ML18347B458
| ML18347B458 | |
| Person / Time | |
|---|---|
| Issue date: | 12/13/2018 |
| From: | Keene J, Doris Lewis NRC/NSIR/DPCP/RSB, Division of Security Operations |
| To: | |
| Lewis D | |
| References | |
| SRM-17-0100 | |
| Download: ML18347B458 (13) | |
Text
Update on Staffs Follow up Actions on SRM-17-0100 Public Meeting Commissioners Hearing Room December 17, 2018
Agenda Overview of Staffs Draft Options Industry Presentation on Security Bounding Time (SBT) White Paper Discussion of Options for Crediting LLEA Questions on Industrys SBT White Paper Discussion on Applying Credit through Changes to Target Sets Discussion on Applying Credit through Changes to the Significance Determination Process (SDP)
Discussion on Applying Credit through Changes to Regulatory Guide 5.81, Criterion 3 Conclusion
Draft Options
- Sliding Scale
- Industrys Security Bounding Time (SBT)
White Paper
- Consideration of 10 CFR 50.47
Sliding Scale Option Site-specific credit based on:
- Level of coordination, planning, and training between licensees and law enforcement (LE) responders
- Area of the site in which law enforcement assistance would be needed (i.e., owner controlled area, exterior portions of a protected area, inside site structures)
Uses standardized criteria to evaluate coordination, planning, and training Cover six types of incident response preparation Guiding principle: more criteria met = better LE preparedness = greater licensee credit Example of potential credit: Add operator actions & equipment (e.g., FLEX) to target sets
Documentation
- Commitments
- Plans
- Training
- Corrective actions
- Lessons learned Information Exchange
- Site information provided in advance Contingency Response Tools Tactical Mission Planning Package
- Periodic review and update of plans Tabletop Discussions
- Periodicity
- Involve site and law enforcement management
- Lessons inform planning, training and documentation Communications
- Primary, secondary, and tertiary systems and protocols
- Individual-or command center-based
- Periodic onsite testing, including of law enforcement equipment
- Frequency map documented and included in plans
- Lessons inform planning, training and documentation Familiarization Activities
- Information on site security, adversary, & law enforcement capabilities
- Periodic walk-downs of areas related to law enforcement support
- Environmental hazards
- Lessons inform planning, training and documentation Training and Validation
- Periodic functional exercises (permissive environment)
- Periodic field exercises (simulated combat environment)
- Lessons inform planning, training and documentation Law Enforcement Preparedness (increasing)
Security Coping Time (decreasing)
Industrys SBT Proposal
- Site-specific credit based on a 6-step process and security coping time formulas Security coping time formulas by support area:
Owner Controlled Area and Protected Area Example of potential credit: Add operator actions &
equipment (e.g., FLEX) to target sets
Consideration of 10 CFR 50.47
- Option for Commission to equate offsite response actions off licensee property under 10 CFR 50.47(c)(1)(iii)(B) with offsite response actions on licensee property, including potentially inside protected areas
- Would likely establish the same security coping time for every power reactor site
- May consider establishing security coping times in tiers, likely based on licensees geographic proximity to LE assistance
- Would need to evaluate if this requires change to other requirements to implement
Questions on Sliding Scale
Questions on Industrys SBT White Paper
Discussion on Applying Credit through Changes to Target Sets
Discussion on Applying Credit through Changes to the Significance Determination Process (SDP)
Discussion on Applying Credit through Changes to Regulatory Guide 5.81, Criterion 3
Conclusion