ML11227A050
| ML11227A050 | |
| Person / Time | |
|---|---|
| Issue date: | 08/19/2011 |
| From: | Patricia Holahan Division of Security Operations |
| To: | Kline D Nuclear Energy Institute |
| Shared Package | |
| ML11227A049 | List: |
| References | |
| Download: ML11227A050 (2) | |
Text
Enclosure U.S. Nuclear Regulatory Commission (NRC) Comments on Nuclear Energy Institute (NEI)
Concept Paper, Proposed Approach to Evaluating Security Personnel Response to Adversary Use of Hostages Page Paragraph Comment 1
1 The paper uses the term Tabletop Exercise. This is a misnomer. The correct title should be Table-top Drill. The drill term comports with long-standing understanding of the difference between an exercise and drill. In addition, the term Tabletop Simulations is later introduced. The paper lacks clarity on the difference, if any, between Tabletop Exercise and Tabletop Simulations.
Recommend changing Tabletop Exercise and Table-top Drill to Tabletop Exercises and Table-top Drills.
1 2
Page 1, Paragraph 2: The following sentence: It is not clear how the Systematic Approach to Training methodology detailed in Regulatory Guide (RG) 5.75, Training and Qualification of Security Personnel at Nuclear Power Plants, was used to support the use of table-top drills and discussions to evaluate this tactic.
If the intent of the review is to evaluate the licensees security force response, recommend changing evaluate this tactic to evaluate security personnel response to the use of hostages by an adversary force.
Need to elaborate on what RG 5.75 says about training to better indicate the relevance of your comment.
1 3
Page 1, Paragraph 3: Table-top drills and discussions may not satisfy the Physical Security Plan requirement that an adequate response strategy be demonstrated, especially regarding the actions of the following personnel: armed security officers, armed responders, search train personnel, and Independent Spent Fuel Storage Installation personnel, etc.
Recommend changing from especially regarding to specifically when evaluating Need to elaborate more on how table-top drills and discussions may not satisfy the Physical Security Plan and regarding the actions of the personnel involved.
Page Paragraph Comment 1
4 It is unclear how this alternative approach would be implemented industry-wide (e.g., 50.54(p) versus an NEI 03-12 template change).
Need to elaborate on how this approach would be implemented industry-wide.
1 5
Page 1, Paragraph 5: The paper does not give any details as to how the drill will be conducted, especially concerning how the disciplines such as operations, security, emergency planning, etc., would be involved.
Recommend changing not give to not provide.
2 1
Page 2, Paragraph 1: In light of these weaknesses, the staff also concludes that performance-based limited scope exercises rather than table-top drills and discussions should be used to assess the hostage tactic.
Recommend changing to in light of these weaknesses, the staff concludes that a licensee should use performance-based limited scope drills instead of table-top exercises to assess the sites security force response to the hostage tactic.
General Comments In the NRC response letter, the beginning of the letter uses the term potential weaknesses. At the end of the letter, however, the statement is made in light of these weaknesses. You might want to consider either using potential in both places, or not at all just for the sake of consistency.
We would offer the observation in response to the NEI paper based on our experience from the Indian Point Integrated Pilot Comprehensive Exercise (IPCE). We believe that Multiple Integrated Laser Engagement System (MILES) equipment can be used and controlled effectively using only the halo and harness without a weapon; and using god guns or M4s with small arms transmitters for exercise controllers. During the Indian Point IPCE, law enforcement players used the NRC-provided MILES gear in this configuration and we encountered no problems related to MILES control.