ML20148D673
| ML20148D673 | |
| Person / Time | |
|---|---|
| Issue date: | 09/27/1978 |
| From: | James O'Reilly Office of Nuclear Reactor Regulation |
| To: | |
| References | |
| RULE-PR-73 NUDOCS 7811020444 | |
| Download: ML20148D673 (104) | |
Text
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1 N'U CLE A R R E G U L ATO R Y CO MMI S S I O N-l Q'
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l IN THE MATTER OF:
I NRC DISCUSSION WITH NUCLEAR POWER REACTOR 1
LICENSEES CONCERNIWG THE IMPLEMENTATION OF APPENDICES B & C 10-CFR-73
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Place - Atlanta, Georgia i
Date. Wednesday, Septcmber 27, 1978 Pages 1 - 103
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(202)347 3700 t
ACE - FEDERAL REPORTERS,INC.
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OfficialRepor:ers Yb7.1036(fyy 44 t North C: cit:i Street Wcshingt=n, D.C. 20C01 NAT:CNWICE COVERAGE DAILY PR73
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I UllITEDISTATES OF AMERICA'
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.NdCLEAR REGULATORY COMMISSION i h.-
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'IIRC Discussion with - Nuclear Power' Reactor.t j
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. Licensees Concerning.the Implementation of.
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7 Appendices B'& C-8 10-CFR-73 9
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lI JAMES O'REILLY 12 Chairperson O
14 15 Brave's Room 16
--Stadium Ilotel 17 Atlanta, Georgia L
18
- Wednesday, September 27, 1978 19 20
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C'O N T E N-T S
'2' MR. O'REILLY..
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MR... MILLER'.
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15 MR.. JONES..
5' MR..PAGANO 22 b,,
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28 MR; : McKENNA.
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MR. ROE..
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LUNCHEON' RECESS ~
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- 11 AFTERNOON SESSION F
. 12 MR. CLARK.
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' 13 QUESTIONS AUD ANSWERS.
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SUMMARY
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PROCEEDINGS 2
MR. O'REILLY:
On the record.
May we all take our
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3 seats, please?
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There'was a little confusion on the starting-time, 5
but I think that, with th'e exception of a few, I think every-6 body is here, so I think we'can start on some of the prelimi-7 naries.
8 I am Jim O'Reilly.
I am the regional director for 0
Region Two office, whicli is housed in Atlanta, Georgia, and I 10 would like to formally welcome you to our first seminar, 11 Physical Protections in the Areas of Training and Personnel 12 Qualification, 13 r-Before we start, I would like to give you a few of
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ltheadministrativedetailsoftheplantoday.
14 We plan to 15 have a coffee break and coffee in the back of the room at 16 10:15.
We intend to break for lunch at 11:50, and we will 17 probably take approximately an hour to complete the luncheon 18 and the clean-up, and we intend to start the conference again 10 at one p.m.
20 We will be using a lot of slides today, and the 21 NRR Staff has provided copies of the slides which will be --
22 you can pick them up or they will be distributed later today,
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23 so keep that in mind as you keep your notes during the meeting.
24 Now, we also have some of our Region Two staff here, (q
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25 and they-Will be taking messages for you, If you want to leave
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~l any special" message, they will make~ travel arrangements for 2~ you or ' help you-in any way that we can, so do not hesitate to 3'
use them. They are in'the back of the room.
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'4 Now, starting off on~the conference, I would like to make a couple'of. points and I intend to say a'few summary wor's I 5
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'uess,'near.the.end.
.The points I would like to make in the 6
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beginning is that NRC, even since-its' conception, and AAC 8
before, has always placed a tremendous amount of attention on
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personnel qualifications andLtraining.
Another word for that, to 1 oking'at the. findings, particularly from the office of nspection and Enforcement, is the, I think, sort of an offshoo i' of personnel training and qualifications is certainly communi-i3 cations, to insure that everybody understands.all of the O
14 ground rules, how serious the, regulatory agency looks at those' l
15 ground rules, and that we', of course, do our part in informing
.16 you all fully..
)
j7 This is'part of t,he seminar, trying to answer all i
18 - of y ur questions, and, obviously we won't have the' answer to
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1 I
39 all of your questions, but we are transcribing this meeting, J
and. NRC.will' be looking through '~these' and trying to improve 20 3
21 this communications probably the next' time arqund, because,
. befdre the - personal qualification. training ' requirements are
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fully improved,'I guess there are obviously several years 23 g - involved,.and there will be a lot of, I guess, guidance pro-
)f vided to.be'sure there is no misunderstanding.
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5 1
When you talk about misunderstanding,'I think.it 2
ties a lot into the Office of Inspection and Enforcement, A
3 because, I guess, as an enforcer, in one way, I have found, s,
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over the years, that I guess particularly when you ;alk to 4
5 large companies or engineers and not really small operations, 6
that you. never get into the problem, in my view, that people 7
overtly or rarely do, overtly, violate fully understood regu-8 lations and rules.
O Understanding them fully and knowing that they are 10 going to be enforced, I think, will add, I think, a new dimen-11 sion in your interest-today and your planning.
12 I wanted to mention, just to give you a little sense 13 7S of our findings, and I guess some of the reasons we've already V
14 placed so much stress on physical perfection, and personal 15 qualifications and training is that I and E has assembled a 16 lot of areas that are, at the moment, considerable cause of i
17 concern in the area of physical protection for reactors, and 18 they relate to such things as the examinations, in' rare cases, 19 6 '- we have looked at and found out the examinations were 20 improperly graded, that passing grades were given on records 21 that were,, obviously the people could never, in a million years 22 have passed, and the fact that this type of thing exists is a O
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23 concern to us.
24 We ha've.J seen',. a' gain in rare cases, in qualifications,
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25 firearm qualifications, that different people have shot for
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i-I other. people who~were not sufficiently qualified, and that 2
changes in the requirements,-like in distance, were substan-3 tially changed to insure that people could qualify, i
4 We;have cases-where training of guards was logged
'5 in and actually interrogation of guards showed clearly-that, 6
in-rare' cases, the training was not conducted. :Those. types-7 of situations rea11y, many of them, relate to fau1ts and a l
8 misleading issue that,
.f course, should never.be associated, q
9 I think, with the subject of security, which, in a. word,'it is 10' a1most' security integrity, is a word'that would be similiar.
11-When we talk that way,'it sounds like there is going 12 to be some new initiative of stricly awesome new way of 13 enforcing >,
and I would like to say that there will not be.
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14 We will, of course, when these rules are implemented, 15 the Office of Inspection and Enforcement will pay more attentio n to to the'.
detailed requirements in personnel qualification and 17 training, but I,would like you to know that I.think.we have i
- 18. certainly.placed more stress on reasonableness and also trying 19 very hard, we are not ta1 king.like falsification,-trying very.
20 hard to place -- and we're doing that right now -- attention 21 to enforcer 6ent graduated and ' keyed very c1osely to the rea1 22.
significance of security violations.
lC 23 Our internal procedures are currently in the review 24 1etter, and by the time these rules 4 come into effect, 1 think LOL
- 2. - you w111 see more eusseentie1 chenges..
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1 Another comment I would like toLmake, when we' talk a
2' about communications, now:that~is between NRC and' licensees,
'3 that internally,'we arelvery conscious of these problems, these 1
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commuaicettem vrou1e e.
1='enie ceee, eue ottice or nas eed-1 I
5 NRR are working. very closely together. They are participating 6
in theEfield test course' work, as many of you know, and my 7
staff, oficourse,'is1here,-and we are heavily involved in 8
trying to minimize any - -that:-is, minimize, we.can't eliminate 1
9 it -- any. differences in' interpretations of complex rules and 10 provisions'of the regulations.
F 11 I th' ink now I will stop.
I will be available for, 12 any. questions, and ILthink'an area of interest to you is
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13 inspection, and so I will turn.the microphone now over.to 14 Mr. Miller.
15 MR. MILLER:
Thank.you, Jim.
i 16 I think.we -are all indebted to Jim O' Reilly and his 17 staff for the arrangements that have been made.
We are not 18 indeb'ted for the recent trip that many of us took to Los 19 Angeles, including Paul Martin.
We were all out there and, 20 I'm afraid,'got colds, so you will have to excuse us today.
R Now there are a few things that should be said.
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21 Of. course, I violated one of the first rules.
My name is Jim 22 _
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Miller, for those of you who don't know me.
I am the Assistant 23 Director for Reactor Safeguards, Division of Operating 24 E()
- 25 Reactors.
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We are taking a transcript.
When you have a question 2
that you would ask or when you have a comment you want to make, I'T
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3 we would ask that you please identify yourself and, for the
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benefit of everyone, it might help if you were to approach 4
5 one of the mikes that re scattered throughout the room.
But l
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it certainly would help the young lady taking the traescript.
I 7
There are a few things that perhaps need to be said, 8
This is a meeting between the NRC and its reactor. licensees.
8 We ask that the questions and discussion be held,at least 10 initially, between those No groups.
If eny of the rest of you
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l 11 have questions or concerns, we will be available in this 12 room following the meeting.
We will be glad to discuss anything 13 you want to dscuss.
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14 I think the only restraint is sometime around five 15 o' clock or four thirty, we have to leave for the airport, but 16 we are glad to talk to anybody.
l 17 One other point.
I think Mr. O'Reilly stressed 1
18 communications.
You will hear some discussion today about the 19 rule, the guard training rule and the accompanying documents, j
20 You will notice that there are some words in the rule that say l
l 21 the NRC has a right to look at your testing.
We ask, I guess, 22 and you will hear it over and over and over again, so I might l
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23 as well be the first, that you keep an open channel of communi-I 24 cation beween Mr. O'Reilly and his staff, so that they can n
25 observe the more complex testing that you will have going on.
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of course, he must maintain the right to look at 2
your records and to request any of the tests.
I think it is
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to your advantage to keep in close. con. tact with the I and E
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4 staff as you proceed with this rather complex effort that we 5
are all about.
O With that, let ne introduce Mr. Vick Stello who is 7
the Director of the Division of Operating Reactors of NRR.
8 Vick.
9 MR. STELLO:
Thank you, Jim.
Good morning ladies 10 and gentlemen. I spent some time thinking about should this 11 conference begin, because many of the conversations that I 12 have had an opportunity to have with many of you indicate 13 that the questions that you have don' t pertain only to the 14 subject matter of this meeting, but many of them deal with the 15 philosophy behind where are we going in the ini.ustrial security 16 and safeguards activity within the NRC.
17 These questions, I know, are important to you, and 18 you really want to dscuss those issues.
I would appreciate, 19 if we can, avoid questions of philosophy.
We have a task to 20 do so we ought to devote our time and attention to the task 21 and purpose that we are here today for.
If there is a need to bring in philosophy, I would 22
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23 appreciate it if you will do that toward the tail end of the 24 meeting, so we allow sufficient time to do the job that we all rn 1
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25 came here to do today..
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. I know many of'you.are very busy and you have 2
schedules that are very' demanding,'and I really sincerely
.3 appreciate your taking time out from your-very busy schedules C
4 to come down.here and listen to us,-but not'just listen.
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5 We want to discuss your point of view about the activity we
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are discussing.
7 We really and sincerely are here to listen.
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I am sure that'many of.you:are going to raise some 9
very good points, some of which we may not have the answers i
10 to, and we'may need,an opportunity to go back and take a real i
I 11 good hard look at some of these issues that have been raised, 12 and' provide answers to you..
13 In that particular context, I am reminded of'the 14 meeting we just had recently on September 14, 1978, with the 15 Edison Electric Institute Security Committee in New York City, 18 to discuss many of the same topics that we will be. discussing 17 here today.
At.'this meeting, several issues and questions 18 were raised, which were very important issues and questions, to and, quite frankly, we did not have all of the answers at that-time.
20 21
- I don't suppose we,have.all of the answers even today, but I would like to spend some time going over those 22 Particular issues.-
23-24
. Specifically, the issues that were raised, and I vill
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25 try to give a response'to them, were, number one, twenty-one 1
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ye'ar age requiremend for our' personnel;.;wo,the' termination of r
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an individual that-has been' convicted of a; felony; three', who' u
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is to~be_ trained and qualified, that is, who is covered;.and p.
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v' four,'are all sites required to have.the specific equipment-3 5
listed in Section 5 of Appendix B.
6 Turning now to that first point. tit was pointed out i
7-that the NRC's. requirement that all the members of 'the security 8
force be at least 21 years old is inconsistent with many state 9-laws that allow licensing'of armed security personnel at
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-The EEI committee indicated that many 18 years of age.
sites now are using' armed security. personnel who are under 21, 12 and that they are serving in that capacity very well.
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Of course, the present. rule would suggest that such 14 individuals would need to be released.
Furthermore, there is 15 an' obvious inconsistency with the military.
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16 Truly, this is a valid point.
We have initiated a 17 l
thorough legal review and intend to reommend to the Commission 18 that the rule be amended to allow arming of personnel,a,t'.18.if 19' it is-, in fact, consistent with state law.
20 I recognize.that since we are talking about a study I
- A and talking about the possibility that-the rule would need to
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i 72 be changed, if indeed it does need to be, that we will need 23 a mechanism to get this information to you, so I would like to 24 say this perhaps once, is that the points that I am going to 35 be discussing here today and issues that are going to be raised
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here at this meeting, there clearly will be a need to communi-2 cate back to you on how this is resolved.
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If it is in the way of a formal regulation, that 4
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will be fairly obvious, but if it is not, you can rest assured 5
that we will' find a mechanism to make sure that each of you 6
have the benefit of whatever the resolution of a particular 7
issue is.
8 We will make every effort to do that as soon as o
possible, so that you will have ample opportunity to include 10 it in what you have to submit' to us.
Il Several members of the EEI Security Committee also 12 pointed out how difficult it is to determine if an individual 13 f-has been convicted of a felony.
Some licensees may not be b) 14 able to use fingerprint and police records checks under some 15 local, state, and federal laws.
That is, have access to a 10 national agency check.
17 This only allows the licensee to conduct the county 18 by county check of courtroom recor'ds, and clearly is not a 19 practicable way to accomplish that purpose.
20 NRC recognizes this difficulty, and this was, in 21 part, the basis when the proposal went through.
The NRC staff 22 is currently studying various options, if the clearance rule O
22 1e noe geeeed, end veur ingue toder wou1d be sincere 1r eggrec-24 iated.
(V'r 25 I am confident that our objectives and yours.- are the
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'l same.
You want to hire" qualified?and trustworthy employees.
2 Each -of - you,; however, _ will' choose to ' demonstrate that your
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3 - program does.indeed accomplish this purpose and I am.sure you h
wil'l' develop a' reasonable approach to overcome.any. difficulty 4
5' you'may.have in.your particular state.
6 If, again, the need' arises, we will' develop 'further-7 guidance on.this matter;
'8 Let me' stress that we are. anxious and look forward'
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9 to any comments'you may have on this particular point during.
j 10 this meeting, so:that.when we do' develop-that-kind'of guidance 1
'l 11 it will-be with'the full b'enefit of your comments.
a 12 The NRR staff was asked to clarify who is' covered i
13 by the training qualifications requirements, specifically.
14 Are the sites required to train, qualify, and keep. records for 15 all plant personnel?
The answer is no.-
16 Only those pesonnel who perform critical and complex 17 tasks,~related to the security activity are covered.
This 18 includes the security positions identified as part of the 19-physical security organization in the physical -security. plant, 20 and those positions identified in the contingency plan responsi -
-21 bility matrix as performing security contingency tasks.
'1 22 Some simple and obvious examples that came to my mind
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23 was a plant superintendent may need to make certain phone calls 24 Would you'need then to keep a record to show that the plant
' 25 superintendent is trained to use the telephone?
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'1 ahswer ob'viously:is no.
That's-just~an: awful' lot of paper.
work that is unnecessary.
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!On:the other hand,-it'is expected that that same 4~
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individualfoperates'some complex. radio equipment that it is 5
nott obvious that he does, indeed, know how to useLit", then 1
6' yes, he:should be trained in the use of such equipment.
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7 So-the measure of reasonableness, what'we need to-8 do, has to do with the complexity of the task.
If the task
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9 is, in fact, a complex one, clearing a training and record.
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10 keeping is needed.-
'11 Lastly, EEI. wanted'to know if the licensees are 12 required to have on-site the specific dquipment specified in.
t 13 Section 5 of Appendix B.
They pointed out the difficulty
-Q 14-this wouldicreate because of local laws,-federal regulations, 15 and incompatibilities of the equipment' listed with specific 16' site requirenents.
-l 17 Appendix B states, and I quote, guards and armed' 18 personnel shall either be equipped with or have available 19 the following security equipment,-appropriate to the' individual 20 assigned contingency security related tasks'or~ job' duties as 21 described in the. licensee's physical-security and contingency 1
22 plants.-
j 23 The equipment identifiedLin~the sites approved secu-24 rity plan meets'this requirement.
The licensees are not 25; required to have on-site the specific equipmentElisted in u
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Section 5.-
Each site will be reviewed on its own merit.-
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- I would-like again tosthank you for. coming to this
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- t mee ting, and I will. thank you in advance for.what I.am sure 4
will be-an interesting meeting and.I hope will provide-us with jO.
5-many:of the concerns"you have over a'll' aspects of the rules
,8 and that we can docour job as best as we can, and hopefully
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7 we will be.able to ease the applicationLof these rules.as they 8
come forward in the next several months.
9 Thank you.
10 MR. MILLER:
I'think.that sort of concludes the 11 opening. statements.
At'this time, w'e would like to get into 12 the rules, the development'of the rules, the guard training-13 rule, and the security planning rule, and the development of-14 some of the guidance,specifically the Tennessee Plan' Guidance 15 and the Guard Training Manuals.
18 The individual --responsible for the development of 17 these documents is Mr. Ralph Jones.
Ralph is Chief of'the-18 Standards Branch, office.of Standards Development.
' 19 Ralph.
20 but. JONES:
Thank you, Jim.
Ladies and gentlemen, 21 we will give you a brief run-downton these rules, how they.
22 were developed, how they.were. changed, why they were changed,
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'23 and sort of what we expect and how-they are'to be applied
- 24 today.
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. 26 Starting with the guard training rule, you are all 4
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aware of the original Appendix B' and how it cam out with 2
detailed qualification requirements, physical fitness require-
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3 ments, running an 8 minute mile, p'ush-ups, training specified
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in numbers of hours, lesson plans, and this sort of thing 5
in the Appendix.
6 The rules published for public comment extended 7
the comment period.
We asked specifically for comments on 8
how the licensees felt it should be implemented, whether it 9
should be a centralized training program, certified by the 10 Commission, licensees allowed to do their own, just how it 11 would be.
We did not receive very many comments on that parti-12 cular aspect of it.
13
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However, we did receive many comments on the specific -
v 14 ness of Appendix B, and the training aspects of it, and the 15 specified hours.
6 Based on these comments, we took another look at 17 the situation.
We also took another look at the EEOC impli-18 cations on how these could be specifically tied to job functior.s.
18 Now, this, of course, we will get into, some of the 20 NRR people will get into in more detail when they talk about 21 the job analysis.
22 Appendix B was turned around, if you will, to provide
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23 flexibility in developing the training programs to permit 24 flexibility in adjusting the training programs, to fit the
!l 25 site specific conditions.-
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-We oliminated specifying the!numberLofLhours of training., It was.not'necessary to'specify this.
Perhapsa person wast.. alre ady ~ trained.-
I 4-Our intentiin revising Appendix B wasito'_ provide 5;
flexibility' to the licensees in developing his ownfprogram.
6 We:eleiminated' physical' fitness requirements.- Your. plant 7
manger /doesn't have to'runithe eight' minute mile"any more.
8
. It depends 'on.what is required of a job -
of a 8
security. job -.as to how physically fit he needs; to be.
10.
Possibly,.the central alarm station operator never-11 has to~ move out of'his chair.
-It might.be a wheelchair.
This 12 - was tdie intent of: revising Appendix B, was e to' provide the-
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flexilibility.=
13 14 Some people have asked why didn'.t you go out for pub-15 lic comment again.
We didn't'go out for public comment again 16-because we revised Appendix B-in line with the comments which
- i 17 ve had'already received.
18 We took into_ account.the comments we received, so 18 we assume that we could solve the problem for you, or at least, t
20 to a great extent.
The comments I have received at. meetings 21 like this and individually lead me to believe th'at we did do
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- 22 this.
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23 I don't'think I need to go through all of the detail
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reauirements'of the rule itself.- _ You are aware of those.
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~ 25 Vick has touched on some of them.that have given you problems.
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Ifdon't'need:to address those.
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. One think I will do though is to address the training i
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manual itself, that you all have copies of..With Regs 464.an'd t
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4 465, these'areLpublished for public comment a few' weeks ago.
5 We recognize that we gave you very'little-time to ccmment on 6
them.. The Commission has directed.us to get~these training t
7' manuals out to the licensees, comments from the licensees', and 8
revised and out;again by October'23,.when the rule becomes 9
effective.
10
- We didn'.t have'very much~ time to wait around fot 11
- comments, We have received comments, however, from a number 12 of licensees.
13 The major thrush of these comments,.along with 14 picking up.a lot of typographical errors..that we had in there, 15-is that:these are excellent training guides, but don't:nake 16 them mandatory.
Don't'make us use all of these lesson' plans 17 in our facility.
18 The intent of these documents is a reference docu-ig ment to provideLinformation to train security personnel.
It i
20 is not a regulatory guide.even.
It does not present a regu-j 2
21 latory position.
It is not required that any or all of'the I
lessons be used.-
- 22 23 It l's an; attempt to assist in developing training
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manuals.
There are statement in the documents that you have
- 24 0;
Y These should not have been
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there and will not be there in the final document.
2 There are' definitions-and references in the docu-3 ment that imply things are required.
These will be removed
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and corrected.
5 I don't think I need to go into the details of the 6
documents themselves.
You have all seen the volumes.
There 7
is an error.
It says there are five volumes and'there are 8
really only four.
A few of these things will be corrected as 9
the revisions occur.
10 But the main. thing I want to stress is this manual 11 is not a requirement.
It is intended to provide y~u with o
12 information.
You will note in the document there are times 13 specified in the various lesson plans.
These are suggested
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14 times.
The course work may take longer or less, depending on 15 the class, the instructor, previous training and experience.
16 The lesson plans in these documents are not in 17 themselves complete.
They are outlines.
They are intended 18 as guidance for the instructor or whoever is developing the 10 plan.
He is expected to fill out these outlines and provide 20 the detail plans and the detail lessons that will be needed to 21 train the personnel in whatever areas are expected to be 22 trained.
_ ( ))
23 We do not expect one individual to be trained in all 24 of the aspects shown in the training manual.
It may be that
. l3
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25 a given licensee will not use any of the training manual and l
20 I
have their own training plans.
This is fine.
2 When NLR reviews your plans, they are not going to
\\/
3 check to see whether you used plan' number 107 or anything O
4
(_)
like that.
They are going to look at your training plan to 5
determine whether or not it adequately meets their job analy-O sis criteria, their performance objectivo criteria.
7 If all of your pe:,.1.e are adequate.ly trained through 8
the military, the police academy or some place like that, 9
maybe you don't even have a license plan, if you have met the 10 performance objective.
11 That's why I want to stress that Nurog 464 is not a 12 requirement.-
13 The contingency' planning area I will say even less 14 about than I have about the training manual.
The regulation 15 has been published as an effective regulation after public 16 comment.
The contingency planning guide Reg Guide 554, was 17 published for public comment.
We received very few comments 18 on that guide. Two. utilities and two individuals commented on 19 the guide.
20 In general, the utilities were concerned that the 21 contingency plan had to be a separate and complete.enti.ty in 22 itself.
This is not the case.
It can be completely and should
_/
23 be completely integrated with the physical protection plan.
24 I believe the NRR people have stated this again and
( j 25 again.
That is the intent.
~_
21' The regulatoryHguide'is:merely a guide to show you 2
what is to.be included in the. contingency plan,-and not
~ (
3.
necessarily as:a separate document.
I
~
I believe that:that'is about all I need to say about 5'
the regulatoryJguide'. -Based on the comments' we. received, we 8
do.not plan a. revision of that guide right.now.
We'are' going:
to wait.until we have had some experience in.the use of the 8
guidec to see what kind of continge'ncy plans result,; what kind -
8 of problems we experience with the guide,.and then,' revise it to along'those lines.
II'
'I-think'that covers the major items.that we'are,.:
12 going to talk about'today, and if'you have any questions,'I; 13 think that.there is' a plan to hold those until laterion in
[
14 the day.
I.will still be here.'
i 15 Thank pou.
16 MR. MILLER:
I think I'should emphasize, some of 3
17 you may have some disagreement with Ralph, but all of your
'18' comments were considered'or used in regard to the changes made 18 in guard training rules, and I can only add to what Ralph said-20 that I promise you you will get another shot at him.
21 We plan to open up, essentially, all afternoon.for
(
.22 you to talk'to.us,to. discuss with us your concerns, your
(
comments.
As has been in the past,.I know you will not be-l 23 24 bashful-in this regard.
l 26L Let me. emphasize another point that Ra1ph brought up.
~
i I
- -. - ~.......
..... _.....,,,, ~...,
4
22 Il Some of you haveEvery. good; training plans and programs now.
2E We believe that.the structuring.of.219, Reg Guide 219 and the
~
3>
guard training rule,. permit you to-u'se these programs, build 4 -
on'them where necessary, but we will_be looking for an overall 5
program, at. l' east the objectives of 219, and specifically, 'the 6
guard training rule.
7
,A.little later this morning, Mr. McKenna and Mr.
-8 Patjano will be talking about the approach and you will hear.
t 9
a flavor'of performance objectives.
I.think we' talked with 10 you'before when we firstLtalked about 7355 along the same lines i
11 or the same words, anyway, of: performance objectives.
12 Believe 'me, they'are not the same, so we.will hold.
13 quostions.on1that.too.
14 At.this time, let me introduce Mr.. Frank Pagano,-
15 who is Chief of the Development Branch of NRR, and Frank'is j
I 16 one. of us that also caughtia? cold. Go to-it, Frank.
t 17 MR. PAGANO:
Can everyone hear m'e alright? -
18 Good' morning,. ladies and gent 1,emen.
I used to get a ig laugh by saying,that I was a shorter, thinner version of Jim-Miller, but f.that doesn't get me any laughs any more, becatse 20 Jim 1 st 70. pounds, and our weights are sort of equal now.
21
.j I may have to pick'on Vick Stello.
Somehow, it doesn't ring 22 anymore,. Jim.
23 Ladies and g'entlemen, during the mxt few moments, I 24 am going to discuss how NRR came'to select the approach out-1 25 ;
t a
23 s
I lined in Reg; 219.for implementing the training and qualificatic n 2
'for performance in Appendix B, but the basic reason as to why ti,j.
3 we adopted the approach is shown on in this viewgraph.
4 b
First, it assures that the site security staff can 5-successfully. implement the physical security and contingency 6
plans and,' secondly, it is compatible with Federal and state 7
legal requirements.
8 Over a year ago, NRR started its search for an 0
approach for determining the adequacy of the training.
We 10 revised the existing literature at training program development, 11 discussed the issues with organizations with similiar problems, 12 talked with other Federal agencies who have experienced more 13 regulatory responsibility in the areas of training and O
14 personnel selection, such as the Department of Labor, Civil 15 Service Commission, the Equal Opportunity Employment -
Equal 16 Opportunity Commission.
17 We have review.ed the comments we received on the 18 drafts of Appendix B and Nureg 219, and we dicussed these 19 issues at length with the NRR staff.
20 Traditionally, the NRC and the security industry 21 have discussed training and qualification in terms of completed 22 course work on various subjects.
However, our experience
/~)
23 uncovered the fact that the course outline approach provides
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24 no guTrantee that an individual can,in. fact, do his or her 3
(V 25 job..
24 1
It does identify the content to'be learned for 2
f
. training, but it does not establish what the trainee is able tc f
3 do upon completion of the course.
4 A course outline may suggest that guards and watch-5 i
men complete 50' hours of course work, but.what has to be-known 6
is what' can this security person do after completion of this J.n -,..
-,s training?
8 For example, can'he or she respond to an alarm and 9
use contingency procedures?
Do they know how to' record a 10 suspicious event or how to retain-a suspect?
11 The basic questions.are: what standards must the 12 trainee meet, and are these standards. compatible with the 13
-( ).
site plants?
Is the individual being adequately trained and 14 evaluated on,the truly critical parts of his job?
15 We feel the course outline approach does not answer 16 thesa questions.
17 The question that all of you is asking is why did 18 NRC publish upgraded training and qualification requirements.
The answer is that the NRC is. determined that it needed assu.
20 rance that the people who perform critical security tasks l
21 at the site can perform _them. adequately.
22 Therefore, our regulatory approach had to lua designec.
23
~
to answer the. question: can this. individual actually do his
-24 g-)
job.
Such related question,s as how much trainingfhas this 4f 25 :
person received.or what. courses has he or she attended could s
..w.
...~.
u.,..
25 I
not really'tell us anything about' successful' performance.
2 We are interested in the ability of the personnel n
3
(_)
to do the job to which he or she has been assigned, and not 4
r~w necessarily how this ability was developed.
O 5
Now, what is the solution?
How can it be determined 6
if an individual can satisfactorily perform his or her security 7
duties?
8 We found that the solution is well developed and 9
widely used.
It is currently being used by all the Armed 10 Forces, by many police organizations, and in every imaginable 11 occupations field from private security to carpentry.
12 Briefly stated, we first analyzed the individual's 13 job to determine what the individual must be able to do to
('T k#
14 successfully perform this job.
That: is,. you conduc.t a job 15 analysis to determine what tasks are required to implement 16 at the site, physical security and contingency plans.
Next 17 you outline, in the form of a performance objective, how the 18 ability to perform these tasks are demonstrated.
19 This objective outlines the tasks to be given to 20 each individual.
Finally, personnel are then qualified to 21 perform their assigned tasks by successfully achieving these 22 objectives.
23 For example, your site contingency plans may require
}
24 the use of night vision equipment during contingencies.
There-()
25 fore the site training and qualification plan should identify
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,e e.
+-
e,
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whoEwill!use'this' equipment, what tasks they would' perform, 2'
and how they~must? demonstrate:their proficiency.
3 formalizes this'proce'ss.
h
'4'
'.On : July 5 last year, the Commission published draf t 5
requirements for upgrad'ing guard training, for comment. ' This 6
was ~the first draft of Appendix B, and it' consisted'of training 7'
courses requiring over-a hundred and fifty. hours;of' instruction 8
In addition, it required 1that all' individuals..taking-9 these courses pass a, test'on the material, making ~at least a 10 70 per' cent-score.
Many.NRC licensees who commented on that-
~
11 document. pointed out that--these requirements ~~did...not. comply 12 with the existing:- EEOC guidelines on testing and selection, 13.
which' require that any.' discriminatory-requirements must be.
qV 14 shown to be valid indicators of an individual!s abi'lity'to 15 do h'is or her-job.
16' In other words, it'must be-shown that'a particular, 17' test score will ' indicate that'the examinee'can or cannot do:
18-the job.
19; Now,-this can:be accomplished by. requiring that the:
20 test represent' samples..of the-knowledge,-skill, or ability 21 necessary to'do this job.
For the.most--part, this can be 22 accomplished by' developing tests.that are miniature' samples 23 -
of.the job..
- - -, For example,. implementations of a' site contingency-
-h
.. 25 plan -inay require the-guard to respond to any point on site-u...
.. ~...
q q
~
f27
~I '
within'three minutes of-notification.- Obviously a'. valid test 2'
f ' this L ability 'would be simply ' to siinuiate sounding an alarm o
g
.3' and.seeLif the individual selected.can, in fact, respond to 4
any polnt on site within three minutes..
-A successful test for a typist in{a; security agency 5
6 would obviously be a - typing', test, and so on.
7 The EEOC guidelines pointed out.that, in' order to 8
develop tests thatLare valid,.you must'first. conduct a job 9
analysis to determine what makes up the job, and,' based on 10.
this information, develop tests that test the knowledge, skills 11 and' abilities ~ identified during the' job.anaiysis..
12' This'isLexactly what wil1~be accomplished when
~
13 training and qualification-~programsDare developed,.as outlined
.O..
-14 in our intereg.219.
We'must first conduct"a job analysis, 15 and based on this analysis,' develop performance objectives 16 that outline valid tests of obvious. skills and abilities.
17 So, we can.see that the approach we outlined in 18 Nureg 219 does precisely'th'ose two things.
First,.~it demon-strates-that the individual c'n perform his or her security'
]
19 a
20 duties, and secondly, it allows development of training and
~
1 21 qualification plans that is compatible with the esta'blished l
. 22 guidelin'es.
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O
- 23 "ow, ur #exe eeexer eni mora1#9 1 Tom acxe##e, 24 who works-in.our. branch, and Tom is now going to go over, into
. 25 more detail, the job analysis.techniciue..
u r
4-
. ~...-
28 MR.: MILLER:
Before wefget to that, I_think we ought to'take_a/ break..
Le t 's try -- i t is now - 'five 'af ter -- le t's
.g,
1~ try to be back about' twenty-five after.
-4
~ ~(Whereupon, a coffee break was taken.)
5' MR. MILLER:
Would those in the back come in, please, 6
so we'can get started?'
7 Ladies and' gentlemen, could.we start again?.
8 At this time, I would like:to introduce'Mr. Tom McKenna.
Tom has been working;with 0219, Reg Guide 02'19'for:
9 lo several' months ~now.
I think the first draft and the second II-draft, whatever-else,_ Tom is-probably.the.most knowledgeable 12 person'on.our staff with this approach to training.
13'
.Again,.we would like to hold questions until this 14 afternoon, and'-Tom will also.be here until later..
I_just.
15 learned -- I_think we are proably going to have to: wrap up 16 around four o' clock or before.
We will see.how things go.
]
17 Tom.
18 MR. McKENNA:
Good morning.' I am. Tom McKenna.
I 19-work'in the Reactors. Safeguards Development Branch, and Frank' 20 is my boss,~and I'am going to briefly discuss.how you can 21 use job analysis _and-performance objectives to meet the-
- 22 equirements contained in-Appendix B.-
.Q
' 23-Now,:we have only got 45 minutes.
It is going to'
.V
- 24 be very, very brief.
.I am-hoping,;if I can define some of.
.I
,./^s
. 1
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25 the_ terms"and give you a: feel for howLit works', then I have n
a e
a m-',
3,+
e
,s
/
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4 e--
29 1
succeeded in what-I am hoping to do.
2 we are going in planning'the wholesome workshops and
('
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3 starting in. February, they are going'to run through April, that
(_ will be designed for working level people, small workshops, 4 5 no more than 20 people, maybe one or two reps from each site, 6 since this business is going to be site specific. These work-7 shops are going to be designed to give you a working level 8 knowledge on performance objectives and how to apply them 9 in developing an adequate plan. 10 They are going to be just that -- workshops. We 11 give problems, you will come up with solutions; we will discuss 12 them. We are planning these. Like i said, it is not firm 13 for two reasons. One, it requires some arrangements on our 7_. V 14 part that are incomplete and the second thing is, we are not 15 really sure that you.want them. 16 So I think that some sort of response, a v' t, nay, 17 if we get a massive response that nobody wants to these 18 things, then we will probably cancel, but these are ng to 19 be working level, and they are not going to be meetings. We 20 are not going to talk at you. It is going to be a small group, 21 ifteen or twenty people, and we are going to have a workbook 22 and we are going to go through the mechanics. (), 23 I think it is important to point out, though, you 24 can start developing your plans now. You don't need to wait .-~s-k-) for the workshop. 25
30 1 We purposely went out and did our homework, checked 2 the literature, talked to the people, and came up with this job analysis approach, and 2.t is n'ot something that we dreamed O up in the NRC. vou don't need to come to ue for erecific 5 guidance. on how to approach the development of your plan. There l l is a lot of literature on this business. There are a lot of 7 people out there who know how to do it. 8 Esentially, because of the pressure from EEOC, they 9 demand this kind of thing, so there are a lot of people who 10 know how to do it. So, I think that, wi th the guidance we have Il given today, and a little research on your part, you can start 12 development. Ma;rbe this is the time to state this. 3 The approach that we have outlined in 0219, and I I 14 keep talking 9, and overybody else talks about 0219. 15 I'm sure some don't know what 0219 is. This is 18 what it looks like, anct it is Nureg 0219, and it's title is 17 Nuclear Security Personnel for Power Plan and it was published 18 in final form in July of '78, and it is a new record. It is 19 not a Reg' guide. It is not a regulation. It is a new record, 20 and it is essentially designed to supply you with information 21 and be helpful in the development of your plan. 22 Now, if you want a copy, you can get it from the AQ 23 National Technical Information Service in Springfield, Virginia 24 at-22161, and it costs you eight bucks, for a hard copy, and .O '/ 25 they will give you a microfish for three bucks.
31 1 I think we have also sent copies,at least one copy, 2 to'every one of our licensees, and I think the rule states Q(_, 3 that you can.get another one by writing us. r~T 4 Okay, I am going to concentrate on the qualifications %) 6 and the training requirement,because-that is where you apply 6 these techniques. Now these requirements in Appendix B are in 7 two sections. 8 In Section 2B, which is the qualifications requirement, 9 and in Section 2D, which is security, knowledge, skills and 10 abilities, let me quote from this, because I.think it is 11 important that we tie this to the rule and see how we can 12 relate. 13 Okay, Section 2B, which is the qualification require- %.) and I quote: each person who performs security 14 ment states, 15 related job tasks or job duties requied to implement the 16 licensee's physical security or contingency plan shall, prior 17 to being assigned to such task or duties, be qualified in 18 accordance with the licensee's NRC approved training and 19 qualification plan. 20 Now, let me quote from paragraph 2D. Now this is 21 titled Security Knowledge, Skills and Abilities, and I quote 22 again: Each individual assigned to perform a securities related task identified in the licensee's physica'l security or contin-() 23 24 gency plans, must, and I think there's a missing word, must p[ demonstrate the required knowledge, skills, and. abilities in k-25 1 1 l e.
3'2 1 - accordance with the spec.'.fied standards for eachitisk, as .2 stated:in th'e NRC's approved'licensco's training and qualifi-3 s. cation plan. ([ Now, that's hard to' understand..IIere are the-key. 5 ideas. One: personnel have ta be qualified to perform their- -6 ~ assigned tasks and' duties. That means the assigned tasks and-7 duties at your. site. gg are doing.all of this so that you.can take a'look [ 8 at your site specific needs,'so that we do not have' central 8' checklists, we hope.to say well,everybody's got to do A,1B,EC, [
- 10' 11 D, E, F, G, because that is.just not' realistic.
That is not 12' the way things are done. 13 Soyone).you havelto identify -- well you have to 14 ' qualify a person to perform the task and duties ati your site. 15 Now, two, this qualification, basi ~ ally is accomplished by [ c '16 having him demonstrate these required s'kille, knowledge, and i T 17 ability to perfrom the task that.are required at your site. 18 And,, finally;,.the rules state that you have to set 19 specific standards and specify these standards in your' plan, I 20 that demonstrate ~that the individual has the necessary know-21 ledge, skill, and ability. 22 Now, 219 formalizes this whole process, and to do ()
- 23 this, we use. job analysis ~and performance objectives,..and,
~ ' 24 as you stated earlier, the reason we have done this.is that - 26. the methodology is out there.. It is well understood. The i ~ ^. r, + 4 i . ~ -
\\ 33 i -1 - 1 terms are wei.ll defined. Everybody knows what it means, so. what ILam going-to do now is just walk through very, very 3 quickly,..a little bit of job analysis, and a little. bit about' performance objectives, and'try toidefin'e a couple of the 5
- terms, 1
8 To meet the requirement that I just outline, basically. 7 requires three steps. First, you identify what security task 8 each' duty assignment performs that is critical,.and I under-8 line critical,.to implement the site's physical security and-10 contingency plan. Now, the reason ~you do this is so.that you l 11 have to set standards for your site. You know, every site l 12' has different layouts, different' legal problems, different 13 equipment, and a different physical security philosophy. 14 So,. you have to conduct an analysis' and we" ca11 iti .i .15 job analysis,.to' determine what tasks and duties are required. l 18 at your site to lo the job. I 17 What is the job? The job is to implement your 18 physical' security and' contingency plan. In other words, 19-training isn't done for training's sake, training is not ~ 20 isolated from other facets of your security system. Tr,ain-21 ing has to complement them. 22 Secondly, once you have identified what your people l O 23 do, ehese due1es end eesxs, you heve to deve1eg teete thee 24 determine wh' ether they have the required knowedge, skills, Ir and abilities to perform the tasks. In ' other'.words, can the l 25 i r ,I k r
34 1 guy do the job. 2 Now these tests, you are going to have to supply a (m (,) certain amount of information for the test. If you don' t, 3-4 r3 then we have no idea whether they are valid tests. In other V 5 words, by validity, we mean that the guy successfully performs 6 the test. 7 Does that mean that he can successfully perform the 8 job? An example: given a written test on the ability to 9 operate a metal detector, for instance, probably is not a 10 valid test, because:.a valid test would require the individual 11 to physically operate the metal detector. Being able to n'ame 12 all the dials and state their function, the nomenclature of 13 the equipment, doesn't say that the guy can operate the equip-14 ment. 15 You have to take a look and find out the best way, 16 to test, so that is one thing. The test has to be valid. 17 The second thing, the test has to be reliable. Now, 1 18 what do I mean by reliability? 19 That means you give it to Joe and you give it to l 20 Fred and you give it to Sue. They all get the same test. 21 They are all tested by the standard. They all are tested under i 22 the same conditions. (} 23 So, the performance objective, which outlines the 24 test -- and I use the word outline because it really doesn't. /N'() 25 contain the specific information that would be required to
m. 35 I l' deal with the specific,. test'-- for-instance, if you say a ~ 1 2? written test, your'performanc,e' objective is'not going'to'be 0 3 It ba'sically states that.you are J the_, actual written. test. h 4 1 going to give.a' written test and outline some of the major 5 points.,We will get into this in a minute.: t 6 ~ We' use the word outline because it is :a -blueprinte .i I of the test,;but it is not the actual test itself.' 8 ~ Finally, now that we.have identified the job' analysis, 8 the' task and duties' performed at'your site,you'have outlined' t 'i 10 in the' form of'a performance objective and sometimes these - 4 -5 11 are called a behavioral objective:., but people ~at.the.'NRC r 12 had fore. trouble with behavioral objectives than performance .13 objectives.and nobody likes performance' objective because'-~- t 14-but'it is not the-same thing..- l 15 We use'these terms because that is what is in the 16 literature. That'is what educators use, andlwe could not see 17 inventing a new term. f 18 So, you have identified the task. You have come 18 up with'a-test, and now you qualify the individual and how f 20 do you qualify him? 21 You have him successfully perform the objectives 22 that are associated with his duty assignment.- In other words, O 23 he deeente heve to do everythine, 3uet the thines thee ere P 24 required by.his job.
- ' O.
He could a 26 Ralph pointed the alarm station, operator.- i pv f i
36 1 be in a wheelchair. If you've got a task set up that doesn't 2 require somebody to run around, you decide that by doing an n U 3 analysis of your site. (~h 4 The final point here was just stressed.being site %) 5 specific. 6 Now, let's look at this first step. It is called 7 job analysis, and I.think I should caution you here. The a job analysis and performance objectives that we have in 219 9 are sort of a watered down version of classical job analysis, 10 and classical performance objectives. 11 So, when you get into literature, you are going to 12 find that they are going to talk about a lot more detail tP m 13 we are talking about, so just keep that in the back of your 14 mind. We are trying to hit the high points. 15 Now, what is job analysis? Basically, it is a 16 process taking a look at the occupational areas at your site, 37 to determine what duties are performed, what tasks are per-18 formed, and what knowledge, skills and abilities are required 19 to implement these tasks. Now, I have the word element up there. When I say 20 element, I mean knowledge, skills, and abilities. It is a 21 final step in the analysis. 22 (h Now, this slide basically shows you the structure 23 of the job. It shows you the relationship between the job, 24 the duties, and the task. The next one will show elements. 25
37 'I It is important that you understand these terms.. Othe rwise, 2 you probably cannot' understand what we are talking about. Gk-) 3 Let's just take a quick look here. We have the l") 4-job identified in this slide as being a search watchman, v 5 Now, what is a job? O Well, a job is everything a guy does at the site. 7 In our case its'everything securitywise, he does. That is a 8 security job. It does not matter what it'is, it is everything. 9 Here again, it is up to you to decide what your to jobs are. 11 Secondly, you have duties. Now, in this case, we i 12 structured it, what I envisioned as a search watchman was 13 somebody U not armed, who just performed search activities 14 all day. Ile didn' t do anything else. So he searches vehicles 15 and he searches personnel.. 16 Now, I just want to stress, it's up to you to 17 decide what the duties are, i 18 Now, a duty is a little stricter definition. A job i 19 is a combination of everything a guy does. A dutylis.what he 20 is assigned to do during a specific shift. These are the 21 titles that you use on your duty rosters. A guy is going to 22 be assigned to search personnel at the entry. A guy is going () to be assigned bepween nine and ten to patrol the perimeter. 23 24 That's a duty. It is something he does at a specific time, .fm k l-25 and it is identified on the duty roster. i
38-1= Thisiwhole program'is outlined in 0219. It zeros 2 in at' duties. 'We. don;'; talk about jobs very much. We basically '3 say.that you'should qualify personnel to perform duties. K '4 The reason we do tnis is something that can J 5' to what.is going on.at the site. An inspector could go 6 and see people performing a specific duty during a speci.
- 7. shift, and.taen, by checking the records, determines ~what h 8
has to be able to do to be ~ qualified-to perform that duty. 4 g So, it is something -- there is a clearcut relation-10 - ship with what is going on at the site. 9j Now, we have received a lot of comments at the way I roke it down. All the detail-in 0219, where we had 13 12 13 duty assignments, identified,-isn't realistic, that this is~ [ O I guess'we. 14 not the way it is going to happen at-the site. don't care. The-bottom line is:that you folks decide what. i 15 the duties are'. 16 l 37 I just broke it down so I could show every.possible one. I tried to dream up overy one that I could, but if you 18 want to train, if you want.to have training everyone to per-3, form every duty, that's fine.- How ever you want to break it g down. You do not have to stick to the type of structure that w3 have in that book. I did it so that I could break'it down into the most complex example I could find, instead of,.possibly, the most realistic. Finally, we have tasks. Now, tasks, t.his is when itjstarts - tasks are, things that'a specific ~ individual has .+ --,,,*;..m., ,-,-,.,,m. .. _, -. ~, _,..., ~....-,..--.,s ,.-c
39 1' to do. LIf two people have to do it, then each one has a task. 2 It is something that is required during performance of these ,~is) 3 duties at the next level down. It is something that is obser-4 vable and measurable. 5 For instance,.some cental prccess, although it might 6 be considered a task, it is not observable. Probably you are 7 going to have to combine it into some other task. 8 Now, I understand and I realize that a lot of these 9 things are very soft. There is a lot of literature out there 10 and~you can read twenty-five definitions of each one of 11 these things, and each one has a slightly different thrust, 12 but, at least, that is some structure. 13 In this case here, we have personnel search.
- Well, O
14 we have'said, in this case,your site has said, as an example, 15 that the guy who does personnel search is going to be, during to the performance of his duty, maybe not every day, but sometine 17 during the day, is 1. going to calibrate metal detectors, 2. 18 he's going to have to communicate with his radio, 3. he has 19 to be able to recognize and authorize unauthorized stuff, 20 because the rules say he can't let unauthorized stuff in:there, 21 but if he can't recognize it, how can he prevent its entrance 22 into the plant? Finally, he has to take notes. 23 Well, if you've got one in', because'I think it is an ~'T (J 24 example of a non-graded test, we only want you to identify, em '(-) in.your plans, the truly critical, non-common knowledge tasks. 25 L
40 I The example given earlier, I think by Ralph, I think 2 he talked about the security supervisor in answering the j k 3 telephone. Don't put him in there. It may be critical, it i 4 may be very important, toibe able to-answer the telephone, but 5 you have got to draw the line somewhere. Uc assume that he 6 knows all that. That is a common knowledge task. 7 Taking notes, in this case, we do not think that is o a critical task. 9 Now, by criticality, we mean if he doesn' t do it 10 right when he has got to do it, it is going to endanger the 11 plant. Now, notes, that's probably an after-action thing. 12 If he doesn't take his notes immediately, and correctly, is 13 that going to endanger the plant? Probably not. 14 We want you to weed out all the non-critical common 15 knowledge tasks, so that they are included in the plan. 16 Now, to go down to the final level, which as elements 17 These are the knowledge, skills and abilities. Now, let's look 18 at recognizing unauthorized materials. Now this is probably 19 the toughest one of all. Each layer gets a little more nebu-1 us, and I think, in some ways, determining what.your know-20 ledge, skills, and abilities are by how y'ou set up your parti-21 cular tasks. I think in some ways that dictates what know-22 () ledge, skills, and abilities are. 23 You will probably want to structure your program so 24 r.k that you will test to pick an' area, and that it. won't have to 25
l ) 41 I be ra lpart'ia11 test again Lin another area,. but as' you get into 2 this', you will. start getting a feel for it. 1 I 3 Infthis. case here,'we'have ability to be able.to {} recognize. unauthorized material. Now, I saw.three components. 4 5 I sawLa knowledge of. explosives in being able to recognize 6 them. What-level am I talking about? Chemical analysis or 7 something?. No, I mean the security. If he shows a stick of 8 dynamitc~, he ought to be.able to identify a stick of dynamite. 9 Recognize explosives, and I have access reason, i 10 Uhat does a' cap look like, what does a timer. cord-look like? 11 Classic example: we.know of an occasion when somebody came 12 into a Federal,buil' ding to give a demonstration,.and he had 13 a fist full of.the. stuff, the guard opened his briefcase, 14 looked at it and said,,go ahead. So, the guard could not 15 recognize.it,'and he.did not say a word.: 1 ~ 16 Finally,. recognize inciniaries. Basically,.this is. ' r 17 just what specific guidance are forbidden in your plant, and-18 you have some sort of little task to determine whether the 19 guy can do that. The question is:'how do you identify these knowledge, 20 skills, and abilities et cetera, to be developed site specific, 21 and the object is to identify what is required to do the job 22 and what is the job? The job is to implement your physical () 23 security at;your. plant. It is not some other job. - 24 ( Well,.first, you review each paragraph.of,your 26 ce ^; -) e + ~,,.,m .-m..- r-~. -,,m
42 I physical' security plan and try to decide what tasks are 2 required. Secondly, you review your decision actions, in res-m N-3 ponsiblity matrix of the contingency plan. () Now, if you are familiar, and Jack.Rosen will talk '4 5 about this in a few minutes, if you are' familiar with the con-6 tingency plan of the responsibility matrix in some ways is a 7 job analysis. It shows by duty assignment what decision action s 8 everybody has'got to do. 9 What do you mean by decision actions? Well, I think 10 a decision action is very closely related to-the task. It 11 may be the same thing, so you take a look at each one of those. .12 Now, here again, just to identify the critical ones, buF if it 13 is in the responsibility matrix, it shouldn't be there, if (S (/ 14 it's not critical. It is not required. 15 Finally, the toughest step of all is going to pro-to bably be to identify.the knowledge, skills, and abilities 17 required to perform these particular tasks that you identified; 18 for example,,the task might be to respond to an alarm. The 10 knowledge, skills, and abilities may require a police and 20 military tactic. The questions is, does it require police and 21 military tactics? 22 Here again, I think that you have to take a look at 23 your specific site requirements and your philosophy and you 24 have to keep in mind the threat level that we are.trying to y) -25 defend against, and I think, in identifying this knowledge,
43 1 skills, and abilities, I think that you have to rely on pro-2 fossional judgment, yours, professional judgment of other () 3 people in the field, literature searches. Basically, I think } that a lot of credit would have to be given to using approaches 4 5 that have been proven to be successful in the past. But that 6 is going to be a tough one. 7 Now, let's just~take a look, quickly. As you review 8 your plan, what are you going to look for? I'm just going 9 to read these..You review your plans to identify critical 10 tasks associated with the use of equipment, job aids and 11 manuals. 12 Now, equipment. Gosh, you know if he's going to use 13 the metal detector, he should be able to demonstrate he knows %) 14 how to do it. If he's going to use a .38, he ought to be 15 able to demonstrate he knows how to do it. us What do I mean by job aids? Well, you have standard 17 operating procedure cards or something that shows the guy u3 what to do under certain conditions. If that is approved in 19 your contingency plan, that is an all right way to go about it. Then that is a job aid, and something that helps you out. 20 He should be able to demonstrate he knows what to 21 do with that. 22 () References falls in the same category. This is 23 security SOP. If you require him to use it, then he should j 24 (~3 N/ be able to demonstrate that he knows how to use it, and he can 25 l n l J
44 I read'at the level that allows him to use it. i 2 Classical example: a lot of school systems are 3 putting out performance objectives, now, and that is what they () 4 are. Before you graduate from high school, you have to be able 5 to read a street' sign. I am not sure that reading a street 6 sign gives you the necessary ability to read security proce-7 dures'in your plant, so if he needs to' read it, you should have 8 some sort of test to show that he can. 9 Now, this could be combined in other things. You may to have him implement contingency plans at some point that may 11 require him to open up the thing and read it, and then take 12 the next step, but if he gets past that step, and gets onto 13 the next step without assistance, then that tells you, yeah, f-V 14 he can read and understand it. 15 Okay, next, we say the critical tasks associated with 16 the implementation of security procedures. Well, primarily,. 17 this is going to be the responsibility matrix. That is what 18 procedures are, and that is the way they are identified, so 19 we are going to take a look into the responsibility matrix in 20 each of these plans, to see that each one of the critical ones has been identified in the training qualification. 21 22 Next, physical abilities required to perform critical () This is a'tou'h area. As you know, in various 23 security tasks. g 24 safety fields, fire fighting, police work, there has been a b-tremendous controversy over what are the physical demands of 25
~ o 45. Il thisijob, primarily.because they-tend to.be discriminatory 2-f l againsti. women, and there 'has been a -lot-of work done 'to deter-3l mine what are. the: physical requirements.. What is really 4 r'equired? Classical' example: is it. required.to be able to-5- carry Lai 200 pound. weight a' hundred yards. to be a-policeman? 6 Is.it required ' to be able to carry a 200 pound weiglit through ~ i 7: a' window ~~and down a2 ladder?' These tend.to be discriminatory-8- against womrn, and.the question is,.are they required by the' 9' particularJjob?.. ..10 'I think here, that this may be.the' area that.is more 11 site specific than any.other. - You.have to look at your a - 12 licensing philosophy, how your site l's laid out,fhow'you broke 13-down your jobs, how your. broke down the tasks, how you broke O 14 down;the duties, and determine what that guy.needs to'be able 15 to do.- .i 16 If.a. security person.may;be' required to respond.by, 17 the. contingency plan to'any point.on the site within ten minu-18' tes, I think that it.is a reasonable performance:cbjective that f 19 the test of'that ability would be to sound the alarm and equip 20 him the way he would have to respond, because he might have to 21 carry a weapon:that would slow.him down.- Demonstrate : that he. 22 can respond:to any point in the' plant in ten minutes, that he 23 has.the physical ability to do it. If he's got to climb ladders-24 to7get to some. operation point-that is required,' demonstrate that he can dotit. .w.. v_,.- .n__,..
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46 1 You notice we got away from the time run. It is 2 site specific. Some site up in Michigan may require a physical () (_j 3 demand that this guy be able to walk for trouble in the dead 4 of winter, up to his knees in snow. This should be demonstrated. 5 Now, this might be a good point to note that the'way 6 we set this thing up, that it is for the first round of quali-7 fications. In other words, in meeting the initial schedules, 8 you-can set performance objectives that could be demonstrated g actually on the job. 10 In other words, if a guy has to walk ai the cold in 11 the dead of winter and it is an important task, but yet, he 12 does it every single day, the performance objective would be 13 that he demonstrates ability to walk in knee-deep. snow and O 14 yes, he was tested. You observed him doing it during his normal rounds. So you can check that performance objective 15 off. He does it every day. 16 You may have communication checks every day with 37 local police departments. Your performance objectives could 18 be set up in such a way that that would meet the requirement. 10 Yes, if he does it every day, check it off. 20 The important thing is, though, that he meet the 21 standard and the conditions be right. 22 Finally, I have knowledge required to perform critical () 23 security tasks. In our contingency planning, fo,r instance, 24 /~T '(,/ we talk about required knowledge. These are the type things 25
~. -47 '9 a' guy needs to know. '2-Well, knowledge falls:into two categories, and I' 3 thinkEthat' Jack's going to talk'about'this, two' types of' 4L knowledge.- We have knowledge that you look up. In other .5 words, you have time to~1ook it up. You look it up, read'it,. 6 then decide what to do..That requires one level ~of understandi ng.. 7 'Then there.is. knowledge that you have to know now, 8 so we are going to'look at that when we look at your:perfor- ~ ,9 mance objectives'and we look at your contingency plans. With -10 that'in mind, it's called. time. tolerance,~and what it says is that the guy needs to know what happens, what he is su'pposed l it 12 to do when'he sees so'mebody coming over the fence. You can't' put a performance event.that he's going'to go'look it up in 13 .O i 14 the. physical: security or SOP, because, he doesn' t have time. to 15 look it up.. Now, in response ~to a' bomb threat,'it might be a 16 good idea to have it written.'down, so you make sure you get' 37 the major points. It is so capable, but it is'important that 18 he knows what he is'doing when he reads it, that he knows'how. 19 to implement the procedures,.but.'that is a different level of' 20 understanding. 21 ( S,-we set up this structure. The plan says that -- 22 Appendix'B states that you are supposed to identify the stuff 23 in y ur P ans, and we have completed this first step, talking .{ l 24 ia-.- 26 about.the first step,.which is the job analysis, step. n, + - ~ l' 4 4. ls
48 I 'In 0219, we show a method of demonstrating that you 2 perform the job analysis. Ilow are you going to summarize () your results and we do it with a task identification summary, 3 4 a task duty summary, and we have duty descriptions. I'll talk 5 about each one now just briefly. 6 We say that you have to identify the task that is 7 critical to implementation of the physical security and 8 contingency plans. That we would like to see the relationship, 8 so that as we go through the plans, we can see that all the 10 critical ones have been identified. \\ 11 For example, task 31 is communicate with a radio. 12 Now, one paragraph implicitly requires communication.with a 13 radio. These numbers come out of Nureg 220, but I think your Oll 14 plans pretty much follow that. It's paragraph 1.4.5.C which 15 basically says that all the security personnel be equipped 16' with a two-way radio. So, if you read that, you've got to be 17 equipped with a two-way radio, and it implies that he has to 18 be able to use it, so that is a task. 10 Take a look at the second one. Receive and react 20 to a bomb threat. What do I mean by that? I mean the task 21 is yes, he has to receive and react to it'. That's the task. 22 Then you have to tell him the performance objective, how he is ' 23 going to do it. [} 24 What I'm talking about here..is the person who ,,) (, 25 receives -- and you notice here it is tied to event 12 in the
49 1 I contingency plan -- that is so that we can go to.that event 2 and check the decision actions on the responsibility matrix 3 for that. event, and see whether you hit this task and event r-4 (_)- 12 obviously is probably receipt of a bomb threat. 5 Sc, this summary shows the relationship of a task to 6 the plans, because the task was supposed to be those that are 7 critical in implementation, and basically assured that we 8 have identified the critical tasks. 9 This one is complicated, but I left it, I didn't 10l simplify it, and I think it is important you see an example. 11 This is an example-that has Duty Summary. Earlier, we said 12 that personnel are going to be qualified to perform duty, and 13 we are going to qualify them to perform duties by having them 14 perform tests that demonstrate that they can perform tasks. 15 llow do we show the relationship? 16 Well, we thought!this was an easy way to do it. 17 This is going to be hard, I'll try to help, but I'm going to 18 go over and actually point to the slide.- 19 Dasically, what you have is a matrix that shows the 20 relationship of duties to tasks. You have the tasks on this 21 axis, and you have the duty assignments on that axis. A black 22 dot means the guy performs that task. () 23 Now, for instance, duty B, CAS/SAS operator, does 24 not. No black dot. Does not investigate suspicious persons 'eg ~2 25 or events, so he doesn't have to know the exact procedures for S 4
't
- 50
-) 7.. 1 'l going up to some. guy who is climbing overia fence'or cutting a. l hole'in a.. wall or something. But,-your patrol guard does, so 3 i he~~is required;to have demonstrated somehow, however you tested ~ it, his ability to perform that task. r 5 I . Now, here again, we don ' t expect, for instance, if f 6 a guy serves as C. a patrol guard, and D-as a member of the 7 response' team, which probably would be the case on your site 8 -- I don't know site specific -- we don't expect him to demon-i i 8 strate that"twice. Just somewhere in the, records, show.that 10 he has demonstrated his ability for the performance of that' H - objective, to perform that particular task. Even though there c 12 are two dots.there, we dontt expect him_to be tested two s 1 13 times for that. O. 14 4 Finally, we have the duty' description. This basicall f, 15 the duty description format, comes right out of civil service, 16 right out of their job analysis program,right".out. of all of 17 the-literature I'have read on how you present a duty-descrip-i 18 tion. It is a summary of all'of the information found by the .l 18 job analysis. You can' read through and find out everything j 20 in summary form, that is required of this individual. 21 Basically, you can tell what he.is, secondly, just 22 briefly describe the duties he has to perform -- I mean what j l 23. the duty consists of -- third, you.tell'what equipment he is Q 24 going to'use. You actually tie the equipment and the site. and. ] 25, the. physical' security-plan to a duty. Nowhere/'else is that n r + x r...,-, n, v,- +~,,-e, ,,,,.w ,,,.,,.,n + ~,, + m'
51 1 done. 2 Next, you tell what references he has to be able to () use. You know, if.he is required to look stuff up and be able-3 (~) to understand security procedures, he is required to under-4 (t 5 stand' maintenance manuals, e t cetera, put it down. 6 Now, here again, critical to the site security. 7 Don!t put everything down. Critical to site security, being 1 8 able to use a pencil or take notes would not fall under 9 critical. 10 Next, supervision. Does he supervise anybody or is 11 he supervised? This 'gives us a good indication of where this 12 guy falls in the systems so that we can look at the test and 13 determine whether you are. testing his ability to supervise i' 14 or not. 15 And finally, I put down task performed, and that is 16 just a numerical listing of the task. It's not really very 17 important, so basically, this summarizes, in the classical 18 way -- and I would imagine most sites already have some sort 19 of duty description already in the guy's folder. Now, we don't want a duty description on every single 20 individual at the site. We just want, by duty, name,.this is 21 a description, what you mean by patrol guard. This is what 22 23 you mean by TAS operator. /~U' 24 Okay, now, let's get to the performance objectives. () This is where you test thei ability of the guy to perform liis 25
52 1 task-that you just identified. 2 These performance objectives tell us a lot of things, D' 3 so, therefore, it has to contain a certain amount of information. (m) 4 if it is going to meet all of its aims. 5 Now, what does it tell us? It gives us enough infor-6 mation so that we can tell whether it is really going to' test 7 the knowledge, skills, and abilities that is identified for 8 that task in your job analysis. Two, it tells the examinee 9 the standards that he has to meet. We are basically telling 10 the guy he is going to be tested, how he's going to be tes ted, 11 but remember this is an outline. This.is not the specific 12 information of how you are going to test in that specific n 13 time. It outlines how he is going to be tested. U 14 So, the guard can go and look and-say, yeah, I'm 15 going to have to shoot 210 on a PPC on my qualifying range. i 16 I'm going to have to demonstrate that I know when the alarm ] 17 goes off, which alarm zone that is, and I have to be able to 18 show that within a couple of minutes, I can bring up to close 19 circuit for that. It gives him very general information about what 20 standards he has to meet. So, now, we look at it. Yes,.it's 21 a g od test. The examinee looks at.it and knows what standards 22 he has to meet. The plant manager or the management, the 23 l shift supervisor, he knows what standards he's got to maintain. 24 It is right there. 25 l
53 1 As we' talked about earlier, the rule basically states 2 that, at the request o'f an authorized representative of the G.O 3 NRC, you have-to be prepared to demonstrate the ability of 4 your personnel to perform their duties, and that is right in 5 the rule. 6 The performance objectives basically outline how that 7 is going to be done, and you are testing them the same way 8 as we are going to test them. 9 Finally, it allows our reviewers, those who conduct to our reviews, to determine whether this is an' adequate test. 11 1 ext slide. This just shows-where it f alls in - the relationship. It.is the final step, the performance objective 12 i 13 test of knowledge, skills, and abilities. \\ 14 Now, a performance objective should have two charac-- 15 toristics. One, it should define a valid test for whatever 16 you are testing. There are many that -- you read the EEOC 17 business and you read the literature, you are out there, and 18 there areca lot of ways to show the test is valid. We basi-10 cally have said that we are going to do it by trying to set 20 up your test so that there are many samples of the jobs. The 21 guy has to type. In this case, it wouldn't be security, but 22 the classic example is the typists' test, valid test, would be (]~ 23 typing, so it has to be a valid test. 24 You actually have the guy demonstrate the knowledge, i 25 skill, or ability, under job conditions or simulated job conditions. l' ll
54 1 Next, it has to' be a reliable test. Reliability is 2 controlled and' validity is controlled also by controlling the (% C) 3 conditions used in the test that is given. Everybody should ,A 4 be tested the same way. It's not fair to test one guy, he's (.) 5 allowed to use'+he SOP and the next guy isn't. 6 Secundly, it has to be done with the same standards. 7 It.is not f air to have one guy run to a certain point,in four 8 minutes and another guy can do it in three minutes, so it 9 should give this information. 10 So, the performance objective outlines the conditions 11 and it outlines the criteria, so let's talk about the conditions. 12 Next slide. 13 Now, here is an example of performance objectives. pb 14' The thing to remember is if you: read the literature, the 15 classic performa.nce objective has a lot more detail than I've to got here. This is a sort of a boiled-down version.. Take a 17 look. 18 We'vc got.a task which is to use and calibrate a 19 hand held metal detector, and I've highlighted two elements. One, is to use the metal detector. He has an ability to do 20 it, and the next is to have the knowledge.of the procedures to 21 be followed if he finds something. That's all tied to using 22 O e metet detector-23 Now, let's look at the performance objective.
- First, 24
'V. note that one performance objective can test more than one 25
55 l' element.. It can:even test several. tasks. The only key is.that 2 ^ -gt has to.be-structured =in such a way that the guy.doing'the 3 testing can observe'all the things that you are testing. That' .4- - the thing to keep in mind..If you can see him do it and gg 5 check it off;as he is doing it,.then you can combine <as many 8-as youflike into one.- 7 Typically, the conditions and statements in perfor-- 8 mance objectives starts with the word.given,' tells the con-9 ditions. What.is given? Given an exercise with the plant's 10 hand. held: metal detector, he can use the' metal detector.to 11 examine 7an individual with two hidden metal objects of the 12 size and description in the NRC guidelines. 13 What I'mean is the guy that is going to be tested ' O 14 is given the use of the metal detector, and~there is going to 15 be another guy there with two hidden metal objects. Now, that is the condition,.and.when I say NRC review. guidelines, that. L 16 r6 view guideline' you received, you could say site procedures., 17 It would be the same thing. You could say site procedures. ja That ties explicitly to your, site. to S, we've seen how you set up the conditions. -Let's 20 look at how you set the standards or criteria. 21 .The important thing -- I skimmed over it -- is that 22 these should be minimum levels. I know it is hard to set, but Q. 23 y u set' minimum levels. If they fall below-the standard, the 24 performance is inadequate, so set them low instead.of set them - 25
56 4 J1 high, because you don't want -- in other words,'95 per cent of ~ ( 21 your guards;on.'a.particular-site'may do.better.than that,-but' g \\, we are n'ot.looking for, percentiles, we are looking for minimum.
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'3 4 evels.of performance, go, no-go tests. ,( 5 I,et's,look at'this one again. Now, we have..given ~ i 6: this guy or' girl a hand held metal detector for the'siteLused, 17' at;the site,Jtwo hidden metal objects of the size described-
- 8. in your site procedures,-for instance, and what arelyou going
~ 9 to-ask him to,do? 10 He will locate 1the two objects within one minute. 11 I' don't.know if'that's realistic', Within'one minute, so you 12 have given him.this standard. Hp hasJto.use the equipment,. q 13 he has to find the metal: object, and then heLhas to alert '() the patrol guard or:maybe you. could say the site guard. I 14 15 don't know. Whoever.at that point is ' watching this operation, k 16 in accordance with.the sites procedures. Our reviewer.can now-look.at that. He has a very 17 18 good idea of.what is going one.. Since'you aren't required to submit the procedures, you aren't really required to outline 19 them here, and he is going to go-out and check and see if there 20 21 are proceures, to see if they are explicit enough so that-you use<them to see whether the guy is,doing his job adequate 13 . 22 So, now we have identified the task but not the test. { ). 23-How are you going to qualify? 24 /~~i b Well, you just.have him successfully perform each l 25; r i 1 l - ,.,., - -, i
57 1 of those performance objectives associated with that duty 2 assignment. Here again, there are different ways to do. that, be^ '3 nd 0219 sumnarizes simulations, actual performance on the 'O 4 job, getting tests. D 5 But this h_a t-be documented, and we basically felt 6 thab the best way to do this was just to summarize the results 7 In a tabular form, where you show the task, basically the date 8 that he performed all the tasks successfully, the signature g of the examinee:, and the signature of the examiner. 10 Now, remember, these things don't necessarily have to highly structured. A lot of this could be done on the job 33 as he performs normally, but he has to perform in accordance-12 with the standards and in accordance with the criteria. 13 c t We d not require you, 'f you are going to use a 14 written test, you don't have to keep that written test at the 15 site. Once the guy has passed, you don't need to keep a file 18 on every piece of paper that you have used to evaulate this 37 guy. If he has completed a written test, 'and he received the 18 necessary score, you do mot keep h. You don't haw to keep 19 it. You can if you like. You don't have to keep it. All you do is record in the tabular record.that he has successfully performed by that performance objective; in case of a written test, the performance objective would have said that he was give a Written test, and he identified the minimum requirements 24 /^\\ V There are other sections that a-well developed job analysis will meet. The physical fitness requirements
58 I -- not' ice the rule requires'that they demonstrate ~their physi-2 cal fitness. The educational development; naturally. the 3 qualification requirements -- now the security knowledge skills O ena edi11eies, 1e wee e 11ee of e nunarca seeme ie there, ie 5 is not required that you identify those hundred items.in your 6. plan. You do you'own job analysis. You look.at your.own site. 7 Don't worry about that list of a hundred, and you decide. 8 Requalification, weapons training, and we'apons. 9-requalification training. Weapons training is such that the only to performance cbjective that's ever been in.any'of these. rules 11 in the past, so naturally it's just another task, using-the 12 weapon and the performance objective is making sure the guy 13 knows how to use'the weapon. 14 Now, we talked about training requirements. I am 15 sure you realize now that we are concentrating on qualification s 16 -- can the guy do'the. job.. We are not worried about; explicitly 17 how.you develop'these qualifications. It is up to you. Ilire f 18 him.- Ilire him and train him a little bit. 19 You may already have him.out'there. Use formal train-t 20 ing. Use training where you-team'him up with someone else 21 who already knows the job. .You decide. 22 Use programmed tests. Use a computer. As long as 23 the ' guy can-meet ' the performance objectives, you -decide. TOL.,. 24 So, therefore, lesson plans, hours of. instruction, 25 qualif.ication of instructors, do not have to be. included in the . a ~.. - _._ _. a.; . u.-
~. 59 'l plans.. Another comment on the; training manuals. The same l' 3 thing 'that Mr.' Jones said.. 'Since. they essentially contain-j{jf i 4-that type of information, you know, lesson plans and such, we .5 just' wanted to point out'once again that we'sent-out-the-6 reference' material, but you don't have to.take them and. send -7 them back in'and include them in'your plans. It's up to you 4 8-to-decide how best to train your people. ~ 9' One interesting thing about the training manuals; 10 overybody in physical security has been talking about 464, 11 which is the fixed site manual. Don't forget about 465. It 12 is for transportation, but a lot of the items.are the same, 13 and it was developed using job analysis as a basis,.and I ( 14 think it may be even more useful than old 465, if you decide f 15 to go to some sort of formal training approach. So, don't j forget.465. Even though the name may. say it's not mine, it, 16 has a lot of good stuff., 37 So, just'to summarize, it is site specific. You 18 decide.what is required. You develop the job structure. You ig decide what.the job's duties, tasks are. You set the standards 20 I don't have it on here, but you test them, also. 21 We're.n t going to do any testing. 0219 says that before we 22 ()' appr ve y ur plan, we're going to go out and test a few folks N 23 and make sure that you've done it. We're not going to do that. 24 q3-U NRR is going to, essentially, do a paper review. We are not g v u .,~4. ...e m~.. J. F
60 I goingJto test before~we approve your plan. ~ - 2 Finally, and I think very important, you develop D 3 the training method. That is where the effort is. going to be.-
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required.LThat is the important' part. You decide-how to get -5 these. guys'up to snuff, and you do it. f 6 - That's all I have to say. I don't know-who's next? 7 MR. MILLER:.Well, we can move right along. During 8 the meetings on 7355, we discussed with you very briefly>the l 9 contingency planning rule,: which was just being promulgated at 10-that time. t 11 We~would like to touch on it briefly again today. r 12 With that, Mr. Jack Roe from the State Safeguard Licensing 13 Branch will talk about contingency-planning. i .O 14 MR.. ROE: Thank.you, Jim.. 15 During this period,'I am going to discuss the con-16 tingency planning rule. I.shall. discuss the~ content require-17 ments of the plan, the' plan's' relationship with guard training 18 and qualificationJrequirements, and the methods of submitting . ig the contingency plans. I will point out that the contingency plan in guard training and transportation plan are closely. 20 related, and that an integrated approach to these plans will .21 result in substantial: reductions in the effort required for i 22 23 both plans. ] ) 24-The contingency planning requires five. categories i of information,.s.in each licensee safeguards contingency plan. - 26 e ,-v v. v -e - - -, ~. N-e,.,e ,w,'ne.- .,.-w,,-.-nn-a .~... ~.. ~ ~ - -.
61 1 These five categories of information_are background, generic 2 planning base, licensee planning base, responsibility matrix, 3' and procedures. 4 ) Although the procedures are the culmination of the 5 safeguards contingency planning process, and an important part 6 of the plan, they should not be submitted to the Commission 7 for approval. The procedures to be inspected by the NRC 8 staff on a periodic basis -- this periodic inspection will 9 affirm that the-procedures reflect the information in respon-10 sibility matrix. 11 The first category of information is the background 12 section. This section identifys and defines the potential 13 dangers of incidences, and describes the general way the plan 14 will deal with them. 15 The background section will have at least four 16 topics: perceived danger, purpose of the plan, scope of the 17 plan, and definitions. 18 Perceived danger is a statement of the perceived 19 danger to the security of special nuclear material licensee 20 personnel and licensee property. The statement contained in 21 7355A, the performance objective, will suffice in this parti-22-cular area.- 23 Statements that perceive danger less than that estab-24 lished by 7355A will not be acceptable. A 25 The purpose of the plan is a disucssion of the general
62 l 1 aims ~ and objectives of the plan. The scope of the plan is a 2 discussion of the types of instances covered in the plan, and 4 3 lists of those contingencies covered in the plan should be ("N 4 g,/ placed here. 5 Definitions is a list of terms and their safeguards 6 - meanings used in the plan. 7 The next category is the generic planning base. This 8 chapter identifies events that signal the start of safeguard 8 contingencies, and identifies the objectives that terminate 10 the safeguard contingencies. In addition to events and 11 contingency cbjectives, the chapter should include decision / 12 action, to be followed when a contingency action develops, and 13 the chapter should contain the data required to affect the 14 decision action. 15 The objective should specify the licensee's goal to 16 effectively satisfy the contingency situation. Each objcctive 17 should be achievable, clearly identified, and should be 18 measureable. 19 Next category of information is the licensee's plan-20 ning base. This chapter contains site specific information 21 used in contingency planning. The following topics should be 22 included: organization structure, physical layout, safeguards 1 i (w) 23 systeins hardware, law enforcement assistance, policy contrainte g_ 24 and assumptions, administrative and logistical considerations. _(~J) \\- 25 Obviously, your physical security plan may contain
t 63 + 1 much of-thisfinformation'already. 2 Let re discuss : brieflyf each one of these ' topics. ~3' organizational structure should delineate' the organization, th a
- ()
'4 chain of command, the, delegation of authority,'and the1 minimum 5 force strengths. 8 Physical' layout:should describe the site and' the l ?
- 7. nearbygfeatures.
Particular emphasis should be placed: on law 8 enforcement entry. routes, location of control points,.and-9 location of safeguards hardware. 10 The safeguards systems hardware should describe all - 11 equipment.available for~ safeguard contingencies. This topic' 1 12 should address at~1 east communications, intrusion detection', l 7 13 surveillance, locks, weapons, and vehicles. 14 Law enforcement assistance -- this section should 15 list each separate law enforcement agency that may provide you 16 support. This section should provide a description of the- [ 17 response capability and a discussion of-the licensee's working i 18 relationship and agreement with the agency.- 19 Next, policy constraints and assumptions should dis-20 cuss such things as state laws, local ordinances. sompany poli-1 21 les, and practices that may govern your response to safeguard 22 contingencies. This section may. discuss such constraints as .() the use of deadly force and jurisdictional boundaries. 23 24 Last, administrative and logistical considerations. 26 This section should. describe your practices that may influence- --e , - +, e*~., -, - ~ww w ---w
64' i 1-the response to. safeguard contingencies. This section.should l 2 highlight the procedures that keeps - all of your safeguards 3 system hardware capable of meeting.your attendant function, - 1 l 4 and a rothod employed to insure that all security personnel 5 are current'with the plan -and procedures in the. general 6 situation at your site. 7 The next category of information is-the responsibility 8 matrix. This section should.be an array of'the information-8 for each safeguard event. Each array should identify the i 10 responsible' individual and their decisions'and actions required 11 This array should display, on a single chart or group of 12 charts, depending on size, for each event, all decision action 13' and the person re'sponsible to conduct each'one. '- 14 . Responsibility matrix should provide an.overall pic-15 ture of the response actions and'their interrelationships. 16 Last category is procedures.. The procedures should 17 clearly and concisely direct the execution of.the responsibility-18 matrix. The responsibility matrix may meet the requirement 19 for some procedures, and this should be stated in a procedure- . 20 section of the plan. 21 Again, the procedure should not be submitted with - 22 the plan. 23 Now,:I'll explain the relationship between the ' 24 contingency plans in training and_ qualification plans. As we lO .. 25 discussed in the sections on training and' qualifications,
- l f
. p a w ee e <. 5 _ _ -, -. _ _ _ _ _. _ + + _. _ _ _, r--
65' a 1 security personnel lmust be tEained and qualified to perform 2 l ~(). critical security' tasks'.- The/ contingency plan identifies 1 .3 potential' events that must be planned for. These events. R -( ) require the. execution of certain decision actions to meet the objective.of the' safeguard of the contingency. 6 The eventsufor safeguard contingency are.the.same as ) 7 the events .to be considered in' contingency related guard 8 training. The-decision actions.are.the task."The objectives i 9 of contingency-relate'd activity are related directly to quali-10 fication requirements. 11 Responsibility'mhtrix is directly related to the 12 duty summary section. Contingency plans require the identifi-13 cation of events, decision actions, and objectives, and also 14 the training and qualification plan prepares these guards to 15 resolve these instances. 16 Therefore, once the events, tasks, and objectives 17 can be developed to :ceet both requirements of contingency 18 plans and contingency related guard training qualification 38 requirements. 20
- Now,
.I will discuss, in a littlelmore detail, several ? 21 sections of the contingency plan. requirements. The contingency I! 22 rule requires that the plan identify those events.that were I) 3-used singlyi-in the-beginning, for aggrevation of the safe-2 t 1 24 guard contingency. I 25 These events are-the same as the accused mentioned P 6 3 L
66-1 in the-traini'ng and qualification' requirements..The event'or F 2' cue'.is when an individual sees here, that signals him or her O.. ': 3 that a' threat to the site 1 exists.- 4 In'the' cases where the response is the same for-5- several. events or cues,.all the events or cues-should be 6 grouped under a single-event for event description. IIe re,, -7. care must be taken to select. an event. description that indi-8 cates what events are covered.. Every attempt.should be-made ] 8 to' reduce, to the-minimum, the number of events. categorized' 10 by different responses. ~ 11 This will' reduce the number 'of responses an.. indivi-12 dual'must know,'and-increase the' reliability.of the force. 13 As pointed out in guide ^to Reg 0219,. recognition of I 14.- i'mproper reaction to'certain events lor cues can-be critical. l 15 For example,.recogniti6n of an intrusion can be very important 16 to site security.- 17 Therefore, the recognition and reaction to critical-18 cues, identified-in the ' contingency plans, should be tested . 19 as part of the qualification requirements. 20 The rule requires decision actions.- In supporting 21 information, you need to bring;about that a successful ~ response 22 be-identified. These dacision actions'are the-critical: tasks 23 that' are performed in dealing with the safeguards contingency .24
- Therefore, the decision actions-and cantingency
~o..' 26 related tasks in the training and. qualifications plans or [ f - 1
67 1 be'the same, although come minor differences in the form may 2 be required, since the task statement does not include what (m,_) 3 will be done. 4~ 73 The staff feels the decision actions or tasks should \\_/ 5 be straight' forward. It is unlikely the guards will follow or 0 have-available detailed written procedut^ during a. fast-breaking 7 emergency. There are two types of decision actions or tasks. 8 Some tasks can be performed successfully even if 9 the individual takes time to look up and follow a written pro-10 cedure. Others cannot, and we will require immediate action 11 based on training. 12 Tir.o delay tolerance should be taken into consider, 13 ration when developing contingency procedures and performance f} 14 objectives used for personnel-qualification. The contingency ~' 15 plan requires definition of the specific objectives to be 16 accomplished, relative to each event.. 17 These objectives are indicators of the site's ability 18 to respond successfully to the events. For example, it would be 10 be impossible for a site to test its ability to respond to 20 an actual attack. Howver, demonstratable objectives could be 21 set to indicate the site can repel an attack. 22 The objectives, therefore, should be measurable. IT 23 They should be achievable, and an indicator of the site's G 24 ability to react to an event. (,/ 25 The rule requires, and it is part of.the audit proce-
68 ~ 1-dures, the task'of 'safeguar'ds._ systems performed-yearly. The 2 contingency objectives will _ set..the acceptable level of' per- '3 formance of these tests or drills. They'will define what i 4 must he' demonstrated to pass the drill. 5 I want to point out specifically that part.7340 6 requires an audit and' test contingency plan. It state's thatLthe 7 licensee shall' provide for development,. provision,'implementa-8 tion, and maintenance of the safeguard contin'gency plans. The 9 licensee shall provide for review at least every' twelve months i 10 of the safeguard contingency plan by individuals independent 11 of security program:ranagement and_ personnel who have direct 12 responsibility for the security program.- 13 The review shall include a review and audit of safe- ~ 14 guard contingency procedures', an audit of the security system, 15 testing and maintenance program, and~a test of the safeguard 16 system, along with commitments established for response by-17 local law enforcement authority. 18 The results-of the review and audit, along.with tg' recommendations for approval, shall.be. documented-and reported to' the' licensee's corporate and plant management and kept .] ~ 20 available at the plant for inspection. 21 As was' discussed, qualifications plan requires that 22 for nach-critical security task performed, the performance 23 _ d bjective~be established to test the ability of:the. individual 24. i 25; to perform ~these tasks, and we-have seen the. contingency plan
69 1 objectives he established to test the ability of a site to 2 respond to events. ) 3 The site's response is no more than the correct r 4 performance of decision actions or tasks by the responsible 5 persons. 6 It is obvious,.therefore, that the qualification 7 plan, performance objectives, and the contingency plan objec-8 tives must be compatible, and in many, many cases, the same. 9 The objectives are the same to meet the requirements for 10 qualification, performance objectives. Correct performance 11 can be demonstrated at the same time during a yearly drill 12 or a test required by the contingency plan. 13 The rule requires that,'for each event, a tabulation f]. 14 shall be made for each responsibility or duty assignment,- 15 depicting the assignment and the responsibility for all 16 decision actions, which are tasks to be taken, responsibility 17 or initiating the event. This is the chart that shows, for 18 each event, what duty assignment performs a critical task. Its counterpart in the training and qualification plan is the jg duty summary, which shows what duty performs that task. 20 The duty summary and responsibility matrix will be 21 checked during our review for consistency. Responsibility matrix should contain the same r-Lx ) decision actions as identified in the general plan base. As g () I have already stated, every attempt should be.made to keep 25
70 1 the different responses and tasks to a minimum. 2 There are three approaches to submittal of the con-3 tingency plan. They are a self contained plan, a plan that references the, physical security plan, and a plan that is a 5 revision of the physical security plan. 8 The first approach is to submit a contingency plan that is self contained, and does not reference any other 8 documents, such as the approved physical security plan. 8 This plan shall include the five categories of information 10 required by the rule. II A second method of meeting contingency plan require-12 ments is suggested by the rule itself. The rule states that, 13 e to the extent that the topics are treated in adequate detail, 14 that the licensee's approved physical security plan may be 15 incorporated by cross reference to that plan. Thus, this will 16 require that the contingency plan be prepared as outlined, in 17 regulatory guide 554, that allows referencing of the physical 18 security plan in the licensee's plan and base. 18 If this approach is followed, an extensive revision 20 to chapter 8 to improve the physical security plan will still 21 be required to make it compatible.with the separate document. 22 ~ The third approach is to revise to improve the O 22 physice1 security g1en. Thie wi11 reeuire rewrieine most of 24 the chapter 8 of the approved physical security plan, to follow V 25 the format required by the rule highlighted in' regulatory guide
'71 'l 554, and it is' to include the background, the generic planning 2 ~ base, and the responsibility matrix information required by () x_ 3 the rule. I1-N 4 (, The information required in the licensee's planning 5 base will already be in there, and it may be required to have 6 some_ additions to the appropriate sections made to bring it 7 up to requirements to make the contingency plan work. 8 This conclusion of my discussion on contingency 9 planning and this summary shows the topics that I have discussed. 10' I would like to turn the program over to Jim Miller. 11 MR. MILLER: I think, at this time, it is probably 12 best, before we get to the meat of the program, which is 13 Mr. Clark'and how are we going to review all of your material, rs (-). 14 that we break for about 10 minutes, and then lunch will be 15 served in this room, and I think what we have to do is sort of 16 move out of the way to let them rearrange the tables. 17 Let's be back in about 10 minutes for lunch. 18 (Whereupon, a luncheon recess was taken.) 19 20 21 22 I V 23 24 25
72 AFTERNOON SESSION 2. MR. MILLER: I-think I have given you now all the 3 background that I can', but at'this. time, a man'who is respon-4 ( sible for doing reviews of-your guard training is going to 6 say a.few words about just how the. reviews are going to be i 6 scheduled. 7 ' Bob. 8 MR. CLARK: I think I have met most-of you at one. 9 time or another, but~my name is Bob Clark. I work in the 10 Division of Operating' Reactors, in the Reactor Safeguards 11 Licensing' Branch, and I guess that, while I promised you some-12 thing special this afternoon, I think they were referring to 13 the question and answer. period,. rather than wliat I will have
- o, 14 to say today.
15 But, I do want.to. talk to you about-several things 16 in th_ few minutes that I will be here at the podium, 17 I am going /to discuss the reduced schedules, some-18 of the review procedures for contingency plans, and-for the [ 19 training and qualification plans, and:I will also cover some 20 of the items of interest which relate to how these schedules i 21 apply to CP's and OL's, and tend to mention, briefly, the 3 22 amendment procedures and I will also talk:to you a little. bit ]) 23 about fees, which I am sure you are anxious to hear about'. ' 24 As you know, some of the dates which'are mentioned i l l25' in. Regulation Appendix _ C. and Appendix B of part. 73 are pretty t _ _. ~,,., _ _,. _ -.,....,
1, .f ; ~ 73. .1 1 1: specific. for the contingency plans.: ;The plans-are due-for'all i ~ 2 operating. power: factories 1on: March 23, 1979. t 'The contingency plans become effective? thirty _ days-after NRC approval. -Prior'to the plan.becoming effective, the; licenseo shall demonstrate the following: that' all(safeguard - of capabilities specified 'in the safeguard contingency. plan are-7 available and functional'; that they do have detailed procedures 8 developed,'according to? Appendix C.and that these are in place; and,.also.they.will have all'of the' appropriate personnel b 8 10. trdined in the 'various.. response and duties related Lto the1 j 11 contingency' plan, as specified in the detailed; procedure. 12 ggy, as it relates to'those:who'are not quite ati 13 the point. of having an. o~perating plan, - the regulation itself; 14 - does not' speak.to the submittal ~of CP's-and the. submittal of '? 15-OL's, so we have developed-the following guidelines, which we would like to suggest to you. 17 For those who willLbe" submitting applications for ,a 18 construction permits, we-expect that this particular stage 18 that you'will submit with your' application,'with your PSAI, 20 an outline of your' contingency plans, and a commitment that yot. 21 'will develop one in accordance.with' Appendix C. ' 22. -Now, that should be submitted with your application l. lO; for e -neerecei-germit. 24' 'For the operating license' application -- and here I L .y 25 cam speaking about the time that you submit your. finalisafety g 1 u. .2. 1,_ ~.
74 ~1 analysis ~ report,.the'FSAR, and'that should have accompanying 2 it a separate document, withheld from public disclosure, the 3 security-plan'for'your' site, and if this is submitted prior 4 -(). to the effective date of this rule, namely, June 6, 1978, then 5 we'would expect you'to' meet the date that is suggested-in'the 8 regulation,~namely March 25, 1979. 7 If-yourJFSAR is submitted after the effective date, l 8 after June 6~, 1978, but before March 23, 1979, while the con-9 tingency plan is due then, on March 23, 1979' or~one hundred 10. .i and'eighty days prior to fuel loading, whichever is the later . 11 dat'e. 12 j Now, for those OL applications, which occur after-13 March 23, 1979, your contingency plans should be-submitted ' O 14 with the SSAR. For the training and qualification plan, these 15 are due on August 18, 1979, and it.is indicated in the rule l 1 to that these plans must be followed 60 days after NRC approval. t 17 So, that means that you submit it for ourireview 18 in August, after our-review'and approval, you have: sixty days 19 to put the plan.into effect and begin - training;your people 1 l 20 ' under-that plan. Also,. submitted with the plan should be at 21 schedule to show'how the securityJpersonnel.will be. qualified-22 within two' years after the. plan /isl approved. j O' think that this'provides~you' adequate time.to
- 23 S
bring all of the personnel thatiare in your security organi-5 24. 1 i 3. zation up to the level of performance that is proposed in your i i s
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'75 4 I training'and qual'ification plan.' .2: It becomes a l' ittleL more complicated in ~ the matter l 3 of CP's and OL's, as for the training and ' qualification plans,: () but'we.would suggest tolyou the.following: 4-5. Forfthe construction permit, the. training program 6 outline and a. commitment to Appendix -B, page 73, submitted with i 7 the PSAR application,: 8 For the. operating license, if'the FSAR is' submitted 9 prior:to.the. effective date of approval, October 23, 1978, t ' to your training plan'would be due Adgust 18, 1979, and then, of 11 ' course, the number' sixty days after approval on the two years 12~ for full implementationLare included for those particular 13 sites. O 14 The operating license, where the FSAR has submitted l 15 after.0ctber 23, 1978 but prior to August 18, 1979. The 16 training ~ plan should be submitted by August 18, 1979 or 300 1 17 days prior to the fuel loading.date, whichever,'is later. j i 18 Of. course, in the matter of implementation, we would 1g expect you to have all personnel trained to the plan-eighteen months after NRC approval. 20 Now, for those who submit applications for operating [ 21 r 22 licens,e'after August 18, 1979, the training plan should be (]I (23 submitted with the FSAR, and your. personnel'should be trained pri r to fuel loading.- 24 ' 26 The contingency plan review will focus on the follow-
76 1 ing areas and as you might expect, they are very close to the 2 areas described in Mr. Roc's presentation. We will be looking ('/T 3 at the events, the objectives, the decision actions which you s-(]) have described, your planning base, and your responsibility 4 5 matrix. O our plan for review is to use the knowledge and 7 expertise that we have developed about your sites and your 8 security plan in a review of the security plan submitted under 0 7355, to the naximum extent possible. It will be the respon-10-sibility of the reviewer to determine if an additional site 11 visit is needed during his reivew of your contingency plan. 12 If he feels that his f amiliarity with the site from J 13 previous visits.is adequate', there will not necessarily be a 14 site visit. However, the Inspector from the Office of.Inspec-15 tion and Enforcement will visit your site to review the to procedure that you have developed in connection with your 17 contingency plan. to This is the traditional review that is performed by 19 the people in the safety areas, which our plan periodically 20' state. You are all familiar with that. 21 .in reviewing the~trhining and qualification plan, 22 we will be looking at the plan that you submit to us to deter-() 23 mine if the task and the elements that you have described 24 are in keeping with your security plan or your contingency f] 25-plan. We will interested in the description of-.the_ duties of
77 1 the personnel on your security force, in your security organi-2 g3 zation. We will be nost interested in the performance objec-(-) 3 tives that you outline. Those things that you feel an indi- ./"N vidual must achieve to_ demonstrate his skill and knowledge and 5 ability. 6 We will also review again those items of equipment 7 which you are providing to make sure of the objectives of your 8 security plans, contingency plan. Here again, we will determin a 9 whether or not a site visit is necessary, based upon the 10 experience and knowledge of the reviewer of your site and your security plan. 12 We hope that we can benefit from our previous visits () to your site. To test the materials, we certainly want you 14 to describe in the objectives that you are going to reach, 15 many of the things that your tests will demonstrate, but we to will leave it up to the Office of Inspection and Enforcement I to review these materials at your site. 18 Let's go on now to the matter of amendments. I am ID not going to spend a lot of time on this particular topic, 20 but, as you understand, somewhere in t'he not too distant future hopefully, many of you, before February of 1979, you will have 21 1 22 identified the security plan development under 7355, as the s r,) 23 approved plan for your site. This will occur, of course, i 24 (-) after our approval and the inspection by our RNE to tell us % /. 25 that the plan is fully implemented and is in place. 1
78 1 That then will be identified as the approved plan 2 for your site, as a condition in your operating license. 3 Itaving done this, you become subject to those parts of the h 4 regulation which are found in 5090 and 5091, where you find it 5 necessary to make a change in your security plan or contin- - 8 gency plan, and we suspect that you have adequate experience 7 in that process, so I don't need to dwell on it at length 8 at this time. 9 We do want to point out to you again that, under 10 5054P, there is the opportunity for you to make determinations 11 that you are either augmenting, but certainly not decreasing, 12 the level of' security at your site by making such changes, 13 and these events, of course, do not have to be submitted for 14 our review and approval, but may be accomplished by notifying 15 us within 60 days that you have made such a change. 16 Now, if, in our review, we come to hard points 17 where we agree / disagree, we are going to do everything.tn can to 18 resolve these points prior to the writing of our security P an or evaluation report. But, as I have mentioned.to you l 50 20 Previously, if it comes down to a point where it is necessary 21 for us to make it a requirement or -- a security plan evalu. 22 ation report -- we will communicate this to you and give you 23 the opportunity to appeal to the NRI management, and if we 24 still find that we cannot agree, then it is our intention to 25 make it'a point of modification of your license, where we will 9 n e
79 1 require' this particular ! tem if we feel it is important to the 2-security at your-particular site. .n 3 Lastly, let me just talk'to you briefly about the .(m 4-matter of' fees. I think it was last February that.the new g 5 fee schedule was published in the Federal Register, and it 0 now applies to things that are submitted to us for review,, in 7 the way of amendment. 8 This 'uill apply to the contingency plan and to the 9 guard training plan, training and qualification program. We 10 mentioned to you that:-the qualification plan, when you file 11 these two things, you should file with it a determination of 12 the amendment class that you feel it falls into and state the 13 basis, as a part of the amendment request. t 14 Also, you should-submit, with this application, the 15 fee that is appropri~ ate for that particular class of amendment. 16 We will evaluate the proposed class determinations and we 17 will inform you if reclassification is required. 18 I guess we have studied this problem, and we have 19 also discussed it briefly with those who are in charge with 20 responsibility in NRC, namely the Licensing Fee Branch, and 21 it is the staff's judgment, at this time, that these amendments 22 will be class 3 amendments, l r' ' (_) 23 You may want to take issue with our suggestion here. 24 We offer it to you as a suggestion from our discussions with l 1) 25 these people.
~. 80 j 1 LI;guessfiniconclusion,.I would like to just make -2 one comment of a general nature. We havo.made-a lot of progres s 3 in the past year, since we met'in. Region 2 to discuss the }} 4 requirements of 7355, and-certainly, I am most appreciative 5 for the cooperation we have received from the licensees in' 6 working out areas of disagreement and seeking for clarification 1 7 on some of the staff positions, and I certainly feel that it i 8 has'been; demonstrated to me that all of the licensees in this g region have.the.same objective that we do as the staff of the 10 NRC, and that 'is to' see that an appropriate level 'of protection ~ 11 is provided for their facility. 12 I appreciate your cooperation in this area. Now,. 13 I think you can recognize from;the presentations that.have 0 14 been made thus far;today that uhat we have been doing up to nw s certainly closely felated.to what we are~ going to.be 15 doing for the next severa1' years, namely, reinforcing some of .18 the areas which are presently.discussedlin your security plans, 37 namely, the area of training and that section in your security 18 plan which discusses contingencies. i 39 We pledge to you our determination to work ' closely 20 ..s with you during the review process to-assure that our objectives are met and that we are satisfied'that these objectives are l () appropriate (for your site. 'Thank'you very much. . 24 r 25 ' J 4 m e a a =' - = w v w N-k,- ,L n +st-v+-<~u .s-'r +u --n-we--g-w, ,-vv p ' + ' - .r
- 81-I I UESTIONS AND ANSWERS Q
a 2 MR.' MILLER: ~ Ladies and; gentlemen-the meeting is ._s. .c 3 now yours.. ; We 'are ' open to any 4. ques tions and answers. - Please 4 state ~youriname. 5 MR'. RUNNER: My name is William Runner,.Vir'ginia ' 6 Electric-Power Company. 'I would like to address a questions 7 tot r. O'Reilly, please. M 8 I.would like to.have INE Region'Two's position or ~ o 9 procedure policy, as theDcase may be, on the licensee's res-- 5 10 ponsibility subject to inspection. :The problem I.am concerned ~ 11 with, I have'been given' previous guidance by a-supervisornof 12 the inspectors.- of' Region Two that we aret responsible. for l . 13 . implementing our security program, and we are furtherlrespon-14 sible for security procedures.which implement that program.- ~ 15 It is assumed.that the security plan fulfills the to requirements of-the Federal regulations of various regulatory 17 guides. As it is NRC's position that all regulations'do not 18 have to be met to the letter of the regulation, where equi-19 valent means can'be' demonstrated and' approved by NRR, I have 20 a recurring problem.with a Region Two inspector not' feeling 4. 21 that what we are doing in our procedures, implementing the 22 ' security plan, as being adequate or sufficient.to. comply 23 with the regulations. j - () 24 I-have.been given guidance.in the Region Two super- ..isors, that when-this occurs, the procedure is.that,the ) ~- 25: v U I j 1 . ~.. - a., ,, ~ _. .,c
82. I' inspectors 1will go.back to Atlanta, refer their problem to 2 7 whati we ' are doing to NRR.- If they can convince-NRR that-they. 3 L are correct, NRR-will correspond with'us and direct us to 4 amend:our procedure,or amend our plans.accordingly. 5 However,we:wouldn't be' subject to, items of-non-9 6L compliance forKthese kind of deficiencies,-but each time we 7 get a-new inspector or each time we get a new supervisor, we-8 have to.go.through.this routine again. 8 - .I would like to hear from Mr. O'Reilly, is this to still the policy.of. Region Two and if not,;what-can we expect? .a 11 We'need to know'what we are accountable for.
- 1 12
.MR. O'REILLY: -It is not the policy.of Region - Two. 13-or-any other region,cother office of inspection and enforce-1 0 14 ment to take'any enforcement' action unless there is a require-- 15 ment. The area, I-think, that really'comes up.as perhaps: 16 an interpretation of the requirement.- 17 Now, if--there-is a disagreement between thelinspector 18 ' and the licensee, usually.you talked about an inspector and 19 a licensee, I believe, or you should. talk, perhaps, to the 20- inspector versus the man'he iexited with, and-I would'say '21 following.the inspector, which may be the plant manager ofi some plants, and-he'is perhaps,;.onl rare' occasions,.the senior-u 22 ' 231-security representative ~atLthe plant. o 24 There is-a,differenceLthere an'd it is identified.- .26 The inspector has'upon-himself'an. obligation of-identifying-s s
~. '83 l' who-islthe supervisor-within any' Region office, and I think 2 on your side.of the issue, that.you would do the same,.and 3 'to identify the problem with any respect, to go to a higher 4 level.of management and get back within the high level of 5, management, within the Region of fice. I am unaware of any significant differences in this 8 7 area between VEPCO and Region Two. '8 - MR. RUNNER:. Well, I wanted to generalize.. Let me 9 cite you a specific, simplistic chample. 10' Compensatory measures is an awkward situation during 11 this transition period between the approved plan and'imple-12 menting'the MAST andithe May 25, 1977 requirements and so f rth, and,,under the MAST, we are supposed to clearly define a 13 what. compensatory measures we have taken for certain degraded-14 hardware or whatever the case may be.- 15 Ilowever, during this period, what we write into our. 16 1 i procedures is compensated for a degraded security condition.- g We feel'that if we foll'ow our procedure, then we should be 18: inspected on our procedure. jg ' When the inspector walks in and he looks at what g. we:are'doing, and.he does not believe what we are doing, the compensatory is adequate, we feel that we should not be cited O k because, in his opinion, what we are doing is not adequate. As long as we are following our procedure, we feel .g that is-what we. should be. inspected on, and now, you'know, 2E .m. . m. a <,-1.:n+~+. .r -e a ~n -n --e v
84 l 1 'if'he. thinks there.ought to be four patrols when.there are 2 three patrols, this is a potential problem. ( 3 I-have not had any real difficulty with the inspec-i 1 () 4 tors. Inimost cases,.they have been-reasonable, but I hate 5 to: get'into these confrontation situations if they can be' 6 avoided, Land we-know what is expected of us, then we can 7 avoid these kinds of problems. 8 14R. O ' REILLY : The fact that'you write a procedure 9 does not mean,Lin effect, that NRC is going 'to accept it. 10 So, if your procedure was reasonable, I wouldflike to think '11 that if you anticipate any problem with the inspector, Ilwould' 12 like.:to think that NRC would agree with it. 13 If your procedure is' inadequate,Ein regard to appro-14 priate compensatory actions, I would expect the inspector 15 would and should take issue with it.: 16 But, now, when you have that type of con'rontation, f 17 which you would not accept, I would'like you.to feel = free -- .18 as a matter of fact, I wish.all of you would be very active ~ 19 and take it up with the NRC, in this case, like you would like. Do it at the next appropriate managerial level to get the -20 issue' resolved before we end up in formal correspondence 21 between the Region and the utility. 22 We-also-will meet with.you if you have any particular 23 q problem... I-don't like to get involved and' exercised.if1I;.._: 24 V $25; don't think that has any substance. t
~ 1 85 I 'If'I find our inspectors are' wrong, we.wil.L change ~ 2-it. I don't know whether I have answered your question, but [ /~) V 3 many times I hear comments about differences between people. I ~ -[Jl 4 I.think really, although this may not be the forum 5 for it, and I don't.think we have time to pursue it, I think l 6 you have'to get down to. specifics, because you hear a lot of 7 general comment. You talk about your procedure. You assume 8 that any re dedure is adequate, and you assume that the 9 inspector would see it not too far along,-and I think the facts 10 of the case should prevail. 11 But, we always will listen, and since I am personally 12 unaware of any particular problem of VEPCO in regard to this 13 difference, I thank you for calling this to my attention. O 14 MR. RUNNER: One final thing, Mr. Miller. I find 15 a real problem with what we have been given today'as_a defi-16 nition of a critical task. Perhaps we won't resolve it here, 17 but the way I understood it, critical tasks should be included 18 in our qualification training plans. They are those tasks to which are necessary and important in the prevention of the 20 sabotage of the plant. 21 Then, almost in the next breath, I heard critical 22 task are those tasks that are necessary to implement the secu-i h 23 rity at the contingency plan. There are many, many tasks 24 that must be implemented to keep them in the plan -- records 25 keeping and alarm testing are two examples. 4
86 [, 1
- Records'k'eepingfand alarm' testing, if not performed, 2
I don't-believe wouldccontribute~to.'the sabotage of the plant. ~ h .I.think you need to work on that-a little bit. Otherwise, you 3 are. going to getT a. wid'e variation of what is a critical 5 task and'yo'ur.'submittals are not going to be uniform, if'you
- 6 will
- think'about that.
7' MR. McKENNA: I think you hit it right on'.the head. 8 When I'say I. implemented the plans,.I mean the critical tasks-8 in implementing ~the plans, and critical'ity, that doesn't really 10-carry through. And I do mean the. tasks ~that are -- if a 11 critical task is any task that, not donc properly, when required, could lead to sabotage.of the plant, and record's 12 13 keeping, taking notes, maintenance on certain pieces of Q_ ,1 14 equipment et c'etera, et cetera,.et; cetera, aren't critical-15 tasks. 16 Is,there'any other-ques. tion? 17 MR. MILLER: Yo'u!did'have a good point, Bill. 18 Another question from the gentleman in the. brown 1'I 19 suit? 20 .MR. BUCKilER: I am Jerry Buckner, Florida' Power. 21 Corporation. If I understand you correctly, when you speak 22 about the security plans and.the contingency plans, and tl-23: guard' training plan, is-this to be one document, with the 24' contingency plan and.the guard. training a part of the~overa.. 251 s e c u r i t y p'l a n ?.- V4
87 1 .I believe.that'is the way you intended it to be. 2' MR. MILLER: The: contingency plan rule states that 3 the contingency plan.can be a part of the security plan. One ('JT 4-. document. \\ The guard' training plan was not contemplated that 5 that could be incorporated into that same document, so you 0 could end up with three documents, the security plan, the. 7 8 contingency plan, the guard training plan, or two documents, the contingency plan, security plan and then the guard training o 10 plan. 11 MR. BUCKNER: Again this question comes to. mind, how detailed these plans should be. When we initially started b 12 to rewrite our present security plan, we got suggestionsfput 13 g 'A f out as to what type of security. It was suggested that he 14 h would make the model and this type of detail. I think we-i 15 pretty well agreed that this is not what you are speaking about 16 as far as detail in these plans. 17 Can you put out any input as to what we are talking 18 about now, in terms of detail? The guard training, for y to i instance, do you want a complete training outline or a complete 20 training program or basically are you talking about a training ] 21 outline? 22 MR. PAGANO: I think the answer to your question is j () 23 we put out guidance in the form of acceptance criteria, as 24 ]S's._/(~~T far as the security plan is concerned, in 0220. That has the 25 i i
m 88 1 detail that we would like. to have seen in' the plan. 2 As far as the training ~ is concerned,we just put out 3 recently'a document.0219, after two drafts went out for copy, ) and that is structure on how we think the training program 5 should be designed. 6 As far as a contingency plan ic concerned, there is 7 already guidance out in the form of Regulatory Guide 554. At 8 . the moment, we don't have any plans for issuing any. additional 8 guides. We think that is sufficient. 10 Does that answer your question? 11 MR. BUCKNER: ' Basically, yes, sir. Again, I am 12 thinking in terms'of site security procedures, really portain-13 {) ing to the entire training plan, really the meat of the 14 subject. 15 MR. PAGANO: Yeah, that's true. The way the guidance 16 is structured istthat a lot of it is to be contained in site 17 specific procedures that is available on site. 18 MR. BUCKE5 And we could reference these procedures? 19 MR. PAGANO: Right. Absolutely. 20 MR. MILLER: Let me ask maybe some of you. Do you 21 think thatcdditional guidance in this area is needed? Do 22 you think there is enough? We are looking for help, too. 23 A SPEAKER: Jim, well, would not the workships be 24 the answer to this? .O IS MR. MILLER: Well, we were going to come to that
89 1 in'a second, but maybe this is a good time. 2 We have solicited, as we mentioned, from EEI, whether pQ 3 they think the workshops should really go on. We also. 4 solicit from you, do you think that workshops on job analysis ] 5 and.the related part should be hold? Can we help? Are you o far enough along that you think you can go on your own? 7 I don't know any other way to do it but a show of 8 hands. 'Is there anybody -- let me put it this way. How many 9 think that we should hold the workshops on guard training 10 job analysis, that type t.hing? 11 (A majority of hands were shown.) 12 Thank you. 13 MR. SAUER:. 'I am Curtis' Sauer with the Tennessee t 14 Valley Authority. As to the previous question, I guess what I would like is some assurance -- and I think this should be 15 10 addressed to Mr. O'Reilly -- and that is, if we do identify and follow the format generally suggested in Nureg 0219', a 17 18 task which might be one of a monitor, let's say, who would 19 be given various responsibilities in his job classification, such as personnel search, package search, vehicle search, 20 pe' haps the vital area of door monitor, and badge him, this r 21 particular individual might have all of this in his job 22 O 22 w do --.try to cover as broad an area as we can. That might 24 be advisable somewhat. 25
90 1 ~ If he was assigned to a post at the time the inspec-2 tor came, that consisted of nothing more than package' searching )' 3 could we be, would we be reasonable in assuming that he would () only be tested against the task or.the duties expected of 4 5 that post and not the broad range of duties which would be 6 included in his job description? 7 If we could have this type of assurance, it will 8 enable us to train an individual in a narrow job function and 9 utilize him say, at shift change, doing this specific task 10 that would not be too difficult. In fact, it might be very 11 simple. Then, in off-change, when we did not need him 12 seraching and we did not need him for searching, we could 13 continue to train him in other tasks that would be included O 14 in his job description, such as maybe vehicle searching, door 15 monitoring or badging or whatever, as long as we were not to using him in that function, but we just were training him 17 in that function? 18 Do you see what I am getting at? Even though his 19 job description might include four or five different duties, 20 if he were only performing those duties and responsible for 21 those duties in one of the narrow functions, could we be 22 assured that he would not be tested by the I and E people in () 23 a broad range of categories?. 24 MR. O'REILLY: The individual you are talking about 25 would not have performed other duties? 9 --ev<
91 MR. SAUER: His purpose.for being_there that day 1 2 would bc.two-fold. One, to do,to perform the search function, 3 maybe' operate _a' sniffer _or a' metal detecor. Nothing more. ) 4 During shift change, he would'be responsible'for.that function. 5 How, just as soon as shift change was over, rather 6 than sending him.home, we might be then training'him, coving 7 as we refer to it, with another officer who was qualified say-8 to badge, to do the badging' function, under his supervision ~. 9 Or training him along with the man that is doing vehicle 10 scraching. He would be out there watching, seeing how it'was 11 done, but he would not be by himself. 12 So, he would be in a training position at that point, 13 not. expected to,know everything about vehicle searching, but () 14 learning. .15 MR. O'REILLY: Absolutely. I agree with you.- You 16 have that assurance. 17 MR. MILLER: I agree with Mr. O'Reilly. What we 18 have in mind, if you have the individual, first he has to be 19 trained to do the job that you have him doing during shift 20 change, and then, that is essentially his only job that he is i 21 trained for, and that is what he can be tested against. 22 MR. SAUER: Even though his job description may be ( much broader'? 23 (%l 24 MR.. MILLER: His job description may be something 25-clse. Now, if you have him on patrol with someone else, I
92 I lodrning the patrol function, but the day you put him on patrol 2-by himself, that is the day that he can be tested. 3 MR. SAUER: 'Very good. One comment with respect to these workshops, Jim. 5 Frankly, without the workshops I am afraid, in spite of the 6 time, that it appears to be a long time, we know how f ast years 7 go by in this business -- unless we do have the workshop' type 8 of help, therpecific assistance, my. people who are representing 9 you and your interests, I'm very much afraid.that'we are going to to end up submitting our. plan half a dozen times, to find out 11 that we arc right down at the deadline and.we don't have an 12 approved plan. g So, the worshops could avoid this. 13 V 14 MR. KNOWN: Dan Known, South Carolina Electric and 15 Gas. I would like to extrapolate on a' point that I thought 16 was trying to be made with the gentleman from VEPCO here. 17 7 vetheard a term, approved,used in the context of the T & Q 18 or training'and qualification plan, and also the safeguards 19 - contingency plan. T).at is a little new to me, from previous 20 NRC experience. 21 Normally, we did not get approvals, we got stop 22 commenting on or people said it was okay to use or never any ( . 23 real formal approval. It is a little bit of a change, and I 24 think the question was saying to me, was; given that we have gV. had that now happen, the admitted security plan, the three 25 s - -r 0
7 ,93- ] + t 'l-quhlification plan'and the safeguards contingency plan,.and 2 NRR. approval,f let's say there are=some things in there:that are j 'q ) 3 alternatesLor interpretations.of what-the-law says,'and'that
- t" 14 ther'e are senantics points available.
5 I think.the' thing that.I am ' concerned.or interested-t 6 in,will-it'be-~I and E's position that when they come in,'they 7 will useithat security; plan as the base document rather-than-8 the law or.the' regulation. In other words, it would.be1out j 9 of their. purview to interpret.what the law means? [ i 10 MR. O' REILLY: : Well, ' if you have an approved NRR 11 plan that is the law, the question is, you'dochave'some things [ 12 that you.just physically cannot do, for some reason, the law 13 tends'to indicate that'that would be-ascribed as~ approval.by O-14 tho-NRC asideviations'from that law.- t 15 -Yet, at the present time, there are,'in effect.right' 16' now, approved security requirements and also additional require t 17 ments in the regulation. That nakes it a little complex, in 18 the new phases of some of the regulations.- That has caused to some of these problems. 20 .MR..SAUER: How do we proceed with the workshop 21 approach. What~is our next step or what is your next step? MR. MILLER: What we' plan to do.is to have three 22 23 - more meetings like this in the various regions, get, if you will, a; feel from those regions, whether they think it.is 24 (b 34 worthwhile or not. .I get the. feel from the show of hands f ..,... ~......
94 I that.you all'think they would be. I want to make it very 2 clear that what.we are talking about are small groups of () 3 working level people. I don't know about all of you, but I ) don't really understand at all these words, these terms. I -4 5 know the overall concept, and I think, just from. discussions, 6 that I sense that a' lot of you are the same way. 7 We would like to make this recruiting process as o easy on ourselves as we can. He will announce, if that is 9 the direction we decide to go in, when and where. 10 lihat we are looking at now are several locations, 11 maybe that-are even tighter clusters of facilities than the 12 regional offices. For example, here'in the Southeat., in 13 several different places, so that we can get the right people O 14 there, but we will let you know. 15 MR. HOLLAND: Tom Holland, Georgia Power. You 16 alluded to the Civil Service program analysis. Could you tell us where this is available to us. The Civil Service 17 18 Program of Job Analysis. In other words, your workshops are 19 going to come February to April timeframe. What can I get today to get started? 20 MR. McKENNA: This may be a simplistic answer, but 21 I think the first thing to do is just go to the library and 22 D look under,those terms. There are a lot of documents. (~J 23 'u The Department of Labor.has put out a thing called 24 the Handbook on Job Analysis, which outlines the process of 25 ~
I 95 ..l'. job' analysis. ' There.are a lot'of good texts on-the subject- .2 material.' :If you look at T-19, you have some refererence. 3 Civil Service has publishedLa series:on' job. analysis,-on o 4' performance / objectives,. on criteria based testing, I--believe I 5 that's what.you call it. t e .I think.you can'get.these through-NYIS. I'11 tell .7 you,.'that'.s the place.I!d go. I'd go through the Government 8 Reports Index a'nd look under job 4 analysis, and look under' s performance objectives,'and.there-has-been a' lot of work done.. 10 There is al'so a.. lot of people out'there who know about it. ti - The'first. step would be to go to your, training [ 12 department and.ask them.- 13 MR.~ MILLER: : Tom, would.it help you if we were-to. O 14 supply you with a list of specific references?. 15 MR. HOLLAND:.Yes, that's what I'm'asking. A'b'iblio t graphy of what you have used' to develop what you have done so t 17 ' far would assist us in coming along your lines of thinking. - 18 MR. MILLER: {fewillseethatyougetalistofour i 10' resources. f MR '. HOLLAND: The second questionsis of a' logistical 20 21 Because of the state of our Modified Amendment-nature. Security Plan and Training Plans to be submitted,.and our 22 Contingency Plans to be submitted,.we had been thinking or I 23 had..been thinking'and recommended-to my staff, instead of ( 24 ~ writing"any standing, long contingency plan, once that is-25' t w ---v-+ - ~ ---., e w ,-r+e-- + ww e s na '^--+--se-e us- +e-ww e*w<e.- %v -r wwc - - -, + r4r ve -r vvww-
o 7 i 9 '6. 1~ ~ reg.now approvedtand the mass?is. approved, then to integrate .2 the two.~intola very common document. Is that acceptable-for k 3 L staff!.' 4~ -MR. MILLER: That's fine. I-might comment.on that. ~
- 5. We are'looking at'a?little longer range, perhaps all three of 6
the documents might fit-together. 7 ' MR. RUNNER: William Runrier. of VEPCO again. I 8 wanted to bring.up-that point. You know, I had talked to some 9-of your staff..in the'past and they had mentioned something 10 about integrating the three documents into one. 11- - Now, I am not.as lup-to--date on. the new fee schedule 12 as, perhaps, I should be. I had just been wondering how that-13 will ef fect l three separate submittals? Would it be 'better ~ O: 14 to send ~ it'in Jone, would -it be. cheaper?L-15-MR.-MILLER: I think you -are already 'startbd.. Your-l 16 security plan, offcourse, is already'in, and that is water 17 over the dam. Your. contingency plan is'due' the first part of 18 the year.-'and your guard training the last.part of the year, 19 unless you can hustle -- well, you can't do it now, anyway, 20 because the guard; training plan,.right now, is to be-separate 21' from the other'two, so you are stuck. . 22 MR. RUNNER:.And-let me make one comment, Mr. Miller. I want to extend my regrets-at your disappointment, 23 24 becaus~e I know you. people.had anticipated a lot'of foot stompin J 1 e25) andl table pounding today, and I apologize for it. ) 'we e- .ws o e v~wree v-r w - mv 1 w - L - = s m
97 1 MR. MILLER: I accept. Are you going to start now? 2 MR. RUNNER: 'No. ~ 3-MR. 110LLAND : CouId-you somehow address the interim .( ) '4 period of training? We are presently -- I presume most of the 5 people are using 520 as the basis of their training. We were b 6 going into a'more formalized or documented training program,' 7 as a result of Appendix B. 8 Ilas there any thinking as to what we are: to do with. i D. the general move towards Appendix B training or what -- how 10 we can progress best to get where we want to be, rather than 11 continuing along with 520 and all of sudden, jumping over. 12-I'd like to hear what you have to say on. that. 13 MR. CLARK : Well, Tom, I think that there has not. 14 been an in-depth. review of that particular problem.'that you 15 raised. I think that the_ regulation itself speaks to the 16 fact that they don't expect you to launch into training your 17 personnel in the course.of your plan until after you have our 18 approval. That is one milestone that you indicated. 19 20 I think that on the other hand, you would be most -- as you proceed through the development of performance 21 objectives,that you may want to factor this.into your training 22 23 program, in lieu of some of the lesson plans, which we now-( ') are using on the 520, simply becuase you are going to be 24 reaching the same goal, and it may easier for you to do it 25
98 1 that way. 2 As you recall, in our review, under 7355, the train-O a ime groerem, we aeve 1 oxea et evectrice117, v er commitme t 4 to having a program which will reacil the objectives of 520, 5 and 1 think that this will continue to be the case, as-far 6 as NRR is concerned, that we will expect you to be meeting y those objectives', and I can see no reason at all why adjusting g to some of the new parts of the training program won't continuo 0 to n'eet those objectives. 10 MR. MILLER: If there are no further ques.tions, I 11 believe some of the gentlemen up here have a few things they 12 would like to say, in summary. i Vick., 13
SUMMARY
14 MR. STELLO: I don't know whether to say I'm dis 15 app inted that we didn't have any foot stomping. I kind of 16 reflected at the way this meeting has gone in general, in 37 contrast to the meeting we had here on the 7355 I guess about 18 two years ago. There is a big difference, and I try to decide 99 w s a r such a d W erence, and I M nk maybe 20 you all have heard.an awful lot in the last couple of years, g On your behalf, I think that learning, perhaps, that this O
- *"d""*"i^'
" ""** **S"'""*d """"ri '**"i'***" ' 2a is here to stay, and we are here to help you make it work. 24 _q b I also think that perhaps we, as a staff, have 25 i o
99 'I learned from some of the mistakes we have made in the past. 2 We are implementing the new requirements further. ahead, trying /~T (,/ 3 to think~through a little more carefully what the requirements- /^T 4 (,j were. 5 Even in spite of that, it was remarked when this O meeting opened, I think there were some major points raised, 7 and we met with EEI and there are probably some errors that 8 we need to correct, and I have heard mucF. discussion on other 9 points or major issues in the present rules that we need to 10 worry about. Actually going up and fixing them, and that is 11 comforting, and maybe that is an indication that we really, 12 indeed, have 'done our homework and done it well, and I would 13 like to thank you people here at the table. I think they 14 have done an excellent job, in doing the best they can to 15 think it through. 16 But again, I would like to remind you, we are here 17 to listen, and if something just pops into your mind before-18 we go out those doors, if you do see a real problem and you 19 want to talk to us privately, I sure would like to hear about 20 it. If you have a problem, I would like to hear. 21 There is one more point that was raised at the 22 EEI meeting that I feel it wouldn't be' fair if I didn't 23 bring it up here. No one has, and I think it is an important 24 point, a point I take pretty seriously. ,,U 25 That realtes to the question of whether there is a
100 1 Federal law that would give you some muscle in dealing with 2 this question of industrial security. If you have a guy who m(,) 3 comes'into your site and.does intend..to cause some harm to () 4 your-facility, it appears that the greatest force that could 5 be brought to bear is to grab a hold of him for trespassing 6 and leave some question as to who grabbed a hold of whom. 7 I do believe that th'at is a very significant question. 8 It is one that I think will have to be dealt with, and we 9 are looking very hard at that question right now. 10 I think the electric utility industry is a very 11 important and vital industry in our economcy, and, as I was 12 reminded at EEI, the government has not provided the same 13 degree of protection for that vital industry as it has for (9 v 14 others, and maybe that is a very important point. 15 I think a contrast to this,if the question of theft' 16 became an issue, well, then, there are Federal laws that 17 cover theft, but there are no Federal laws for sabotage. So 18 we will be looking very hard at the question, and, of course, 19 it will require legislation, more than likely. I am not a 20 lawyer, so don't let me suggest that without giving.you the 21 answer that they already have it. But itvill very likely be a very long and drawn 22 () out process before we can accomplish a new, definitive law, 23 24 if we need one. (' I promised EEI we will make sure that.the industry 25 i i
101 1 is' aware of any particular activity in this area, so uuat they. 2 will have an opportunity to express their views. rS 1 3 \\_/ I am sincerely committed that we will, indeed, s 4 () keep you posted on that issue. 5 I thought perhaps at the end there were going to be 6 a lot.of things to summarize, related to the questions that 7 have been raised here, as to whether there _is...a n.eed for a o great deal more. guidance and clarification related to the 9 implementations of these rules, and I guess I have to conclude 10 that there really isn't. There very cl~arly is a need for the-workshop. I 11 e 12 think that was almost an overwhelming expression, from the 13 hands I saw raised, everyone decided that was really needed, b,s 14 If we have ' the workshops, I think they will also 15 tend to resolve some of these questions on detail and how 16 much detail is really needed. What really are the critical 17 tasks, which is another issue that was raised. 18 I believe some of the other insues that became 19 apparent, we just take pen in hand and start writing. The workshops, perhaps, will provide that mechanism for getting 20 21 initial guidance. I remind you again this is a give and take affair, 22 23 I invite you to make sure that you do your best, and make us (]) l aware of where we have problems, and with that, I would like 24 ,m (-) to conclude.. Thanks a lot.- I think this has been a very ) 25 r
102 1 surprising meeting, at the least. 2 I think, as I said earlier, perhaps we were doing t' ' 3 a better job, both of us, in moving down the road toward 4 ) implementing the regulations. 5 MR. O'REILLY: I am not going to do any summarizing, 6 because I think anything I say might detract from Vick's 7 comments. If you will forgive me a little bit, as I sit here 9 and we are talking, we are sitting here talking about the 9 future and severa). years from now, and the need for more 10 training, and the need for more people for protection, the 11 application of' resources that are finite, I would like to s 12 a stress the fact that you all have your' operating power reactort 13 and existing security plans. ( ) 14 Security is very real. Security is necessary today. ? 15 I hope that we keep that in mind, because my role is to assure 1 g 16 that these plans that we are all in the inspection business, t 17 we are in the enforcement business, and the importance of 18 security today has not diminished. 19 So, our efforts in this arca will continue vigorously 20 and, of course, based particularly I would say our inspection } 21 program, is based solely on requirments, and if we feel that's 22 not so, I think you should talk with me. ] 23 Jim, do you have any final shots? 24 MR'.' MILLER: I would like to remind all of you J 25 that copies of all of the slides and viewgraphs are on the tab: e s-4
' i 103 1 right'outside the door. Thank you all_for coming, and have 2 ~ a nice, safe' trip home. i ll-3 -(Off the record at 3:13 p.m.) /^ 4 O) 5 6 7 8. 0 10 11 12 O 14 15 10 17 18 19 20 21 22 23 24 ) t 25 .}}