ML24046A131
| ML24046A131 | |
| Person / Time | |
|---|---|
| Site: | Turkey Point  |
| Issue date: | 02/16/2024 |
| From: | Clark J Security Performance Evaluation Branch |
| To: | Lopez A Florida Power & Light Co |
| References | |
| Download: ML24046A131 (1) | |
See also: IR 05000250/2024001
Text
Antonio Lopez
Site Security Manager
Florida Power & Light Company
9760 SW 344th Street
Florida City, FL 33035
SUBJECT:
RESPONSE TO FORMAL DISAGREEMENT WITH ADVERSARY
CHARACTERISTICS, ATTRIBUTES, OR TACTICS EMPLOYED OR
PREPARED AS PART OF AN NRC-EVALUATED FORCE-ON-FORCE
EXERCISE - DISPUTED ITEM 05000250,251/2024-01
Dear Antonio Lopez:
The NRC staff received your email and subsequent attachment to the Division of Security
Operations (DSO), Security Performance Evaluation Branch titled Formal Disagreement with
Adversary Characteristics, Attributes, or Tactics Employed or Prepared as Part of an NRC-
Evaluated Force-on-Force Exercise, dated February 14, 2024 (Agencywide Documents Access
and Management System (ADAMS) Accession No. ML24046A050), in accordance with
Addendum 4 of NRC Inspection Procedure 71130.03 Contingency Response - Force-on-Force
Testing. In your letter you dispute a tactic, technique, or procedure (TTP) within Scenario 1
developed by an NRC Force-on-Force inspection team.
The NRC has carefully reviewed your formal escalation and concluded that the disputed TTPs
(i.e., NEI 09-05 traversal times) are approved for use within the NRC-evaluated exercise
scenario for the following reasons; (1) it is within the design basis threat; (2) supported by
industry data that is NRC endorsed; (3) within your program requirements to provide defense-in-
depth; (4) can be safely performed and controlled; and (5) provides a credible challenge to your
sites protective strategy. Furthermore, the Sandia study you referenced is not approved for use
currently in NRC force-on-force (FOF) inspections. If NextEra would like to utilize this document
in the future it would need to follow a formal NRC review/approval process.
If you would like to appeal this decision, provide a written response within 3 days from the date
of this letter with the basis of your appeal to the Director, DSO.
Sincerely,
Jefferson Clark, Branch Chief
Security Performance and Evaluation Branch
Division of Security Operations
Office of Nuclear Security and Incident Response
February 16, 2024
Signed by Clark, Jefferson
on 02/16/24
Ltr ML24046A131
OFFICE
NSIR/DSO/SPEB
/ETB
NSIR/DSO/SPEB
/ETA
NAME
JBerry
JClark
DATE
Feb 15, 2024
Feb 16, 2024