ML24303A066
| ML24303A066 | |
| Person / Time | |
|---|---|
| Issue date: | 10/29/2024 |
| From: | Office of Nuclear Security and Incident Response |
| To: | |
| References | |
| Download: ML24303A066 (14) | |
Text
NRC Public meeting to discuss:
- The FOF Escalation Process, Industry Improvements to Force-on-Force Guidance,
- Feedback on IP 71130.03,
- Open discussion Office of Nuclear Security and Incident Response (NSIR)
Division of Security Operations (DSO)
Security Performance Evaluation Branch (SPEB)
2 This meeting is an information meeting only.
Any comments and/or feedback provided during this meeting will be considered, but the agency will not be issuing a response to any comments or considerations made by the public.
Meeting Agenda
- Escalation Process (Open)
- Overview
- What has gone right
- What improvements are being considered
- Nuclear Energy Institute, (NEI) 05-05 Update (Closed)
- NEI 11-02 Update (Closed)
- Inspection Procedure (IP) 71130.03 (Closed) 3
The Escalation Process
- What is the escalation process for?
- Dispute adversary characteristics, attributes, or tactics within the scenarios developed by the NRC inspection team.
- What is the threshold criteria for potential disputed items?
- within the Design Basis Threat;
- be adequately controlled;
- safe for use or safely simulated;
- How do I submit an escalation or appeal?
- An initial phone call is sufficient for initiating the process followed by any written information to substantiate the position.
- Licensees may use the Addendum in the IP or a similar format.
- Addendum example in the next slide.
- Protect the information appropriately.
- Please submit an uncontrolled cover sheet to submit into ADAMS.
5 Escalation Submittals
6 IP 71130.03 Addendum 3 The Escalation Process Form
7 Escalation Process Timeline Planning Week Schedule Protective Strategy Brief Site Tours Monday Tuesday Entrance Meeting Target set reviews Wednesday Thursday Friday Table-top exercises MAF director review/site tour Scenario Development Scenario Disclosure MAF Tour (if not conducted on Wed)
MAF Scenario Development NRC review of scenarios Licensee matrix development All attempts should be made by the licensee and the inspection team to resolve issues on-site during the Planning Week.
- Scenarios are disclosed on Wed afternoon, this is the first opportunity to engage with the team on concerns.
- The licensee should/may ask additional questions after the Mock Adversary Force (MAF) director has developed the scenarios on Thursday.
- Notification of the disputed item to the SPEB Branch Chief (BC) by the first Wednesday after the Planning Week.
- SPEB BC should render a decision and respond by the first Friday after the Planning Week.
8 Escalation Process Timeline Licensee matrix development Monday Tuesday NRC reviews and approves scenarios Wednesday Thursday Friday Licensee matrix development Licensee matrix development Licensee matrix development Licensee submits matrices for initial review Wednesday Thursday Friday Exercise Week schedule submitted to NRC JCAF travels/training and rehearsals NEI CAF travels to site JCAF conducts rehearsal exercises Monday Tuesday NRC review and evaluation of scenario matrices Monday Tuesday Wednesday Thursday Friday Planning week
Appeals of BC decision transmitted to DSO Director by Monday prior to Exercise Week.
DSO Director, in coordination with NSIR Director, will transmit final decision by Wednesday prior to Exercise Week.
9 Escalation Process Timeline Monday Tuesday Wednesday Thursday Friday Licensee submits matrices for initial review Wednesday Thursday Friday Exercise Week schedule submitted to NRC JCAF travels/training and rehearsals NEI CAF travel JCAF conducts rehearsal exercises Monday Tuesday NRC review and evaluation of scenario matrices Monday Tuesday Wednesday Thursday Friday Planning week Wednesday Thursday Friday Monday Tuesday Exercise Week
Changes after Escalation Process Closure
- Exercise scenarios should be developed and followed as closely as possible to their original intent.
- Instances may arise that necessitate small revisions. These include information identified in the mission narrative(s) as:
- incorrect,
- changed,
- or details that were missed during MAF planning and rehearsals
- These items could be identified by either the licensee exercise development team or MAF and warrant a minor revision to the exercise.
- The licensee should also account for small revisions by the MAF during the final development of the exercise (i.e.,
minor changes to planned zone breaches).
Changes after Escalation Process Closure cont.
- The NRC inspection team lead will determine whether the proposed revisions are a departure from the original scenario that:
- could add significant value to, or
- change the intent of the scenario.
- These items must be resolved quickly due to the short timeline for the exercises.
- The NRC inspection team lead, in consultation with the SPEB BC, will work with the licensee to implement any appropriate adjustments.
Discussion Topics on the Process
- Should the number of weeks in between the planning and exercise weeks be increased?
- More data is needed by the staff to evaluate
- Allow further development of the exercise scenario control measures.
- Allow more time to gather data needed for escalation items.
- Update the submittal and response timelines to allow more evaluation time by licensee and NRC staff.
- Entry criteria into the escalation process.
- Do the entry items need to be expanded?
12
Questions/Comments?
13
14 Closed Meeting Discussion Topics
- NEI 05-05 Update
- NEI 11-02 Update