ML20148D605
| ML20148D605 | |
| Person / Time | |
|---|---|
| Issue date: | 10/03/1978 |
| From: | James Keppler NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION III) |
| To: | |
| References | |
| RULE-PR-73 NUDOCS 7811020427 | |
| Download: ML20148D605 (106) | |
Text
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NUCLE AR REGULATORY COMMISSION-I O
t IN THE MATTER OF:
MEETING ON
~
IMPLEMENTATION OF 10 CFR 73 APPENDICES B AND C i
GUARD TRAINING AND C'ONTINGENCY PLANNING O-Place. Chicago, Illinois i
Octe -
Tuesday, 3 October 1978 Pages 1:- 105
- i 1
- i Telechene:
(002)347 3700 ACE TEDERAL REPORMS,INC.
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CR9110-WEL/wJl 1 UNITED STATES OF'LAMERICA 2
NUCLEARi! REGULATORY COMMISSION 3
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-5 6
MEETING ON l
7 8
i IMPLEMENTATION OF 10,CFR 73 APPENDICES B AND C
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9 GUARD TRAINING AND CONTINGENCY PLANNING 10 7
11 12 13 Ballroom o
Ramaea O.uare Imo
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6500 N. Manheim.
Chicago, Illinois 15 16 l
17 The meeting was convened at 9:00'a.m.
i 18 19
.l 20.
PRESENT:
Messrs. J. G. KEPPLER, J. MILLER, E. CASE, I
I R. JONES, F. PAGANO, T. MC KENNA, J. ROE, and R.
CLARK.
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E 9. E I. E E T_ S_-
2 SPEAKER
' SUBJECT PAGE 3
J.
G..Keppler
'Welcome 3
~4 J. Miller
' Moderator 7
5 E. Case Opening Remarks 8
6 R. Jones Rules' 13 7
F. Pagano Why NRR Adopted this Approach-21 8
T. McKenna The Approach.
27 9
J.
Roe.
Contingency Plans 64 10 R.. Clark NRR Staff Reviews 77 11 Questions and Answers-86 12 J. G.
Keppler Closing Remans
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MR. KEPPLER:
Good morning'.
~3-I'm Jim Keppler, Director of !UTC's Region III 4-office.
O:
5 I'd like to welcome you to Chicago and to this-6 regional meeting with power plant licensees to discuss imple-7 mentation of the new guard training and contingency planning a
requirements.
i
'9 Before beginning'the-meeting I'd like to make a 10 few brief announcements.
i 11 We do have two secretaries available here in the i
12 back of the room to assist you if you have.any administrative 13 type problems.
If there are any incoming telephone calls
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for any of you to the motel, a message will be brought up to 14 15 them and-they in turn will get it to you.
16 At 10:00 o' clock this morning there will be a 17 complimentary coffee break in the back of the room.
i 18 No specific arrangements have been made regarding
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19 lunch.
We've got an hour and a half set aside for lunch, from 12:00 to 1:30, and there are a number of restaurants-20 here in the motel and in the. surrounding area so you're free 21 22 to eat where you wish.
23 As you know, Appendix B deals with the general
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24 criteria for security personnel employment.and training.
25 These' general criteria outline the requirements for qualifying, c9ce 9ederal cReporters, $nc.
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equipping and training of individuals who are responsible for 2
-protecting special nuclear-materials, nuclear facilities and 3'
nuclear shipments.
The details of these requirements will be 4
,/'s covered by representatives of the Office of-Nuclear Reactor O
5 Regulation during the course of this meeting; 6
Without wishing to detract from the basic purpose 7
of the meeting, I would like to take a few minutes to discuss 8
two related matters which are of some concern to the NRC.
9 is the large One big problem, as we view it, 10 turnover rate which has occurred within guard forces.
As a 11 direct result of this. turnover, recruitment, screening'and 12 t: aining problems have been compounded.
13 Another adverse result of high turnover is that former guards, some of whom may be disgruntled,-have 15 acquired intimate knowledge of your security plans and 16 procedures and are quite familiar with. day-to-day operations 17 which may exist in the reactor facility.
18 +
The second problem relates to falsification of 19 records and other irregularities associated with the qualifi-t cation of guards which-have been found at some reactor sites.
21 Within Region III alone during the past year, we have had 22 three cases which have been or will be' reviewed by the
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Department of Justice.
One case involved the falsification 24 of training _and qualification records employed by a guard 25 contractor.
This case resulted in the conviction and c: Ace. Jedeta( cAepostets, Onc.
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1 imprisonment of three contractor supervisors.
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Recently.a second case, similar'in nature, was 3
identified by a licensee-through its audit program and has 4
been referred to the Department of Justice for consideration O,
5 of' prosecution.
6 A third case involved security problems identified' 7
by allegations from some guards -- from some former~ guards --
8 and is presently being actively pursued by the Department 9
of Justice.
10 I'm sure I don't need to tell you how these 11 matters are treated by the news media.
12 Because of our concerns in this area, an NRC 13 circular dealing with guard training and associated records 14 will be issued shortly.
This circular will contain specLfic 15 examples of qualification records falsification and weapons 16 qualifications improprieties.
17 In one instance certification of firearms qualifi-18 cation was provided in the form of targets containing holes 19 which were purported to have been made by guards during 20 range firing.
It was later determined that the holes had 21 been made with a pencil.
In another case a number of notarized firearm 22
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- 23 qualification forms were later discovered to contain informa-24 tion which did not accurately reflect the facts.
25 In still another instance guard training records cOce 9edera( cAeporteu, Sne.
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.indicatad that individuals had qualified in the use of 2-firearms with specific ^ range scores, when in fact individuals-3 other-than the qualified guards had fired the qualifying 4
scores.
5 As a result of these and other problems, we are 6
taking a hard look at guard qualification efforts during our q
7
. inspection program.
In this regard, it behooves lISensees 8
to periodically evaluate their. guard forces to assure that 9
whatever commitments were'made to the'NRC are.being met.
. 10 We expect: your guard force to be capable of 11 performing its assigned tasks through physical and mental 12 capabilities.
In other words, as Part 73.55,.Section B.3' 13 states, "No individual shall be permitted to act'as a guard, 14 watchman, or armed: response individual until that individual l
15 has been trained and qualified and has demonstrated an j
16 understanding of the licensee's security procedures and the 17 ability to execute all duties required of him or her by such 18 procedures.-"
)'
19 In other words, an NRC concern which has arisen 20 from our recent experiences is:
Are the individuals who are 21 responsible for the day-to-day protection actually capable 22
.of providing the security required?
23.
A Security Agency study of 1975 concluded that 24 the creation-of a federal. guard force for maintaining 4
25 security in the nuclear' industry would not-result in a higher
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degrca of guard forcs offectivanoss than can be achievsd by 2
the use of private guards properly qualified, trained and 3
certified.
That study fostered these new regulations, and 4-it will require a concerted effort by all of us, NRC and
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5-
-licensees together, to properly implement this upgraded 6
Program.
7 I would now like to turn over the meeting to Jim 8
Miller, Assistant Director for Reactor Safeguards, who will 9'
serve as the moderator for the meeting.-
-10 MR. MILLER:
Thank you, Jim.
11 Before we start, there are a few things ~IJthink 12 need to be said.
13 For those of you who may have missed it, Washington
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14 beat Dallas last night..
)
15 (Laughter.)
1 16 Some of us are happy about that, and some aren't.
17 The second thing is that I noticed Jim Keppler --
u 18 there's no discrimination in this Region, his sign is just 19 bigger than ours, that's all.
20 (Laughter.)
21 I think I need to remind those of you maybe in 22 the back that there is a transcript being taken of the 33 meeting.
For.the benefit of the transcriber, if you have a 24 question or discussion I'm-sure he would appreciate.it and 25 we would appreciate' it if you would identify yourself and c4ce. 9edera( cAeportcu, One.
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1 Lyour_ affiliation.
2 Also,'there:are microphones in several places in the room andiso that'everyone can hear your question, we.
I 3.
J
. ould-appreciate it if you can'get'to one of the mikes.
If 4
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5 not; talk loud enough for everyone to' hear.
6 I remind you this is a meeting between the'NRC 7'
-and licensees.
We.would.like to entertain questions from 8
the licensees first, Land then we'will. entertain: questions 9
from anyone else that might be in.the room.-
9 10 The meeting is structured into three parts:
11 First of all, some general comments.that will be 12 made, probably up.until about 10:00 o' clock.
Then we will-13 get into specifics of guard training and contingency planning, 14
.what we expect, what the rules say.
And then this afternoon 15 We Will.0 Pen the meeting up to.you for questions, comments, J-16 discussion and so on.
17 I might' add that we're going to try to reduce IB the lunch hour down to an hour, since in discussion with 19 some of you you have early planes to.get.out of here.
20
. With that, let me introduce Mr. Edson G.
- Case, 21
. who has some-opening remarks.
.Mr. Case is Deputy Director!
22 of Nuclear' Reactor Regulation.
1 23 OPENING REMARKS BY EDSON G. CASE, DEPUTY 24 DIRECTOR, NUCLEAR REACTOR REGULATION.
25 MR. CASE:'
Thank you, Jim.
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Lrdies and gentlemen, I'd like to express my 2
thanks for your.taking time out from your busy schedules to-3 come.here today.
These types of meetings give us an oppor-4 tunity to present our proposed positions and to hear your 5
comments on them, face to face.
6 We learn from these meetings, and we hope you do 7
too.
8 Before we get into the specifics, I'd like to 9
make a few general observations.
10 As you know, we're here today to discuss the s
11 implementation of the recently proposed rules cut guard 12 training and contingency planning.
I hope we can concentrate 13 in this meeting on how best to'get this done, and not on 14 philosophy.
Because after all, the rules have been published 15 in effective form.
16 Considering that many of you already have ongoing 17 guard training programs, we have ensured that.the guard 18 training requirements we will discuss today were designed 19 to allow you to build on these existing programs.
i 20 On September 14, 1978 the NRR Staff met with the 1
21 Edison Electric Institute Security Committee in New York
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22 City to discuss many of the topics that we will discuss 23 today.
At this meeting several issues and questions were
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24 raised concerning Appendix B that I'd like to specifically 251 address first.
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The' questions ware, or tha locuant 2
(1) The age 121 requirement for armed personnel; 3~
(2) The problem of determining felony convictions; 4
(3) Who'is to be' trained and qualified; and Lh 5'
(4) Are all sites. required to have the specific-6-
equipment listed'in Section 5'of Appendix B.
7 We pointed out at the EET meeting -- and it was 8
pointed out to us -,that NRC's requirement that-armed 9
members of the security force'be at least 21 is inconsistent 10 with many state laws 1that allow licensing of armed security 11 personnel at 18 years of' age.
12 The EEI Committee' indicated that on many sites 13 they are now using armed security personnel who are under 14
'21, and they are also serving well.
15 The obvious inconsistency with the military was 16.
also pointed out.
17 We believe that this is a valid point, and follow-18.
ing a thorough legal review by our staff ' lawyers, we intend 19 to recommend to the Commission that the rule be amended to 20 allow arming of personnel at 18 if that is consistent with 21 state laws at the-individual sites.
22 Severa1' members of the EEI Security Committee 23 Pointed out how difficult it is to determine if an 24
-individual has ever been convicted of a felony.
We're aware-
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- 25-of these difficulties, and this was in part the basis for cAce 9ederal cReporteu, Anc.
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our recommendation of the' proposed clearance. rule.
2-We are currently studying various' options that.we 3
might.suggest iffthe clearance' rule is not passed.
.As you
'd know, it's before'a hearing board.in Washington.
And we
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,welcome'any; input that you might have on this subject.
8 I'm confident.that our objectives in this area:
7 are the same.
You.want to have qualified and trustworthy 8
personnel ~at'your' site, and we want to have qualified'and 9
trustworthy personnel in nuclear. power plants.
We've got'to 10 work together on this issue.
11' At the EEI meeting, NRR was also asked to. clarify 12 who is covered by the training and qualifications requirements Specifically, are the sites required to train, qualify and 13 14 keep records for.all plant personnel?
The answer to that 15 is no.
Only those personnel who perform tasks critical to 16 site security are covered.
This includes the security 17 positions identified as a part of the physical security or-18 ganization in your physical security plan, and those positions 19 also identifi.ed in the contingency plan as performing key t
20 security tasks.
21 Lastly, EEI wanted to know if the licensees are 22 required ~to have on site the specific equipment specified' 23-in Section 5 of Appendix B.
They pointed out the difficult'ies
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24 it would create because of local laws, federal regulations,.
25 and incompatibility of.the' equipment listed with specific cAce. CIedesa( cReporten, Anc 444 NORTH CAPITOL STREET WASHINGTOM. D.C. 2 Met (202) 347 3700.
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site requirements.
2 Going to Appendix B, it states -- and I quote:
3
" Guards and armed response personnel shall either 4
f~
be equipped with or have available the following
(-)
5 security equipment appropriate to the individual's 6
assigned contingency / security related tasks or job 7
duties as described in the licensee's physical security 8
and contingency plan."
9 Thus, the equipment you have identified in the 10 site's approved security plan meets this requirement.
11 Therefore, you are not required to have on site all of the
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12 specific equipment listed in Section 5.
Equipment require-13 ments for each site will be reviewed on their own. merit, on O
14 a case-by-case basis.
15 Although we're here today primarily to discuss 16 guard training and contingency planning, if you have 17 questions on other topics that you feel must be asked, we'll 18 be happy to address them during the question-and-answer 19 period this afterneon.
20 I'd like to thank you again for coming to the 21 meeting, and I express my confidence that it will be a 22 productive one for us and you alike.
23 Thank you.
24 cR. MILLER:
At this time let me introduce to 25 you Mr. Ralph Jones.
Ralph is responsible for the cAce 9ederal cReporteu, Dnc.
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promulgation.of rules in the safeguards ~ area.-
He is Chief 2
.of'the Safeguards Standards Branch, Office of Standards 3
Development.
4 PRESENTATION BY RALPH JONES, CHIEF, SAFEGUARDS O
5 STANDARDS. BRANCH, OFFICE OF STANDARDS DEVELOPMENT.
6 MR. JONES:
I'm not,sure I like that introduction.
7 It' sounds like I'm responsible for the whole thing.
8 (Laughter.)
9 But', nevertheless, what'I propose to do is discuss to the status of some of the regulations thatlyou're aware of 11 and are concerned with, and one of.the Regulatory Guides 12 that we're. mainly concerned with here'today.
13 The security personnel training and! qualification' O.
regulation was published for_ comment, and' included detailed 14
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15 training requirements and specific qualification requirements-16 hours of training, specific courses you had to train people l
17 in.
It addressed training, mainly.
,j 18 Comments were received primarily as to the 19 inappropriateness of specifying these detailed requirements 20 without recognition of the skills and abilities that were j
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21 needed, and without any recognition of the skills and
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22 abilities that the guards might already have.
23 Comments also indicated possible problems with 24 EEOC guidelines where the requirements were not job related.-
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25 Further comments were also concerned with the cAce. 9edesa{ cRepsten, Sac d44 NORTH CAPITOL STREET WASHINGTON. D.C.
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chort' implementation time and clarification of the applicabil-2 ity of the requirements and definition of some of the terms.
'3 When the rule was published for comment, the l
4 Commission also requested comments regarding implementation
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5 with respect.to central, regional or local training, and-6 certification or licensing considerations.
7 The major change that we made in-Appendix B was 8
to turn'it around, so to speak, and specify the-skill'and-9 knowledge to be considered in the licensee's training plan.
10 There still are some qualification requirements for employment 11 suitability, but even these have been modified to be job 12 related.
13 For example,.the physical fitness qualification
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14 no longer calls for an 8-minute mile and pushups.
- Rather, 15 it is required that a person be physically fit for his 16 assignec task.
If a CAS operator or the central alarm 17 station operator, for example, doesn't have to do anything 18 but sit at a console and run the central alarm station, it 19 may be that he could do this from a wheelchair.
20 The major thrust now is to provide flexibility for 21 you, the licensee, to design the training and qualification 22 program to fit site-specific security programs.
23 This turnaround, to tie into job related skills
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24 and abilities, should resolve the EEOC' problems, with the-25-Possible exception of the 21 year age question.
Although at c0ce-9edesaf cRepsteu, One.
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'1-tha timo wa ch:cksd with EEOC and tha otatutas, and thsy 2'
indicated there was no lower limit.
They were' concerned with
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3 the older people.
4 The implementation times have'also been changed-1
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to' provide' considerably more time to develop'and implement' 6
the-plans.
7 A few comments were received on the question of 8-training location and certification.
The final rules 9
provide flexibility in this area.
It does not require 10 certification, does.not specify the type'or location of 11 training.
12 We have undertaken a study _ toe.look at the pros 13 and cons of centralized training, regional training, local
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training, certification, licensing of guards. 'As a result
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14 15 of this study and the' success of implementation of the 16 program as it is now structured, the NRC will consider 17 whether or not any further action is-necessary.
18 I don't believe I need to review the details of 19 the requirements in the regulation itself.
You're all 20 aware of these, as stated in the Federal Register.
If there 21 are any specific questions, we can take them up during the 22 question-and-answer period..
R 23 One_ question that_did arise in discussing this 24 with some of the regional offices was the problem of
- 25 documentation of-training and qualifications.
The regulation, l
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.:bi-73.55, does not specifyLthat you will document your l
1 2
' original trainingJand qualifications.
It is, however, 3
specified that this be done in the Appendix -- specified-
'4 in the Appendix that it be done.
And the Appendix has the
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5 same force :bt law as the Regulation itself.
So Appendix B, f
6 Section'2.B, specifies that your original qualifications ~for your guards shall be' documented.
So.that should resolve 7
8
'one question'that has arisen.
9 To' assist in implementation of'the guard training-10 rule, several guidance documents have been published.
NUREG 0219, which will be discussed later on in some detail, is 12 one-of them.
Two others were NUREG 0464 and 0465.
These 13 are training manuals.
They have now been published for
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14 comment.
15 We recognize that we gave a very short time to 16 comment on a large volume of material.
Nevertheless, we 17 were committed to~have these final documents available to.
18 you.by October 23, the effective date of the regulation.
We i
19 didn't have time to provide any further comments.
20 We have received a number of commen~s.
other c
21 than typographical errors and incorrect statements, the-22 comments.primarily concern the. status of these manuals as
(])
23.
requirements 'or guidance.
They were intended as a reference 24
. document to provide information for you to use in training 25 your' security personnel.
It is not a Regulatory Guide.
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17 I
'does not'present a regulatory position.
It does not require 2
that any or all of these lessons be used.
It is an_ attempt 3
to~ assist in developing training plans.
4 In reading the document myself, I found a number 5
of statements that implied requirements.
These should not 6
have been there.
It will not be there in the final document.
7 I also noted definitions and references to the 8
regulations that have changed.
,These will be removed:and/or 9
corrected.
10 The regulation in 10 CFR Part 73 specifies, 11 the requirements.
This training manual provides information 12 that can be used in meeting the regulations.- And that is 13 all information, it is not' required.
/"%
V 14 All of you have seen the document, so I'll not is
-spend-any time telling you what it is.
But to put into 16 context the subject material in it, the 0464, the site one, 17 is;of major concern.
Volume.I covers basic material that 18 most security people should know.
Some of it may not be 19 appropriate to your facility or to every person in your 20 security organization.
Select from it to develop your own 21 basic training.
22 Perhaps you will have more than one. basic
('s 23 training course, depending on how your security functions V
24 are structured.
25 Some comments have addressed the content of some i
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1 of the basic training plans as being inappropriate or 2
unnecessary.
One comment'said.that a guard does not need to 3
know anything'about objectives of the adversary or the' role j
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4 of private security. officers in the criminal justice system, 5
or the growth of private security in the nuclear-industry to 6
carry out his security duties.
Well, this may be true'in'the 7
. strict sense.
But the person who has some background infor-8 mation and has an understanding of why the security job he.
9 is doing is necessary, and where it fits the total picture, j
10 should be able to do a better job.
-l
'l 11 But, again, these are only lesson plans that are 12 suggested.
They are not required.
You'do not'have to'give 13 your guards this kind of training.
O:.
14 volume II provides more basic material, more 15 specific topics.
Again, select appropriate to your site.
16 Volume III is said to cover advanced training.
17 This may be misleading.
It is advanced in that it is more 18 specific than basic.
It is intended to advance the training 19 to site-specific topics and procedures.
Perhaps a better 20 label could be used.
In any case, the intent is to provide 21 guidance in developing.a training' plan tailored to specific 22 sites.
(~T 23-Volume IV covers the weapons training and
.v.
24 qualification.
Again, you would select the parts: appropriate 25 to.the weapons your people would have available to them.
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'I original' publication 'indicct;d thora wara fiva volumen.- Thsra 4
2:
are not.
We did'haveLfive originally, but in the revised 3
there's only four.
That, too, will be corrected..
4 In summary, let me repeat:
5 This manual is not a requirement, butcis intended a
to provide information..You will note that'there are-times 7
.specified in the lesson plans..These are suggested times.
8 The course work may take longer, or not as long, depending 9
on the class,-instructor, previous training,. experience, and 10 so forth.
1:
In fact, if a security person already has skills 12 and knowledge in the function, and it can be shown by some 13 demonstration that he has these, then no training is needed
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14 at &ll.
However, you should still have a training program 15 for those who do n3t have such skills or knowledge.
16 Prior training, military training, could reduce 17 or eliminate the need for additional trair And this-18 document, the training manual, might not bt Jed, or might 19 be needed only for selected areas that are not covered by 20 somebody's prior training.
21 In summary, it's strictly information for your 22 use.
23 Regarding the contingency plans, the rules have
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24 been published, as you know, and Reg. Guide 0554 was 1
25 published to provide guidance.
This is e Regulatory Guide, cAcc. Jedeta( cAepostcu, Snc.
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It hnsla'differant status'than th2 NUREG documsnts.
J 2' Jack Roe will goIinto the details of contingency 3
plans and what you will be~ expected to'come up with in 4-relation to this, so I will'not do that.
I'll simply tell O
5-you,the status of the Guide.
8 It was. published for comment-in March.
We have 7
- received a few comments.
Two utilities and two individuals
-8 commented.
In general, the comments were concerned.with 9
thJ redundancy of the contingency plans and the physical 10 protection plans, and the need for centrolling access to the 11 information contained therein.
12' As you will hear several times today, we do not
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13 expect you to repeat various.itemsfin your physical protectior.
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14 pl'an and yet-r vontingency plan.
They can be combined-as one.
15 They c.
.te plan'.
However_you wish to do that-for 16 your plan 17 None of the comments that we received were e
18 considered to call for a revision of the Guide'at this time.
19 So Reg. Guide 554'will not be' revised until after we have l
20 had some experience in using it in the' development of 21 contingency plans.
In the meantime, if any of you have.any 22 comments, please send them to us.
23-The other rule I want to mention to you this 24 morning is the Material Access Authorization Program, l
. 25 '
commonly known as the clearance progren.
As Ed mentioned, 1
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it was before.a hearing board. :The hearings were. held in l
,2 July. 'They've been massaging the, transcripts and'what not..
~
t 3
- They i etre requested by 'the Commission to provide reccmmenda-j i
tions'to the Commission, and they were required to provide to
~
5 l
the Commission yesterday a schedule for completion of their 1
task,,the-hearing board'sitask.
We have not'yet' heard what f
6 that schedule is.
I' called the o'ffice yesterday, and nobody.'
~
8 had that'information.
I don't know what the. hearing board's schedule is to complete the recommendations to the Commission.
+
10 I would expect it should be within the next month or so,.but Il right at the moment I don't have that information.
By.the 12 time I get'back to Washington, later on this week, it should 13 be available.. So you can call me or Jim, or some of us, if O'
I#
you're really interested.in that, and we'should be able to-15' tell you.
16 Thank you.
'l7 MR. MILLER:
Thank you,. Ralph.
'8 To wrap up the general portion of the meeting,
'8 let me introduce Mr. Frank Pagano.
Frank is the.. Chief of j
20' the Reactor Safeguards Development LTanch, NRR.
21 PRESENTATION BY FRANK PAGANO, CHIEF, REACTOR 22 SAFEGUARDS DEVELOPMENT BRANC51, OFFICE OF. NUCLEAR
]
O 23 REACTOR REGUtATION.
MR. PAGANO:
Can everyone hear me all right,
)
24
< 25
- because my cold is so bad.I can't even hear myself.
I sound
~
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like I'm in a barrel.
2 Good morning, ladies atJ gentlemen.
During the 3
next few minutes I'm going to discuss how NRR came to select 4
,q the approach outlined in NUREG 0219 for inplementing the
%)
5 training and qualification requirements in Appendix B, but a
the basic reasons as to why we adopted this approach is 7
shown on this Vugraph.
_ Slide.)
(
8 9
First, it ensures that the site security staff to can successfully implement their physical security and 11 contingency plans and, secondly, it is compatible with 12
' federal and state legal requirements.
13 (Slide.)
14 Over a year ago, NRR started a search for an 15 approach for determining the adequacy of training.
We 16 reviewed the existing literature on training program develop-17 ment, discussed the issues with organizations with similar 18 problems, talked with other federal agencies who have 19 experience or regulatory responsibility in the areas of 20 training and personnel selection, such as the Department of 21 Labor, the Civil Service Commission, the Equal Employment 22 Opportunities' Commission.
23 We reviewed the comments received on the drafts
}
24 of Appendix B and NUREG 0219, and discussed the issues at 25 length with the NRR Staff.
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Traditiennlly tha NRC cnd th2 sccurity industry 2.
.have discussed training and qualification in terms of 3
completing course work on various subjects.
However, our 4
experience uncovered the fact that the course outline O
5 approach provides no guarantee that an individual can, in C
6 fact, do his or her job.
It identifies the content to be 7
learned or trained in, but it does not establish what the 8
trainee is able to do,upon completion of the course.
9 A course outline may suggest' that guards and 10 watchmen complete 50 hours5.787037e-4 days <br />0.0139 hours <br />8.267196e-5 weeks <br />1.9025e-5 months <br /> of course work, but what has to 11 be known is what can this security person do after completion 12 of this training.
13 For example, can he or she respond to an alarm in
()
14 accordance with the site contingency procedures?
15 Do they know how to report a suspicious event, or 16 how.to detain a suspect?
17 The basic questions really are: _ What standards 18 must the trainee meet, and are these standards compatible 19 with the site plans?
20 Is the individual being adequately trained and 21 evaluated on the truly critical parts of his job?
22 We feel the course outline approach does not 23 answer these questions.
24 (Slide.)
25 The question that all of you are asking is why i
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did the NRC publish.this upgraded. training-and. qualification-2
- requirements?: The answer is that the NRC determined that it.
3 needed assurance that the people who perform critical 4
security tasks at the site can perform.them adequately.
5-Therefore, Lour regulatory approach had to be designed to 6
answer the1 question:
Can this individual do his cn: her 7
job?
8-Such questions as how much training,has this 9
. person received, or what courses has he or she:4ttended, do 10 not really tell us anything about successful performance.
11 We are interested in the ability of the person to do the 12 job'to which he or she has been assigned,-and not necessarily 13 how this ability was' developed.
i 14 (Slide.)
15 Now, what is the solution?
How can it be 16 determined if an individual can satisfactorily perform their j
17 security duties?
18 We found that the solution is well deve30 ped and 19 widely used.
It is currently being used by.all.the armed 20 forces, by many. police organizations, and in every imaginable 21 occupation from private security to carpentry.
22 Briefly stated, you must'first analyze the 23 individuals job to determine what the individual must.be
{)
24 able to do to successfully perform this job.
That is,.you 25 conduct'a job analysis to determine what tasks are required cAce-9edeta( cReposten, Onc..
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to implement the site physical security ^and contingency plans.
2 Next, you outline-in the form of_a performance 3
objective how the ability to perform these tasks is demon-4~
strated.
This objective outlines the test to be given to f-i 5
each individual.
6 Finally, personnel are qualified to perform their 7
assigned tasks by successfully achieving its objectives.
8 For example, your site contingency plans may require the 9
use of night vision equipment during contingencies.
There-10 fore, the site training aad qualification plan should 11 identify who would use tais equipment, what tasks they would 12 perform, and how they must demonstrate their proficiency.
13 NUREG 0219 formalizes this approach.-
14 (Slide.)
15 on July 5 of last year the Commission published 16 draft requirements for upgraded guard training for comment.
17 This was the first draft of Appendix B.
It, consisted of i
18 training courses requiring over 150 hours0.00174 days <br />0.0417 hours <br />2.480159e-4 weeks <br />5.7075e-5 months <br /> of instruction.
In 19 addition, it required that all individuals taking these 20 cources pass a test on the material making at least a 70 21 percent score.
22 Many NRC licensees who commented on that document
{)
23 pointed out that these requirements did not comply with j
24 EEOC-guidelines on testing and selection, which require that i
25 any discriminatory requirements must be shown to be valid i
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26 indicators of'an individual's ability to do his or her job.
1-
-2 In other words, it must be shown that a particular test 3
score will indicate that the examinee can or cannot do the 4
job.
5
-Now, this can be accomplished by requiring that 6
the test represent samples of the knowledge, skill or 7
abilities necessary to do this job.
For the most part this 8
can be accomplished by developing tests that have miniature 9
samples of the job.
For example, implementation of a site 10 contingency plan may require the guard to respond to any 11-point on site within three minutes of notification.
A valid 12 test of this ability is simply to simulate the soundir., of 13 an alarm and see if that particular individual can respond 14 within three minutes, and so on.
15 (Slide.)
16 EEOC guidelines further pointed out that in order 17 to dCvelop tests that are valid you must first conduct a 18 job. analysis to determine what makes up the job.
And based 19 on this information, develop tests that test the knowledge, 20 skills and abilities identified during the job analysis.
21 (Slide.)
22 This is exactly what will be accomplished when 23 training and qualification programs are developed as we have
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24 outlined in NUREG 0219.
25 You must first conduct a job analysis and, based cAce-9edera{ cReportcu,.One.
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1-on this analysis, develop performance objectives that outline
'2' valid tests of the knowledge, skills and abilities identified.
3
-(Slide.)
i 4
The approach outlined in NUREG 0219 does two 0
4 5
. things:
i i
6 First, it demonstrates that the individual can.
7 perform his or her security ' duties, and, secondly, it allows a
development of a training and qualification plan that is 9
compatible with EEOC g -(delines.
10 Thank you.
11 MR. MILLER:
Ladies and gentlemen, I think 12 there's some coffee back there.
Why don't we break and be 13 back here at 10:05.
I 14 (Recess.)
15 MR. MILLER:'
All right, if we could begin, at' 16 this time we'd like to get a little more specific.
17 Let me introduce Mr. Tom McKenna.
I think he has 18 probably talked with most of you.
Tom is the gentleman who-4 19 has been working on 0219 and some of the concepts that have l
20 been put into 0219 that have been briefly discussed this 21 morning.
Tom is in the Reactor Safeguards Development Branch in NRR.
22 r'h 23 PRESENTATION BY THOMAS MC KENNA, REACTOR
\\J 24 SAFEGUARDS DEVELOPMENT BRANCH, OFFICE OF NRR.
l 25 MR. MC KENNA Good morning.
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I work for Frcnk Pcgano, who just addrcaccd you a i
2 few minutes ago.
3
- Now, I'n. going to discuss briefly how you car 4
job analysis and performance objectives to meet the r<
)
f 1
5 ments in Appendix B.
l 6
(Slide.)
7 I'm not going to discuss all the requirements 8
Appendix, I'm just going to concentrate on the-training P.
9 qualification requirements.
I'm not going to talk about 10 suitability or the physical and mental qualifications, or 11 the equipment requirements, but just concentrate on that 12 one area.
13 This is going to be very brief.
14 I am just hoping to define a few terms and give 15 you the flavor of the approach.
0219 gives you some more 16 detail on the approach, and I'm not sure that everybody here 17 knows what 0219 is.
18 This is 0219.
(Holding up a document)
And it's 19 a NUREG document.
It's entitled, " Nuclear Security Personnel 20 for Power Plants."
It was published in final form in July 21 of 1978.
We mailed one copy out to each one of our licensees 22 and applicants.
The rule itself mentions.it and states that
[}
you can get another copy by writing us at the NRC.
In 23 24 addition to that, it's available from'NTIS for eight bucks.
25 (Slide.)
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1 W2'ro going to start with the qualification 2-requirements.
The qualification requirements are shown in H
3 two separate sections of' Appendix B.
Next slide, please._
4
- O 5
(Slide.)
6 I'm going to quote now.
Paragraph II.B of-7 Appendix B, which is the qualification requirements section, 8
states - - and I quote:
9 "Each person who performs security related to job tasks or job duties required to implement the 11 licensee's physical security or contingency plan 12 shall, prior to being_ assigned to'such. tasks or 13 duties, be qualified in accordance with the licensee's
}
14 NRC approved training and qualification plan."
15 Now, paragraph II.D -- and this is security 16 knowledge, skill and. ability -- and again I quote:
17 "Each individual assigned to perform the 18 security related tasks identified in the licensee's 19 physical security or contingency plan shall demon-20 strate the required knowledge, skill and abilities 1
21 in accordance with specified standards for each 22 task, as stated in the NRC's approved licensee's 23 training and qualification plan."
24 Now, there are some key ideas.
25
'First, personnel must be qualified to perform c0ce. 9ederal cArposteu,.One.
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- their security tasks and' duties.-
('
.}
Secondly, this qualification is done by'having 3
them d'emonstrate-the: knowledge, skill and ability required 4
to'performethese security tasks and duties.
5'
'And, finally, this has'to be demonstrated. 'This 6
- y,y,y of knowledge, skill and ability has to.be demonstrated
'to specified standards.
And these standards have to be
^
8 specifiedEin your plan.
9 Now, 0219 formalizes this process.
10 l(Slide.)
11 We use job analysis and' performance. objective to 12
~
'The-reason we've used these techniques are:
do this.
'3
.(1) It does the" job for us.
It does formalize LO-1.
this process.
15-Secondly, these are-well known techniques.
16
.They've.been used throughout education development ereas for a number of years.
So there's a lot of literature availabic
-l 18 on these particular approaches.. And, for that matter, in the last meeting.several people asked if we could supply 20 -
some references.
Well, we did, ve produced;a short list --
21 I think there's five or six snecific, references, and they 22-were handed out st this meeting ~.
These were some cf the
.23' h
references that we used in developing this approach.
But 24 there are many out there.
You.can go to any library:and 25' look under performance objectives or job analysis, and you'll
'?-
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. find a fairly extensive list..
2 I'm also sure that'most of your personnel in your q
3 training department, or your personnel departments in.
1 general'have people who are knowledgeable in these techniques.
5 This whole technique has become widely u' sed'in the last few 6
years, primarily under pressure from EEOC.
.They have 7
essentially identified this as a way of meeting their guide-8 lines, and this has created a lot of pressure on a lot of:
8 segments of'the economy to use'these approaches.
10 I have to caution you, though, the level.of_ detail _
11 that we indicate is required in 0219 -- or suggested in 0219 --'
12 is not the same level of detail that's indicat,ed in.the 13 various literature on this subject.
Ours requires less 14 detail.
In a' sense, it's a watered down version.
It 15 provides enough information to answer certain basis questions g
16 to us -- and I'll talk about what those questions are.
But 17 it may not specifically meet EEOC requirements.
You may 18 have to take a more rigid approach.-
J 19 But it is compatible -- and what I mean by that 20 is you can meet EEOC requirements while meeting ours.
21 Next slide, please.
22 (Slide.)
23 Meeting these requirements requires essentially 24 three steps:
25 First, you have to conduct an analysis to j
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determine what tasks and duties are required, are critical 2
to the implementation of your site's physical security and I
3 contingency plans.
({)
We don't want training standards or qualification 5
standards to be set in a vacuum, they have to be related to 6
your. site requirements, how you are going to bnplement these 7
plans.
8 So, how else can you set these standards?
You 9
have to look at your site requirements,.at your approved 10 plans, and decide what is required.
1*
Secondly, you have to develop tests that determine 12 whether an individual can perform these tasks that were 13 identified in the first-step.
Now, here again, this requires s
14 an. identification of the knowledge, skills and abilities to 15 perform these tasks, and then a test that tests these 16 knowledges, skills and abilities.
These tests.have to have 17 two characteristics:
18 One, they have to be valid.
What I mean by 19 valid is that they have to be a true indicator of the 20 ability to perform the task; 21 Secondly, they should be reliable.
Everybody 22 should be tested the name way.
()
So when you set up the tests -- and we're going 24 to call them performance objectives -- you have to provide 25 sufficient information so that we can be assured that they I
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33 1-are valid, and that they are reliable.
2 Finally, you-have to qualify your people.- And 3-you qualify them by having them demonstrate their ability to 4'
perfonn the tasks that are identified for their-specific g(e)
/
5 duty assignments.
And this is done by having them success-6 fully complete the performance objectives that have been 7
identified for those tasks, as tests for those tasks.-
8 This might be.a good point to talk about part 9
3 of 0219.
As you probably know, part 3 contains a sample.
10 of a qualification plan that has a sample set of tasks and 11 a sample set of performance objectives..It is just that, it 12 is a sample.
Each site has to conduct their own analysis 13 based on their own plans, to identify the tasks and then 0
14 determine what are valid, reliable tests of those tasks.
15 We have been criticized in the past when we've 16 written guidance that we never supplied any sample, so we 17 never really knew what you people wanted.
Well, we supplied 1
18 it this time, and that's the purpose, is to show you the 19 level of detail.
And we also hope that it's useful to you.
20 Because essentially we went through the steps that are l
21 required.
22 Next slide, please.
(}
23 (Slide.)
24 So now let's take a look at this first step.
25 We saw that-there were three steps.
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34 7
do.an analysis of the job at your site, you had to identify 2
tests of these knowledge, skills and' abilities, and you had 3-to qualify the personnel.
)
The first step is called job analysis, and this 5
is in.which you identify the tasks, duties and-elements --
6 we use the word " element" here to signify knowledge, skill 7
~ and ability rather than say knowledge, skill and ability each 8
time -- required to implement your physical security plan.
)
8 The key is that the' specific site determines the 10 structure -- here again, based on your physical security and 11 contingency plans.- A lot of. people have commented that the 12 way it~was broken down in 0219 was cumbersome.
We had 13 t
13 duties, broke it down, every individual-had to be assigned I
14 and qualified in a specifin duty.
You decide the duty 15
' assignments that are required to implement your physical 16 security and contingency. plans.
You determine the structure.
17 The next two slides'are going to show this 18 structure, and I'll try to define what a duty,,a task and 18 an element is.
20 (Slide.)
i 21 In this' case here the top level is the job.
A 22
- job is everything an individual does for you at the site.
(])
It's possible'this could encompass security and non-security 23 24 work.
It's possible it could encompass a whole wide. range 25 i
of activities.
It's everything the individual does.
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In this case we have a search watchman as'being i
2
.the t'op level.
That's the job.
The fact that'it does cover-
]
3 such a wide range of activities, and it's difficult to 4
correlate what an individual is doing during a specific es.
U 5
shift and his job, we decided that qualification shouldn't i
'6 be based on job, but should be based on the next level --
i 7
which is duties.
8 In this case, we have two duties.
There may be 9
more.
We have vehicle search and personnel search.
10 Now,'the characteristic. of a duty that makes it 11 ideal for basing qualification, or as a basis for qualifica-~
12 tion, is that a duty is what an individual is assigned to 13 do during a specific shift.
That essentially is the'defini-r.
J 14 tion of a duty.
It's what the shift assignment has 15 identified as this particular individual's job during that 16 shift.
In this case, here, the individual might be conduct-17 ing vehicle search or he might be conducting personnel.
18 search.
19 Now, he may not be doing them both during the 20 same duty assignment.
On one shift he might be doing 21 vehicle search and another shift he might be conducting 22 personnel search.
But we can go out to the site now, I&E
(^T 23 can go out there, and if an individual is assigned on the u) 24 duty roster to perform vehicle search then we can check to 25 see if he's qualified to do it.
So you can see that the cAce-9edera{ cReprteu, Dnc.
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relationship between qualification and duty assignment is 2-clear cut in this case.
What the guy is assigned to do during 3 '
.a shift as you've identified it is his duty assignment, and' 4
.he has to be qualified to perform it.
5 The next level are the tasks.
These are the.
8 specific -- and here I'm going to use the. term again -- these 7
are.the tasks that'an individual performs while performing 8'
a specific duty.
And we'ask you to identify them by duty.
8 In this case we have personnel search, where.he probably i
performs certain tasks.
I 10 Now, what's a task?
Well, a task is something that f
11-12 one. individual performs.
If a group of individuals perform 13 it, then each one performs a slightly different task.
It's O
14 something that's observable.
You can see him do it.
'It's 15' measurable.
You can set some sort of standard to determine 16 whether he's done it correctly or not.
And it has a. specific 17 beginning and end.
3 18 In this case, while conducting the duty of 18 personnel search he might have to do the following things:
l 20 He might have to calibrate the metal detector -- he or she 21 might have to calibrate the metal detectorr'might have to 22 communicate with a radio; may have to recognize unauthorized h
23 materials, because how can they determine whether a person 24 has something unauthorized -- which is the basic purpose of 25 the search -- unless.they can recognize unauthorized materials?
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And they may have to take notes.
2 Now, I've added the'"take notes" because we state in 0219 that you should only identify in your physical' 3
4 security -- not in physical security -- I mean~in your qual-5 ification plan, in other words when you conduct your 6
analysis -- only those tasks that are critical to implementa-7 tion of your physical security and contingency plans.
If 8
we didn't do this, the list would probably'be very, very 9
long.
As it is, we're trying,to zero in on the tasks that i
10 are truly important.
11 Rath'er than create some confusion I think I'll 4
12 quote from 0219 on what we mean by a critical task -- and I 13 quote:
O
\\'
14 "A task is considered critical if its performance 15 is essential for successful implementation of the 16 site's physical security and contingency plans when 17 needed, even though it may not be performed frequently 18 cr only performed during a contingency."
19 Now, this is probably the key phrase here:
20
" Inadequate performance of a critical task 21 impacts on the ability of the site to detect, assess, 22 respond or neutralize some sort of unauthorized
(])
23 activity."
24 Now, in this case I would consider calibration 25 of a metal detector, communications with a radio and cAce. Llederal cRepmteu, Anc 444 NORTM CAPITOL STREET WASHINGTON. D.C.
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recognition.of unauthorized materials as being critical tasks.
2 If you didn't perform those.it would impact on your ability 3
to detect, respond, assess and neutralize.
4 But taking notes probably is not a critical task.
5 That's probably used to make after action reports, et cetera.
6 So that probably would not be included in your. plan.
7 other examples are filling out maintenance 8
records.
Although you have to do it correctly, and I&E is 9
going to go out.there and see if you're doing it correctly, i
10 it shouldn't be included in your qualification plan because 11 it's just going to add bulk, and we're trying to get to the 12 critical tasks.
13 Another thing that shouldn't be included are what
.,Q
14 we call common knowledge or universally performable tasks.
I 15 Example:
Answering the telephone.
Answering the telephone 16 may be very critical,.but its. inclusion, here again, in your 17 plan is not going to 2ero in on critical -- it.isn't going 18 to add any substance.
19 Now, you have to be careful when you're talking 20 in certain areas like physical tasks, because some of these 21 may be considered as universally performable when they i
l 22 really aren't.
(}
23 Next slide, please.
24 (Slide.)
25' Now, thiu shows the next level.
This shows the cAcc. 9ederal cReporten. Dnc.
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ltotalbreakdown.
Now'a va addtd knowlcdgD, Okill and 8
1 w
2 ability in this slide.
Remember, the rule and the' approach i
3 we're taking suggests that you qualify personnel to perform 4
task's by having them demonstrate _that they have acquired the O
5 required knowledge, skill and ability to perform these tasks.
6 So you have to take the analysis.one step further, 7
and that is to identify the knowledge, skill and ability 8
required to perform the tasks.
This is probably the toughest 9
step.
Tasks are fairly clear cut.
I think duty assignment to you decide.
But what knowledge, skill and ability is 11 required to perform these tasks is both a critical.and a 12 difficult step.
13 In this. case -- this, here again, is just an 14 example -- we say to recognize unauthorized materials requirer 15 the knowledge to be able to recognize explosives, the 16 knowledge to be able to recognize explosive accessories 17 not "assessories" as we have here -- and the. knowledge to be 18 able to recognize incendiaries.
19 This identification of knowledge, skills and 20 abilities, as I've just said, is going to be difficult.
And 21 I think to a great extent it should be based on accepted 22 practice, what is accepted practice in dealing with a 23 contingency, what do other organizations with similar
(}
24 problems -- how do they break down the knowledge, skills and 25 abilities.
And -- as we'll talk about in a few minutes -- I cAce-9edet:{ cAeportcu,.Onc 444 NORTH CAPITOL STREET W ASHINGTON. D.C SMot tan) s4MMo
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1 think that probably the source of this information would bat 2
(1) professional judgment of your staff, and 3
(2) literature searches.
4 I think there's a lot of information, a lot of people know 5
how to perform these things, and I think that's where you i
6 have to do for this information.
7 Next slide, please.
8 (Slide.)
9 Now, how do you -- we talk about an analysis, and 10 that you' have to analyze the requirements at your site.
But 11' how do you do this?
12 First, job analysis, again, is intended to identify 13 the tasks and the knowledge, skills and abilities required 14 to perform those tasks.
And to do this I think requires 15 three' basic steps:
16 (1) To identify the task you go through your 17 physical security plan, and you take a look at each paragraph 18 and write down what tasks you believe are critical to success-i 19 ful implementation of that particular paragraph.
Here again, j
20 remembering criticality.
There may be some record keeping 21 tasks, a paragraph that deals with record keeping, that in i
22 themselves aren't critical to the protection of the site.
23 So remember criticality.
Take a look at each paragraph of
(}
24 your physical security plan.
I 25 (2)
Take a look at your contingency plan.
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i 1
in your crntingency plan it in required that you provideEn 2
responsibility matrix.
And Jack Roe is gcing to talk about 3
this, so I'm stealing some of his thunder.
But the 4
responsibility matrix says that for each contingency event
'C 5
that you've identified, you identify basically.the duty 6
assignment and what each individual does, the decision /
7 actions that are required, to handle the event.
8 Now, the thing to note.is that these decision /
9 actions required to respond to a particular event are 10 probably very, very similar to'the tasks required to respond 11 to the event.
And since only critical decision / actions 12 should be included in your responsibility matrix in your 13 contingency plans, it's reasonable that.you should.go to
'*(
14 your responsibility, matrix, take a look.at each one of the is decision / actions in'the responsibility matrix, and determine 16 what tasks are required to implement those decision / actions.
17 I think in many cases those could be one on one, la could'be the same.
The decision / actions and the tasks could' 19 be the same.
20 Finally, we've identified the tasks by going 21 through the plan, and now we have to identify the knowledge, 22 skills and abilities.
There again it's a tough step.
I say 23 a security literature search.
You can also use the 24 professional judgment of your staff.
Break it down one step
'25 further,.and decide what the guy needs to know, needs to be c: Ace-9edesaf cAepcwten, !)nc 444 NORTH CAPf?OL STREET WASHINGTON. 04 3MC1 (Sea) 347 3790 4.
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' ablG to do, what ckills han h3 devaleped.
7 So this analysis..what is it going to identify?
3-Well, here again I'm just going to read through some of the 4
basic types of tasks that are involved.
5 You should identify all the critical tasks 6
associated with the use of security equipment, job aids, and 7
references.
8 Security equipment.
Tasks involving security 9
equipment.
That's clear cut.
A piece of equipment is a 10.
weapon.
So there's certain tasks requiring the use of a 11 weapon.
Use of a metal detector -- clear cut.
12
. What do we mean by job aids?
Well, you may, for 13 instance, decide that on a certain watch you're going to O.
14 give the people some sort of summarized card that tells them-15 what to do in certain situations.
That's a j ob aid.
And 16 if it's required that they use.this in the performance of 17 their duties, and it's' critical, then you should have a-1 18 performance objective that demonstrates that they can use 19 it.
l
~
20 Next, manuals.
You may, for instance, have 21 certain critical tasks that have to be performed that they 22 have to look up, for instance, in your site security 23 procedures, some sort of more complicated manual.. If that's
{j 24 required, and if they have to be able to read this informa-t 25.
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understanding, then you should have a performance objective 2
that tests this -- if it's critical, agaln.
3 Jack is going to talk about different types of 4
information in a few minutes.
'd 5
Critical tasks associated with the implementation 6
of procedures.
If you have a specific procedure at your 7
site that's critical to the security of the site, then there 8
should be a task identified.
You Know, you ' ~ve to identify 9
the task required to implement those procedures.
The obvious 10 example, here again, are the dec:.sion/ actions in your 11 responsibility matrix.
12 Physical abilities required to perform critical 13 tasks.
As Mr. Jones commented earlier, we revised the
,3 ik 'i 14 requirement on physical performance, or physical fitness 15 requirement, and we basically said that you'd conduct an 16 analysis at your site to determtne what physical abilities 17 are. required to implement your physical security and 18 contingency plans, or to perforn certain duties.
19 So, in your qualification plan you should identify 20 what physical abilities are required to implement a particular 21 facet of the plan.
Now, here again, there may be a broad 22 Spectrum of abilities required.
I think what you're trying
(~)
23 to concentrate on are what are: considered, here again, not J
24 universally performable, truly important.
The example that 25 Mr. Jones gave about having a CAS operator who is not c4cc-9edeta[ cReporteu,.Onc.
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.1' irequired:to walk', therefore that-particular physical ability 2
would'not be-required in your. duty description.
So you
'3 could hire somebody to do that-job and he c'ould meet the 4'
physical fitness requirements, because it's.not required by H
- O, 5
- the. j ob..
6 The otaer' classical example, controversial 7
example,11s response time.
In the other version of the rule, 8
the earlier draft,'we said'8-minute mile.
.That's been 9
scratched.
10 But it's reasonable to say if an individual is required to respond'to any point'on.the site ip "X" number 11 12 of minutes, this.being a physical' ability, it probably l
13 requires him to run, that that be made a performance objective- '
14
'and that a task be identified for~that, and that you have.
15.
a performance objective that tests that.-
16 Now,.the thing is this could be combined'into.a 17 performance objective that tests several things.
We'll talk 18 about.that.
But it has to be tested somewhere.
19 The knowledge required.
Here again, if there's 20 certain knowledge required, that they can't look up -- they 21 don't have-time to look it up in a manual, they have tolknow 22 it, they have to know a. phone number, they have to know a l
23.
procedure, they.have to have-it there just like that,Lthen
{}
24 there'has to be a task identified and a performance objective
- 25L that tests-this ability..
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Maxt clida, plenza.
2 (Slide.)
~
3 So, we said to meet the requirementslof Appendix 4
B you have to conduct an' analysis to determine what tasks and 5
' duties are required, you essentially-have to identify which 6
duty assignments perform these tasks.
How do you document 7
this?
8 Well, we suggest a way in 0219.
And this 9
includes three summaries:
10 A task identification summary; a task duty 11 summary; and a duty description.
12 I'll talk about each one briefly.
13 Next slide, please.
14
-(Slide.)
15 The first is the task identification summary.
16 We said that you should conduct an analysis to determine what 17 tasks are critical to the implementation of your physical 18 security and contingency plans.
This summary shows that i
19 relationship.
It shows which tasks you believe are critical 20 to the implementation of these plans.
21 Okay.
In the top one we have task number 31 --
j 22 the numbers don't.mean anything -- that says, " communicate 1
23 with a radio."
And I say in this case, and this slide says,
}
24 that it's critical to the implementation of paragraph 1.4.5.C 25-of your physical security plan.
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came from NUREG 0220.
But I'think that mo3t physien1 2
security plans that deal with that information probably_
3 confirm that your personnel will be equipped with a radio, 4
and that implies that they be able to communicate with a O
5 radio.
6 The second example here is " Receive and react to 7
a bomb threat."
In this case, we say that it's associated 8
with event 12 in your contingency plan, and it's obvious 9
that event 12 in this case probably is receipt of a bomb 10 threat.
11 When I say receive and react to a bomb threat, by 12 the way, this is a task, and your performance objective 13 should test how they'll do that.
And it should be in
(
accordance, here again, with your physical security plan.
14 is
-so, this first summary shows the relationship 16 to-physical security plans, contingency plans, and tasks, 17 and essentially it's a check to make sure that all the 18 critical tasks have been identified.
19 Next slide, please.
20 (Slide.)
21 I'm going to have to walk over here, I think, and 22 point this out, but let me talk abo.ut it just a little bit.
23 We said that you qualify personnel to perform 24 duties.
You do this by making sure that they can-perform 25 the tasks.
So there has to be some way to show relationship cAce 9ederaf c. Reporters, Onc 444 NORTH CAPITOL STREET W A S HI N GTO N, D.C.
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between tasks and duties, and we felt that a matrix was the-2 ideal way'to do this.
3
'!k) let'me just walk over here quickly.
4' In this case here e have the CAS operator, and k,,
5
-we have a' pat si cuard, and we have a task which says, c.
" Investigate a suspicious person or event."
7 Well,.we don't expect that the CAS operator, when 8
performing the duty of a CAS operator, would have to perform 9
that task.
So as you gc over the matrix, under "B",
which' 10 corresponds to CAS operator, there's no black dot, which 11 means that is not a task that he'has to be qualified to 12 perform.
But a patrol guard, naturally, in the performance-13 of his duties, will probably have to routinely investigate 14 suspicious persons or events.
Therefore, there is a dot, 15 which means, here again, that he does have to perform.that 16 task.
17 Naturally, the fact that a person may. perform 18 several dutics that encompass the same task doesn't mean 19 they have to be qualified on each task each single time --
l 20 only once.
This shows the relationship.
21 As we stated earlier, some people said that the 22 way we broke the jobs down in 0219 was cumbersome.
It's
.{}
up'to the site'to determine how the duties correspond to 23 24 the requirements of your physical security and contingency 25 plans.
.I identify 13, I believe.
You could identify a l
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significantly smaller number.
But, hora again, if a guy is 2
assigned that particular duty on that particular shif t, then 3
he has to have been qualified to perform all the tasks 4
identified for that duty assignment.
5
.Next slide, please.
6 (Slide. )
7 The final summary to summarize the results of 8
your job analysis is the duty descriptions.
It's just that, 9
it's a summary of all the results of the total job analysis.
to It identifies the duty; it summarizes what this' duty.
11
. encompasses in words, in English, so.they can raad it; it 12 identifies what equipment an individual might be required 13 to use.during this duty assignment -- and this I think is 14 the only place this is shown; it tells what references he 15 might be required to use and, therefore, has to be able to 16 use; what supervision he receives; and what supervision he 17 gives.
And we summarize the task at the bottom..That's 18 not really required.
19 This follows the standard format basically.
indicated in a lot of'the other documents on job analysis, 20 21 and it summarizes in one single place'all the information 22 about what an individual does, and it allows for easy j
l verification of duties with the requirements in the physical
[}
23 24 security and contingency plans.
i 25-Next slide, please.
L 1
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(Slids,)
2
^Now, we've completed'the first step.- We've.done i
3 the job analysis, and we've documented the job analysis,
~4 Now, the second step is to develop a test of these O
5 tasks, and knowledge, skills.and abilities we've identified 6
during the job analysis.
And we use " performance objective;"
7
'The reason we use performance objective is that these are 8
well understood and well documented.
The terms'are all 9
well understood.
You may run across some other terms.
t 10
" Behavioral objective"-is:another one, " terminal _ objective" --
11
'there are several used in the field, but'they all mean-i 12 essentially the same thing.
This is not a performance 13 objective as in the case of'73.55, it's different.
It has l
14 its own meaning in educational development areas.
15 Next slide, please.
16 (Slide.)
17 Now, this objective has to tell us certain things,
)
18 and let's just run through them quickly.
This indicates 19 why we settled on a certain level of detail.
20 (1) It has to contain enough information so that it is a valid test of the knowledge, skill and' ability 21 i
22 required to perform.the task, or that it indicates to the I
l 23 Staff that it is.
j 24 (2) It tells the examinee what standards he or l
25 she has to meet.
Now, this may seem a little strange, this l1 l
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'1 outlining of tocts.
ona would think that tha examinee'-- a-2 l guard on the site, for instance -
wouldn't be given access
.3 to'it.
But these are outlines ofJthe test, they aren't the s
specific tests.themselves.
It should be made available to.
4 5
him, so that he knows what standards he has-to~ maintain'.
6 (3) It tells plant management what standards they 7
have to maintain. 'He can look down and say, "Ah, that's 8
what the particular duty assignments have to perform. That's 9
the level-of quality I have to' maintain.
It defines how 10 I&E is going to have you demonstrate the ability of your 11 personnel to perform their assigned duties.
12 In Appendix B it states that upon request of an 13 authorized. representative of the Nuclear Regulatory Commission 14 the specific site -- I don't know'the exact words -- has to l
15 demonstrate the ability of their security force'to perform 16 their duties.
This is going to be done, as. outlined by your 17 performance objectives.
In other words,' this demonstration-
-p 18 of; ability will be in line with the test outlined in your 19 approved qualification plan.
20 Finally, it has'to provide enough information so 21 that the NRC' reviewer is assured that thisLis a valid, 22 reliable test of.the task knowledge, skill and ability that
~
- 23 were tested..
24 Next slide.
r 25 (Slide.)-
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This ju=t briefly chows the final relationship.
2 We go all the way through, duties, tasks, elements, and 3
finally we have performance objective.
4 Next slide.
5 (Slide.)
6 Now, performance objective has to have two 7
qualities -- very important:
8 (1) It has to be a valid test.
In other words, 9-it has to be really a test of what we're testing.
Now, to to do this, there are three different ways -- I know of three, 11 there may be more -- of developing valid tests.
12 It seems to us that the.most practical method is 13 to make the performance objective a mini-sample of the task.
()
14 knowledge, skill and ability being tested.
15 The example being given by EEOC in their guidelines 16 is if the task being tested is typing skill, a valid test of 17 typing skill is a typing test.
18 So it has to provide sufficient information so 19 that we can see that it is a valid test.
Here again, we're" 20 not asking for as detailed information as.EEOC might.
And to 21 do this, what do you do?
You do two things:
You control the conditions, you make the 22 conditions at the time of the test similar, or simulate, those
}
23 24 of the task that'.s being performed, and you set some 25 standard that corresponds to what will be required for cAce 9edesaf cRepsteu, Snc add NORTH CAPITOL STREET WASHINGTON. D.C.
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1 successful performance.in a real situation.
2 By mini-sample, though, if it's purely a mental 3
task, for instance, knowing what to do, for instance, and 4
- then going on to another procedure, this probably could be 7-)/
\\_
5 tested by a written test.
So you have to take a look at 6
these, when we talk about mini-samples.
And 0219 discusses 7
this.
I'm not going to get into it.
8-The next thing is it has to be reliable, a 9
reliable test.
Everybody should be tested the same way, to 10 the same standards.
11 So, the test, here a;cin, has to contain two 12 pieces of information:
the conditions at the time of the 13 test, so everybody is tested the same way; and the standards, O
14 so that everybody is tested to the same level.
15 Next slide, please.
16 (Slide.)
17 okay.
We said the' conditions of the performance 18 objective tells the conditions at the time of the test.
19 These conditions should reflect those on the job at the time the task will be required, as practical.
We realize you 20 can't control all the conditions, but within limits those 21 that can be controlled to test realism should be controlled.
22 These conditions should reflect the worst 23 conditions under which the individual has to respond, also.
24 25 We also control conditions so that, here again, cNce. 9edezal cReposten, Onc 444 NORTH C APITot. STREET W ASHINGTON, D.C.
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1-you have test. reliability.
We'have test validity and wa 2
have test reliability.
Everybody,'here again, is tested 3
under the same conditions, in the same way.
4 Next slide, please.
.O 5
(Slide.)
6 Now, this is a simple example of what we'mean by 7
a' conditions statement.
This is the first time we've 8
actually seen the performance objective, so I'll walk through 9
the whole thing quickly.
10 At the top we have the task that we're testing, 11 which is, "Use and calibrate a hand-held metal detector."
12 Underneath that I've identified three elements, 13 or knowledge, skills and abilities, that I think are required:
14 Know the procedure for calibrating a hand-held metal' detector; 15 use a hand-held metal detector; know the procedures to be 16 followed if unauthorized material is found.
If you're 17 using it and find something, it's logical that the guy has 18 to know what to do then.
19 Now, this performance objective tests the final 20 two elements.
It's all right to lump them tocether.
You can 21 test as many as you want at one time, as long as it's reasonable that the individual doing the testing, observing 22 23 the individual perform, can observe all these various things
(}
24 that you're testing.
If you lump too many of them together, 25 stuff is going to start falling out.
You're not going to be cAce 9edera( cRepsten, One 444 NORTH CAPITOL STREET k
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able to obssrve it, or if somnthing.movas too feet that you 4
2 can't observe it, that's-the. criteria there.-
3 In this' case we~ say the performance objective is:
4 and the conditions statement generally starts with the word
.O
'5 "Given."
This is standard stuff throughout the educational 6
development field, and.I have it highlighted:
7 "Given an exercise with the plant hand-held-8-
meta 1' detector..." --
9 in other words, you're giving'him the-hand-held metal 10 detector he uses every day --
11
... an individual..." --
12 this is someone pretending to be'an adversary --
13
...with 2 hidden metal objects of the size described-()
14 -
in the NRC Review Guidelines, 15 in other words, the individual is' coming up, he's got two 16 hidden metal' objects as described-in that guideline.
You 17 could say as described in your site procedures.
'That-18 explicitly. tells what these things.are going to be.
'So, you 19' know, you can say site procedures.
So now we have an exercise.
It's going to.be a 20 21 practical exercise.
The guy is going to be tested.by having 22 him~use the metal detector to. find these' objects.
i 23 This might be a point to indicate that in a lot 24 of cases you might be able'to test your individuals while
'25 they're actually performing their day-to-day functions, as
~
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1:
long'ca thsy ara.tactcd'to tha standardo no dsfin d'in the 2
performance objectives:under the.same conditions as in your 3
" performance objectives.
4 An example is that you may, as part of your O
5 procedures, conduct a radio check with local law enforcement 6'
one,every day, or once every two days -- whatever, and-yet 7
you may have a task that says_that.the CAS operator has to 8
be'able to contact the-local law'-enforcement to a certain 9
standard.
This could be demonstrated by this day-to-day 10-performance of his duties.
It doesn't have to be a. separate 11 test.-
12 For that matter, when you think about it, the 13 ideal mini-sample of a guy performing his -.or a girl --
performingaspe$ifictask,istheactualon-the-job 14 15 performance of the task.
How more valid a test could you 16 have, if he actually does it correctly on the job?
But 17 here again it has to be to the standards and conditions 18 defined in your objectives.
19 Next slide, please.
20 (Slide.)
21 So we see now that having identified and stated 22 the conditions at the time of'the test, now you have to state f 'g 23 the standards that the person _has to achieve when performing U
24 the objective.
25 These should be minimal levels.
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- again,-very difficult.
But you should set minimum isvalo.
2 If an individual falls below the performance objective 3
~ criteria, then he-shouldn't be' considered as qualified to 4
perform that task.
5 So-that when you do your aanlysis, set minimum 0
' levels.
7 Next slide, please.
8 (Slide.)
9 Here again, we're back to the same task.~
In this 10 case, the' criteria is highlighted.
The examinee will locate-11-the two objects.
Okay.
It tells you.what he's got to do --
4 12 within one minute.
These are just arbitrary.
This is an 13 example, I stress.
14 "The examinee will also alert the patrol guard..."
15 and I assume your procedures have, for instance, a patrol 16 guard there watching these operations.
But this is just an
/
17 example.
18
"...on accordance with the site procedures..." --
19 so if you have detailed procedures, you'd expect that he'd 20
.do thisnin accordance with~those procedures.
. 21 These minimum levels of criteria should"be 1
1 22-compatible with'the objectives and procedures at your site.
-23
-in your contingency plan, and you're required to have-
)-
24 Performance objectives also for the events -- or objectives 25 for the' events that'you expect to meet.
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So when you set these performance objectives and 2
your tasks, they should be compatible.
And that'll be part
'3 of the review process.
f 4
Next slide, please.
5 (Slide.)
6 So now we've gone through s'an 1, we've done the 7
analysis.
8 Two, we've outlined the-test.
9 Now we have to qualify the people.
10 Next slide.
1.
(Slide.)
12 people are qualified to perform duties.
They're 13 qualified to perform their duties by successfully completing 14 all the performance ob atives associated with those duties.
15 You qualify the people.. In 0219 we say that 16 before we approve your plan we're going to go out and 17 conduct a spot check, or something to that effect, of a
\\
18 certain number of tasks.
i 19 We are not going to do that.
20 We will.do a review to determine whether the 1
21 tasks are appropriate that you've identified, and whether we l
22 think these are valid, reliable tests of those tasks.
i 23 But the qualification will be performed by you.
({}
24 You-qualify the individual to perform his duties by having 25 him successfully perform all the objectives that are c0cc 9edera( cRepsteu, One.
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acsociatsd with tha tacks.
2 0219 also states that: the records... -- well, 3
here's an example.of the typeLof records that we suggest 4
that you keep.
O..
5 It states the task, the date that the~ associated 6
performance objectives were demonstrated, die cignature of 7
the examinee, and the signature of the examiner.
8 An'the rule states, this has to be demonstrated 9
to the security shift supervisor.
Well,. it could also be 10 demonstrated to his authorized representative, because-some i
ti.
may have separate training staffs, an'd such.
12 0219 states, I think, that you should' keep a 13 record-for every performance. objective.
That's not required.
14 Just list the task and.the date that all the performance i
15 objectives associated with that task were demonstrated.
16 Here again, holding down the amour.t of paperwork.
But-it 17 also gives the assurance that the guy has successfully 18 demonstrated al1~the performance objectives associated with
.l 19 the task.
20 Something I think needs to be highlighted, 0219 I
21 states that.you are not required to. keep all the detailed d
~
22 paperwork that might be used in testing.
Example:
If you q
1
- 23 give-a guy a written test, you don't'have to keep on site 24 the completed written' test..Your performance objective' 1
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.certain requirements.
Keep one copy of it, of the test 2
given.
But you don't have to keep his completed test.
Just 3
keep a copy so that we can see -- or I&E can go out and 4
check to see if the. test materials are compatible with the 5
performance objectives.
6 But if you give this test to'30 people, you do 7
not'have to keep all 30 tests.
8 In'this record you basically sign off'that he has 9
achieved an acceptable score, as defined in your performance to objective.
And that's your certification that he success-11 fully performed that test.
The actual material used, the 12 test' material,. checklist, rating forms, et cetera, do not 13 have to be maintained for every individual, every piece of 14 paper that was developed during the performance.
But keep 15 a copy so that we can see that they are compatible with the 16 objectives, with the requirements.
17 Next slide.
18 (Slide.)
' i 19 A well developed qualification program based on 2q
-a good job analysis, good performance objectives, will meet 21 other requirements of Appendix B, in addition to the 22 qualification requirements.
0219 indicates'this.
I'll just 23 walk through them very, very quickly:
)
24 The suitability, educational development require-25 ments.
It states that the person can either have a high cAce 9ederal cAeposten, $nc.
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1 school diploma or have the required -- hava demonstretsd 2
through a practical test -- the required mathematical, 3
language and' reasoning skills required for his' job.
i 4
Well, how can you do that?
How can you determine
..O 5
what these are?
L 6
-You have to conduct an analysis, a job analysis.
)
7 How do you test him?
8 You. test him with performance objectives.
So 9
that can meet that requirement.
10 Physical fitness.
We already talked about this.
11 You identify what the critical physical requirements are for 12 your armed personnel and for your CAS operator, and-you test 13 him.through a performance objective.
Here again,'you test O
14 these.
You define them.
i 15 Next slide, please.
16 (Slide.)
17 Qualification requirements.
Obviously, it meets 18 that requirement.
19 Security knowledge, skills and abilities.
t 20 Appendix B says that you have to qualify personnel, and that 4
21 your qualification program should, I think, consider a list--
22 I think there are a hundred items that are portrayed as
~23 knowledge, skills and abilities.
Don't worry!about it.
)
24 Conduct your analysis.
Determine what is required'at your 25 site.
And it will identify all the knowledge, skills and t
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abilitics requirsd, and they will be ascociated'-- or 2
whatever the term is that's used in the rule.
So don't 3
worry about that list.
You conduct your analysis.
4 Weapons training and weapons requalification.
(}
5 Weapons qualification is no more than another perfornance 6
objective.
It's probably the only performance objective 7
that was ever really identified in the previous rule.
So 8
here-again it's part of the qualification requirenents.
)
9 Next slide.
l 1
10 (Slide.)
11 Now let's talk about training requirements.
12 You determine the method.
What's the' training for?
13 It's to produce people that can do their jobs.. And we've
(~')
14 asked you to demonstrate to us and document how you can 15 determine whether the guy can do the job, or the girl can do 1
16 the job.
l 17 Training plans that contain instructor qualifica-18 tions.
Lesson plans.
Hours of instruction.
These are not 19 required.
It's up to you to determine how to produce these 20 people in the nost cost-effective way.
0 l
21 Just a quick couple of examples:
22 Hiring people who already possess the required 23 knowledge, skills and abilities.
You hire them, you test 24 them, if they're up to par that's it.
25 Somebody -- the first time I heard the term --
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62-1 but "covoying" whnra youlput somsbody who is not qualified 2
' with somebody who; is qualified, and they just go around the 3.
site -- sort of an OJT program -- where the one guy who is 4
qualified always has to accompany.the other individual until i
O 5
his ability is up to par.
6 But you don't need a formalized training program.
)
.7 What we're interested in is the ability of the individual 4
8 to do the job. -It's your job to bring them up to that-9 ability, in the most cost-effective method.
10 A few'words about the training manuals,-because 11 there's a lot of confusion.
12 The reference material, as Ralph Jones said, the 13 type of_ material contained in there -- lesson plans, et
]
14 cetera -- is not required in your plan.
It's designed to.
15 help you, if you have to develop formal training.
l 16 Maybe I should point out, too, that NUREG 0465, 1
17 which talks about transportation security,.is a very 18 interesting document also.
It was based on a performance i
19 or behavioral. objective approach.
It's based on a job 20 analysis.
And a lot of that information is applicable to 21 fixed sites.
1 22 So don't ignore that.
Don't just-get 0464 23 -
because it says fixed' sites.
Take a look at 0465 too.
I
' 24 -
think it has a lot of good'information in it.
25 Next slide, please.
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(Slide.)
j 2~
So, just to summarize, since we're interested in 3
the' ability of the individual to perform'the job, and the 4
job'is to implement the. physical security and contingency 5
plans at your site, this program has to bs site specific.
6 Each site has its'own environmental, securityLphilosophy, 7
legal, physical-layout.
Every site has its own unique set
' i 8
of circumstances.
9 There may be a core of common tasks, but right at 10 this moment we don't know what those would be.
11
.You define the job structure.
12 You set the. qualification. standards.
13 You qualify the individuals.
O.
14 You determine how best to bring the individuals 15 up to those standards.
16 NRR will take a look at the analysis to see if 17 the critical tasks have been identified.
18 We will take a look at the performance objectives 19 and your associated standards to see if we think they're 20 compatible.with your physical security and contingency plans, 21 again.
22 I&E will come out and see if you've developed 23 specific test materials to see, here again, if they are
[}
24 compatible.
25 That's it.
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1 MR. MILLER:
I think th ra era probably some E
2 questions, but I would like to hold them until we get a 3
chance to give you essentially a double-barrel shot.
4 So at this time, Mr. Jack Roe, from the Reactor f
~
5 Safeguards Licensing Branch, will talk about contingency 6
plans.
7 PRESENTATION BY JACK ROF, REACTOR SAFEGUARDS 8
LICENSING BRANCH.
9 MR. ROE:
During this period, I'm going to discuss 10 the contingency planning rule.
I shall discuss the content 11 requirements of the plan, the plan's relationship with guard 12 training and qualification requirements, and the methods of 13 submitting the plan.
I'll po' int out that the contingency plan and (J
14 15 guard training and qualification plan are closely related, 16 and an integrated approach to these plans will result in a 17 substantial reduction in overall effort.
18 Also, I want to point out that much of the infor-19 mation and data required for the contingency planning.
20 requirements is contained in your physical security plan and 21 other security-related documents.
22 The contingency planning rule requires five 23 categories of information in each plan.
These five 24 categories of information are:
25 (Slide.)
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[.
1'
'Bnckground; gan:ric planning baco, licznsco 2'
planning ~ base; responsibility matrix; and procedures.
3 Although the procedures are the culmination of-4 the safeguards contingency planning process, an important j
5 part of the plan', they should not be submitted to'the.
6
' Commission for approval.
The procedures will be inspected 7
by the NRC Staff'on a periodic basis at.the site.
8 This periodic _ inspection will affirm that.the 9
procedures reflect the information contained in the to responsibility matrix.-
It (Slide.)
12_
The first category of information is the background 13 section.
This section identifies and' defines the potential.
O dangers and incidenes, ane describes the eenera1 ways the 14 P an will deal with them.
l 15 16 The. background section will have at least four 17 topics:
18 Perceived _ danger;! purpose of the plant scope of 19 the plan; and definitions.
20 The. perceived danger is a statement of the
~
21 Perceived danger to the security of special nuclear material, 22 licensee personnel, and licensee property.
23 The statement contained in 73.55 (a) will suffice.
~
24 Statements of perceived danger less than that-contained in 25
- 73. 55 (a) will not be acceptable.
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j 1 Purpose of the plan.
It's a discussion of the 2
general aims and objectives of the plan.
3 Scope of the plan is a discussion of the types of 4
incidents covered in the plan.
A list of those contingencies 5
covered in.the plan should be placed here.
6 Definitions is a list of terms and their safe-7 guards, meaning used in the plan.
8 The next category of information is the generic' 9
planning base.
10 (Slide.)
11
-This chapter identifies events that signal the 12 start of safeguard contingencies, and identifies the i
13 objectives that-terminate the safeguard contingencies.
In 14 addition to events and contingency objectives, the chapter l
15 should include decision / actions.to be followed when a 16 contingency action develops, and the chapter should contain 17 the data required-to.effect'these decision / actions.
18 The objective of the contingency' event should to satisfy the licensee's goal to effectively satisfy the_
~
- (
20 contingency.. incident.
Each objective should be achievable, 21 clearly identified and measurable.
22 (Slide.)
Q
'23 The next. category of information is the licensee G
24 planning' base.
This chapter contains site-specific informa-J23-tion used in. actual contingency planning.
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topics.should be included:
I 2
Organizational structure; physical layout; 3.
safeguards systems hardware; law enforcement assistance; g3 policy constraints and assumptions; and administrative and 4
\\.)
5 logistical considerations.
6 Your present physical security plan that's under 7
review may contain much of this information.
8 Let me discuss each one of these topics:
9 Organizational structure:
This should delineate to the organization, the chain of command, and the delegation 11 of authority of the security organization, and the minimum 12 strength at all times.
13 Physical layout should describe the site and the 14 nearby features.
Particular emphasis should be placed on 15 law enforcement entry routes, location of control points, 16 and actual location of safeguards hardware.
17 Safeguards systems hardware should describe all 18 equipment available for safeguard contingencies.
This topic ig should address at least communication, intrusion detection,
~
/
20 surveillance, locks, weapons and vehicles.
~
21 Law enforcement assistance.
This section should 22 list each separate law enforcement agency that may provide 23 assistance.
This section should provide a description of
[}
24 their response capabilities and'a discussion of your working 25 relationship and working plan with them.-
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1 Policy constraints and assumptions should discuss 2
state laws, local ordinances and company policies and 1
3 practices that may govern response to safeguards contingen-4 cies.
This section may address such topics as the use of U,,
5 deadly force and jurisdictional boundaries.
6 Administrative and logistical considerations.
7 This section should describe your practices that may influ-
. 8 ence response to safeguard contingencies.
This section 9
should highlight the procedures to keep all safeguards 10 hardware operable, and the method employed to assure that 11 all security personnel _are current with the present plan, 12 the present procedures and'the present situation at the site-l 13 and surrounding the site.
14 (Slide.)
15 The next category of information is the responsi-16 bility matrix.
This section should be an array of informa-17 tion for each safeguards event.
Each array should identify 18 the responsible individual and their decision / actions.
The 19 array should display on a single chart or group of charts
/
20 for each event all decision / actions and the person respons-21 ible to conduct them.
22 The responsibility matrix should provide an i
(")
23 overall picture of the response actions and their inter-U 24 relationships.
25 The last category is procedures.
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.1 The procaduras should provide clear.and concise 2
direction for the execution of the responsibility matrix.
3 The responsibility matrix may meet the requirement for some 4
procedures, and this should be stated in the procedures
.O-5-
section.
Again, the procedures shall.not be' submitted with 6
the plan.
t 7'
(Slide.)
6 Now I.will' explain the basic relationship g
between the contingency plan and.the guard training and to qualification plan.
11 As was discussed in the section on training and 12 qualification,: security personnel mus't be trained'and 13 qualified to perform critical security tasks.
Thecontingebeyplanidentifies.potentialevents 34 15 that must be planned for.
These events require the 16 execution of certain decision / actions to meet the objectives 17 of the safeguards contingency, and therefore terminate it.
18 The events for the' safeguard contingency are the 19 same events to be considered in' contingency-related guard C
20 training.
21 The decision / actions are the tasks.
22 The objectives-of the contingency relate directly 23 to qualification objectives.
/])-
24' Responsibility matrix is directly related'to the 25 duty summary section.
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- contingency plans require-the: identification of 2
events,~ decision / actions, and objectivest and;the training 3.
and qualification' plan prepares guards to resolve the 4
incidents that we have planned for.-
Therefore, one set of 5
events, tasks and-objectives can be developed to meet both 6
the contingency and the contingency-related guard qualifica-7
. tion requirements.,
-8 (Slide.)
9 Now'I'll discuss several sections of'the contin-i 10 gency plan requirements.
11 The contingency plan rule requires that the plan 12 identify those events that will be used for' signalling the 13 beginning or activation of the safeguards' contingency.
These O
\\
14 events are the same as the cues that will be mentioned in
~
1 f
15 training and qualification requirements.-
16 The event, or cue,'is what the individual sees, 17 hears, reads or perceives, that; signals him that a threat 3
a-18 to'the site exists.
19 In cases where the response is the same for 20 several different events or. cues, all the events or cues 21 should be grouped'under.the single event or event"descriptien,-
22' Care mustlbe.taken to select an event' description that:
( )~
23 indicates what events are covered.
Every attempt should be 24 made to reduce to a minimum the number of event categories 25 covered by different responses.
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It's pointed out'in the document NUREG 0219 that 2
recognition of and proper reaction to certain events or cues
-3 can be critical.
For example, recognition of an intrusion 4
can be very important to your site. security.
Therefore, the
-3 5
recognition and reaction to critical cues identified in 6
contingency plans should be tested as part of your qualifica-
?
tion requirements.
8 (Slide.)
.i 9
The rule requires that decision / actions and 10 supporting information needed to bring about a successful 11 response be identified.
These decision / actions are the 12 critical tasks that are performed when. dealing with the 13 safeguards contingency.
Therefore, the decision / actions 14 and the contingencyrrelated tasks and uhe training qualifica-15 tion plan should be the same, although some minor differences i
16 in format may be required since the task statement does not 17 indicate what will be done.
18 The Staff feels that decision / actions or tasks 19 should be straightforward.
It's unlikely that guards will N
20 be able to have available detailed written procedures during 21 a fast breaking emergency.
22 There are two types of decision / actions or tasks.
23 Some can be performed successfully even if the individual
)
- {])
24 takes the time to look up and follow a detailed written.
q 25 procedure, while others cannot and will require immediate cAce-9edera( c.Reporteu, Sne 444 NOMTH CAPITOL STREET WASHINGTON. D.C.
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72 1
action based on training.
Therefore, time delay. tolerance.
2 should be taken into consideration when developing contin-3 gency procedures and performance objectives used'for 4
personnel qualification.
5 (Slide.)
6 6
The contingency plan rule requires definition of 7
the specific objectivesto be accomplished relative to each 8
event.
These objectives are indicators of the' site's 9
ability to. respond successfully to events.
10 For example, it would be impossible for.a site 11 to test its ability to respond to an actual attack.
- However, 12 demonstratable objectives could be set that indicate that 13 the site can repel an attack, such as response time-to any 14 point on the site or the time required to request offsite 15 assistance.
16 The objectives, therefore, shcM a be demonstrate-17 able, achievable, measurable, and an indicator of the site's 18 ability to react to annevent.
19 This rule'also requires,Jas part of the audit 20 procedures, that test of safeguards systems be performed-21
. yearly.
The contingency objectives will set the. acceptable-22 level of performance for these drills or tests.
They define
/"%
23 what must be demonstrated to pass the drill.
O 24 (Slide.)
25 -
Please note that at 7340, that requires an audit c:Oce 9edesa( cReportcu, Anc d44 NORTH CAPITOL STREET
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73
[
1 and. test of the contingancy plan, it states that.-- quotor 2~
"The licensee shall provide for the development, 3
revision, implementation, and maintenance of a safe-guards contingency plan.
The licensee shall. provide 4
.O-5 for a review at least every.12 months of th'e safeguards 6
contingency plan by individuals independent of both 7
security program management and' personnel who have 8
direct responsibility for implementation ofithe 1
9 security program.
The review shall include a review to and audit of safeguard contingency procedures and 11 practices, an audit of the security system testing 12 and maintenance program, and a test of the safeguards 13
~ system, along with commitments established for response
-( )
14 by local law' enforcement authorities.
Results of the 15 review and audit, along with recommendations for 16 improvement, shall be documented, reported to the 17 licensee's corporate plant management, and.kept avail-18 able at the plant for inspection for a period of two 19 years."
20 As was discussed, the qualification plan requires 21 that for.each critical. security ~ task-Jperformed that a l
22 performance objective be established to test the ability-of r'
23 the individual to perform these tasks.
As we have seen,-the a
.l 24 contingency plan requires that objectives be established to-25
' test'the ability of the site to respond'to events.
The site's I
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- response is no more tduus the correct performance of decision /
2 actions or' tasks by responsible individuals.
It is obvious, 3
therefore, that the qualification plan performance objective 4
and the contingency plan objective must be compatible, and 5
in many cases will be the same.
6 If the objectives are the same and meet the 7
requirements for qualification performance objectives, 8
correct performance can be demonstrated at the same time as 9
contingency plan testing during a yearly drill or test 10 required by the contingency planning rule.
11 (Slide.)
12 The-rule requires that for each event a tabulation j
13 shall be made for each response entity or duty assignment 14 depicting the assignment and the responsibility for all 15 decision / actions --'which are tasks.-- to be taken in 16 response to an initiating event.
17 This is a chart that shows how each event, which 18 indicates the duty assignment, performs that critical-19 contingency task.
Its counterpart in the training and s
s 20 qualification plan is the duty summary, which shows what 21.
duty performs what task.
22 The. duty' summary and responsibility matrix will (v')
23 be checked during our review for consistency.
The 24 responsibility matrix should contain the same decision / actions 25 identified in the generic planning base.
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l
-l 1
Ac-wa heva nircady-statad, cvery.a 2mpt should b3 2
madeLto keep'the different responses and' tasks to a minimum.
3
'(Slide.)
4 There are basically three approaches to' submittal 5
of your contingency plan.
These are:
6 A self-containe'd plan; a plan that references 7
your physical security plan; and a plan that basically B
rev!.nes your physical security plan.
9 The first approach is to submit a. contingency 10 plan that is self contained.
It does not-reference any 11 other documents, such as your physical security plan.
This 12 plan'would include the five categories of information 13 required by the rule.
()
14 (Slide.)
15 A second method of meeting the contingency is plan requirements is suggested by the rule itself,-and it' 17 states:
18 "To the extent-that the topics are treated in 19 adequate detail in the licensee's approved physical 20 security plan, they may be incorporated by cross-21 reference to that plan."
22 This approach will require the contingency plan 23 '
to be prepared as outlined in Appendix C and Regulatory 24 Guide 0554, but allows referencing the physical security 25 plan in the licensee planning base section.
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1 If this approach is follow:d, en'cxt:nsiva 2
revision to Chapter VIII of your approved physical security 3
plan will be required to make it compatible with the 4
contingency plan.
5 (Slide.)
6' The third approach is to revise the physical 7
security plan itself.
This requires rewriting Chapter 8 of 8
the physical security plan to follow the format shown in 9
Regulatory Guide 0554, and to include the background, the 10 generic planning base, and responsibility matrix information 11 required by the rule.
12 The information required from the licensee 13 planning base will be incorporated with the plan by revisions
(
and additions to the appropriate sections of the existing.
14 15 plan.
i 16 (Slide.)
17 This is a summary of what I have discussed is concerning contingency planning, and shows the topics that.
19 I have covered.
20 This is the end of the morning session.
Ne 21 will now adjourn for lunch, and we request that everybody return at 1:00 o' clock and we will continue the "~~ tram at 22 23 that time.
}
24 (Whereupon, at 11:25 a.m.,
the meeting u
25 recessed, to reconvene at 1: 00 p.:.t., this same day.)
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(1:00 p.m.)
3
. MR. MILLER:
Could we get started again, please?.
4 If we could have your indulgence for just one more 5
moment, before it's really your turn, Mr. Bob Clark, who is 6
Chief of the-Reactor Safeguards Licensing Branch, would like 7
to say a few words about schedules and reviews, both from 8
your point and somewhat from our point.
9 PRESENTATION BY ROBERT CLARK, CHIEF, RFACTOR 10 SAFEGUARDS LICENSING BRANCH.
11 MR. CLARK:
Thanks, Jim.
12 To begin this discussion, let me express my 13 appreciation for the cooperation that we have received-in q'
l/
14 the review of your physical security plans, and I think it 15 needs to be said that we're not here today trying to point 16 out to you that we're starting all over again.
17 I hope that you've got the message that what 18 we're doing now is a review process, not a new process.
We 19 realize that your contingency plans are contained at this 20 point in time as a section of your physical security plan.
21 We also recognize that there are commitments to training 22 your security organization personnel in your security plan.
23 So you should be aware of the fact that we don't believe
)
24 that we're-starting over again, but only that we're adding
' 25 to what we've accomplished to date.
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78
-i 1-(Slide.)
2 In.the brief. time.that I'll speak'to you this 3
afternooncI'm going to discuss the review schedule and in a' l
g<.
4 Every sketchy fasion the review procedures for: both' the f
a 5-contingency plan and training qualification plans, and I'll 6
'alsol touch'upon~ amendment procedures and fees.-
7 Speaking first about the schedule for. contingency 8
Lplans,.just in the way of a reminder to you, the. contingency-i 9
plans.for operating power reactors are due on March 23, 1979, 10' Then the plan'is to be effective.30 days after'NRC tpproval.
11 And we will not approve it until you have all of the 12 capabilities in place described in;your plan, and your 13 procedures are complete and your-personnel have been trained 14 to carry out their responsibilities as stated in your.
l 15 responsibility matrix.
16 Now,.there are' questions.which arise as relate 17 to these plans for plants who are applying for construction 18 permits and th'me who may be submitting their ?SAR's in y
19 the completion process for their operating license.
)
20 Let me just speak a minute about some guidance 21
.that we might provide to you for those of you who have 22' plants in this stage of completion.
For those who are
-23 going to be submitting applications.for construction permits,
- 24 we'would expect 1to be submitted with the PSAR, the preliminary:
~
.2c safety, analysis report, an outline of your contingency plan cAcc. 9edesa( cAeporters, Onc.
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79-1 and.a commitmeht to developing:it.in accordance with the 2
- guidance.given-in Appendix C;to meet.those-objectives.
And-3
.this should beLaubmitted'with your application, of. course.
4 For those'of you who have operating licenses or O.
5 are' planning to. submit requests for operating licenses, if-i L6 the FSAR -- and I use.that term FSAR to mean-security plan, 7
I think you understand that;--Jthe security plan, although
~
8 it's submitted separately, is withheld from public disclosure, 9
is ' a part of that total package. - So those'of.you who have 10 submitted your FSAR pri'or 's the effective date of this 11 regulation, which was June 6, 1978, you should= plan to 12 submit your contingency plan-on the date scheduled, March 13 23, 1979.
O' 14 If your.FSAR is submitted'after the effective-15 date, but before March-23, 1979, your contingency plan 16 should be submitted by March 23, 1979 or 180 days. prior to-17 fuel loading, whichever is later.
18 Lastly, those who will be submitted FSAR's after 19 March 23, 1979, your contingency plan should be submitted 20 with your FSAR or security plan.
21 I guess just one word as relates to the schedule 22 for the NRC's review of these plans.
23 (Slide.)
I
{])
24 Certainly we're getting ready now to conduct that 25 review, and we will be doing it with personnel who have cAce. 9ederal cReposten, Onc add NORTH CAPITOL STREET '
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80 1-become familiar with your security plans of your sites by-2' virtue of the review of the 73.55-physical security' plans.
3 We plan to approach this review in much the same way-that 4
we have done the 73.55 review, and I'll be speaking about~
5 these procedures just briefly in a moment.
6 But lot me just comment that it's-difficult at 7
this point in time to put firm dates -- month or year -- as 8
to when we will be able to complete the contingency plan 9
reviews.
10 We will proceed with them as quickly as we can, 11 and it's my hope that this will adapt itself to about a 12 six-month process.
I have a great deal of optimism in that, 13 from the-standpoint that this does not h11ow for many.
0 14 iterations and if your plan is not complete, and~we have to 15 go back and forth with the question-and-answer process, it'll 16 take us at least a year.
17 All right.
Speaking now of the review process 18 for the guard training, review. schedule for guard training 19 plans, the training and qualification plans are due on 20 August 18, 1979.
The training and qualification plan shall 21 be followed by the licensee no later than 60 days after NRC 22 approval.
1
(])
23-The training and qualification plan shall 24
- include a-schedule to show how security personnel will be 25-qualified within two years after the plan is approved.
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For those of.'you-who will be applying for 2
construction permits and operating licenses, let me suggest 3
this guidance, which-isinot found in the regulation, but we 4
feel that.for an~ application for a construction permit you 5-should provide with the PSAR an outline of your training 6
- program and aLcommitment to the objectives of Appendix B.
7 And you should submit this with your application.
B For an operating license, if the'FSAR was sub-9 mitted prior to the effective date of the rule, October 23, 10 1978, your plans will'be due August 18, 1979.
.And, of 11 course, 60 days after the NRC approval and the two-year 12 training period will apply to these applicants.
13 For an operating license applicant who submits-O 14 his FSAR after October 23, 1978, but prior to August 18, 1979,
.15 your training plan should be submitted by August 18, 1979, 16 or 300 days prior to fuel loading, whichever is later.
We 17 feel.that for this particular case you should plan to have 18 all your personnel trained in accordance with the plan 18 19 months after you receive NRC approval of your plan.
20 For applications submitted after August 18, 1979,'
21 the training plan should be submitted with the FSAR, and 22 your personnel should be trained prior to fuel loading.
Q 23 (Slide.)-
24 Now, speaking about our review procedures,.I
- 25 mentioned it briefly in suggesting to you the type of cAce-9ederaf cReporteu, Dnc.
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1 cch duls we etn forcona at this point in tima, in'the rcview i
2 procedure we will be looking at the. events that you 3
described in your plan, your objectives.
We'll also be 4-interested in theLdecision/ actions that you included in your rT-
-g 5
responsibility matrix.
We will also-be examining again the r
6 licensee planning base,'your responsibility matrix and the 7
Office of Inspection and Enforcement will visit'your site 1
8 to review.the procedures that you have prepared that are l
9 associated with your contingency plan.
10 Now, ideally, our familiarity that we have gained 11 in doing the review of your physical security plan might not l
12 make it necessary for.us to visit the site during this I
l 13 review.
However' if the reviewer feels that in order to l
()
establish the consistency of your plan with your physical 14 15 security plan and your site, he will' elect that option of 16 going to your site again, reviewing things at the site with 17 you.
18 Now, it's important in these reviews, as I 19 mentioned in my d'.stroductory remarks, that we look for l
t 20 consistency be'. ween the physical security plan and the 21 contingency plan.
And we think that that will fall 22 naturally, but we're going to be looking for that in our
' 23 review.
24 (Slide.)
25 In reviewing the training and qualification plans, cAce-9ederaf cRepsteu, Dnc dad NORTH C APITOL STREET l
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83 1'
Tom mention d moct of thm_crece that we're going to be 2
focusing on, but let me just remind you that we again'will 3
be looking at the tasks and elements that you have described,-
4 we will look at your. duty descriptions, and we'll be h
5 especially interested in tne performance objective that you 6
have identified.
7 We Will'be looking at the list of equipment that
'you're going to qualify your personnel, and their use of 8
9 that equipment at your site.
s 10 Again, there will be a need for the office of 11 Inspection and Enforcement to visit your site to review the 12 test material that you have prepared, which should be kept 13 at the site.
Also, we will expect them to inform us that
)
you have all this information in effect before we give our 14 15 final-approval to your plan.
16 (Slide.)
17 Let's go on now to the amendment procedures.
18 I'm not going to take long on this, because you're familiar 19 with it.
20 But we will try to resolve all issues so that we j
i 21 will make the finding that your plan is in. compliance with 22 the regulations.
There may be site-specific areas where
-23 there have to be judgments made as to compensating features 24 or equivalent, and we're prepared to make those judgments.
25 We will need your assistance in arriving at some of these i
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84 1
conclusions.
2 However, if there become areas where we feel that 3
we should require you to do certain things that you have not
(~}
4 committed to in your plan, we will identify those things for L;
5 you and you will have the right to appeal them to the 6
management of NRC.
7 If, however, following the appeal process, it is 8
still determined that these requirements should be placed 9
upon the licensee, we will do that in the process of to amending -- conditioning your license with these appropriate 11 requirements.
12 Now, there are certain things which are described 13 in 50.54 P of the regulation which relate to changes that
( ')
'~
14 can be made, if you determine that they do not reduce the 15 level of protection at your site.
Certainly if you're 16 augmenting the system that you have proposed, and are 17 upgrading it, this cannot be interpreted as being a is lessening of the degree of protection you're providing.
19 And, as you know, you're able to make that determination and then not request our approval but simply notify us within 20 21 60 days that you've made this change.
22 This applies to the contingency plans and to the
( ))
23 physical security plan.
24 of course, once your plan becomes a part of 25 your license, and you wish to make a significant change that cAce 9edeza( cReportcu,.Onc.
444 NORTH CAPITOL STREET W A S HIN G TO N, D.C.
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85 1.
rsquires our cpproval, th;n wn hnva to go threugh the 1
2 procedures prescribed in 5090, 5091 of the regulations.
3 (Slide.)
I l
4 Let's-talk just a moment, in conclusion,.about i
5 fees.
All f the submittals that you have made to us 6
based upon 73.55 have been submittad without fee, and this 7
8 is in accordance with the date of' publication of the new g
regulation on fees.
10 However, the contingency plans and the guard l
training and qualification plans to represent amendments 11 which require NRC review and approval, and when you submit 12 i
those to us you should provide a proposed determination of 33 O
the amendmene c1 ass and state the sasis therefer as a pare s
of the amendment request.
33 Also, you should submit with your application the 16 fee associated with that particular class of amendment.
17 3g Now, we will evaluate your proposed amendment class determination and will inform you if a reclassification 39 is required.
20 I guess that, to help you, our thinking on the 21 Staff is that these two submittals will fall in the 22 category of Class 3 amendments, and we would suggest to you
(~
-23 that in making your determination you give that some 24 consideration.
Our understanding, in talking with our legal j
25 cAcc.9ederaf cRepotten, Snc 444 NORTH CAPITOL STREET W ASHINGTON. D.C.
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86 Paople, in that wa rcquiro two r:quasta upon your part for
~
1 amendments; one for-the contingency plan, another for the 2
training plan. 'These will be two submittals,'and you will 3
-have to submit also your. fees with these submittals.
4 O
With that, I will conclude and thank you for 5
6 -
y ur. assistance, and we'd like to give you our pledge that t
during the coming' reviews we'd-like to continue to work 7
closely with you in order that we might-meet our mutual' g_
objective of providing the appropriate protection for your 9
Plants.
10 MR. MILLER: : Ladies and ger:tlemen, it's now your 11 turn.
12 I would remind you again to please identify 33 O
yourse1ves.and your aff111ation so that it can se put inte the record.
15 There was a question here that I cut off earlier.
16 m
Would you like to start?
g
.. ~,,
MR. SAUNDERS:
Barry Saunders, Commonwealth 18 Edison, Dresden.
3g In referen e to Mr. McKenna's statement on guard 20 f rce qualification tests themselves, I wanted to be 21 absolutely clear that'you are not requiring the actual 22 test, but only the cover sheet-stating that that test has Q
23 been administered and this person scored such and such.
24 25-MR. MC KENNA:
Well, 0219 addresses this, but CfCTlClio 01Ce CC*
C CT42 444 NORTH CAPITOL STREET WASHINGTON. D.C. ' 30001
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_-...J20t} S47 8%,,,
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what wa're neying is that, yes -.tha antwsr'is yas -- that 1
2 you certify in the record that the person has. met the 3
performance objectives associated with that task, and the 4
'date that they were met.
ThatLmay involve a. written test, 5
it may. involve some sort of simulation which unes, for 6
instance, a checklist.
7 We do ask, though, that you keep a copy of the.
8 test or the checklist at the site so that we can go determine 9
whether -- in this case I&E can determine whether -- it is 10 compatible with the performance objective as stated.
In 11 other words, the test really is compatible.
12 In other words, if the performance objective says--
13 and this is a point that wasn't made clear before. In your
()
performance objective you'should provide sufficient informa-14 35 tion to give the reviewer an indication of what the person 16 has to do to pass...But you don't need all the details.
17 For instance, it could be a written test that requires --
18 and you could summarize it, such as that it will demonstrate 19 the following things in the written test.
20 But the actual written test that the guy completes, 21 the person completes, does not have to be maintained.
But 22 a copy of it should be on site so that we can check it to r3 23 see if it's compatible.
So if 30 people took the test, you j
(>
24 need one copy, blank, so that we can see it.
25 But you're certifying that he successfully passed cAce 9edezaf cReportets, Anc 444 NORTH CAPITOL STREET WASHINGTON. D.C.
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I 88 1
that test in your records.
2 MR.'MAYER:
Lee Mayer, Northern States Power.
3 I'd like to ask for at least us, and any other 4
licensees that are interested,'that we be given a copy of O
5 the legal opinion which imposes a fee on these.
6' As I recall reading 5054, it says that you have 7
to submit a license amendment if you are submitting something a
which would decrease the effectiveness of your security g
program.
And certainly submitting a contingency plan and 0
to a training plan are increasing the effectiveness, and 11 wouldn't require a license amendment.
12 None of us have anything in our license that I 13 know of to date that requires us to have the security plan, 14
. and I don't'think the regulation mentions training and 15 qualification plan.
16 So I, for one, would like to'have a copy of the 17 legal opinion which imposes these fees on this for our u
1e lawyers to study..
19 MR. CLARK:
Well, as I indicated in the presenta-20 tion, you have to make that determination and submit it to i
1 21 us.
22 Our discussion with our licensing branch and the 23 legal people associated made that determination.
I don't
(}
24 know whether it's in writing or not.
However, certainly if l
i 25 you determine that you feel that this is not appropriate, we 1
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]
l
-89 1
then'are obligated to write you back and' explain to you why 2
weLthink reclassification-is necessary.
3.
JMR..MAYER:
Thank you.
4 MR. MILLER:
Let me. throw out a few points.
5:
At the Atlanta meeting we made the offer,.and 6
I'dflike.to make it here, many of you have heard that we 7
are planning workshops which essentially give some detailed 8
instruction on the job-analysis and performance objectives.
9 These are intended to be working-level workshops,-small to groups, 20 people, held in various' areas of the country.
11 If some of you are at-least as lay as I am in-12 this business, I'm sure that a lot of what Tom had to say 13 sort of went over; your heads, or struck at least some chords.
14 I-don't know, if'there interest in a workshop 15 type thing in job analysis?
I don't know any other way to 16 do it than ask for a. showing of hands.-
17 Can I.see the hands of those that would be 18 interested in workshops, who think it's a good idea?
19 (Show of hands.)
20 Okay.
Thank you.
21 Are there any other questions or comments?
22 Larry?
23 MR. BEAN:
Larry Bean, of Commonwealth Edison.
)
24 Mr. Miller, could you comment on the status of the 25 security plan reviews,.and maybe in doing that give us some cAce-9edesaf cReportcu, Linc.
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1 idea of the relationship between Appendix B and Appendix.C, 2
and maybe Part 11, and the status of those reviews?
3 MR. MILLER:
Bob, do you want to -- I think Bob l
4
-r.
would be the best one to answer that.
( '
5 MR. CLARK:
At this point in time, our reviews, j
l 6
as most of you know, on 7355 requirements of the new physical 7
security plan are essentially complete.
We would expect:to l
8 begin issuing the security plan evaluation reports to the 9
licensees'in about 30 days, I guess, give or take a week or 10 so.
11 This represents the first step in the approval 12 process.
Namely, we identify your security plan as being i
13 acceptable and meeting the requirements of the regulation O
14 when fully implemented.
15 The next process, I think -- and I'm'not forgetting 16 the other part you mentioned, Larry, but I'll try and work 17 them in here -- the next step is your notifying NRR and ISE 18 that you now have fully implemented all of the hardwsre, 19 personnel, security organization, and you have those things 20 in place and operable, and they will then make a visit to 21 your site to confirm that these things are in position and 22 operable, and will make a notification to NRR that your
{}
implementation is now complete.
23 24 Following that notification, we will then make 25 a notification to you, and.to the rest of t'he world'in the cAce 9edeza{ cReporteu, Onc '
444 NORTH CAPITOL STREET W ASHINGTO N. D.C.
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'l Federal Register,.that we're' amending your license and will I
i 21
' identify asfa condition of your license the physical. security Lj i
3L plan'as being/the plan that'you should be operating at.your
~
t 4'
siten in other words, your approved physical security plan.
5 As.you know, and Mr. Mayer brought up'in his 6~
question, those licenses that have been issued.that'are.
.s 7
more or,less contemporary with this time all have.that' 8
condition,in'them.
Some of the older. licenses, your 9
security plans,1while approved were never.put in your 10 license as a. condition.
i 11 Now, it is our intent,'and our legal advisors 12 suggested to us,'that'in the future all of these plans will-
/
13 be identified in the license as the approved plan for your O.
14 Esite.
15 Now, Appendix B and, Appendix C reviews.. As I i
16
' indicated-to you, this is a continuation of the review:
17 process for your plan, and you do have in your plan' currently 18 contingency plans and training plans which will have our 19 approval at the end of this process I just discussed, or 20 just mentioned.
21 Now, we are-able to make changes in the plans 22 and identify, along with the physical security plan'that 23 we have reviewed and approved, additions, changes that you
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24 may make or.that-we may feel'are important to make, and 25 '
this, of. course,.is a change which has been required _by our c:Oce 9edetaf cReptieu, Onc.
444 NORTM CAPITOL STREET WASHINGTON. DA 20001
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1 92 1
regulations, and all'of us will'have to abide by those 2
regulations.
3 So'there may be some of you who feel that the 4
section that you wrote on contingency planning is complete 5
and doesn't need~any further augmentation.
We would find 6
that hard to accept at.this point in time, simply because 7
you would not have the complete guidance that's been i
8 prepared for preparing those plans up to this time.
9 So once we have approved your contingency plan, 10 that, at some appropriate time, will be noted as a part of j
11 your security plan package, and also will be associated with 12 that condition in your license.
13 As a separate part,.the development of the guard ks 14 training and qualification program currently is a part of 15 your plan, and we will make that change indicating that the 16 new plan you develop will supplant that which is currently 17 in,your security plan.-
1 7
18 Now, the new Appendix B, Appendix C type review 19 process has included in itua time for implementation 20 following NRC approval, if you've noted that.
And this, I 21 think, is important for you to note.
22 Also important for you to note is that you will
[}
be following those things that are in your physical security 23 24 plan up to that point in time when you make that transition 25 to the new approved plan, which will follow the Appendix B, cAce. 9edera[ cAepottets. Onc.
444 NORTH CAPITOL STREET W A S HIN G TO N, D.C.
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93 1
App;ndix C rcquirrm:nto..
2 Part 11.
I think'Mr. Jones discussed the' status 3
of Part 11 with you briefly'this morning.
Certainly there's 4
nothing that we can do at this point in time until the
.,_s
(-)
5 Commission has made a decision in the way of planning on how 6
we will incorporate that into the review process.
7 I think that the concern here -- if I can put 8
words in your mouth, Larry -- is that if-Part llibecomes.a 9
requirement and it's needed for meeting the performance to objectives of 7355, then some of these other requirements 11 we're making may change in form.
12 At this point in time.we're proceeding as though 13 there were not a clearance rule, and everything that we're 14 doing is based upon existing regulations and not on proposed 15 regulations..
16 I think that's the best I can do at this time, 17 Larry.
Did.I cover-most of the points for you?
18 MR. BEAN:
(Nodding affirmatively.)
19 MR. MILLER:
Yes, sir?
20 MR. GREEN:
Bill Green, with Toledo Edison.
21 our plans are, because we're a multiple-unit 22 facility, we're not revising the training or not revising 23 the contingency planning, but at that point in time revising
{}
24 the industrial security plan to cover the second unit and 25 then the third unit.
Because if they are acceptable, they cAce-9ederal cAepiteu, Snc 444 NORTH C APITOL STREET l
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chould remain ecc:ptablo.
2 Now, those two, I'm asking the timing for the 3
submittal of the revised security plan to address the addition 4
of the other unit.
We will drop a fence-between the two V
5 units and go to a larger perimeter, so the timing for the 6
submittal of that revised plan?
7 MR. CLARK:. Well, of course, before you can load a
fuel you'll have to have our approval of your plan, so that's t
9 one key date.
10 Now, submittal of the plan as it relates to the 11 date that you're going to load fuel, it has to pre-date 12 that long enough for us to do the review process.
13 Now, as you know, I indicated 180 days in one 14 case, and 300 days in another.
And I would say that for a 15 multiple-unit site we're looking at a security plan for the 16 site, for the most part.
There are difficult transitions 17 where you're going from construction of one. facility while 18 you have an operating unit on that site, and we will want 19 to review that very carefully with you.
20 So I would say that you should allow at least 21 300 days prior to your prospective fuel loading date in the 22 second unit for us to review the transition and the 23 incorporation of your second unit into your security plan, 24 What you say is true, if it has been approved for 25 one unit, it'should be acceptable for the second unit on that cOcc 9edera{ cReportcu, Sac 444 NORTH CAPITOL STREET W ASHINGTON D.C.
30001 (202) 347 3700
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.~
~.. _,.
v 95 1
mite.1 2.
MR. GREEN:- I1 realize the. danger of its being a
3 reviewed a second' time.-
4 MR. CLARK:
Well:.
- O.
1 L
5 MR.. GREENS
'I didn't mean there's'a, danger, but
~
6 different' interpretations of the documents sometimes. create 7.
Problems.
'I e
(Laughter.)
Well, we recognize'it both ways. 'And 4
10 we.would say to you that prior to our granting you 'a license' 11 for the.second unit, we're going to have to be satisfied' 12 that there is nothing during this transition period which 13 would lessen the security of the operating plant.
O 1
14 MR. GREENS Thank you.
j 15 MR. MAYER:
Lee Mayer,.again.
Coming from what'.I might call a highly sensitive 16 4
l,,
17 intervenor area of the United States, is there any. intent-18 on first license amendment or future license amendments for
)
.s 19 security plans or contingency' plans, to pre-notice these 20 amendments ~and offer right of public hearing, as happens on 21 slight fuel changes and almost any other license amendment 22 we submit?- The NRC considers.them to.be significant. hazards ~
23 consideration and publishes a pre-notice, and we attract 24 intervenors like flies.
25 MR. CLARK:
I don't think that's going to change
.i cAce. 9edesaf c.Repsteu, $nc.
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I a wholo lot.
Wa'ra going to meet the rcquirementa cf cur 2
noticing regulations, and we'll have to notify the public of 3
our intent in these areas.
And there will be the opportunity- -
4 pre-noticing -- I don't know that that decision has been made 7,
)
uj 5
yet.
6 MR. MAYER:
You don't know right now whether your 7
guidelines on what is pre-noticed and what is not pre-noticed 8
would or would not include the security plan material?
9 MR. CLARK:
I have not discussed this with our 10 legal staff.
33 MR. MILLER:
Any other questions?
12 MR. COOPER:
Skip Cooper, Consumers Power Company.
13 After we have all the things we've been talking 14 about today implemented, does the NRC have anything else 15 on the drawing board that we could straighten out now?
16 MR. MILLER:
NRR doesn't.
I'll let me Jones talk 17 for Standards.
18 MR. JONES :
No.
The only thing we have on the 19 drawing board is the clearance program, which is still on 20 the drawing board.
i 21 You're also aware of the IAEA reporting require-22 ments for the implementation of the President's offer for 23 non-proliferation IAEA inspections.
But that's not going to
(~}
24 be a major effort.
25 That's it, as far as I know, cAce. 9edeta( cAeporters,.Onc.
444 NORTH C APfTOL. STREET W ASHINGTON. D.C. 20001 (202) 347 3700
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' 97 -
11 MR. CLARK : ' Wall,- you'should be cdviced - that there 2
,is:one other rule'that's currently _ proposed and spoken'of 3'
as the, upgrading rule, that'will_have no significanceito 4
the niajority of. you.. In fact, I'think in this area _-- well, 5.
'I guess _there's one exception - 'but for.those few sites 6
where power reactors have strategic special nuclear material'-
.7 on their sites,'this new upgrade rule may have un implica '
s tion'for your site..But;it's very site and reactor' specific.
L 9
MR.-CLARK:'_ Dave Clark,.with the' Indiana &
10 Michigan Power Company.
11 It was stated during the lecture series here:
12 that we.were going to be required to.prov'ide' training to 13
.all of the personnel who were going to stand watch, okay?-
0 14 ind my guestion is If we have someone who omes l
.15,
in who?is not previously trained in security, are we going 16 to have to provide.that p'erson with'an entire training 17 program, which'is going'to last three,or_four weeks, or.
'l 18 whatever, prior to that person. standing any watch?- Because 19
. We are requir'ed -- as we were told'here earlier -- for those 20 people to be trained in all of the procedures associated 21 with that watch, or which all of our procedures and our 22 contingency plans.
23 So are we' going to be allowed to, say, train that' person at one particular watch and put that person on' 24 25 a watch station until we'can implement a training program cAcc.Jedesaf cReposteu, Sac des NORTH CAPITO4. STREKT WASHINGTON D.C.
20001
'(801) 847 3700
98 l
1 of a certain group'siza?
2 MR. MC KENNA:
Well, as we've stated, you qualify 3
people to perform duties.
A duty could be a watch.
So if 4.
you want to structure-it this way, so that you bring someone 5
in, you structure the duty assignment such that he's 6
qualified for it, and that's the way it's documented.
Then 7
that's fine.
Then naturally that's the only duty assignment 8
or watch that he is required to perform, then that's the 9
only one he.has to be qualified to do.
And, therefore, if 10 say you bring him in, bring him up to a certain level -- for 11 instance, to perform searches, and then through this buddy 12 system eventually they're going to be qualified to perform 13 patrols, this is fine.
14
'But they can't perform a particular duty assign-15 ment until they've been qualified for it.
But it's your 16 job to determine what these duty assignments are based on 17 your physical security plans.
.j l
18 But if they are assigned to a watch or a duty 19 assignment, then they have to be qualified to perform all the tasks associated with that duty assignment.
i 20 21 MR. MILLER:
Anything else?
22 MR. BEAN:
Larry Bean, Commonwealth Edison.
23 In the so-called upgrade rules there are proposed 24 changes to 73.2, the addition of a definition of radiological' 25 sabotage, definition of deceit, stealth, and things of'that cAcc. 9edesaf cAeposteu, Sac 444 NORTH CAPITOL STREET W A S HIN GTO N. D.C.
20001 (202) 347 3700
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nature..Those'words, " deceit,. stealth,"'and so'on, are
\\
2
- contained'in the: performance requirements of 73.55..
- )
.3 Is~there intent there that the definition of-4 those words'canLin any way influence or have an effect on l
,O 51 the review of the~ security plan submitted under 73.557-6 IUR. CLARK:. No, there's no intent. -Forithe most 7
part,.we. felt they represented our current practice.
There e
are some differences that relate to fixed. sites.for fuel
'9 cycles, and soLon.-
I 10 MR. BEAN:
The addition of one word in'particular, 11 and I mentioned this in the EEI meeting also, is the 12-
. addition of'the word " shield" in the definition of isolation l
13 zone, the purpose of that addition.
l O
R'.
JONESt-
'I don't know why everyone is looking M
14 i
15 at me..
16 (Laughter.)-
l
,,x 17 MR. BEAN: 'Well,-just to expand'on it a'little I
18 bit, the definition of= isolation zone was that it was an i
19 area.next to a protected area barrier which is specified to l
i 20 remain clear of objects which would conceal --
l 21 MR. JONES:
Oh, the intent of the word " shield" l
22 there is to shield, if you will, the person from being (J
' 23 '
observed, so as not to have something in your isolation zone 24 that would prevent you from observing a person in the h
25 isolation zone.-
That's what the word " shield" means there.
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)
1 Perhaps we could use afdifferent. word.
But the idea there 2
is to avoid having anything in the isolation zone that 3
somebody could hide behind.
~
4 MR. MILLER:
Again, Larry, there is no intent.
5 When we reviewed your physical security plan -- and'for all 6
of you -- we reviewed the isolation zone with that in mind.
7 Anybody else?
8 MR. BEAN:
Could'I ask one more?
9 MR. MILLER:
Sure.
10 MR. BEAN:
There was a statement made
-- I don't 11 recall which presentation I believe it was Mr. Roe --
12.
about -- I think you were quoting from 73.40,.about a. testing 13 of LLEA response.
14 1s that'a proposed change, or is that in the 15 existing regulation?
16 And, secondly, is-the intent there that if'we 17 test a contingency procedure,-'or something. to that effect, i6 to actually have LLEA people respond to the site?
Or is l
w it permitted to verify that they have the capability?
20 MR. ROE:
The quote I made from 73.40 will 21 become effective, and that is a part of the contingency 22 planning rule.
And the drills that we talk about would be
({}
23 drills which show that the LLEA could provide the capability 24_
'that you have taken credit for in physical security planning
- 25 and contingency. planning.
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444 NORTH C APITOL STREET W ASHINGTON. D.C.
20001
f
'101 1
MR.. CLARK ' Let me?just add to that, it's not our 2
intent for you_to involve LLEA in a way that would have them 3
testing their squad cars transit time to your site.
That is 4
not the intent.
It's an' intent for you to.have documented,
.f g 5
'as we have discussed with you before, that there is a j
6 capability with the LLEA to join you in this process, and 7
that.you're satisfied that those things which.he'has stated 8
are within his capabilities.
9 In most cases we've had conversations with LLEA 10 also to. satisfy ourselves that'e agree with your assessment.
w 11 MR. MILLER:
All right.
If there are no more --
12
'MR. MILLER:
Steve Miller, with Detroit Edison.
13 Many of your documents that you produced, and the a
O~^
14 ones that you have listed as being reference documents speak 15 about having qualified instructors.
Ic There is a minor revolution occurring in the 17 training throughout the country regarding the use of 18 individualized instruction.
19 I would like to know if the NRR has taken any 20 position as to the acceptance of individualized instruction 21 for the training of security personnel versus the implied 22 requirement to have qualified lecturers or instructors?
- (')
23 MR. MC KENNA:
I thought we made that clear.
V 24 We are interested in the ability.of the. individuals 25 to be able to perform their jobs.
How this ability is cAce 9edeta( cReporteu, Snc.
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1-
. developed i:s basically tha function'and ranponsibility of 2
the: site.
j 3
-So self-paced instruction, computer-assisted
'I 4
. instruction,.on-the-job-training, as long as'it's carried
,,,g
'O 5
out.in'such a way that no unqualified l individual is perform-6 ing the function, that's the site's responrlbility..
7 So if you' Wanted to use -- I think you're-8 talking about self-paced instruction.in this case -
that's 9
fine.
10' As you noted, in.the one slide we talked about 11 the training program, lesson plans, hours of instruction, 12 qualification of instructors are not required in your plan.
13 We're concerned with identification of the important tasks 14 and how you're going to-test that ability, and'having'them 15 successfully pass.the. test.
16 MR. MILLER:
Thank you.
17 MR. MILLER:
If-there are no more, on behalf of j
18 NRR I would like to thank all of you for coming, and 19 particularly Mr. Keppler and his people for having us all 20 here.
21 I think Mr. Keppler will probably want to end 22 the meeting -- is there.one other question?
23' HMR. COMEY:
This is really a comment, rather than q
)
24 a question.-
25' I'm David Comey, Citizens for A Better Environment.
c: Ace 9eaeta{ CAeportets, $nc.
f 444 NORTH CAPITOL. STREET W ASHINGTON. D.C.
20001 (202) 347 3700
~103 j-1' Bob Clark indicated that a site visit by the 2
reviewer from headquarters was not.necessarily something 3
that they were planning.in.every case.
4 My' comment is that I think that it ought.to'be O.
5 a requirement, and I would urge you to do so.
I'think this 6=
is-an area in which a. reviewer will find that a site visit 7
is extremely helpful,-because there is really no substitute 8
for actually getting out there and taking a hard look at.
9 the specific site.
10 I don't think,a paper' review is sufficient.
11.
MR. CLARK:
I think youLtook me a little out.of 12 context.
13 My statement was made'with the knowledge-that 14 we are using~ reviewers who had previously been to the site, 15 and I say if they want to return to the site that is 16 optional.
17 A site visit will be made in connection with 18 every review.
I agree with you.
19 MR. MILLER:
I think we all agree.
The reviewers 20 that Bob is talking about are the.same individuals who have 21 been.the reviewers for the physical security plans, and I-22 think in most -- well, in all cases, they have been to the.
~
sites.
23 24 MR. ROE:
Yes, at least once.
25 MR. MILLER:
Yes, I was going to say probably cOce Jedeta( cReportets, Sac 444 NORTM CAPtTOL STREET WA$HIN070N. D.C.
3000t
~.
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104
'l two or'thre9 timas.
2-So.we are going out.
What Bob was talking about 3
was if a reviewer for the physical security plan is also 4
going to be the same reviewer for a contingency plan, he f-5 may be familiar enough with the site that he feels he 6
doesn't'have to go back.
7 MR. COOPER:
I'm still concerned, in iew 8
interest of the Justice Department, in the fact that wh...
9 do a review for felony background for individuals we hire 10 utilities are severely hampered by the Freedom of Information 11 Act, in.that we can develop a liaison with local law enforce-12 ment and they will do that locally, but when you hire 13 someone who is not from the local area, and go up in another
{l 14 area, distant local law enforcement, even if they've got a 15 piece of paper in their hand? signed by the individual, they 16 will refuse to release the information.
~
17 And you could have a convicted, arrested, a man 18 who served a term for a major felony, and he could be one 19 of your employees, and you'd have no way of knowing it.
20 MR. MILLER:
I think we share your concern, and 21 this is what Mr. Case talked about this morning.
22 That's one of the reasons why the Staff has been r~s 23-pushing so hard for some type of clearance program, since d
24 the Federal Government, of course, is able to obtain these-25 type records.
Some of us share your concern.
cAce 9ederal cAeporters,.One.
444 NORTH CAPITOL STREET WASHINGTON. D.C.
RC$01 (302) 347 3700 '
105 1
'With that, lat me turn the m sting back over to 2
our host, Jim Keppler.
3 MR. KEPPLER:
Thanks, Jim.
4 I just wanted' to thar.t each and every one of you O
5 for coming.
I hope you found t?e meeting productive..
As I mentioned in my opening remarks, I know that 6
the implementation of these new regulations, new rules, will 7
8-emuire a concerted effort'on both our parts to assure that g
they're properly' implemented.
And'I would like to encourage you to maintain close contact with-the people in my Region 10 and with the people-in the' Office of Nuclear Reactor =
11 Regulation in the implementation of this program,.the 12 various facets of it.
We'll try to be as responsive as 13
()
possible to concerns or issues that are raised.
34 Again, thanks for coming,'and have a safe trip 15 h ***
16 (Whereupon, at.1:55 p.m., the meeting was 37 concluded.)
]
18 g
20 i
21 22 L23 1
24 1
J 25 i
cAce 9edeta( cAeporters, Snc.
444 NOMTH CAPITOL STREET W ASHINGTON. D.C. 20001 (302) 347 8700
-.