ML24191A380
| ML24191A380 | |
| Person / Time | |
|---|---|
| Issue date: | 07/22/2024 |
| From: | Brooks M NRC/NSIR/DSO/SOSB |
| To: | Desiree Davis Office of Nuclear Security and Incident Response |
| Shared Package | |
| ML24191A438 | List: |
| References | |
| Download: ML24191A380 (1) | |
Text
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MEMORANDUM TO:
Desiree Davis, Chief Security Oversight and Support Branch Division of Security Operations Office of Nuclear Security and Incident Response FROM:
Maury Brooks, Security Specialist Security Oversight and Support Branch Division of Security Operations Office of Nuclear Security and Incident Response
SUBJECT:
SUMMARY
OF THE BASELINE SECURITY SIGNIFICANCE DETERMINATION PROCESS PUBLIC MEETING HELD ON JUNE 24, 2024 Meeting Identifier: 223473873283 Date of Meeting: June 24, 2024 Type of Meeting: Open Discussion Meeting Purpose of Meeting: On June 24, 2024, the U.S. Nuclear Regulatory Commission (NRC) staff hosted a hybrid public meeting with various internal and external public stakeholders to provide an update on the NRC's progress on the effort to evaluate its Baseline Security Significance Determination Process (BSSDP) and determine whether there are any aspects of the BSSDP that can be improved or further risk-informed.
General Details: The meeting was attended by approximately 22 NRC personnel and external stakeholders. Representatives from Enercon, Entergy, the Nuclear Energy Institute (NEI),
Dominion, Constellation, Certrec, Ameren, RoPower, Tennessee Valley Authority (TVA),
Arkansas Nuclear One, Southern Nuclear, STARS Alliance, Idaho National Laboratory, and the Union of Concerned Scientists (UCS) were among the participants that identified themselves and provided comments or questions. The meeting started at 1:00pm EDT and completed by 2:00pm EDT, as scheduled. The meeting was held in person at NRC headquarters and virtually over the Microsoft Teams application.
Summary of Presentation: The NRC provided a formal presentation for the meeting discussion. This presentation can be located at ML24191A170. No other participants provided a formal presentation.
CONTACT: Maury Brooks, NSIR/DSO/SOSB (301) 415-3075 July 22, 2024 Signed by Brooks,Maury on 07/22/24
2 D. Davis NRC staff provided details on the efforts of the BSSDP working groups (WG) phased assessment approach to determine whether any aspects of the tool can be improved or further risk-informed.
Staff provided an overview of the four options considered in Phase I by the Working Group:
1.
Develop a new BSSDP 2.
Revise BSSDP 3.
Clarify Existing BSSDP Guidance 4.
Status Quo The BSSDP working group used the Principles of Good Regulation, and the Be riskSMART framework to assess each proposed option. The WG considered the advantages and disadvantages to both the agency and external stakeholders when developing each option.
These factors included, but were not limited to, the near-term and long-term regulatory impacts, and the level of effort to develop required resources internally and externally.
Based on this analysis, the WG presented its recommendation to proceed with Option 2, a revision of the BSSDP. Comments from external stakeholders did not object to the working groups recommendation.
The BSSDP Option 2 revision would:
1.
Discontinue use of figures 7-11 for the processing of physical security findings and enhance reliance on the Significance Screen, to include adding more examples.
2.
Explore additional entry criteria (figure 4) and further define low/medium/high thresholds.
3.
Aim to address the main concerns from the inspector survey results and industry input (subjectivity and complexity).
4.
Preserve the assessment tools, such as the Significance Screen, that are more straightforward and user-friendly, to achieve the significance determination that would most closely align with the risk significance.
Staff also noted that Option 2, as proposed, would include the improvements described in Option 3 (i.e., clarifying guidance).
Industry Input/Comments After the initial introduction and presentation by the NRC, various external stakeholders shared their thoughts regarding the working groups proposed recommendation. The following list is a high-level summary of the comments and suggestions offered by external stakeholders and are not verbatim:
NEI: The NRC recommendation for Option 2 is aligned with similar conclusions as the industry.
The NRC should work to resolve BSSDP complexity and subjectivity concerns regarding the worksheets in Figures 7-11. NEI suggested that the NRC recommendation should include a detailed review of human error findings versus programmatic findings and the differences in determining the final significance of those findings. NEI looks forward to future engagements
3 D. Davis and asked to be provided more information on the proposed timeline for the start and completion of the Phase II revision of the BSSDP, when known by the NRC.
Entergy: The BSSDP is overly complex; the industry completed their own assessment and came to a similar conclusion as the WG. NRC Security Inspectors sometimes had differing views as to how impact areas (Owner Controller Area, Protected Area and Vital Area) should be applied. Entergy also suggested a review of the technical basis for human error findings versus programmatic findings and the differences in determining the final significance of those findings, and further noted that the current Significant Screen (Figure 4) examples need to be clarified.
TVA: TVA agreed that the NRC recommendation for Option 2 is aligned with similar conclusions as the industry. TVA also suggested that a focus area for Option 2 should be to provide more details and clarifying language in the technical basis for the BSSDP for human performance findings versus programmatic findings to include the determining factors for moving the threshold from a human error finding to a programmatic finding.
UCS: The BSSDP revision and recommendation from the WG needs to consider the Force-on-Force (FOF) program changes (specifically the reduction in number of NRC-evaluated FOF exercises) as directed by the NRC Commission, in the recent FOF SRM/COMSECY. Some of the rationale for the Commission decision for the reduction of the number of NRC-evaluated exercises was based on ensuring the remaining Contingency Response attributes contained within the Physical Protection Baseline Security Inspection Program and Significance Determination Process would be comprehensive enough to offset that reduction in NRC-evaluated FOF exercises. UCS recommends the NRC ensures the above comments related to the connection of the FOF SRM/COMSECY and the Physical Protection Baseline Security Inspection Program are part of the Option 2 revision process for the BSSDP.
Next Steps The Phase II BSSDP assessment effort is planned to begin later in calendar year 2024. NRC staff will continue to engage external stakeholders in Phase II.
Conclusion At the end of the meeting, NRC management gave closing remarks.
The enclosure provides the attendance list for this meeting.
Enclosure:
As stated
ML24191A438; Memo ML24191A380 OFFICE NRC/NSIR/DPCP
/RSB NSIR/DSO/ILTAB NRC/NSIR/DPCP
/RSB NAME MBrooks DDavis MBrooks DATE Jul 9, 2024 Jul 10, 2024 Jul 22, 2024