ML17242A096

Response to Formal Disagreement and Appeal with Adversary Characteristics, Attributes, for Tactics Employed as Part of an NRC-Evaluated Force on Force Exercise - Davis-Besse Disputed Item 05000346/2017201-01 and Disputed Item 05000346/20172

ML17242A096
Person / Time
Site:	Davis Besse
Issue date:	08/31/2017
From:	Johnson R C Security Performance Evaluation Branch
To:	Ellis J D FirstEnergy Nuclear Operating Co
Josh Berry
References
IR 2017201
Download: ML17242A096 (3)

See also: IR 05000346/2017201

Text

August 31, 2017

Mr. James Director, Fleet Security Program First Energy Nuclear Operating Company 341 White Pond Drive Mail Stop: A-WAC-B1 Akron, OH 44320

SUBJECT: RESPONSE TO FORMAL DISAGREEMENT WITH ADVERSARY CHARACTERISTICS, ATTRIBUTES, OR TACTICS EMPLOYED OR PREPARED AS PART OF AN NRC-EVALUATED FORCE-ON-FORCE EXERCISE - DISPUTED ITEM 05000346/2017201-01 AND DISPUTED ITEM 05000346/2017201-02

Dear Mr. Ellis,

Thank you for your e-mail sent by Mr. William Willis, Manager, Site Security, at Davis-Besse Nuclear Power Station, on August 29, 2017, to the Division of Security Operations (DSO), Security Performance Evaluation Branch with the two attachments entitled "Formal Disagreement with Adversary Characteristics, Attributes, or Tactics Employed or Prepared as Part of an NRC-Evaluated Force-on-Force Exercise" (safeguards encrypted), in accordance with Addendum 4 of the U.S. Nuclear Regulatory Commission (NRC) Inspection Procedure 71130.03 "Contingency Response - Force-on-Force Testing."

In your attachments you dispute tactics, techniques, or procedures (TTP) within Scenario 1 and Scenario 2 developed by an NRC Force-on-Force inspection team.

The NRC has carefully reviewed both of your formal escalations and concluded that the disputed TTPs are approved for use within both the NRC-evaluated exercise scenarios for the following reasons: (1) it is within the design basis threat; (2) it is supported by available data; (3) it is within your program requirements to provide defense-in-depth; (4) it can be safely performed and controlled; and (5) it provides a credible and realistic challenge to your site's protective strategy. If you would like to appeal this decision, provide a written response within 3 days from the date of this letter with the basis of your appeal to the Director, DSO.

Sincerely,/RA/

Robert C. Johnson, Chief Security Performance Evaluation Branch Division of Security Operations Office of Nuclear Security and Incident Response

Enclosures:

1. NRC Response to Disputed Item 05000346/2017201-01 2. NRC Response to Disputed Item 05000346/2017201-02

cc w/enclosures: William Willis, Manager, Site Security SUBJECT: RESPONSE TO FORMAL DISAGREEMENT WITH ADVERSARY CHARACTERISTICS, ATTRIBUTES, OR TACTICS EMPLOYED OR PREPARED AS PART OF AN NRC-EVALUATED FORCE-ON-FORCE EXERCISE - DISPUTED ITEM 05000346/2017201-01 AND DISPUTED ITEM 05000346/2017201-02 DATED: August 31, 2017 ADAMS ACCESSION NUMBER: ML17242A096 OFFICE NSIR/DSO/SPEB NSIR/DSO/SPEB NAME J. Berry C. Johnson SIGNATURE DATE 8 / 29 /2017 8 / 31 /2017 OFFICIAL RECORD COPY