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NEI Presentation Related to the Development of Adversary Timelines NRC Comment Resolution
	ML22102A202
Person / Time
Site:	Nuclear Energy Institute
Issue date:	04/12/2022
From:	Clore A, O'Neill D; Nuclear Energy Institute, Pacific Gas & Electric Co
To:	; Office of Nuclear Security and Incident Response
References
	Download: ML22102A202 (12)
	v • d • e

NEI White Paper, Development of Adversary Timelines NRC Comment Resolution AJ Clore Nuclear Energy Institute Dustin ONeill Pacific Gas & Electric/Nuclear Energy Institute

Purpose This white paper provides guidance for determining performance-based adversary timelines.

The following slides will address how the NRCs comments on this white paper were resolved.

NRC Comment - Overall Numerous comments pertaining to the generic travel speed table that was proposed during the July 2021 public meeting.

Given the feedback provided by both NRC and industry, the guidance in the white paper was revised and is solely focused on performance basing adversary timelines, rather than a standard travel speed.

This change would allow sites to factor: terrain, cover/concealment, dead space, engagement opportunities, multiple responders/adversaries and various other elements.

NRC Comment Comment - Adversary Timelines developed to meet the physical security design requirements are only considered appropriate when starting from a regulatorily required intrusion detection system. NEIs statement of some detection point should be clarified to the committed intrusion detection system as identified in the NRC-approved site security plan.

Resolution - Agree, addition of recommended language can be found on page 3 of NEI white paper.

NRC Comment Comment - Both active and passive barriers should be included/considered.

Resolution - Agree, described in section 4 on page 4 of white paper.

NRC Comment Comment - Consideration that the adversary is well trained and willing to kill or be killed, per 10 CFR 73.1.

Resolution - Agree, 73.1 reference was absent in initial paper.

Description added within Background section on page 2, as well as Reference section on page 5.

NRC Comment Comment - Outer edge of a building should be expanded to include a location where adversary operations can be conducted from which a target element may be destroyed or rendered incapable of performing its intended safety function or action.

Resolution - Agree, recommendation included on page 3, under Adversary Pathway Selection.

NRC Comment Comment - It would seem appropriate to use the breaching option most advantageous to the adversary. As written, the white paper appears to give sites options to potentially use a breaching methodology that could represent the slowest for an adversary.

Resolution - Agree, added section 4 on page 4 to account for variables associated with breaching and using the most advantageous technique for the adversary.

NRC Comment Comment - The methodology does not address changes to plant configurations associated with outages and other evolutions that change plant layout and target sets (mode changes).

Resolution - Agree, addition of section, Plant Configurations can be found on page 5 of white paper.

Path Forward April 21st, 2022 - NEI will be hosting a joint implementation workshop to roll out:

White paper on Developing Adversary Timelines

Reasonable Assurance of Protection Time (RAPT)

Part of the focus of this workshop will be potential changes to sites security plans. To include:

Appropriate guidance to follow

Validation exercises to support a change

Documentation of exercises (technical basis)

Maintaining all documentation for inspection

Points of Contact AJ Clore Dustin ONeill Senior Project Manager Principal, Security Strategy 202.285.205 Technical Lead ajc@nei.org 805.503.0785 djo@nei.org or djo9@pge.com

Questions

ML22102A202

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