asked for suggestions for
correcting issues and concerns, and these suggestions should be discussed.

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Appendix B to DG 5072
Conduct of Law Enforcement Contingency Response
Force-On-Force Exercises
(g)

As a conclusion to the critique, the lead controller should review the goals,
objectives, and key program elements of the drill or exercise and discuss how
each was or was not met.

(h)

Any participant or controller/evaluator that identifies a deficiency in the
licensee’s protective strategy (e.g., equipment, system, or performance failure),
regardless of whether that participant took action in the drill or exercise, should
provide specific details during the critique.

5.

Drill or Exercise Documentation

5.1

As described in Section VI, paragraphs C.3.(g), (h), and (i), of Appendix B to 10 CFR Part 73, the
results of a tactical response drill or FOF exercise shall be documented and entered the licensee’s
corrective action program. The following information shall be part of the drill or exercise
documentation:
(1)
(2)
(3)
(4)
(5)
(6)
(7)
(8)

5.2

Controllers,
MAF,
scenario description,
key elements and evaluation criteria in the drill,
failures, deficiencies, or other findings in performance, plans, equipment, or strategies,
actions taken on failures, deficiencies, or other findings,
corrective actions (plant corrective action or training program) and the timeframe or
priority given for resolution and identification of the individual responsible for
resolution, and
which participants took part in the exercise(s).

The following information should be part of the drill or exercise documentation, and is in addition
to the information described in Section 5.21.1 of RG 5.75:
(1)
(2)
(3)
(4)
(5)

date and time,
drill/exercise number or another identifier,
plant conditions, security system status, and weather conditions,
program or process strengths identified, and
whether the goals, objectives, and key program elements of the drill or exercise were
met.

5.3

The drill-planning package developed for the evolution should be attached to the report. As
described in Section VI, paragraph C.3.(j) of Appendix B to 10 CFR Part 73, the licensee must
protect deficiencies identified during a drill or exercise consistent with the requirements of 10
CFR 73.21.

5.4

The training program normally addresses issues or deficiencies related to training and human
performance. As described in Section VI, paragraph C.3.(i), all program element deficiencies
shall be entered in the licensee’s corrective action program. After the final critique results are
prepared, the licensee can determine the disposition of each deficiency. Identification of issues
from the drills or exercises is only the first step in the corrective action process. Management
should thoroughly review each deficient item identified and promptly develop and take corrective

DG-5072, Appendix B, Page 27

Appendix B to DG 5072
Conduct of Law Enforcement Contingency Response
Force-On-Force Exercises
action. To ensure resolution of issues, the licensee should regularly review the corrective actions
identified through the drill and exercise process and evaluate their effectiveness.
5.5

It is important that drill and exercise activities are properly documented to ensure appropriate
levels of review and resolution of issues. Not all documents generated in the process of
performing drills or exercises must be maintained as records. As described in Section VI,
paragraph C.3 and H. of Appendix B to 10 CFR Part 73, and 10 CFR 73.55(q), the licensee shall
retain the following documents:
(1)
(2)

(3)
(4)
(5)
5.6

scenarios,
participation records showing which security force personnel participated in
tactical drills and FOF tactical exercises, and when LE armed responders
implementing the LECR participated, records should show which LE armed
response personnel participated in the tactical drills and FOF tactical exercises,
completed critique material, including chronologies,
final drill or exercise report, and
resolution or proposed resolution of critique items.

As described in Section VI, paragraph C.3.(h), of Appendix B to 10 CFR Part 73, the licensee
shall retain an attendance roster for all drill- and exercise-related trainings and briefings.
Documents that are to be retained as records should be legible and completed appropriately. They
must be maintained consistent with NRC regulations, including 10 CFR 73.70, 73.21, and 73.22.

DG-5072, Appendix B, Page 28

Appendix B to DG 5072
Conduct of Law Enforcement Contingency Response
Force-On-Force Exercises
Response
Validation
Options
Full-Scale
Exercise with
laser engagement
equipment

Benefits

•
•

•

•
•

•
•

•

Challenges/Limitations

Includes elements from the LX Benefits
Involves relevant incident management
system elements (e.g., fire, medical,
Incident Command Post, Tactical
Operations Center, a site’s primary or
alternate Emergency Operations Facility)
Involves actual mobilization of resources
(e.g., mobile command posts, tactical teams
in full gear)
Decisions and actions occur in real time.
Exposes tactical teams to the maximum
number of real-world stressors inside sites’
power blocks (e.g., adversary and LE
weapons fire, heat, noise, radiation, interior
complexity of site, communications
challenges)
Necessitates sound tactical plans and
movements
Laser engagement equipment provides the
realistic tactical stimuli to which LE team
members can respond, instead of
responding to verbal information or a
written inject.
Can identify potential incidences of
fratricide or lessons learned on how to
avoid them in the future

•
•
•
•

•
•
•
•
•
•

•

Includes elements from the LX Challenges/Limitations
Adds additional layers of complexity to the tactical response and limited
scope exercise
Using controllers as adversaries vice an adversary team to maximize the
training value for LE participants (i.e., minimize the win-lose mindset
individual adversary players may exhibit)
Having controllers or adversaries who are flexible enough to know when
to engage LE to accomplish training/learning objectives (e.g., to slow
progress and maintain the exercise timeline, to penalize poor tactical
movement)
Requires exercise controllers (from the site), evaluators (from LE) and
possibly role players, and specialized training for each group to ensure
plant safety and to maximize the benefit from this event
Significant exercise documentation (e.g., exercise evaluation guides,
master scenario events list, communications plan, controller/evaluator,
and player handbooks)
Has a significant logistics component, from exercise venue locations and
security; to participant transportation, sustenance, and screening; to
communications networks and protocols
May involve a Simulation Cell
Incorporating laser engagement equipment training, issue, testing and
turn-in into an already full schedule
Involves 2-4 hours of participant briefings (e.g., laser engagement
equipment operation, plant status, Safeguards Information, radiation
safety, etc.) that can reduce the amount of time available for the exercise;
if moved to the day prior to the exercise, participants and support staff
would need to make an additional commitment.
Finding enough laser engagement equipment to outfit LE participants and
select controllers

DG-5072, Appendix B, Page 29

Appendix C to DG 5072
Security Bounding Time and
Adversary Interference Precluded Time
1.0

Applicable Rules and Regulations
10 CFR 73.55(f)(1): The licensee shall document and maintain the process used to develop and
identify target sets, to include the site-specific analyses and methodologies used to determine and
group the target set equipment or elements.
10 CFR 73.55(s)(1)(iv) Analysis. The applicant or licensee electing to meet one or more of the
alternative security requirements in paragraph (s)(2) of this section must perform a technical
analysis demonstrating how it meets the criteria in paragraph (s)(1)(ii) of this section. The
licensee must maintain the analysis until the certifications required by § 50.82(a)(1) of this
chapter or § 52.110(a) of this chapter have been submitted by the licensee.
10 CFR 73.55(s)(2)(ii)(A)(2): The licensee must provide adequate delay for threats up to and
including the DBT of radiological sabotage to enable law enforcement or other offsite armed
responders to fulfill the interdiction and neutralization functions for threats up to and including
the DBT of radiological sabotage.

2.0

Security Bounding Time (SBT) Concept

2.1

Licensees should adhere to the guiding principle that an SBT for SMRs or non-LWRs reflects the
period of time that would be needed, following the initiation of a hostile action at a nuclear power
reactor, for adversary interference to be precluded and for operators to complete actions that
would prevent significant offsite release of radionuclides from any source. For an SMR or nonLWR licensee that relies on LE or other offsite personnel (e.g., licensee proprietary or contracted
force) to interdict and neutralize the DBT adversary, the licensee should calculate a site-specific
SBT as indicated below. Once calculated, a licensee should use the SBT to define
1)
2)
3)

the period that the offsite radiological consequences analysis required by 10 CFR
73.55(s)(1)(iv) should consider,
the time after which target sets may be screened, 4 and
the adversary delay time that its protective strategy should provide if the licensee
elects to meet the alternative physical security requirement in 10 CFR
73.55(s)(2)(ii).

2.2

Licensees should consider that responses to their calls for assistance during an attack could have
one of two immediate objectives: 1) interdict and neutralize all known adversaries, so site staff
can take action to prevent or mitigate offsite radiological consequences without adversary
interference (hereafter referred to as an adversary-focused mission); or 2) protect site staff and
associated equipment from adversary interference in limited plant areas when there isn’t
sufficient time to interdict and neutralize all known adversaries before the site staff takes action to
protect public health and safety and the environment (hereafter referred to as a plant conditionfocused mission). The determining factor between the two mission types is whether there is
sufficient time for the offsite response force to interdict and neutralize all known adversaries prior
to site staff taking action to prevent or mitigate offsite radiological consequences. Some
circumstances may provide time only for the planned offsite response force personnel to secure
safety-related areas of a facility (e.g., the immediate areas surrounding personnel, equipment, and
pathways necessary for a preventative or mitigative action), leaving adversaries in other locations

4

See Regulatory Guide 5.81, Revision 2, for additional information regarding the target set screening process.

DG-5072, Appendix C, Page 1

Appendix C to DG 5072
Security Bounding Time and
Adversary Interference Precluded Time
of the facility for a subsequent, mutual aid force(s) to interdict and neutralize. Licensees should
ensure that offsite response personnel that the licensees rely upon to interdict and neutralize the
DBT adversary are prepared for both mission types. For the purpose of SBT, licensees should
calculate an SBT for each mission type, and when they differ, implement the longer of the two
SBTs.
2.3

Licensees should calculate an SBT by identifying and adding the following six time elements: 1)
Alarm Assessment and Communication, 2) Response, 3) Mission Preparedness, 4) Mission
Execution, 5) Additional Action, and 6) Safety Margin. Once calculated, a licensee should round
its SBT up to the next full hour (e.g., 13¼ hours becomes an SBT of 14 hours). A licensee should
recalculate its SBT when any of the elements used to calculate the SBT increase; when any of the
elements used to calculate the SBT decrease, a licensee may opt to recalculate its SBT or
maintain its original SBT so that it does not have to reassess or revise its target sets, offsite
consequence analysis, and adversary delay time.
(1) Alarm Assessment and
Communication Time

Alarm Assessment and Communication Time includes the
maximum time it takes for the licensee to detect and assess
threats up to and including the DBT of radiological sabotage and
the maximum time it could take for the licensee to notify the
responsible offsite response element(s).

(2) Response Time

Response Time is the period from when the responsible offsite
response element(s) receives the licensee’s call for assistance
until the necessary response resources arrive at the site or
designated staging area.

(3) Mission Preparedness
Time

Mission Preparedness Time represents the time it takes for offsite
armed responders to review avenues of approach, facility floor
plans, and other relevant site information; receive timely and
accurate threat information; and develop and rehearse a mission
plan(s) prior to site entry.

(4) Mission Execution
Time

Mission Execution Time is the period from when offsite armed
responders depart the mission planning and rehearsal location or
arrive onsite and begin their missions (if the responders traveled
directly to the site) until all known adversaries are neutralized
(i.e., for an adversary-focused mission) or site staff completes
preventative or mitigative actions to maintain the site at, or return
the site to, a safe condition (i.e., for a plant condition-focused
mission).

(5) Additional Action
Time 5

Additional action time is the longest task time for the available
preventative or mitigative measures that a licensee could take
after loss of a target set and after all known adversaries are
neutralized (i.e., applicable only to an adversary-focused
mission).

5

Additional Action Time is a term that staff introduced in Enclosure 2 to SECY 20-0070 (not
publicly available), as a necessary component of an acceptable SBT calculation methodology.

DG-5072, Appendix C, Page 2

Appendix C to DG 5072
Security Bounding Time and
Adversary Interference Precluded Time
(6) Safety Margin

Safety margin time is a constant time that attempts to account for
the uncertainties that may exist in the data or assumptions used to
calculate an SBT.

2.4

Although the SBT calculation methodology uses six discreet time elements, staff is aware that a
licensee’s specific circumstances may not perfectly align with this model. For example, a licensee
should be able to identify all six time elements when it calculates an SBT for adversary-focused
missions. For plant condition-focused missions, a licensee will not need to identify an Additional
Action Time, because the Mission Execution Time will already include the time it takes for site
staff to complete preventative or mitigative actions. Another example is a licensee that has trained
and validated offsite armed responders to an extent that enables them to complete mission
preparedness activities while traveling to a site, essentially condensing the timelines for response
and mission preparedness to only the time needed for response. Because the basis and
justification for a site-specific SBT could vary significantly from one site to another, a licensee
should fully document its SBT development process and decisions and have them available for
inspection.

2.5

To the extent practical, a licensee should use data derived from real-world emergency responses
to site calls for assistance. Licensees should consider data from other real-world emergency
responses by the same LE or other offsite response entity to be the next best source of
information. Data such as notification and assembly times may be similar regardless of the
emergency event. When suitable real-world data do not exist, licensees should use data derived
from exercises or other sources. For example, instead of using real-world emergency-related
travel times to the site or designated staging area (e.g., LE Code 3 response times), licensees may
have to obtain travel time data for another location in the vicinity of the site or staging area and
then modify the time to account for the difference in location between the data’s actual
destination and the site or staging area. Licensees may also identify travel times using a route
planning tool with real time traffic condition capability; licensees adopting this method for
identifying the travel time component of response time should identify routes for the range of
traffic conditions that typically exist between the response force starting location and the site or
staging area, and then select the route(s) with the longest time(s). Another source from which
licensees may be able to identify suitable Mission Preparedness and Mission Execution Times is
from the drills or exercises that are required by Appendix B to 10 CFR Part 73, Section VI,
paragraph C.3.(l)(1).

3.0

Guidance for Determining the Six SBT Elements

3.1

Alarm Assessment and Communication Time
3.1.1

Alarm Assessment and Communication Time has two components: 1) the maximum time
it takes the licensee to detect and assess threats up to and including the DBT, and 2) the
maximum time it could take for the licensee to notify the responsible offsite response
personnel. To the extent practical, when determining the maximum detection and
assessment time component, licensees should review a site’s actual sensor performance
and alarm acknowledgment and assessment data and use the maximum time
demonstrated by that data. Actual sensor performance and alarm acknowledgment and
assessment data are the preferred sources for the detection and assessment times because
the data will likely account for detection or assessment delays, such as those associated
with adverse environmental conditions, potential signal travel over substantial distances,

DG-5072, Appendix C, Page 3

Appendix C to DG 5072
Security Bounding Time and
Adversary Interference Precluded Time
real-world distractions for an alarm monitor, or multiple, simultaneous alarms (e.g., alarm
stacking).

3.2

3.3

3.1.2

When real-world alarm sensor performance and acknowledgment and assessment data are
not available (e.g., newly installed intrusion detection system with few or no actual
sensor activations to date), licensees should use the maximum detection and alarm
acknowledgment and assessment times that were established during performance-based
testing of the intrusion detection system(s).

3.1.3

Licensees should use 15 minutes as the notification component of the Alarm Assessment
and Communication Time, since that is the maximum period that a licensee has after
declaring an emergency, pursuant to Appendix E to 10 CFR Part 50, paragraph IV.D.3, to
notify responsible state and local governmental agencies.

3.1.4.

Under this construct, the Alarm Assessment and Communication Time becomes the sum
of 15 minutes and the maximum detection and assessment time.

Response Time
3.2.1

Response Time represents the period from when LE or other responsible offsite armed
response personnel receive a licensee’s call for assistance until the necessary response
resources or assets arrive at the site or designated staging area. Activities such as paging a
tactical team, tactical team mustering, and travelling to the site or a staging area are all
components of Response Time. A licensee should consider a response force’s available
modes of travel (e.g., land, air, water) and utilize the travel time for the slowest mode to
inform the Response Time used for its SBT calculation. If a licensee relies on more than
one response force for interdiction and neutralization of the DBT adversary, then the
licensee should use the longest overall response timeline to inform the Response Time
used for its SBT calculation.

3.2.2

A licensee should calculate Response Time using one of two methods. The preferred
method is for a licensee to collect information from single incidents, each of which
involves a response by the necessary offsite resources or assets to the site or designated
staging area. Using this method is more reliable, because all of the response variables
(e.g., weather, traffic, communications challenges, rationale for decisions) are consistent
across each of the Response Time components, and the starting and ending points used to
calculate Response Times will represent complete and actual response time performance
on a given day. A less-preferable method would be for a licensee to identify the times for
Response Time components (e.g., maximum call-out, assembly, and travel times) from
different incidents or events, and then combine those component times to create an
estimated Response Time. This alternate method will likely produce uncertainties in the
final Response Time estimate, because conditions that increase the time for one
component on one day may not exist or adversely affect other component times on
different days. A licensee should confirm the accuracy of its Response Time estimate
with a subject matter expert who is a member of the offsite response force before
including the estimate in its SBT calculation.

Mission Preparedness Time

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Appendix C to DG 5072
Security Bounding Time and
Adversary Interference Precluded Time
3.3.1

Mission Preparedness Time represents the time that offsite armed responders need to
review avenues of approach, facility floor plans, and other relevant site information;
receive timely and accurate threat information and a mission objective(s) from a site; and
then plan and rehearse a mission(s) prior to site entry. Licensees should identify a
credible Mission Preparedness Time using data from real-world incidents at a site or the
drills or exercises that are required by Appendix B to 10 CFR Part 73, Section VI,
paragraph C.3.(l)(1). Prior to a site being built and beginning operation, exercise data will
likely not be available; under such circumstances, licensees should base Mission
Preparedness Time estimates from discussions or tabletop exercises with LE or other
offsite armed response personnel, or on planning time data obtained from LE or other
offsite armed response personnel for similar emergencies at comparable facilities (i.e.,
complex industrial environments).

3.3.2

It is unlikely that LE or other offsite armed response personnel will initially be familiar or
have experience with an DBT adversary with the attributes, characteristics, and
capabilities described in 10 CFR 73.1(a). Licensees should ensure that LE or other offsite
armed response personnel fully know and understand the DBT of radiological sabotage
and are able to prepare to successfully interdict and neutralize threats up to and including
it. When identifying Mission Preparedness Time based on discussions, tabletop exercises,
or planning time data from similar emergencies at comparable facilities, licensees and LE
or other offsite armed response personnel should determine whether additional time
should be added to account for the DBT adversary’s capability to potentially delay or
disrupt response operations to a greater degree than typically experienced by the LE or
other offsite armed responders.

3.3.3

To the extent practical, licensees should replicate real-world conditions during the drills
and exercises that are required by Appendix B to 10 CFR Part 73, Section VI, paragraph
C.3.(l)(1). For example, licensees should use only the personnel, locations, and
equipment that would actually be involved with the emergency response. Licensees may
use role players during drills or exercises in lieu of on-shift personnel; role players should
possess the same knowledge, skills, and abilities as their on-shift counterparts. To the
extent practical, licensees should ensure that role players and other drill and exercise
participants use real-world equipment and locations when such use does not present an
unacceptable risk to personnel or plant safety. For example, if a licensee uses a role
player to simulate a control room operator, the role player should be stationed inside the
actual control room and use the control room’s communications and other equipment if
the licensee can continue to safety operate the plant during the exercise. When it is not
practical to use real-world equipment or locations, licensees should ensure that
artificialities replicate real-world conditions to the maximum extent possible (e.g., control
room simulators), so that they do not result in inaccurate assumptions, outcomes, or
training, including negative training for drill and exercise participants.

3.3.4

There is an inverse relationship between a licensee’s level of effort to inform and train
LE or other offsite armed response personnel and the amount of time those responders
will need for planning purposes. That relationship should incentivize licensees to offer
sufficient and quality information and frequent and quality training to LE or other offsite
armed response personnel to enable them to plan missions in the least amount of time
possible. Licensees may discover that if the information and training they provide is
effective, LE or other armed response personnel may become familiar enough with a site,
the DBT adversary, and mission objectives that rehearsal and planning time is not
DG-5072, Appendix C, Page 5

Appendix C to DG 5072
Security Bounding Time and
Adversary Interference Precluded Time
needed, and offsite armed responders can go directly to a site and begin their mission(s).
The benefit of establishing this level of proficiency is that Mission Preparedness Time
becomes zero (or near zero), which results in a shorter SBT.
3.3.5

Licensees that want opportunities to periodically establish shorter Mission Preparedness
Times and use those times to recalculate their SBTs should use mission preparedness data
from the most recent 3-year period. Using data from the past 3 years should 1) result in
SBTs that more accurately reflect licensees’ and LE or other offsite armed responders’
current performance capabilities, and 2) provide the flexibility for licensees to credit
shorter Mission Preparedness Times (and by extension shorter SBTs) as their and law
enforcement or other offsite armed responders’ knowledge, training, and performance
improves. Licensees should document mission planning times from all real-world
incidents and drills and exercises. Licensees should also ensure that the data used to
calculate SBTs represent LE or other offsite armed responders’ mission preparedness
times for a wide range of DBT scenarios; licensees should not rely on mission
preparedness data that, collectively, exclude threats from either end of that spectrum.

3.3.6

A licensee with fewer than 3 years of data should use the longest documented Mission
Preparedness Time in its SBT calculations. After a licensee has documented mission
preparedness times for at least 3 years from real-world incidents, drills, or exercises, and
for a variety of DBT scenarios, the licensee may use a Mission Preparedness Time that
represents the 75th percentile in its SBT calculation. To calculate the 75th percentile, a
licensee should use one of these two methods:
Method 1
3.3.6.1 Calculate the 75th percentile electronically using a spreadsheet application:
3.3.6.1.1 Place individual data points (i.e., the mission preparedness times from
real-world incidents and drills and exercises over the last 3 years) into
separate, contiguous cells in a spreadsheet.
3.3.6.1.2 Use the percentile function to calculate the 75th percentile.
3.3.6.1.3 For example, consider a data set with the following 10 mission
preparedness times: 147, 118, 82, 90, 102, 111, 89, 126, 141, and 74
minutes.
3.3.6.1.4 A licensee would enter each of the 10 mission preparedness times into
separate cells within a contiguous range in a spreadsheet. For this
example, assume the licensee entered the times into cells B9 through
B18, inclusive.
3.3.6.1.5 In a blank cell on the same spreadsheet as the data range, a licensee
would use the PERCENTILE (array, k) formula, where “array”
represents the range of data cells and “k” represents the percentile in
decimal form. In this example, a licensee would enter the following
formula into a blank cell to identify the 75th percentile for the sample
data set: =PERCENTILE(B9:B18, 0.75).

DG-5072, Appendix C, Page 6

Appendix C to DG 5072
Security Bounding Time and
Adversary Interference Precluded Time
3.3.6.1.6 The spreadsheet application should produce the result of 124. Because
124 minutes represents the 75th percentile, a licensee would use 124
minutes as the Mission Preparedness Time for its SBT calculation.
Method 2
3.3.6.2 Calculate the 75th percentile manually by performing the following steps:
3.3.6.2.1 Order individual data points (i.e., the mission preparedness times
from real-world incidents and drills and exercises overt the last 3
years) from the shortest to longest times.
3.3.6.2.2 Multiply the total number of data points, N, by 75 percent (i.e., 0.75).
If a licensee has 12 data points, N would equal 12.
3.3.6.2.3 The resulting number is called the index. For example, 12 x 0.75
equals 9, so the index would be 9.
3.3.6.2.4 If the index is a whole number, count the values in the data set from
left to right (i.e., from the shortest to the longest time) until the index
number of data points is reached.
3.3.6.2.4.1 The 75th percentile is the average of that corresponding
value in the data set and the value that directly follows it.
3.3.6.2.5 For example, consider a data set with the following 12 mission
preparedness times: 60, 60, 72, 85, 93, 106, 110, 113, 120, 124, 130,
and 145 minutes.
3.3.6.2.6 Using a whole number index of 9, the 75th percentile would be
represented by the average of 120 minutes (i.e., the ninth position in
the data set) and 124 minutes (i.e., the tenth position in the data set).
3.3.6.2.6.1 Therefore the 75th percentile would be (120 + 124) / 2 =
244/2 = 122 minutes.
3.3.6.2.6.2 A licensee would use 122 minutes as the Mission
Preparedness Time for its SBT calculation.
3.3.6.2.7 If the index is not a whole number, round it up to the nearest whole
number.
3.3.6.2.8 Then, count the values in the data set from left to right (i.e., from the
shortest to the longest time) until the index number of data points is
reached.
3.3.6.2.9 The corresponding time represented by the index data point is the 75th
percentile.

DG-5072, Appendix C, Page 7

Appendix C to DG 5072
Security Bounding Time and
Adversary Interference Precluded Time
3.3.6.2.10 For example, consider a data set with the following 13 mission
preparedness times: 60, 60, 72, 85, 93, 106, 110, 113, 120, 124, 130,
135, and 145 minutes.
3.3.6.2.11 The index number for this data set would be 13 times 0.75, which
equals 9.75. Since 9.75 is not a whole number, round the index up to a
whole number, which in this example would be from 9.75 to 10.
3.3.6.2.12 The time in the tenth position in the sample data set is 124 minutes.
3.3.6.2.13 Because 124 minutes represents the 75th percentile in this data set, a
licensee would use 124 minutes as the Mission Preparedness Time for
its SBT calculation.
3.4

Mission Execution Time
3.4.1

Mission Execution Time represents the period from when offsite armed responders depart
the mission planning and rehearsal location (e.g., staging area) or arrive onsite and begin
their missions (if the responders traveled directly to the site) and continues until all
known adversaries are neutralized (i.e., for an adversary-focused-mission) or site staff
completes preventative or mitigative actions to maintain the site at, or return the site to, a
safe condition (i.e., for a plant condition-focused mission). Licensees should identify a
credible Mission Execution Time using data from real-world incidents at a site or the
annual drills or exercises that are required by Appendix B to 10 CFR Part 73, Section VI,
paragraph C.3.(l)(1).

3.4.2

Prior to a site being built and beginning operation, exercise data will likely not be
available; under such circumstances, licensees should base Mission Execution Time
estimates on discussions or tabletop exercises with LE or other offsite armed response
personnel, or on execution time data obtained from LE or other offsite armed response
personnel for similar emergencies at comparable facilities (i.e., complex industrial
environments).

3.4.3

Licensees that use information or results from security modeling or vulnerability
assessment software applications to inform their Mission Execution Time estimates
should employ only software applications that are accredited by a U.S. government
agency for the function(s) being analyzed (e.g., pathway analysis, combat simulation,
system effectiveness). Additionally, licensees should ensure that any data used in such
software applications accurately represent the actual capabilities, performance, training,
and other related characteristics of the LE or other offsite armed responders (i.e., not a
default or unrelated defensive force), as well as the full capabilities of the DBT adversary
(i.e., not exercise-related limitations associated with the site or the NRC’s mock
adversary force).

3.4.4

Licensees should ensure that LE or other offsite armed response personnel fully know
and understand the DBT of radiological sabotage and possess the knowledge, skills,
abilities, and equipment to successfully interdict and neutralize threats up to and
including it. When identifying Mission Execution Time based on discussions, tabletop
exercises, or execution time data from similar emergencies at comparable facilities,
licensees and LE or other offsite armed response personnel should determine whether
DG-5072, Appendix C, Page 8

Appendix C to DG 5072
Security Bounding Time and
Adversary Interference Precluded Time
additional time should be added to account for the DBT adversary’s capability to
potentially delay or disrupt response operations to a greater degree than typically
experienced by the LE or other offsite armed responders.
3.4.5

For plant condition-focused missions, Mission Execution Time should include the
credible task time for preventative or mitigative actions than a licensee may need to take.
To identify a credible preventative or mitigative action task time, licensees should refer to
performance testing or training times for an action, or site procedures such as abnormal
or emergency operating conditions, diverse and flexible coping strategies, severe accident
management guidelines, extensive damage mitigation guidelines, or other relevant
documentation. Licensees should be mindful that preventative or mitigative actions for
plant condition-focused missions would be occurring within an actively hostile
environment (i.e., known adversaries would not be neutralized before commencing
preventative or mitigative actions); therefore, licensees should determine how much
additional time needs to be added to the normal task times to account for delays that may
be caused by an adversary, security force engagement of an adversary, or implementing
localized security measures immediately prior to, or simultaneous with, the preventative
or mitigative actions. For example, licensee personnel would likely not be able to reach
or move equipment stored outside a main protected area until armed response personnel
are in position to facilitate movement of personnel or equipment. In addition to the
normal task time related to the deployment of that equipment, a licensee would have to
consider how armed response personnel would facilitate that action and include the
additional time in its Mission Execution Time estimate. The need to add additional time
may be caused by numerous factors, including: 1) offsite armed responders navigating to
onsite personnel, escorting them to equipment stored in an owner controlled area, and
then reentering the site together with the equipment; 2) offsite armed personnel
rendezvousing with recalled offsite licensee personnel and entering the site together with
the equipment; 3) offsite armed responders navigating to high ground like the rooftops of
protected area buildings so armed responders can use their weapons to cover hose or
cable runs in outdoor areas without positioning themselves in the target area; or 4) armed
response personnel sweeping, clearing, and holding interior passageways and locations
for planned preventative or mitigative actions.

3.4.6

There is an inverse relationship between a licensee’s level of effort to inform and train
LE or other offsite armed response personnel and the amount of time those responders
will need for planning purposes. That relationship should incentivize licensees to offer
sufficient and quality information and frequent and quality training to LE or other offsite
armed response personnel to enable them to plan missions in the least amount of time
possible. Licensees may discover that if the information and training they provide is
effective, LE or other response personnel may become familiar enough with a site, the
DBT adversary, and mission objectives that Mission Execution Time may be reduced
from hours to minutes. The benefit of establishing this level of proficiency is Mission
Execution Time is minimized, which results in a shorter SBT.

3.4.7

Licensees that want opportunities to periodically establish shorter Mission Execution
Times and use those times to recalculate their SBTs should use mission execution data
from the most recent 3-year period. Using data from the past 3 years should 1) result in
SBTs that more accurately reflect licensees’ and LE or other offsite armed responders’
current performance capabilities, and 2) provide the flexibility for licensees to credit
shorter Mission Execution Times (and by extension shorter SBTs) as their and LE or
DG-5072, Appendix C, Page 9

Appendix C to DG 5072
Security Bounding Time and
Adversary Interference Precluded Time
other offsite armed responders’ knowledge, training, and performance improves.
Licensees should document mission execution times from all real-world incidents and
drills and exercises. Licensees should also ensure that the data used to calculate SBTs
represent LE or other offsite armed responders’ mission execution times for a wide range
of DBT scenarios; licensees should not rely on mission execution data that, collectively,
exclude threats from either end of that spectrum.
3.4.8

3.5

A licensee with fewer than 3 years of data should use the longest documented Mission
Execution Time in its SBT calculations. After a licensee has documented mission
execution times for at least 3 years from real-world incidents, drills, or exercises, and for
a variety of DBT scenarios, the licensee may use a Mission Execution Time that
represents the 75th percentile in its SBT calculation. To calculate the 75th percentile, a
licensee should use one of the two methods described in Section 3.3.6.

Additional Action Time
3.5.1

Additional action time is the longest task time for the available preventative or mitigative
measures that a licensee could take after loss of a target set and after all known
adversaries are neutralized. Licensees should identify an Additional Action Time only for
adversary-focused missions, because the maximum credible task time for preventative or
mitigative actions will be included in the Mission Execution Time for plant conditionfocused missions. To identify a maximum credible preventative or mitigative action task
time, licensees should refer to performance testing or training times for an action, or site
procedures such as abnormal or emergency operating conditions, diverse and flexible
coping strategies, severe accident management guidelines, extensive damage mitigation
guidelines, or other relevant documentation.

3.5.2

Because licensees will likely conduct preventative or mitigative action-related drills or
exercises less frequently than security drills and exercises, licensees that want
opportunities to periodically establish shorter Additional Action Times and use those
times to recalculate their SBTs should use performance data from the most recent 5-year
period. Using data from the past 5 years should 1) result in SBTs that more accurately
reflect licensees’ and LE or other offsite armed responders’ current performance
capabilities, 2) provide sufficient data for calculating an acceptable Additional Action
Time estimate (see paragraph 3.5.3), and 3) provide the flexibility for licensees to credit
shorter Additional Action Times (and by extension shorter SBTs) as their and LE or other
offsite armed responders’ knowledge, training, and performance improves. Licensees
should document additional action times from all real-world incidents and drills and
exercises. Licensees should also ensure that the data used to calculate SBTs represent
their and LE or other offsite armed responders’ additional action times for the range of
possible preventative or mitigative actions; licensees should not rely on additional action
data that, collectively, exclude preventative or mitigative actions from either end of the
complexity or time spectrums.

3.5.3

A licensee with fewer than 5 years of data should use the longest documented Additional
Action Time in its SBT calculations. After a licensee has documented additional action
times for at least 5 years from real-world incidents, drills, or exercises, and for a variety
of possible preventative or mitigative actions, the licensee may use an Additional Action
Time that represents the 75th percentile in its SBT calculation. To calculate the 75th
percentile, a licensee should use one of the two methods described in Section 3.3.6.
DG-5072, Appendix C, Page 10

Appendix C to DG 5072
Security Bounding Time and
Adversary Interference Precluded Time
3.6

4.0

Safety Margin Time
3.6.1

Safety margin time attempts to account for the uncertainties that may exist in the data
used to calculate an SBT, or different conditions at the time of an attack than those
considered or assumed by a licensee’s SBT calculation methodology. Examples of
uncertainties include potential inclement weather; chemical, industrial (e.g., steam,
flooding/drowning, confined space), environmental (e.g., heat), or radiological hazards;
traffic conditions; communications challenges; competing demands for offsite responder
resources; unanticipated decisions or actions by offsite armed responders (e.g.,
implementing isolate-and-contain protocols rather than those for active shooters);
estimating times using response data or assumptions involving threats with lesser
capabilities than the DBT of radiological sabotage; damage or destruction of more than
the equipment in a single target set by an adversary; inadvertent destruction of target set
or other plant equipment by less than fully trained or knowledgeable armed response
personnel; an adversary’s use of unexpected or more effective tactics; inoperable
mitigation equipment; obstructed pathways on or near the site; and uncertainties
associated with the use of exercise data, where times may be more favorable because the
activities were planned and announced.

3.6.2

Prior to a licensee operating a site for at least 10 years, the licensee should use a safety
margin of 50% of the total of SBT time elements 2 through 5 (i.e., Response Time,
Mission Preparedness Time, Mission Execution Time, and Additional Action Time) for
its SBT calculation. After a licensee has been operating a site for at least 10 years, the
licensee may use a safety margin of 25% of the total of those same four SBT element
times for its SBT calculation.

SBT Examples

Example 1
4.1

Licensee facility in an urban area

Years in operation:
Bounding mission:

0 (facility under construction)
Adversary-focused

SBT Calculation:
Alarm Assessment and Communication Time
1 minute to receive and assess alarm
15 minutes to notify offsite armed responders

16 minutes

Response Time
city police tactical team(s) establishes a near-site staging area

1½ hours

Mission Preparedness Time
lack of familiarity with facility, adversary, and potential missions

4 hours

Mission Execution Time
travel to the site, negotiate delay features, neutralize adversary

2½ hours

DG-5072, Appendix C, Page 11

Appendix C to DG 5072
Security Bounding Time and
Adversary Interference Precluded Time
Additional Action Time
complete a diverse and flexible coping strategy procedure

3 hours

Subtotal: 11 hours, 16 minutes
+ 5 hours, 30 minutes
16 hours, 46 minutes

Safety Margin Time (50% of SBT elements 2 through 5)
1½ + 4 + 2½ + 3 = 11 x .50 = 5½ hours

SBT = 17 hours (when rounded
up to the nearest hour)
Example 2
4.2 . Licensee facility in a rural location
Years in operation:
Bounding mission:

10 years
Plant condition-focused

SBT Calculation:
Alarm Assessment and Communication Time
5 minutes to receive and assess alarm
15 minutes to notify offsite armed responders

20 minutes

Response Time
regional tactical team responds directly to the site
small elements enter site upon arrival, rather than
wait outside to assemble a full team

4 hours

Mission Preparedness Time
responders very familiar with the facility and design
basis threat, so they complete preparations
while responding

0 minutes

Mission Execution Time
able to quickly negotiate delay features, neutralize adversary in
safety-related plant areas, and protect site personnel during
preventative actions

3 hours

Additional Action Time
included in Mission Execution Time

0 minutes
Subtotal: 7 hours, 20 minutes
+ 1 hour, 45 minutes
9 hours, 5 minutes

Safety Margin Time (25% of SBT elements 2 thru 5)
4 + 0 + 3 + 0 = 7 x .25 = 1¾ hours

SBT = 10 hours (when rounded up to
the nearest hour)
5.0 Adversary Interference Precluded Time (AIPT) Concept
DG-5072, Appendix C, Page 12

Appendix C to DG 5072
Security Bounding Time and
Adversary Interference Precluded Time
5.1

After the initiation of a physical attack, AIPT represents the point at which an SMR or non-LWR
licensee can assume that the adversary would no longer interfere with a reactor operator’s
movement or actions. An SMR or non-LWR licensee can use AIPT during the target set
development process to determine when the adversary interference criterion for a credible
operator action is satisfied. 6 The AIPT calculation methodology described below is consistent
with the alternative method described in Section 5.5.3 of RG 5.81, and it is analogous to how
large LWR licensees apply the reasonable assurance of protection time that is described in
Section 1.2 of RG 5.76, “Physical Protection Programs at Nuclear Power Reactors” (SGI).

5.2

To calculate AIPT, an SMR or non-LWR licensee should use the following four time elements
from their SBT calculations for adversary-focused missions: Response Time, Mission
Preparedness Time, Mission Execution Time, and Safety Margin. A licensee does not need to
consider an Additional Action Time when calculating an AIPT because the licensee adds the task
time for specific mitigative actions (i.e., similar to an Additional Action Time) to the AIPT during
the target set development process to determine whether a target set is achievable. Once
calculated, a licensee should round its AIPT up to the next full hour (e.g., 11¼ hours becomes an
AIPT of 12 hours). A licensee should recalculate its AIPT when any of the elements used to
calculate the AIPT increase; when any of the elements used to calculate the AIPT decrease, a
licensee may maintain its original AIPT so that it does not have to reassess or revise its target
sets.

5.3

Prior to a licensee operating a site for at least 10 years, the licensee should use a safety margin of
50% of the total of SBT time for elements 2 through 4 (i.e., Response Time, Mission
Preparedness Time, and Mission Execution Time) for its AIPT calculation. During the 10 year
period, the licensee would perform its annual and quarterly drills and exercises and complete
three triennial force-on-force NRC-graded exercises. These drills and exercises should enable the
licensee to obtain sufficient experience with performance of the contingency response strategy
and effectively implement corrective actions to address any identified deficiencies. Based upon
the anticipated level of experience and maturity of the licensee’s security programs, after 10 years
of operation the licensee may use a safety margin of 25% of the total of those same three SBT
element times for its AIPT calculation.

5.4

Example 1 above reflects an SBT based on an adversary-focused mission. The AIPT for the
hypothetical site that is under construction in Example 1 would be:
Alarm Assessment and Communication Time
Response Time
Mission Preparedness Time
Mission Execution Time

16 minutes
1½ hours
4 hours
+2½ hours
Subtotal:

8 hours, 16 minutes

Safety Margin Time (50% of SBT elements 2 thru 4) + 4 hours, 0 minutes
1½ + 4 + 2½ = 8 x .50
= 4 hours
12
hours and 16 minutes
6

For additional information regarding credible operator actions and the adversary interference
criteria refer to Section 5.5 in Regulatory Guide 5.81.

DG-5072, Appendix C, Page 13

Appendix C to DG 5072
Security Bounding Time and
Adversary Interference Precluded Time
AIPT = 13 hours (when rounded up to the nearest hour)

DG-5072, Appendix C, Page 14

BIBLIOGRAPHY
1.

U.S. Nuclear Regulatory Commission (NRC), Regulatory Issue Summary (RIS) 2002-12A:
“NRC Threat Advisory and Protective Measures System.”

2.

NRC, RIS 2002-21, “National Guard and Other Emergency Responders Located in the Licensee's
Controlled Area.”

3.

NRC, RIS 2006-02, “Good Practices for Licensee Performance During the Emergency
Preparedness Component of Force-On-Force Exercises.”

4.

NRC, RIS 2007-02, “Clarification of NRC Guidance for Emergency Notifications During
Quickly Changing Events.”

5.

NRC, Information Notice (IN) 2007-12, “Tactical Communications Interoperability Between
Nuclear Power Reactor Licensees and First Responders.”

6.

Nuclear Energy Institute (NEI) White Paper – “Best Practices for Maintaining Relationships with
Law Enforcement Agencies and First Responders at Nuclear Reactor Facilities,” February 2010.

7.

NEI 12-03, “Security Operating Experience Submittal Guideline.”

8.

U.S. Department of Energy, Sandia National Laboratories, SAND99-2486, “Explosive
Protection.”

9.

U.S. Department of Defense, “Structures to Resist the Effects of Accidental Explosions,” United
Facilities Criteria (UFC) 3-340-02.

10.

NRC, SECY 20-0070, “Technical Evaluation of the Security Bounding Time Concept for
Operating Nuclear Power Plants,” July 30, 2020, (ML20126G332).

DG-5072, Bibliography, Page 1

REFERENCES 7
1

U.S. Code of Federal Regulations (CFR), “Definitions,” Part 171.5, Chapter 1, Title 10,
“Energy.”

2

CFR, “Requirements for physical protection of licensed activities in nuclear power reactors
against radiological sabotage,” Part 73.55, Chapter 1, Title 10, “Energy.”

3

CFR, “Physical Protection of Plants and Materials,” Part 53, Chapter 1, Title 10, “Energy.”

4

CFR, “Domestic Licensing of Production and Utilization Facilities,” Part 50, Chapter 1, Title 10,
“Energy.”

5

CFR, “Licenses, Certifications, and Approvals for Nuclear Power Plants,” Part 52, Chapter 1,
Title 10, “Energy.”

6

U.S. Nuclear Regulatory Commission (NRC), Regulatory Guide (RG) 1.145, “Atmospheric
Dispersion Models for Potential Accident Consequence Assessments at Nuclear Power Plants,”
Washington, DC.

7

NRC, RG 1.183, “Alternative Radiological Source Terms for Evaluating Design Basis Accidents
at Nuclear Power Reactors,” Washington, DC.

8

NRC, RG 1.194, “Atmospheric Relative Concentrations for Control Room Radiological
Habitability Assessments at Nuclear Power Plants,” Washington, DC.

9

NRC, RG 1.233, “Guidance for a Technology-Inclusive. Rick-Informed, and Performance-Based
Methodology to Inform the Licensing Basis and Content of Applications for Licenses,
Certifications, and Approvals for Non-Light-Water Reactors,” Washington, DC.

10

NRC, RG 5.69, “Guidance for the Application of the Radiological Sabotage Design-Basis Threat
in the Design, Development, and Implementation of a Physical Security Protection Program that
Meets 10 CFR 73.55 Requirements,” Washington, DC. (not publicly available)

11

NRC, RG 5.71, “Cyber Security Programs for Nuclear Facilities,” Washington, DC.

12

NRC, RG 5.74, “Managing the Safety/Security Interface,” Washington, DC.

13

NRC, RG 5.75, “Training and Qualification of Security Personnel at Nuclear Power Reactor
Facilities,” Washington, DC.

14

NRC, RG 5.76, “Physical Protection Programs at Nuclear Power Reactors,” Washington, DC.
(not publicly available)

15

NRC, RG 5.77, “Insider Mitigation Program,” Washington, DC. (not publicly available)

7

Publicly available NRC published documents are available electronically through the NRC Library on the NRC’s public
Web site at http://www.nrc.gov/reading-rm/doc-collections/ and through the NRC’s Agencywide Documents Access and
Management System (ADAMS) at http://www.nrc.gov/reading-rm/adams.html. The documents can also be viewed on line
or printed for a fee in the NRC’s Public Document Room (PDR) at 11555 Rockville Pike, Rockville, MD. For problems
with ADAMS, contact the PDR staff at 301-415-4737 or (800) 397-4209; fax (301) 415-3548; or e-mail
pdr.resource@nrc.gov.
Copies of International Atomic Energy Agency (IAEA) documents may be obtained through their Web site:
WWW.IAEA.Org/ or by writing the International Atomic Energy Agency P.O. Box 100 Wagramer Strasse 5, A-1400
Vienna, Austria. Telephone (+431) 2600-0, Fax (+431) 2600-7, or E-Mail at Official.Mail@IAEA.Org

DG-5072, References, Page 1

16

NRC, RG 5.81, “Target Set Identification and Development for Nuclear Power Reactors,”
Washington, DC. (not publicly available)

17

NRC, NUREG 0800, “Standard Review Plan for the Review of Safety Analysis Reports for
Nuclear Power Plants: LWR Edition” Washington, DC.

18

NRC, NUREG/CR 7145, “Nuclear Power Plant Security Assessment Guide,” Washington, DC.

19

NRC, NUREG 1964, “Access Control Systems: Technical Information,” Washington, DC.

20

NRC, NUREG/CR 7201, “Characterizing Explosive Effects on Underground Structure,”
Washington, DC.

21

NRC, NUREG/CR 6190, “Protection Against Malevolent Use of Vehicles at Nuclear Power
Plants: Vehicle Barrier System Siting Guidance for Blast Protection,” Vols. 1 and 2, Washington,
DC.

22

U.S. Department of Energy, Sandia National Laboratory, “Access Delay Technology,” SAND992168.

23

U.S. Department of Energy, Sandia National Laboratory, “Vital Area Identification for U.S.
Regulatory Nuclear Power Reactor Licensees and New Reactor Applicants,” SAND2008-5644.

24

U.S. Department of Energy, Sandia National Laboratory, “Security Assessment Technical
Manual,” SAND2007-5591.

25

Atomic Energy Act of 1954, as amended, Section 42, United States Code (U.S.C.).

26

Federal Register (FR) Notice, “Nuclear Regulatory Commission International Policy Statement”
(79 FR 39415), July 10, 2014.

27

Management Directive and Handbook 6.6, “Regulatory Guides,” Washington, DC.

28

IAEA Nuclear Security Series No. 13, “Nuclear Security Recommendations on Physical
Protection of Nuclear Material and Nuclear Facilities (INFCIRC/225/Revision 5)”

29

IAEA Nuclear Security Series No. 27-G, “Physical Protection of Nuclear Material and Nuclear
Facilities (implementation of INFCIRC/225/Revision 5)”

30

Management Directive and Handbook 8.4, “Management of Backfitting, Forward Fitting, Issue
Finality, and Information Requests,” Washington, DC.

DG-5072, References, Page 2