ML20309A698

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Meeting Memo - Discussion with Industry of FOF Options During PHE for 2021 (Nov 2 2020) and Enclosure
ML20309A698
Person / Time
Issue date: 11/23/2020
From: Steve Ruffin
Security Performance Evaluation Branch
To: Sabrina Atack
Division of Security Operations
Stone R
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ML20308A706 List:
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Download: ML20309A698 (5)
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November 23, 2020 MEMORANDUM TO: Sabrina Atack, Director Division of Security Operations Office of Nuclear Security and Incident Response FROM: Steve Ruffin, Acting Chief /RA/

Security Performance Evaluation Branch Division of Security Operations Office of Nuclear Security and Incident Response

SUBJECT:

MEETING

SUMMARY

FOR THE PUBLIC MEETING BETWEEN THE U.S. NUCLEAR REGULATORY COMMISSION STAFF, NUCLEAR ENERGY INSTITUTE, ENTERGY, NEXTERA, AND INDUSTRY STAKEHOLDERS ON FORCE-ON-FORCE INSPECTION ACTIVITIES IN 2021 DURING THE COVID-19 PUBLIC HEALTH EMERGENCY On November 2, 2020, the U.S. Nuclear Regulatory Commission (NRC) held a public meeting. The purpose of this meeting was to discuss force-on-force inspection activities in 2021 during the COVID-19 public health emergency with representatives from the Nuclear Energy Institute, NextEra, Entergy, and other relevant stakeholders. Enclosed is a summary of the meeting, including the NRC Presentation and a detailed summary of the discussions held during the public meeting, and the responses to questions received after the public meeting.

Enclosures:

1. Meeting Summary
2. Responses to Questions Received After the Public Meeting CONTACT: Rebecca Stone, NSIR/DSO/SPEB 850-496-4581

U.S. Nuclear Regulatory Commission Public Meeting Summary

Title:

U.S. Nuclear Regulatory Commission (NRC)-Conducted Force-on-Force (FOF)

Inspection Activities for 2021 during the COVID-19 Public Health Emergency (PHE)

Date of Meeting: Monday, November 2, 2020 Location: Teleconference Type of Meeting: Category 2 Public Meeting Purpose of the Meeting: The purpose of this meeting was to have discussions with Nuclear Energy Institute (NEI), NextEra, Entergy, Union of Concerned Scientists and other industry stakeholders regarding FOF inspection activities in 2021 during the COVID-19 PHE.

Simplified List of Attendees:

Speakers NRC: Brian Holian, Sabrina Atack, Danté Johnson, Dave Bradfield Union of Concerned Scientists: Dr. Ed Lyman NEI: AJ Clore Industry: Ken Peters (Luminant Power), Aldo Capristo (STP)

NextEra: Mark Fencl Entergy: Jon LaPlante Additional attendees included various NRC staff members and stakeholders.

General Details:

The Office of Nuclear Security and Incident Response (NSIR) staff hosted a public meeting with representatives from NEI, NextEra, Entergy, the Union of Concerned Scientists, and other stakeholders to discuss FOF inspection activities in calendar year (CY) 2021 during the COVID-19 PHE. During this meeting, the NRC provided a brief overview of the NRC actions taken regarding FOF inspections during the PHE and how the lessons-learned from the temporary Inspection Procedure (IP) 92707 limited scope inspection procedure will inform the path forward for CY 2021 FOF inspections. NRC staff then gave a summary of the NRCs proposed plan for a temporary inspection procedure in CY 2021, which would include a hybrid evaluation of one full exercise with a limited number of participants. In order to maintain the safety of NRC inspectors and licensee personnel, the same COVID-19 strategies employed since the start of the PHE (i.e., social distancing, facial coverings, minimal necessary time onsite, etc.) would continue to be utilized. The meeting was then opened for discussion and questions from NRC staff, industry representatives, and public stakeholders.

Action Items/Next Steps:

  • NRC staff will evaluate the information presented and concerns expressed during the meeting to determine the appropriate level of oversight while still maintaining the health of the NRC and site personnel.
  • NRC staff will continue to engage industry and the public, as needed.

Attachments:

  • Summary of Discussions from the Public Meeting - ML20309A526 Enclosure 1

RESPONSES TO FOLLOW-UP QUESTIONS FROM PUBLIC MEETING Several questions were received after the public meeting. The questions and responses are provided below.

  • Full pathway: What does the full pathway from owner-controlled area (OCA) to licensees defense-in-depth mean? Does that mean if the licensee terminates everyone at the fence line, instead of the drill being over that the adversary will regather inside the fence, and when they are terminated, they will regather inside the plant somewhere so they can test every aspect?

o During the conduct of the Inspection Procedure (IP) 92707 Limited Scope Drills (LSD) the U.S. Nuclear Regulatory Commission (NRC) inspection team planned a full mission (attack originates in the OCA and progressed along a specific route through the layers of defense to the selected target set) then selected key elements (along segments of the adversary pathway) of the contingency response within the protective strategy to evaluate. Each LSD was conducted independently without being informed by the other LSDs (run that one LSD/segment, stop, critique and reset for the next LSD/segment).

o During the conduct of the proposed temporary instruction for 2021, the NRC inspection team would plan a full mission (attack originates in the OCA and progresses along a specific route through the layers of defense to the selected target set) and the mock adversary would execute the full mission. If the adversary were neutralized at the fence line, the objective determination would be made there, then the existing controller matrix would be used to perform a sample of performance-based evolutions further along the pathway inside the protected area (PA). If, alternatively, the adversary made it into the PA and a substantive portion of the protective strategy was implemented, resurrection may not necessary.

o Similar to IP 71130.03 Contingency Response FOF Testing, the NRC will continue to provide an objective determination by characterizing the exercise results using the following:

Regulatory Evaluation - No Material Defects Identified

  • The licensee successfully demonstrates implementation of the contingency response in accordance with the protective strategy and physical security plan during the conduct of an NRC-evaluated FOF exercise where the security response force neutralizes and/or mitigates the mock adversary force (MAF) prior to completing the simulated destruction of a complete target set.

Regulatory Evaluation - Potential Material Defects Identified Tier I

  • The licensee contingency response was either only partially and/or not implemented in accordance with the protective strategy and physical security plan during the conduct of an NRC-evaluated FOF exercise. The security response force was Enclosure 2

able to neutralize and/or mitigate the MAF prior to completing the simulated destruction of a complete target set, however the mock adversary force was able to penetrate the defense-in-depth to simulate the destruction of multiple target set elements and/or preparing to enter an area that contained a single element target set.

  • NRC Response - Exercise outcomes would be placed into the licensee corrective action program (CAP) for further analysis and the NRC would review the results of the licensee analysis during the licensees next triennial FOF evaluation.

Regulatory Evaluation - Potential Material Defects Identified Tier II

  • The licensee contingency response was not implemented in accordance with the protective strategy and physical security plan during the conduct of an NRC-evaluated FOF exercise. The security response force is unable to neutralize and/or mitigate the mock adversary force prior to completing the simulated destruction of a target set.
  • NRC Response - Exercise outcomes would be placed into the licensee CAP for further analysis and the NRC would review the results of the licensee analysis during the licensees next IP 71103.05 Protective Strategy Evaluation and Performance Evaluation Program inspection.
  • The NRC maintains a regulatory nexus with the CAP reviews under Problem Identification and Resolution where the licensee is subject to regulatory requirements for correcting identified deficiencies.

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ML20309A698 Memo, Pkg. ML20308A706 OFFICE NSIR/DSO/SPEB BC:NSIR/DSO/SPEB NAME RStone SRuffin DATE 11/04/20 11/23/20

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