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Public Mtg_2024-04-03 Pre-submittal Meeting with the Nuclear Energy Institute (NEI) to Discuss an Update to NEI 03-12, Security Plan Template (Revision 8)_NEI Slides
	ML24092A313
Person / Time
Site:	Nuclear Energy Institute
Issue date:	04/03/2024
From:	; Nuclear Energy Institute
To:	; Office of Nuclear Security and Incident Response
References
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NEI 03-12, Rev. 8 Pre-submittal Meeting

April 03, 2024

Overview

Industry Representation and Point of Contact

Brief History of Document

Purpose for Revision

Revision Attributes

Supporting Document

Requested Outcome

NEI 03-12 Team Industry Representation:

AEP

Constellation Energy

Dominion Energy

Duke Energy

Entergy

Excel Services

Holtec

Nuscale Power

PG&E

PSEG

Southern Company

Tennessee Valley Authority TVA)

NEI 03-12 Team Point of Contact and Team Lead

Primary Point of

Contact:

Mike Whitlock, Nuclear Energy Institute

Team Lead:

Pat Asendorf, TVA

History of NEI 03-12

Template Physical Security Plan, Training and Qualification Plan, and Safeguards Contingency Plan, hereinafter Plan

Composite Plan is designated as Safeguards Information

Nuclear Strategic Issue Advisory Committee (NSIAC) Initiative

Initial development and issuance

History of NEI 03-12, continued

Revision 2 thru 5, minor revisions

Revision 6, first major revision

Currently two NRC endorsed versions

Revision 7, dated 2011

Revision 7.1, dated 2018

Purpose

The purpose of this template revision is to maintain industry alignment as initially intended by the NSIAC initiative. This achieves two goals:

implementation of consistent standards, programs, and practices to meet the same objective of providing high assurance that 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, and

provides a regulatory framework that is consistent for the NRC to verify, through inspections, that licensees have a clearly documented security program to meet specific regulatory requirements

Revision Attributes

Incorporate lessons learned over past two decades through

NRC Inspection activities

New/Updated/Revised Guidance

Resolution of Security Frequently Asked Questions (SFAQs)

Benchmarking and sharing of Operating Experience (OE)

Internal audits and self-assessments

Revision Attributes, continued

Streamlined overall document through reorganization of sections and flow of information for readability, improved alignment with regulations, and elimination of redundant and unnecessary information

Combine Revisions 7 and 7.1 into one template

Edited and/or added bracketed text to include guidance for licensees to edit/add appropriate level of site-specific information, as applicable

Edited to better align with regulatory terminology

Adjusted formatting for clarity with implementation

Portion marked for proper designation of specific information

Supporting Document - Sample revision matrix summary of changes

Next Slide

NEI 03-12, Revision 8 Pre-submittal Meeting

Section NEI 03-12, Revision NEI 03-12, Revision 8 Description of change 7/7.1 Language Language Cover pages, [Current text] [Current text] Changed revision identifier from 7/ 7.1 to 8 headers, and table of Changed dates respectively from October 2011 and January 2018 to April 2024 (note: this date will be adjusted to contents coincide with final publication).

Total number of pages from 119 to 157 (note: the page count number will be adjusted with final publication to ensure accuracy).

Changed title for consistency throughout the document. Expanded for licensee/applicant options regarding ISFSI and new construction.

Added guidance for completing the template for transitioning to a site -specific document. General summary of changes throughout include but are not necessarily limited to:

Table of contents reordered accordingly with movement, addition or relocation of specific information from original sections identified below. Removed specific safeguards information from original Sections headers 9.3.1 and 9.3.2 and reformatted information within appropriate section.

Portion marked document for proper designation of specific information. Editorial and formatting changes throughout.

Added bold font to all bracketed text for ease of differentiating between template text and guidance for adding site -

specific information. Added notes in red font text and within braces for direction/guidance. Italicized defined terms.

Applied use of acronyms and deleted those not used throughout.

Moved/combined sections, separated paragraphs into several paragraphs and reordered sentence structures for clarity and improved flow of the overall document.

Minor editing for clarity.

Section NEI 03-12, Revision NEI 03-12, Revision 8 Description of change 7/7.1 Language Language New 2.5 N/A Added new bracketed text for licensees that must adhere to requirements of Subpart B to Part 73.

4. Establishment of Security 3. (U) Establishment of Formatted section from one paragraph to two. Edited for clarity and elimination of redundant Now 3. Organization Security Organization information. Moved the bracketed text to Section 18 (formerly 22), Records, adding sub-

[Current text] section 18.14, Contracted Security Services, since this information is specific to records retention requirements.

Moved the last sentence up to add to the end of the first paragraph to improve flow of information.

5. Qualification for N/A Deleted to eliminate redundancy of information. Although referenced within 10 CFR 73.55 Employment in Security (c) Security plans and (d) Security organization, this information is not necessarily relevant to

[Current text] the Physical Security Plan, and as indicated the subject information is included within the Training and Qualification Plan.

10. Work Hour ControlsN/A Removed information as the requirements for work hour controls are governed under 10 CFR

[Current text] Part 26, which is implemented in accordance with the licensee fitness for duty program for specifically identified individuals/work groups. 10 CFR 73.55 (b)(9)(ii)(B) (element of the insider mitigation program) is the only reference to the part 26, to which is not relative to part 26, subpart I, work hours.

Requested Outcome

NRC endorsement of NEI 03-12, Revision 8, Template Physical Security Plan, Training and Qualification Plan, and Safeguards Contingency Plan by October 2024.

ML24092A313

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