NUREG-0211, Forwards Jul 1978 NUREG-02119 Entitled Nuclear Safety Personnel for Power Plants,Content & Review Procedures for Security Training & Qualification Program. Summarizes Major Comments Received Re 780421 Draft Nureg.W/O Encl
| ML19312B761 | |
| Person / Time | |
|---|---|
| Site: | Oconee  |
| Issue date: | 08/04/1978 |
| From: | John Miller Office of Nuclear Reactor Regulation |
| To: | Porter W DUKE POWER CO. |
| References | |
| RTR-NUREG-0219 NUDOCS 7911190537 | |
| Download: ML19312B761 (4) | |
Text
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UNITED STATES y
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August 4,1978 All Power Reactor Licensees Gentlemen:
This letter and enclosed NUREG-0219 titled " Nuclear Security Personnel for Pcwer Plants, Content and Review Procedures for a Security Training and Qualification Program," dated July 1978, are being sent to all licensees authorized to operate a nuclear. cower reactor and to all applicants with applications for a license to operate or construct a power reactor.
Within the next few weeks the Comission is scheduled to publish in final form amendments to 10 CFR 73 to impose upgraced qualification, training, and equipping requirements for security personnel protecting against theft of special nuclear material and industrial sabotage of nuclear facilities or nuclear shipments.
The enclosed document provides a basis on which comercial nuclear reactor applicants and licensees can develop acceptable programs to implement these new requirements.
A second draft of this document was published for cement on April 21, 1978 and as a result the staff has considered the cements received and incorporated many changes.
The following rumarizes the major coments received and how the NRR staff addressed them in preparing the final document:
1.
Approximately one third of the 32 that comented stated that the sample plan indicated an excessive amount of detail and the guidance should not exceed that currently given for safety related training.
The final document contains only 25 pages of guidance (Parts 132);
the remainder is a sample plan.
The samole was proviced to assist tne applicants and licensees in preparation of a plan based on a new approach.
As noted in item 3 below, the sample should not be considered a requirement.
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The staff reformated the sample plan to reduce the amount of detail and removed many tasks based on the ratings submitted in response to the request in Draft 2.
This resulted in a reduction of 16", in the numcer of cages devoted to :erformance cbjectives (173 vs. 94) and a reduction of 445 in the numcer of performanc ocjectives (344 vs.191).
A further recuction snould be realized when the site analysis is comoieted, since the samole olan incluces many tasks that are not appropriate for all sites.'
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2-2.
Many comments stated that the number of onsite evaluations by the NRC was excessive (i.e., 1 by NRR every 2 years and 3 each year by I&E).
The I&E schedule set forth in the draft was based on the established frequency of onsite I&E physical security inspe-tions with the assumption that these inspections woulo e expanded to include training and personnel qual if ication.
Mcwever, all references to I&E inspection have now been deleted from the final version since this document addresses NRR policy only.
3.
Scme ccmmented that although we state that each site is required to develop a qualificaticn program based on a site specific job analysis, that the NRR reviewers would treat the sample plan in NUREG-0219 as the only acceptable approach.
The NRR staff feels that the sample plan provides valuable guidance and shculd remain in the document.
However, the final version was revised to stress that the sample is not a require -
ment.
One example is fcund on page 1-1 and reads:
"It must be stressed that it is the resp'onsibility of each site, using the methodology described in this document, to identify its site-specific tasks, elements, and performance objectives.
The security program selected must evaluate each individual's ability to implement the site-approved physical security and contingency plans.
Training and evaluation are not done for their cwn sake.
The sample qualification plan found in part 3 should not be considered a requirement, but only a guide; Each specific site plan is reviewed on its own merits."
A.
Other ccmments stated that tasks shcwn in the sample were too extensive.
They indicated that tne sample program exceeded that required by most military and police organizations and/or the requirements to meet the 73.55 threat level.
A few ccmmented that the type of response indicated in the sample plan is outside the responsibility and capabilities of private security.
The applicants and licensees are required to identify in their qualification plan only those security tasks critical to successful imolementation of the site c:ntingency and physical security plans.
If a licensee can develoo acceotable contingency plans that meet the threat and do not require police or military tactics, then the tactical tasks can :e deleted.
Mcwever, i' must ce realized that the military and police are the only j
organi:ations witn experience dealing with such problems.
The vast majority of the military and police related tasks contained in the sample are at the basic training level.
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Finally, a few commented that the NRC should hold working sessions with the utilities to develop its detailed requirements.
Although the actual development of training and cualification plans are the responsibility of each licensee, NRR is planning to hold a series of workshops with the utilities to develop a mutual understanding of how to implement the methodology described in NUREG-0219.
These workshops will be small and devoted to actual plan development.
Additional copies of NUREG-0219 can be obtained frem the National Technical Information Service, Springfield, Virginia 22161 at current prices.
Sincerely,
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James R. Miller, Assistant Director for Reactor Safeguards Division of Operating Reactors
Enclosure:
NUREG-0219 cc w/o enclosure:
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3 Duke Power Company 50-269 50-270 50-287 cc: Mr. William L. Porter Duke Power Company P. O. Box 2178 422 South Church Street Charlotte, florth Carolina 28242 J. Michael McGarry, III, Esquire' DeBevoise & Liberman 4
700 Shoreham Building 806-15th Street, NW.,
Washington, D.C.
20005 Oconee Public Library
'201 South Spring Street Walhalla, South Carolina 29691 I
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