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| | issue date = 09/06/2017 | | | issue date = 09/06/2017 |
| | title = NRC Appeal Response to Davis-Besse Force on Force Disputed Item 05000346/2017201-01 and Disputed Item 05000346/2017201-02 | | | title = NRC Appeal Response to Davis-Besse Force on Force Disputed Item 05000346/2017201-01 and Disputed Item 05000346/2017201-02 |
| | author name = Bailey M G | | | author name = Bailey M |
| | author affiliation = NRC/NSIR/DSO | | | author affiliation = NRC/NSIR/DSO |
| | addressee name = Ellis J D | | | addressee name = Ellis J |
| | addressee affiliation = - No Known Affiliation | | | addressee affiliation = - No Known Affiliation |
| | docket = 05000346 | | | docket = 05000346 |
Line 14: |
Line 14: |
| | page count = 3 | | | page count = 3 |
| }} | | }} |
| See also: [[followed by::IR 05000346/2017201]] | | See also: [[see also::IR 05000346/2017201]] |
|
| |
|
| =Text= | | =Text= |
| {{#Wiki_filter:SAFEGUARDS INFORMATION SAFEGUARDS INFORMATION | | {{#Wiki_filter:SAFEGUARDS INFORMATION |
| September 6, 2017
| | September 6, 2017 |
|
| | Mr. James D. Ellis |
|
| | Director, Fleet Security Program |
| Mr. James D. Ellis Director, Fleet Security Program
| | 341 White Pond Drive |
| 341 White Pond Drive | | Mail Stop: A-WAC-B1 |
| Mail Stop: A-WAC-B1 | | Akron, OH 44320 |
| Akron, OH 44320 SUBJECT: RESPONSE TO YOUR APPEAL OF THE FORMAL DISAGREEMENT WITH ADVERSARY CHARACTERISTICS, ATTRIBUTES, OR TACTICS EMPLOYED | | SUBJECT: RESPONSE TO YOUR APPEAL OF THE FORMAL DISAGREEMENT WITH |
| OR PREPARED AS PART OF AN NRC-EVALUATED FORCE-ON-FORCE | | ADVERSARY CHARACTERISTICS, ATTRIBUTES, OR TACTICS EMPLOYED |
| EXERCISE - DISPUTED ITEM 05000346/2017201-01 AND 05000346/2017201-02 Dear Mr. Ellis: | | OR PREPARED AS PART OF AN NRC-EVALUATED FORCE-ON-FORCE |
| The Division of Security Operations (DSO) has received your letter, dated September 1, 2017, appealing the U.S. Nuclear Regulatory Commission (NRC) staff's decision to continue to use two tactics, techniques, or procedures (TTP) planned for the Davis-Besse force-on-force exercise. Your original dispute was submitted on August 29, 2017, and the NRC staff's initial decision was issued on August 31, 2017. | | EXERCISE - DISPUTED ITEM 05000346/2017201-01 AND |
|
| | 05000346/2017201-02 |
| In your original submittals, you disputed a TTP within Scenario 1 and 2 developed by the NRC force-on-force inspection team. I have carefully reviewed your appeal to the initial decision, and concluded that the disputed TTP is approved for use within the NRC-evaluated scenario for the following reasons: (1) it is within the design basis threat, (2) it is supported by available data, | | Dear Mr. Ellis: |
| (3) it is within your ability to provide defense-in-depth, (4) it can be safely performed and | | The Division of Security Operations (DSO) has received your letter, dated September 1, 2017, |
| controlled, and (5) it provides a credible and realistic challenge to your site's protective strategy. | | appealing the U.S. Nuclear Regulatory Commission (NRC) staffs decision to continue to use |
| The NRC's detailed response to your appeal has been entered into the NRC Response to Disputed Item Database, Disputed Item 05000346/2017201-01 and Disputed Item
| | two tactics, techniques, or procedures (TTP) planned for the Davis-Besse force-on-force |
| 05000346/2017201-02, and is provided as an Enclosure to this letter, marked Safeguards | | exercise. Your original dispute was submitted on August 29, 2017, and the NRC staffs initial |
| Information. The enclosure transmitted herewith contains Safeguards Information. When separated from the enclosure, this transmittal document is decontrolled. | | decision was issued on August 31, 2017. |
| SAFEGUARDS INFORMATION J. Ellis 2 SAFEGUARDS INFORMATION Upon notification by Robert Johnson, Branch Chief, Security Performance Evaluation Branch, DSO, of the NRC's decision that the disputed TTP was approved for use, you requested to
| | In your original submittals, you disputed a TTP within Scenario 1 and 2 developed by the NRC |
| appeal the decision to me. I received your appeal via e-mail on September 5, 2017. After
| | force-on-force inspection team. I have carefully reviewed your appeal to the initial decision, and |
| further discussion, the NRC carefully reevaluated your dispute and determined that the disputed
| | concluded that the disputed TTP is approved for use within the NRC-evaluated scenario for the |
| item is still appropriate for use in an NRC-evaluated force-on-force exercise. Sincerely, /RA/
| | following reasons: (1) it is within the design basis threat, (2) it is supported by available data, |
| Marissa G. Bailey, Director
| | (3) it is within your ability to provide defense-in-depth, (4) it can be safely performed and |
| Division of Security Operations
| | controlled, and (5) it provides a credible and realistic challenge to your sites protective strategy. |
| Office of Nuclear Security and Incident Response
| | The NRCs detailed response to your appeal has been entered into the NRC Response to |
| Enclosure:
| | Disputed Item Database, Disputed Item 05000346/2017201-01 and Disputed Item |
| NRC Response to Disputed Item
| | 05000346/2017201-02, and is provided as an Enclosure to this letter, marked Safeguards |
| 05000346/2017201-01 and 05000346/2017201-02
| | Information. |
|
| | The enclosure transmitted herewith contains Safeguards Information. When separated |
| cc w/enclosure: William Willis, Manager, Site Security
| | from the enclosure, this transmittal document is decontrolled. |
| SAFEGUARDS INFORMATION J. Ellis 3 SAFEGUARDS INFORMATION SUBJECT: RESPONSE TO YOUR APPEAL OF THE FORMAL DISAGREEMENT WITH ADVERSARY CHARACTERISTICS, ATTRIBUTES, OR TACTICS EMPLOYED | | SAFEGUARDS INFORMATION |
| OR PREPARED AS PART OF AN NRC-EVALUATED FORCE-ON-FORCE
| |
| EXERCISE - DISPUTED ITEM 05000346/2017201-01 AND
| |
| 05000346/2017201-02 DATE: SEPTEMBER 6, 2017
| |
| DISTRIBUTION: K. Riemer, DRS, RIII
| |
| ADAMS Accession No. ML17249A406 OFFICE NSIR/DSO/SPEB NSIR/DSO/SPEB NSIR/DSO NAME J. Berry C. Johnson M. Bailey DATE 9/ 6 /17 9 / 6 /17 9 / 6 /17 OFFICIAL RECORD COPY
| |
|
| |
|
| | SAFEGUARDS INFORMATION |
| | J. Ellis 2 |
| | Upon notification by Robert Johnson, Branch Chief, Security Performance Evaluation Branch, |
| | DSO, of the NRCs decision that the disputed TTP was approved for use, you requested to |
| | appeal the decision to me. I received your appeal via e-mail on September 5, 2017. After |
| | further discussion, the NRC carefully reevaluated your dispute and determined that the disputed |
| | item is still appropriate for use in an NRC-evaluated force-on-force exercise. |
| | Sincerely, |
| | /RA/ |
| | Marissa G. Bailey, Director |
| | Division of Security Operations |
| | Office of Nuclear Security and Incident Response |
| | Enclosure: |
| | NRC Response to Disputed Item |
| | 05000346/2017201-01 and 05000346/2017201-02 |
| | cc w/enclosure: William Willis, Manager, Site Security |
| | SAFEGUARDS INFORMATION |
| | |
| | |
| | ML17249A406 |
| | OFFICE NSIR/DSO/SPEB NSIR/DSO/SPEB NSIR/DSO |
| | NAME J. Berry C. Johnson M. Bailey |
| | DATE 9/ 6 /17 9 / 6 /17 9 / 6 /17 |
| }} | | }} |
|
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Category:Letter
MONTHYEARIR 05000346/20243012024-02-0202 February 2024 NRC Initial License Examination Report 05000346/2024301 IR 05000346/20230042024-01-31031 January 2024 Integrated Inspection Report 05000346/2023004 ML23313A1352024-01-17017 January 2024 Authorization and Safety Evaluation for Alternative Request RP 5 for the Fifth 10 Year Interval Inservice Testing Program ML23353A1192023-12-19019 December 2023 Operator Licensing Examination Approval Davis Besse Nuclear Power Station, January 2024 L-23-260, Corrections to the 2022 Combined Annual Radiological Environmental Operating Report and Radioactive Effluent Release Report for the Davis-Besse Nuclear Power Station2023-12-0707 December 2023 Corrections to the 2022 Combined Annual Radiological Environmental Operating Report and Radioactive Effluent Release Report for the Davis-Besse Nuclear Power Station L-23-243, Independent Spent Fuel Storage Installation - Request for Exemption from Enhanced Weapons, Firearms Background Checks, and Security Event Notifications Implementation2023-12-0606 December 2023 Independent Spent Fuel Storage Installation - Request for Exemption from Enhanced Weapons, Firearms Background Checks, and Security Event Notifications Implementation ML23338A3172023-12-0606 December 2023 Notification of NRC Baseline Inspection and Request for Information; Inspection Report 05000346/2024001 IR 05000346/20234032023-11-0202 November 2023 Security Baseline Inspection Report 05000346/2023403 ML23293A0612023-11-0101 November 2023 Letter to the Honorable Marcy Kaptur, from Chair Hanson Responds to Letter Regarding Follow Up on Concerns Raised by Union Representatives During the June Visit to the Davis-Besse Nuclear Power Plant L-23-215, Changes to Emergency Plan2023-10-19019 October 2023 Changes to Emergency Plan ML23237B4222023-09-28028 September 2023 Energy Harbor Nuclear Corp. - Vistra Operations Company LLC - Letter Regarding Order Approving Transfer of Licenses and Draft Conforming License Amendments ML23269A1242023-09-27027 September 2023 Request for Withholding Information from Public Disclosure IR 05000346/20234012023-09-13013 September 2023 Security Baseline Inspection Report 05000346/2023401 (Public) L-23-205, Supplement to Application for Order Consenting to Transfer of Licenses and Conforming License Amendments2023-09-12012 September 2023 Supplement to Application for Order Consenting to Transfer of Licenses and Conforming License Amendments L-23-172, Quality Assurance Program Manual2023-08-31031 August 2023 Quality Assurance Program Manual IR 05000346/20230112023-08-30030 August 2023 Biennial Problem Identification and Resolution Inspection Report 05000346/2023011 ML23129A1722023-08-25025 August 2023 Request for Withholding Information from Public Disclosure for Beaver Valley Power Station, Units 1 and 2; Davis Besse Nuclear Power Station, Unit 1; and Perry Nuclear Power Plant, Unit 1 IR 05000346/20230052023-08-24024 August 2023 Updated Inspection Plan for Davis-Besse Nuclear Power Station (Report 05000346/2023005) L-23-188, Energy Harbor Nuclear Corp., Supplement to Application for Order Consenting to Transfer of Licenses and Conforming License Amendments2023-08-0707 August 2023 Energy Harbor Nuclear Corp., Supplement to Application for Order Consenting to Transfer of Licenses and Conforming License Amendments IR 05000346/20230502023-08-0303 August 2023 Special Inspection Report 05000346/2023050 IR 05000346/20230902023-08-0101 August 2023 EA-23-002 Davis-Besse Nuclear Power Station - NRC Inspection Report No. 05000346/2023090 (Public) ML23178A2742023-08-0101 August 2023 Letter to the Honorable Marcy Kaptur from Chair Hanson Responds to Letter Regarding the License Transfer Application for the Davis-Besse Nuclear Power Station L-23-175, Submittal of Fifth Ten Year Inservice Testing Program2023-08-0101 August 2023 Submittal of Fifth Ten Year Inservice Testing Program IR 05000346/20230022023-07-27027 July 2023 Integrated Inspection Report 05000346/2023002 ML23193A7842023-07-13013 July 2023 Information Request for the Cyber-Security Baseline Inspection, Notification to Perform Inspection 05000346/2023402 ML23178A2422023-06-28028 June 2023 Reassignment of the U.S. Nuclear Regulatory Commission Branch Chief in the Division of Operating Reactor Licensing for Plant Licensing Branch III ML23160A2342023-06-13013 June 2023 Confirmation of Initial License Examination L-23-034, 2022 Annual 10 CFR 50.46 Report of Changes to or Errors in Emergency Core Cooling System Evaluation Models2023-06-13013 June 2023 2022 Annual 10 CFR 50.46 Report of Changes to or Errors in Emergency Core Cooling System Evaluation Models IR 05000346/20235012023-06-13013 June 2023 Emergency Preparedness Biennial Exercise Inspection Report 05000346/2023501 L-23-135, Response to Regulatory Issue Summary 2023-01, Preparation and Scheduling of Operator Licensing Examinations2023-05-31031 May 2023 Response to Regulatory Issue Summary 2023-01, Preparation and Scheduling of Operator Licensing Examinations L-23-065, Annual Financial Report2023-05-22022 May 2023 Annual Financial Report ML23124A1742023-05-17017 May 2023 Energy Harbor Fleet Vistra License Transfer - Request for Withholding Information from Public Disclosure for Commance Peak Plant, Units 1 & 2, Beaver Valley Station, Units 1 & 2, Davis Besse Station, Unit 1 and Perry Plant, Unit 1 ML23129A0112023-05-16016 May 2023 Notice of Consideration of Approval of Indirect and Direct License Transfer for Comanche Peak Plant, Units 1 & 2, Beaver Valley Station, Units 1 & 2, Davis Besse Station, Unit 1 and Perry Plant, Unit 1 (EPID L-2023-LLM-0000) (Letter) ML23131A2732023-05-15015 May 2023 Notification of NRC Supplemental Inspection 95001 and Request for Information L-23-101, Combined Annual Radiological Environmental Operating Report and Radioactive Effluent Release Report for the Davis-Besse Nuclear Power Station - 20222023-05-12012 May 2023 Combined Annual Radiological Environmental Operating Report and Radioactive Effluent Release Report for the Davis-Besse Nuclear Power Station - 2022 L-23-131, Readiness for Resumption of NRC Supplemental Inspection2023-05-12012 May 2023 Readiness for Resumption of NRC Supplemental Inspection IR 05000346/20230102023-05-0909 May 2023 Commercial Grade Dedication Inspection Report 05000346/2023010 ML23123A1272023-05-0303 May 2023 Information Request to Support Upcoming Problem Identification and Resolution Inspection at Davis-Besse Nuclear Power Station IR 05000346/20230012023-05-0101 May 2023 Integrated Inspection Report 05000346/2023001 and 07200014/2022001 L-23-092, Occupational Radiation Exposure Report for Year 20222023-04-27027 April 2023 Occupational Radiation Exposure Report for Year 2022 ML23111A1972023-04-26026 April 2023 Information Meeting with Question and Answer Session to Discuss NRC 2022 End-of-Cycle Plant Performance Assessment of Davis-Besse Nuclear Power Plant Station ML23114A1062023-04-25025 April 2023 Information Request to Support the NRC Annual Baseline Emergency Action Level and Emergency Plan Changes Inspection CP-202300181, ISFSI, Beaver Valley, Units 1 and 2, ISFSI, Davis-Besse, Unit 1, ISFSI, Perry, Unit 1, ISFSI, Corrected Affidavit for Application for Order Consenting to Transfer of Licenses and Conforming License Amendments2023-04-20020 April 2023 ISFSI, Beaver Valley, Units 1 and 2, ISFSI, Davis-Besse, Unit 1, ISFSI, Perry, Unit 1, ISFSI, Corrected Affidavit for Application for Order Consenting to Transfer of Licenses and Conforming License Amendments CP-202300157, ISFSI, Beaver Valley, Units 1 and 2, ISFSI, Davis-Besse, Unit 1, ISFSI, Perry, Unit 1, and ISFSI, Application for Order Consenting to Transfer of Licenses and Conforming License Amendments2023-04-14014 April 2023 ISFSI, Beaver Valley, Units 1 and 2, ISFSI, Davis-Besse, Unit 1, ISFSI, Perry, Unit 1, and ISFSI, Application for Order Consenting to Transfer of Licenses and Conforming License Amendments ML23096A1382023-04-11011 April 2023 Review of the Spring 2022 Steam Generator Tube Inspection Report L-23-061, Submittal of the Decommissioning Funding Status Reports2023-03-31031 March 2023 Submittal of the Decommissioning Funding Status Reports L-23-037, and Perry Nuclear Power Plant - Independent Spent Fuel Storage Installation Changes, Tests, and Experiments2023-03-29029 March 2023 and Perry Nuclear Power Plant - Independent Spent Fuel Storage Installation Changes, Tests, and Experiments L-23-066, Annual Notification of Property Insurance Coverage2023-03-21021 March 2023 Annual Notification of Property Insurance Coverage ML23066A2892023-03-14014 March 2023 Request for Threshold Determination Under 10 CFR 50.80 and 10 CFR 72.50 for an Amendment to the Voting Agreement ML23066A2592023-03-14014 March 2023 Request for Withholding Information from Public Disclosure for Beaver Valley Power Station, Units 1 and 2, Davis Besse Nuclear Power Station, Unit 1, and Perry Nuclear Power Plant, Unit 1 2024-02-02
[Table view] |
See also: IR 05000346/2017201
Text
SAFEGUARDS INFORMATION
September 6, 2017
Mr. James D. Ellis
Director, Fleet Security Program
341 White Pond Drive
Mail Stop: A-WAC-B1
Akron, OH 44320
SUBJECT: RESPONSE TO YOUR APPEAL OF THE FORMAL DISAGREEMENT WITH
ADVERSARY CHARACTERISTICS, ATTRIBUTES, OR TACTICS EMPLOYED
OR PREPARED AS PART OF AN NRC-EVALUATED FORCE-ON-FORCE
EXERCISE - DISPUTED ITEM 05000346/2017201-01 AND
05000346/2017201-02
Dear Mr. Ellis:
The Division of Security Operations (DSO) has received your letter, dated September 1, 2017,
appealing the U.S. Nuclear Regulatory Commission (NRC) staffs decision to continue to use
two tactics, techniques, or procedures (TTP) planned for the Davis-Besse force-on-force
exercise. Your original dispute was submitted on August 29, 2017, and the NRC staffs initial
decision was issued on August 31, 2017.
In your original submittals, you disputed a TTP within Scenario 1 and 2 developed by the NRC
force-on-force inspection team. I have carefully reviewed your appeal to the initial decision, and
concluded that the disputed TTP is approved for use within the NRC-evaluated scenario for the
following reasons: (1) it is within the design basis threat, (2) it is supported by available data,
(3) it is within your ability to provide defense-in-depth, (4) it can be safely performed and
controlled, and (5) it provides a credible and realistic challenge to your sites protective strategy.
The NRCs detailed response to your appeal has been entered into the NRC Response to
Disputed Item Database, Disputed Item 05000346/2017201-01 and Disputed Item
05000346/2017201-02, and is provided as an Enclosure to this letter, marked Safeguards
Information.
The enclosure transmitted herewith contains Safeguards Information. When separated
from the enclosure, this transmittal document is decontrolled.
SAFEGUARDS INFORMATION
SAFEGUARDS INFORMATION
J. Ellis 2
Upon notification by Robert Johnson, Branch Chief, Security Performance Evaluation Branch,
DSO, of the NRCs decision that the disputed TTP was approved for use, you requested to
appeal the decision to me. I received your appeal via e-mail on September 5, 2017. After
further discussion, the NRC carefully reevaluated your dispute and determined that the disputed
item is still appropriate for use in an NRC-evaluated force-on-force exercise.
Sincerely,
/RA/
Marissa G. Bailey, Director
Division of Security Operations
Office of Nuclear Security and Incident Response
Enclosure:
NRC Response to Disputed Item
05000346/2017201-01 and 05000346/2017201-02
cc w/enclosure: William Willis, Manager, Site Security
SAFEGUARDS INFORMATION
ML17249A406
OFFICE NSIR/DSO/SPEB NSIR/DSO/SPEB NSIR/DSO
NAME J. Berry C. Johnson M. Bailey
DATE 9/ 6 /17 9 / 6 /17 9 / 6 /17