ML19200A238

NEI Presentation for Risk Informing Security Public Meeting July 23 2019

ML19200A238
Person / Time
Site:	Nuclear Energy Institute
Issue date:	07/19/2019
From:	Nuclear Energy Institute
To:	Office of Nuclear Security and Incident Response
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Download: ML19200A238 (8)

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Risk-Informing Physical and Cyber Security Programs J U LY 2 3 , 2 0 1 9

Review of Principles Where used in 10 CFR 73.55 and related guidance, the concept of high assurance of adequate protection is equivalent to reasonable assurance All outcomes of the process must ensure that reasonable assurance of adequate protection is maintained

• Conclusion should be made considering overall capabilities of the physical protection program, rather than an individual program component Regulatory standards already include appropriate margin that the Commission deemed necessary to provide for adequate protection; there is no requirement for additional margin beyond these regulatory standards ©2018 Nuclear Energy Institute 2

Review of Principles Risk-informing criteria and processes should reflect realism Performance-based approaches and data are preferred Approaches will likely use qualitative and semi-quantitative analyses as quantitative data may not be available or feasible to produce Decisions may consider insights from safety and engineering assessments, and capabilities described in the facility licensing basis

©2018 Nuclear Energy Institute 3

Physical Security - Tier 1 (July 19, 2019)

Tier 1 Projects

• Revision to Section 21 of NEI 03-12, Security Plan Template NRC endorsed risk-based methodology to identify implementation of Compensatory Measures Implementation Workshop (June 25-27)

Next Steps

• Revision to NEI 09-05, Guidance on Unattended Openings Closed meeting on July 23 Employing realism and consideration of three-dimensional unattended opening testing conducted by Sandia National Labs

©2018 Nuclear Energy Institute 4

Physical Security - Tier 1 (July 19, 2019)

Tier 1 (continued)

• Regulatory Guide 5.81, Target Set Identification and Development Comments distributed to NRC on July 1

• Criterion 3 of RG 5.81 and Adversary Timelines Industry team in process of review of NUREG-7145, Security Assessment Guide Specific focus pertaining interdiction, delay, and neutralization

©2018 Nuclear Energy Institute 5

Physical Security - Tier 2 (July 19, 2019)

Tier 2

• Gain efficiencies through flexible post staffing and rotation requirements

• Gain efficiencies by basing security equipment surveillance/testing activities on performance and reliability data (i.e., not prescriptive requirements)

• Review of previous Delivering the Nuclear Promise initiatives Team Meeting on July 24

©2018 Nuclear Energy Institute 6

Cyber Security - Tier 1 and 2 (July 19, 2019)

Tier 1

• Qualitative risk-informing considerations in cyber security:

Transforming the NRC cyber security inspection process Right-sizing cyber security scoping of CDAs and cyber security controls Revision to cyber security guidance, as appropriate Tier 2

• Changes to the cyber security rule, consistent with NEIs petition for rulemaking

©2018 Nuclear Energy Institute 7

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