ML21225A696
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| Issue date: | 03/08/2021 |
| From: | NRC/OCM |
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| NRC-1420 | |
| Download: ML21225A696 (64) | |
Text
Official Transcript of Proceedings NUCLEAR REGULATORY COMMISSION
Title:
33rd Regulatory Information Conference Technical Session - M6 Docket Number: (n/a)
Location: teleconference Date: Monday, March 8, 2021 Work Order No.: NRC-1420 Pages 1-61 NEAL R. GROSS AND CO., INC.
Court Reporters and Transcribers 1323 Rhode Island Avenue, N.W.
Washington, D.C. 20005 (202) 234-4433
1 UNITED STATES OF AMERICA NUCLEAR REGULATORY COMMISSION
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33RD REGULATORY INFORMATION CONFERENCE (RIC)
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TECHNICAL SESSION - M6 REMAPPING THE LANDSCAPE OF SECURITY OVERSIGHT PROGRAM 20 YEARS AFTER 9/11
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MONDAY, MARCH 8, 2021
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The RIC session convened via Video Teleconference, at 1:30 p.m. EST, Samuel Lee, Deputy Director, Division of Security Operations, presiding.
PRESENT:
SAMUEL LEE, Deputy Director, Division of Security Operations, NSIR/NRC JEFFERSON CLARK, Team Lead, Security Performance and Evaluation Branch, Division of Security Operations, NSIR/NRC THOMAS CLAY MESSER, Deputy Director, Office of Safeguards and Security Assessments, U.S. Department NEAL R. GROSS COURT REPORTERS AND TRANSCRIBERS 1323 RHODE ISLAND AVE., N.W.
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2 of Energy SCOT SULLIVAN, Senior Security Specialist, Security Oversight and Support Branch, Division of Security Operations, NSIR/NRC ANTHONY CLORE, Senior Project Manager, Nuclear Security
& Incident Preparedness, Nuclear Energy Institute STEVEN ORTH, Chief, Plant Support Branch, Division of Reactor Safety, RII/NRC NEAL R. GROSS COURT REPORTERS AND TRANSCRIBERS 1323 RHODE ISLAND AVE., N.W.
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3 P R O C E E D I N G S (1:30 p.m.)
MR. LEE: Good afternoon to those attending from the Eastern Time Zone, and good morning and good evening to those attending from elsewhere around the continent and the globe. I hope you have been enjoying the 2021 NRC Regulatory Information Conference.
Welcome to Technical Session M6 titled Remapping the Landscape of Security Oversight Program 20 Years After September 11th, 2001. My name is Sam Lee, and I currently serve as Deputy Director of the Division of Security Operations at the NRC's Office of Nuclear Security and Incident Response. And I will be your session chair and moderator for the panel discussion on this topic.
There will be three parts under this umbrella topic, remapping the landscape of security oversight. The first part will be on a brief history and evolution of force-on-force programs covering the USNRC force-on-force history, and the U.S. Department of Energy force-on-force history since 9/11.
Originally we also had on schedule an NEAL R. GROSS COURT REPORTERS AND TRANSCRIBERS 1323 RHODE ISLAND AVE., N.W.
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4 opportunity to hear about the Canadian Nuclear Safety Commission's force-on-force history from Dr. Ali El-Jaby, the Director of Nuclear Security Division of CNSC. But unfortunately, due to an unforeseen circumstance he cannot join us today.
We will shift gears in Part 2 to discuss transformation in security oversight, both currently undergoing and projected in the future, focused on leveraging technology and risk informing in security programs.
Lastly, in Part 3, the panelists will share how security oversight has been conducted during the public health emergency since last year due to COVID-19.
We will then have an opportunity for the session audience to engage in a question and answer session with the panelists. Members of the audience can submit written questions via the virtual environment. And at the Q&A portion of our session, I will pose the questions to the panelists and give them an opportunity to address them.
Before we get started, I would like to introduce the panelists joining me at this virtual table.
First is Mr. Clay Messer, who is Deputy NEAL R. GROSS COURT REPORTERS AND TRANSCRIBERS 1323 RHODE ISLAND AVE., N.W.
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5 Director in the Office of Safeguards and Security Assessments in the U.S. Department of Energy. He will be discussion the evolution of DOE's force-on-force history since 9/11, and will also discuss some of the changes in DOE's force-on-force program.
He is unable to be seen here, and he is at an undisclosed location with limited video capability, and so we will only be hearing his voice.
Next is Mr. AJ Clore, Senior Project Manager in the Nuclear Security and Incident Preparedness Group within the Nuclear Energy Institute.
He will be discussing an industry perspective on future use of technology and risk-informed initiatives related to physical security.
Next is Mr. Steve Orth, Chief of Plant Support Branch in the Division of Reactor Safety in NRC's Region III office. He will be speaking on virtual inspections and other regional changes in response to the COVID environment.
The last two panelists are my colleagues in the Division of Security Operations in NRC's Office of Nuclear Security and Incident Response. They are Scot Sullivan, who is our security, Senior Security Specialist in the Security Oversight and Support NEAL R. GROSS COURT REPORTERS AND TRANSCRIBERS 1323 RHODE ISLAND AVE., N.W.
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6 Branch. He will be addressing the concept of applying reasonable assurance of protection time for providing continued defense against design-basis threat.
And lastly, but not least, Mr. Jefferson Clark, who is pinch hitting for Dave Bradfield who could not join us today. As Dave is, Jeff is also a team leader in the Security Performance Evaluation Branch that is responsible for conducting NRC-led force-on-force inspections.
He will be speaking on the history of NRC force-on-force evaluation since 9/11, and then later on, how force-on-force evolved further during the COVID environment.
So without further ado let's get started with Part 1 of this panel discussion on history of force-on-force programs. As I mentioned, we will have two panelists to address this topic. First up is Mr.
Jefferson Clark of NRC to speak on the evolution of NRC force-on-force.
Jeff, you have the mike.
MR. CLARK: Thanks, Sam. So, to talk about the present, I really need to just take a minute and talk about the past.
The Nuclear Regulatory Commission has NEAL R. GROSS COURT REPORTERS AND TRANSCRIBERS 1323 RHODE ISLAND AVE., N.W.
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7 conducted performance=based inspections through the use of force-on-force exercises at the commercial operating nuclear power plants for over 30 years, and for the compliance-based security inspections for over 40.
Back in the 1980s it was known as the Regulatory Effectiveness Review. It was originally developed in 1982. And although the initial focus of the RER program was the Category 1 fuel facilities, it was later developed for the reactor licensees with the focus on the objective of safeguards protection against radiological sabotage.
This program was sunset in May of 1991 when the NRC decided it needed a better program for continued evaluation of the licensing response capability. So in May of 1991, the RER program was replaced by the Operational Safeguards Response evaluation Program, or OSRE.
The major difference between these two programs was the OSRE was performance-based and was more comprehensively focused on security. The goal of the OSRE program was to evaluate a licensee's contingency response capability and the interface between safety and security.
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8 Under the OSRE program, the NRC conducted site visits at all of the operational nuclear power plants to observe force-on-force exercises. These visits were conducted once every eight years, with finally completing in 2000.
So the events of September 11th, 2001, put a halt to the NRC's force-on-force program, and they took a pause and allowed the licensees to implement increased security through the actions that were taken and the orders that were given out to them by the NRC.
For those two years afterward, the NRC spent time researching, evaluating, and redesigning the force-on-force program. In 2002, the NRC conducted expanded tabletop drills, and they were followed by expanded force-on-force exercises in 2003.
At February of 2004, the NRC began a transitional force-on-force program. It incorporated lessons learned from the previous two years but used the characteristics of the new design-basis threat that had been developed because of the actions of September 11th.
And with this revamped force-on-force inspection program it required the licensees to be inspected every three years. And this was in NEAL R. GROSS COURT REPORTERS AND TRANSCRIBERS 1323 RHODE ISLAND AVE., N.W.
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9 accordance with the Energy Policy Act of 2005.
And so starting in 2003, back to 2003, the NRC initiated a pilot program for full force-on-force exercises which expanded the adversary characteristics that were developed because of the threat from 9/11.
And the purpose of the force-on-force exercises were to assess and improve and the as-necessary performance of defense strategies at licensee facilities, and to identify the most effective means of conducting these activities.
Now, these exercises are not on a win or lose paradigm. However, they are used to assess the strategies for continued improvement.
So like I said, in accordance with the NRC order, by 2004 all the nuclear power plants had to be able to meet the requirements of the new design-basis threat. So in 2005 we begin cycle one. Every three years we have a cycle. So cycle one started in 2005.
Some of the instances started in 2005 in this first cycle where the first use of the Multiple-Integrated Laser Engagement System, or MILES.
This is the, as I call it, high tech laser tag to better determine the outcomes of the exercises, the realistic engagement of the adversary and the responder players.
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10 We also developed a credible mock adversary force in this time frame that gave us the ability to wholly assess each of the licensees on a reliable and consistent approach.
The exercises, they began in the owner-controlled area, as the adversaries moved their way up to the first element of detection. And since this program was new and the inspectors were new, we had to develop a general inspection guidance, and we had to implement interim inspector qualifications.
In cycle two we developed an appeal process for licensees when they had concerns about scenarios and adversary actions, and whether or not they were within the confines of the design-basis threat in their capability.
We also developed and implemented formal qualification programs for our inspectors. And we worked with the industry to develop several guidance documents, including implementation of what we called the Executive Lessons Learned Program, that allowed senior leaders to come into the NRC and to talk about lessons learned that they had throughout the elements of their inspection.
In cycle three, which was from 2011 to 3013, NEAL R. GROSS COURT REPORTERS AND TRANSCRIBERS 1323 RHODE ISLAND AVE., N.W.
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11 we developed and incorporated program threshold criteria into our exercise assessments. This was to inform the significance determination process on the significance of the outcome of the exercise.
There was also a change management plan that was developed by NEI at this time frame. There was the evaluated force-on-force exercises and we deemed it acceptable for use in this time frame.
In cycle four, we reduced the number of NRC evaluated FOF exercises from three to two. In the previous exercises, if the licensee did well in the first two exercises, the third exercise could be deemed a training exercise. However, soon we felt that the time was to adapt, and to evolve, and not have this exercise, so we went from three to two.
Most licensees at this time were using it as a training exercise. We expanded and we enhanced the formal exercise critique process. And we added NRC inspections of licensee-conducted annual exercises to the baseline inspection program, which is not related to our NRC-conducted FOF.
In cycle five we changed the notification time for the licensees on these inspections to align with the rest of the inspections scheduled in the ROP.
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12 Prior to this point, licensees were only given 8-week notice of their inspection.
We also reduced the on time for our NRC-provided MILES. We allowed them to use our equipment during their practice exercise before, but because of an aim 2020 effort and a cost savings effort we determined that this was a course to reduce this, since most of the licensees are using some form of MILES equipment. And it's compatible, but not completely the same as the NRC's in its reliability and its consistency.
And the ISDs, they had not had any form of degradation since this happened.
Now, cycle six in 2020 started off really great. We did one force-on-force exercise. And then with the public health emergency of the COVID-19, things changed. And I'm going to talk more about what we did during the public health emergency in our Session 3.
And that is pretty much up to date.
Sam.
MR. LEE: Thank you, Jeff. At this time we will turn to Mr. Clay Messer from Department of Energy to hear about DOE's force-on-force history. Clay.
MR. MESSER: Yes, sir. Thank you, Sam.
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13 So Department of Energy is not dissimilar to NRC. At some point we have -- you're going to see a lot of familiarities with Mr. Clark's presentation.
From the early -- the late '80s to early
'90s, the department has had a composite adversary program where it has applied a adversary element to assess the sites. And we also use an engagement simulation system that also uses the MILES-type gear, as well as some other information to help inform.
The department is a little different in that, for those that are familiar with the Department of Energy, most of our facilities are government-owned and contract operated. So the big changes since 9/11 for Department of Energy has been the design basis threat.
The department -- and I will get into this in another session, Part 2 of the session -- the department manages its risk through a risk management framework as established through compliance performance directives assigned through the deputy secretary of energy.
So since 9/11 the department has had six iterations of a design basis threat or security protection policy which was one of those iterations.
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14 That manages the adversary capabilities list and the numbers of adversaries that the department's contractors must plan and design their protection to.
So accordingly, on the force-on-force exercises that informs both compliance and performance for Department of Energy, our office evaluates the site capability in accordance with where their espoused implementation of those design basis threats are.
With the department's process of using vulnerability analysis and/or security risk assessments there's times that different target locations at a facility can adhere to different DBTs, depending on where their implementation status is.
In many cases it takes three to, three to four years, and sometimes longer, to fully implement a DBT. And with six changes, most recent being in 2016, and then we've had a subsequent change in '20, it sometimes takes the sites a minute or two to catch up.
And they might be operating off two or three different policies, depending on their status So the department evaluates them in accordance with wherever they are accredited to perform.
So much like the NRC, DOE does not evaluate NEAL R. GROSS COURT REPORTERS AND TRANSCRIBERS 1323 RHODE ISLAND AVE., N.W.
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15 against win/loss. That was a change in 2008. Prior to that there was some win/loss evaluation.
The data from the large scale performance test, or force-on-force, as well as limited scope performance tests, are used to analyze and measure a site's ability to perform routine and emergency duties as described in their security site plan and their security incident response plans, as well as how they perform across all topical areas, and that includes program management, personnel security, physical security system, material control accountability, to some extent information security and, obviously, protective force.
One of the largest changes that DOE has done has been since COVID, and especially in my office, the Office of Safeguard and Security Assessments, previously our office developed the scenarios and obtained site federal approval for running those scenarios.
Currently, our office only evaluates the site's ability to develop, perform, and execute the performance of those scenarios in accordance with DOE policy. We no longer develop scenarios. And that is a recent change and, well, actually to be implemented NEAL R. GROSS COURT REPORTERS AND TRANSCRIBERS 1323 RHODE ISLAND AVE., N.W.
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16 at our next appraisal in April. So that's the biggest change, most recent change.
But much like Mr. Clark's presentation, the DOE process is very similar to what is used by Nuclear Regulatory Commission.
Thank you, Sam.
MR. LEE: Thank you, Clay. We will now transition to Part 2 of our discussion. But before we do that, I would like to remind the audience that you can submit written questions via the virtual environment at any time. And if you have questions for Jeff or for Clay, please do so and we will address them, again, at the Q&A portion later.
Now to Part 2. During this portion we will have three panelists addressing the top of transformation in security oversight, specifically about leveraging technology, and risk informing security programs.
First up will be Scot Sullivan of NRC who will address the concept and application of reasonable assurance of protection time.
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17 initiatives.
Lastly, Clay will return with -- pardon me -- to discuss how DOE handles any deviations in force-on-force exercises performance or non-performance in a risk-informed way.
So, with that, let's start with Mr. Scot Sullivan. Scot.
MR. SULLIVAN: Sure. Thank you, Sam.
So you've all heard about the NRC goal of looking for transformational opportunities. Today I will be talking about one of those opportunities where the Office of Nuclear Security in their response developed guidance associated with licensee physical protection programs, and how sites consider all available assets when designing their physical protection program.
The topic I'll be covering in this segment is the development of the reasonable assurance of protection time, commonly referred to as the RAPT.
In November of 2020, the NRC issued a revision to Regulatory Guide 5.76, which is physical protection programs at nuclear power reactors guidance document. This revision included implementation guidance on the RAPT.
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18 By developing the RAPT concept, the NRC took one more step forward in providing realism in our oversight program, while using risk information to ensure licensee programs are designed and developed to ensure protection of risk-important systems.
More insights into the development of (audio interference) SECY 17-0100 where the Commission directed the staff to develop recommendations for providing credit for a broader set of operator actions, including the use of flex equipment, and providing credit for response by local, state, and federal law enforcement in our security inspection program.
The Commission also directed that staff should take into consideration that the NRC has already codified its recognition of the reality that in an actual emergency federal, state, and local government officials will exercise their best efforts to protect the health and safety of the public.
Understanding why the NRC undertook this effort, there are a few other items I want you to understand about the Nuclear Regulatory Commission's security regulations regarding the RAPT. They didn't change.
They continue to require nuclear power plan NEAL R. GROSS COURT REPORTERS AND TRANSCRIBERS 1323 RHODE ISLAND AVE., N.W.
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19 licensees to establish physical protection programs at their sites that are capable of defending against a design-basis threat of radiological sabotage without reliance on support from federal, state, or local law enforcement agencies.
Although the NRC's regulations require licensees to document the capabilities of available law enforcement responders, and to maintain agreements with law enforcement agencies to the extent practicable, licensees do not recognize this response as an essential contributor to the site's defense against the DBT. They are ultimately responsible for site defense.
The NRC is confident that law enforcement agencies near nuclear power plant sites can benefit the site's security and, in real emergency, law enforcement agencies will honor their commitments to take appropriate action to protect public health and safety in the environment.
That said, let's get into the RAPT.
It reflects the staff's determination that a licensee's current physical protection program meets the general performance objective of 10 CFR 7355(b)(1),
which is to provide reasonable assurance that NEAL R. GROSS COURT REPORTERS AND TRANSCRIBERS 1323 RHODE ISLAND AVE., N.W.
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20 activities involving special nuclear material are not inimical to the common defense and security, and do not constitute an unreasonable risk to the public health and safety.
A licensee may demonstrate reasonable assurance by having a physical protection program that allows the site to independently defend against the DBT for a minimum of 8 hours9.259259e-5 days <br />0.00222 hours <br />1.322751e-5 weeks <br />3.044e-6 months <br /> from ignition of an attack.
This 8-hour time is referred to as the reasonable assurance of protection time, or RAPT.
The RAPT provides reasonable assurance through a framework that considers how the many existing layers for defense, safety, and security work together for protecting a site.
After the RAPT, there is a reduced risk profile that licensees can reasonably expect to have additional resources available, such as law enforcement and/or recall of off-duty personnel. Those groups will provide support for the licensee to continue to defend against the DBT.
Although a licensee remains bound by regulation to continue to protect its site following the RAPT, the staff recognizes that its response to an attack will likely be augmented with these additional NEAL R. GROSS COURT REPORTERS AND TRANSCRIBERS 1323 RHODE ISLAND AVE., N.W.
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21 resources. The RAPT will enable licensees to refine their protection strategies in a risk-informed manner.
While implementation of the RAPT may require some revisits -- excuse me -- revisions to site documentation, it does not require any additional commitments beyond the regulatory, current regulatory framework.
The NRC believes this process provides for a realistic approach towards the protection of nuclear power reactors but, most importantly, allows licensees to focus their efforts and protection programs on the most risk-significant elements at their respective site.
So with that, if you have questions, please provide them so we can get to those in our answer, question/answer segment. Sam.
MR. LEE: Thank you, Scot. We will now turn to AJ Clore of NEI to share with us industry perspective on future use of technology and risk-informed initiative. AJ.
MR. CLORE: Great. Thank you, Sam. As Sam alluded to, good afternoon, everybody, my name is AJ Clore, and I am a senior project manager at the Nuclear Energy Institute. Primarily, my focus is on NEAL R. GROSS COURT REPORTERS AND TRANSCRIBERS 1323 RHODE ISLAND AVE., N.W.
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22 physical security. And today I am going to focus on two subject areas.
Subject area one is mainly going to be on new technology and innovation and what the future looks like in physical security.
And subject two I'll talk a little about risk-informing some of the security projects we have.
But a term we would like to use more on the industry side is performance-based things. And I will touch upon that as well in a little bit.
But first and foremost let's talk about technology. Technology applicable to our physical security systems continues to evolve year after year and, therefore, presents an opportunity for our physical security programs to evolve as well. At NEI, one of our strategic overview items for 2021 is innovation.
And we have three specific areas we are going to focus on in 2021. The first one, as I mentioned, is innovation.
Another area talks about performance-basing physical security that I will talk about in a little bit.
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23 Jeff Clark hit on in his first session and we'll cover in the third session.
These priorities are presented to the Security Working Group which, for background, is our governing body of physical security, access to authorization, and cyber security at NEI. This group is comprised of security directors from the fleet, or security managers at specific sites at all NEI member companies.
This committee is chaired by our CNO with our vice chair CNO from the industry as well. And this group meets quarterly and we discuss projects, priorities, and how to move forward as an industry, and what projects we want to pursue, what engagement level we have with the regulators. And we, obviously, build task forces that come out of this to work on a specific project.
One of those task forces that came about late last year was new technology and innovation. And that's what I'm going to talk about here now.
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24 in place. Computer modeling I would like to use as one example.
I use modeling software as an example because I believe over the last five years that has been the most paramount technology that has came up through the industry, but also shows the largest benefit to the nuclear fleet. Modeling software as of right now, I believe, is used in about 75 percent of the nuclear operating fleet. This software has enabled licensees to review and challenge their security plans and strategies in a way not seen before.
This has also allowed licensees to make modifications to their programs and strengthen their overall strategies.
I will caveat by saying this: the technologies I am about to mention, as well as modeling which I just discussed, that the Security Working Group focuses on we do ask ourselves the question each time is: Is this equipment being utilized elsewhere?
Where can we learn from other organizations, other agencies, other critical infrastructure, of technology, of innovation in a way to help prepare ourselves to work on this project?
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25 past experiences. We learn from operational experiences. And I think Jeff hit on that very well in the force-on-force aspect and how much force-on-force is changing. And we're taking the same approach here for innovation and technology.
So the computer modeling, as well as a handful of others I'm going to mention here, at a high level are all technology innovation areas that we have found are being utilized at other federal agencies of regulated sites. This includes the Department of Energy. This also includes law enforcement using these, and even the military to some extent.
And as I mentioned, these are at a very high level. We are going to look at these list year.
But from a technical standpoint I am not going to get into too many details just because there's so much unknown when it comes to them.
The first one being remote-operated weapons. That is a program that we as the industry have utilized before. There has been remote-operated weapons going back, I believe, 10, 11 years now some licensees utilized them. And obviously, as technology grows, as we can, you know, look across the board at anything, remote-operated weapons have come a long way.
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26 And that is one area we want to look at again here in 2021.
The second area is advanced intrusion protection. This includes a litany of different items, including thermal imaging, a laser grid of intrusion protection, enhanced camera capturing, and motion protection.
And then lastly, utilization of vehicles for surveillance. This includes autonomous vehicles as well as the very popular unmanned aircraft systems.
These areas are all areas that industry's security technology team will evaluate over the course of 2021 and discuss lessons learned to promote use at other sites.
And what I mean by that is through our Security Working Group and sharing OE, we have found that some licensees out there aren't taking advantage of these technologies. And what we'd like to do is build a more broader working group/task force to allow each other, their peers, to share this information with each other, learn about it, and see how it approaches the broader industry.
And I use computer modeling as that example. It started at one site. And as I mentioned, NEAL R. GROSS COURT REPORTERS AND TRANSCRIBERS 1323 RHODE ISLAND AVE., N.W.
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27 it's at about 75 percent of the industry right now.
And the nuclear fleet typically operates that way.
One site or licensee takes advantage of a technology and innovation, it's nice to hear what hurdles they had to go through before others consider it. And that's how kind of the wave operates with programs like that, with technology and innovation.
Also, I don't want to forget, too, in 2019 we began partnering with the light water reactor sustainability program. You all have heard of that, I'm sure. Or maybe you know it better as the LWRS.
And this program includes individuals from both Sandia and Idaho National Labs who are engaged with nuclear facilities in an effort to better understand what technologies are needed, the potential or inherent benefits, and consideration for licensee deployment throughout the fleet.
The broader audience of this working group includes various suppliers from across the industry providing a wide range of services, as well as NRC and NEI.
That covers it for technology. But what I would like to do is hit on two subject areas in regards to performance-basing physical security.
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28 You know, we have three priorities for 2021 that I laid out at the beginning of this presentation.
Scot Sullivan hit on one, the reasonable assurance of protection time, so I'm not going to spend any more time on that.
But two of the areas we are looking at are adversary time lines and unattended openings. And I will kind of give you the background a little bit of why we're pursuing both of these.
For adversary time lines, they are the principal catalyst for the development of plant protective strategies, and are based on two solitary factors, one of those being the travel speed for how fast the design basis threat adversary can sprint without a break, and; two, the breaching time for passage of delay barriers, i.e., time to cut a fence, breach a door, et cetera.
Allowances for adversary interruptions due to response force interdiction was only recently accounted for in Regulatory Guide 5.81, which talks about target set development. And at this time there is no approved methodology that exists. So that's why we have taken the industry approach to look at performance basing this to see what modifications, what NEAL R. GROSS COURT REPORTERS AND TRANSCRIBERS 1323 RHODE ISLAND AVE., N.W.
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29 realism and aspects we can add to this program and this project that, as I mentioned, could drastically change how programs at a nuclear site are set up to enhance them and even make them stronger.
And as I mentioned, we held off on this for a very long time because Regulatory Guide 5.81 kind of impeded some aspects of that. But recent revisions to that document, also as Jeff alluded to in Reg. Guide 5.76, have allowed us to open kind of doors to look at different areas of physical security and performance base them.
In regards to unattended openings, the current guidance and guidelines on that for determining the minimum passable opening size are based on historical research. And quite frankly, that's it.
As I mentioned in the beginning, a lot of these items, and as Jeff listed in force-on-force, we're looking at moving forward. We're changing, looking into the future, and updating historical data, historical guidance, and so forth. And that's the purpose of both of these projects.
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30 to chat one-on-one with, I'm happy to answer a phone call or email. My contact information is provided and I'm happy to help.
With that, Sam, back to you.
MR. LEE: Thank you, AJ. And that concludes Part 2 of our discussion. And now we will shift to the last category of discussion, that is how security oversight activities were conducted during the public health emergency under the COVID environment. We will start with Jeff Clark to speak to how force-on-force was changed during the public health emergency.
And then Steve Orth from NRC's Region III Office will speak to how security oversight inspections were performed during the COVID environment as well.
And time permitting, we will have other panelists to share their perspectives and thoughts.
Jeff, please go ahead with your portion.
(Pause.)
MR. LEE: Jeff, is your mike on?
MR. CLARK: There we go. Sorry about that.
MR. LEE: That's okay.
MR. CLARK: We started out really good.
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31 We had one normal force-on-force inspection. But it went downhill right after that.
We put the force-on-force inspections initially on hold. We pushed them more toward the end of the year as we looked how the public health emergency was playing out. And we eventually came up with a modified inspection procedure, Inspection Procedure 92707.
So what this did was it allowed us to go out to the sites under all of the precautions of the COVID, taking into account any site conditions that were going on. This was state by state at the time, you know, what conditions for travel. Were there hotels available? You know, was there the ability for the inspectors to be able to eat at restaurants?
So there were a multitude of conditions that were looked at for the inspectors going out to inspect the sites.
So the 92707 on the first week of inspection activity looked pretty much like the normal force-on-force. And it being only a one-week inspection pretty much culminated everything together.
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32 a protective strategy briefing. We did tabletop drills. And we had previously looked at information that the licensee had sent in to the NRC for us to review remotely or under our safeguard system.
What we did was we eliminated some of the in-person briefing, or we reduced the people in the room to the absolute minimum for the briefing. We conducted the entrance meetings remotely. And we had our other meetings with maybe one or two representatives.
So the NRC still built scenarios. And we took that scenario and we cut it up into pieces. And it allowed us to do performance testing on a limited number of responses, one, two, maybe three at a time, looking at a different element, a different layer of defense in the strategy itself, and not looking at the holistic assessment of the protective strategy like we would in a normal force-on-force inspection.
So because we did that, we didn't enter these, they didn't meet the stratification of completing the baseline, or they were not able to meet our requirement for the Energy Policy Act. But gave us the ability to look at individual responder actions in their second, third layer of defense, in the key NEAL R. GROSS COURT REPORTERS AND TRANSCRIBERS 1323 RHODE ISLAND AVE., N.W.
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33 elements of these, these strategies.
Like I said, we talked about, you know, repeatedly all the conditions they modified. We moved inspections back and forth and so we could satisfy.
And we were able to get all the inspections in with the exception of one. And one site just had conditions that we could not, we could not make it to, and we had to push it to this year.
So starting this year in 2021, we adapted what we learned from the 92707 and we were able to structure that. And also, with some of the relaxation of the restrictions that were with COVID, we were able to go out and modify our normal inspection procedure for force-on-force, our Inspection Procedure 71130.03.
And we were able to have an addendum to it with COVID mitigation that would allow us to incorporate the appropriate amount of people that would allow the NRC inspectors to look at the strategy in its entirety and be able to make a reasonable assessment that it is effective or ineffective. And we were able to use it to complete baseline. And we're using it to satisfy the requirements of the Energy Policy Act.
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34 then after the scenario is developed and presented to the licensee, that the licensee could not meet it due to hardship criteria, they can't meet it with the number of personnel because of local restrictions, or other conditions, then we would exit out to the 92707 procedure that we modified a little bit, so that we can incorporate more samples if we're not seeing the level of performance that we need.
And at the current place we are now is we are conducting the 71130.03 inspections with the modification. And this is what our plan is to do for the rest of this year.
Sam.
MR. LEE: Thank you, Jeff. We will now turn to Steve Orth of NRC's Region III Office to provide regional perspective on inspections conducted during the COVID environment, virtual inspections as well as any other changes that the regions made.
Steve.
MR. ORTH: Thank you, Sam. Good afternoon. I'm the NRC Region III branch chief responsible for security inspections of Region III operating power plants, reactor decommissioning sites, and independent fuel storage installations, otherwise NEAL R. GROSS COURT REPORTERS AND TRANSCRIBERS 1323 RHODE ISLAND AVE., N.W.
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35 known as ISFSIs.
As part of our routine oversight function we perform a number of baseline inspections at each of our operating reactor sites. The inspections evaluate a facility's security program, including access authorization, protective strategy, access controls, equipment maintenance, training, and several other areas that we have determined to be important to safety.
Now, we normally schedule a week-long onsite inspection. And our security inspectors review procedures and documents, interview facility staff, and observe important activities in the areas that we're inspecting. Our inspections provide a key aspect of our regulatory role to ensure adequate protection of public health and safety.
In response to the public health emergency we curtailed a great deal of our onsite security inspection activity. While minimizing the potential of exposing our staff to the virus, and the potential to bring that virus to our regulated facilities, we looked for alternate means that we could perform our oversight functions.
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36 inspection activities that could be performed remotely.
Our regional inspectors and our program office staff looked carefully at our inspection requirements and identified those that could reasonably be achieved using remote inspection approach.
The remote activities typically included requesting access to plant records and documents that we would normally have reviewed during the onsite inspections. From their homes and our offices, our inspectors are performing reviews of plant documents, corrective action records, and logs, and are conducting interviews with members of the site security staff.
Our remote review of the inspection areas balance the need to protect personnel during the public health emergency, while insuring the appropriate level of inspection is performed. Even during panic when areas of the country were closed, we would still respond to significant site events.
Now, we clearly recognized that the remote approach alone was not sufficient to meet all of our inspection requirements. As part of the country reopened to travel, each region formed a team to monitor COVID-19 conditions, both at a regulated facility, and in the nearby communities where our inspectors would NEAL R. GROSS COURT REPORTERS AND TRANSCRIBERS 1323 RHODE ISLAND AVE., N.W.
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37 routinely travel, and by identifying those areas are reasonably safe for our inspectors.
In our region, that team meets twice a week to monitor the sometimes very dynamic conditions. We also share that information with other NRC offices, including our force-on-force inspectors.
Now, when sites are cleared and we believe it's safe to travel, we still continue some aspects of the remote inspection to ensure that we're taking reasonable actions to mitigate the potential spread of the virus.
In some cases we have also allowed onsite inspection activities to uncleared areas, but we have reduced the number of our inspectors and limited the onsite time to balance our inspection needs with the risks associated with the public health emergency.
If travel doesn't seem reasonable based on conditions, we've worked with the facilities to reschedule our onsite inspections. Even if some areas or facilities do not have favorable conditions, again we will still respond to significant security issues and events.
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38 observe the day-to-day operations of the facilities and maintain an eye on the physical security features to identify any significant changes to the security program or onsite performance.
Our security inspectors communicate frequently with the resident inspectors so that we maintain an awareness of any changes that may be occurring. Even under non-public health emergency conditions we rely on the resident inspectors to provide us with the real-time indications of the issues that may need to be evaluated by our security inspectors.
In summary, we instituted measures that managed the risks of the public health emergency and our oversight responsibilities. While using remote inspection techniques combined with our onsite presence, we continued to maintain assurance of adequate protection of public health and safety.
We recognize the importance of a strong onsite inspection presence to provide a performance-based assessment of licensee programs and activities. And we continue to focus on the need for our security inspectors and our resident inspectors to provide that onsite presence.
Thank you, Sam. Back to you.
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39 MR. LEE: Thank you, Steve. Thank you, Jeff, Steve, and AJ for all your perspectives.
I would like to open up the mike at this time to other panelists who would like to speak to this issue about security oversight performed during the public health emergency.
MR. CLORE: Hey, Sam, this is AJ. You know, one thing I do want to add to everything Steve and Jeff discussed was, you know, I think last year was a unique year. And I think the one positive we took away from the industry side and the regulator was the flexibility aspect. And I think we have learned that we kept what was paramount in front of our face was the health and safety of the public. And that was never challenged at all.
And I think moving forward we can take lessons learned from the past year and use those as, you know, to evolve what we talked about throughout the duration of this panel, whether it's force-on-force, or risk informing, or performance-basing, what have you, technology.
I think COVID, one of the unfortunate positives of COVID is it's showing us how to operate a little bit differently. And I think in 2020 we were NEAL R. GROSS COURT REPORTERS AND TRANSCRIBERS 1323 RHODE ISLAND AVE., N.W.
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40 successful as an industry, but also from the regulator's standpoint as well. And that's from an industry perspective.
MR. LEE: Thank you, AJ. Appreciate that.
Anyone else?
MR. SULLIVAN: If I could, Sam. You know, we're still learning. Right? You know, so, a lot of our programs, how we implemented, you know, you heard Steve talk or, you know, kind of change, we really tried to be agile through this, move into it with a lot of flexibilities. And we're still learning.
So you know, kind of looking back could we -- could I give you a specific assessment and say at this point that these were the definitive things that we learned coming out of 2020, moving into 2021?
I'm not sure we're there yet. There's still information that we want to gather as we move forward.
And you know, those things will be things that we evaluate.
I know we have a question later on that was asked: Are there lessons learned? We're still looking at that. There are some things that we learned.
You know, there are some inspections that we conducted remotely. We're really trying to evaluate those.
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41 Yeah, we were able to do them remotely, but were they as effective as we want them to be?
Or, are there changes that we can make to the inspection effort to make them more effective as we move forward?
You know, that's one of the big things that we're looking at right now.
Thanks, Sam.
MR. LEE: Okay. Thank you, Scot. I think we're done with Part 3 of the discussion. And so at this point we would like to transition into a question and answer session. We have a few questions in the pipeline. And I will read the question, and repeat it, and direct the questions to the individual panelists who would be able to address them.
So the first question -- and this may be a question for you, Scot and others that would like to chime in -- for NRC much has changed in the United States since 9/11 regarding homeland defense, not the least of which are the creation of Department of Homeland Security and the establishment of the Office of Director of National Intelligence.
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42 security framework?
MR. SULLIVAN: Yeah. So one of the things that we look at, we have an Intelligence Threat Liaison Assessment Branch. They partner with our different federal agencies to provide insights. They evaluate the DBT for changes.
You know, obviously, as federal programs increase, you know, there could be a likelihood that, you know, the DBT, capabilities of the DBT are limited or changed. If those things are assessed and evaluated, we look at that in our internal programs associated with the regulations. And we can make adjustments through those means. You know, we do that on an annual basis.
Right now I think we are seeing some of the risk tolerances that, you know, we have now, I think because of those, you know, the evolution of security in the industry -- or in the country.
MR. LEE: Thank you, Scot. The next question is for NRC as well. How important is the NRC force-on-force program in assessing the licensees' capabilities to defend against a terrorist attack?
Will there be any significant changes in how the NRC assesses licensees in the near future?
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43 I'll repeat the question.
How important is the NRC force-on-force program in assessing the licensees' capabilities to defend against a terrorist attack? Will there be any significant changes in how the NRC assesses licensees in the near future?
MR. SULLIVAN: I can answer that one, too, Sam. So, you know, we have a suite of inspection procedures that we use to verify compliance against.
They are comprised of compliance-based and performance-based inspection.
Force-on-force is one of those procedures, specifically one out of about 12. And so it is an integral part but it's not the only part. You know, the other, you know, nine or so procedures that make up the baseline inspection program are definitely complemented with your force-on-force inspection.
You know, the one thing that I think force-on-force does where, you know, the other procedures don't, is they don't look at every part of the program through implementation of a performance-based exercise. And that's what we really get with the force-on-force inspection. We are able to look at, you know, every component and develop a NEAL R. GROSS COURT REPORTERS AND TRANSCRIBERS 1323 RHODE ISLAND AVE., N.W.
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44 scenario where we can test each of those elements of a licensee's strategy.
So it's an important part of our inspection program. But if I were to rank it, rank that, yeah, I don't know that I'd rank it any higher than I would any other, you know, aspect of the program.
MR. LEE: Jeff, you may want to add?
MR. CLARK: I would disagree with you that, you know, the force-on-force program is, you know, just a little bit more important than the others but only because I'm biased easily there.
(Laughter.)
MR. CLARK: And but, so, Scot, you are right is that the force-on-force is performance-based, so it is the culmination of, you know, several of the other inspection procedures: training, protective strategy, you know, all those that go together, you know, are finely sewn together as they interweave into the implementation of the protective strategy. So I would agree with you on that.
And I think the other part of the question is are there changes, is it near-term changes in the future? Significant changes. Significant changes how we assess the licensees in the near future.
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45 And as far as this cycle is concerned, we don't have any changes as far as how we're assessing the licensees.
And Scot, if you have any more to caveat on that?
MR. SULLIVAN: Yeah. So there is a commission at this -- you know, at the moment. We presented it, I don't know, a little over a year or so ago. And you know, that had some recommendations for change.
Obviously, you know, last year was kind of interesting with, you know, the public health emergency so, you know, we haven't got an affirmation on that. We have implemented changes or altered the programs slightly just because of the public health emergency. You know, we're kind of still in the, I guess, the throes of that. As we come out of that, any significant changes beyond what's been proposed at this point, I don't see any in the foreseeable future.
MR. ORTH: Now, if I could just throw out a counterpoint to Jeff from the regional perspective that there are several elements of the baseline inspection program that, you know, essentially fit within the structure and complement the force-on-force.
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46 So we won't go into a debate today here, but I just, you know, I'd be remiss if I didn't mention those.
And then in terms of (audio interference) duty fitness. So there's a whole suite. But we'll hold the debate till later.
MR. LEE: Thank you, Steve. I'm getting a little bit of indication that there may be an internet issue. I don't know if others are experiencing that at this time, but we'll proceed.
Becca, I may need you to step in here if this persists.
But thank you, Steve. And I appreciate that. And this is the beauty of the panel discussion, too, to be able to listen to one another's perspective and to offer perhaps variations in our opinions.
The next question actually is for Clay Messer of DOE.
Clay, the question is what was the motivation and intent behind the recent change away from the headquarter selection of the scenarios?
You know, how does this impact DOE's ability to conduct independent evaluation of site contingency response?
Clay, can you speak to that question?
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47 MR. MESSER: Yes, sir. I appreciate the question. So, much like here and our NRC counterparts, we've also become -- COVID has given us an opportunity to be a little more introspective and really evaluate our process.
And I won't make this as protracted as it may seem, but about two years ago we, our office, had historically done physical protection systems. And we would use our team of assessors and SMEs to actually do penetration testing and other types of testing of physical security systems.
And during that time we, we did find issues and weaknesses, but we also recognized that we were missing an opportunity to evaluate our contractor organization and the local federal oversight organizations and how they conduct their assessments, their surveys, their self-assessment, their mandated performance testing because we were doing it.
And it resulted in an enormous amount of data, both we were seeing strengths that we were able to identify best practices that we were missing and put those out to the balance of the complex, as well as we were seeing weaknesses in some organizations' ability to conduct the performance testing because we NEAL R. GROSS COURT REPORTERS AND TRANSCRIBERS 1323 RHODE ISLAND AVE., N.W.
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48 were doing it.
Hence, about March 16th of last year COVID happened. And while we had recognized that we had other areas where we were actually performing the work, i.e.,
scenario development, rather than assessing the organizations' ability to conduct that work, COVID gave us an opportunity to stand down and re-look at our process, and critically look at what we were doing that was effective, as well as identifying areas that may be not as effective as we would have liked.
One of the areas that quickly came out was our force-on-force evaluation process, specifically, the fact that we were creating the scenarios. We have some great staff in our organization and they are very effective at creating scenarios and following the DOE process to do so. However, again, we were missing the opportunity to evaluate the site's capability.
And that's really our goal is how well is the organization that's being paid to do the work and provide the oversight of the work executing that mixture?
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49 inability to execute that performance test, as we all know, they are very expensive, they take time, we are not going to let them fail. However, we will validate the information. More likely will become some sort of discrepancy in our report. We will work with the local site entity, both contractor and federal, to ensure that they're successful to execute that testing while we're able to evaluate it.
But if they have an inability to perform, we're going to work with the organization and ensure that we're able, also able to execute that performance data and -- or obtain the performance data and inform our report. But I appreciate the question. Thank you, Sam.
MR. LEE: Thank you, Clay. I'm going to switch gears. A question for AJ.
AJ, if adversary time lines are the fundamental foundation of developing a protective strategy, then wouldn't a conservative approach to the development of adversary time lines be a better approach to ensure a licensee can implement their strategies?
So AJ, can you speak to that, that particular question?
MR. CLORE: Yeah, sure. Thank you, Sam.
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50 And that's a good question. And that's kind of the purpose of the performance basing. We're going to learn a lot about what our sites can do even more, I guess you could say. And I hate to use the caveat that every site is different, but they all are different.
And I think adversary time lines may look a little bit different every site based on what some licensees have in play at their sites already.
One positive thing that we're looking at, too, is this allows sites, based on what they learn from conducting time lines, to look at their overall strategies, and maybe even enhance them further. What I mean by that, that maybe they realize that by having this data at the ready they can now, you know, justify constructing an elevated BRE in a different spot, or moving different positions around to enhance their strategy even further.
And what we realized is there's a lot of subject areas in security that, historically, which seem to be the focus of this panel, going through different updates, different revisions, performance-basing, risk informing, what have you.
They allow you to change and evolve your strategies overall. And that's kind of the purpose of the NEAL R. GROSS COURT REPORTERS AND TRANSCRIBERS 1323 RHODE ISLAND AVE., N.W.
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51 adversary time lines.
MR. LEE: Thank you, AJ. Appreciate that response.
MR. SULLIVAN: Yeah, if I could just touch base on AJ's response, one of the interesting pieces that we have, you know, we did conduct performance evaluation inspections, you know, through SPEV. So yeah, we sit back and, you know, are interested to see what comes out of this. You know, because obviously once industry, as they go to implement a change like that to the design of their strategy, you know, we'll be assessing it with Jeff Clark's group, you know, through performance tests.
So whatever change they make, we'll inspect it and verify that the site can continue to, you know, defend against the DBT.
MR. LEE: Okay. Thanks, Scot. I am still getting some feedback on internet challenges for me, but I'll continue here.
So we had a question about whether this session is being recorded. And the answer I received was that, yes, this session is being recorded, so that will be made available in a future time.
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52 look to you first and then maybe then to Jeff. And that is are there -- and you referred to this question, I think, and it's partially been addressed by the talks given regarding, you know, how we did force-on-force during the, during the PHE environment.
So the question is, are there any learnings from the PHE, public health emergency, in either NRC or NRC licensing programs, that NRC will carry forward into the post-COVID era?
MR. CLARK: Scot, if you want, I can take it. I can take this first.
MR. SULLIVAN: Go ahead.
MR. CLARK: He alluded to it a little bit earlier that we are continuing to look at this and to try to take in in-depth lessons learned for, you know, each step we've made in this public health emergency to see if the measures that we are taking place now are something that are beneficial, you know, in the future.
You know, is this the opportunity for us to break the paradigm and be, you know, transformative to still be able to be effective but be a more useful time?
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53 is the mass briefings that we have that take place during the force-on-force exercise where we get all of the players together and, you know, we have these briefings.
So we weren't able to do that. We're not able to that in the current, you know, environment, you know, most licensees. And we're transitioning that into a computer-based learning.
So one of the messages when we go out for a force-on-force exercise is to make sure that it can be controlled and it's conducted safely. So I think as long as we can look at that -- and, again, we're evaluating. It's not saying that it's going to be something long term. If we can look at that and look at the new measures to make sure that we still have the appropriate level of control and the exercise is conducted safely, that this may be something that we could adapt.
And the benefit there was it would be a time saving in the time of day that, you know, we're spent onsite for the length of the exercise, where these briefings could be done on a computer, they could be done ahead of time, as long as it's accounted for and as long as it's, you know, it basically, you know, meets our requirements that, you know, the exercise is still NEAL R. GROSS COURT REPORTERS AND TRANSCRIBERS 1323 RHODE ISLAND AVE., N.W.
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54 safe.
And you know, some of the other measures, too, as far as the number of personnel. Briefings like the entrance briefing being conducted personally. If you have members of the hierarchy, the site management that's remote, you know, they have the opportunity to be able to dial in instead of traveling to the site.
So there's, you know, the benefits of cost savings there but, you know, it's also the ability for us to conduct our inspections and try to conduct them more efficiently.
MR. SULLIVAN: Yeah. So I've seen some of the same things that Jeff's talking about. And one of the regional inspection efforts where, you know, some of the briefings were computer-based CBT training instead of an in-person brief. And specifically, this was a "mows" briefing so it's something, you know, site personnel use on a regular basis.
So you know, that was something different.
So that, that exercise they went from, like, an 8-hour day to -- and these are licensee-conducted exercises that we evaluate -- went from an 8-hour day just for that briefing, you know, down to 6.
There were some other things that we saw NEAL R. GROSS COURT REPORTERS AND TRANSCRIBERS 1323 RHODE ISLAND AVE., N.W.
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55 that, you know, I think will be included in licensee programs, how they implement that, which obviously will affect our, you know, time onsite. If it's, you know, training that we can review that's computer-based, you know, we can look at that and make that same evaluation as an in-person briefing or if someone's giving the briefing themselves.
Some of the other things I kind of alluded to that I think it's still early in the game to say that we'll definitely incorporate, you know, changes in the inspection program. I think there's going to be areas that, you know, maybe we can be more efficient.
But again, it's a fine line between being more efficient and less effect. And that's what we need to take a look at. Just because we can do it remotely, does it give us the same opportunities to make the assessment that we need to verify compliance.
You know, we've got working groups that are, you know, beginning over the next, you know, several months that will be assessing exactly that.
AJ, was there something maybe on your side that you wanted to talk about, something maybe you've seen that -- and I think this question also went to licensees.
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56 MR. CLORE: No, Scott. I don't have anything to add. I think you and Jeff put it adequately. I'm in agreement with everything you said.
MR. LEE: Okay, great. The next question, AJ, since you're on why don't I go to you. And that is you mentioned software modeling in your presentation. Is there any consideration on using JCATs-type software to validate some of the security plans or some of the adversary time line modeling?
MR. CLORE: Yeah. Thanks, Sam. That's another great question. You know, where we're at right now is really no technology is off the table. I'd like to, you know, state it that way.
What I do want to add, you know, from the JCATs standpoint or computer modeling overall is I want to state that that's just a tool. You know, licensees are using computer modeling to look at what you can do, look at performance, you know, look at where maybe they have, you know, where they can make areas stronger potentially.
However, computer modeling is just a tool.
You know, that is a tool to help support a potential security plan change. However, where, you know, I think the rubber meets the road here is, obviously NEAL R. GROSS COURT REPORTERS AND TRANSCRIBERS 1323 RHODE ISLAND AVE., N.W.
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57 drills and exercises, you know, is getting people out there performance-basing, what's the modeling show you.
You know, as an example, a licensee can run hundreds of thousands of scenarios through the computer modeling software, and I think what that does is it helps narrow down areas where maybe they want to focus on. And maybe using drill and exercise data from previous force-on-forces or other inspections, they can look at, okay, well, let's run this scenario through modeling and see what it looks like. And then let's performance-base it with drills and exercises.
And at that point a site can make a determination that maybe we can make a security plan change. And I think to go back to what Scot said earlier: all of that is subject to NRC review as well.
So, modeling, yes.
To go back to your original question, Sam, JCATs, all technology is on the table as we start to really look at it this year from an innovation standpoint. But from a modeling standpoint I do want to reiterate that that is just a tool to support our licensees conducting their drills and exercises to make any security changes.
MR. LEE: Thanks, AJ. Appreciate that.
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58 I think there was a little bit of buffering there but I think you addressed it at the end there.
The next question is for Clay. Clay, a simple question. Do you think the DOE force-on-force exercises are more effective without the win/lose determination? And if so, why?
MR. MESSER: Yeah. I appreciate that question as well, Sam.
So yes, the performance tests, the FOF activities being win/loss are, depending on how many evolutions are done during a night or over two nights, depending on the scope of that effort, are exactly that, they are one, two, maybe three, four data points.
So taking that as a win/loss, taking that off the table has been much more effective for us.
And taking that data and overlaying it with the compliance and other performance data that's achieved during a appraisal activity that includes LSPT data as well as other testing has proved much more beneficial and more effective for us.
Much like some of the other questions, the effectiveness of FOF, they're invaluable to see how the command and control and execution of the system works. However, at least in most of our sites we, it's NEAL R. GROSS COURT REPORTERS AND TRANSCRIBERS 1323 RHODE ISLAND AVE., N.W.
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59 a pretty plain playing field. We remove a lot of the operational aspects and we put bad guy against blue guy and we get the results. Very beneficial, but taking that as a win/loss is inaccurate. And overlaying it with the data has been much more effective for us.
MR. LEE: The next question is a little long, so I'll try to get to it. And it's for NRC.
Is this really the right time for the NRC to give more credit to local enforcement agency response for protection against radiological sabotage?
You know, recently there have been questions about the LLEA being infiltrated by extremist groups perhaps. How can the NRC ensure that the law enforcement agencies, which are not covered because of access authorization requirements to be appropriately vetted for the presence of insiders who may seek to assist in terrorist attacks?
Any thoughts that, Scot, you might want to share on that one?
MR. SULLIVAN: So one of the things, you know, that in the presentation I provided was about the RAPT. And that was about, you know, liaison with licensees and understanding that there is going to be a response, some type of response from law enforcement NEAL R. GROSS COURT REPORTERS AND TRANSCRIBERS 1323 RHODE ISLAND AVE., N.W.
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60 in the event there's a terrorist attack.
One of the key elements that I really tried to emphasize in that discussion is that the licensee is still ultimately responsible for site protection.
What the RAPT does is recognize that at some point there are other elements that will come into play.
One of those is as an event, you know, takes place, licensee capabilities, whether it's law enforcement that are coming in, or whether it's off duty security personnel, or off duty personnel, licensing capability will increase, while, you know, the DBT adversary, you know, they'll expend resources, it's likely to decrease.
So the key element in the RAPT is that we're not giving more credit for law enforcement. You know, the licensee is still responsible, but we understand and we want the licensees to work with their law enforcement group to really know what that response will look like and be able to take credit for that as they design their physical protection program.
I think another key element is, you know, we don't regulate law enforcement, nor background checks for law enforcement. Obviously, the things that we are seeing in the media today, I'm sure that is making NEAL R. GROSS COURT REPORTERS AND TRANSCRIBERS 1323 RHODE ISLAND AVE., N.W.
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61 changes, you know, for different law enforcement agencies and groups. Maybe that, or put their people through different vetting processes, we don't regulate that, I can't necessarily speak to those things.
MR. LEE: Thanks, Scot.
I will go to our next question.
COVID-19 posed a challenge to most, if not all, regulators around the world. Was there a process to learn from other regulators and adoption to NRC's inspection procedures and protection of staff?
I'll take a first crack at it, and then, Scot or Jeff, if you want to chime in, please feel free.
So as the COVID unfolded and as we, as Jeff described earlier about some of the considerations that we went through and how we go forward with conducting force-on-force during the COVID environment, we certainly wanted to know about how other regulators around the world were coping with that situation. So we sought out the opportunity to engage from various foreign regulators, other international regulators to see what they were doing.
And we continue to do so. And in fact (audio interference) today to share their perspective.
Unfortunately, we couldn't hear that perspective.
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62 But we continue to engage our international counterparts to continue to understand what they're doing, why they're doing what they're doing, and for us to share that as well, and try and learn from one another and be able to keep the conversation going to do so through our Office of International Programs folks.
Anything to add there, Scot or Jeff? If not, I'll go to our last question.
Actually, it's 2:44, and I'm told that we should probably end soon because there is another session at 2:45. So I want to take this opportunity to thank the panelists for your presentations and for all your excellent answers to the questions that have been posed. Thank you for your preparation.
I want to thank the session coordinator Rebecca Stone, with support from Charity Pantello, for coordinating this meeting and for all the prep work that she's done.
And of course, I want to thank the audience for your attention and for your good questions. As I said before, this session is recorded and it's also transcribed. So that should be made available at a later time.
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63 With that, I thank you all for your participation, and we wish you a good rest of the conference. And thank you. Take care.
(Whereupon, the above-entitled matter went off the record at 2:44 p.m.)
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