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Response to Northern Power States Co. Appeal of the Formal Disagreement with Adversary Characteristics, Attributes, or Tactics Employed or Prepared as Part of an NRC Evaluated Force-on-Force Exercise - Disputed Item 05000282/2017201 and 050
	ML17083A096
Person / Time
Site:	Prairie Island
Issue date:	03/24/2017
From:	Brian Holian; Office of Nuclear Security and Incident Response
To:	White R; Northern States Power Company, Minnesota
	Becca Richardson
References
	IR 2017201
	Download: ML17083A096 (2)
	v • d • e

March 24, 2017

Mr. Rob White

Security Director

Northern States Power Company - Minnesota

414 Nicollet Mall - 7th Floor

Minneapolis, MN 55401

SUBJECT: RESPONSE TO NORTHERN STATE POWER COMPANYS APPEAL OF THE

FORMAL DISAGREEMENT WITH ADVERSARY CHARACTERISTICS,

ATTRIBUTES, OR TACTICS EMPLOYED OR PREPARED AS PART OF A U.S.

NUCLEAR REGULATORY COMMISSION EVALUATED FORCE-ON-FORCE

Dear Mr. White:

Thank you for your phone call on March 23, 2017, to discuss Northern State Power Companys

appeal to the U.S. Nuclear Regulatory Commissions (NRC) initial response, dated

March 22, 2017, related to your Formal Disagreement with Adversary Characteristics,

Attributes, or Tactics Employed or Prepared as Part of an NRC Force-on-Force Evaluated

Exercise, in accordance with Addendum 4 of NRC Inspection Procedure 71130.03

Contingency Response - Force-on-Force Testing.

In your original email dated March 20, 2017, Northern State Power Company disputes a tactic,

technique, or procedure (TTP) within Scenario 1 developed by the NRC Force-on-Force (FOF)

inspection team.

The NRC carefully reviewed the appeal to the initial decision, and concluded that at this time,

the disputed TTP is not approved for use within NRC-evaluated Scenario 1 until the pending

update to Regulatory Guide 5.69, Guidance for the Application of the Radiological Sabotage

Design Basis Threat in the Design, Development and Implementation of a Physical Protection

Program, is issued. I expect the updated regulatory guide to include guidance that will clarify

that the disputed TTP is acceptable for future FOF exercise scenarios.

Sincerely,

/RA S. West for/

Brian E. Holian, Director

Office of Nuclear Security and Incident Response

OFFICE NSIR/DSO/SPEB NSIR/DSO/SPEB NSIR/DSO NSIR

NAME RRichardson CJohnson DPretzello BHolian (SWest for)

DATE 3 / 24 / 17 3 / 24 / 17 3 / 24 / 17 3 / 24 / 17

ML17083A096