ML25064A550
| ML25064A550 | |
| Person / Time | |
|---|---|
| Site: | Nuclear Energy Institute |
| Issue date: | 03/05/2025 |
| From: | Nuclear Energy Institute |
| To: | Office of Nuclear Security and Incident Response |
| References | |
| Download: ML25064A550 (1) | |
Text
©2025 Nuclear Energy Institute Annual Force-on-Force White Paper March 11th, 2025 Presented by NEI
©2025 Nuclear Energy Institute 2 Background and Purpose COVID-19 PUBLIC HEALTH EMERGENCY (PHE)
During the PHE, licensees utilized alternative processes to satisfy security officer training requirements NRC granted enforcement discretion for annual FOF exercise qualification requirements for current, qualified security officers, due to the rigorous nature of licensees security training programs (EGM-20-002 Attachment 1)
Licensees reviewed training programs to identify enhancements developed during the PHE.
NRC challenged licensees to identify and implement program improvements LESSONS LEARNED Enhanced training effectiveness, increased officer engagement, improved officer morale, reduced administrative burden, and significantly reduced risks associated with radiological, industrial and personnel safety
©2025 Nuclear Energy Institute 3 Regulatory Concerns ALTERNATIVE APPROACH TO ANNUAL FOF EXERCISES Lessons learned leveraged from PHE to develop NEI White Paper: FOF Annual Exercises NRC Public Meeting held 2023 for Revision 0 NRC CONCERNS - Rev. 0 (CY2023)
Performance evaluation program design Demonstration of requisite knowledge, skills and abilities Limiting adversary capabilities and attack pathways Post-exercise critique Committed response numbers Industry reviewed concerns, revised NEI White Paper, validated a cross-walk of changes against the concerns, submitted for subsequent review.
©2025 Nuclear Energy Institute 4 Implementation Concept TACTICAL EXERCISE ACTIVITY Participants - Remaining security officers who are assigned to the specific team/crew being exercised (overstaffing)
Facilitated by qualified controller(s) under the overall direction of the Lead Controller who provide real time exercise injects Conducted simultaneously with the in-field activities Participants communicate their respective response actions in real-time Controllers evaluate participant actions based upon the requisite knowledge, skill, and abilities articulated by the officers.
Post-exercise critique conducted with participants to identify failures, deficiencies or other findings in performance, plans, equipment or strategies to be captured in the Corrective Action Program (CAP)
Participation would not be performed by same officer in consecutive years
©2025 Nuclear Energy Institute 5 Summary REGULATORY Alternative approach meets the regulatory requirements for annual force on force participation credit Participation in a Tactical Exercise Activity in concert with in-field activities Evaluated by a qualified controller Hotwash/Critique conducted Deficiencies/enhancements entered into Corrective Action Program BENEFITS Reduces the overall risk to safe plant operations, participants, and plant personnel Enhances training effectiveness Improves officer morale Provides burden reduction