ML20167A109
| ML20167A109 | |
| Person / Time | |
|---|---|
| Issue date: | 06/15/2020 |
| From: | Dante Johnson Security Performance Evaluation Branch |
| To: | |
| Johnson D | |
| References | |
| Download: ML20167A109 (29) | |
Text
Security Oversight for Nuclear Power Plants in Relation to the COVID-19 Public Health Emergency June 16, 2020
Purpose To discuss the considerations surrounding security oversight for nuclear power plants in relation to the COVID-19 Public Health Emergency (PHE).
Agenda NRC Response to PHE NRC Security Baseline Inspection Activities Considerations for Resuming Inspections Stakeholder Comments/Questions 2
NRC Response to PHE Exemptions/
enforcement discretion issued for regulations, including licensee training and qualification Assessing balance between flexibility and continuity to maintain reasonable Baseline Deferred FOF assurance inspections inspections; (remote conduct solidifying plans with onsite to reinitiate resuming in graded manner) 3
NRC Response to PHE The regulations in Title 10 of the Code of Federal Regulations (10 CFR) Part 73, Appendix B,Section VI require individuals "assigned to perform duties and responsibilities required for the implementation of the Commission-approved security plans, licensee response strategy, and implementing procedures" to meet minimum training and qualification requirements.
NRC issued EGM 20-002, Attachment 1, to allow enforcement discretion for training and qualification requirements in 10 CFR Part 73, Appendix B, Section VI (ML20083K794).
On April 20, 2020, NRC issued guidance for expedited exemptions (ML20091L385).
The NRC-conducted FOF inspection is not part of the annual FOF exercise requirement and is therefore not part of the exemption.
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Enforcement Guidance Memorandum (EGM)
Within the Coronavirus Guidelines for America, it states that individuals who work in a critical infrastructure industry, as defined by the DHS, have a special responsibility to maintain [their] normal work schedule, and establish practices.
Applied to licensees that take prudent and reasonable actions to limit and minimize staff exposure to the COVID-19 virus in an effort to maintain a healthy site work force and to maintain facility safety and security during the PHE.
Conclusion in EGM - Security staff will be able to maintain proficiency if requalification periodicity is temporarily exceeded based on:
rigorous nature of nuclear security personnel training programs scheduled training activities to include weapons training, contingency response drills and exercises, demonstrated acceptable performance of day-to-day job activities (e.g., detection and assessment, patrols, searches, and defensive operations) 5
Enforcement Guidance Memorandum (EGM)
The following areas were included in the EGM and guidance letter for the expedited exemption process Subsection B - Employment Suitability and Qualification Subsection C - Duty Training (Annual Exercise and Quarterly Drills)
Subsection D - Duty Qualification and Requalification Subsection E - Weapons Training Subsection F - Weapons Qualification and Requalification Subsection G - Weapons, Personal Equipment and Maintenance 6
Exemption Guidance Letter Exemptions approved under the expedited review process will be in effect until 90 days after the PHE is ended or until December 31, 2020, whichever occurs first.
Specific to requirements that challenge assembly restrictions and social distancing recommendations.
Other requalification requirements impacted by COVID-19 (range closures; medical personnel/facility limitations).
Expectations for licensees to apply other methodologies to support security training and response force readiness while limited by PHE restrictions.
- Scenario-based evolutions (table top exercises; communication-based; lessons learned reviews; walkdowns of exercise travel routes)
- Discussions regarding critical tasks needed to perform assigned security duties
- Individual discussion of firearms fundamentals and weapons range objectives 7
Industry Exemption Updates Operating Power Reactors (23) -
10 sites have only requested an exemption from the annual exercise requirement; additional details on next slide Decommissioning Power Reactors (3)
Independent Spent Fuel Storage Installations (4) 8
Industry Exemption Updates 10 CFR 73 Appendix B Subsection Scheduled for 2020 Licensee/Plant Name Exemption Submittal Date C NRC FOF B D E F G Annual FOF Davis Besse 4/23/2020 X X X X X X Perry 4/24/2020 X X X X X Beaver Valley 4/23/2020 X X X X X H.B. Robinson 4/30/2020 X X Duane Arnold 5/1/2020 X X X X Vogtle 1&2 5/8/2020 X Indian Point 2&3 4/29/2020 X Surry 4/6/2020 OJT Only Oconee 4/14/2020 X X Peach Bottom 2&3 5/8/2020 X X Salem 1&2 5/12/2020 X X Hope Creek 5/12/2020 X X Comanche Peak 5/14/2020 X Shearon Harris 5/20/2020 X Turkey Point 5/21/2020 X X X X X Point Beach 5/21/2020 X X X X X STP 5/21/2020 X X X X X Seabrook 5/21/2020 X X St. Lucie 5/21/2020 X X X X X X North Anna 1&2 5/28/2020 X Millstone 5/29/2020 X X Fitzpatrick 5/29/2020 X X McGuire 1&2 6/4/2020 X Callaway 6/4/2020 X X Ginna pending DC Cook pending Montecello pending Praire Island pending X X Farley pending X X Hatch pending 9
Security Inspection Program The baseline security inspection program, which is risk-informed/performance-based, has been implemented for several Reactor Oversight Process cycles to date.
NRC has observed improvement of licensee performance and adjusted the amount of licensee oversight based on this assessment.
COMSECY-19-0006 was developed based on robust licensee security programs and NRCs oversight using the security baseline inspection program.
NRC-conducted FOF inspections are part of the security baseline inspection program and are required triennially per the Atomic Energy Act.
Since 2014, NRC baseline inspection program includes observation of one licensee-conducted FOF triennially.
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Security Inspection Areas The Security baseline inspection program is comprised of a suite of inspection procedures that are conducted on varying periodicities and based on risk-significance.
Baseline Security Inspections for Power Reactors Frequency Access Control Annual Security Plan Changes Annual Security Training Biennial Equipment Performance, Testing, and Maintenance Biennial Contingency Response - Force-on-Force Testing (NRC-Conducted FOF) Triennial Protective Strategy Evaluation Triennial Access Authorization Triennial Fitness-For-Duty Program Triennial Review of Power Reactor Target Sets Triennial Protection of Safeguards Information As Needed 11
Security Baseline Inspection Activity Objective: To gather sufficient, factual inspection information to determine whether a licensee is meeting the objective of the security cornerstone.
Inspectors are coordinating resumption of on-site inspections starting in June 2020.
Licensee and NRC staffs health and safety will be considered as on-site inspections are resumed.
Regional inspectors have partially completed some inspection procedures during the last few months through record reviews.
None of the Security Baseline inspections can be fully completed without security inspectors on-site.
Local social distancing and gathering size limitations will be followed consistent with on-site practices.
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NRC-Conducted FOFs NRC has taken action to enable licensees to implement social distancing and assembly recommendations to conform to guidance from the federal government as well as state and local policies.
NSIR postponed all FOF inspections scheduled through June 2020 with a tentative restart scheduled for July 2020.
Staff recognizes that social distancing measures implemented by sites present a challenge for conducting a FOF inspection per the IP 71130.03 as currently designed.
During a closed public meeting held on May 12, industry voiced concerns over resuming onsite inspections due to impacts to currently-implemented pandemic plans, risk of infection being introduced to sites, and the size and nature of FOF inspections (especially B-week activities)
Inspection concerns include challenges associated with use of PPE during exercises, the need to conduct multiple briefings to ensure social distancing due to conference room capacity, and having multiple individuals in a bullet resistant enclosure during exercises.
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Considerations for FOFs During a PHE Resuming NRC FOF Inspections:
NRC is benchmarking with other agencies to assess timing of oversight activities and is mindful of holistic regulatory paradigm (e.g.,
exemptions granted, modifications to oversight program) 17 inspections are scheduled through the end of the CY2020; staff is considering a measured approach to account for the varied timelines for each region.
State and local officials are implementing a phased plan for lifting restrictions and guidelines. The timeline for each region/community varies based on the impact for the respective area. The timelines are not set which creates an element of uncertainty.
FOF inspections involve support from individuals that will travel from multiple geographic areas (i.e., NRC HQ staff, NRC regional inspectors, DOE contractors, SOCOM advisors, MAF) and involve sites bringing in additional shift security staff (B week only) 14
Plan for FOF Inspections NSIR will institute a rolling 6-8 week look at the PHE conditions at the sites that are in this window for both A and B week activities.
Decisions regarding FOF inspections will be made based on site-specific conditions Graded approach will be used for sites that are still under state/local PHE restrictions Modified A week activities resuming in July Longer than typical gap between A week and B week B week activities will be conducted once conditions permit Some inspections may be rescheduled in CY 2021 All sites for CY 2020 have been notified of their scheduled FOF inspections and are kept updated with changes as determinations are made.
Social distancing measures and PPE will be used to promote health and safety during inspections.
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Benchmarking Team Inspections DOE - Temporarily Suspended oversight for 180 Days Effective early March.
30 day notification to sites to resume inspection activity.
Working on plan to conduct inspections, with social distancing guidelines.
No plan to cancel inspections for 2020, tentative resumption dates August/September.
International - Following protocols as established per the affected region as well as state and local policies.
(e.g., Canada has postponed inspections until 2021) 16
2020 NRC FOF Schedule Site Location Fleet VC Summer Jenkinsville, SC South Carolina Electric Salem & Hope Creek* Hancocks Bridge, NJ PSEG Sequoyah Soddy Daisy, TN TVA HB Robinson Hartsville, SC Duke Energy Farley Dothan, AL Southern Peach Bottom Delta, PA Exelon Millstone Waterford, CT Dominion Callaway Fulton, MO Union Electric Company Seabrook Seabrook, NH NextEra Oconee Seneca, SC Duke Energy St. Lucie Jensen Beach, FL NextEra Nine Mile Point Oswego, NY Exelon Clinton Clinton, IL Exelon Palisades Covert, MI Entergy Davis-Besse Oak Harbor, OH FENOC Fitzpatrick Lycoming, NY Exelon Prairie Island Welch, MN Excel Cooper Brownville, NE Nebraska Public Power
- SHC completed A Week. B Week postponed until September.
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Considerations for Inspections During a PHE Considerations for Force-on-Force Inspections during Current Status and Items for Discussion during Public Meeting the COVID-19 Public Health Emergency Access to hotels & restaurants within commuting area All 17 sites scheduled for inspection in 2020 have options available for food of site available and lodging.
Airline travel available (as required) Airline travel is available for all sites.
Stay-at-Home Orders Lifted All 17 sites scheduled for inspection in 2020 have had the Stay-at-Home Orders lifted in their respective states.
Out-of-State travel restrictions lifted (i.e., requirement 15 out of 17 sites meet this criteria. Two sites are impacted by quarantine to self-quarantine upon arrival in state) requirements. (Florida has a 14-day self-quarantine requirement for individuals traveling from New York, New, Jersey, or Connecticut, and Nebraska has a 14-day self-quarantine requirement for individuals traveling from international locations.)
No inspection participants are affected by travel restrictions (i.e., NRC, contractors who provide services associated with multiple integrated laser engagement systems (MILES), SOCOM advisors, or mock adversary force members).
Travel conditions allow DOE MILES trailer travel to All 17 sites scheduled for inspection in 2020 are in locations where the trailer inspection location in reasonable duration can be effectively routed.
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Considerations for Inspections During a PHE Considerations for Force-on-Force Inspections during Current Status and Items for Discussion during Public Meeting the COVID-19 Public Health Emergency Personal protective equipment (PPE) available for the PPE is available for NRC inspectors, SOCOM advisors, and MILES contractors.
inspectors Site conditions support inspection (less than 10 All 17 sites scheduled for inspection in 2020 meet this criteria. NRC is employees with active positive cases onsite) interested in feedback in this area and information from industry on the criteria that are being used to make decisions related to exercising site pandemic plans.
Social distancing guidance can be achieved while on- Protocols were presented during closed meeting regarding NRC site or PPE can be effectively used recommendations for implementing social distancing during exercise activities. The NRC recognizes that measures for protecting staff in bullet resistant enclosures is of high interest and should be discussed. Protocols for operator licensing, outages, and minimizing contact between different security shifts could be leveraged for best practices.
Security staff available from site shifts or other sites to The NRC will coordinate with sites on an individual basis to obtain information support inspection positions on availability of staff to serve as players and controllers, and to ensure suitable coverage for routine shift coverage.
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FOF Inspection Considerations 2020 FOF Schedule - Cycle 6, Year 1 Security Air Travel Licensee Licensee Licensee Measured Approach Measured Approach SAH Access Social Staff Region NRC PPE Travel No OOS Travel conditio Supports Supports Supports Contact with Team Ctrl. No. Site Fleet Planning Week Exercise Week Notification Date Planning Week Exercise Week Order Hotel/R Distancing Available (15 Weeks) Available Restricti Restrictions ns allow On-site On-Site On-Site Lincense (6-8 weeks) (6-8 weeks) Lifted est Available for ons MILES Inspections A Week B Week Support 20.02 V. C. Summer South Carolina Electric II A 3-Feb-20 24-Feb-20 11-Nov-19 20.03 Salem & Hope Creek PSEG I C 24-Feb-20 21-Sep-20 8-Jun-20 1/6/2020 8/3/2020 4/28/2020 20.11 Sequoyah TVA II A 6-Jul-20 19-Oct-20 6-Jul-20 5/18/2020 8/31/2020 5/21/2020 20.04 HB Robinson Duke Energy II B 13-Jul-20 21-Sep-20 8-Jun-20 5/25/2020 8/3/2020 6/10/2020 20.12 Farley Southern II C 20-Jul-20 14-Sep-20 1-Jun-20 6/1/2020 7/27/2020 5/28/2020 20.13 Peach Bottom Exelon I B 27-Jul-20 31-Aug-20 18-May-20 6/8/2020 7/13/2020 6/10/2020 20.14 Millstone Dominion I C 3-Aug-20 24-Aug-20 11-May-20 6/15/2020 7/6/2020 5/19/2020 20.08 Callaway Union Electric Company IV A 10-Aug-20 31-Aug-20 18-May-20 6/22/2020 7/13/2020 5/28/2020 20.10 Seabrook NextEra I D 14-Sep-20 5-Oct-20 22-Jun-20 7/27/2020 8/17/2020 4/28/2020 20.01 Oconee Duke Energy II B 14-Sep-20 5-Oct-20 22-Jun-20 7/27/2020 8/17/2020 20.16 St. Lucie NextEra II C 28-Sep-20 19-Oct-20 6-Jul-20 8/10/2020 8/31/2020 20.17 Nine Mile Point Exelon I A 5-Oct-20 26-Oct-20 13-Jul-20 8/17/2020 9/7/2020 20.05 Clinton Exelon III D 19-Oct-20 16-Nov-20 3-Aug-20 8/31/2020 9/28/2020 3/13/2020 20.18 Palisades Entergy III B 26-Oct-20 16-Nov-20 3-Aug-20 9/7/2020 9/28/2020 4/24/2020 20.15 Davis-Besse FENOC III B 2-Nov-20 30-Nov-20 17-Aug-20 9/14/2020 10/12/2020 3/20/2020 20.06 Fitzpatrick Exelon I A 2-Nov-20 14-Dec-20 31-Aug-20 9/14/2020 10/26/2020 3/20/2020 20.07 Prairie Island Excel III A 16-Nov-20 7-Dec-20 24-Aug-20 9/28/2020 10/19/2020 20.09 Cooper Nebraska Public Power IV C 16-Nov-20 14-Dec-20 31-Aug-20 9/28/2020 10/26/2020 4/13/2020 Inspection Count 18 Yes Team A 6 Partial Team B 5 No Team C 5 No Data Team D 2
- SHC completed A Week. B Week postponed until September.
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FOF Heat Map 21
Social Distancing Recommendations for Inspection Activities Modified A Planning Week:
NRC Team on site 1 to 2 days, Tuesday or Tuesday & Wednesday.
Conduct/Observe: Protective Strategy Brief, Site Tours (multiple tours/smaller groups), Table Top, Target Set review, coordinate with MAF Lead, and develop Target Set Worksheet.
MAF on-site 2 days, Coordinate days with NRC Site tour, coordinate with NRC, insider coordination.
Develop draft Mission Narratives.
Return to HQ for review of mission Review draft MAF Mission Narratives.
Coordinate with site and MAF on any site changes prior to B Week.
Final Mission Narratives will be sent to site 3 weeks prior to B Week.
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Social Distancing Recommendations for Inspection Activities
- Planning (A) Week Activities:
- Entrance/Exit Meetings: conducted virtually
- Protective Strategy Briefing: NRC review presentation with minimal licensee personnel. Room large enough to exercise social distancing.
- Site Tours: Conduct tours simultaneously; limit personnel on each tour.
- Tabletop Drills: Conduct only with lead and adversary controllers to minimize personnel.
- MAF Interface: Limit number of staff interaction in room big enough to practice social distancing.
- Modified A week will be conducted to reduce on-site time 23
Social Distancing Recommendations for Inspection Activities
- Exercise (B) Week Activities:
- Scenario Matrix Review: Conducted virtually.
- Adversary Mission Overview and Controller Briefing: Attended by minimal personnel in room/area big enough to practice social distancing.
- Controller/Safety Briefings/Critiques/Hot Washes: Room big enough to practice social distancing, multiple briefing may be necessary due to number of personnel required. Conduct virtually, if possible.
- MILES Issue and Return: Conducted outside with social distancing practices in place. Equipment sanitized after each exercise. Ultraviolet light used in MILES trailer overnight.
- Exercise:
- Inspection team observe from distant areas.
- Limit personnel in BREs.
- Players and MAF practice social distancing and wear facemasks when unable to space.
- Licensee consider positioning of on-duty force to minimize exposure and stay in compliance.
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Summary of Path Forward Consider feedback received from stakeholders on considerations for resuming exercises Use graded approach to conduct inspections to the extent that activities can be conducted safely and in harmony with site/locality/State-conditions and controls Coordinate with sites 6-8 weeks prior to scheduled inspection date to consider decision criteria A Week activities resume in July; B week activities Fall as conditions permit 25
Industry Presentation 26
Open Discussion 27
NRC-conducted A-week Force-on-Force Site walkdowns, tabletop
-IP 71130.03 NRC-conducted can be credited for annual exercise year cycle
-approx. 20 sites per year B-week Cycle 6 Simulated attack Licensee Security 2020 2021 2022 Response Force Training and Evaluation Quarterly Drills Activities Licensee-Conducted Exercises Required Annual Exercises by 10 CFR Part 73 -approx. 4 per site to ensure all security staff participate as a player
-NRC observes once every ROP cycle as part of 71130.05 inspection 28
FOF Heat Map COVID-19 FOF Table
% of % of
- of cases # of cases in Site Location County State Pop. State County Pop. County in state county pop. pop.
Salem & Hope Creek Hancocks Bridge, NJ Salem 8,882,000 165,816 1.87% 62,385 689 1.10%
Sequoyah Soddy Daisy, TN Hamilton 6,829,000 28,340 0.41% 367,804 1210 0.33%
HB Robinson Hartsville, SC Darlington 5,149,000 16,441 0.32% 66,618 342 0.51%
Farley Dothan, AL Houston 4,903,000 22,845 0.47% 105,882 270 0.26%
Peach Bottom Delta, PA York 12,800,000 81,848 0.64% 449,058 1117 0.25%
Millstone Waterford, CT New London 3,565,000 44,461 1.25% 265,206 1147 0.43%
Callaway Fulton, MO Callaway 6,137,000 15,699 0.26% 44,743 34 0.08%
Seabrook Seabrook, NH Rockingham 1,360,000 5,209 0.38% 309,769 1400 0.45%
Oconee Seneca, SC Oconee 5,149,000 16,441 0.32% 79,546 70 0.09%
St. Lucie Jensen Beach, FL Martin 21,480,000 69,069 0.32% 161,000 760 0.47%
Nine Mile Point Oswego, NY Oswego 19,450,000 380,892 1.96% 117,124 119 0.10%
Clinton Clinton, IL DeWitt 12,670,000 130,603 1.03% 15,769 4 0.03%
Palisades Covert, MI Van Buren 9,987,000 65,449 0.66% 75,448 195 0.26%
Davis-Besse Oak Harbor, OH Ottawa 11,690,000 40,004 0.34% 40,525 112 0.28%
Fitzpatrick Lycoming, NY Oswego 19,450,000 380,892 1.96% 117,124 119 0.10%
Prairie Island Welch, MN Goodhue 5,640,000 29,316 0.52% 46,340 86 0.19%
Cooper Brownville, NE Nemaha 1,934,000 16,315 0.84% 6,958 4 0.06%
Totals: 157,075,000 1,509,640 0.96% 2,331,299 7678 0.33%
Updated: 6/12/2020 29