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Public Meeting with NRC on Opac - SBT (Final) - NRC Copy
	ML18348B146
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Site:	Nuclear Energy Institute
Issue date:	12/17/2018
From:	Hanson R, Doris Lewis, Washington T, White R, Whitlock M; NRC/NSIR/DPCP/RSB, Nuclear Energy Institute
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	Download: ML18348B146 (32)
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Credit for Operator and Mitigation Actions, and Security Bounding Time December 17, 2018 Trina Washington, Rob White, Richard Hanson and Mike Whitlock NRC Public Meeting to Discuss Staffs Follow-up Actions in Response to SRM-SECY-17-0100

©2018 Nuclear Energy Institute 2 Extend RG 5.81* criteria to broader set of operator actions Add more target elements to target sets Receive credit for law enforcement tactical support to enable additional licensee mitigation actions that would prevent radiological sabotage NRC establishes a default Security Bounding Time (SBT)

NRC endorses NEI approach to determining a site-specific SBT Allow removal of target elements that lead to a target set loss over a long duration (in excess of a SBT)

Address in RG 5.81 and endorsed NEI document Credited actions that enhance site protective strategies Desired outcomes

Regulatory Guide 5.81, Target Set Identification and Development for Nuclear Power Reactors

Determination that a licensee may rely on an action to be performed when developing a protective strategy

Conclusion of action viability should meet a reasonable assurance standard Operator Action - An action meeting criteria in RG 5.81 An operator action is a target element within a target set It cannot rely on removal of adversary interference by law enforcement, but viability should consider the capabilities of the site protective strategy Operator can use plant, FLEX or B.5.b equipment Definition of terms

©2018 Nuclear Energy Institute 4 Mitigation Action - An action that may be taken by an operator to prevent the irreversible onset of radiological sabotage but does not meet the operator action criteria in RG 5.81 May prevent the loss of a target set or compensate for the loss of a target set May include the use of guidelines and equipment for mitigating the consequences of beyond-design-basis (BDB) external events, or events leading to a loss of large areas of the plant due to explosions or fires, as required by NRC regulations, orders and licenses (FLEX and B.5.b)

Requires the removal of adversary interference (i.e., a Security Bounding Time) to permit performance Definition of terms

©2018 Nuclear Energy Institute 5 Security Bounding Time (SBT) - The elapsed time, measured from recognition of an attack, required for a law enforcement tactical team to eliminate adversary interference sufficiently to allow performance of a mitigation action Mitigation actions are taken to protect public health and safety Tactical team is augmenting the onsite security force for a specific purpose; security supervision maintains control of overall site security response The NRC staff has suggested that recalled licensee security personnel may also be considered as a tactical resource for establishing a SBT; NEI supports development of this option Definition of terms

©2018 Nuclear Energy Institute 7 Determination of adversary timelines should be made with consideration of the effectiveness of a licensees protective strategy, and demonstrated capabilities to interdict adversaries Adding operator actions increases the complexity of the adversarys mission, which decreases the probability of success and improves margin Assessment of an operator action employing equipment maintained for the mitigation of BDB events (e.g., FLEX or B.5.b) should be able to credit the equipment, procedures and training described in associated program documents Operator actions

- If FOF drill and exercise performance demonstrates that the protective strategy protects the operator, travel path and performance location, then the action should be credited Computer modeling - If a licensee has a site-specific computer model of their protective strategy, then the operator action may be permitted if the model shows there is reasonable assurance that an adversary cannot preclude performance Potential changes to RG 5.81 - adversary timelines

©2018 Nuclear Energy Institute 9 Delay factors - Adversary timelines should reflect all factors that would hinder the movement of an adversary, not just passive features Through a review of military or other literature, these factors should be identified, quantified, and made available for licensee assessments of operator actions Location of the action relative to other target set equipment - Permit operator action when performance location is in the same area as another target element and that area is included within the protective strategy Consider in cases when the adversary will arrive after the operator but before the action is completed Potential changes to RG 5.81 - adversary timelines

©2018 Nuclear Energy Institute 10 Increase the number of barriers to radiological sabotage Viable if the action can be performed after adversary interference has been eliminated, and before the onset of irreversible radiological sabotage An action could involve use of plant equipment or equipment maintained for responses to BDB events (FLEX and B.5.b)

Eliminating adversary interference could be accomplished through containment of adversary force members within areas that do not permit interference with implementation of the action (considering both travel routes and work areas) or neutralization Establish a SBT to credit law enforcement tactical response Mitigation actions

©2018 Nuclear Energy Institute 12 As a result of NRC staff feedback on the NEI Security Event Mitigation Assessment (SEMA) white paper, submitted on May 3, 2017, the NEI SBT white paper addresses only the determination of a site-specific SBT Other aspects of assessing the viability of a mitigation action need to be defined (e.g., availability and protection of FLEX equipment)

The assessment of a mitigation action employing equipment maintained for the mitigation of BDB events should be able to credit the equipment, procedures and training described in associated program documents Mitigation actions

©2018 Nuclear Energy Institute 13 Determines credit for law enforcement tactical support received from a local, regional, State, or Federal source Licensee will likely seek credit for a tactical team with the shortest response time, other factors being equal. For example, a site may achieve SBT credit based on the support from a local tactical team, even though additional tactical responders would be available from State and Federal agencies.

Ensures tactical team has site information prior to attack Specifies minimum capability standards for tactical support NTOA standard, or equivalent State/Federal standard Capabilities may be adjusted by law enforcement agency based on site-specific mission needs NEI SBT process

©2018 Nuclear Energy Institute 14 Mission planning and execution times Based on licensee experience and discussions with LLEAs Reasonable and bounding for a wide range of conditions Tactical team may determine times greater (but not less) than assumed times based on planning process Two planning categories/time formulas Outside Protected Area Inside Protected Area (whether inside or outside power block)

SBT process is focused on facilitating performance of a mitigation action; it is not intended to create an integrated response plan Security supervision maintains control of overall site security response NEI SBT process

©2018 Nuclear Energy Institute 15 Permit consideration of law enforcement tactical support and mitigation actions Recognize adversary interference is eliminated after the SBT is exceeded, and subsequent mitigation actions Consideration could inform:

Target set development Selection of FOF exercise scenario target sets

Certain scenarios with durations beyond an SBT would screen out because a mitigation action could be taken Inform SDP by allowing the outcome of an FOF exercise to be evaluated under the framework of the Baseline SDP

Could eliminate the FOF exercise SDP Credit for mitigation actions - desired outcomes

60 120 180 240 300 360 420 480 540 600 660 1

2 3

4 5

6 7

8 9

10 Minutes Target Set Lost Mesa NPP - Time to Core Damage Time to CD -

loss of support system Time to CD -

loss of target elements SBT = 4.5 hours5.787037e-5 days 0.00139 hours 8.267196e-6 weeks 1.9025e-6 months

©2018 Nuclear Energy Institute 17 Lost Mesa NPP with a 4.5 hour5.787037e-5 days 0.00139 hours 8.267196e-6 weeks 1.9025e-6 months SBT - potential support element screen-outs Mitigation action example SBT

©2018 Nuclear Energy Institute 28 Change summary Operator Action Security Bounding Time and Mitigation Actions Change Revise RG 5.81 Criterion 3 to include suggested assessment criteria (FOF exercise performance, computer modeling, delay factors or location of the action relative to other target set equipment); make conforming changes to IP 71130.14 Revise RG 5.81 to identify Elements beyond the SBT as unattractive; make conforming changes to IP 71130.14 Impact RG 5.81, Appendix A, Attribute 9 RG 5.81, Appendix A, Attributes 6 and 11; elements beyond SBT in TSs will become unattractive - move from Attribute 6 to 11 (or a new Attribute)

Benefits Increase elements in TSs and reduce the number of standalone targets Unattractive Elements will not require protection due to the capability to mitigate after SBT

TCD = 3 hrs.

TCD = 4.5 hrs.

TCD = 6.5

6. Target Set Equipment:

Element A or Element D And Element B And Element C

11. Additional Considerations:

9. Credited Operator Actions and Damage Control Measures:

0 1

2 3

4 5

6 7

8 Element D Element A, B, C Element A Time (hours)

Example 1 (current)

6. Target Set Equipment:

Element A or Element D And Element B And Element C

11. Additional Considerations:

Element D is mitigated by operator providing BDB pump.

Damage control measure is credited because time to core damage is beyond SBT and operator has sufficient time to preform actions of placing BDB equipment in place.

9. Credited Operator Actions and Damage Control Measures:

0 1 2 3 4 5 6 7 8 Element D Element A, B, C Element A Time (hours)

Example 1 Mitigation Action (proposed)

RESULT: Protection for Element D no longer needed due to ability for operator to perform actions after SBT. Evaluate strategy for impacts.

Primary TS Equipment Alternate Elements A, B and C Element A TCD = 3 hrs.

TCD = 4.5 hrs.

Secondary Fuel Fuel source for Element A (Element D)

TCD = 6.5

TCD = 4.5 hrs.

TCD = 7.5

6. Target Set Equipment:

Element E or Element F And Element B

11. Additional Considerations:

Time to core damage can be decreased by eliminating Element F and Element G

9. Credited Operator Actions and Damage Control Measures:

0 1

2 3

4 5

6 7

8 Element E, B Element F, B Element F, G, B Time (hours)

Example 2 (current)

6. Target Set Equipment:

Element E Or Element F and Element G And Element B

11. Additional Considerations:

Element F is mitigated by operator closing valve in PA yard.

Damage control measure is credited because time to core damage is beyond SBT and operator has sufficient time to preform actions of closing valve in PA yard.

9. Credited Operator Actions and Damage Control Measures:

RESULT: Protection for Ele. F not needed due to operator actions after SBT; however Ele. G will need protection if Ele.

F protection is removed. Evaluate strategy for impacts.

Primary TS Equipment Alternate Elements E and B Elements F, G and B

TCD = 2 hrs.

TCD = 4.5 hrs.

Secondary Flooding Effects Flooding Element E

TCD = 7.5 0

1 2

3 4

5 6

7 8

Element E, B Element F, B Element F, G, B Time (hours)

Example 2 Mitigation Action (proposed)

ML18348B146

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