ML19241B822
| ML19241B822 | |
| Person / Time | |
|---|---|
| Issue date: | 07/31/1979 |
| From: | Office of Nuclear Reactor Regulation |
| To: | |
| References | |
| NUREG-0576, NUREG-576, NUDOCS 7907240057 | |
| Download: ML19241B822 (79) | |
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N U R EG-0576 NUCLEAR POWER REACTOR SECURITY PERSONNEL TRAINING AND QUALIFICATION PLAN REVIEWER WORKBOOK Interim Report Manuscript Completed: June 1979 Date Published: July 1979 Division of Operating Reactors Office of Nuclear Reactor Regulation U. S. Nuclear Regulatory Commission
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Washington, D.C. 20505 U " r !,'
Comments on thi Accument should be sent to:
WRITE:
Reactor Safeguards Development Branch Division of Operating Reactors U. S. Nuclear Regulatory Commission Washington, D.C.
20555 CALL:
Tom McKenna 301-492-7846 1
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NUCLEAR POWER REACTOR SECl'RIT', PEr,SONNEL TRAINING AND QUALIFICATION PLAN REVIEWER WORKBOOK INDEX 1.
OVERVIEW I-l 2.
ACCEPTANCE CRITERIA 2.1 73.55 (b) (4) IMPLEMFNTATION SCHEDULE 2-1
- 2. 2 SUITABILITY (App. B, I.A) 2-1
- 2. 3 PHYSICAL AND MENTAL QUALIFICATIONS (App.
B, I.8).
2-3 2.3.1 PHYSICAL AND MENTAL QUALIFICATIONS (App.
B, I.B.1) 2-3 2.3.1.1 GENERAL PHYSICAL QUALIFICATIONS (App. B, I.B.l.a) 2-3 2.3.1.2 FHYSICAL EXAMINATION (App. B, I.B.l.b) 2-3 2.3.2 MENTAL QUALIFICATION (App. B, I.B.2) 2-6 2.3.2.1 GENERAL MENTAL QUALIFICATIONS (App. B, I.B.2.a) 2-6 2.3.2.2 PROFESSIONAL MENTAL EXAMINATION (App. 8, I.B.2.b) 2-7 2.3.2.3 CONTINUED OBSERVATION (App. B, I.B.2.c) 2-8 2.4 PHYSICAL-FITNESS QUALIFICATIONS (App. B, I.C) 2-8 2.5 CONTRACT SECURITY PERSONNEL (App. B, I.D) 2-10 2.6 PHYSICAL REQUALIFICATION (App. B, I.E) 2-11 2.7 DOCUMENTATION (App. B, I.F) 2-11 2.8 IRAINING AND QUALIFICATION PLAN (App. 8, I' 2-11 2.8.1 TRAINING REQUIREMENTS (App. B, II.A) 2-11 2.8.2 QUALIFICATION REQUIREMENTS, (App.
B, II.B) 2-12 2.8.3 CONTRACT PERSONNEL (App. B, II.C) 2-13 2.8.4 SECURITY KNOWLEDGE, SKILLS AND ABIt.ITIES (App. B. II.D) 2-18 2.8.5 REQUALIFICATION (App. B, II.E) 2-22
- 2. 9 WEAPONS TRAINING (App. B, III) 2-23 2.10 WEAPONS QUALIFICATION AND REQUALIFICATION PROGRAM (App. B, IV) 2-25 2.10.1 HANDGUN (App. B, IV.A) 2-25 2.10.2 RIFLE (App. B, IV.8) 2-26 2.10.3 SHOTGUN (App. B, IV.C) 2-27 2.10.4 REQUALIFICATION (App.
8, IV.D) 2-2E 2 11 EQUIPMENT (App. B, V) 2-2E APPENDIX A - STANDARD QUESTIONS A-1 APPENDIX B - STANDARD FINDINGS B-1 APPENDIX C - DISCUSSION C-1 APPENDIX D - GUIDANCE INDEX D-1 GUIDANCE LETTERS D-3 i/9 I~1 t, a !
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CHAPTER 1 - OVERVIEW The Training and Qualification Plan Reviewer Workbook has been developed to provide the information required for evaluating the adequacy of the Training and Qualification (T&Q) Plans developed to meet the requirements of 10 CFR 73.55(b)(4) and 10 CFR 73, Appendix B (Published in final form in August 1978).
This workbook contains the following informa ion:
(1) Chapter 2 contains the criteria indexed to Appendix B, used to assess the adequacy of the T&Q Plans and, where necessary, the procedure to be followed when applying the criteria to the plans.
(2) Appendix A contains a set of standard licensee questions or requests, referenced to the criteria, that could be used by the reviewer to inform the licensee of possible deficiencies or omissions.
(3) Appendix B contains a sample set of evaluation findings which specify how the T&Q Plans satisfactorily meet the requirements of 10 CFR 73.55(b)(4) and 10 CFR 73, Appendix B.
(4) Appendix C contains acceptance criteria discussions as appropriate.
(5) Appendix D contains copies of question and answers which have been sent to the licensees concerning implementation of 10 CFR 73, Appendix B.
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CHAPTER 2 - ACCEPTANCE CRITERIA 2.1
- 73. 55(b)(4 )
IMPLEMENTATION SCHEDULE ACCEPTANCE CRITERION (b)(4) - 1:
The licensee must provide an implementation schedule that shows how all security personnel will be qualified within 2 years of Training and Qualification Plan approval.
The schtdule must indicatn the number of days following plan approval at which qualification of personnel will begin and the number of days following plan approval at which all personnel will be qualified.
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SUITABILITY (App. B, I.A)
ACCEPTANCE CRITERION I.A-1:
The licensee must commit that, prior to employment or assignment to the security organization, and individual shall meet the following suitability criteria:
a.
Educational Development possess a high schoul diploma or pass an equivalent Performance examination designed to measure basic job related mathematical, language and reasoi,ing skills, ability, and knowledge, required to perform security job duties.
Personnel who have performed security job duties (documented) prior to the date of plan approval need not meet the education development requirement for those duties.
b.
Felony Convictions - have no felony convictions involving the use of a weapon and no felony convictions that ieflect on the individual's reliability.
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ACCEPTANCE CRITERION I.A-2:*
The licensee must commit that prior to employment or assignment to the security organization in an armed capacity, an individual must be the age specified in 10 CFR 73, Appendix B.
ACCEPTArjCE CRITERION I.A-3:**
The licensee must describe the elements used:
(a) to determine that an individual has had no felony conviction involving the use of a weapon or that reflects on his or her reliability.
( t) )
to determine that an individual assigned to an armed position is the age specified in 10 CFR 73, Appendix B.
REVIEW PROCfDURE:
The de3criptions submitted by all the sites will be surveyed.
Based on the results of this survey a site may be requested to supply alternative methods Consideration will be given to local legal restrictions.
See Appendix for other Federal Restrictions Cancerning Receipt, Possession or Transportation of Firearms.
This criteria is subject to change based on Commi< s ion ac tion on Part 11.
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- 2. 3 PHiSICAL ANL MENTAL QUALIFICATION (App. B, I.8)
- 2. 3.1 PHYSICAL Q<UALIFICATIONS (App.
B, I.B.1)
? 3.1.1 GENERAL PHYSICAL QL;.'LIFICATIONS (App.
B, I.B.1.a)
ACCEPTANCE CRITERION 1.B.1.a.-1:
The licensee shall prescribe how he will assure that security personr.'l have no pnysical weakness or abnormalities '.shich would adversely affect performance of assigned security duties.
A commitment to observe personne1 for physical weaknesses as part of the continued observation program (App. 8, l.B.2.c) wil' meet this requirement.
2.3.1.2 P'iYSICAL EXAMINAT ION ( App. B, I.B.l.b)
ACCEPTANCE CRITERION I.B.l.b-1:
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The licensee must commit that all armed security personnel and central alarm station operators shall successfully pass a physical examination administered by a licensed physician.
The licensee must also prescribe that following the examination the physician must attest that the exami-nation detected no condition that renders the individual incapable of performinc their assigned crucial security tasks.
The physical examina-p tion can be administered by licensed health professional trained to y
administer physical examinations provided the final attestment is made by a licensed physician.
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ACCEPTANCE CRITERION I.B.l.b-2:
The licensee must prescribe that all armed security personr:>l shall meet the following visual requirenents:
(a)
For each individual, distance 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.
If uncorrected distance vision is not at least 20/40 in the better eye, the individual shall carry an extra pair of corrective lenses.
Near visual acuity, corrected or uncor-rected, shall be at least 20/40 in the better eye.
Field of vision must be at least 70 horizontal meridian in each eye.
The ability to distinguish red, green and yellow colors is required.
Loss of vi ion in one eye is disqualifying.
Glaucoma shall be disqualifying, unless controlled by acceptable medical or surgical means, p' vided such medications as may be used for controlling glaucoma do not cause undesirable side ef fects which adversely a'fect the individual's ability to per form assigned security Jut.ies, and provided the visual acuity and field of vision 'equirements stated above are met.
(b) Where corrective eyeglasses are required, they shall be of the safety glass type.
Plastic lenses will be considered acceptable.
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ACCEPTANCE CRITERION I.B.l.b-3:
The licensee must prescribe that all armed security personnel shall raeet the following hearing requirements:
(a)
Individuals shall have no hearing loss in the better ear greater than 30 decibels average at 500 Hz, 1000 Hz, and 2000 Hz, with no lesel greater than 40 decibels at any one frequency (by ISO 1964 or ANSI 1969 audiometry).
(b) A hearing aid is acceptable provided suitable testing procedures demonstrate auditory acuity equivalent to the above stated requirement.
ACCEPTANCE CRITERION I.B.l.b-4:
The licensee must prescribe that all armed security nersonnel shall have no established medical history or medical diagnosis of epilepsy or dia-betes, or, where such a condition exists, the individual shall provide medical evidence that the condition can be controlled "ith proper medi-cation so that the individual will not lapse into a coma or unconscious state while performing assigned security.
ACCEPTANCE CRITERION I.B.I.o-5:
The licensee must prescribe that all 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 r.
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program which would give a reasonable degree of confidence that the individual would be capable of perferming assigned security duties.
ACCEPTANCE CRITERION I.B.l.b-6:
The licensee must prescribe that the ability of armed security personnel to perform their assigned crucial security tasks while wearing corrective lenses, hearing aids or while afflicted with mild color vision defects will be demonstrated prior to assignment.
The requirement can be met by the crucial task demonstrations required in the qualification section (II.B).
ACCEiTANCE CRITERION I.B. l.b-7:
The licensee must prescribe that any armed security personnel who have been incapacitated by a serious condition to the extent they cannot perform their security duties will be required to provide, prior to resumption of security duties, medical evidence of recovery.
2.3.2 MENIAL QUALIFICATION (App. B, I.B.2) 2.3.2.1 GENERAL MENTAL QUALIFICATIONS (App. B, I.B.2.a)
ACCEPTANCE CRITERION I.B.2.a-1:
The licensee must identify for each security assig"aent the job tasks, standards and as appropriate conditions that represent the spoken, reading and writing skills required by the assignment ( i f a ny ).
The licensee may reference tasks, standards and conditions contained in the qualification section of the plan.
The plan must commit that before being assigned an f j' l 2-6
individual will demonstrate the communication tasks identified to the standards and under the conditions contained in the plan.
Successful performance demonstration of the tasks identified in the quali-fication section of the plan requires individuals to possess the following mental qualities identified in paragraph I.B.2.a of 10 CFR 73 Appendix B:
mental alertness capability to exercise your judgment, implement instructions and assimilate assigned security tasks.
Therefore, no specific reference to these mental qualities is required in the Training and Qualification Plan.
2.3.2.2 PROFESSIONAL MENTAL EXAMINATION (App.
B, I.B.2.b)
ACCEPTANCE CRITERION I.B.2.b-1:
The licensee must prescribe that a person professionally trained to identify emotional instability will have determined and attested that the central alarm station operatcrs and armed members of the security organi-zation have no emotional instability condition that would interfere with the performance of the crucial tasks associated with the individual's assigned duties.
The use of tests is acceptable provided the final determination is made by a person professionally trained to identify emntional instability.
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2.3.2.3 CONIINUED OBSERVATION (App. B, I.B.2.c)
ACCEPTANCE CRITERION I.B.2.c-1:
The licensee must prescribe that the security supervisors, as part of their normal duties, observe their security personnel to detect any indication of emotional instability.
ACCEPTANCE CRITERION 1.B.2.c-2:
The licensee must commit that indications of emotional instability observed by a security supervisor shall be subject to verification by a licensed person trained to identify emotional instability.
The plan must commit that the individual will not be allowed to return to his or her security duties unless the examiner attests that tt'e examination detected no condition that would interfere with the performance of the examinee's assigned crucial security tasks.
2.4 PHYSICAL FITNESS QUALIFICATION (App.
B, l.C)
ACCEPTANCE CRITERION I.C-1:*
The licensee must identify for each armed security assignment a set of physically demanding job tasks, standards and conditions (pe r f oi mance objectives) and a time period during which this set of tasks must be performed.
The following is a list of typical t'
- ical demands of the type to be considered:
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(a) lifting (b) carrying (c) pulling (d) climbing (1) stairs (2) ladders (e) crawling (f) running This set of tasks and period of performance must represent one of the most physically demanding day-to-day and contingency situations that may be encountered during assignment performance.
The task condition statements must specify the personnel equipment to be carried during task perfor-mance.
The licensee may reference the tasks and associated standards and conditions contained in the qualification section of the plan.
If per-formance objectives are identified that are not job tasks the licensee must demonstrate their job relevance.
REVIEW PROCEDURE:
The set of tasks will be reviewed against the assignments responsibilities to insure that they represent the most physically demanding tasks per-formed.
The condition statement will be reviewed to insure that the eauipment is consistent with the duty assignment.
In addition, the physically demanding tasks submitted by other sites will be surveyed.
Based on comparison of the results of this survey with site specific A ~/ '/
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requirements, a site may be questioned on the applicability of other tasks cr combinations of tasks and requested to resubmit more demanding tasks.
ACCEPTANCE CRITERION I.C-2:
The licensee must commit that prior to assignment to an armed security position, an individual will demonstrate his or her physical fitness qualification by successfully performing all the tasks identified (performance objectives) within the period of time under the conditions and to the standards specified.
The licensee must also commit that the results of qualification testing will be documented and attested by the licensee security supervisor in accordance with Acceptance Criterion II.B-5.
2.5 CONTRACT SECURITY PERSONNEL (App.
B, I.0)
ACCEPTANCE CRITERION I.D-1:
The licensee must commit that all contract security personnel shall meet the suitability, physical and mental commitments contained in the plan submitted by the licensee.
The responsibility for verifying the adequacy of contractor programs to meet these requirements rests with the applicant or licensee.
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- 2. 6 PHYSICAL REQUALIFICATION (App. B, I.E)
ACCEPTANCE CRITERION I.E-1:
The licensee must commit that central-alarm station operators and armed security personnel will be required at least every 12 months to pass a physical examination in accordance with Acceptance Criterion I.B.l.b-1.
The licensee must commit that armed security personnel will, at least every 12 months, be required to meet vision and hearing requirements in accordance with Acceptance Criterion I.B.l.b-2 and I.B.1.b-3 and to demonstrate their physical fitness in accordance with Acceptance Criterion I.C.-2.
2.7 DOCUMENTATION (App. B, I.F)
ACCEPTANCE CRITERION I.F-1:
The licensee must commit that results of the suitability and the physical and montal qualification procedures will be documented at the site.
The documents actually completed during the examinations or demonstrations need not be retained.
2.8 TRAINING AND QUALIFICATION PLAN (App. B, II) 2.8 1 TRAINING REQUIREMENTS (App B, II.A)
ACCEPTANCE CRITERION II.A-1:
The licensee must outline the training program to be used to train security personnel who require training to perform assigned security related tasks or duties.
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ACCEPTANCE CRITERION II.A-2:
The licensee must describe the means of maintaining personnel and force effectiveness for contingency response tasks that are not performed during day-to-day operations (e.g.,
responding to an attack) and provisions for upgrading qualifications of security personnel in areas where deficiencies have been observed.
2.8.2 QUALIFICATION REQUIREMENTS (App. B, I1.B)
ACCEPTANCE CRITERION II.B-1:*
The licensee must identify by security assignment the crucial security tasks required to implement the licensee physical security or contingency plan.
Security qualification is required for individuals who have full time security duties, other individuals having response force assignments part time and individuals whose assignments are specifically identified in the contingency plan responsibility matrix.
Terms such as " observer" are not considered specific assignments.
A security task is considered crucial if:
(a)
Its proper performance is essential for successful irpiementa-tion of the,ite Phj>jCal '3H urity and COntingen(y Plans when nee @d even if it i, pertorned only during conti ncp nc ies Iee bppe nd i
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It is not simple and an individual could make mistakes 2
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lack of knowledge, skills or ability that affect security.
That A
is, these tasks are not of minimal difficulty and there is a probability of deficient performance.,
1 2
REVIEW PROCEDURE:
(1) The rei iewer will confirm that aach shift and task assignment d
d identified in the T&Q plan are the same as or equivalent to operational J
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elements cited in the Contingency Plan or the fulltime security and part-j l
time response positions identified in the site security organization as i
J described in the Physical Security Plan.
If there is not a one-to one j
relationship the T&Q plan must show how the assignments in the T&Q plan j
relate to the positions and operational elements c"mmitted to in the j
licensee's Physical Security Plan and Contingency Plan.
(2)
The reviewer will confirm that each decision action contained in a licensee's responsibility matrix of his Contingency Plan has correspoading crucial tasks identified in the licensee's Training and Qualification Plan.
All the tasks required to complete the decision actions identified in the licensee's Contingency Pian ar, assumed crucial to licensee's event responses, except those simple security tasks of minimal difficulty, or those with little probability of deficient performance.
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The reviewer will confirm that tasks involving initating event (cue) recognition and initial response are iden+ified as crucial where cue recognition is essential for successful implementation of the site Physical Security and Contingency Plans.
(3)
The reviewer will confirm that the licensee has identified all crucial tasks required to implement the licensee's Physical Security Plan.
At a minimum, this confirmation will assure that the licensee has identified the ctucial security tasks implementing licensee commitments like utili-zation of security equipment, communications, LLEA coordination, access control, monitoring protected and vital areas, search, patrol and escort.
All specific commitments in the licensee's Physical Security Plan per-formed by members of the security organization as defined in the Physical Security Plan are assumed crucial to site security except those of minimal difficulty or of low probability of deficient performance.
As an aid in completing review procedures 2 and 3, the reviewer will compare each 3ite identified task list against a security task inventory that is b sed on all available sources and sorted by security functions.
I n corrpa r i ng th i s tas k list with site identified tasks, omission of tasks can be justified by 4/9 Uhb 2-14
1.
differe es in site procedures and equipment 2.
physical layout and environmental differences 3.
MASP and Contingency Plan commitment differences 4.
differences in security force composition, numbers, and assignments 5.
local operational and legal constraints 6.
site operational status:
a.
operating reactors b.
construction on-site 7.
differences in LLEA agreements 8.
LLEA response time 9.
Other site specific considerations ACCEPTANCE CRITERION II.B-2:*
Each licensee provided task statement will:
(1) Contain a verb and object, (2) Be observable, and (3) Be measurable.
REVIEW PROCEDURES The reviewer will confirm that each licensee provided job task sta '.eme n t -
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See Appendix C for rational.
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s (1)
Is a statement of a highly specific action which contains a verb and object and that describes a job action.
(2)
"Is observable" so that by observing the performance of the job holder, or the results of his efforts, a definite determination can be made that the task has been performed.
(3)
"Is measurable", so that a technically proficient individual can cbserve the performance of the task, or the product produced by the task and be able reasonably to conclude that the task has or has not been properly performed.
For example, verbs such as:
appreciate, comprehend, understand, conclude, know, supervise, think, etc., are neither observable nor measurable.
Certain verbs, such as gr sp, may have multiple meanings depending on their usage (i.e, grasp the stick, or grasp the meaning) and shoJld be a'ccided in this context or clarified.
The task statements should be couched in site job language ACCEPTANCE CRITERION II.B-3:
The l i c e r,3 ee must commit that all personnel who have full time security duties, other individuals have response force assignments part time and individuals whose assignments are specifically identified in the con-tingency plan responsability matrix will have successfully performed, before assignment, all the crucial security tasks identified for that 4
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security assignment, under the conditions, and to the standards specified in the Training and Qualified Plan.
A_CCEPTANCE CRITERION II.B-4:
The licensee must commit that the security personnel qualification records will be available at the site.
ACCEPTANCE CRITERION II.B-5:
The licensee must commit that the qualification record will contain attestment by a security supervisor, that performance of all crucial tasks associated with the examinee's assigned duties have been successfully demonstrated.
The attesting supervisor is responsible for proper documentation and is responsible for its veracity.
Further, for each crucial task the record will c tain the date of successful performance, the signature of the observing individual (security supervisor or his/her designated representative) and the initials of the examinee.
The appli-cant or licensee is not required to retain the detailed materials completed for each individual during the qualification, such as completed tests or rating forms.
ACCEPTANCE CRITERION II.B-6:
The licensee must commit that a copy of each item of detailed material developed to assure reliable and objective task demonstrations (tests) is available at the site.
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2.8.3 CONTRACT PERSONNEL (App. B, II.C)
ACCEPTANCE CRITERION II.C-1:
The licensee must commit that all contract security personnel will meet the same qualification requirements as av the licensee's employees with respect to their security assignments.
The licensees must commit that the qualification of contract personnel will be documented and attested tc in accordance with Acceptance Criterion II.B-5.
The responsibility for verifying the adequacy of the contractor personnel qualification rests with the applicant or licensee.
2.8.4 SECURITY KNOWLEDGE, SKILLS, AND ABILITIFS (App.
B, II.D)
ACCEPTANCE CRITERION 11.0-1:*
Any licensee specified task conditions (equipment, material or environ-mental influence) must be conditions which influence performance of the security tasks.
REVIEW PROCEDURE Reviewers will confirm that the conditions statements accurately reflect:
(1) tools and equipment used to perform the task, or (2) special job aids or manuals, or See Appendix C for discussion.
479 0,~ 0 2-18
(3) kind and amount of supervision, or (4) special physical demands of the task, or (5) environmental cc,ditions that influence task completion, or (6) location of performance, or (7) cues that initiate action.
Conditions should be job related conditions and not conditions inserted for test administration purposes without relation to what may actually be expected on the job.
Detailed conditions are not required.
Task Condi-tions must be controllable by the licensee (i.e.,
lightning, fog, outside support like LLEA, are not acceptable since they are not under licensee control).
Conditions may be summarized for multiple tasks which are perfnrmed under the same conditions.
Conditions need not be specified for all task statements (except as required by criterion II.0-2), but if none are specified it is assumed that performance is under all normal job conditions.
ACCEPTANCE CRITERION II.D-2:
Cues (initiating events) must be specified for tasks for which cue recognition and initial response determines success or failure of the tasks.
ACCEPTANCE CRITERION II.D-3:
- The licensee must specify a task standard for each task identified in the plan.
See Appendix C for rational.
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ACCEPTANCE CRITERION II.0-4 The 1icer.ee must provide a job task standard that is observable, is measurable in quality or quantity ano against which successful performance of each task can be assessed.
REVIEW PROCEDURE The revie-er will confirm that:
(1) Each standard is observable and measurable.
(2) No standard contradicts commitments made in the site's physical security and/or contingency plans.
(3)
Each standard sp.i fies a product and/or process quality and/or quantity by which acceptable task performance can be assessed.
It the standard is a process, all crucial sub-tasks must be stated, unless a procedure is referenced and measurable and observable sub-tasks that summarized tno proceduro are provided and that represent a minimum level of acceptable performance A summary is not required for procedures that have already been summarized in the site physical security plan or by the decisions / actions in the contingency plan.
However, in these cases the other plans must be referenced tn insure coverage (4)
The standard is a job related standard and not a test administration standard See Appendix C for rational.
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GUIDELINES FOR DOCUMENTING TASK CONDITIONS ITEM THAT MAY BE INCLUDED IN STATEMENT OF TASK CONDITIONS EXAMPLES 1.
Tools and equipment used to 1.
Gas Mask perform the task.
2.
Weapon 3.
Flashlight 4.
Radio 2.
Special job aids and manuals.
1.
Procedural checklists 2.
Technical manuals 3.
SOP 4.
Post Oraers 3.
Kind and amount of supervision and 1.
Job holder performs task assistance normally available during without assistance frcm task performance.
Others.
2.
Task performed under close supervision.
3.
Task performed as a member of a team.
4.
Special physical demands of the 1.
Crowded working conditions.
task.
2.
Runnirg 3.
Climbing 4.
Crawling 5.
Deliverable Environmental conditions 1.
Temperature that influence task completion.
2.
Night / Day 6.
Lecation of performance.
1.
Air conditioned building.
2.
Outdoors in all weather conditions.
3.
CAS 7.
Coas (initiating event) 1.
Radio Message 2.
Observation of 3.
Metal detector alarm annuncia-tion.
4.
Telephone bomb threat cigure 2 4~/9 05 2-21
(5) The standard is go/ho go (not referenced to class performance).
(6)
Time standards are provided for time-constrained tasks.
Differential standards, as a function of experience are acceptable to allow for consideration of the greater experience.
However, any specific commitments in the site approved MASP and Contingency Plan must not be violated.
2.8.5 REQUALIFICATION (App. B, II.E)
ACCEPTANCE CRITERION II.E-1:
The licensee must commit that security personnel will be requalified at l east every 12 months to pe^ form their assigned crucial security tasks and duties in accordance with the NRC approved licensee Training and Qualifi-cation Plan and Acceptance Criterion II.B.3.
Requalification must be within 12 months of its last demonstration as documented in the task qualification record.
ACCEPTANCE CRITERION II.E-2:
The licensee must commit that the results of the requalification must t;e documented and attested by a licensee security supervisor in accordance witn Acceptance Criteria II.B-4, II.B-5 and li.B-6.
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2.9 WEAPONS TRAINING (App. B, III)
ACCEPTANCE CRITERION III-1:*
The licensee shall identify, for each site weapon, either a task and standard from the qualification requirements (Section II.8) or a course of fire from the weapons qualification requirements (Section IV) that prescribe a standard for each of the following subject areas:
(1) Mechanical assembly, disassembly, range penetration capability of weapon, and bullseye firing (2) Weapons cleaning and storage (3) Combat firing, day and night (4) Safe weapons handling (5) Cleaning, loading, unloading, and reloading (6) When to draw and point a weapon
( 7) Rapid fire techniques (8) Close quarters firing (9) Stress firing (10) Zeroing REVIEW PROCEDURE Review the tasks or courses of fire identified in order to confirm that each has a standard that addresses the subject areas and for the site weapons.
See Apper. dix C for reference.
h O.
..~s 2-23
The reviewer will confirm that:
(a) " Bullseye firing" includes single-action handgun firing.
The bullseye firing requirement for the rifle and shotgun is met by the courses of fire specified in Section IV of Appendix B.
(b) " Combat f i ring day and night" for the handgun includes double-action firing and the use of combat handgun position (met by the Practical Pistol Course (PPC) or the National Police Course (NPC) cited in Section IV).
In addition, if the individual may be required to use a weapon while wearing a protective mask, f amiliarization firing while wearing the mask must be identified.
The night firing requirement is met by the night familiari-zation (Acceptance Criterion IV-1).
Combat firing for the rifle includes rapid fire and combat positions (met by the rifle course of fire cited in Section IV).
(c)
"When to draw and point a weapon" includes target recognition and reaction.
This requirement need not be demonstrated on the range and is independent of weapon.
(d)
" Rapid firing techniques" includes handgun doutle action timed fire (net by NPC or PPC).
The rapid f ir e requirement tot the shotguo and rifle
's met by the course of fire requited in Section It of Appendix B (e)
' Closo quarters f i r i m,"
leuludos handgun quick-draw firing from hip (crouth) (aet by PPC and NPC).
"Close quarters firing" for the s h o t tp n includes hip fire (not t 3 the shotgun course cited in Section IV).
?-?4
[4 }/ Q
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(f)* " Stress firing" includes firing the weapon after physical exertion to illustrate the effects of physical stress on his or her marksmanship.
The firing need not be for score.
(g) " Zeroing of assigned weapon," is applicable to the rifle only.
2.10 WLAPONS QUALIFICATION AND REQUALIFICATION PROGRAM (App.
B, IV)
ACCEPTANCE CRITERION IV-1:
The licensee must confirm that all individuals assigned to positions which require armed personnel will receive night familiarization on their assigned weapons.
2.10.1 HANDGUN (App. B, IV.A)
ACCEPTANCE CRITERION IV.A-1:
The licensee must confirm that armed personnel shall qualify with a revolver or semiautomatic pistol firing the National Police Course, or an equivalent rationally recognized course.
Qualifying score shall be an accumulated total of 70 percent of the maximum obtainable score.
The PPC is considered an equivalent nationally recognized course.
To be equi-valent a course must ir.clude double action timed combat firing using the following positions:
See Appendix C for discussion.
479 0//
2-2s
(a) crouch (close quarter firing)
(b) standing no support (c) prone (d) barricace (strong / weak hand)
(e) kneeling and firing at ranges up to 25 yards.
2.10.2 SEMIAUTOMATIC RIFLE (App. B, IV.B)
ACCEPTANCE CRITERION IV.B-1:
The licensee must commit that armed security personne, assigned to use the semiautomatic rifle by the licensee, shall qualify with semiautomatic rifle by firing the 100 yard course of fire specified in Section 17.5(1) of the National Rifle Association, High Power Ri fle Rules book (ef fective March 15, 1976), or a nationally recognized equivalent course of fire.
Qualifying score shall be an accumulated total of 80 percent of the maximum obtainable score The Department of Energy (DOE) day rifle course outlined below is cons ider ed a nat ion-illy recognized equiv a lt nt course of fire and would be acceptablo 4i9 0I8 2-26
DOE Day Rifle Course Range No. of Rounds Position Time Target Stage 1 100 yds 5
Standinq 30 seconds B-27 Stage 2 100 yds 5
Kneeling 30 seconds B-27 Stage 3 100 yds 5
Sitting 30 seconds B-27 Stage 4 100 yds
_5 Prone 30 seconds B-27 Total 20 rounds Firing Stages 1 Semiautomatic mode of fire; no artificial support; iron sights; time begins with shooter in firing position, magazine with 5 rounds loadod in weapon, first round unchambered.
2.10.3 SHOTGUN (App. B, IV.C)
ACCEPTANCE CRITERION IV.C-1:
The licensee must commit tha. armed security nersonnel, assigned to use the 12 gauge shotgun by the licensee, shall quali fy with a full choke or irrp rov ed, modi f ied cho ke, 12 gauge shotgun firing the course specified in Section IV.C of Appendix B to 10 CFR 73.
To qualify, the individual shall be required to place 50 percent of all pellets within the black silhouette.
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2.10.4 REQUALIFICATIONS (App. B, IV.0)
ACCEPTANCE CRITERION IV.D-1:
The licensee must commit that all armed security personnel shall be requalified on the weapon with which armed at least every 12 months in accordance with the NRC approved licensee Training and Qualifications Plan, and in accordance with Acceptance Criteria IV.A-1, IV.B-1, and IV.C-1.
2.11 GUARD, ARMED RESPONSE PERSONNEL, AND ARMED ESCORT EQUIPMENT (App.
8, V)
ACCEPTANCE CRITERION V-1:*
The equipment specified in the licensee approved Physical Security Plan meets this requirement and it does not have to be addressed in the Training and Qualifications Plan.
T See Appendix C for discussion.
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APPENDIX A a,q, ;)
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U ()
APPENDIX A STANDARD LICENSEE QUESTIONS OR REQUESTS 1.
73.55 (b) (4) IMPLEMENTATION SCHEDULE 1.1 Provide a Training and Qualification Plan implementation schedule that shows how all security personnel will be qualified within 2 years of Training and Qualification Plan approval.
1.2 State the number of days following plan approval at which qualification of p?rsonnel will begin.
1.3 State the number of days following plan approval at which all personnel will be qualified.
2.
SUITABILITY (App. B, I.A) 2.i Provide a commitment that, prior to employment or assignment to the security organization, an individual will possess a high school diploma or pass an equivalent performance examination designed to measure basic job related mathematical, language and reasoning skills, ability, and knowledge, required to perform security job duties.
2.2 Provide a commitment that, prior to employment, or assignment to the security organization, an individual han no felony convictions involving the use of a weapon and no felony convictions that reflect on the individual's reliability.
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A-1
2.3 Describe the process used to verify the accuracy of information used to determine an individual's suitability.
?,4 Describe the process used to verify that an individual assigned to the security organization has no felony convictions involving the use of a weapon or that reflects on his or her reliability.
2.5 Describe the process used to verify that an individual assigned to an armed position is the age specified in Appendix B or older.
3.
GENERAL PHYSICAL QUALIf ICATIONS ( App.
B, I.B.l.a) 3.1 Describe how the site will assure that security personnel have no physical weakness or abnormalities which would adversely affect performance of assigned duties.
4 PHYSICAL EXAMINATION (App. B, I.B.l.b) 4.1 Provide a commitment that armed security personnel and central alarm station operators must successfully pass a physical examination administered by a licensed physician or licensed health professional trained to administer physical examinations.
4.2 Commit that following the physical examination of the armed security perron:,el and central alarm operators that the physician must attest that he or she detected no condition that renders the individual incapable of performing the crucial tasks ider ified for the examinee's as-ignments.
A-2 k) 00b
4.3 Com;.iit that armed security personnel shall meet the following vision requirement (s).
(
)
Distant visual acuity in each eye shcll be correctable to 20/30 (Snellen or equivalent) in the better eye and 20/40 in the other eye with eye fassas or contact lenses.
(
)
If uncorrected distance vision is not at least 20/40 in the better eye, the individual shall carry an extra pair of corrective lenses.
(
)
Near visual acuity, corrected or uncorrected, shall be at least 20/40 in the better eye.
(
)
Field of vision must be at least 70 horizontal meridian in each eye.
(
)
The ability to distinguish red, grec and yellos colors is required.
(
)
Loss of vision in one eye is disqualifying.
(
)
Glaucoma shall be di Tialifying, unless controiled by acceptable medical or surgical means, provided such medications as may be used for csntrolling glaucoma do not cause undesirable side effects which adve sely affect the individuil's ability to A-3 h
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perform assigned security job duties, and provided the visual acuity and field of vision requirements stated above are met.
(
)
Where corrective eyeglasses are required, they shall be of the safety glass or plastic type.
4.4 Commit that armed security personnel s,-all meet the following hearing requirement (s):
(
)
Shall have no hearing loss in the better ear greater than 30 decibels averaging at 500 Hz, 1000 Hz, and 2000 Hz, with no level greater than 40 decibels at any one frequency (by 150 1964 or ANSI 1969 audiometry).
(
)
Individuals who require a hearing aid to meet the hearing requirement will demonstrate their auditory acuity to or above the levels stated in Appendix B.
4.5 Commit that armed L onnel shall have no establisheu 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 jub duties.
479 085 A-4
4.6 Commit that armed 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 documen-tation of having completed a rehabilitiation program which would give a reasonable degree of confidence that the individual would be capable of performing assigned security job duties.
4.7 Commit that the ability of armed individuals, who wear corrective lenses, to perform their assigned crucial security tasks while weoring corrective lenses will be demonstrated.
4.8 Commit that the ability of armed individuals, who wear hearing aids, to perform their assigned crucial security tasks while wearing a hearing aid will be demonstrated.
4.9 Commit that the ability of an armed individual to perform his or her crucial security tasks while affected with mild color vision defects will bo demonstrated.
4.10 Commit that armed individuals who have been incapacitated by a serious illness to the extent they cannot perform their duties will be required to provide, prior to resumption of security duties, medical evidence of recovery.
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Cd6 A-5
5.
GLNERAL MENTAL _ QUALIFICATIONS (App.
B, I.B.2.a) 5.1 Identify for each security assignment the job communication, task, standards and as appropriate that represent the spoken, reading and writing skills required by the assignment.
5.2 Commit that before being assigned an individual will demonstrate the communication tasks identified to the standards and under the conditions contained in the plan.
6.
PROFESSIONAL MENTAL EXAMINATION (App.
B, I. B. 2. t; )
6.1 Commit that a person professionally trained to identify emotional instability will determine and attest that the central alarm station operators and armed individuals have no emotional instability condition that would interfere with the performance of the crucial tasks associated with their assigned duties.
7.
CONTINUED OBSERVATION (App. B, I.B.2.c) 7.1 Commit that the security supervisors, as part of their normal duties, observe their personnel to detect any indication of emotional instability.
7.2 Commit that indications of emotion instability shall be subject to verification by a licensed person trained to identify emotional instability.
470 007 A-6
- 7. 3 Commit that an individual suspected of emotional instability will not be allowed to return to duty unless the examiner attests that the examination detected no condition that would interfere with the performance of the examinee's assigned crucial security tasks.
8.
PtfySICAL-FITNESS QUALIFICATION (App. B, I.C) 8.1 Identify for each armed assignment a set of job tasks, standards and conditions (performar.ce objectives) and specify a period of time during which all the tasks will be performed.
This set of tasks and period of performance must represent one of the most physically demanding day-to-day and contingency situations that may be encountered during job performance.
8.2 Specify a period of time during which the examinne inust complete all the physical fitness performance objectives.
- 8. 3 Demonstrate the job relevance of the performance objectives in your physical fitness qualification program.
8.4 Demonstrate the job relevance of the time standard in your physical fitness program Ab Provide justification for non-inclusion of the following tasks as representing one of the nost physically denanding situations encountered during assignment as a A-7 4i.
~
'1
8.6 Provide confirmation that prior to assignment to an armed position an individual will demonstrate his or her physical fitness qualification by successfully compir ing all the physical fitness objectives (tasks, conditions, standards) within the specified period nf time
- 8. /
Provide confirmation that the results of the physical fitness demonstration will be documented and attested to by the licensee security supervisor in accordance with Acceptance Criterion II.B-5.
9.
CONTRACT SECURITY PERSONNEL ( Ap p. B, I.0) 9.1 Commit that all contract security personnel wil1 meet the same suitability and physical and mental requirements as the licensee's employees.
10.
PHvc T CM REQUALIFICAT ION ( App.
B, I.E) 10.1 Commit that the central alarm station operat
~s and armed individuals will be required at least every 12 months to pass a physical examination in accordance with Acceptance Criterion I.B.I.b-1.
10.2 Commit that armed personnel will at least every 12 months meat vision and hearing requirements in accordance with Acceptance Criteria I.B.l.b-2 and I.B.1.b-3.
10.3 Con:m i t that ar med persennel will at least every 12 months demonstrate their physical fitness in accordance with Acceptance Criterion 1.L./.
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i L; U,4 A-3
11.
DOCUMENTATION (App. B, I.F) 11.1 Commit that the results of the suitability and the physical and mental qualification procedures will be documented at the site.
12.
TRAINING REQUIREMENTS (App. 8, II.A) 12.1 Outline the security training program to be conducted at your site.
12.2 Describe the means of maintaining personnel and force effectiveness for contingency response tasks that are not performed day-to-day.
13.
QUALIFICATION REQUIREMENTS (App. B, II.8) 13.1 The following task is assigned to the in your plan and is assigned to the in your Training and Qualification Plan, resolve the apparent inconsistency.
13.2 Identify for the following assignment titles, equivalent titles in your:
(
) (a) Contingency Plan Respon<ibility Patrix
(
) (b)
Physical Security Plan, security organization soctions.
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A-9
13.J Identify the crucial tasks performed by the 13.4 Correct the following task statements so that they contain both a verb and object describinq fob actions.
13.5 Correct the following task statements so that they are made observable and measurable 13.6 Correct the following statement to form a task statement.
As stated it is not a task but is a:
(
)
duty
(
)
function
(
)
decision / action 13.7 Provide justification for non-inclusion of the following tasks, or include them as modifications to your qualification requirements.
13.8 identify the assignments and crucial tasLs, conditions, and standards rerpi red to implement the following decision actions contained in your respt ns ibility natrix for (event.
13,9 Idontify the assignments and crucial tasks, conditions and standards invulsing cue recognition and initial response for the following initiating events (cue >):
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13.10 Identify the assignments, crucial tasks, conditions, and standards for implementing the commitments made in sections of your Physical Security Plan concerning 13.11 Commit that all personnel who have full time security duties, other individuals having response for ;e assignments part time, and individuals whose assignments are specifically identified in the contingency plan responsibility matrix will successfully perform, before assignment, all the crucial security tasks identified for those assignments, under the conditions, and to the standards specified in the training and qualified plan.
13.12 Commit that the qualification record of each individual assigned security related duties will be available at the site.
13.13 Commit that:
(
)
the qualification record will contaii attestment by a security supervisor, that performance of all crucial tasks associated with the examinee's assigned duties have been accessfully demonstrated.
(
)
for each crucial task the record will contain the date of successful performance, the signature of the cbserving individual (security supervisor or his/her designated representative) and the initials of the examinee
{( )r,]
u A-11
13.14 Commit that a copy of each item of detailed materials developed to assure reliable and objective task demonstrations (tests) are available at the site.
14.
CONTRACT PERSONNEL (App. B, II.C) 14.1 Commit that all site contract security personnel will meet the same training, equipment and qualification requirements as the licensee's employees as appropriate to their assigned duties.
14.2 Commit that the qualification of contract personnel will be documented and attested to in accordance with Acceptance Criterion II.8-5.
15.
SECURITY KNOWLEDGE, SKILLS, AND ABILITIES (App.
8, II.D) 15.1 torrect the following task conditions statements so that they identify only those job related conditions that significantly influences task performance.
15.2 Correct the following task conditions to eliminate all specificaticos that are not under your direct control.
15.3 Provide the initiating cue for the following tasks for which cue recogni-tion is essential for performance.
1179 003 A-12
15.4 Correct the following task conditions statements so that they are compatiable with the commitments section of your plan concerning 15.5 Correct the following task standards statements specifications to include observable and measurable qualities or quantities.
15.6 Provide a standard for the following task statements in your submittal.
15.7 Make the following task standards compatible with the commitments made in Section(s)
, of your
(
) (a) Physical security plan
(
) (b) Contingency Plan.
15.8 Provide measurable and observable sub-tasks that summarize the "proce-dures" referenced in the following tasks and/or standards and that represent a minimum level of acceptable performance.
1). 9 Confirn (or modify) the following task standards as an actuai Job standard and not 4
test administrative standard or requirement.
15.10 Modify the following task standards to make them go/no go.
/ rA7l nLap4 A-13
15.11 Provide time standards for the following time-constrained tasks.
15.12 Provide more detailed standards for the following tasks.
16.
REQUALIFICATION (App.
8, II.E) 16.1 Commit that all security personnel will be requalified at least every 12 months in accordance with the NRC approved licensee Training and Qualification Plan.
16.2 Commit that the results of the requalification will be documented and attested by a licensee security supervisor in accordance with the commitments contained in NRC approved licensee Training and Qualification Plan.
17.
WEAPONS TRAINING (App.
8, III) 17.1 Identify for the following areas the task and standard from the qualification requirements or the cou,se of fire that prescribes a standard for the (weapon)
(
) Mechanical assembly and disassembly
(
) kange penetration capab4lity of weapon 479 095 A-14
(
) Single action handgun firing
(
) Weapons cleaning and storage
(
) Double-action firing and use of combat positions
(
)
Safe weapons handling
(
) Clearing, loading, unload;ng, and reloading
(
)
iarget recognition and reaction
(
)
Rapid fire techniques
(
) Close quarter firing
(
)
Stress firing
(
) Zeroing.
18.
WEAPONS QUALIFICATION AND REQUALIFICATION PROGRAM (App.
B, IV) 18.1 Commit that all individuals assigned to armed positions will receive night familiarization on their assigned weapons.
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A-15
18.2 Commit that all armed individuals will qualify with a handgun by successfully firing the Practical Pistol Course (PPC) or National Police Course.
18.3 Demonstrate that the handgun qualification course of fire identified in your plan is equivalent to the National Police Course.
18.4 Commit that personnel assigned to use the semiautomatic rifle by the licensee training and qualifications plan, shall qualify with a semi-automatic rifle by firing the iOO yard course of fire specified in Section 17.5(1) of the Natic>nal Rifle Association, High Power Rifle Rules book (Effective March
'.5, 1976),* or a nationally recognized equivalent course of fire.
18.5 Demonstrate that the rifle qualification course of fire identified in your plan is equivalent to that identified in Appendix B, IV.B.
i8.6 Commit that semiautomatic rifle course that the:
(
)
targets used sh:
se as stated in Sectit r the 100 yard course
(
)
time limits for individuals shall be as specified in Section 8.2 of the NRA rule book, regardless of the course fired.
479 097 A-16
/
)
qualifying score shall be an accumulated total of 80% of the maximum obtainable score.
18.7 Commit that individuals assigned to use the 12 gauge shotgun by the licensee training and qualifications plan shall qualify with a full choke or improved modified choke 12 gauge shotgun firing the following course:
Range Position No. Rounds Target iD yds.
Hip fire 4
B-27 Point 25 yds.
Shoulder 4
B-27 1 The 4 rounds snall be fired at 4 separate targets within 10 seconds using 00 gauge (9 pellet) shotgun snells.
2As set forth by the National Rifle Association (NRA) in its Official Rules and Regulations, "NRA Target Manufacturers Index," December 1976.
18.8 Commit that to qualify on the shotgun course the individual shall be required to place 50% of all pellets (36 pellets) within the black silhouette.
18.9 Commit that individuals shall be weapons requalified at least every 12 months in accordance with the NRC approved licensee training and quali-fications plan.
4 h>
09,9 A-17
APPENDIX B 479 099
APPENDIX B EVALUATION FINDINGS 10 CFR 73.55(b)(4) 1.
Implementation Schedule The licensee has provided a schedule that shows that all security personnel will be qualified within 2 years after the plan is approved by the NRC.
Based on our review, we conclude that the Training and Qualififcation Plan implementation schedule and pro (.edures met the requirements of 10 CFR 73.55(b)(4) dild i5 dCCeptdoie.
Suitability Prior to employment, or assignment to the licensee security organization, an individual will meet the following suitability criteria:
Educational Development-- possess a high school diploma or pass an equi-a.
valent performance examination designed to measure basic job related mathemat..1 1, language and reasoning skills, ability, and knowledge, required to perform security job duties.
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b.
'elony Convictions--have no felony convictions involving the use of a weapon and no felony convictions that reflect on the individual's relia-bility.
Prior to employment or assignment to the licensee security organization in an armed capacity, an individual, will be 21 years of age or older.
The licensee will verify the accuracy of the information used to determine an individual's suitability.
Based on our review, we conclude that the Training and Qualification Plan meets the suitability criteria of Section I.A of 10 CFR 73, Appendix B and is accept-able.
3.
PHYSICAL AND MENTAL QUALIFICATION The licensee will monitor his sacurity personnel to assure that an individual gives no indication that he or she can not meet the physical demands associated with his or her assigned security duties.
Licensee armed personnel and central alarm station operators shall successfully pass a physical examination administered by a licensed physician a licensed professional trained to conduct physical examinations.
A licensed physician will attest that examinatinn detec ?d no condition that renders the examinee incapable of performing his or her security assignments.
,vl
., /
B-2
Armed members of the licensee security organization shall meet the following physical requirements:
(1) Vision (a) 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.
If uncor-rected distance vision is not at least 20/40 in the better eye, the individual shall carry an extra pair of corrective lenses.
Near visual acuity, corrected or uncorrected, shall be at least 20/40 in the better eye.
Field of vision must be at least 70 horizontal meridian in each eye.
The ability to distinguish red, green and yellow colors is required.
Loss of vision in one eye is disquali-fying.
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 job duties, and provided the visual acuity and field of vision requirements stated above are met.
On-the-job eval-uation shall be used for individuals who exhibit a mild color visico defect.
(b) Where corrective eyeglasses are required, they shall be of the safety glass or plastic type.
ll.l' iQ B-3 Ud
(c)
The use of corrective eyeglasses or contact lenses shall not inter-fere with an individual's ability to effectively perform assigned security job duties during normal or emergency operations.
(2) Hearing (a)
Individuals shall have no hearing loss in the better ear greater than 30 decibels average at 500 Hz, 1000 Hz, and 2000 Hz, with no level greater than 40 decibels at any one frequency (by ISO 1964 or ANSI 1969 audiometry).
(b) A hearing aid is acceptable provided suitable testing procedures demonstrate auditory acuity equivalent to the above stated require-ment.
(c)
The use of a hearing aid shall not decrease the effective performance of the indivdual's assigned security job duties during normal or emergency operations.
(3) Diseases--Individuals 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 con-trolled with proper medication so that the individual will not lapse into a coma or unconscious state while performing assigned security job duties.
479 103 B-4
(4)
Addiction--Individuals shall have no estabiished medical history or medical diagnosis of habitual alcoholism or drug addiction, or, where such a condition has existed, the individual. hall provide certified documen-tation of having completed a rehabilitation program which would give a reasonable degree of confidence that the individual would be capable of performing assigned security job duties.
(5) Other Physical Requirements--An individual who has been incapacitated due to a 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 medical evidence of recovery and ability to perform such security job duties.
Individuals whose security tasks and job duties are directly associated with the effective implementation of the licensee physical security and contingency plans shall demonstrate during qualification mental alertness and the capability to exercise good judgment, implement instructions, assimilate assigned security tasks, and possess the acuity of senses and ability of expression sufficient to premit accurate communication by written, spoken, audible, visible, or o+her signals reauired by assigned job dutios.
A person professionally trained to identi f y emotic "al instability will determine that the central alarm station operators and arned members of the security organization have no emotional instability that would interf ere wit n tho individuals job performanco
/
9
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t B-5 v
The responsible supervisors will continuuously observe their security per-sonnel for indications of emotional instability.
Identification of emo-tional instability identified by supervisors will be verified by a licensed
,rofessional trained to identify emotional instability and who must attest that the examinee has no condition that would interfere with the individual's job performance before the examinee is reassigned.
Based on our review, we conclude the Training and Qualification Plan meets the physical and mental criteria of Section I.B of 10 CFR 73, Appendix B and is acceptable.
4.
PHYSICAL FITNESS QUALIFICATIONS The licensee quards, armed response parsonnel and armed escorts will demonstrate the physical fitness required for their assigned security job duties by per-forming a practical physical exercise program within a specific time period.
This program represents one of the most physically demanding day-to-day and response situation that may be performed by that individual.
Based on our review, we conclude that the Training and Qualification Plan meets the physical fitness qualification criteria of Section I.C 10 CFR 73, Appendix B and is ac.:eptable 5.
CONTRACT SFCURITY PERSONNEL Licensou employed contract security personnel will meet all the suitability, physical and mental criteria contained in Appendix B.
Based on our review, we b
B-6
conclude that the Training and Qualification Plan meets the contract security personnel criteria of Section I.D of 10 CFR 73, Appendix B and is acceptable.
6.
PHYSICAL REQUALIFICATION At least every 12 months, the licensee central alarm station operators and armed members of the security organization will pass a physical examination administered by a licensed physician who will attest that he or she found no condition that renders the individual incapable of performing his or her security duties.
At least every 12 months, the armed members of the security organization will demonstrate they can meet the entry level vision, hearing and physical fitness qualification detailed in sections 3 and 4 of the findings.
Based on our review, we conclude that the Training and Qualification Plan meets the physical requalification criteria of Section I.E of 10 CFR 73, Appendix B and is acceptable.
7.
DOCUMENTATION The licensee or his agent will document the results of the suitability, physical and mental qualification test and examination.
Based on our review, w conclude that the Training and Qualification Plan meets the documentation criteria of Section I.F of 10 CFR /3, Appendix B and is acceptable.
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H.
TRAINING RF OUIP!MENTS The licensee will conduct training at the site to maintain security employee profic1ency on contingency response tasks.
Based on our review, we conclude that the T raining and Qualification P;an meets the training criteria of Section II.A of 10 CFR 73, Appendix B and is acceptahle.
9.
QUALIFICATION REQUIREME' i The licensee has identified by shift assignment the tasks crucial to imple-r,entat ion of the site physical security and contingency plans.
Each person prior to shift assignment will demonstrate his or her ability to perform all the assignments crucial tasks to the standards and under the conditions identified in the plan.
The security supervisor will attest that the indi-viduals have successfully demonstrated the tasks identified toe their assignments.
The licensee will document the date of successful task performance, signature of the observing individual (security supervisor or his/her designated representative) and the initials of the examinee.
Based on our review, we conclude that the Training and Qualification Plan meets the qualification criteria of Section II.B of 10 CFR 73, Appendix B, and is acceptable 10.
CONTRACT PERSONNEL Contract security personnel will meet the same equipment, training and quali-fication criteria as licensee employees as appropriata to their assigned B-8
/ 'l V/
~M
duties.
Based on our review, we ccnclude that the Training and Qualification Plan meets the contract criteria of Section II.C of 10 CFR 73, Appendix B and is acceptable.
11.
SECURITY KNOWLEDGE, SKILLS AND ABILITIES The licensee has specified for each crucial task identified in the plan an observable and measurable standard by which successful task performance can be assessed.
The standards identified are compatable with the successful implementation of the site Physical Security and Contingency Plans.
Based on our review, we concicde that the Training and Qualification Plan meets the security knowledge, skills and abilities criteria of Section II.D of 10 CFR 73, Appendix B and is acceptable.
12.
REQUALIFICATION Licensee security personnel will be requetlified at least every 12 months to perf orm assigned sE" Jrity related job tasks and duties for both norma! and contingency operations.
Requalification will be in accordance with the NRC approved licensee Training and Qualifications Plan.
The results of requali-tication shall be documented and attested b',
a licensee security supervisor.
Based on our review, we conclude that the Training and Qualification Plan meets the requalification criteria uf Section II.E of 10 CFR 73, Appendix B and is a c c e p t a t; l e.
1.
4l 1 r, B-9 i (j ]
13.
W!APONS TRAINING Licensee quards, arrwd response per:,unne l and armed escort s stull meet prescribed standards in the following areas for his or her assigned weapon ( s):
1.
Mechanical.is s emb l y, (ii sa s semb ly, range, penetration capability ut weapon, and bul1seye tiring 2.
Weapons cleaning and storage 3.
COTbat tiring, day and night 4
Safe weapons handling 5.
Clearing, loading, unloading, and reloading 6.
When t o draw and po int a weapon 1.
Rapid fire techniques R.
Close qua-ter tiring 9.
Stre>s f i t ing 10.
teroing as;1gned weapon (s) i'G B-lu j
t
Basea on our review, we concluoe that the Training and Qualification Plan meets the weapons training criteria of Section III of 10 CFR 73, Appendix B and is acceptable.
14.
WEAPONS QUALIFICATION AND REQUALIFICATION PROGRAM All individuals assigned to armed positions at the licensee site will receive night familiarization on their assigned weapons.
Licensee guards, armed escorts and armed response personnel shall qualify with a revolver or semi-automatic pistol firing, during the day, un the Prattical Police Course.
Qualifyirj score shall be an accumulated total of /01 of the maximum obtainable score.
Licensee guards, armad escorts and armed response personnel, assigned to use the semiautomatic rifle by the licensee shall qualify with a serniautomatic rifle by firing during the day the 100 yard course of fire specified in Section 17.5(1) of the National Rifle Association, High Power Rifle Rules Book (Effectise March 15, 1976).
Targets used shall be as stated in Section 17.5 for the 100 yard course.
Time limits for individuals shall be as specified in Section 8.3 of tne NRA rule book, regardless of the course fired.
Qualifying score shall be an accumulated total of 80% of the maximum obtainable score.
Licensee quards, armed escorts, and armed response personnel assigned to use the 12 gauge shotgun by the licensee shall qualify with a full choke or impro ud modified choke 12 gauge shotgun firing, during the day the following cource i
7 ul B-11
1 9
Range Position No. Rounds Target' lb yds.
Hip fire 4
B-27 Point 25 yds.
Shoulder 4
B-27 The 4 rounds shall be fired at 4 separate targets within 10 seconds using UO gauge (9 pellet) shotgun shells.
As set forth by the National Rifle Association (NRA) in its Official Rules and Regulations, "NRA Target Manufacturers Index," December 1976.
To qualify the individual shall be required to place 50% of all pellets (36 pellets) within the black silhouette.
Individuals will be weapons requalified at least every 12 months in accordance with the NRC approved licensee Training and Qualifications Plan.
The results of the weapons qualification and requalification will be documented by the licensee or his agency.
Based on our review, we cor.clude that the Training and Qualificatico Plan meets the weapons criteria of Section IV of 10 CFR 73, Appendix B and is acceptable.
15.
CONCLUSIONS Based on our evaluation of the licensee's Training and Qualification Plan, we conclude that the licensee meets the requirements of 10 CFR 73(b)(4), and 10 CFR 73, Appendix B.
479 1ii B-12
G APPENDIX C 479 112
APPENDIX C INDEX ITEM Page Other Federal Restrictions on Possession of Firearms (A.C, I.A-2)
C-1 Identification of Physically Demanding Job Tasks, Standarcs, and Conditions (A.C.,
I. C-1 ).
C-3 Identification by Shift-Assignment of the Crucial Job Tasks (A.C,II.B-1)
C-5 Observable and Measurable Task Statements (A.C, II.B-2)
C7 Specification of Job Conditions (A.C, II.D-1)
C-8 Specifications of Measurable and Observable Job Standards (A.C.,
II.D-2; A.C., II.D-3)
C-9 Weapons Standards (.4.C.,
III-1)
C-10 Stress Firing (A.C.,
III-1)
C-ll Equipment Requirements (A.C., V)
C-12
/r! 7 fi 1 1
(
i I: s
ACCEPTANCE CRITERIA I.A-2:
OTHER FEDERAL RESTRICTIONS CN RECEIPT, POSSESSICN OR TRANSPORTATION OF FIREARMS In addition to the Appendix B suitability requirements for arred personnel the licensee should be aware of the following:
TITLE 18, UNITED STATES CODE - APPENDIX Section 1202.
Receipt, possession, or transportation of firearms--Persons liable; penalties for violations (a) Any person who--
(1) has been convicted by a court of the United States or of a State or any political subdivision thereof of a felony, or (2) has been discharged from the Armed Forces under dishonorable conditions, or (3) has been adjudged by a count of the United States or of a State or any political subdivision thereof of being mentally incompetent, or (4) having been a citizen of the United States has renounced his citizenship, or (5) being an alien is illegally or unlawfully in the United States, and who receives, possesses, or transports in commerce or affecting commerce, after the date of enactment of this Act, any firearm shall be fined not more than $10,000 or imprisoned for not more than two years, or both.
(b) Any individual who to his knowledge and while being employed by any person who--
(1) has been convicted by a court of the United States or of a State or any political subdivision thereof of a felony, or (2) has been discharged from the Armed Forces under dishonorable conditions, or (3) has beeh adjudged by a Court of the Unites States or of a State or any political subdivision thereof of being mentally incompetent, or i :i C-1 N
(4) having been a citizen of the United States has renounced his citizenship, or (5) being an alien is illegally or unlawfully in the United States, and who, in the course of such employment, receives, possesses, or transports in commerce or affecting commerce, after the date of the enactment of this Act, any firearm shall be fined not more than $10,000 or imprisoned for not more than two years, or both.
(c) As used in this title--
(1)
" commerce" means travel, trade, traffic, commerce, trans-portation, or communication among the several States, or between the District of Columbia and any State, or between any foreign country or any territory or possession ar.d any State or the District of Columbia, or between points in the same State but through any other State or the District of Columbia or a foreign country; (2)
" felony" means any offense punishable by imprisonment for a term exceeding one year, but does not include any offense (other than one involving a firearm or explosive) classified as a misde-meanor under the laws of a State and punishable by a term of imprisonment of two years or less; (3)
" firearm" means any weapon (including a starter gun) which will or is d2 signed to or may readily be converted to expel a projectile by the action of an explosive; the frame or receiver of any such weapon; or any firearm muffler or firearm silencer; or an; destructive device.
Such term shall include any handgun, rifle, or shotgun; (4)
"destructiva device" means any explosive, incendiary, or poison gas bomb, gren&de, mine, rocket, missile, or similar device; and includes any type of weapon which will or is designed to or may readily be converted to expel a projectile by the action of any explosive and having any barrel with a bore of one-half inch or more in diameter; (5)
" handgun" means any pistol or revolver originally designed to be fired by the use of a single hand and which is designed to fire or capable of firing fixed cartridge ammunition, or any other firearm originally designed to be fired by the use of a single hand; (6) " shotgun" means a weapon designed or redesigned, made or remade, and intended to be fired from the shoulder and designed or redesigned and made or remade to use the energy of the explosive in a fixed shotgun shell to fire through a smooth bore either a number of ball shot or a single projectile for each single pull of the trigger;
$if C-2 4/ /
f1ID i
(7)
" rifle" means a weapon designed or redesign, made or remade, and intended to be fired from shoulder and designed or redesigned and made or made to use the energy of the explosive in a fixed tallic cartridge to fire only a single projectile through rifled bore for each single pull of the trigger.
ACCEPTANCE CRITERIA I.C-1:
RATIONALE FOR:
IDENTIFICATION OF PHYSICALLY DEMANDING JOB TASKS, STANDARDS AND CONDITIONS Appendix B, I.C.
states:
"The exercise program performance objectives shall be described and shall consider such as they pertain to each individual's assigned security."
Mager(l) has identified three essential characteristics of performance objec-tives as follows:
"1.
They identify the terminal behavior.
The statement of an objective must identify exactly what the trainee must be able to do at the end of an instructional unit or complete course of instruction to demon-strate that he has achieved the desired bebavior.
The learned behavior may involve the application of knowledge or the demonstra-tion of a specific skill or constellation skills.
2.
The' describe the conditions of perfor,1ance.
The statement of a p"'formance objective must describe clearly and completely the conditions under which the trainee must be able t, demv,istrate the behavior.
That is, the conditions of the objective identify what the trainee will be given to use in doing the job (tools, equipment, job aids, references, materials), what he will be denied (tools, equip-ment and the 1ike), what assistance he wil1 have (if any), what supervision will be provided, and the physical environment in which he must perform (climate, space, light, and the like).
(1) Robert F. Mager, Preparing Objectives for Programmed Instruction.
Palo Alto, Calif.
Fearon Publishers, 1962, p.
12 r_3 4 / c/
lib L _ -- _.-- - - _...
3.
They set a criterion of acceptable performance.
The statement of a performance objective must describe how well the trainee must be able to perform.
The criterion or standard establishes the minimum performance requirements for a duty, task, or job element.
To do this, the objective statement must prescribe the quality of the work product or service produced (accuracy, completeness, clarity, toler-ances, and the like); the quantity of work products produced (the number of work units completed); the time allawed to complete the j ob, <iuty, task, or element; or any combination of quality, quantity, and tima standards."
Therefore, the performance objective specifies the action or task performed, conditions and standards.
The physical demands identified for consideration were identified by the Department of Labor.(2)
In addition, the performance objectives must represent job situations.
The NRC must not require objectives whose job relevance has not been demonstrated (pull up, etc.).
TITLE 29 Labor, Chapter XIV - Equal Employment Opportunity Commission (EEOC) Part 1607 - Uniform Guidelines on Employment Selection Procedur es (1978), II Adverse Impact, states, "If adverse impact exists, it must be justified on grounds of business necessity.
Normally, this means by validation which demonstrates the relation between the selection procedure and performance on the job."(3)
(2)
U.S. Department of Labor, Handbook for Analzying Jobs, 1972, p.
338.
(3) 43 FR 36291 479 117 C-4
ACCEPTANCE CRITERIA II.8-1:
RATIONALE FOR:
IDENTIFICATION BY SHIFT ASSIGNMENT OF THE CRUCIAL JOB TASKS 10 CFR 73, Appendix II.B states:
"Each person who performs security related job tasks or job duties required to im"lement the licensee physical security or contingency plans shall, prior.o being assigned to such tasks or duties, be qualified in accordance with the approved plan."
In addition, Appendix B, II.D. states, "Each individual assigned to perform the security related tasks identified in the licensee physical security or contingency plan shall demonstrate in accordance with the specified standards for each task as stated in the approved plan."
Paragraph II.B requires personnel to be qualified to perform their assigned tasks and duties and paragraph II.B requires that these tasks be identified in the plan along with standards.
Therefore, the licensee must identify for each assignment the security tasks performed.
In addition, the following may further clarify the need for this information.
The U.S. Army IRADOC Pamphlet 350.30 states:
"Regardless of the route that you the ultimate end product, or cutput, must include a validated list of tasks that make up the job.
These tasks must be described in sufficient detail to permit collectico, of valid and reliable data for use in making decisions as to which tasks will be trained.
In addition, for those tasks selected for training, sufficient information such as conditions, initiating cues, standards, and elements
[h iI-IU C-5
.= = m mtK!K r uth s J
E
=
a 1
1 1
1 I
must be collected and verified to provide a sound basis for developing Job Performance Measures (JPMs)."(4) i i
Title 29 Lacor, Chapter XIV - EFOC Part 1607 - Uniform Guidelines on Employee l
Selection Procedures (1978), and Part 300 - Employment Section 14, paragraph B,2.
" Analysis of the Job" states:
"There should be a review of job information to determine measures of work behavior (s) or performance that are relevant to the extent they represent critical or important job duty work behaviors or work outcomes as developed from job information."(5)
J 1
Tracy states:
4 j
"T raining and development programs must be based on job data, not on what someone recalls that he did or thinks that a graduate should be able to do The method of obtaining these data is job or task analysis."(6)
Why are only the " crucial tasks" to be identified in the plan?
If the site I
were to require formal qualification on all the tasks performed, it would be 5
counter productive.
Important resources would be waste', on non-important or
[
trivial tasks.
f 3
il 1
J 3
(4)
U.S.
Army TRADCC Pamphlet 350-30, pg. 34, PHASE I, (NTI5 ORDER No. AC019487) j National fechnical Information Sorvice, Springfield, Virginia 22161.
1 l
(5) 43 FR 38 300, Aug. 25, 1978 i
(b)
- r3Cef, N.
R. Designing training and development systems.
New York:
A - 4cen one,ement A ocietion. inc.
i971, po. 86.
)
3
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4 / '/
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mrmmer._ _ _ _ _ - m-w-pr
- _ _ mes,
.mur:ar srarnagrnispers
The Army states:
"Some tasks are seldom required on the job and only minimum job degra-dation would result if the tasks were not performed.
On the other hand, some tasks are highly critical to successful job performance, and the complex nature of the task makes training essential.
Economic and time considerations require a decision as to which tasks will be selected for training and which tasks will not."(7)
Title 29 Labor, Chapter XIV - EEOC Part 1607 - Uniform Guidelines on Employee Selection procedures, Technical standards Section 14, paragraph (3) Criterion measures, states:
"Whatever criteria (Standards) are used should represent important or critical (emphasis added) work behaviors or work outcomes."(8)
ACCEPTANCE CRITERIA II.B-2:
RATIONALE FOR:
OBSERVABLE AND MEASURABLE TASK STATEMENTS The task statement will be the basis for the qualification of individuals, therefore, it must be observable and measurable.
If you cannot see it performed or measure it when it is performed, how do you know it has been successfully demonstrated as required by Appendix B, II.D?
(7)
Op. cit., TRADO, PHASE I, pg. 113.
(8) 43 FR 38300
/r /17 ()
C-7 i ~, U F
/
i.
The Army states:
" Task statements must be constructed carefully to assure that the final analysis yields useable job performance data.
The following are charac-teristics of tasks and task statements:
1.
A task statement is a statement of a highly specific action.
The statement has a verb and object.
4.
Tasks must be observable in that by observing the performance of the job holder or the results of his efforts a definite determination can be made that the task has been performed.
5.
A task must be measurable; that is, in the real woric, a technically proficient individual can observe the performance or the task or the product produced by the task and be able to conclude that the task has or has not been properly performed."(9)
ACCEPTANCE CRITERIA II.D-1:
RATIONALE FOR:
SPECIFICATION OF JOB CONDITIONS:
Appendix B Specifications of task condition at the time of performance will assure that the factors influencinq performance are held constant during the testing of all personnel.
This creatly increases test fairness and relia-
.ility.
If the conditions are not specified in the plan it will be assumed that the level of performance (standard) specified in the plan can be achieved under all normal jnb conditions.
Title 29 Labor, Chapter XIV - EEOC, Part 1607 - Uniform Guidelines on Employee Selection Procedures, Documentation of Impact and Validity evidence, paragraph (3) Job Analysis states:
(9) op. cit. TRADOC, PHASE I, Pg. 13-14.
ILh C-8
D.h2 2 ? Ln,O : 5 ~,L:.U-.'s:l.4l S S S:,'s k~.c f.g M Wf f 04 ' ' " ' Y is. N '
"The work situation should be described, including the setting in which work behavior (s) are performed, and where appropriate, the manner in which knowledge, skills, and abilities are used, and the complexity and diffi-culty of the knowledge, skill or ability as used in the work behavior (s)."(5)
ACCEPTANCE CRITERIA II.D-2, II.D-3:
RATIONALE FOR:
SPECIFICATION OF MEASURABLE AND OBSERVABLE JOB STANDARDS 10 CFR 73, Appendix B, II.D states:
"E.ch individual assigned to perform a security related task identified in
'.ne licensee physical security or contingency plan shall demonstrate the required knowledge, skill, and ability in accordance with the specified standards for each task as stated in the NRC approved licensee training and qualification plan."
Therefore, it becomes mandatory that a standard be provided for each task named in the T&Q Plan.
Title 29 Labor, Chapter XIV - EEOC Part 1607 - Uniform Guidelines on Employee Selection Procedures (1978), Technical Standards Section 14, paragraph (3)
Criterion measures, states:
"Whatever criteria (standards) are used should represent important or critical work behaviors or work outcomes."
The U.S.
Army states:
" Standards, refers to the acceptable quali~y of performance of a task in the real world job environment.
The standard for a task is a statement of how well that task must be performed.
Ta;k standards are the basis f or job norf ormance measure standards (Quali f ici tion tests).
3 C3 q/j l{
~
w-amen m
l Standards must be sound statements of the standard of performance actually
- equired on the job."(10)
"The :,tandard of performance of a task can be defined by identifying an acceptable process, product or both."
The standard should be defined in terms of an acceptable product it:
1.
The product is observable and can be inspected.
?
The process by which the product was produced cannot be easily observed.
3.
The process is relatively unimportant as compared to the product."(l1)
It can he 'eadily seen that security related tasks standards must be:
(1) provided for each crucial task, (2) observable and measurable, and (3) detinintive of product or process qualities and/or quantities that signal successful task completion.
ACCEPTANCE CRITERIA III-1:
RATIONALE FOR:
WEAPONS STANDARDS SEE:
o Police Reference Notebook, Section 5, Proficiency Areas, International Association of Chie's of Police, 11 Firstfield Road, Gaithersburg, Maryland 20760.
Police Firearms Instructors Manual, NRA, 1600 Rhode Island Avenue, N.W.,
Washington, D.C.
20036 (10) op. cit., TRADOC, PHASE I, pg. 24 (11) ibid, page 29 th.l'j 1~'
C-10
ACCEPTANCE CRITERIA III-1:
DISCUSSION OF STRESS FIRING REQUIREMENT Tange states:
"Many serious confrontations encountered occurred at the climax of a chase.
Trained police cfficers are aware of the difficulty of accurately firing a revolver on a controlled pistol range where all the factors for good marksmanship are present.
In a police action involving a chase, the emotional tension and physical exertion will cause rapid heart beat, muscle tremors and irregular breathing.
Couple the physical factors with poor lighting, irregular terrain, obstructed view and irregular movement of the target and it will be rapidly seen that accurate shooting under these conditions is extremely difficult.
For this reason, an exertion course is recomme,ded to make officers aware of the difficulties experienced while firing under stress situations.
The intention behind the use of the exertion course is to graphically illustrate to the officer the effects of physical stress on his marks-manship and the futility of firing his revolver while running.
The course is designed to increase the heart beat and respiratory rates by running, and to induce an unsteadiness of the shooter's shooting hand.
Experiencing a decline in proficiency during physical stress will certainly produce an awareness on the part of the officer of his reduction in skill and accuracy with a firearm.
It will also make him think cf what measures he must take, mechanically, to compensate for such a loss."(12)
(12) A Model Firearms Program for All Police Agencies:
Can One Be Cevised?,
2-74, D. E. Tange, Thesis, John Jay College of Criminal Justice of City University of New York, N.Y., h.Y.
10036, pg. 44 4.7 o i.?. -
C-I l
iE1M ACCEPTANCE CRITERION V-1:
DISCUSS 10fi OF EQUIPMENT REQUIREMENTS Acceptance Criterion V-1 states that the equipment soecified in the licensee approved Physical Security Plan meets the equipment requirements and you don't need to address this requirement in your Training and Qualification Plans.
This is true, provided you have supplied a sufficient description of each item of persennel security equipment in your physical security plan.
(By personnel security equipment we mean weapons and radios).
In the absence of sufficient equipment specification in your Physical Security Plan, you will be inspected against the equipment specification contained in Appendix B.
This does not mean that you are required to have each item of equipment ide.,'.ified in Appendix B but that for each item of equipment you do have you must eitner describe it in your Physical Security Plan or it is assumed that it meets the specification as appropriate in Appendix B.
For example, if you have riot shotguns at your site, but describe them only as shotguns in your plan then it will be assumed they meet the specification in Appendix B.
In this case it would be assumed that the shotguns would have a full or modified ch Therefore, you r ust assure that either the weapons and radios identified in voor Physical Security Plan meet the specification in Appendix B or that your Physical Security Plan contains sufficient detail to identify where your equipment differs from that specified in Appendix B.
.W 4f}
lo OC C-12
APPEt4 DIX 0 f.] Q 13' i
sLQ
__.s 5
E i
L E
GUIDANCE LETTER INDEX t
F-IMPLEMENTATION QUESTIONS #3, #4, #7, W
SCHEDULE
- 12, #24 E
SUITABILITY DOCUMENTATION QUESTION #1 5
CRUCIAL TASK IDENTIFICATION QUESTION #14 g
b CRUCIAL TASK DOCUMENTATION QUESTION #16 E
QUALIFICATION DOCUMENTATION QUESTIONS #2, #17
=-
=-
TASK STANDARDS QUESTION #10 CONTINGENCY TRAINING QUESTION #5 TEST MATERIAL QUESTION #8, #11, t
- 18, #23 APPENDIX B CONFLICTS QUESTION #19 WITH OTHER FEDERAL REQUIREMENTS
[
5 f
STRIKES QUESTION #20 8
I lh ? 4 i c,?
?
D-1 E
k
-usah.
m.-
C
GUIDANCE LETTER INDEX (Continued)
PLAN FORMAT QUESTION #6, #13, #14, AND CONTENI
- 21, #22, #25 I&E IN5PECTIONS QUESTION #26, #27 TEST IMPLEMENTATION QUESTION #28
/7D 1
.i i< /
- .. o D-2
QUESTION 1:
What records must be naintained at the site to demonstrate compliance with the provisions of Section I (suitability and, physical and rental qualifications) of Appendix B?
Answer-The site is required to have available at the site, verification tnat each member of the security organization (contract and proprietary) has met the suitability, physicai and mental require-ments of Appendix B.
The actual detailed results of an individual's suitability veri ficatinn and or physical and mental examination are not required to be kept at the site.
QUESTION 2:
How long are the qualification records required by Section II B of Appendix B to be maintained at site?
Answer:
The records that document and attest that the individual (contract & proprietary) has met the qualification requirements contained in the NRC approved plan aust be kept on site for the period of the indi-v idual 's employment.
One copy of each detailed item used during qualification such as tests or rating forms must be available at the site for 3 years.
- However, the licensee is not required to maintain any of the detailed naterials completed during the individual's qualification such as an individual's completed test.
QUESTION 3:
What is the trair,ing and qualification plan submission and implementation schedule for sites that do not have an operating license?
Answer:
The schedule is outlined below:
OL rSAR (Security Plan) submitted prior to effective da te of Appendix B (October 23, 1978) - Training and qualification plans should be submitted by August 18, 1979.
OL - FSAP submitted a f ter October 23, 1978 but prior to August 18, 1979 - Training and quali fication plans should be submitted by August 18, 1979 or 300 days prior to fuel loading date whichever is later.
All security personnel should be trained and qualified to the plan 24 months a f ter NRC approval.
GL - FSAR submitted a f ter August 18, 1979 - Tra i ning and qualification plans should be subnitted with FSAR.
All security personnel should be trained and qualified prior to fuel loading.
CP - Suhnit the training and quali fication prograr out) inn and a comm:tnent to Appendix B Part 73 with the PSAR application.
D-3 d[g l2g
QUESTION 4: What provisions have been made for the transition from the training commitments contained in the site MASP, and the new Appendix B requirements?
Answer:
The following guidance is provided:
1.
Licensees must follow their approved security plans.
(After February 23, 1979, power reactor security forces should be trained in accordance with their Modi fied Amended Security Plan - generally committing to meet R. G. 5.20).
Any departure frc m the approved security plan must be formally docu: ated in accord 5..
with the provisiens of 10 CFR 50.54(p).
2.
A licensee may follow his training and qualificacion plan prepared to meet the requirements of Appendix B prior to licensing approval provided it meets or exceeds the requirements of his current physical sec uri ty plan.
However, this must be docu-mented in accordance with the provisions of 10 CFR 50.54(p),
3.
The licensees can change their commitment to qualify security personnel through formal class-room training and use examinations to establish the qualification of these personnel without prior approval of the NRC subject to the provi-s ions o f 10 CFR 50.54(p).
The licensee (including his contractor) would be in compliance, provided the examina tion has assured that the examinee possesses requisite knowledge of the subject matter.
QUESTION 5:
Is the Appendix B approach to personnel qual i fica tion acceptable for meeting the contingency plan training requirements contained in 10 CFR 50.54(p)?
A n sge_r :
The licensees can follow the training and quali fica tion plan prepared to meet the Appendi x B requirenents prior to the plan approval by NRC to meet contingency plan training requirements contained in 10 CFR 50.54(p).
f.,U E S l I Oi_.
Can the training and quali fica tion plan re f erence sections of the site contingency plan and MASP?
Anwor Def erenc inq of any pa rt o f the si te a pproved plans i' acceptable provided the,e plan; are available
,t tre nito for inspections However, nodifying the contirs;ency plan or PASP to neet Appendix B requirenonts may result in an additional fee.
/l [ 9 J lii D-4
.su
_uestion 7:
Development and impl eme n t a t i o n of a training an" qualifica-Q tion plan to meet the requirements o f Appondi x B is, ar.
pointed out in thc> norkshnp, very ti e consu-in';.
Theref ro, using the Appendix B approach to r oo!
- Fe Co
- n yn -
p' a n training requirements as suggested *, *he arw r to que-+ inn 5 may not be possible.
Thus, can the requirs-ont in l ' c r :'
- 50. 54 ( p ) requ i ri'nq tha t conti ngency tra iri ng be compl e!"i prior to the contingency plan impl emen ta t i on be relaved?
Answer:
No QJestior 8:
Can NRR supply further dssistance an.
q;i'i ~ e ir + % a.m of test development? Can arrangement, l
.de, t hro a -
- o NPC, to make available the applicable nil.
- ar, test tochni-ques to the licensees ?
Answer:
We are investigating tnis possiniilts an, nopo we can provide this type of support t:efore the training and qualification plan revien is complete.
Question 9:
Can arrangements be rade to ansaer spe~i'ic trainir, an-qualification plan questions prior to pl 3 n su bmi + t al ?
Answer:
Licensees will have an o p p o r t u n i t ', to ask t un:
f-questions concerning training and qualificatinn develo: e
- durin1 the second day of the meetinq scheduled for June 11-12, in Albuquerque, New Mexico.
Question 10:
Is it acceptable to reference procedures in jour q;ali-fication plan standards ?
Answer:
Procedures can be referenced provided a summary o f t he mi niru-items required for successful per forma nce i s included.
This su mary is not necessary it the proccdures have already been su narized in the site physical 1ecuri',
plan or by the decisions / actions in tho contirce-cy pian '
responsibility ratrix.
However, in theso cases the other plans must be referenced to insure coverage.
Question 11 What portions of the training and qualification plan and test materials developed to complement the plan can be made available to the examinees?
Answer-Tho task s and standards identi fied for indisidual quaTification provide a valuable resource for the job
~
holder or examinee.
They identify the standard' that rust be maintained.
Therefore, the pertinent tas k and s tanda rd in for-nation contained in the plan can be nado available to the job holder.
In addition, the specific perforrance requirements for hands-on-tests can also be given to appro-priate individuals; however, written test raterials must be secured.
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Question 12:
How will the site personnel be quali fied during the two year training and qualification plan implementation period that 'ollows plan approval ?
Answer During this inplcmentation phase security personnel must be trained in accordance with the provisions of the a pproved MASP until portions are phased out b, t he t ra ining and quali fica tion plan.
I f a si te does not ha ve an approved MASP at the tire o' training and qualification plan approval an interin training plan equivalent to that doscribed in Reg. Guide 5.20 should be instituteJ until the training and qualification plan can be phased in.
At no tine shouid an indiviJual be assigned to security duties until properly trained and or qualified.
Question 13:
"ast the training and qualification plan include the " duty
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descriptions" refered to in paragra ph 2.2.2.5.2 (page 2-8) of NUREG 0219 and for which examples are shown on page 3 4 thru 3-11 of NUREG 0219?
Answcr We have determined that these descriptions do not 3dd any additional information and therefore are not required to be part of your training and qualification plan.
Question 14: Should the licensee's submit all the tasks considered for inclusion in the training and qualification plan or only those chosen as sufficiently critical or crucial.
Answer:
Only those tasks used for personnel hiiaTi f i c a t i on should be included in the training and quali fica tion plan.
Quostion 15:
How can we get a hard copy of "The Interservice Procedures
~
for Instructional S items Development"?
f Answor:
Call or write to the National Technical I n fo rne t i o n SErVic e, Springfield, Virginia 22161, phone (703) 557-4660.
The following order numbers should be used:
Executive Summary - AD019496 Phase I: Analyze - AD019497 Phase II: Design - AD01948B Phase III: Develop-A00194R9 Phase IV/V: In pl emen t/ Con trol - ADDl9490 9
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QUESTION 16:
In their training and qualification pian can the licensee commit to procedures to t e follcael if an individual is tes ted on-the-job and f a il s to demons tra te his or her ability to perform a crucial task?
Answer I f the tra ic.ing a nd qual i fica t ion nian contains such a procedure i t will be reviened by NRR a r.d if founj acceptable it then becomes part of thc approved plan and is therefore inspectable.
QUESTION 17:
Can an individuals qualification records be destrojed af ter five years instead of being maintained a t the site for the individuals period of ermloyment?
Answer:
Yes QUESTION [8:
Can the test naterials developed to inplerent the site training and qualification plan include adninistrative test itens that are for site use and that are not i ri t e r.d ed to test crucial tasks?
Answer:
Yes, but these items must be clearly designated as not being part of the test for crucial tasks, QUESTION 19:
There are federal government requirenents that require that a percentage of employees be fron ninority categories, but we are also under stringent requirenents for aualification of security force personnel.
Which set of requirements would tend to weigh nore heavily on our situation?
Answer:
NRR knows of no federal requirenent that would prevent a site from qualifying its security personnel in accordance with the reauirements in Appendix B and as detailed in NUREG 0219 and at the training and qualification workshops.
The " Uniform Guidelines and Employnent Selection Procedures (1978)" (43 FR 33291) states "If adverse inpact exists, it must be justified on grounds of business necessity.
Nornally, this means by validation which demonstrates the relation betweor. the selection procedures and performance on the job" The Gi 'delines go on to discuss in detail how the relationship between employner.t procedures and the job is demonstrated.
~he NRC training and qualification requirements are ouilt on the sane concepts, specifically, conducting a job analysis to identify what is required to perform the job (job analysis) nd secondly developing a valid test of the individuals capabilitie.- to perforn L:iese job requirements.
However, neeting the requirenents in the Guidelines may require a more rigid and detaileo application of these concepts, to include test validation, than that required by the NRC.
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- QUESTION 20: Must site personnel, who are assigned to a security-related post only in the event of a security force strike, be trained and qualified?
Answer:
Yes QUESTION 21:
The responsibility matrix seems to be of extreme importance and value to the total Training Plan.
Is it really that vital or is its role being over-emphasized?
Answer:
Appendix B requires the licensee to identify, for each assignment, the tasks crucial to implementation of the site physical security and contingency plans.
The matrix format of presenting this information appears to be the most economical < however, it is no more critical than other elements of the required information.
QUESTION 22:
Should plan submittals be organized identically to that outlined in the workbook?
Answer:
The plan in the workbook was developed to show how the l
workshop products can be used in developing your trai ing and qualification plans.
Therefore, the references to workshop
'ro-ducts such as the responsibility matrix or the job analysis l
wor? aeets are not applicable if you are using a different fornat to supply the information required by pc. agraphs II.B and II.D of Appendix u.
Remember to meet the requirements of these two paragraphs your plan must:
(1) identify, for each task, the job standards and condition of performance, (2) identify, by shift assignment, the crucial tasks performed, (3) cornit to qualify individuals to these standards and conditions prior to assignment, (4) commit to keep the appropriate records and (5) commit to keep a copy of all test material developed.
Except for the qualification section the index in the workbook follows the contents of Appendix B.
This is how the NRC review will also be conducted; therefore, organizing your plan in the same order as the requirements in Appendix B (as shown in index) will be a great convenience to both your site and to the NRC reviewer.
QUESTION 23:
What exactly is meant by Test Materials?
Answer:
The information contained in your training and qualification plan represents the results of defining the job (job analysis).
In order to properly qualify your personnel the job inforr ! tion in your plan (tasks, standards, & conditions) must Le tr a -
formed into tests.
The materials develooed to do this are the test materials refered to in the workshop and set forth in NUREG 0219.
They could include items such as:
(1) detailed test conditions, (2) detailed test criteria, such as, ched 1ists, rating forms, actual written tests and grading forcs etc., (3) examinee instructions and (4) examiner instructions.
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QUESTION 24: What is the full meaning and intent of Question 7 which was sent out in the April 10, 1979 letter?
Answer:
The question in our April 10, 1979 letter was phrased as it was to show the NRC was aware of the problens involved.
QUESTION 25: Must the type of tes+ (hands-on or written) used to qualify individuals be identified in the plan?
Answe" No.
This type of inforration will be s !bject to
_changes as the site qualification proararir.atures and should not be in the plan.
Therefore, the trainino and cualification plan shauld not include the test development blueprint (Form 2-2 in latest version of workbook).
QUESTION 26:.,n it cri teria will IE use to assess tre am
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Contingency Pian procedures requirco h,
s,,enais ; ta 10 CFR 73 but not subject to NnR revie.,
Answer:
IE will first determine if the ;)rcce.res e.;st.
T,,2 secnnd step will be to ensure that tne :rocea re; ice cc plete and tney detail and reflec t :ne in9,r.at' contgined in the si te approved contir.
.:..csoons;pi',t, matrix.
Criteria to deter ine adequac, 0; tner.e prccecures will be developed in the future.
QUESTION 27 On what basis will IE inspect a o te trainin-fication prograJ that has been "cd.*1e-in acCorcance with the provisions of 10 CFR 50.54(p)?
Answer:
IE will inspect against tne f.K appr;cca c,an decrease in effectiveness has t;een ade, ::.ill accent the cnange as being inspectable.
If a decrease r.s cccurred, the licensee will be cited.
The i nspec to r, ill e>.sure tna t the rer.ord keeping and noti fication recai re _.:ts c f 1C CF 50.51(p) have t]een complied wi th.
If trere is
<, - : e r, nce of opinion as to the adequacy of the procem 3 a x -,e n t to the change, or wnether any decrease in effectiveress occurred, IE will forward the matter to imR f or thei r resolution.
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If a member of the security organizations is tested on
-~QUESTInil 28:~~-
a task identified in the approved training and qualifica-tion plan as crucial for their assignment and fails What is his or her status?
Answer:
IT~the individual is not actually on duty at the time of the failure he or she must successfully demonstrate an ability to perform the task (pass the test) prior to an assignment requiring performance of the task being tested.
If the individual fails while on duty one of the following procedures must be followed:
1.
The individual is instructed at once on his or her deficient performance and retested.
2.
During the remainder of the shif t the individual is restricted to the performance of tasks for which he or she has been qualified.
Tne in:ividuel must be requalified on the failed task pri;r to rea; sign-ment.
J.
The individual is removed f em the past an: : *.e a ppropria te compensa tory mca curos tai er.
It is option is taken if neither option 1 nor2 can be impi 'orted without a decrease in the levei of sear it the t,
a site.
The incividual must be requalified on the failed task prior to reassignment to the post D-10
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NRC r onu 335 1 Hi l' O H T N t 'i4 L H (4 % > i / r twC/
US N UC L E A H H E G U L A T O H Y C D'.M11 SSI ON NUREG 0576 BIBLIOGRAPHIC D ATA SHEET 4 1 l T L E A N O ;Li d l l 1 L E (A JJ V e > oe N o, o f.s, p o v ron te)
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Nuclear Pcwer Reactor Security Personnel Training & Qualification Plan Reviewer Workbook (Interim) 3 Ht cieit N r S Acct SSiON No 7 AU T HOHIS) 5 OATE HI PO H T L O'/Pl t if D f
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9 Pt H F U H Y I N G O H G A N I / A T I ON N A ME A N D "1 A l t I NG A DO H E SS (/nc lu de 2,0 Cmfel D AT E Hi POH T ISSUI D
[ n AR voNT" Reactor Safeguards Development Branch Division of Operating Reactors
_ July 79
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U.S. Nuclear Regulatory Comission Washington, DC 20555 d (L w e t:!aak) 12 SPON SO HIN G OHG ANi2 A T ION N A'/E AN D M AILING Al)D HF SS (/"clude / p Code)
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11 CON T H AC T NO 13 IYPE OF HLPOH T i L HlO D C OV L H E O ll"clu s,,e dams)
Workbook 15 SL f Pl L */i N T A H Y N O T E S 14 fl e a.e 6/ " 4 /
16 A H51 H AC T (200 + ordi or less)
This document provides the infornation required for evaluating the adequacy of the Training and Qualification Plans developed to meet the requirerents of 10 CFR 73.55 (b)(4) and 10 CFR 73, Appendix B (Published in final form in August 1978).
- 17. K E WO R DS A ND D OCU'/ t N T AN A t.Y SIS 11a Ut hC HIP T OHS Ilb ICL N Tif IE HS' OPE N i N DF 0 T E HVS
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