SECY-17-0100, VR-COMSECY-19-0006: Revised Security Inspection Program Framework (Option 3) in Response to SRM-SECY-17-0100 (Wright)
| ML24136A094 | |
| Person / Time | |
|---|---|
| Issue date: | 05/14/2024 |
| From: | David Wright NRC/OCM |
| To: | Carrie Safford NRC/SECY |
| Shared Package | |
| ML24136A090 | List: |
| References | |
| COMSECY-19-0006 VR-COMSECY-19-0006 | |
| Download: ML24136A094 (1) | |
Text
RESPONSE SHEET TO:
Carrie M. Safford, Secretary FROM:
Commissioner Wright
SUBJECT:
COMSECY-19-0006: Revised Security Inspection Program Framework (Option 3) in Response to SRM-SECY-17-0100 Approved X Disapproved Abstain Not Participating COMMENTS:
Below Attached X
None Signature Entered in STARS Yes X
No David A.
Wright Digitally signed by David A.
Wright Date: 2024.05.14 12:36:03 -04'00'
Commissioner Wrights Comments on COMSECY-19-0006, Revised Security Inspection Program Framework (Option 3) in Response to SRM-SECY-17-0100 I appreciate the staffs systematic and comprehensive response to the Commissions direction in SRM-SECY-17-0100. I approve the staffs proposed framework for a revised baseline security inspection program, which includes one NRC-conducted force-on-force (FoF) exercise, an enhanced NRC inspection of a licensee-conducted annual FoF, and guidance for addressing an indeterminate outcome from an NRC-conducted FoF exercise.
The proposed changes to the inspection procedures for both NRC and licensee conducted FoF exercises are well-reasoned and should improve the effectiveness, reliability, and efficiency of the program. For example, the proposed approach will use a simplified significance determination process in evaluating ineffective exercises. This approach is supported by analysis, appropriately recognizes the inherent artificiality in FoF exercises, and should reduce the possibility of aggregated findings resulting in unnecessary escalated enforcement actions.
The staff should continue to engage with stakeholders on the viability of eliminating the characterization of exercise outcomes given the ambiguity that arises from indeterminate and ineffective outcomes. The focus of any outcome should be on ensuring that licensees take appropriate corrective actions to ensure the effectiveness of their protective strategies.
Finally, the staff has concluded that licensees could use their own MILES equipment during NRC-conducted FoF exercises if the equipment met NRC standards for safety, equipment technology, maintenance, and testing. As discussed in the paper, the industry views the development of these standards as unnecessary and prefers to continue using NRC-provided MILES equipment for the time being. Therefore, I support the staffs plan to defer any further work in this area at this time. Given the importance of the safety features present in the current NRC-issued equipment, any future work related to this issue should ensure that these, or comparable, safety features remain in place. The enhanced guidance incorporated into the inspection procedures is a good first step.