Comments on May 31, 2021 Discussion Paper, “The issues identified atnuclear security cornerstone assessment and the issues of J-ROP”
1. The questions posed on slide 5 (What’s wrong with it?) are the best questions to ask andanswer. They provide the best insights into J-ROP’s strengths and weaknesses.
2. The way that the 14 issues on slide 6 are assigned to the various parties (e.g., Society, JROP, etc.) is a comprehensive way of monitoring J-ROP. J-ROP affects all these parties,and reviewing the pilot for consequences to these parties is valuable.
3. Slide 9 covers Information Disclosure and points out that the issuance of “white” and“red” inspection findings resulted in distrust of the company by the public. It may seem
unlikely, but these findings can and should also increase trust by the public. What if NRAnever issued “white” and “red” findings. That may indicate that security and safety areadequately protected. But it also might indicate that security and safety inadequacies arebeing missed, overlooked, or downplayed by NRA. It gives me comfort when the NRC
reports that a US plant failed a force-on-force test. It tells me that the tests are robust. Iwould much prefer that a plant fails a robust test than pass a weak test. True, I’d prefermore that plants pass robust tests. But the occasional test failure is necessary for people
on the outside, like me, to understand that the tests are robust.
4. The comparison of the four elements of Nuclear Safety to the four elements of Nuclear
Security on slide 10 is a great way to explain both issues. Well done!
5. The discussion for Issue 4 on slide 11 addresses a key difference between safety andsecurity problems. While safety problems can be publicly discussed in detail, security
problems cannot be so freely discussed so as to prevent terrorists from using thisinformation to plan their attacks. But there is another downside to this situation. The lackof open communication about security problems also impedes the awareness of workers
in industry and NRA to them. Thus, if I am a worker at Plant X, I can better understandthe nature of safety problems at Plant Y than I am to understand a security problem atPlant Y. Consequently, I am better able to take steps from that safety problem fromaffecting my Plant X than I am at avoiding a repeat of Plant Y’s security problem. Thereneeds to be a better way to keep vital security information form terrorists while still
providing non-vital security information from the nuclear industry, NRA, and the public.
Withholding almost all security information helps keep it from terrorists, but it might also
keep too much information from those needing and deserving to get it.
6. The discussion of Issue 7 on slide 12 addresses the goal of J-ROP to prevent signs of“red” events before they occur. This is the proper goal, but challenging to meet. One
thing that the NRC’s ROP contains is a backward look when a reactor’s declining
performance moves it into Column 3, 4, or 5 of the Action Matrix. When that occurs, theNRC formally reviews the Baseline Inspection Program under the ROP to see if theyshould be allocating resources and oversight focus differently. In other words, could they
have detected the declining performance sooner and prevented it from dropping so low asto move the reactor into Column 3, 4, or 5? Asking and answering this question either
confirms that the ROP’s Baseline Inspection Program is right or identifies revisions thatmake the effort more effective.

Comments on May 31, 2021 Discussion Paper, “The issues identified atnuclear security cornerstone assessment and the issues of J-ROP”
7. The discussions of Issue 8 on slide 13 and Issue 9 on slide 14 seem to be connected. Issue
8 mentioned that the pilot only discussed green and minor problems. Issue 9 mentionedthat there is no formal dialog between NRA and industry regarding more serious
problems. Combined, this means that NRA and industry lack opportunities to reachcommon understandings of the most serious safety and security problems. This seems
opposite to proper allocation of time and attention. It is most important that NRA andindustry share a common understanding on the most serious safety and security problems
if future efforts at avoiding them are to be successful. This discussion paper makes thiskey point very well.
8. The discussion of Issue 10 on slide 15 makes a point that I raised repeatedly wit the NRC.
Any time that an NRC inspector identifies a violation, he or she has actually identified
two violations – the violation and also the failure of the operator to have found theviolation before the NRC did. I argued that the operator must fix BOTH violation – thespecific violation as well as the programmatic failures that prevented it from finding andfixing the problem first.
9. The discussion of Issue 14 on slide 16 touches upon the point made in Comment 5 above.
Suppose someone has worked the past 5 years in the security department at a Japanesenuclear plant and then transfers to a safety role at that same plant. And consider anotherperson at this same plant doing just the opposite – transferring into the security
department after working 5 years in a safety position. The first person is less likely to beaware of security problems that happened during the five years before his or her transfer
into security. And the second person is likely to be more aware of safety problems during
the prior five years even though he or she was working in security. Opening all
information on security problems to all persons cannot be done. As a compromise, formal
knowledge transfer programs could be used. For example, in the case above of a worker
transferring from a safety department to a security department at a plant, it could berequired that the worker review and perhaps be tested about security events during theprior five years. There’s an old saying that “Information is power.” Workers must begiven the power to perform their security duties at their fullest capabilities.
10. The reference material on the CASE on slide 18 circles back to information such as thatabout Issue 2 on slide 10. Management and workers at Kashiwazaki-Kariwa were awareof security problems but failed to take steps necessary to fix them. Would similar
problems on the safety side also been tolerated and not fixed? If not, why were security
problems not perceived to be as important as safety problems?
The WG’s Discussion Paper does a fine job of communicating its review effort and makes very
sound findings and observations.
Dave Lochbaum. June 2021