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| ML24345A057 | |
| Person / Time | |
|---|---|
| Issue date: | 12/30/2024 |
| From: | David Hostetter Security Performance Evaluation Branch |
| To: | |
| References | |
| Download: ML24345A057 (1) | |
Text
1 U.S. Nuclear Regulatory Commission Public Meeting Summary November 13, 2024
Title:
Staff discussion on the updated Force-on-Force (FOF) Escalation Process (Revision 1),
Industry Improvements to Force-on-Force Guidance, and Feedback on Inspection Procedure 71130.03.
Meeting Identifier: 20241225 Date and Time of Meeting: November 13, 2024, 11:00 AM ET Location: Webinar/OWFN Type of Meeting: Observation/Information Meeting Purpose of the Meeting(s): The purpose of this meeting was to discuss the Force-on-Force Escalation Process, Revision 1, Inspection Procedure 71130.03 and Industry Improvements to the Force-on-Force Program.
General Summary: The meeting began at 1100 a.m. ET. Following introductions and opening remarks, NSIR staff:
Provided a presentation describing FOF Escalation Process and potential changes to the document, which:
a.
Provided a high-level summary of the changes to the Force-on-Force Escalation Process, Revision 1.
b.
Described proposed changes to the timeline to help facilitate the industrys escalation submittals.
c.
Provided an the process for the NRC management to review the tactic and make a determination for the exercise scenario(s).
Following the presentation, NRC staff and NEI staff discussed the Force-on-Force program feedback to include:
Utilizing a point system (entry criteria) for FOF exercises.
Increasing licensee engagements throughout, but particularly in the case of a new scenario.
Increasing tools to licensees.
Removing the escalated item(s) from the scenario until the item is resolved.
Expanding the schedule between Planning and Exercise weeks.
Considering whether planned scenarios go beyond reasonable assurance Increasing realism within exercises.
During the closed portion, both the NRC staff and NEI staff discussed additional topics and will continue to engage in discussion as needed. The following discussion points will be followed up in a future meeting(s):
(1) Industry representatives indicated that exercise objectives need more clarity, and provided the following details to support their position:
2 a) Exercises need to have more security officer engagement b) Exercises should test just the licensee contingency response plan c)
Exercises should not test other programs that are tested within other procedures d) Industry and NRC should evaluate the information that is assumed to be available to the insider (2) Exercise complexity: Industry provided 2024 FOF exercise data sheet and discuss their perceived correlation between complex exercises and the number of escalations. Industry noted that excessive simulations can lead to an increase in disputed items.
a.
Industry noted that a point system could be useful in addressing exercise complexity (3) Scenario development:
a.
Industry would like to expand the Planning Week to have everything involving scenario development completed by the following Tuesday and/or Wednesday.
b.
Industry suggested that the mock adversary team lead could participate in a portion of the Planning week to avoid changes to the exercise just before Exercise week.
c.
Industry suggested having a back-up exercise developed in the event of an escalation.
(4) Industrys detailed feedback on the escalation process, which NEI will submit in a letter to NRC in the near-term:
a.
A process is needed to capture all disputes i.
Safety concerns ii.
Controller concerns iii.
Policy issues b.
Current process is condensed, in terms of levels of escalation from start to finish. NRC could consider different entities for the escalation and appeal.
NRC staff and NEI discussed a need for a follow-up meeting(s) in FY2025 on the following six (6) topics:
(1) Inspection Procedure 71130.03, 71130.05 (2) Additional Detailed Comments for the Escalation Process (3) Point System(s) for FOF exercises (4) FOF Realism (5) Change Management (6) NEI 05-05, NEI 03-12, NEI 11-02 In closing, NRC staff will continue to meet with external stakeholders in FY2025 for discussion on resolution to documented concerns.
The meeting was attended by 44 individuals, including security and program personnel from licensee sites, staff from NEI, NRC headquarters and regional personnel, and members of the
3 public. A list of attendees is included as an attachment to this meeting summary. The meeting ended at approximately 145 p.m. ET.
4 LIST OF ATTENDEES 11/13/2024 Discussion on the updated Force-on-Force Escalation Process (Revision 1), Industry Improvements to Force-on-Force Guidance, and Feedback on Inspection Procedure 71130.03 No.
Name Affiliation 1
Matthew Ford APS 2
Christopher Frasca Constellation 3
Steven Hayes Constellation 4
Chris Newton Duke Energy 5
John Cherubini Entergy 6
Jonathan LaPlante Entergy 7
Quincy Colstrom Evergy 8
Lance Link Evergy 9
William Gross NEI 10 Sue Perkins NEI 11 Michael Whitlock NEI 12 David Young NEI 13 Shawn Kirven PGE 14 Robert Zimkowski PGE 15 Charles Coles Stars Alliance 16 Jay Bodnar STP 17 David Berkenpas TVA 18 Edwin Lyman Union of Concerned Scientists 19 Kurt Gosney Xcel Energy 20 David Gerads Xcel Energy 21 Joshua Adams NRC 22 Joshua Berry NRC 23 David Bradfield NRC 24 Charles Bustamante NRC 25 Stephen Cavanaugh NRC 26 Jefferson Clark NRC 27 Chad Davis NRC 28 Desiree Davis NRC 29 Craig Erlanger NRC 30 David Hostetter NRC 31 Tara Inverso NRC 32 Travis Leach NRC 33 James Maltese NRC 34 Philip Negrete NRC 35 Michael Ordoyne NRC 36 Jeremiah Rey NRC
5 37 Joshua Rhodes NRC 38 Cliff Roundtree NRC 39 Steven Sarver NRC 40 Jeffrey Stovall NRC 41 Kevin Williams NRC 42 Joseph Willis NRC 43 Andrew Woyansky NRC 44 Brian Yip NRC
ML24345A057 OFFICE NSIR/DPCP/RSB NSIR/DSO/SPEB
/ETB NSIR/DSO/SPEB
/ETA NSIR/DSO NAME DHostetter JBerry JClark TInverso BYip for DATE Dec 10, 2024 Dec 10, 2024 Dec 10, 2024 Dec 30, 2024