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NEI Insights on BSSDP Phase II Working Group Effort
	ML25052A001
Person / Time
Site:	Nuclear Energy Institute
Issue date:	02/20/2025
From:	; Nuclear Energy Institute
To:	; Office of Nuclear Security and Incident Response
References
	Download: ML25052A001 (1)
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Background

Recommended approach

Human performance (HU) v. programmatic issues

Suggested risk-informing criteria

Potential improvements to existing figures

Reoccurring events

Summary

Background

SECY-23-0032 (ML23026A346): the objective of the assessment is to determine whether there are any aspects of the BSSDP [baseline security significance determination process] that can be improved or further risk-informed Public meetings:

March 20, 2024, to discuss the staffs progress on initiatives related to the evaluation of the BSSDP June 24, 2024, to provide an update on the NRC's progress on the effort to evaluate the BSSDP December 18, 2024, to share the results of the BSSDP Phase I activities, including an overview of the working groups recommended path forward in Phase II.

©2025 Nuclear Energy Institute 4 Stakeholder input from public meeting 6/4/24 Consider changes to the entry and exit criteria for the Significance Screen for Physical Protection (Figure 4) within Inspection Manual Chapter 0609, Appendix E, Part 1.

Evaluate the exportability gap between human performance errors and programmatic issues as they relate to a licensees defense-in-depth.

Contemplate additional risk questions related to physical security findings that could lead to further risk informing the BSSDP.

Consider providing the public more detailed information and rationale to better understand the proposed changes and have a more fulsome discussion.

©2025 Nuclear Energy Institute 5 Current Significance Screen The IPPP/Time Matrix of Step 4 in Figure 4 uses impact to the physical protection program (IPPP) and duration (time) to determine significance.

These parameters give the 9-box significance determination table shown to the right.

An expanded table would allow for additional risk-informing criteria

©2025 Nuclear Energy Institute 6 Benefits of using 18-box table Allows for additional insights to be included in the decision process Maintains the ease-of-use of the current decision table Input 1 Input 2 Input 2 Input 3 Input 1

©2025 Nuclear Energy Institute 7 Human performance v. programmatic issues Performance deficiencies arising from HU errors should be screened as less significant than those associated with programmatic issues It is virtually impossible for an adversary to predict and exploit an HU error A revised BSSDP could determine into which category the deficiency falls and have separate tables for determining the significance The tables could include insights discussed in the June 2024 public meeting, such as accounting for the:

Defense-in-depth of a site protective strategy, Comprehensive set of requirements in all site security plans, and Degree of information availability to an adversary.

©2025 Nuclear Energy Institute 8 Potential HU Significance Screen Assessed independent of programmatic aspects Keeps the current user-friendly table presentation but has 18 blocks instead of 9 Maintains impact and time inputs, but these could be further risk-informed Accounts for licensees access control programs and time available for exploitation Opportunity to include consideration of licensee-identified issues

©2025 Nuclear Energy Institute 9 Potential Programmatic Significance Screen Assessed independent of human performance aspects Keeps the current user-friendly table presentation but has 18 blocks instead of 9 Maintains impact and time inputs, but these could be further risk-informed Accounts for information availability to an adversary and time available for exploitation Opportunity to include consideration of licensee-identified issues

Working group recommendation to the commission:

Explore additional entry criteria (Figure 4) and further define low/medium/high thresholds Low/medium/high thresholds in the current SDP reflect actual events and not potential events

Potential events could be incorporated by:

Development of examples in a separate table, or Adjusting impact on proposed table based on actual v. potential events

Opportunity to include credit for licensee performance, consistent with ADVANCE Act goal of considering existing performance

Reflect current FOF exercise practice of a licensee providing any requested SGI to the adversary team

Assess the degree to which the effectiveness of a site protective strategy is compromised when determining the significance of a loss of SGI control

maintained and revised to add criteria from the proposed HU error and programmatic issues tables (time available for exploitation), or

incorporated into the proposed HU error and programmatic issues screening

Option to include a process for assessing issues that repeat in less than a year

Focus on most risk-significant

/ high impact performance deficiencies

Have clear criteria to identify repeat events to ensure alignment and consistency

©2025 Nuclear Energy Institute 15 18-box table incorporates additional insights for determining significance Human performance and programmatic issues are evaluated separately Suggested approach considers site protective strategy defense-in-depth, totality of security plan requirements, and degree of availability of information to an adversary Opportunities to credit licensee-identified performance deficiencies Significance determination for mishandled SGI considers practices and performance in FOF exercises Repeat issues process places focus on the most risk-significant / high impact performance deficiencies Summary

ML25052A001

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