ML19018A229

Use of Licensee Multiple Integrated Laser Engagement System (Miles) Equipment in Force-on-Force Exercises

ML19018A229
Person / Time
Site:	Nuclear Energy Institute
Issue date:	01/18/2019
From:	Gross W Nuclear Energy Institute
To:	Marissa Bailey Document Control Desk, Office of Nuclear Reactor Regulation, Office of Nuclear Security and Incident Response
References
Download: ML19018A229 (2)

Text

WILLIAM R. GROSS Director, Incident Preparedness Facility Security Officer 1201 F Street, NW, Suite 1100 Washington, DC 20004 P: 202.739.8123 wrg@nei.org nei.org January 18, 2019 Ms. Marissa Bailey Director, Division of Security Operations Office of Nuclear Security and Incident Response U.S. Nuclear Regulatory Commission Washington, DC 20555-0001

Subject:

Use of Licensee Multiple Integrated Laser Engagement System (MILES) Equipment in Force-on-Force Exercises Project Number: 689

Dear Ms. Bailey:

In a letter dated August 8, 2018, the Nuclear Energy Institute (NEI), 1 on behalf of its members, provided suggested improvements to the Force-on-Force (FOF) exercise inspection process. In that letter, we requested the U.S. Nuclear Regulatory Commission (NRC) consider allowing licensees to use their own MILES equipment in NRC-evaluated FOF exercises. Subsequently, in the Staff Requirements Memorandum to SECY-17-0100, 2 the Commission directed the staff to assess whether there exist any obstacles to the NRCs acceptance of the use of licensee MILES equipment in both an NRC-conducted and a licensee-conducted FOF exercise, and if none, adopt this practice.

We appreciate the agencys consideration of this proposal. NEI has continued to engage with its members to assess the feasibility and timing of a transition to the use of licensee MILES equipment. SRM-SECY-17-0100 directs the staff to pursue several other actions that are of significant interest to our members, and they have indicated their belief that pursuing NRC approval for use of licensee MILES equipment at this time would be an unnecessary distraction. Accordingly, NEI would like to defer further work related to obtaining NRC approval for use of licensee MILES equipment until a future time.

1 The Nuclear Energy Institute (NEI) is responsible for establishing unified policy on behalf of its members relating to matters affecting the nuclear energy industry, including the regulatory aspects of generic operational and technical issues. NEIs members include entities licensed to operate commercial nuclear power plants in the United States, nuclear plant designers, major architect and engineering firms, fuel cycle facilities, nuclear materials licensees, and other organizations involved in the nuclear energy industry.

2 Refer to ADAMS Accession Number ML18283A072.

Ms. Marissa Bailey January 18, 2019 Page 2 If you have any questions or require additional information, please contact me at (202) 739-8123 or wrg@nei.org.

Sincerely, William R. Gross c: Mr. Brian Holian, NSIR, NRC NRC Document Control Desk