ML031750754

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Suitability, Training & Qualification Plan, Revision 20
ML031750754
Person / Time
Site: Palisades Entergy icon.png
Issue date: 06/10/2003
From: Cooper D
Nuclear Management Co
To:
Document Control Desk, Office of Nuclear Reactor Regulation
References
Download: ML031750754 (52)
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Nuc n Committed to Nuclear Excele Palisades Nuclear Plant Operated by Nuclear Management Company, LLC June 10, 2003 10 CFR 50.54 U. S. Nuclear Regulatory Commission Document Control Desk Washington, DC 20555-0001 PALISADES NUCLEAR PLANT DOCKET 50-255 LICENSE NO. DPR-20 PALISADES NUCLEAR PLANT SUITABILITY, TRAINING AND QUALIFICATION PLAN, REVISION 20 Nuclear Management Company, LLC (NMC) is enclosing two attachments that comprise Revision 20 of the Palisades Nuclear Plant Suitability, Training and Qualification Plan. Attachment 1 contains a description of, and justification for, the changes included in Revision 20. Attachment 2 contains one original and three copies of the revised Plan.

NMC has determined that the changes contained in Revision 20 do not decrease the safeguards effectiveness of the Palisades Suitability, Training and Qualification Plan.

Accordingly, this revision is submitted under the provisions of 10 CFR 50.54(p)(2).

SUMMARY

OF COMMITMENTS This letter contains no new commitments and no revisions to existing commitments.

Dou as E. Cooper Palisades Site Vice President CC: Regional Administrator, USNRC, Region IlIl Project Manager, USNRC, NRR (w/o att)

NRC Resident Inspector - Palisades (w/o att)

Attachments 1, c-- 5 )

27780 Blue Star Memorial Highway

  • Covert, Ml 49043 Telephone: 616.764.2000

ATTACHMENT I NUCLEAR MANAGEMENT COMPANY PALISADES PLANT DOCKET 50-255 DESCRIPTION OF AND JUSTIFICATION FOR SUITABILITY, TRAINING, AND QUALIFICATION PLAN CHANGES REVISION 20 3 Pages Follow

10CFRSO.54(p) SCREENING EVALUATION DocumentRevision: Palisades Nuclear Plant Security Training and Qualification Plan, Revision 20 Section/Title: Entire Document PROPOSED CHANGE(S): List of changes attached? Yes No This is a general revision of the plan. The revised plan supersedes Suitability, Training and Qualification Plan, Revision 20. A comprehensive summary of changes made to the superseded plan is provided in ATTACHMENT 1.

IMPACT ON EFFECTIVENESS:

This section asks a series of questions. If the response to each question is "no" and the rationale supports a "no" response, the change may be processed using the provisions of 10 CFR 50.54(p) without NRC prior approval. The questions are as follows:

1. U Yes 3 No Does this change delete or contradict any regulatory requirement?
2. Ul Yes S No Would the change decrease the overall level of security system performance as described in paragraphs (b) through (h) of 10 CFR 73.55 to protect with the objective of high assurance against the design basis threat of radiological sabotage as stated inl0 CFR 73.1(a)?

Rationale: The rationale to support the answer 'NO" for each change is provided in ATTACHMENT 1.

3. U Yes 3 No For any licensee that has NRC-approved security plan commitments as alternatives to one or more of the requirements of 10 CFR 73.55(b) through (h):

Does this change decrease the overall level of security system performance needed to protect with the objective of high assurance against the design basis threat of radiological sabotage as stated in 10 CFR 73.1(a).

Rationale: No changes are being made to the NRC-approved Security Training and Qualification commitments which are altematives to the requirements of 10CFR73.55(b) through (h).

U Yes 3 No If the response to each question is no" and the rationale supports the response, then the change may be processed under the provisions of 10CFR50.54(p) without prior NRC approval. If any response is yes," then NRC approval is required Drior to implementing the change. Is NRC approval required?

Review and Approval:

Completed By: Date: 72 7-atY Reviewed By: Date: 4-231-02 Approved By: Date: f/3Mt Page 1 of 3

ATTACHMENT 1: Assessment of Acceptability of 10 CFR Section 50.54(p) Changes to the Palisades Security Training And Qualification Plan

1. The following matrix correlates information contained in the applicable sections and paragraphs of the revised plan with the applicable sections and paragraphs of the superseded plan. A description of each change and, where required, the rationale for the "NO" response to question 2 of the 10 CFR Section 50.54(p) evaluation is provided.
2. A separate description is provided for changes and the rationale for the change is provided to include its impact on the overall level of security system performance specified in the Physical Security or Safeguards Contingency Plans.

Page 2 of 3

PALISADES SECURITY TRAINING AND QUALIFICATION PLAN CHANGE MATRIX Change Superseded Revised TQP Number TQP Reference Reference Change Description and Rationale Section 4, Section 4, Change: Revised the handgun qualification course.

4.1 4.1 Rationale:

The handgun and handgun qualification course have been changed. Nuclear Management Company has adopted a standard weapon to be used at all NMC sites. Weapons have been changed from a 9mm (.355 caliber) Glock to a .40 caliber Heckler & Koch. The qualification course is also being standardized. The Palisades Security Training and Qualification Plan is being revised to adopt this new qualification course. The course revision was based on lessons leamed from Operational Safeguards Response Evaluations, specifically the effective range of a handgun. Since there will be no change in actual weapons training for Security Officers, there is no decrease in the ability of the onsite physical protection system or security organization to protect with a high assurance against the design basis threat as stated in 10 CFR 73.1(a)(1).

2 Appendix B Appendix B ChanQo: Chancied "Glock Model 17 Pistol" to "handgun".

5.1 5.1 Ratlonale:

The handgun has been changed to the Nuclear Management Company's standard weapon. The Security Plan has previously been revised to change any reference to a specific make or model of a handgun to "handgun". NMC's standard weapon meets the requirements stated in 10 CFR 73, Appendix B.V.A.3 Page 3 of 3

ATTACHMENT 2 NUCLEAR MANAGEMENT COMPANY PALISADES PLANT DOCKET 50-255 PALISADES NUCLEAR PLANT SUITABILITY, TRAINING, AND QUALIFICATION PLAN REVISION 20 46 Pages Follow

NUCLEAR MANAGEMENT COMPANY PALISADES NUCLEAR PLANT SUITABILITY, TRAINING AND QUALIFICATION PLAN List of Effective Pages Revision 20 Section Page Rev Sect ion Page Rev List of Eff Pages 1 of I 20 Table of Contents 1 of 2 20 2of2 20 Scope 1 of 14 20 Section 1 2 of 14 20 3 of 14 20 4 of 14 20 5 of 14 20 6 of 14 20 Section 2 7 of 14 20 8 of 14 20 9 of 14 20 Section 3 10 of 14 20 Section 4 11 of 14 20 12 of 14 20 13 of 14 Section 5 14 of 14 20 Appendix B 7 of 20 20 13 of 20 20 Appendix C 5 of 8 20

NUCLEAR MANAGEMENT COMPANY PALISADES NUCLEAR PLANT SUITABILITY, TRAINING AND QUALIFICATION PLAN Table of Contents Revision 20 Page SCOPE OF SUITABILITY TRAINING AND QUALIFICATION PLAN SCOPE .......................................... I SECTION 1 - EMPLOYMENT SUITABILITY AND QUALIFICATION 1.0 EMPLOYMENT SUITABILITY AND QUALIFICATION ..................................... 2 1.1 SUITABILITY .......................................... 2 1.1.1 Education Development .......................................... 2 1.1.2 Felony Conviction ......................................... 2 1.1.3 A.e .......................................... 2 1.2 PHYSICAL AND MENTAL QUALIFICATIONS .......................................... 2 1.2.1 Physical Qualifications.......................................... 2 1.2.2 Mental Qualifications .......................................... 4 1.3 PHYSICAL FITNESS QUALIFICATIONS .......................................... 5 1.4 CONTRACT SECURITY PERSONNEL .......................................... 5 1.5 PHYSICAL AND MENTAL ANNUAL REQUALIFICATION ............................... 5 1.6 DOCUMENTATION ...... 6...................

1.7 RECORDS RETENTION .......................................... 6 1.8 CONSTRAINTS .......................................... 6 SECTION 2 - TRAINING AND QUALIFICATIONS 2.0 TRAINING AND QUALIFICATIONS .......................................... 7 2.1 TRAINING REQUIREMENTS ..........................................7 2.2 QUALIFICATION REQUIREMENTS ............. ............................. 8 2.2.1 Individual Responsibility Matrix .......................................... 8 2.2.2 Job Analysis .......................................... 8 2.2.3 Duty Qualification ............................. 8 2.2.4 Individual Qualification Record (IQR) ........................... 8 2.2.5 Test Materials ........................... 9 Page 1 of 2

NUCLEAR MANAGEMENT COMPANY PALISADES NUCLEAR PLANT SUITABILITY, TRAINING AND QUALIFICATION PLAN Table of Contents Revision 20 Page 2.3 CONTRACT PERSONNEL .................... 9 2.4 REQUALIFICATION ................... 9 SECTION 3 - WEAPONS TRAINING 3.0 WEAPONS TRAINING .10 SECTION 4 - WEAPONS QUALIFICATION AND REQUALIFICATION PROGRAM 4.0 WEAPONS QUALIFICATION AND REQUALIFICATION PROGRAM . 11 4.1 HANDGUN .11 4.2 RIFLE .12 4.3 REQUALIFICATION .13 SECTION 5 - GUARD, ARMED RESPONSE AND ARMED ESCORT EQUIPMENT 5.0 GUARD. ARMED RESPONSE AND ARMED ESCORT EQUIPMENT 14 5.1 FIREARMS .14 5.2 AMMUNITION .14 5.3 CONTINGENCY EQUIPMENT .14 APPENDICES Appendix A, "Company Training Program" Appendix B, "Job Analysis' Appendix C, "Individual Responsibility Matrix" Page 2 of 2

NUCLEAR MANAGEMENT COMPANY Scope PALISADES NUCLEAR PLANT Revision 20 SUITABILITY, TRAINING AND QUALIFICATION PLAN Page 1 of 14 TITLE: Scope This is the Suitability, Training and Qualification Plan (STQP) for the Nuclear Management Company's Palisades Nuclear Plant. This plan establishes the program for selecting, training, equipping, testing, and qualifying individuals assigned the responsibility of protecting nuclear material at the plant from theft or sabotage.

The STQP is drafted, approved, and revised by the Security Manager (SM). No changes to the STQP are made without prior review of the Nuclear Management Company (NMC)

Director, Security or designate.

Revisions which do not decrease the safeguards effectiveness of the STQP may be made without prior approval of the Nuclear Regulatory Commission but must be reported to the Commission within two months after the change is made in accordance with 10 CFR 50.54(p).

Revisions which decrease the safeguards effectiveness of the STQP shall be subject to prior approval by the Nuclear Regulatory Commission pursuant to 10 CFR 50.90.

In addition to this plan, a Suitability, Training and Qualification Plan Implementing Procedure is maintained by the plant. This procedure shall be considered the implementation document for the STQP.

NUCLEAR MANAGEMENT COMPANY Section 1 PALISADES NUCLEAR PLANT Revision 20 SUITABILITY, TRAINING AND QUALIFICATION PLAN Page 2 of 14 TITLE: Employment Suitability and Qualification 1.0 EMPLOYMENT SUITABILITY AND QUALIFICATION 1.1 SUITABILITY Prior to employment or assignment to the security organization, an individual shall meet the following criteria.

1.1.1 Educational Development (Fulfill one of the following)

Provide evidence of completion of at least a high school education or equivalency (ie, high school or college diploma; certificate of completion from a high school or college, certificate of successful passing of a high school level General Education Development examination). In cases where individuals were educated in foreign countries, documentation supporting the equivalent of a high school education shall be available.

1.1.2 Felony Conviction An individual may not be assigned to the security force if convicted of a felony.

Every individual must sign a statement indicating whether or not he or she has ever been convicted of a felony; if yes, no further consideration for assignment as a member of the security force shall be given; if no, the background investigation should be conducted in a manner to determine the truthfulness of this matter.

1.1.3 Aqe Provide evidence that he or she is at least 21 years of age, ie, birth certificate, baptismal certificate, DD Form 214, drivers license, etc, if seeking qualification as an armed officer status; 18 years of age if seeking qualification as an unarmed officer status.

1.2 PHYSICAL AND MENTAL QUALIFICATIONS 1.2.1 Physical Qualifications

a. General Physical Qualifications Each individual whose primary responsibility involves the effective implementation of the security program shall not have any physical weakness or abnormalities that would adversely affect his or her performance of assigned security duties. Supervisors are responsible for the prompt reporting of any such weakness and/or abnormality noted during the continued observation program of assigned security personnel.

NUCLEAR MANAGEMENT COMPANY Section 1 PALISADES NUCLEAR PLANT Revision 20 SUITABILITY, TRAINING AND QUALIFICATION PLAN Page 3 of 14 TITLE: Employment Suitability and Qualification

b. Physical Examination In addition to the above, armed personnel and central alarm station operators shall successfully pass a physical examination designed to measure the individual's physical ability to perform security job duties. The examination will be conducted by a licensed physician who has been provided appropriate information as to the physical requirements of the security program and criteria outlined in 10 CFR 73, Appendix B. Upon completion of each examination, the physician will provide a statement attesting to the individual's successful passing of the required examination and that there is no medical contraindication to participate in the stated physical fitness qualification test.
c. Armed Personnel Requirements Armed personnel shall be required to meet the following additional requirements conceming vision, hearing, epilepsy, diabetes, drug or alcohol addiction:
1. Vision: For each individual, distant visual acuity in each eye shall be correctable to 20/30 (Snellen or equivalent) in the better eye and 20/40 in the other eye with eyeglasses or contact lenses. Near visual acuity, corrected or uncorrected, shall be at least 20/40 in the better eye. Field of vision must be at least 70E horizontal meridian in each eye. The ability to distinguish red, green and yellow colors is required. Loss of vision in one eye is disqualifying. Glaucoma shall be disqualifying unless controlled by acceptable medical or surgical means, provided such medications as may be used for controlling glaucoma do not cause undesirable side effects which adversely affect the individual's ability to perform assigned security duties, and provided the visual acuity and field of vision requirements stated above are met.

The ability of armed security personnel to perform their assigned crucial tasks while wearing corrective lenses or afflicted with mild color vision defects will be demonstrated prior to assignment.

If corrective lenses are required to meet vision requirements of 1.2.1 .c.1, a second set of corrective lenses shall be maintained on site for each affected officer. Prompt action shall be initiated to replace lost or damaged corrective lenses.

2. Hearina: Each individual shall have no hearing loss in the better ear greater than 30 decibels average at 500 Hz, 1,000 Hz and 2,000 Hz, with no level greater than 40 decibels at any one frequency (by ISO 1964 or ANSI 1969 audiometry).

NUCLEAR MANAGEMENT COMPANY Section 1 PALISADES NUCLEAR PLANT Revision 20 SUITABILITY, TRAINING AND QUALIFICATION PLAN Page 4 of 14 TITLE: Employment Suitability and Qualification A hearing aid is acceptable provided it demonstrates auditory acuity equivalent to the above-stated requirement, under suitable testing procedures. The tests will be completed prior to the individual being assigned to duties involving crucial security tasks.

3. Diseases: Armed security personnel shall have no established medical history or medical diagnosis of epilepsy or diabetes or, where such a condition exists, the individual shall provide medical evidence that the condition can be controlled with proper medication so that the individual will not lapse into a coma or unconscious state while performing assigned security duties.
4. Addiction: Armed security personnel shall have no established medical history or medical diagnosis of habitual alcoholism or drug addiction or, where such a condition has existed, the individual shall provide certified documentation of having completed a rehabilitation program which could give a reasonable degree of confidence that the individual would be capable of performing assigned security duties.
d. Other Physical Requirements
1. An individual who has been incapacitated due to serious illness, injury, disease or operation which could interfere with the effective performance of assigned security job duties shall, prior to resumption of such duties, provide a statement signed by a licensed physician indicating adequate recovery and physical ability to perform such security job duties.
2. Security supervisors will, as part of their normal duties, observe their personnel to detect any indication that they cannot meet the physical demands of their assigned duties. In the event a deficiency is detected, the situation will be reported to the Security Force Leader for appropriate resolution (ie, referral to a physician).

1.2.2 Mental Qualifications

a. General Mental Qualifications Supervisory and training personnel will, as part of their normal duties, observe their personnel to detect any indication that they cannot provide the required mental and communicative skills demanded by their duty assignments. The ability of an individual to meet these requirements will be demonstrated during the testing by meeting performance objectives of necessary tasks.

NUCLEAR MANAGEMENT COMPANY Section 1 PALISADES NUCLEAR PLANT Revision 20 SUITABILITY, TRAINING AND QUALIFICATION PLAN Page 5 of 14 TITLE: Employment Suitability and Qualification

b. Professional Mental Evaluation Security personnel will be evaluated by a licensed psychologist or psychiatrist, or physician or other person professionally trained to identify emotional instability. The professional must attest that his or her evaluation detected no mental condition that would interfere with the individual's ability to perform the crucial tasks associated with his or her assigned security duties.
c. Continued Observation Supervisors will be constantly alert to detect any indications of emotional instability on the part of their shift personnel. Any individual demonstrating an apparent lack of mental ability or emotional stability will be promptly referred to the licensed health professional for evaluation. The person concemed will not be reassigned to security duty until a statement is received from the professional attesting that the individual is mentally fit to perform the crucial tasks associated with his or her assigned security duties.

1.3 PHYSICAL FITNESS QUALIFICATIONS All armed members of the Security Force, excluding Central/Secondary Alarm Station (CAS/SAS) operators, will comply with the physical fitness requirements by successfully demonstrating the performance objectives for Task 5.5 as outlined in Appendix B, Vehicle Escort Officer. The results of the physical fitness testing will be recorded as prescribed in Section 2, Step 2.2.4, "Individual Qualification Record (IQR)" and Section 2, Step 2.3, "Contract Personnel."

1.4 CONTRACT SECURITY PERSONNEL In accordance with the terms of the contract between this Company and the contract security service, all contract security personnel shall meet the suitability, physical and mental requirements outlined in this Plan.

1.5 PHYSICAL AND MENTAL ANNUAL REQUALIFICATION Every 12 months armed personnel and CAS Supervisors will be required to pass a physical examination in accordance with Paragraph 1.2.1 b. Armed personnel will meet the additional requirements outlined in Paragraphs 1.2.1.c, 1.2.2.b, and 1.3.

This 12 month requalification requirement may be extended with the following stipulations:

a. the maximum allowable extension shall not exceed 25% (three months) of the 12 month requalification period and

NUCLEAR MANAGEMENT COMPANY Section 1 PALISADES NUCLEAR PLANT Revision 20 SUITABILITY, TRAINING AND QUALIFICATION PLAN Page 6 of 14 TITLE: Employment Suitability and Qualification

b. the combined time extension for any three consecutive training intervals shall not exceed 3.25 times the 12 month training interval. (12 months x 3.25 = 39 months in any three consecutive years)

Verification of requalification will be as specified in Paragraphs 1.2.1.b and 1.2.2.b.

1.6 DOCUMENTATION The designated contractor representative(s) is required to document and attest to the fulfilling of each requirement outlined inthis plan. The Nuclear Oversight Department will conduct periodic audits and surveillances to ensure compliance with this program.

These documents will be available for inspection by an authorized representative of the US Nuclear Regulatory Commission.

1.7 RECORDS RETENTION Records documenting physical and mental qualifications and requalifications required by Sections 1.2.1.b, 1.2.2.b, and 1.5 of this plan shall be retained for a period of three years from the date results are obtained. These records may be maintained by the company or the contract security agency.

All test and written evaluation materials utilized to demonstrate adequate job performance of required tasks shall be on file onsite for a minimum of three years.

Each individual's initial Individual Qualification Record shall be retained on file onsite for the lifetime of the plant and three years thereafter.

1.8 CONSTRAINTS Nothing herein authorizes or requires any Company or contractor supervisor to investigate into or judge the reading habits, political or religious beliefs, or attitudes on social, economic or political issues of any person. The provisions of Company and Federal Equal Employment Opportunity programs will be strictly adhered to.

NUCLEAR MANAGEMENT COMPANY Section 2 PALISADES NUCLEAR PLANT Revision 20 SUITABILITY, TRAINING AND QUALIFICATION PLAN Page 7 of 14 TITLE: Training and Qualifications 2.0 TRAINING AND QUALIFICATIONS 2.1 TRAINING REQUIREMENTS Objectives of this training program are to produce security personnel fully qualified and capable of performing crucial tasks associated with their assigned security duties and to insure they maintain proficiency by detecting any deficiencies in performance. The manner in which individuals are qualified and proficiency is maintained includes formal, on-the-job training and/or, at the time of hiring, determines the individual possesses the necessary knowledge and skills by testing of required performance objectives. As determined by the licensee, initial task evaluations of security personnel will be by practical demonstration when feasible.

Proficiency is maintained by ongoing training and performance evaluation.

Individual and force effectiveness to meet contingency response tasks will be demonstrated by an officer participating in at least one drill per year and successfully passing a written examination on contingency response procedures.

To qualify, the individual must receive a minimum passing score of 70 percent correct answers on written tests and/or demonstrate the correct technique for each action element indicated on the supervisor's checklists as required for any critical task associated with his/her shift assignment. In the event an individual, at any time, fails to demonstrate the required degree of proficiency, he or she will receive retraining until satisfactory performance is demonstrated by retesting of the required performance objective or a decision is made to permanently disqualify the individual.

2.1.1 The training/evaluation program begins as a portion of the hiring process. During the initial interview, it is determined if the individual has had any previous training and/or experience with similar security programs. If experience is indicated, the person will be evaluated to determine his or her specific training needs. The Company training program is designed to initially qualify an individual in the position requiring proficiency in the least number of tasks; ie, Personnel Search Officer (PSO). When an individual qualifies as a PSO, he or she then receives the additional training necessary to qualify in the position requiring the next least number of tasks; ie,Vehicle Search Officer (VSO). The training needs to progress from one position to another have been determined and are outlined in Appendix B.

Thus, an individual will eventually progress, through a combination of training techniques and job experience, from the position requiring the least degree of knowledge and skill to the most challenging position. This program is outlined in Appendix A.

Weapons qualification may be performed prior to initiation of training in any other tasks to ensure newly hired armed officer candidates or unarmed officers seeking armed officer qualification can successfully qualify with required weapons.

NUCLEAR MANAGEMENT COMPANY Section 2 PALISADES NUCLEAR PLANT Revision 20 SUITABILITY, TRAINING AND QUALIFICATION PLAN Page 8 of 14 TITLE: Training and Qualifications 2.2 QUALIFICATION REQUIREMENTS 2.2.1 Individual Responsibilitv Matrix A detailed review has been made of the site physical security and safeguards contingency plans and procedures. Based upon the identified tasks the responsibilities of the contract security personnel were established. The established responsibilities, by job position, are outlined in the Individual Responsibility Matrix, Appendix C. These tasks were used in conducting the job analysis as outlined in Section 2.2.2, "Job Analysis."

2.2.2 Job Analysis Utilizing the Individual Responsibility Matrix (Appendix C), a specific job analysis was accomplished for each shift assignment indicated. The purpose of the analysis (Appendix B) was to authenticate and identify crucial tasks required for the successful implementation of the plant security and safeguards contingency plans which are of sufficient difficulty to require evaluation. The identified crucial tasks along with established standards and conditions will be used for the qualification evaluation of individuals assigned to the specific shift assignments.

2.2.3 Duty Qualification All personnel assigned to security-related duties are required to successfully demonstrate the capability to perform all crucial security tasks, under the conditions and to the standards specified on the applicable Job Analysis Sheet(s) prior to assignment to the specific shift assignment involved. The demonstration must be performed to the satisfaction of an appropriate Plant or Security Supervisor. The individual will receive retraining in the event the demonstration is unsatisfactory.

The routine performance of a task meets this objective provided it is accomplished in accordance with the specifications outlined in the appropriate Job Analysis Sheet (Appendix B).

2.2.4 Individual Qualification Record (IQR)

An IQR is maintained for each individual assigned to security-related duties. The IQR outlines each specific task required for a given shift assignment function, the date that the successful performance for each task was completed, the initials of the evaluating supervisor and examinee certifying completion. Upon initiation of requalification, a new IQR will be utilized to record the evaluation. The IQR(s) for each individual assigned to security-related duties will be available for inspection by an authorized representative of the US Nuclear Regulatory Commission.

NUCLEAR MANAGEMENT COMPANY Section 2 PALISADES NUCLEAR PLANT Revision 20 SUITABILITY, TRAINING AND QUALIFICATION PLAN Page 9 of 14 TITLE: Training and Qualifications 2.2.5 Test Materials All test and evaluation materials, to include individual qualification records, utilized to demonstrate adequate performance of required tasks will be retained on the plant site for a minimum of 3 years for inspection by an authorized representative of the NRC.

2.3 CONTRACT PERSONNEL All contract personnel assigned to security-related duties will meet the training and qualification requirements outlined in this plan. The Security Training Manager or designated contract agency representative will, prior to assigning any contract Security Force member to security-related duties, certify that he has reviewed the individual's IQR and that the person has demonstrated adequate performance for all tasks required of the shift assignment position(s) indicated. Training records will be audited on a periodic basis by the Nuclear Oversight Department.

2.4 REQUALIFICATION 2.4.1 All personnel assigned to security related duties shall, once every 12 months, successfully demonstrate the capability to perform all tasks outlined in the applicable Job Analysis Work Sheet(s). This 12 month requalification period may be extended under the following conditions:

a. the maximum allowable extension shall not exceed 25% (three months) of the 12 month requalification period and
b. the combined time extension for any three consecutive 12 month requalification periods shall not exceed 3.25 times the 12 month requalification period. (12 months x 3.25 = 39 months in any three consecutive years.)

The results of the requalifications will be documented and attested to as outlined in Paragraphs 2.2.4 and 2.3 above.

2.4.2 Personnel holding training positions shall be exempt from requirements in Paragraph 2.2.4 with the exception of weapons qualifications, physical examination and physical agility. Qualification in the remaining tasks, as indicated in the Job Analysis Sheet, shall be evaluated by the individual's supervisor, based on observed duty performance.

NUCLEAR MANAGEMENT COMPANY Section 3 PALISADES NUCLEAR PLANT Revision 20 SUITABILITY, TRAINING AND QUALIFICATION PLAN Page 10 of 14 TITLE: Weapons Training 3.0 WEAPONS TRAINING 3.1 All personnel required to be armed in the performance of their duties shall receive weapons training in accordance with the provisions of this plan. The training will ensure each individual is knowledgeable in the safe use of his or her assigned weapons and shall include the material concerning: Weapons clearing, loading, unloading, reloading and storage, combat firing day and night for the handgun, rapid firing for the weapons, close quarters firing, stress firing, and target recognition. Each individual must complete the initial training prior to being armed and at 12 month intervals thereafter. Requalification training may be extended beyond the 12 month training interval under the following conditions:

a. the maximum allowable extension shall not exceed 25% (three months) of the 12 month requalification training interval and
b. the combined time extension for any three consecutive training intervals shall not exceed 3.25 times the 12 month training interval. (12 months x 3.25 = 39 months in any three consecutive years.)

3.2 Documentation of training provided will be in accordance with Section 2, Step 2.2.4, "Individual Qualification Record (IQR)= and Section 2, Step 2.3, "Contract Personnel". The specific material covered by the training program is available for inspection by authorized representatives of the NRC.

NUCLEAR MANAGEMENT COMPANY Section 4 PALISADES NUCLEAR PLANT Revision 20 SUITABILITY, TRAINING AND QUALIFICATION PLAN Page 11 of 14 TITLE: Weapons Qualification and Requalification Program 4.0 WEAPONS QUALIFICATION AND REQUALIFICATION PROGRAM Each individual required to be armed in the performance of his or her security-related duties shall qualify in the use of assigned weapon(s) as indicated below.

The individual must qualify with the weapon prior to being armed on duty and documentation of the qualification be accomplished as indicated in Section 2, Step 2.2.4, "Individual Qualification Record (IQR)", and Section 2, Step 2.3, "Contract Personnel".

4.1 HANDGUN RANGE AND NUMBER OF STAGE POINTS DISTANCE ROUNDS POSITION 1 10 15 Feet 10 Standing 2 10 15 Feet 10 Standing

_ 3 10 15 Feet 10 Standing Three 8" x 11.5" sheets of paper shall be used as targets. Each round shall be scored as a "hit" or umiss." A uhit" is a round that entered through the paper and is assigned a point value of one (1). A "miss" is a round that has not entered the paper and is assigned a point value of zero (0).

Total Possible Score: 30 points.

Qualifying Score: Ž24 points

NUCLEAR MANAGEMENT COMPANY Section 5 PALISADES NUCLEAR PLANT Revision 20 SUITABILITY, TRAINING AND QUALIFICATION PLAN Page 12 of 14 TITLE: Weapons Qualification and Requalification Program 4.2 RIFLE To qualify in use of the rifle, the individual must successfully complete the following course with a minimum score of 80% (i.e., 39 hits out of a possible 48 within the shaded area):

RANGE NUMBER STAGE DISTANCE OF ROUNDS TIME POSITION I 50 YARDS 2 5 SECONDS STRONG SIDE STANDING BARRICADE 50YARDS 2 5SECONDS REACTION SIDE STANDING 2 50 YARDS 2 5 SECONDS STRONG SIDE STANDING 4 50 YARDS 2 5 SECONDS REACTION SIDE STANDING 45 YARDS 2 5 SECONDS BARRICADE 5 25 YARDS 2 25 YARDS 2 5 5 SECONDS SECONDS STRONG STRONG SIDE SIDE STANDING STNDEING 25 YARDS 2 5 SECONDS STRONG SIDE KNEELING 6 25 YARDS 2 5 SECONDS STRONG SIDE STANDING 10 25 YARDS 2 5 SECONDS BARRICADE 82 25 YARDS 2 5 SECONDS BARRICADE 9 25YARDS 2 5SECONDS ~~STRONG SIDE STANDING 13 25 YARDS 25 SECONDS BARRICADE 11 25 YARDS 2 5 SECONDS STRONG SIDE KTNEING STRONG SIDE KNEELING STRONG SIDE KNEELING 10 25 YARDS 2 5 SECONDS

______________BARRICADE 15 25 YARDS 2 5 SECONDS STRONG SIDE STANDING 16 25 YARDS 2 5 SECONDS BARRICADE 12 25 YARDS 2 5 SECONDS STRONG SIDE KNEELING 12 25 YARDS 2 5 SECONDS BARRICADE REACTION SIDE STANDING 13 25 YARDS 2 5 SECONDS BARRICADE 1 25YARDS 2 5SECONDS REACTION SIDE KNEELING 14 25 YARDS 2 5 SECONDS BARRICADE 15 25YARDS 2 15 25 YARDS 2 5SECONDS 5 SECONDS

~~REACTION SIDE STANDING

~BARRICADE 16 25YARDS 2 16 25 YARDS 2 5SECONDS 5 SECONDS

~~REACTION SIDE KNEELING

~BARRICADE 17 25 YARDS 2 5 SECONDS REACTION SIDE STANDING BARRICADE 18 25YARDS 2 18 25 YARDS 2 5SECONDS 5 SECONDS

~~REACTION SIDE KNEELING

~BARRICADE 19 25YARDS 2 19 25 YARDS 2 5SECONDS 5 SECONDS

~~REACTION SIDE STANDING

~BARRICADE 20 25YARDS 2 20 25 YARDS 2 5SECONDS 5 SECONDS

~~REACTION SIDE KNEELING

~BARRICADE 21 25YARDS 2 21 25 YARDS 2 5SECONDS 5 SECONDS

~~STRONG~BARRICADE SIDE STANDING 22 25YARDS 2 22 25 YARDS 2 5SECONDS 5 SECONDS

~~STRONG~BARRICADE SIDE KNEELING

NUCLEAR MANAGEMENT COMPANY Section 5 PALISADES NUCLEAR PLANT Revision 20 SUITABILITY, TRAINING AND QUALIFICATION PLAN Page 13 of 14 TITLE: Weapons Qualification and Requalification Program RANGE NUMBER STAGE DISTANCE OF ROUNDS TIME POSITION 23 25 YARDS 2 5 SECONDS REACTION SIDE STANDING 24 25 YARDS 2 5 SECONDS REACTION SIDE KNEELING 4.3 REQUALIFICATION Individuals required to be armed in the performance of their security related duties shall be requalified in the use of their assigned weapons once every 12 months.

This 12 month requalification period may be extended under the following conditions:

a. the maximum allowable extension shall not exceed 25% (three months) of the 12 month requalification period and
b. the combined time extension for any three consecutive 12 month requalification periods shall not exceed 3.25 times the 12 month requalification period. (12 months x 3.25 = 39 months in any three consecutive years).

The requalification will be in accordance with the provisions of Paragraphs 4.0 and 4.2 above the documented in accordance with Section 2, Step 2.2.4, 'Individual Qualification (IQR)", and Section 2, Step 2.3, "Contract Personnel".

NUCLEAR MANAGEMENT COMPANY Section 5 PALISADES NUCLEAR PLANT Revision 20 SUITABILITY, TRAINING AND QUALIFICATION PLAN Page 14 of 14 TITLE: Weapons Qualification and Requalification Program 5.0 GUARD, ARMED RESPONSE AND ARMED ESCORT EQUIPMENT 5.1 FIREARMS An adequate number of handguns and rifles are maintained at the plant to arm all security personnel required of the security manpower requirements as outlined in the Plant Security and Contingency Plans. All weapons meet, as a minimum, specifications outlined in 10 CFR 73.55, Appendix B, Section V.

5.2 AMMUNITION 5.2.1 For each assigned weapon as appropriate to the individual's assigned contingency security job duties and as readily available as the weapon:

a. 18 rounds per handgun.
b. 100 rounds per rifle.

5.2.2 Ammunition available onsite is two (2) times the amount stated in 5.2.1 above for each weapon.

5.3 CONTINGENCY EQUIPMENT The following personnel equipment is readily available for issue to individuals assigned tasks in accordance with the plant Contingency Plan:

a. Riot Helmets
b. Flexible Restraints
c. Rifles

NUCLEAR MANAGEMENT COMPANY Appendix A PALISADES NUCLEAR PLANT Revision 20 SUITABILITY, TRAINING AND QUALIFICATION PLAN Page 1 of 1 TITLE: Licensee Training Program Security Force Leader (SFL)

Security Shift Leader (SSL)

Response Force Leader (RFL)

Central/Secondary Alarm Station Supervisor (CAS/SAS)

ID Station Supervisor (IDSS)

Response Force Member (RFM)

Patrol Officer (PO)

  • Vehicle Escort Officer (VEO)

Vehicle Search Officer (VSO)

Personnel Search Officer (PSO)

Determine Proficiency Level Hiring Process

  • Crucial Task 5.1, "Demonstrate Qualification in Use of Handgun" is a crucial task in qualification as Vehicle Escort Officer. This task may be performed prior to initiation of training in any other task to ensure newly hired armed officer candidates or unarmed officers seeking armed officer qualification can successfully qualify with required weapons.

NUCLEAR MANAGEMENT COMPANY Appendix B PALISADES NUCLEAR PLANT Revision 20 SUITABILITY, TRAINING AND QUALIFICATION PLAN Page 1 of 20 Job Analysis SHIFT ASSIGNMENT:

Personnel Search Officer Number Duties and Tasks Conditions Standards (Actions) (Measurable and Observable) 2.1 Control Personnel Entry Control Facility, Picture Demonstrate ability to (1) Determine proper personnel Access Badges; Visitors Logs; identification (2) Locate and issue correct badge, keycard Magnetic Key Cards; (3) Explain badge coding (4) Make proper visitor Individual Seeking Access/ notifications (5) Complete Visitor Log (6) Identify escort Depart Area. (7) Recover badges.

2.1.1 Conducts Searches of Use Metal and Explosive Det; Will properly check each category of individual, Suspicious Persons Use Metal and Explosive Det demonstrate ability to recognize prohibited items usable Plus Pat Search. All Outer for sabotage (ie, firearms, explosives, incendiary Garment Pat Search. devices) and how to handle contraband.

2.1.1.1 Conducts Pat Down Individual at Personnel Demonstrates following proper Search Entry Point Requesting Entry. sequence:

1. Obtains individual's permission.
2. Security Officer and individual are same sex.

(Search may be conducted by officer of opposite sex if individual being searched grants approval.)

3. Conducts search correctly.
4. Takes appropriate action if contraband is found.

NUCLEAR MANAGEMENT COMPANY Appendix B PALISADES NUCLEAR PLANT Revision 20 SUITABILITY, TRAINING AND QUALIFICATION PLAN Page 2 of 20 Job Analysis SHIFT ASSIGNMENT:

Personnel Search Officer Number Duties and Tasks Conditions Standards (Actions) (Measurable and Observable) 2.1.1.2 Conducts Metal Detector Individual at Personnel Entry Demonstrate proper procedure if detector alarms.

Searches Point Requesting Admission

1. Walk Through Detector Individual and Metal Demonstrate proper procedure in use. Follow Detector proper procedure if detector alarms.

2.1.1.3 Conducts Explosive Individual and Explosive Demonstrate:

Detector Searches Detector

1. Use of detector operation and alarm conditions.
2. Proper procedure for vapor alarm, illegal exit condition.

2.1.1.4 Observes/Patrols Designated A specific Physical Security Demonstrate correct procedures to compensate for Areas Equipment Failure Daytime/ (1) failure of intrusion detection systems (2) excessive Nighttime wind or other spurious alarms and properly report observations to CAS/SAS.

2.1.4 Conducts Visitor Escort Individual(s) Not Authorized Demonstrate ability to maintain continual and effective Unescorted Entry observation over visitor, permit access to only authorized areas; detecting and reporting to CAS/SAS of unauthorized activity.

NUCLEAR MANAGEMENT COMPANY Appendix B PALISADES NUCLEAR PLANT Revision 20 SUITABILITY, TRAINING AND QUALIFICATION PLAN Page 3 of 20 Job Analysis SHIFT ASSIGNMENT:

Personnel Search Officer Number Duties and Tasks Conditions Standards (Actions) (Measurable and Observable) 2.3 Conducts Physical Hand CarTied Items Demonstrate proper search procedures and ability to Searches of Packages recognize prohibited items which could be used for sabotage (ie, firearms, explosives, incendiary devices).

2.3.1 Search Packages Using X-ray Device Demonstrate ability to use X-ray device if available, an X-ray Device to detect, control and report prohibited items which could be used for sabotage ( ie, firearms, explosives, incendiary devices); report any event which appears to be a malfunction.

4.9 Ensure All Radio and Two-Way Radio, Intra-Plant Demonstrate ability to, in accordance with site Line Communications Telephone, Intra-Plant Paging procedures, conduct operational tests of communications Systems Are Functioning Telephone, Emergency systems.

Telephone 5.3 Use of Radio Portable Radio and/or Demonstrate ability to, in accordance with site Communications Repeater/Remote procedures, conduct operational test of hand held radio transceiver, report improper test results, transmit radio message.

7.1.2 Direct/Search for Plant Work Area/ Demonstrate ability to (1) properly search area Bomb Simulated Bomb Device (2) locate unauthorized item (3) report findings and location (4) control access pending further instructions.

NUCLEAR MANAGEMENT COMPANY Appendix B PALISADES NUCLEAR PLANT Revision 20 SUITABILITY, TRAINING AND QUALIFICATION PLAN Page 4 of 20 Job Analysis SHIFT ASSIGNMENT:

Personnel Search Officer Number Duties and Tasks Conditions Standards (Actions) (Measurable and Observable) 7.1.4 Contingency - Increase Simulated Contingency Event Demonstrate ability to maintain access controls required Access Controls during a contingency.

7.1.6 Contingency - Visitor Access Simulated Contingency Event Demonstrate ability to properly control visitor access.

NUCLEAR MANAGEMENT COMPANY Appendix B PALISADES NUCLEAR PLANT Revision 20 SUITABILITY, TRAINING AND QUALIFICATION PLAN Page 5 of 20 Job Analysis SHIFT ASSIGNMENT:

Vehicle Search Officer Number Duties and Tasks Conditions Standards (Actions) (Measurable and Observable) 2.2.1 Conducts Physical Vehicle Vehicle at Protected Area Demonstrate knowledge of search requirements of all Searches Entry categories of vehicles (designated, emergency, exiting vehicles, etc) and proper search of a vehicle:

(1) instructions to driver (2) vehicle cab area (3) cargo area (4) underhood/engine compartment (5) undercarriage, wheel wells, bumpers (6) use of mirrors.

2.4 Conducts Physical Cargo Vehicle Entry Point and Must demonstrate knowledge of search requirements for Searches Bills of Lading Describing category of cargo involved and give examples of cargo Various Types of Cargo for each Category: I. II, III, IV, V, IV.

NUCLEAR MANAGEMENT COMPANY Appendix B PALISADES NUCLEAR PLANT Revision 20 SUITABILITY, TRAINING AND QUALIFICATION PLAN Page 6 of 20 Job Analysis SHIFT ASSIGNMENT:

Vehicle Escort Officer Number Duties and Tasks Conditions Standards (Actions) (Measurable and Observable)

AU crucial tasks required by shift assignments of Personnel and Vehicle Search Officers 2.2.2 Escort Non-designated Non-designated Vehicle at Escort Officer must demonstrate continual and effective Vehicles Entry Point observation and control over both driver and vehicle, secure vehicle in accordance with site procedures if left unattended, prevent loading/unloading of unauthorized materials.

5.1 Demonstrate Qualification Classroom, Suitable Weapons Must demonstrate with weapon ability to: (1)safely use in Use of Handguns Range, Handgun and Necessary (2) proper clearing (3) loading, unloading and storage I Ammunition (4) combat firing, day and night (5) rapid firing (6) close firing (7) stress firing and target recognition (8) achieve qualifying score firing established course.

NUCLEAR MANAGEMENT COMPANY Appendix B PALISADES NUCLEAR PLANT Revision 20 SUITABILITY, TRAINING AND QUALIFICATION PLAN Page 7 of 20 Job Analysis SHIFT ASSIGNMENT:

Vehicle Escort Officer Number Duties and Tasks Conditions Standards (Actions) (Measurable and Observable)

All crucial tasks required by the shift assignments of Personnel and Vehicle Search Officers 5.5 Demonstrate Required Doctors Statement of Demonstrate ability to complete following physical agility Physical Fitness Satisfactory Physical course within 2 minutes 45 seconds while wearing a Condition handgun (may be simulated) and weapons belt:

  • Run 100 yards to building, pick up rifle and load 1 magazine of ammunition (may be dummy rounds);
  • Run 50 yards and ascend stairway to lower shooting plafform;
  • Perform tactical maneuver using handgun;
  • Descend stairway from lower shooting plafform;
  • Run 50 yards to building, perform tactical maneuver using handgun or rifle;
  • Run 50 yards to course end.

NUCLEAR MANAGEMENT COMPANY Appendix B PALISADES NUCLEAR PLANT Revision 20 SUITABILITY, TRAINING AND QUALIFICATION PLAN Page 8 of 20 Job Analysis SHIFT ASSIGNMENT:

Patrol Officer Number Duties and Tasks Conditions Standards (Actions) (Measurable and Observable)

All cruclal tasks required by the shift assignments of Personnel and Vehicle Search, Vehicle Escort Officers 2.1.2 Controls Personnel Vital Area Entry Portal Demonstrate knowledge of personnel entry Portals (Vital Areas) requirements, unescorted/ escorted to vital areas, badges, area designations, key card.

3.2 Survey Protected Area Protected Area Daylight Demonstrate knowledge of frequency, method and Nighttime; Required Keys, purpose of patrols including (1) capability to demonstrate Radio correct patrol activities (2) checking isolation zones, fencing, gates, alarm devices, perimeter lighting, personnel and vehicle identification, vehicle barrier system (3) reporting fire and unusual items/events (4) completing documentation.

3.4 Inspects Vital Areas Vital Doors - Key Card Demonstrate ability to locate all entrances to designated vital areas and proper use of key cards.

Note: Security Officers will participate in at least one contingency drill per year and successfully pass an examination on contingency response procedures.

NUCLEAR MANAGEMENT COMPANY Appendix B PALISADES NUCLEAR PLANT Revision 20 SUITABILITY, TRAINING AND QUALIFICATION PLAN Page 9 of 20 Job Analysis SHIFT ASSIGNMENT:

Patrol Officer Number Duties and Tasks Conditions Standards (Actions) (Measurable and Observable) 3.5 Patrols Special Designated A Specific Physical Security Demonstrate correct procedures to compensate for Areas Equipment Failure Daylight/ (1) protected area barrier deterioration (2) loss of Nighttime illumination. Properly completes required notification to CAS/SAS.

4.2 Ensure Perimeter Fencing Protected Area Perimeter Demonstrates ability to properly check, identify and Is In Proper Condition Nighttime document deficiencies.

7.1.5 Contingency Patrols Designated Area, Simulated Demonstrate ability to (1) proceed to area by most direct Contingency Event route (2) correctly patrol area (3) report suspicious activity to CAS/SAS.

7.1.7 Respond to Perimeter Perimeter Intrusion Alarm Demonstrate ability to proceed to designated sector Intrusion Alarms Simulated Security within 5 minutes, properly reporting security situation Situation to CAS/SAS.

7.1.9 Respond to Unidentified Simulated/Actual Demonstrate ability to proceed to protected area; specific Person at or Within Unidentified Individual in part of proper procedures for handling individual and Perimeter or at Protected Area reporting situation to CAS/SAS.

Note: Security Officers will participate in at least one contingency drill per year and successfully pass an examination on contingency response procedures.

NUCLEAR MANAGEMENT COMPANY Appendix B PALISADES NUCLEAR PLANT Revision 20 SUITABILITY, TRAINING AND QUALIFICATION PLAN Page 10 of 20 Job Analysis SHIFT ASSIGNMENT:

Patrol Officer Number Duties and Tasks Conditions Standards (Actions) (Measurable and Observable)

Actual or Simulated Breach 7.1.10 Response to Breach of Actual or Simulated Breach Demonstrate ability to proceed to barrier location and Perimeter Barrier in Perimeter Barrier proper reporting of situation to CAS/SAS. Maintaining surveillance.

7.1.12 Respond to Vital Area Simulated Vital Area Alarm Demonstrate knowledge of specific location, response, Alarms time restraints, reporting procedure to CAS/SAS.

7.1.14 Investigates/Reports Vital Area Alarm Demonstrate ability to correctly enter area; investigate Vital Area Alarms situation, awareness of radiation protection boundaries, reporting results to CAS/SAS and, if required, maintaining surveillance.

Note: Security Officers will participate in at least one contingency drill per year and successfully pass an examination on contingency response procedures.

NUCLEAR MANAGEMENT COMPANY Appendix B PALISADES NUCLEAR PLANT Revision 20 SUITABILITY, TRAINfNG AND QUALIFICATION PLAN Page 11 of 20 Job Analysis SHIFT ASSIGNMENT:

Patrol Officer Number Duties and Tasks Conditions Standards (Actions) (Measurable and Observable) 7.1.15 Investigates Report of Actual/Simulated Demonstrate ability to correctly enter area; proper Unidentified/Unauthorized Unidentified/Unauthorized handling of individual and reporting procedures to Individual Entering Vital Individual in Vital Area CAS/SAS. This includes positive surveillance of suspect Area until support personnel arrive, and, as appropriate, detain suspect within legal limits of Michigan Law. Authority of armed personnel to use weapons shall be limited to the extent and degree permissible under the laws of the State of Michigan. A search of this individual, if lawfully detained, should be conducted, using appropriate method (ie, hands-on).

7.1.16 Investigates Report of Vital Simulated Vital Area Breach Demonstrates ability to proceed to location within 5 Area Boundary Found minutes and proper reporting procedures to Insecure or Breached CAS/SAS.

7.1.17 Investigates Security Force Simulated Security Demonstrate ability to report to area; conduct an Member Failure to Perform Force Member Failure an adequate investigation and report situation to by Position or Location CAS/SAS.

Note: Security Officers will participate in at least one contingency drill per year and successfully pass an examination on contingency response procedures.

NUCLEAR MANAGEMENT COMPANY Appendix B PALISADES NUCLEAR PLANT Revision 20 SUITABILITY, TRAINING AND QUALIFICATION PLAN Page 12 of 20 Job Analysis SHIFT ASSIGNMENT:

Patrol Officer Number Duties and Tasks Conditions Standards (Actions) (Measurable and Observable) 7.1.18 Investigates Discovery of Simulated Bomb or Sabotage Demonstrates ability to report to area; conduct an initial Bomb or Sabotage Device Device investigation, report situation to CAS/SAS; properly isolate area.

7.1.19 Investigate Fire, Simulated Fire, Explosion Demonstrate ability to respond to area of event, Explosion or Other or Catastrophe investigate for security aspects and accurately report Catastrophe to CAS/SAS.

7.1.21 Investigates Multiple Simulated Multiple Loss of Demonstrate ability to proceed to location of offsite Loss of Offsite Offsite Communications communications equipment, identify obvious damage Communications and to properly report to CAS/SAS.

7.1.22 Investigate Sabotage; Simulated Device/ Demonstrates ability to report to designated facility Device Inoperable, Equipment or Intruder location, take correct actions to handle device or Tampered/Deranged intruder, proper reporting of situation to CAS/SAS.

Equipment Restored, Intruder/Saboteur Captured or Escaped 7.1.23 Security Alert Patrol Simulated Security Alert Demonstrate ability to correctly patrol protected and vital areas as directed and control access when directed.

Note: Security Officers will participate in at least one contingency drill per year and successfully pass an examination on contingency response procedures.

NUCLEAR MANAGEMENT COMPANY Appendix B PALISADES NUCLEAR PLANT Revision 20 SUITABILITY, TRAINING AND QUALIFICATION PLAN Page 13 of 20 Job Analysis SHIFT ASSIGNMENT:

Response Force Member Number Duties and Tasks Conditions Standards (Actions) (Measurable and Observable)

All crucial tasks required by shift assignments of Personnel and Vehicle Search, Vehicle Escort and Patrol Officers:

5.2 Demonstrate Qualification Classroom, rifle, ammunition, Must demonstrate, with appropriate weapon, ability to in Use of rifle Suitable Range (1) use safely (2) properly clear (3) load, unload, correctly store (4) combat fire, day/night (5) rapid fire as appropriate, (6) close firing, (7) stress firing, target recognition, and (8) achieve qualifying score on established firing course.

7.1.11 Respond to Confirmed Simulated Protected Area Demonstrate ability to (1) obtain contingency equipment Protected Area Intrusion Intrusion and take security emergency station (2) demonstrate ability to systematically and effectively search area for an intruder (3) demonstrate ability to deploy as directed and (4) demonstrate ability to follow order, as directed.

7.1.20 Intemal Disturbance, Simulated Intemal Demonstrate ability to obtain contingency equipment Respond to Terminate or Disturbance and take appropriate action as directed to terminate Other Actions, As appropriate action as directed to terminate condition.

Directed.

NUCLEAR MANAGEMENT COMPANY Appendix B PALISADES NUCLEAR PLANT Revision 20 SUITABILITY, TRAINING AND QUALIFICATION PLAN Page 14 of 20 Job Analysis SHIFT ASSIGNMENT:

ID Station Supervisor Number Duties and Tasks Conditions Standards (Actions) (Measurable and Observable)

All crucial tasks required by the shift assignments of Personnel and Vehicle Search, Vehicle Escort, Patrol Officers and Response Force Member 2.1.3 Controls Personnel Portals ID Station Facilities Demonstrate ability to (1) Monitor and control access (Protected Area) portal (2) recover keys.

2.2 Control Vehicle Access ID Station Facilities and Demonstrate ability to control vehicle gates (1) using Vehicle Gate Keys CCTV (2) electronic releases (3) correct issuance of keys.

3.6 Surveys CCTV Monitored ID Station Facilities Demonstrate ability to correctly use CCTV to survey Areas responsible areas.

4.1 Ensure CCTV Is ID Station Facilities Demonstrate ability to correctly test CCTV equipment Functioning Properly (1) switching unit (2) monitor (3) windshield wipers (4) maintaining proper records (5) test frequency (6) recording malfunctions.

6.1 Monitors Alarm Displays ID Station Facilities Demonstrate ability to properly monitor explosive and and Sensors metal detection equipment.

7.1.3 Contingency - Personnel Simulated Contingency Demonstrate ability to maintain access controls required and Vehicle Access Event during a contingency.

Note: Security Officers will participate in at least one contingency drill per year and successfully pass an examination on contingency response procedures.

NUCLEAR MANAGEMENT COMPANY Appendix B PALISADES NUCLEAR PLANT Revision 20 SUITABILITY, TRAINING AND QUALIFICATION PLAN Page 15 of 20 Job Analysis SHIFT ASSIGNMENT:

CAS and SAS Supervisors Number Duties and Tasks Conditions Standards (Actions) (Measurable and Observable)

Successfully complete all classroom training related to use of equipment and tactical considerations and demonstrate:

1.1.1.2 Coordinates and Directs Simulated Threat-Event Demonstrate ability to locate and use the proper All Threat-Event Responses Situation contingency response checklist.

1.1.1.3 Makes Command Decisions Simulate Threat-Event Demonstrate ability to promptly determine the authority and Threat Responses Situation for making command decisions during any specific emergency situation.

3.1 Surveys Owner-Controlled CCTV-CAS/SAS Console Demonstrate the ability to use available equipment to Area survey the isolation zones in the owner-controlled area.

3.3 Utilizes CCTV to Survey CAS/SAS Console CCTV Demonstrate the ability to use available equipment to Protected Area Units survey the isolation zones in the protected area.

4.6 Ensure Perimeter Alarms CAS/SAS Console Demonstrate ability to perform tests in accordance with Are Functioning and site procedures.

Tested As Required 4.7 Ensure Access Alarms Are CAS/SAS Console Demonstrate proper techniques for knowledge of Functioning Properly required frequency for testing intrusion alarms for vital area.

NUCLEAR MANAGEMENT COMPANY Appendix B PALISADES NUCLEAR PLANT Revision 20 SUITABILITY, TRAINING AND QUALIFICATION PLAN Page 16 of 20 Job Analysis SHIFT ASSIGNMENT:

CAS and SAS Supervisors Number Duties and Tasks Conditions Standards (Actions) (Measurable and Observable) 4.8 Ensure Altemate Power CAS/SAS Consoles Demonstrate proper techniques for testing alarm Source for Security system's DC batteries. Equipment Is Functioning 5.4 Use of Offsite Public Telephones-Two Demonstrate location of list of LLEA's telephone number Communications Way Radio and radio call signs and ability to contact them.

7.1.1 Directs Security Force CAS/SAS Consoles Demonstrate ability to locate and follow appropriate Contingency Event Checklist contingency checklist.

Response

7.1.8 Direct Response to Simulated Perimeter Demonstrate ability to correctly (1) use alarm panels Perimeter Intrusion Intrusion Alarm (2) log alarms (3) dispatch security force member to Alarms include compensatory measures for malfunctioning CCTV.

7.1.13 Direct Response to Vital Simulated Vital Area Demonstrate ability to correctly (1) use alarm panels Area Alarms Alarm (2) log alarms and (3) dispatch security force member.

NUCLEAR MANAGEMENT COMPANY Appendix B PALISADES NUCLEAR PLANT Revision 20 SUITABILITY, TRAINING AND QUALIFICATION PLAN Page 17 of 20 Job Analysis SHIFT ASSIGNMENT:

Response Force Leader Number Duties and Tasks Conditions Standards (Actions) (Measurable and Observable)

All crucial tasks required by the shift assignments of Personnel and Vehicle Search, Vehicle Escort and Patrol Officers, ID Station Supervisor, Response Force Member and CASISAS Supervisor 1.1.1.1 Deploys and Coordinates Response Force Member Plus Demonstrate ability to properly control the response force Response Force Simulated Contingency and to deploy the force in the most effective manner Situations under given contingency situations (maximum use of cover, greatest fire power, protection of resource).

4.10 Ensure Contingency Contingency Equipment and Demonstrate ability to (1) locate contingency equipment Equipment and Weapons Weapons and weapons (2) ensure ready availability and (3) proper Are Available and Operational quantity and operational condition.

NUCLEAR MANAGEMENT COMPANY Appendix B PALISADES NUCLEAR PLANT Revision 20 SUITABILITY, TRAINING AND QUALIFICATION PLAN Page 18 of 20 Job Analysis SHIFT ASSIGNMENT:

Security Shift Leader Number Duties and Tasks Conditions Standards (Actions) (Measurable and Observable)

All crucial tasks required by the shlft assignments of Personnel and Vehicle Search, Vehicle Escort and Patrol Officers, Response Force Members and Leaders, ID Station Supervisor, CASISAS Supervisors.

1.1.1 Conducts Command and During Normal and Demonstrate ability to identify chain of authority under all Control Contingency Security operations. Designates successor in event of Conditions nonavailability.

1.1.1.6 Supervises Contingency Simulated Operational Demonstrate ability to provide on-the-job training to SFM Response Orientation Situation - Security Force and evaluate demonstrated proficiency.

Drill and Testing Member 4.3 Ensure Metal Detectors Site-Approved Testing Demonstrates proper site procedures for operational Are Properly Tested Device tests.

4.4 Ensure X-ray Machine Is Using Site-Approved Demonstrate proper site procedures for operational tests.

Properly Tested Testing Procedure 4.5 Ensure Explosive Detector Using Site-Approved Demonstrate proper site procedures for operational tests.

is Properly Tested Testing Procedures 7.1 Directs Contingency Event Simulated Contingency Demonstrate ability to locate and follow appropriate Response Event - No Security contingency event checklist.

Manager Onsite

NUCLEAR MANAGEMENT COMPANY Appendix B PALISADES NUCLEAR PLANT Revision 20 SUITABILITY, TRAINING AND QUALIFICATION PLAN Page 19 of 20 Job Analysis SHIFT ASSIGNMENT:

Security Shift Leader Number Duties and Tasks Conditions Standards (Actions) (Measurable and Observable) 8.1 Records Functional Tests Daily Activities Log - Security Must demonstrate ability to record functional test.

Equipment Test List 8.2 Records Equipment Outages See 8.1 Must demonstrate ability to identify types of malfunctions and when and how to report.

NUCLEAR MANAGEMENT COMPANY Appendix B PALISADES NUCLEAR PLANT Revision 20 SUITABILITY, TRAINING AND QUALIFICATION PLAN Page 20 of 20 Job Analysis SHIT TASSIGNMENT:

Security Force Leader Number Duties and Tasks Conditions Standards (Actions) (Measurable and Observable)

Must be familiar with all tasks required by each shift assignment on the securfty force however, demonstrated proficiency is not required.

1.1 Conducts Security Normal and Contingency Demonstrate ability, under specified conditions, to Personnel Supervision Operations determine security force personnel are fulfilling and Management operational requirements.

1.1.1.4 Monitors Conduct of Security Contract, Security Demonstrate ability to develop appropriate training Training and Contingency Plans criteria to ensure contractual and security requirements are fulfilled.

1.1.1.5 Ensures Security Personnel Suitability, Training and Demonstrate complete knowledge of suitability criteria Meet Suitability Criteria Qualification Plan and provide proper documentation for each security force at Time of Hire member.

NUCLEAR MANAGEMENT COMPANY Appendix C PALISADES NUCLEAR PLANT Revision 20 SUITABILITY, TRAINING AND QUALIFICATION PLAN Page 1 of 8 Individual Responsibility Matrix Per Veh Veh Res ID Res Sec Sec Sch Sch Esc Ptl For Stat For CAS/ Sft For Off Off Off Off Mbr Supv Ldr SAS Ldr Ldr 1.0 Security Personnel Supervision and Management 1.1 Conducts Security Personnel Supervision and Management X 1.1.1 Conducts Command and Control X 1.1.1.1 Deploys and Coordinates Response Force X 1.1.1.2 Coordinates and Directs All Threat-Event Responses X

  • 1.1.1.3 Makes Command Decisions and Threat Responses X 1.1.1.4 Monitors Conduct of Training X 1.1.1.5 Ensures Security Personnel Meet Suitability Criteria at Time of Hire X 1.1.1.6 Supervises Contingency Response Orientation Drill and Testing X 2.0 Access Control 2.1 Control Personnel Access X
  • Tasks required for shift assignment in the event of security related emergency conditions as outlined in paragraph 1.4.3 of the Security Plan.

NUCLEAR MANAGEMENT COMPANY Appendix C PALISADES NUCLEAR PLANT Revision 20 SUITABILITY, TRAINING AND QUALIFICATION PLAN Page 2 of 8 Individual Responsibility Matrix Per Veh Veh Res ID Res Sec Sec Sch Sch Esc Ptl For Stat For CAS/ Sft For Off Off Off Off Mbr Supv Ldr SAS Ldr Ldr 2.1.1 Conducts Searches of Suspicious Persons X 2.1.1.1 Conducts Pat-Down Search X 2.1.1.2 Conducts Metal Detector Searches X 2.1.1.3 Conducts Explosive Detector Searches X 2.1.1.4 Observes/Patrols Designated Areas X 2.1.2 Controls Personnel Portals (Vital Areas) X 2.1.3 Controls Personnel Portals (Protected Areas) X 2.1.4 Conducts Visitor Escort X * * * * * * *

  • 2.2 Control Vehicle Access X 2.2.1 Conducts Physical Vehicle Searches X 2.2.2 Escort Non-designated Vehicles X

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  • Tasks required for shift assignment in the event of security related emergency conditions as outlined in paragraph 1.4.3 of the Security Plan.

NUCLEAR MANAGEMENT COMPANY Appendix C PALISADES NUCLEAR PLANT Revision 20 SUITABILITY, TRAINING AND QUALIFICATION PLAN Page 3 of 8 Individual Responsibility Matrix Per Veh Veh Res ID Res Sec Sec Sch Sch Esc PtI For Stat For CAS/ Sft For Off Off Off Off Mbr Supv Ldr SAS Ldr Ldr 2.3 Conducts Physical Searches of Packages X 2.3.1 Searches Packages Using an X-ray Device X 2.4 Conducts Physical Cargo Searches X 3.0 Surveillance 3.1 Surveys Owner Controlled Area X 3.2 Survey Protected Area X 3.3 Utilizes CCTV to Survey Protected Area x 3.4 Inspects Vital Areas X 3.5 Patrols Special Designated Area X 3.6 Surveys CCTV Monitored Area X 4.0 Security Equipment

  • Tasks required for shift assignment in the event of security related emergency conditions as outlined in paragraph 1.4.3 of the Security Plan.

NUCLEAR MANAGEMENT COMPANY Appendix C PALISADES NUCLEAR PLANT Revision 20 SUITABILITY, TRAINING AND QUALIFICATION PLAN Page 4 of 8 Individual Responsibility Matrix Per Veh Veh Res ID Res Sec Sec Sch Sch Esc Pt For Stat For CASI Sft For Off Off Off Off Mbr Supv Ldr SAS Ldr Ldr 4.1 Ensure CCTV Is Functioning Property X = '

4.2 Ensure Perimeter Fencing Is In Proper Condition X _

  • 4.3 Ensure Metal Detectors Are Properly Tested X 4.4 Ensure X-ray Machine is Properly Tested X 4.5 Ensure Explosive Detector is Properly Tested X 4.6 Ensure Perimeter Alarms Are Functioning/Tested as Required X 4.7 Ensure Access Alarms Are Functioning Properly X 4.8 Ensure Alternate Power Source for Security Equipment is Functioning X 4.9 Ensure All Radio and Line Communications Systems are Functioning X * * * * * *
  • 4.10 Ensure Contingency Equipment and Weapons Are Available and X
  • Operational 5.0 Security Weapons, Communications and Physical Fitness I aksrqirdfr hf asgmeti teevn f euit eatdeerec

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  • Tasks required for shftl assignment in the event of security related emergency conditions as outlined in paragraph 1.4.3 of the Security Plan.

NUCLEAR MANAGEMENT COMPANY Appendix C PALISADES NUCLEAR PLANT Revision 20 SUITABILITY, TRAINING AND QUALIFICATION PLAN Page 5 of 8 Individual Responsibility Matrix Per Veh Veh Res ID Res Sec Sec Sch Sch Esc PtI For Stat For CAS/ Sft For Off Off Off Off Mbr Supv Ldr SAS Ldr Ldr 5.1 Demonstrate Qualification in Use of Handguns X 5.2 Demonstrate Qualification in Use of rifle x 5.3 Use of Radio Communications X * * * * * * *

  • 5.4 Use of Offsite Communications X 5.5 Demonstrate Required Physical Fitness x . . .

6.0 Monitors Alarms 6.1 Monitors Alarm Displays and Sensors X 7.0 Detection and Assessment 7.1 Directs Contingency Event Response X 7.1.1 Directs Security Force Contingency Event Response X 7.1.2 Direct/Search for Bomb X - t * * * * *

  • Tasks required for shift assignment in the event of security related emergency conditions as outlined in paragraph 1.4.3 of the Security Plan.

NUCLEAR MANAGEMENT COMPANY Appendix C PALISADES NUCLEAR PLANT Revision 20 SUITABILITY, TRAINING AND QUALIFICATION PLAN Page 6 of 8 Individual Responsibility Matrix Per Veh Veh Res ID Res Sec Sec Sch Sch Esc Ptl For Stat For CAS/ Sft For Off Off Off Off Mbr Supv Ldr SAS Ldr Ldr 7.1.3 Contingency - Personnel and Vehicle Access X

  • 7.1.4 Contingency - Increase Access Controls X 7.1.5 Contingency Patrols X 7.1.6 Contingency - Visitor Access X 7.1.7 Respond to Perimeter Intrusion Alarms X 7.1.8 Direct Response to Perimeter Intrusion Alarms X 7.1.9 Respond to Unidentified Person at or Within Perimeter X *
  • 7.1.10 Respond to Breach of Perimeter Barrier x . .

7.1.11 Respond to Confirmed Protected Area Intrusion X .

7.1.12 Respond to Vital Area Alarms X 7.1.13 Direct Response to Vital Area Alarms X

  • Tasks required for shift assignment in the event of security related emergency conditions as outlined in paragraph 1.4.3 of the Security Plan.

NUCLEAR MANAGEMENT COMPANY Appendix C PALISADES NUCLEAR PLANT Revision 20 SUITABILITY, TRAINING AND QUALIFICATION PLAN Page 7 of 8 Individual Responsibility Matrix Per Veh Veh Res ID Res Sec Sec Sch Sch Esc PtI For Stat For CAS/ Sft For Off Off Off Off Mbr SUDV Ldr SAS Ldr Ldr 7.1.14 Investigates/Reports Vital Area Alarms X 7.1.15 Investigates Report of Unidentified/Unauthorized Individual Entering Vital X Area 7.1.16 Investigates Report of Vital Area Boundary Found Insecure or X Breached 7.1.17 Investigates Security Force Member Failure to Perform X 7.1.18 Investigates Discovery of Bomb or Sabotage X t .

7.1.19 Investigates Fire, Explosion or Other Catastrophe X

  • 7.1.20 Intemal Disturbance, Respond to Terminate or Other Actions as X
  • Directed 7.1.21 Investigates Multiple Loss of Off-Site Communications X 7.1.22 Investigate Sabotage: Device Inoperable, Tampered/Deranged X *
  • Equipment Restored, Intruder/Saboteur Captured or Escaped l 7.1.23 Security Alert Patrol X .
  • 8.0 Documentation and Reporting
  • Tasks required for shift assignment in the event of security related emergency conditions as outlined in paragraph 1.4.3 of the Security Plan.

NUCLEAR MANAGEMENT COMPANY Appendix C PALISADES NUCLEAR PLANT Revision 20 SUITABILITY, TRAINING AND QUALIFICATION PLAN Page 8 of 8 Individual Responsibility Matrix

_ __ __ __ __ = =.---

Per Veh Veh Res ID Res Sec Sec Sch Sch Esc Ptl For Stat For CAS/ Sft For Off Off Off Off Mbr Supv Ldr SAS Ldr Ldr 8.1 Records Functional Tests X 8.2 Records Equipment Outages X

- - - = - = l 11

  • Tasks required for shift assignment in the event of security related emergency conditions as outlined in paragraph 1.4.3 of the Security Plan.
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