ML23317A048

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EP-Security Interface in NRC Regulations - NEA Workshop
ML23317A048
Person / Time
Issue date: 11/24/2023
From: Tanya Smith
Office of Nuclear Security and Incident Response
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Download: ML23317A048 (1)


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Security-Emergency Preparedness Interface in the U.S. Nuclear Regulatory Commission Regulations Todd Smith, PhD Senior Level Advisor for Emergency Preparedness and Incident Response Office of Nuclear Security and Incident Response U.S. Nuclear Regulatory Commission Nuclear Energy Agency (NEA) Workshop on Radiological Protection during Armed Conflict November 22-24, 2023 Oslo, Norway

Facing the new threat environment Following the events of September 11, 2001, the NRC:

Issued orders requiring compensatory measures for nuclear security and safety Evaluated security events within the planning basis for emergency preparedness (EP)

Observed and evaluated licensee performance of security force-on-force exercises and security-based EP drills and exercises Reviewed current public radiological protective action guidance Discussed security-based EP issues with various stakeholders, including licensees and Federal, State and local government officials

Hostile Action An act toward a Nuclear Power Plant or its personnel that includes the use of violent force to destroy equipment, take hostages, and/or intimidate the licensee to achieve an end.

NRC enhanced EP-security interface in regulation In 2011, the NRC published enhancements to its EP regulations to address hostile action against the site including:

On-shift staffing Emergency Action Levels (EALs) for Hostile Action Emergency Response Organization (ERO) augmentation at alternative facilities Coordination with Offsite Response Organizations (OROs) during Hostile Action Protection for onsite personnel Challenging drills and exercises

On-shift Staffing Analysis On-shift personnel must be able to implement the emergency plan without having competing responsibilities that would prevent implementation On-shift staff respond to damages while others declare the emergency and make notifications

Emergency Action Levels for Hostile Action Hostile Action EALs provide for anticipatory response and timely notification of Federal, State, and local agencies

Staff Augmentation at Alternative Facilities Alternative facilities provide staging areas for response staff to implement EP functions and prepare for site entry, without exposing them to danger Access to response facilities onsite may be restricted Alternative facilities provide safe staging areas

Coordination with Office Response Organizations Ensures the appropriate State, local, and Federal law enforcement agencies are identified along with the expected assistance needed for hostile action

Protection for Onsite Personnel Protection of onsite workers ensures continued ability of the licensee to safely shut down the reactor and implement the emergency plan Normal response actions for personnel protection, such as site evacuation, site assembly and accountability, and activation of onsite emergency response facilities, may not be appropriate during hostile action Rather, evacuation from potential target buildings and accountability after attack and other site-specific strategies may be more appropriate Security provides escorts for safe travel

Protection for the Public Protective actions for the public consider the unknown threat environment Protective Action Strategies consider impediments to evacuation Sheltering is a viable initial action

Hostile Action-Based Exercise Demonstration A Hostile Action-Based (HAB) exercise is required once per 8-year exercise cycle to demonstrate:

Implementation of emergency plan in an unknown security state Safely move response personnel to mitigate urgent damage Safely move non-essential personnel Interface of EP with site security and local law enforcement

Cybersecurity protects critical EP functions Cyber security plans ensure cyber attacks will not adversely impact the ability to implement an EP function Critical digital assets are protected, including:

Emergency call-out systems Dose assessment codes and workstations Meteorological instruments for dose assessment Offsite notification and communication systems Alternative means for performing intended EP functions may be warranted Equipment susceptible to cyber attack is periodically checked to ensure it is performing its intended function

Additional HAB Lessons Learned are available Hostile Action Based Emergency Preparedness (EP) Drills https://www.nrc.gov/about-nrc/emerg-preparedness/respond-to-emerg/hostile-action.html Emergency Preparedness in Response to Terrorism https://www.nrc.gov/about-nrc/emerg-preparedness/respond-to-emerg/response-terrorism.html Frequently Asked Questions About NRC's Response to the 9/11/01 Events https://www.nrc.gov/security/faq-911.html Post 9/11 Information https://www.nrc.gov/security/post-911.html

The EP-security interface in NRC regulations provides for radiological protection of workers and the public in the event of Hostile Action