NRC-91-0161, Forwards Rev 7 to Security Personnel Training & Qualification Plan,Changing Shotgun Qualification Course to Require Shooting from Shoulder Instead of Hip Position.Rev Withheld

Forwards Rev 7 to Security Personnel Training & Qualification Plan,Changing Shotgun Qualification Course to Require Shooting from Shoulder Instead of Hip Position.Rev Withheld

ML20087E221
Person / Time
Site:	Fermi
Issue date:	01/08/1992
From:	Orser W DETROIT EDISON CO.
To:	NRC OFFICE OF INFORMATION RESOURCES MANAGEMENT (IRM)
References
CON-NRC-91-0161, CON-NRC-91-161 NUDOCS 9201210091
Download: ML20087E221 (3)

Text

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Detroit ' ...-. h3.,J EcLson EE9"2 ir es, h

l January 8,1992

• NRC-91-0161 U. S. 'Heclear Regulatory Ctemission Attn Document conttol Dask Washingt on, D. C. 20555  ;

Referonc - -Fermi 2 HRC Docket No. 50-341 HRC Licenne No. NPF-43 Subjecti Submittal and Request for Approval of Fermi 2 Security Personne1 T aining and Qualification Plan (Revision 7)

In- accordance with 10CFR50.54(p)(2). Dutroit Ediaca hereby submits the Fermi 2 Security Personnel Training and Qualification Plan (SPT&QP).

Revision 7. Only the af fected page (App 6ndix 0, page 0-1) is submit t ed . Changes to the tt xt- are highlighted (cade.1).

" This revision involves a change in the shotgun qualification ourse to require shooting from the shoulder insteaa of the hip positie at the 15 yard line. The qualification requirements have also been incteased f rom 50% . t o 70%. The proposed shngun qualif seation course is dif ferent- f rom that prescribed ^oy 10CFR73. Appendix B which includes hip shooting. . Qualification !n accordance with 10CFR73, Appendix B is required-initially and annually thereafter for certain members of the security force to. meet the' requirements of 10CFR73.55(b)(4)(i).

In accordance with 10CFR73.55(a), the Commission may authorir.e met.sures for protection against radiological sabotage other than those required by 10CFR73,55 if the licensee demonstrates.that the measures have the same high assurance objective as specified in 10CFR73.55(a) and that tha overall level of system performarce provides 'ptotection against radiological sabotage equivalent to that which would be provided by paragraphs 10CFR73.55(b) through (h) and meets the general performance requirements of 10CFR73.55.

Detroit Edinon has determined that the proposed change will not doctease the of fectiveness of the current SPT&QP for the following reasons:

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+ USHRC January 8.1992 NRC-91-0161  :

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1) The revised course requires a higher level cf proficiency to '

qualify than the cur ent course of fire.

2) Shooting f rom the hip is inherently less accurate than shocting  ;

irom the shoulder and should be discouraged when responding t o a .

design basis threat of radiological sabotage. The likelihood of l hitting a fellow of ficer responding to the same threat is also increased. When of ficers are qualified to fire from the hip position they are ef fectively being told that it's acceptable to i tespond to a threat in that menner. Det roit Edison Nuclear Security has determined that when responding to a throat with the .

inherently less accurste hip shooting method, the tesponding I officer is less likely to atop an inttuder than by chooting irom  ;

i the more accurate shoulder oosition. The endorsement of hip '

shooting implied by the cut .ent t raining program, theref ore.

reduces the potential ef fectiveness of response to a design basis threat. For these reasons, replacement of the hip shooting with shoulder shooting along with the increased accuracy requirements proposed for the SPT&Qp improves the overall ability of the security organization to respond to a design basis threat of radiological sabotege.

As discussed above, since the ef fectivenese of the SPT&QP is not decreased, the proposed shotgun qualification course change tesults in

• a SPT&QP which meets the same high assurance objective specifled in .

10CFR73.55(a), provides protection againat radiological sabotage equivalent to that provided by 10CFR73.55(b)(4) and meets the general performance requirements of 10CFR73.53.

Since the proposed change resu4ts in a shotgun qualification course that is dif ferent than the requirennents of 10CFR73.:5(b)(4)(i). '

Detroit Edison will not implement this change until the Nuclear Regulatory Commission determines the Qange to be acceptable pursuant to the requirements of 10CFR73.55(u).

If you have any questions regarding this submittal, please contact ,

Mr. Joseph H. Korte. Deputy Director-Nuclear Security at (313) 586-4949.

Sin.srely.

/

N Enclosure  :

cc T. G. Colhurn (w/o encl. )

A. B. Davis (w/o eucl . )

J. W. C,ied (2 copies w/cncl.)

R. W. Def ayet te (w/o encl .)

S. Sta'ck (w/o encl.)

USNIC Document Control Deck (2 copies w/ encl.)

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s.

APPENDIX G DitCIGUN QUALIFICATION COURDB Thoro are 2 positions of fire for the Shotgun course totaling a rounds. For each position 4 rounds of 00-buchchot shall be fired at 4 separate targets.

l To goalify, the individual is required to placo 70% of all polleta

) 151 pollets for the entiro .courno)- within the black silhouette of L the NRA D-27E targot, or similar targot uLing an equivalent scoring method.

Bhotgun Course

Range No. of Time hAl. R91tnen Egal_ tic.n .inssi 15 4 Shouldor 10 25 4 Shoulder 10 Revision 7 G-1 December, 1991 m_____ ____ _ _ _ ____ _ _.______ _ _ ______ _ _______________ _ __ ___ __ _ ___ _ _ _ _ _ _ ___ _ _ _ _ _ _ ___