ML25064A434
| ML25064A434 | |
| Person / Time | |
|---|---|
| Site: | Nuclear Energy Institute, 99902028 |
| Issue date: | 03/05/2025 |
| From: | Whitlock M Nuclear Energy Institute |
| To: | Barwell O Office of Nuclear Security and Incident Response, Document Control Desk |
| References | |
| NEI 05-05, Rev. 7 | |
| Download: ML25064A434 (1) | |
Text
Michael Whitlock Director, Security & Incident Preparedness Phone: 540.333.5087 Email: mlw@nei.org March 5, 2025 Mr. Owen Barwell Chief Financial Officer U.S. Nuclear Regulatory Commission Washington, DC 20555-0001
Subject:
Fee Exemption Request for NEI 05-05, Force-on-Force Exercise Controller Responsibilities Guideline, Revision 7 Project Number: 689
Dear Mr. Barwell:
The Nuclear Energy Institute (NEI)1, on behalf of its members, is submitting concurrent with this letter, NEI 05-05, Force-on-Force Exercise Controller Responsibilities Guideline, Revision 7 for endorsement. The guidance in this document addresses the knowledge and skills necessary to be a controller in both a licensee Force-on-Force (FOF) exercise, as well as the NRC evaluated FOF as part of Inspection Procedure 71130.03, Contingency Response - Force-on-Force Testing. FOF exercises are scripted to maximize realism; however, simulations are employed where necessary to assure the safety of the participants. NEI 05-05 provides acceptable simulations and control measures for a broad range of expected tactics. Revision 7 of NEI 05-05 was created, in part, to incorporate controlling measures that have been identified in FOF exercises since the previous endorsement on October 25, 2018 (Agencywide Documents Access and Management System (ADAMS) Accession Number ML18297A295). Additionally, the revision will address explosive artificialities and simulations which challenge the realism associated with the exercise as described in COMSECY-19-0006.2 NEI requests that any reviews and post-submittal meetings associated with NEI 05-05, and any future submissions of the guidance document be granted a fee waiver pursuant to the provisions of 10 CFR 170.11. This document meets the exemption requirement in 10 CFR 170.11(a)(1)(ii) in that it will assist 1 The Nuclear Energy Institute (NEI) is responsible for establishing unified policy on behalf of its members relating to matters affecting the nuclear energy industry, including the regulatory aspects of generic operational and technical issues. NEIs members include entities licensed to operate commercial nuclear power plants in the United States, nuclear plant designers, major architect and engineering firms, fuel cycle facilities, nuclear materials licensees, and other organizations involved in the nuclear energy industry.
2 COMSECY-19-0006, REVISED SECURITY INSPECTION PROGRAM FRAMEWORK (OPTION 3) IN RESPONSE TO SRM-17-0100, states, FOF exercises contain artificialities and simulations, both of which can impact response force actions and adversary actions during an exercise in a manner that challenges the realism associated with the exercise.
Mr. Owen Barwell March 5, 2025 Page 2 Nuclear Energy Institute the NRC in generic regulatory improvements or efforts (e.g., rules, regulatory guides, regulations, policy statements, generic letters, or bulletins). In this case, NRC review and endorsement of Revision 7 of NEI 05-05 will facilitate in the development of control measures associated with planned FOF scenarios and provide clarity to licensees on control attributes associated with Force-on-Force.
If you have any questions or require additional information, please contact me at mlw@nei.org.
Sincerely, Michael Whitlock Director, Security & Incident Preparedness cc:
Chris Carroll, OCFO Tara Inverso, NSIR/DSO Desiree Davis, NSIR/DSO/SOSB Becca Lagios, NSIR NRC Document Control Desk