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Industry Presentation (NEI) - Security Oversight for Nuclear Power Plants in Relation to the Covid 19 Public Health Emergency, June 16, 2020
	ML20168A070
Person / Time
Site:	Nuclear Energy Institute
Issue date:	06/16/2020
From:	; Nuclear Energy Institute
To:	; Office of Nuclear Security and Incident Response
	Johnson D
References
	Download: ML20168A070 (14)
	v • d • e

Security Oversight for Nuclear Power Plants in Relation to the COVID-19 Public Health Emergency June 16, 2020

Enforcement Guidance Memorandum, EGM 20-002

EGM states, It is expected that licensees will take reasonable actions to prepare for and limit staff exposure to COVID-19.

Conducting training evolutions with multiple personnel may increase the spread of the COVID-19 virus and ultimately have a negative impact on the licensees ability to staff mission-critical positions necessary to successfully implement its protective strategy at the site and,

The NRC recognizes that impacts on a licensee could continue after the official termination of the PHE. Consequently, the provisions of this EGM may be applied after termination of the PHE to allow, on a case-by-case basis (not to exceed 1 year from the issuance date of the EGM), appropriate consideration of specific circumstances that arise during the inspection cycle following the PHE recovery.

NEI Member Perspective on Resumption of FOF Exercises

Reasonable assurance of robust security posture is provided through ongoing utility training activities and numerous inspections conducted by the NRC

Conduct of a FOF exercise will pose an undue risk of exposure to COVID-19 for security personnel

Could negatively impact the licensees ability to implement its NRC-approved security plan

Prudent criteria proposed for resumption of FOF exercises

Unique Characteristics of IP 71130.03

The exercise portion of IP 71130.03 poses a risk to a significant number of critical station employees unlike any other inspection:

o Roughly 75% (3 of 4 shifts) of security personnel must be on site at the same time in close proximity to support the exercise o Additional personnel including interstate travelers interface with the security force o Site pandemic protocols (e.g., social distancing) can not be maintained during the exercise o Use of medically qualified face masks and social distancing introduce exercise artificialities o Heat issues restrict officer stay times o Fogging of safety glasses causes sight acquisition issues o Communication between responders and controllers impaired

Maintaining Reasonable Assurance

The 71130 Inspection Series is composed of numerous elements that collectively inform NRCs reasonable assurance determination

IP 71130.03 Inspection Procedure, Contingency Response -

Force-on-Force, is just 1 of 10 inspections in the series o Majority of IP can still be performed; just the exercise portion that poses the risk

During the PHE, the NRC has been conducting numerous inspections under this series including:

o Access Controls (.02) o Equipment Performance/Maintenance/Testing (.04) o Security Training (.07)

90% of inspection activities are still taking place with some modifications

Maintaining Reasonable Assurance

NRC is conducting the majority of the elements of IP 71130.03, Contingency Response - FOF (Modified Planning (A) Week):

o Plan and procedure reviews o Protective strategy review briefings o Walk downs and interviews with site security personnel o Protective strategic walk downs in the Owner Control, Protected, and Vital Areas o Mission planning and scenario development for exercise o Tabletop protective strategy exercises o Walk down and testing of Intrusion Detection Systems (IDS)

Modified Planning A Week evaluates the robustness of the utility security strategies

Maintaining Reasonable Assurance

Capabilities to detect, assess, interdict the DBT are maintained at all times:

o Contingency response tabletop command and control drills demonstrate proficiency in protective strategies:

o Detection and assessment o Patrols o Searches o Defensive operations o On-going weapons training - day/night fire, tactical course of fire while moving, weapons familiarity, tabletops, written exams, physical fitness/agility tests, etc.

Defense-in-depth through the integration of systems, technologies, equipment and supporting processes and procedures

NEI Member Perspective on Resumption of FOF Inspections

Conditions for resumption of FOF exercises composed of three parts that must be met to ensure inspection consistency across the fleet:

Part 1: Entry Criteria To Resume FOF Exercises

Part 2: Conditions Following Entrance Criteria

Part 3: Specific Criteria for Conduct of IP 71130.03, Contingency Response - Force on Force Testing

Part 1: Entry Criteria to Resume FOF Exercises

EGM 20-002 Attachment 1 references recommendations to which licensees must conform

FOF exercises should not resume until all are met:

o CDC relaxes or rescinds recommendations outlined in the March 28, 2020 Memorandum for prevention of the spread of COVID-19 o Conformance to the U.S. Department of Labor Guidance on Preparing Workplaces for COVID-19, is no longer necessary to prevent the spread of COVID-19 o Conforming State and local PHE guidelines are rescinded

Part 2: Conditions Following Entry Criteria

Nuclear power generators are designated by DHS as critical infrastructure o Protective measures imposed to reduce the risk of transmission of the virus o Protective measures will likely be required beyond the PHE

FOF exercises must be conducted in accordance with licensee required safety protocol:

Facemasks and other PPE

Pre-access screening/testing for visitors

Quarantining of out-of-state visitors

Others

Part 2: Conditions Following Entry Criteria, contd.

Exercise execution should incorporate additional safety controls such as:

o Limit the number of inspectors to enable full complement of participants (e.g. players, controllers, law enforcement, etc.) to conform to social distancing and assembly guidelines o NRC inspectors observe exercise remotely and not in BREs or other posts with limited space

Part 3: Specific Criteria for Conducting IP 71130.03, Contingency Response - FOF Testing Activities associated with B week may be conducted when:

Access to hotels and restaurants within commuting area of site are available

Airline travel available (as required)

Out-of-state travel guidance lifted (i.e., requirement to self-quarantine upon arrival in state)

Travel conditions allow DOE MILES trailer travel to inspection location in reasonable duration

Screening requirements are met in accordance with licensee requirements

Part 3: Specific Criteria for Conducting IP 71130.03, Contingency Response - FOF Testing, contd.

Activities associated with B Week may be conducted when:

DOE has a plan in place to sanitize MILES gear after use

Responders, adversaries, and their controllers can conduct drill play without donning masks and without practicing social distancing

Temporary exemptions for annual FOF exercises have expired

Conclusions

The exercise portion of IP 71130.03 poses a risk to a significant number of critical station employees unlike any other inspection o Maintaining the public, plant and worker health and safety is our number one priority.

Temporary suspension of FOF exercises, one element of one inspection procedure, does not impact reasonable assurance.

o 90% of the security physical security inspections are being conducted.

ML20168A070

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