ML25139A312

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NRC Security Status Update for the Advance Act Section 507
ML25139A312
Person / Time
Issue date: 05/21/2025
From: Jeremiah Rey
NRC/NSIR/DSO/SOSB
To:
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Download: ML25139A312 (1)
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NRC Security Status Update for the ADVANCE Act Section 507 May 21, 2025

Security Response to Section 507 of the ADVANCE Act:

In response to Section 507 of the ADVANCE ACT, the Office of Nuclear Security and Incident Response (NSIR) conducted a thorough review and assessment of the physical and cybersecurity oversight and inspection program to identify efficiencies, eliminate redundancies, and standardize routine processes while ensuring a risk-informed, performance-based approach to security oversight and inspection functions.

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Status of Security Initiatives for Operating Reactors 3

NSIR Oversight and Inspection Initiative 1 for Operating Rx

  • Revise the inspection frequency for IP 71130.07 Security Training from biennial to triennial.
  • Implementation: Start of 10th ROP triennial cycle CY 2026
  • Link to ADVANCE Act: Travel resources, inspection planning/preparation, use of technology/data, preparation/documentation time (Section 507 (d)(1)(A), (B), and (C))

4

NSIR Oversight and Inspection Initiative 2 for Operating Rx

  • Perform a risk-informed evaluation of all inspection requirements in security baseline IPs to validate prioritization (i.e., Tier I, II, and III)
  • Minimum samples will constitute procedure completion.
  • Status: In progress - IP revisions are underway.
  • Implementation: January 2026
  • Link to ADVANCE Act: Risk-inform procedures, balance level of resources with safety significance, review inspection resources based on licensee performance (Section 507 (d)(3)(A) and (B))

5

Industry Proposed Initiative 6

  • Apply risk-informed and performance-based principles.

Prioritize and scope each inspection to be commensurate with risk and licensee performance, considering previous inspection findings, performance indicators, and corrective action program reviews.

  • Aligns with NSIR initiative 1 and 2 Inspection frequency and risk informed evaluation
  • NRC Evaluation: Accepted for implementation
  • Status: In progress
  • Implementation: January 2026

NSIR Oversight and Inspection Initiative 3 for Operating Rx

  • Develop an inspection schedule for security baseline inspections to reduce travel costs and maximize time on-site.

For instance, IPs 71130.02,.05, and.14 would be inspected during the same week, possibly reducing two additional trips to the site.

  • Status: In progress
  • Implementation: CY 2027 Inspection schedules and licensee drill dates are already developed for CY 2026.

This timeline will allow the regions to coordinate with licensees.

  • Link to ADVANCE Act: Travel resources, inspection preparation/documentation time, documentation collection time (Section 507 (d)(1)(A),(B)and (C))

7 IP 71130.02-Access Control IP 71130.05-Protective Strategy Evaluation and Performance Evaluation Program IP 71130.14-Review of Power Reactor Target Sets

Industry Proposed Initiative 8

  • Optimize the use of fleet-level inspections.
  • Aligns with NSIR Initiative 3 Inspection schedule
  • NRC Evaluation: Accepted for implementation
  • Status: Not started For inspections that involve the corporate office, the region will coordinate inspections with the site and corporate office to maximize resources and reduce duplicate effort.

Industry Proposed Initiative 9

  • Re-allocate inspection resources to gain efficiencies in travel resources.

Assess current inspection scope for the resident inspectors, region, and headquarters and divide the scope to gain efficiency (e.g., target sets, lock and key, evaluated Force on Force).

  • Aligns in part with NSIR Initiative 3 Inspection schedule
  • NRC Evaluation: Accepted in part for implementation
  • Status: In progress This initiative will be implemented in part by creating efficiencies though the scheduling and resources of inspections.

Example: Resident inspectors who are target set qualified, may conduct that inspection thus reducing travel resources.

Inspectors must hold qualifications for the program area they inspect.

NSIR Oversight and Inspection Initiative 4 for Operating Rx 10

  • Develop a standard request for information template for each IP.
  • Status: Complete - Templates have been developed for each IP
  • Implementation: Effective July 1, 2025, and January 1, 2026
  • Link to ADVANCE Act: Inspection Preparation/documentation time, documentation collection time (Section 507 (d)(1)(B)and (C))

July 1, 2025 January 1, 2026 71130.01 - Access Authorization 71130.03 - Contingency Response Force-on-Force Testing 71130.02 - Access Control 71130.04 - Equipment Performance, Testing, and Maintenance 71130.05 - Protective Strategy Evaluation and Performance Evaluation Program 71130.07 - Security Training 71130.08 - Fitness-for-Duty 71130.14 - Review of Power Reactor Target Sets

Industry Proposed Initiative 11

  • Standardize requests for information to support baseline inspection activities.
  • Aligns with NSIR Initiative 4 Request for information template
  • NRC Evaluation: Accepted for implementation
  • Status: In progress
  • Implementation: July 1, 2025, and January 1, 2026

NSIR Oversight and Inspection Initiative 5 for Operating Rx 12

  • Status: Completed-Revisions have been made to associated IMCs
  • Implementation: May 2025
  • Link to ADVANCE Act: Level of resources commensurate with the safety significance (Section 507 (d)(3)(A))

NSIR Oversight and Inspection Initiative 6* for Operating Rx 13

Reduces inspection procedure (IP) 71130.03 Force-on-Force (FOF) inspection program from 2 NRC conducted exercises to 1 exercise.

Reduction of hours in IP 71130.03 from 393 hours0.00455 days <br />0.109 hours <br />6.498016e-4 weeks <br />1.495365e-4 months <br /> to 275 hours0.00318 days <br />0.0764 hours <br />4.546958e-4 weeks <br />1.046375e-4 months <br />.

  • SRM was underway prior to the ADVANCE Act; implementation will incorporate the ADVANCE Act goals.

Incorporated additional enhancements to eliminate inspection redundancies, enhance guidance for inspection planning and performance, reduce impact of licensee and NRC resources.

  • Commission Approval Received

NSIR Oversight and Inspection Initiative 6* for Operating Rx (cont.)

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  • Status: In progress-revisions to the inspection procedures are close to completion.
  • Implementation: January 1, 2026, Start of Triennial FOF Cycle 9
  • Link to ADVANCE Act: Travel resources, inspection planning/preparation, preparation/documentation time, elimination of duplicative activities (Section 507 (d)(1)(A), (B), and (C) and (d)(2)(A))

Industry Proposed Initiative 15

  • Review inspection procedures and eliminate duplicative inspection requirements.

71130.03 and 71130.05

  • NRC Evaluation: Accepted for implementation
  • Status: In progress-revisions to the inspection procedures are close to completion.
  • Implementation: January 2026

Industry Proposed Initiative 16

  • Credit for licensee performance during force-on-force inspections.

Implement an inspection model like the emergency preparedness (EP) evaluated exercises as an approach to demonstrate reasonable assurance in FOF inspections if a licensees baseline performance warrants (e.g., no action matrix movement due to security performance).

  • NRC Evaluation: Accepted in part for implementation.

All FOF related exercise performance deficiencies will screen as green, thus no action matrix movement.

Implementation of EP model is not within the existing Commission direction outlined in SRM-COMSECY-19-0006.

NEI provided a letter to NSIR proposing an EP-like approach for scenario development. As a next step, NSIR will conduct a public meeting to discuss the specifics of the proposal.

  • Status: Complete
  • Implementation: January 1, 2026

NSIR Oversight and Inspection Initiative 7* for Operating Rx 17

  • Status: In progress-draft BSSDP is being developed.

Commission approval required. On track to submit a SECY paper in October 2025. A public meeting will be conducted in late spring 2025 to provide an update.

  • Implementation: TBD pending Commission approval
  • Link to ADVANCE Act: Risk-informed, performance-based assessment, preparation/documentation time, inspection approach with the level of resources commensurate with safety significance (Section 507 (d)(1)(B),

(C), and (3)(A))

  • Commission Approval Required

Industry Proposed Initiative 18

  • Simplify the BSSDP for power reactors.
  • NRC Evaluation: Accepted for implementation
  • Status: In progress, on track for the SECY to go to the Commission in October 2025.
  • Implementation: TBD

NSIR Oversight and Inspection Initiative 8 for Operating Rx 19

  • Enhance the Security Issues Forum (SIF) process.
  • Status: In progress, draft SIF Charter has been developed, will be issued in July 2025.
  • Implementation: July 2025
  • Link to ADVANCE Act: Improve oversight and inspections (Section 507 (d)(2))

NSIR Oversight and Inspection Initiative 9 for Operating Rx 20

  • Removed IP 71130.06 Protection of Safeguards Information from the baseline inspection program and placed it in IMC 2201, Appendix C, Generic, Special, and Infrequent Inspections.
  • Status: Complete
  • Implementation: September 1, 2024, and redesignated as IP 81822
  • Link to ADVANCE Act: Improve oversight and inspections (Section 507 (d)(2)(A))

NSIR Oversight and Inspection Initiative 10 for Operating Rx 21 Cybersecurity Inspection

  • Evaluate the inspection frequency and resources.
  • Revise the inspection procedure (IP) and request for information (RFI) document.
  • Use of risk informed principles for sampling as much as possible.
  • Streamline/reduce amount of information requested for inspections.

NSIR Oversight and Inspection Initiative 10 for Operating Rx (cont.)

22 Status:

  • Final stages of the evaluation to determine the inspection frequency and resources.

Implementation: January 2026

  • Link to ADVANCE Act: Improve oversight and inspections (Section 507 (d)(2)(A))

Industry Proposed Initiative 23

  • Revise the cybersecurity inspection procedure to reflect the maturity of licensee programs.
  • Aligns with NSIR Initiative 10
  • NRC Evaluation: Accepted for revision
  • Status:

- IP 71130.10 currently under revision (risk-informed sampling, inspection requirements guidance).

- RFI: Evaluation of proposed ideas to achieve effectiveness and use of modern tools to reduce amount of information requested.

  • Implementation: January 2026

Industry Proposed Initiative 24

  • Credit existing performance indicators (PI) for inspection efficiencies.

Remove inspection elements that are already being assessed with PIs.

  • Aligns with an NRR initiative for Section 507 of the ADVANCE Act
  • NRC Evaluation: Accepted
  • Status: In progress, working group has been established.

Public meeting scheduled for June 5, 2025.

  • Implementation: TBD

Industry Proposed Initiative 25

  • Revisions to the blind testing program included in SECY-24-0058, Rulemaking Plan on Drug and Alcohol Testing: Technical Issues and Editor Changes.
  • Status: In progress, plan submitted to the Commission in July 2024
  • Implementation: TBD

Industry Proposed Initiative 26

  • Augment current urine testing with oral fluid testing for all testing conditions.
  • Aligns with SECY-24-0058, Rulemaking Plan on Drug and Alcohol Testing:

Technical Issues and Editor Changes.

  • Status: In progress, plan submitted to the Commission in July 2024
  • Implementation: TBD

Industry Proposed Initiative 27

  • Redefine the minor/more-than-minor threshold.
  • Aligns with the NRR initiative for Section 507 of the ADVANCE Act.
  • Evaluation: Accepted
  • Status: In progress
  • Implementation: 1st Quarter 2026

Industry Proposed Initiative 28

  • Optimize qualifications for armed response force member that continue to meet the reasonable assurance standard.

Consider NEI Annual FOF Exercise Whitepaper

  • NRC Evaluation: Complete NEI provided for the whitepaper to the NRC for information only, not approval.
  • Status: Concerns with regulatory compliance were communicated during a public meeting on 3/27/25. Currently, with NEI to decide path forward.
  • Implementation: TBD

Status of Security Initiatives for Fuel Cycle Facilities 29

NSIR Oversight and Inspection Initiative 1 for Fuel Cycle Facilities 30

  • Evaluate all CAT I physical security IPs to identify and remove any redundancies.
  • Evaluate the combination and elimination of three protective strategy-specific IPs.

Keep IPs 81700.05 and 81700.11.

Eliminate IP 81700.06.

Disperse elements of IP 81700.06 into 81700.05 and 81700.11.

  • Status: In progress-revisions are underway to associated IPs
  • Link to ADVANCE Act: Reduction in inspection effort (20+ hours),

preparation/documentation and reduce travel costs. (Section 507 (d)(1)(A), (B), (C) and (d)(2)(A))

IP 81700.05, Category I Fuel Cycle Facility Physical Protection and Protective Strategy IP 81700.06, Licensee Conducted Force-on-Force Exercises at Category I Fuel Cycle Facilities IP 81700.11, Annual Observation of Licensee Conducted Force-on-Force Exercises at Category I Fuel Cycle Facilities

NSIR Oversight and Inspection Initiative 2 for Fuel Cycle Facilities 31

  • Redesignate IP 81700.10 Safeguards Information (SGI) to an as needed IP.
  • Status: In progress-revisions are underway to the associated IPs
  • Link to ADVANCE Act: Improve oversight and inspections, eliminate duplicative activities (Section 507 (d)(2)(A))

NSIR Oversight and Inspection Initiative 3 for Fuel Cycle Facilities 32

  • Revise template language in the reactor program system (RPS) for CAT I fuel facilities to align with power reactor template language for physical security reports.
  • Status: In progress-revision underway
  • Implementation: June 2025
  • Link to ADVANCE Act: Increase use of templates in documentation (Section 507 (d)(2)(B))

NSIR Oversight and Inspection Initiative 4 for Fuel Cycle Facilities 33

  • Revise IMC 0616, Fuel Cycle Safety and Safeguards Inspection Reports to include language that would allow physical security inspection reports to contain different information than non-security reports.
  • Status: Complete-revisions have been made to IMC 0616
  • Implementation: June 2025
  • Link to ADVANCE Act: Increase use of templates in documentation (Section 507 (d)(2)(B))

Questions?

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