ML16125A063
| ML16125A063 | |
| Person / Time | |
|---|---|
| Site: | Nuclear Energy Institute |
| Issue date: | 05/03/2016 |
| From: | Michael Layton Division of Security Operations |
| To: | Kline D Nuclear Energy Institute |
| M Ralph | |
| Shared Package | |
| ML16125A051 | List: |
| References | |
| Download: ML16125A063 (3) | |
Text
From: Layton, Michael Sent: Tuesday, May 03, 2016 12:03 PM To: KLINE, Dave <dk@nei.org>
Cc: Pretzello, Andrew <Andrew.Pretzello@nrc.gov>; Way, Ralph <Ralph.Way@nrc.gov>; Ralph, Melissa
<Melissa.Ralph@nrc.gov>; Holian, Brian <Brian.Holian@nrc.gov>; West, Steven <Steven.West@nrc.gov>
Subject:
RE: Industry Comments on Draft Response to SRM Addressing SECY 14-088 Thank you.
Our Recommendations Report is purposely written as a publically available document to support the Commissions open dialog on the topic. I see that your comments on the public document are marked security related information. Would you take another look at the content of your letter and determine whether it is sensitive, providing potentially unearned information? If it does not, would you provide confirmation that we may make the letter publically available?
Many thanks, MCL Michael Layton, Director Division of Security Operations Office of Nuclear Security And Incident Response 301-287-3664 From: KLINE, Dave [1]
Sent: Tuesday, May 03, 2016 11:38 AM
Subject:
[External_Sender] Industry Comments on Draft Response to SRM Addressing SECY 14-088 SECURITY RELATED INFORMATION - WITHHOLD UNDER 10 CFR 2.390 THE ATTACHED PDF FILE CONTAINS COMPLETE CONTENTS OF THE LETTER May 3, 2016 Mr. Michael C. Layton Director, Division of Security Operations Office of Nuclear Security and Incident Response U.S. Nuclear Regulatory Commission Washington, DC 20555-0001
Subject:
Industry Comments on Draft Response to SRM Addressing SECY 14-088 Project Number: 689
Dear Mr. Layton:
On behalf of the nuclear energy industry, the Nuclear Energy Institute (NEI) appreciates the opportunity to comment on the NRC Security Working Group Response to Staff Requirements Memorandum (SRM) SECY-14-088. The industry has identified six areas for comment:
Composite Adversary Force (CAF) tactics, techniques, and procedures; mock adversary training and qualification standards; controller training and qualification standards; post exercise critique guidance; mission planning training and qualification standards; and Operational Experience (OE) sharing.
Regarding Composite Adversary Force (CAF) tactics, techniques, and procedures, the first paragraph on page two states in part, the working group did not identify gaps between the TTPs used by the NRC CAF during FOF exercises and the methods used in real-life adversary training and actual attacks. This finding is again stated in the first paragraph on page four of the letter. The report also contains a table at the bottom of page three to illustrate this point; however, the table identifies attributes at such a high level that it provides no useful comparison to the clear meaning of the attribute and the tactics employed by the CAF. To the contrary, the industry has raised concerns when there have been attempts to introduce tactics, techniques, or procedures not supported by any intelligence provided to the industry. In some cases, the proposed tactics or techniques were unlikely to produce effective and repeatable results and we do not think that they would be considered by a planner.
David R. Kline Director, Security Nuclear Energy Institute 1201 F Street NW, Suite 1100 Washington, DC 20004 www.nei.org P: 202-739-8174 F: 202-533-0137 E: dk@nei.org