ML25052A165

Draft - IMC 0308 Attachment 6; Draft - IMC 0609 Appendix E Part II, Force-on-Force Significance

ML25052A165
Person / Time
Issue date:	02/21/2025
From:	Jeffrey Bream NRC/NSIR/DSO/SOSB
To:
References
Download: ML25052A165 (1)

Text

This document is being provided for information only for the sake of the March 3, 2025, public meeting related to this topic. The content of this inspection procedure is draft and is subject to change prior to final issuance. The NRC is not soliciting official comments.

Any comments provided to the NRC during or after the public meeting may or may not be considered prior to issuance.

Issue Date: DRAFT 1

0609, App E Part II NRC INSPECTION MANUAL NSIR/DSO/SOSB INSPECTION MANUAL CHAPTER 0609, APPENDIX E, PART II FORCE-ON-FORCE SIGNIFICANCE DETERMINATION PROCESS Effective Date: January 1, 2026 0609EII-01 PURPOSE The purpose of the Force-on-Force (FOF) Significance Determination Process (SDP) is to provide an objective and consistent means of evaluating findings associated with licensee exercise performance during a U.S. Nuclear Regulatory Commission (NRC) triennial FOF inspection. Findings in the security cornerstone unrelated to exercise performance, including target set findings, are evaluated using Inspection Manual Chapter (IMC) 0609, Appendix E, Part I, Baseline Security Significance Determination Process.

0609EII-02 BACKGROUND The FOF inspection process is designed to assess the robustness of a licensees protective strategy by testing the licensees ability to adequately protect target set equipment in order to prevent significant core damage and spent fuel sabotage during an NRC-conducted FOF exercise. Generally, a licensees protective strategy is evaluated on the basis of its ability to protect the structures, systems, and components (SSCs) and credited operator actions that make up the applicable target sets for that facility.

IMC 0609, Appendix E, Part II, evaluates the overall significance of findings associated with the licensees exercise performance during the conduct of all NRC-conducted FOF exercises. The NRC assesses licensee exercise performance as:

1. Effective implementation of the protective strategy

2. Ineffective implementation of the protective strategy

3. Indeterminate performance during an exercise, where an overall determination of adequacy was not achieved 0609EII-03 DEFINITIONS Canceled Exercise: An exercise that was not conducted because of the risk to exercise participants or to the safe operations of the facility. These conditions include but are not limited to, hazardous weather or other extenuating circumstance such as a plant transient.

Effective Exercise: An exercise where the licensees protective strategy successfully protected the selected target set from simulated destruction and compromise by the mock adversary force

This document is being provided for information only for the sake of the March 3, 2025, public meeting related to this topic. The content of this inspection procedure is draft and is subject to change prior to final issuance. The NRC is not soliciting official comments.

Any comments provided to the NRC during or after the public meeting may or may not be considered prior to issuance.

Issue Date: DRAFT 2

0609, App E Part II in order to prevent significant core damage and spent fuel sabotage in accordance with implementation procedures, regulatory requirements, or other Commission requirements.

Ineffective Exercise: An exercise where the licensees protective strategy failed to adequately protect the selected target set from simulated destruction and compromise by the mock adversary force in accordance with implementation procedures, regulatory requirements, or other Commission requirements such that which all components of the selected target set were simulated destroyed or compromised.

Indeterminate Exercise: An exercise where the results were significantly skewed by an anomaly or anomalies, resulting in the inability to determine the outcome of the exercise (e.g.,

site responders neutralize the mock adversary force using procedures or practices unanticipated by the design of the site protective strategy or training of security personnel to implement the site protective strategy, or significant exercise control failures to include controller performance failures). The inability to reliably determine the outcome of the exercise can also create an indeterminate exercise.

Target Set: The minimum combination of equipment or operator actions which, if all were prevented from performing their intended safety function or prevented from being accomplished, would likely result in significant core damage (e.g., non-incipient, non-localized fuel melting and/or core destruction) or a loss of spent fuel water inventory and exposure of spent fuel, barring extraordinary actions by plant operators.

0609EII-04 ASSESSMENT PROCESS The FOF SDP assesses more-than-minor exercise performance deficiencies during NRC-conducted FOF exercises. When an issue of concern with a licensees exercise performance is identified, the issue is first screened using IMC 0612, Appendix B, Issue Screening. All more-than-minor performance deficiencies related to exercise performance (i.e., ineffective implementation, or indeterminate exercise performance), will be screened through the FOF SDP to determine the findings significance. If the finding is in the security area but unrelated to licensee exercise performance, evaluate the finding using IMC 0609, Appendix E, Part I. If the finding is related to ineffective exercise performance, it is screened as a Green finding.

Inspectors will utilize the FOF SDP to determine the appropriate Re-Visit Action for ineffective and indeterminate outcomes.

The Re-Visit Action for an ineffective exercise will be an NRC-conducted FOF exercise and a review of the licensees corrective action measures (CAMs) from the previous exercise.

Inspectors should consider the following when determining the appropriate Re-Visit Action for indeterminate outcomes: an NRC-conducted exercise is required when no useable data is gathered during the exercise, other Re-Visit actions will be determined based on the inspection teams assessment and NRC Managements input.

If the finding is in the security cornerstone but is unrelated to exercise performance associated with the ineffective implementation of the protective strategy, then inspectors will evaluate the finding using IMC 0609, Appendix E, Part I. For significant issues, Part I provides a path for

This document is being provided for information only for the sake of the March 3, 2025, public meeting related to this topic. The content of this inspection procedure is draft and is subject to change prior to final issuance. The NRC is not soliciting official comments.

Any comments provided to the NRC during or after the public meeting may or may not be considered prior to issuance.

Issue Date: DRAFT 3

0609, App E Part II escalated enforcement. The process for evaluating FOF exercise findings is described below and is depicted in Figures 1 and 2.

04.01 Determine if the licensees exercise performance resulted in an EFFECTIVE exercise outcome with performance deficiencies.

a. If the licensees exercise performance resulted in an effective exercise outcome with associated performance deficiencies, continue to IMC 0609, Appendix E, Part I, Baseline Security Significance Determination Process.

04.02 Determine if the licensees exercise performance resulted in an INDETERMINATE exercise outcome.

a. If the licensees exercise performance resulted in an indeterminate exercise outcome with associated performance deficiencies, continue to IMC 0609, Appendix E, Part I, Baseline Security Significance Determination Process;

b. Refer to the Re-Visit Action table in Figure 2 to determine the appropriate re-inspection activity.

c. Inspections that result in an indeterminate outcome require Re-Visit Action. One of the following will be applied based on the quantity and nature of the observations that were gathered from the exercise relative to the implementation of the protective strategy:

1. A review of the CAMs;

2. NRC observation and assessment of licensee-conducted exercise(s);

3. One NRC-conducted exercise.

04.03 Determine if the licensees exercise performance resulted in an INEFFECTIVE exercise outcome.

a. If the licensees exercise performance resulted in an ineffective exercise outcome, the finding is Green.

b. Inspections that result in an ineffective outcome require both of the following Re-Visit Actions:

1. A review of the CAMs;

2. One NRC-conducted exercise.

04.04 FOF SDP use for re-inspection exercises.

Re-inspection is considered for all exercise outcomes resulting in an indeterminate or ineffective characterization. Refer to the Re-Visit Action column in Figure 2 for potential re-visit activities.

This document is being provided for information only for the sake of the March 3, 2025, public meeting related to this topic. The content of this inspection procedure is draft and is subject to change prior to final issuance. The NRC is not soliciting official comments.

Any comments provided to the NRC during or after the public meeting may or may not be considered prior to issuance.

Issue Date: DRAFT 4

0609, App E Part II When an issue of concern with a licensees exercise performance is identified during re-inspection, the issue should first be screened using IMC 0612, Appendix B. If the issue is determined to be a more-than-minor performance deficiency, it is a finding. If the finding is related to ineffective or indeterminate exercise performance outcomes, use the FOF SDP. If the finding is in the security area but unrelated to the licensees exercise performance, then evaluate the finding using IMC 0609, Appendix E, Part I.

Other factors that may be assessed and reviewed before determining the final significance of findings related to re-inspection activities include:

a. A review of the licensees corrective actions implemented as a result of the triennial inspection that caused the re-inspection:

1. Were the corrective actions ineffective and/or contribute to the cause of the ineffective implementation of the sites protective strategy or indeterminate exercise performance during an exercise(s)?

2. Is the finding(s) during re-inspection related to new issues unrelated to the corrective actions implemented before the re-inspection activities?

b. A review to determine the need to conduct additional inspection activities, such as the following:

1. An NRC-conducted exercise (for an ineffective or indeterminate NRC-conducted Re-Visit exercise);

2. NRC observation and assessment of licensee-conducted FOF exercise;

3. Review of CAMs taken to resolve programmatic issues related to the finding(s) identified during the re-inspection activity.

If the NRC becomes aware of situations that are not appropriately captured by this SDP, indicating flaws in the development or implementation of a licensees protective strategy, NSIR management may exercise discretion to further evaluate the potential deficiency 0609EII-05 REFERENCES IMC 0609, Appendix E, Part I, Baseline Security Significance Determination Process END Figures:

Figure 1: Force-on-Force Significance Determination Process Flowchart Figure 2: Force-on-Force Significance Determination Process Tabe

This document is being provided for information only for the sake of the March 3, 2025, public meeting related to this topic. The content of this inspection procedure is draft and is subject to change prior to final issuance. The NRC is not soliciting official comments.

Any comments provided to the NRC during or after the public meeting may or may not be considered prior to issuance.

Issue Date: DRAFT 5

0609, App E Part II Figure 1 - Force-on-Force Significance Determination Process Flowchart Finding identified During FOF Exercise Exercise results in an effective outcome with performance deficiencies Yes Yes No Yes Exercise Performance Related Go to IMC 0609, App. E Part I No Go to IMC 0609, App. E, Part I, and to Figure 2 for Re-Visit Action.

Go to IMC 0609, App. E Part I Exercise results in an indeterminate outcome?

No Yes Green Finding and go to Figure 2 for Re-Visit Action.

Exercise results in an ineffective outcome?

This document is being provided for information only for the sake of the March 3, 2025, public meeting related to this topic. The content of this inspection procedure is draft and is subject to change prior to final issuance. The NRC is not soliciting official comments.

Any comments provided to the NRC during or after the public meeting may or may not be considered prior to issuance.

Issue Date: DRAFT 6

0609, App E Part II Figure 2 - Force-on-Force Significance Determination Process Table Exercise Significance Re-Visit Action Ineffective Green

1) CAMs Review and NRC-conducted FOF exercise Indeterminate Determine via baseline security SDP

1) CAMs Review; 2) NRC observed FOF exercise; or 3) NRC-conducted FOF exercise Re-Visit Action for Ineffective Exercise Outcomes

1. NRC-Conducted Exercise, and CAMs Review.

Re-Visit Action Examples for Indeterminate Exercise Outcomes

1. NRC-Conducted Exercise: When the overall outcome of the exercise cannot be determined and there are no useable observations from the single NRC-conducted exercise.

2. Observe Licensee-Conducted Exercise: When the overall outcome of the exercise cannot be determined but useable observations can be gleaned from the single exercise; however, multiple security response force performance issues or significant controller issues were identified.

3. CAMs Review: When the overall outcome of the exercise cannot be determined but useable observations can be gleaned from the single exercise; however, individual response force issues or one or more controller issues were identified.