ML24099A216
| ML24099A216 | |
| Person / Time | |
|---|---|
| Issue date: | 04/09/2024 |
| From: | Brooks M NRC/NSIR/DSO/SOSB |
| To: | Desiree Davis Office of Nuclear Security and Incident Response |
| Shared Package | |
| ML24099A217 | List: |
| References | |
| Download: ML24099A216 (1) | |
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MEMORANDUM TO:
Desiree Davis, Chief Security Oversight and Support Branch Division of Security Operations Office of Nuclear Security and Incident Response FROM:
Maury Brooks, Security Specialist Security Oversight and Support Branch Division of Security Operations Office of Nuclear Security and Incident Response
SUBJECT:
SUMMARY
OF THE BASELINE SECURITY SIGNIFICANCE DETERMINATION PROCESS PUBLIC MEETING HELD ON MARCH 20, 2024 Meeting Identifier: 20240214 Date of Meeting: March 20, 2023 Type of Meeting: Observation Meeting Purpose of Meeting: On March 20, 2024, the U.S. Nuclear Regulatory Commission (NRC) staff hosted a virtual public meeting with various internal and external public stakeholders to discuss the staffs progress on initiatives related to the evaluation of the Baseline Security Significance Determination Process (BSSDP). The topics discussed during this virtual meeting are described below.
General Details: The meeting was attended by approximately 33 NRC personnel and external stakeholders. Representatives from ENERCON, Entergy, the Nuclear Energy Institute, Southern Nuclear, STARS Alliance, and the Union of Concerned Scientists were among the participants that identified themselves and provided comments or questions. The meeting started at 1:00pm EDT and completed by 2:00pm EDT, as scheduled. The meeting was held virtually over the Microsoft Teams application.
Summary of Presentation: The NRC provided a formal presentation for the meeting discussion. This presentation can be located at ML24092A283. No other participants provided a formal presentation.
CONTACT: Maury Brooks, NSIR/DSO/SOSB (301) 415-3075 April 9, 2024 Signed by Brooks,Maury on 04/09/24
2 D. Davis From January 17th through the 18th, 2024, the BSSDP working group (WG) held their kick-off meeting. During this meeting, the team was introduced to one another. The WG includes an inspector from each NRC region, as well as staff from the Security Performance Evaluation Branch, the Office of Nuclear Security and Incident Response, the Technical Training Center, the Office of Enforcement, and the Office of Nuclear Reactor Regulation. The working group members discussed the purpose and desired outcomes, namely, to review the BSSDP and identify any aspects of the guidance that can be improved, or further risk-informed. Additionally, the staff provided an overview of the BSSDP working group activities, including plans for a phased approach:
WG Phase I (January - June 2024)
Evaluate data collected on the current BSSDP (e.g., internal agency surveys and responses, finding reviews, etc.).
Identify any areas for improvement, if needed and as appropriate, and present options to NRC management for consideration.
WG Phase II (TBD)
If directed by NRC management based on the results of Phase I, the WG may commence Phase II to develop the selected option which best supports the objective of the BSSDP.
Industry Input/Comments After the initial introduction and presentation by the NRC, various external stakeholders shared their thoughts regarding the initiation of the project and made several suggestions for agency consideration moving forward. External stakeholders expressed their desire to participate in the process, to the extent permitted. The following list is a high-level summary of the comments and suggestions offered by external stakeholders and are not verbatim:
Nuclear Energy Institute: Expressed support for the evaluation of the current BSSDP and potential changes that would eliminate the complexity and subjectivity of the tool and support further risk-informing the current BSSDP.
STARS Alliance: Commented that the NRC should consider modifying the entry and exit criteria in that if a finding is screened and does not meet the criteria described within the Significance Screen for Physical Protection, the final significance determination of the finding would be categorized as a very low security significance (i.e., Green).
Southern Nuclear: Requested that the NRC evaluate the impact that a particular condition (or vulnerability) has on a licensees physical protection program, as defined within IMC 0308, Attachment 3, Appendix E, that describes programmatic findings being more exploitable by an adversary than a finding related to a human performance error within an otherwise adequate program or process being implemented.
3 D. Davis Entergy: Commented that the NRC should consider mitigating factors such as defense-in-depth and/or other security program elements successfully being implemented by the licensee when determining potential significance.
ENERCON: Provided comments regarding the need for NRC to contemplate additional risk questions related to physical security findings that could lead to further risk-informing the BBSDP.
Union of Concerned Scientists (UCS): Requested that the NRC consider providing more detailed information and rationale for the public to better understand any proposed changes to the BSSDP.
Next Steps The WG continues to evaluate the current BSSDP and will create options for NRC management review and consideration. Subsequent WG meetings and periodic WG status meetings with NRC management will be held over the next few months to complete Phase I. Once Phase I is completed, the outcomes of the WG efforts will be communicated to NRC management for review and decision for a path forward. The specific date and time for the next BSSDP public meeting is to be determined.
Conclusion At the end of the meeting, NRC and industry management gave closing remarks.
The enclosure provides the attendance list for this meeting.
Enclosure:
As stated
ML24099A217; Memo ML24099A216 OFFICE NRC/NSIR/DPCP
/RSB NSIR/DSO/ILTAB NRC/NSIR/DPCP
/RSB NAME MBrooks DDavis MBrooks DATE Apr 8, 2024 Apr 9, 2024 Apr 9, 2024