ML20304A058
| ML20304A058 | |
| Person / Time | |
|---|---|
| Issue date: | 10/30/2020 |
| From: | Dante Johnson Security Performance Evaluation Branch |
| To: | |
| Johnson D | |
| References | |
| Download: ML20304A058 (14) | |
Text
2021 FOF Inspection Activities Landscape In 2020, NRC staff launched IP 92707 Enabled performance testing of limited number of responders Allowed assessment of individual responder actions and limited elements of the licensee protective strategy Circumstances associated with COVID-19 PHE continue; implementation of safety protocols have enabled increased ability to conduct oversight activities.
In 2021 Apply lessons learned from IP 92707 and other inspections conducted in 2020 to continue to perform oversight in a risk-informed manner Expand to include evaluation of denial strategies Balance safety with more comprehensive evaluation of integrated protective strategy Leverage application of TI to inform future program evolutions 2
Path Forward Generate Temporary Instruction A and B weeks Hybrid evaluation One exercise that includes full pathway Limited number of exercise participants Alternative assessment process Leverage licensees corrective action programs Implement strategies to address COVID-19 considerations Limit time on site to minimum necessary to conduct inspection Use social distancing/facial coverings Infrastructure Use NRC-owned MILES Use JCAF/CAF for adversary force and limit to necessary attendees Begin inspections in March 2021 3
Inspection Structure Two-week inspection used to evaluate the licensees security response Planning week Protective Strategy Briefing Tabletop Drills Site (Owner Controlled Area/Protected Area/Vital Area/Target Set) Tours Exercise week Matrix Review Exercise Briefings; Safety, Controller, Adversary, Player & On-Duty Exercise Use the minimum number of members of the response force and the mock adversary team sufficient to execute the scenario being tested a credible, realistic and thorough test of a sites protective strategy evaluates the key security program performance elements bounded by the DBT provides scenario controls and exercise controllers tests responders in BREs with appropriate protective measures Management Critique 4
Exercise Model One exercise Exercise begins in owner-controlled-area and progresses through the licensee's defense-in-depth 5
Exercise Model 6
Alternative Assessment Approach Concept was considered by staff during formulation of revised FOF framework in 2019 Considered eliminating the characterization of exercise outcomes Use ROP security cornerstone activities to assess the ability of the licensee's physical protection program to defend against the DBT through the NRC's robust, multi-faceted inspection programs NRC-conducted FOF exercise used to evaluate and assess the licensee's protective strategies 7
Alternative Assessment Approach FOF SDP will not be used for exercise outcomes Inspection team will use an alternative approach to assess licensee performance during exercises No Vulnerabilities Identified Potential Vulnerabilities Identified Inspection team will assess performance deficiencies related to other inspection activities using the security baseline SDP 8
Bullet Resistant Enclosures (BREs)
Responders and controllers would only be in the BRE during the actual drill play. During timeouts and/or no play time the responder/controller would exit the BRE.
Use portable/temporary BREs Implement compensatory measures Consider using available technology Use pods for staffing BREs Follow current CDC guidelines during the exercises to wear facial coverings if distance cannot be maintained.
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Comparison between 71130.03, 92707, and TI Activity Done during 92707 TI 71130.03 Protective Strategy Briefing Tabletop Drills Site (OCA/PA/VA/Target Set) Tour Use NRC-owned MILES Use JCAF/CAF Exercise (with all security responders)
Limited Scope Tactical Response Drills Exercise (only with security responders that would potentially have engagements during the exercise)
Management Critique 10
Social Distancing Recommendations for Inspection Activities Entrance/Exit Meetings/Management Critique: conducted virtually Protective Strategy Briefing: NRC review presentation with minimal licensee personnel. Room large enough to exercise social distancing, divide people into more than one room, or use technology.
Site Tours: Conduct tours simultaneously; limit personnel on each tour.
Tabletop Drills: Include Ops and LLEA. Room large enough to exercise social distancing, divide people into more than one room, or use technology.
MAF Interface: Limit number of staff interaction in room big enough to practice social distancing.
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Social Distancing Recommendations for Inspection Activities Adversary Mission Overview and Controller Briefing: Attended by minimal personnel; room large enough to exercise social distancing, divide people into more than one room, or use technology.
Controller/Safety Briefings/Hot Washes: Room large enough to exercise social distancing, divide people into more than one room, or use technology.
MILES Issuance and Return: Conducted outside with social distancing practices in place. Equipment sanitized before and after each exercise.
Exercises: Only staff necessary positions; determine compensatory/safety protocol measures for BREs 12
Realism/Consistency MILES Equipment use NRC-owned equipment inconsistency in types of MILES equipment used across the industry DOE calibrates equipment 3 DOE personnel need to come to site DOE staff have sanitization process for equipment MAF Use JCAF/CAF minimize number of personnel going to site 13
Considerations for Conducting Inspections in 2021 Access to hotels & restaurants within commuting area of site available Airline travel available Facial coverings or other protective supplies available for the inspectors Site conditions support inspection Security staff available from site shifts or other sites to support inspection positions, as needed NRC will not permit inspection team members to travel if they have symptoms associated with COVID-19, or have been in contact with a person who is presumed positive, or has tested positive for the virus within 14 days preceding the start of travel.
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