ML24008A145
| ML24008A145 | |
| Person / Time | |
|---|---|
| Issue date: | 01/09/2024 |
| From: | Clark J Security Performance Evaluation Branch |
| To: | Laplante J Entergy Operations |
| References | |
| Download: ML24008A145 (1) | |
Text
January 9, 2024 Jonathan LaPlante, Director Security Operations Entergy Operations, Inc.
M-ECH-44 1340 Echelon Parkway Jackson, MS 39213
SUBJECT:
U.S. NUCLEAR REGULATORY COMMISSION OVERSIGHT OF MOCK ADVERSARY FORCE IN SUPPORT OF FORCE-ON-FORCE INSPECTIONS
Dear Jonathan LaPlante:
The U.S. Nuclear Regulatory Commission (NRC) is providing this letter to clarify the basis, continued need for, and approach to the evaluation of the Joint Composite Adversary Force (JCAF) in support of NRC-evaluated force-on-force (FOF) inspections. This letter also provides notice that Entergy will be billed for JCAF oversight activities during calendar year 2024.
Section 170D of the Atomic Energy Act of 1954, as amended (AEA) requires, in part, that Not less often than once every 3 years, the Commission shall conduct security evaluations at each licensed facility that is part of a class of licensed facilities, as the Commission considers to be appropriate, to assess the ability of a private security force of a licensed facility to defend against any applicable design basis threat. Section 170D further requires that:
- 1) The Security Evaluations shall include FOF exercises.
- 2) The FOF exercises shall, to the maximum extent practicable, simulate security threats in accordance with any design basis threat applicable to a facility.
- 3) In conducting a security evaluation, the Commission shall mitigate any potential conflict of interest that could influence the results of an FOF exercise, as the Commission determines to be necessary and appropriate.
As such, the NRC has a statutory obligation under Section 170D of the AEA to mitigate any potential conflict of interest (COI) that could influence the results of an FOF exercise. The staffs monitoring of the JCAF for any potential of COI is an integral part of the FOF program, and is included in Inspection Procedure 71130.03, Contingency Response - Force-on-Force Testing.
The JCAF must mimic, as closely as possible, the attributes of the adversary as described in Part 73.1 of Title 10 of the Code of Federal Regulations. The NRC evaluates the individual and collective selection, training, and proficiency of the JCAF to ensure that the published standards as outlined in NSIR/STD2004/15001, Revision 2, Composite Adversary Force Performance Standards for FOF Exercises, (OUO-SRI) are met. NSIR/STD2004/15001, Revision 2, identifies minimum physical fitness and training standards, and also addresses knowledge of attack strategies to ensure mock adversary force (MAF) personnel are trained in offensive, rather than defensive skills.
J. LaPlante 2 One NRC inspector will be onsite to provide oversight of the JCAFs requalification and annual training that are currently scheduled for March 18-22, 2024. Time spent for the inspector traveling to the training activities and while onsite providing oversight will be billed to Entergy.
The inspector will evaluate JCAF training against the standards outlined in NSIR/STD2004/15001, Revision 2.
This letter does not represent any changes to the NRCs approach to evaluating the JCAF, rather, the letter confirms the ongoing need for the continued process to ensure the NRC is mitigating any potential COI that could influence the results of an FOF exercise. The NRC will continue to assess the process for evaluating MAFs, and any changes to the current process will be communicated promptly.
The NRC is open to any suggestions that could assist in focusing NRC staffs oversight efforts so that inspector time is used as efficiently as practicable.
Should you have any questions regarding this matter, please contact me at (301) 287-3666 or at Jefferson.Clark@nrc.gov.
Sincerely, Signed by Clark, Jefferson on 01/09/24 Jefferson Clark, Chief Security Performance Evaluation Branch Division of Security Operations Office of Nuclear Security and Incident Response
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