ML25069A010
| ML25069A010 | |
| Person / Time | |
|---|---|
| Issue date: | 03/25/2025 |
| From: | Tara Inverso Office of Nuclear Security and Incident Response |
| To: | Whitlock M Nuclear Energy Institute |
| Lagios B | |
| References | |
| Download: ML25069A010 (1) | |
Text
Michael Whitlock, Director Security & Incident Response Nuclear Energy Institute 1201 F Street, NW, Suite 1100 Washington, DC 20004
SUBJECT:
RESPONSE TO LETTER, NEI 11-02, CHANGE MANAGEMENT PLAN-EVALUATED FORCE-ON-FORCE EXERCISES, REVISION 1 AND FORCE-ON-FORCE ESCALATION PROCESS PROPOSED REVISIONS
Dear Michael Whitlock:
I am responding to your \
December 31, 2024, letter (Agencywide Documents Access and Management System (ADAMS) Accession No. ML24366A072) regarding a public meeting held on December 12, 2024, where guidance document NEI 11-02, Change Management Plan for Evaluated Force-on-Force (FOF) Exercises was discussed. In your letter, you stated that an FOF issue resolution process can only be effective if the FOF schedule minimizes, to the greatest extent practical, changes to the scenario after planning week and requested that the U.S. Nuclear Regulatory Commission (NRC) conduct further engagement with the industry to structure exercise activities to achieve this objective.
The staff held three public meetings to engage with external stakeholders on FOF-related topics. On November 13, 2024,1 during a public meeting to better understand feedback on a variety of FOF topics, the NRC agreed to hold additional meetings in fiscal year 2025 to discuss NEI 11-02 and other topics. During the December 12, 2024,2 meeting the NRC committed to review the proposed revisions to the NEI 11-02 FOF scenario dispute resolution flowchart (ML25051A267) and provide feedback at a later public meeting. During the March 6, 2025,3 meeting the NRC provided detailed feedback on the flowchart. The staff is currently working with you to schedule the next series of public meetings to further dialogue on these important inspection guidance elements.
During these meetings, you expressed the desire to finalize NEI 11-02 in a timeframe that supports implementation in January 2026. The staff benefitted from the discussions and feedback received during the public meetings and is committed to reviewing NEI 11-02, Revision 1 once NEI submits the draft document to the NRC. The timeline for finalizing NEI-11-02, Revision 1, will depend on when the NRC receives the initial draft from NEI and timely comment resolution of any comments that the NRC staff may have.
1 Summary of November 13, 2024, Meeting with External Stakeholders on the updated Force-on-Force Escalation Process (Revision 1), Industry Improvements to Force-on-Force Guidance, and Feedback on Inspection Procedure 71130.03, dated December 30, 2024 (ML24345A057).
2 Summary of Public Meeting on Early Warning Systems and NEI Guidance Document 11-02, held December 12, 2024, dated January 22, 2025 (ML25017A195).
3 Summary of Public Meeting on Pre-Submittal of Nuclear Energy Institute (NEI) 11-02, Change Management Plan for Evaluated Force-On-Force Exercises, dated March 19, 2025 (ML25077A310).
March 25, 2025
M. Whitlock 2
We appreciate your engagement on these matters and your willingness to meet in public forums to discuss planned changes. Please contact Becca Lagios at rebecca.lagios@nrc.gov if you have any additional questions or concerns.
Sincerely, Tara Inverso, Director Division of Security Operations Office of Nuclear Security and Incident Response Signed by Inverso, Tara on 03/25/25
Ltr ML25069A010 OFFICE NSIR/DPCP NSIR/DSO/SOSB NSIR/DSO/SPEB
/ETA NSIR/DSO NAME RLagios DDavis JClark TInverso BYip for DATE Mar 11, 2025 Mar 11, 2025 Mar 11, 2025 Mar 17, 2025 OFFICE NSIR NSIR/DSO NAME CErlanger TInverso DATE Mar 25, 2025 Mar 25, 2025