ML20148D662
| ML20148D662 | |
| Person / Time | |
|---|---|
| Issue date: | 10/05/1978 |
| From: | John Miller NRC OFFICE OF NUCLEAR MATERIAL SAFETY & SAFEGUARDS (NMSS) |
| To: | |
| References | |
| RULE-PR-73 NUDOCS 7811020441 | |
| Download: ML20148D662 (83) | |
Text
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1 NU CLE AR REGUL ATO RY COMMISSION-
- D IN THE M ATTER OF- .
IMPLEMENTATION OF 10 CFR 73, APPENDICES B and C, GUARD TRAINING AND CONTINGENCY PLANNING
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Picca - San Francisco, California Octe - Thursday, 5 October 1978 P=ges 1-81 Teleonone:
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CR 9111 1 UNITED STATES NUCLEAR REGULATORY COMMISSION b JACKSON' 2 .
- i 3 Implementation of 10 CFR 73, :
Appendices B and C, Guard :
.4 Training and Contingency :
QS Planning :
V 5 :
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Hilton Inn, 7 San Francisco International !
Airport, l
8 San Francisco, California.
g Thursday, October 5, 1978.
10 The meeting commenced at 9 o' clock a.m., James Miller, 33 Assistant Director, Safeguards, NRR,-Moderator. ]
12 - ALSO PRESENT:
1 13 ROBERT ENGLEKEN, Director, I & E, Region V. l EDISON G. CASE, Deputy Director, NRR.
14 15 RALPH JONES, Chief, Safeguards Standards Branch, OSD.
16 FRANK PAGANO, Chief, Reactor Safeguards Development Branch, OSD.
17 18 THOMAS MC KENNA, Member, Reactor Safeguards. Development.
F Branch, OSD.
19 20 JACK ROE, Member, Reactor Safeguards Licensing Branch, l' OSD..
21 l 22 ROBERT CLARK, Chief, Reactor Safeguards Licensing Branch,
.23 OSD.
24 LEROY R. NORDERHAUG, Safeguards Branch, NRC, Region V.
25 c0ceOederal cReporters, Dne 444 NOMTH CAPITOL STREET W ASNINGTON. D.C. 20001 (act) 347 3700
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.9.9 E T,,E E 1 g 2 '
STATEMENT OF: PAGE 3'
Robert Engleken 3 e s- Edison G. Case 6 1 1,q(,ry -
5 Ralph Jones lo 6 Jack Roe. 17 7
Frank Pagano '.1
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29 8 '
Robert Clark 60 9 -
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,, l 11 Pages at which material is to be inserted:
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15 16 17 18 19 20 21 d
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23 24 2s cAce 9ederaf cReposteu, .One 444 NORTM CAPITOL STREET WASHWSTON. D.C. 30001
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PROCEEDINGS
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( 2 , MR. MILLER: We usually start these meetings by 3 saying we",ome. ladies and gentlemen but I don't see many 4 ladies or any ladies.
I don't know what it is about you U 5 Westerners.
i 6 We usually begin the session at least every time, J 7 by talking about some things that are not really relevant l
8 like the last session the Redskins-had just beat Dallas.
9 This session we might say a few things about the submarine to situation but it may hurt some of you a little more than 11 others and we will just let it go. I 12 For those who don't know me, my name is Jim Miller.
s 13 I am the assistant director for Reactor Safeguards, NRR.
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14 10 begin the meeting I wou1d 11ae to introduce xr. i 15 Bob Engleken who is the director of Region V and our precious te hope. Bob. 1- -
8 l 17 STATF'.'NT OF ROBERT ENGLEKEN 18 MR. ENGLEKEN: Good morning.
19 It is a pleasure for me to welcome you to this meet-20 ing sponsored by the' office of Nuclear Reactor Regulation.
21 The meeting is for the purpose of discussing recent amendments
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22 to the NRC safeguards regulations pertaining to security guard
/ a training and contingency planning. As Jim mentioned, I am 24 director of the Region V office located in Walnut Creek and
'2s Karl Seyfrit, director of the Region IV office in Arlington, crlee 9edesaf cReposteu, Soc.
444 NORTM CAPITOL. STREET W ASHINGTON. D.C. 30909
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1 Texas,.has asked ma to welcome those of you.who repraccnt )
P: 2 : licensees from our' Region IV area as well.
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3 The Region V. inspection and enforcement office is l' . .
L '4- pleased to host this meeting and although we're not on the n.
i h -5 . agenda, we are vitally interested inLthe. proceedings here 1
6 this morning, particularly the rule changes that will be dis--
7 cussed here today because we are the ones who will be called 8 upon to enforce these. changes and the regulations. . It is im-9 portant that those who enforce these rules have a common 10 understanding of their intent and.the language of the rules 11 with those of you who are required to comply with.them. So 12 we hope to benefit as you do from the discussions-here this i
13 . morning.
14 We in the enforcement end of this business are very 15 much aware of the importance of the' rule changes for guard is training in particular. Some of our recent inspection ex-17 perience indicates that there is an urgent need for improve-18 ment in the training of security personnel. We expect to 19 inform you about.some of our recent experiences, inspection 20 experiences, by way of a circular that will be mailed to you 21 in the near future. I hope that when it arrives you will give 22 it your serious consideration.
23 Mr. Noderhat.g, who supervises the Region V safeguards
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24 staff, and several members of his physical securitiert staff r
25 are present in the audience. Mr. Noderhaug will be on the cAce- 9ederal cRepsten, Sac 444 NORTH CAPITOL STREET WASHINGTON. D.C. 20001 ,
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.1 panol this aftarnoon during the question and answar session i'
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- 2 and I invite you all to present any questions to him which 3 might pertain.to the inspection function. I hope you all j i
g.. 4 have a very productive and useful meeting here this morning 5
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1 and I thank you very much. j l c MR. MILLER: Thank you, Bob.
7 A few remarks before we begin. I remind you this l 8 is a meeting between the NRC and reactor licensees. There-a fore, in the interest of time, I would appreciate it if the to questions, discussion, what have you, are between the NRC 11 and licensees. The staff will remain after the meeting or 12 toward the latter part of the meeting to hear questions from 13 anyone e'.se that may be in the audience.
LO 14 I lso remind you that a transcript is being taken.
15 copy will be available in your region at headquarters and 16 at the public document room in Washington. With that trans-17 cript when it comes time for questions, discussion, we ask 18 that you identify yourself and your affiliation. If'you have 19 a name that is rather difficult to pronounce or maybe spell, 20 a little bit more than Miller, if you would spell it at least 21 the first time, it would help our transcribers.
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22 There will be a slight change in the agenda but it (h 23 will essentially be the same meeting we have now held in At-U 24 lanta and Chicago. I just thought it might be better to change 2s the order a little bit and it will make it a little more of-c:Oce- 9ederal cAeporteu, Snc.
d44 NORTH C APITOL STREET W ASHINGTON. D.C. 30005
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'l ficial.. Also thara -is a sign-in. sheet. that .is being passed . '
2 arourd. 'I ask you.to-please' sign your.name:andLaffiliation.
3 That way-we'will know who all is.here.
If you would.like a ,
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p, 4- copy.of the-sheet, if you will let one of us know,.we will'be if
's glad'to:see-that.you get one. ,
6 With that let me introduce to you-Mr. Edison G.
t 7 Case. -Mr. Case is deputy director of Nuclear Reactor-Regula-8 ' tion.
9 STATEMENTbFEDISONG. CASE
-10 MR. CASF: Thanks, Jim. . Good morning. )
11 I'd like to express my thanks to you'all for coming 12 here today and taking time from your busy schedules for this [
13 meeting.
14 : These types of meetings are helpful to us because-15 hey give us an opportunity to discuss our proposed positions '
~16 and hear your reaction to them face to face. I hope they are 17 just as helpful to you.
4 18 Before we get into some of:the specifies that will 19 come later on, Itd like to make a couple of general observa- >
20 tions. As you surely know, we are here to discuss the im-21 plementation of these proposed rules. _They are already in 22 effective form so there is no need for philosophy on whether 23 we ought to have them or not. We have them and our job, mutual l 24 job, is to implement them well.
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, ; 25. Considering that many of you already have guard c0cc. 9edew( cReputen, Sac 444 NORTM CAPITOL STREET
~ WASNINGTON. D.C. 30001 '
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' 7 training programs, we've tried to ensure the impaementation 2
of this rule will build on your existing programs and take ad-3 vantage of them. Earlier this year on September 14 we met
'{, 4 with the Edison Electric Institute security actmittee in New N \
5 York City to discuss many of the issues that we will talk 6 about today. Several important issues were raised there and 7
Itd like to repeat to you some of the discussion we had 8
earlier.
9 Four of the most obvious questions thtt uhey raised 10 were, (1), the age 21 requirement for armed personnel. We 11 will discuss that more today. (2) The problem you have in 12 determining felony convictions. (3) Who is to be trained and 13
('8 qualified under these new rules and, (4), are all of the
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> 14 sites required to have the specific equipment that is listed 15 in Section 5 of Appendix B.
16 It was pointed out at the EEI meeting that our re-17 quirement that our members of the security force be at least 18 21 is inconsistent with many state laws and that many of the 19 state laws allow licensing of armed security personnel at 18 20 years of age. The EEI committee indicated that many sites are 21 now using armed security personnel who are under 21 and they 22 are serving well. The obv1ous inconsistency between our re-w
(,) 23 quirement and the military was also pointed out.
24 After considering this issue we believe this is a 25 valid point and following a thorough legal review, if that cAce. 9edera{ cReporters, Snc 444 NORTH C APITOL STRECT W A S Hn N GTO N. D.C. 20009 f201% SA %1 *CQ
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turns out all right, wo intcnd to recommend to tha Commiscion 2 that the rule be amended to allow arming of personnel at 18 3 provided this is consistent with state law in the sites in-e 4 volved. -
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/~N 5 Several members of the EEI committee also pointed
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6 out how difficult it is for licensees to determine if an indi-7 vidual has ever been convicted of a felony. We are aware of 8 these difficulties and this in large part was the basis for 9 the proposed clearance rule. We are currently studying 10 various options we would pursue if the clearance rule were 11 not to be adopted by the Commission. We welcome any input
>2 you may have on this subject. Our objectives in this are the 13 same. You want to have qualified and trustworthy employees f
f; 14 at your nuclear power plant site and we want qualified and 15 trustworthy employees guarding those nuclear power plants.
16 At the EEI meeting we were also asked to clarify 17 who is covered by the training and qualificatinns requirement.
18 More specifically the question raised was are the sites re-19 quired to train, qualify, and keep records for all plant per-20 sonnel. The answer to this is no. Only those personnel who 21 perform critical tasks to site security are covered. This 22 would include the security positions identified as part of (d
gm 23 the physical security organization in your physical security 24 plan, and those positions identified in the contingency plan 25 as those that are performing key security tasks.
1 cAce 9ederal cReporten, $nc I
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Lastly, EEI wanted.to know if the licensees ara-2: required to have on' site all of the specific equipment speci-3 fied in'Section 5 of Appendix'B. They pointed out-the diffi--
p 4 -culties that this would create'because of local laws, federal
'O e regu1ations, and incompatib111 ties of the equipment 11eted in 6 Section 5 of Appendix B with specific site requirements.
a 7- Quoting from Appendix B it says, " Guards and . armed I 8 response personnel shal1 either be equipped with or have 9 available the following security equipment appropriate'to the j l
10 individuals assigned to contingency or security related tasks .
11 or job duties as described in the licensee's physical security I 12 and contingency' pl:au," unquote. Thus the~ equipment you have 13 identified in.the sites approved security plan meets this p -
-O '4 reautre= eat ae vou re not reautrea to a ve 11 or tae equir-15 ment listed in Section 5.
16 . Equipment requirements for each site will be reviewec 17 on their own merit on a case by case basis.
18 A1though we are here today primar11y to discuss 19 guard training and contingency planning, if you have questions I 20 on other topics you feel should be asked and answered, we will 21' be happy to address them later this afternoon.
I'd like to thank you again for coming and express 22 23 my confidence that this will be a productive meeting for both
! (%h) 24 the.NRC'and the industry alike. Thanks very much.
. 25 MR. M1T.TRR: At this time let me introduce Mr.
Ralph' Jones. . Ralph g gg g eg o thegafeguardsStandard 444 NORTH CAPITOL 9TREET '
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Branch, Office of Standard:Davelopment; and was intimately.'in <
'2 volved in.the writing-of.these rules. Ralph..
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STATEMENT OF RALPH JONES
- 4 MR. JONES: He changed;that introduction slightly.
O- s. ne was to eay z was responsid1e for a11 of thie but now 1 am 6 dust intimately involved.
7 What'I' propose to do.is discuss briefly the regula-8 tion, guard training regulation, the. guard training guides, R
9 'the contingency plan guides, to tell you sort of how we got . i 10 where we are and what happened to some of the comments you
-11 made and.the statuslof these.various' things. 1 12 Asyouknow,thesecurikypersonneltrainingand 13 qualification regulation was published for comment and, as l h 14 published, originally included detailed training requirements ;
15 and specific qualification requirements, hours of training, d
16 and details such as that. ,
Comments' received were primarily concerned with the '
17 18 inappropriateness of specifying.these detailed requirements 19 without recognition of the skills and abilities needed for l
20 specific security duties. Comments also indicated possible 21 problems with EEOC guidelines where the requirements were.not 22 job related. Further comments were concerned with the short -
f 23 implementation time'and clarification of the applicability of O
24 the requirements in definition of terms. ]
2s- In addition, the Commission asked for comments re- i l
1 cAcc.9ederaf cReporten, .Onc. l 44d NORTM CAPITOL STREET J
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garding implementation with respset to c'intral, regional, or 2 local training, or with certification or licensing considera-3 tions.
4 The major change from the proposed rule to the
-) 5 final rule in Appendix B was to turn it around and to specify 6 areas of skill and knowledge to be considered in the licensee 7
training plan rather than to specify all of the training that 8 needed to be carried out. There are still some qualification 9
requirements for employment suitability even though they have 10 been modified to be job related. For example, the physical 11 fitness qualification no longer calls for an eight-minute 12 mile and pushupc. Rather it is required that the person be 13 physically fit to carry out his assigned task.
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14 Forexample,theCASoperator,ifa$1hehadtodo 15 was sit at the console, he might be able to sit in a wheel-16 chair.
17 The major thrust now is to provide flexibility for 18 you, the licensee, to design the training and qualification to program to fit your site specific security programs. This 20 turnaround to tie in the job related skills and abilities 21 should resolve the EEOC's problems except perhaps the 21-year 22 age question.
)) 23 The implementation times also have been changed to 24 provide considerably more time to develop and implement the 25 plans.
cice-9ederaf cAeporters, Snc 444 NORTH C APITCL STREET W ASHINGTON, D4 RMOl (402) 3d747H I
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We rocaiv;d vary fcw comments r:garding th tr:2ining 2
location and certification. The final rules provide flexi-3 bility in this area and does not require certification of 4
e security personnel b y the NRC, only approval of the training
) S qualification plan.
6 We have a study underway to investigate the pro's 7
and con's and cost benefits of various training options and 8
certification by the NRC of security personnel. The result 9
of this study and the success of implementing the rule under 10 the current conditions will determine whether or not we need 11 to take any further action.
12 I don't believe I need to review the rule, itself, 13 in detail. You all have the Federal Register notices and,are
() 14 awar'e of those requirements. If you have any specific ques-15 tions, we will be here to attempt to answer them.
16 With regard to the training manuals under Reg 464 17 and 465 which you all received copies sometime ago and were 18 given a very short time to comment on, we recognize this, we
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19 were, however, committed to have those published in final 20 form by October 23 so we had no choice but to give you a short 1
21 time to comment. We have received a number of comments on the 22 manuals. Some of them, of course, were typographical errors
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23 and incorrect statements. The comments, however, were pri- l 24 marily concerned with the status of the manuals as requirements 25 or guidance. These manuals are intended as reference documents cAce- 9edera{ cReporten, Sac ud NORTH CAPROL MREET WASH 5NGTON. OA 20001 (202) 347 3700 i
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~1' only to provide)you with :information to develop your training -
4- .
, 2 program. The manuals are not regulatory guides. They do not ;
3 present a regulatory position. .They are:not required. The g d' icsson plans, any or all of'them, can be used'or not used;de-5 pending on your own program. ItLis an att'empt to assist-in ,
6 developing training plans.- In reading the documents myself I-l 7 have' noticed a number of statements that imply they are're-8 quirements.. These should not have been there and will not be 9 there in the final documents. There are a number-of other to corrections and definitions that have'been changed to conform 11; them to current regulations. Keep in mind it is the regulatiert 12 in10CFR,.Part73,thatspecifihs~therequirements. .The new 13 Reg documents are intended to provide'you with information to
(- 14 assist you in meeting those requirements.
15 Briefly,-the context of the. manuals, I believe they 16 say.there are five volumes in the. introduction but there are ,
17 only-four. We have made some revisions and that will have to 18 be corrected, too. . Volume' I covers general basic material 19- that most security people should know. Some of'it may.not be.
1 20 appropriate to your' facility or to every person in the security 21 organzation. Select from it to develop your basic training .
22 program. Perhaps you will have more.than one basic training 23 program depending on how your security functions are struc~ ,.
24 tured.
Comments received indicate that-some'of the basic-
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training plans are inappropriate and unnecessary, For example, 2 a commentor said a guard does not need to know anything about 3 such things as.the objectives of the adversaries, the role of 4
private security officer in the criminal justice system, or s, ) 5 the growth of private security in the nuclear industy to 6 carry out his security duties. While this may be true in the 7 strict sense, a person who has some of this background infor-8 mation has'a better understanding of wry the security job he 9 is doing is necessary. This, in turn, should result in a de-10 sire to do a better job du the assigned tasks. Again, these 11 lesson plans are not required but are given as suggested plans.
12 ,You do not have to use them.
13 Volume II covers more basic material on more specific
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Tj 14 topics. Again, select appropriate to your site security pro-15 gram.
16 Volume III is set to cover advance training. This 17 may be misleading. It is advanced in that it is more specific 18 than basic and is intended to advance the training to site 19 specific topics. In any case, the intent is to provide guid-20 ance in developing training plans tailored to specific sites.
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21 (olume IV covers weapon training and qualification.
22 Again, you would select those parts appropriate to the weapons
'~3 23 your people would have available to them. Mr. Case pointed
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24 out you would not necessarily use all of the weapons identified 25 in Appendix B.
cAce- 9edesaf cReportcu, Snc 444 NORTH CAPf70L. STREET W A S HIN GTO N, D.C. 20001 (zoal a47 3700
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In summary, lat ma r;paat. This manual is not a c
2 requirement, these manuals, but are intended to provide infor-3 mation. You will note times specified in the lesson plans.
4 These are suggested times. The course work may take longer or 1
5 not as long depending on the class, the instructor, previous e training, experience, and so forth. In fact, if the security 7 personnel are al' ready skilled and knowledgeable in their func-8 tions as can be shown by tests and demonstrations, training is 9 not needed at all. Prior training or military training would 10 reduce orcliminate the need for additional training. This 11 document might not be needed at all or only selected areas 12 not covered by other training such as site specific procedures.
- 13' Reg guide 554, changing from guard training to con-7 , ,
\J 14 tingency plans now, I won' t say anything about the regulation is on the contingency plan, itself. It is published. It is a 16 final regulation and you've all read it in the Federal Register.
17 Reg guide 554 is intended to provide a regulatory position on 18 what your contingency plans should contain and the format.
19 This is a little different than the new reg document. It does 20 contain a regulatory position. Jack Roe is going to go into 21 details of the contingency plan and explain these various 22 contents to you. I won't do that. I will simply tell you the w
) 23 status of this guide.
v 24 It was published for comment in March. We have re-25 ceived very few comments, two utilities and two individuals cAce 9edera{ c. Reporters, .Onc 444 NORTH C APITOL STREET W ASHINGTON. D.C. 20009 f ?@ . is t.wrws i
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hav commentad on the guidas. In g:neral, they w:re concarn3d i 2 with the redundancy of the contingency plans with the physical 3 protection plans and the need for controlling access to the l
] 4 information contained therein.
5 We do not expect, as you will be told later, that 6 the contingency plans be redundant to the physical security 7 plans and we are also looking at ways to control the informa-8 tion. None of the comments received are considered to' call 9 for revision to the guide right now. We will wait until we 10 have had some experience with this guide before we consider 11 changes.
12 In the meantime, if any of you have any comments 7 13 of Reg Guide 554, please send them to us.
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V 14 One other item, which is not really a subject for 15 this meeting but which many of you are interested in, is the 16 material access authorization program commonly known as the 17 clearance program. As you know, we had hearings in July.
18 The hearing board has been considering the testimony given at 19 that hearing. Final testimony was submitted by various parties 20 on September 1 The Commission asked the hearing board to 21 make recommendations to it and to present a schedule of when a
22 they would have those recommendations.
C 23 At prior meetings I estimated that the hearing board 24 would present their findings to the Commission a little opti-2s mistienlly. I found out yesterday their schedule calls for cGee Jederaf cReposten, $nc 444 NORTH CAPITOt. $7 MEET WASHINGTON. D.C. 20000
1 17 th:2 to-submit their recommendations-to the Conmission by 2
Decamber 31, so it will be next year before we find out really 3
what is happening on'the clearance program.
4 f' Thank you.
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- 5 MR. MILLER: I think I failed to mention it is 6 probably best if we hold questions until everyone gets 7
finished and we get essentially everything we have to say and 8
then we will go into essentially your part of the meeting and ,
9 open up for questions. '
10 At this time I'd likb to change the agenda a little 11 bit and ask Mr. Jack Roe to discuss with you the contingency 12 plan. Jack.
13
~s , STATEMENT OF JACK ROE
'() 14 MR. ROE: During'this period I am going to discuss 15 the' contingency planning rule. I shall discuss the content I 16 requirements of the plan, the plan's relationship with guard - '
17 training qualification requirements and the methods of submit-1 18 ting your contingency plan.
19 I'm going to point out that the contingency plan and !
20 the guard training qualification plan are closely related and 21 that an integrated approach to both of these plans result in 22 a substantial reduction and effort, k]) 23 I also want to point out that much of the information l 24 and data required for contingency planning is contained in your 25-physical security plan and other security related documents i
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cAce- 9edeta( cAeposteu, Sac 444 NORTH CAPITOL STREET WASHINGTON. D.C. 30004 :
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1 18 that~are at the-site..
2-2 The. contingency planning rule requires five'cate-3- gories.of;information in each safeguards contingency plan.
- f. 4 These five'. categories of information are background, the 5
generic planning base, the licensee planning base,'the <
6- responsibility matrix, and procedures. Although the procedures, 7- are a culmination of the safeguards contingency planning pro- ,
8 cess and an important part of the plan, they should~not be 9
submitted to-the Commission for approval. The procedures will ;
10 be inspected by a member of the NRC staff on a periodic basis.
11 This periodic inspection will affirm that the procedures re-12 flect-the information contained in the responsibility matrix.
13 The.first category of information is the background 40 14 section. Thie section identifies and defines the potentia 1 15 dangers in' incidents and describes the general ways the plan 16 will deal with them. The background section will have at 17 least four topics, perceived danger, purpose of the plan, 18 scope of the plan, and definitions. The perceived danger is 19 a statement of the perceived danger to the security of special l 20 nuclear material, licensee personnel, and licensee property.
21 The statement contained in 7355-A will suffice in 22 this area. Statements of perceived danger that are less than )
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' 23 those contained in 7355-A will not be acceptable.
24 The purpose of the plan is the discussion of the 25 general aims and objectives of the plan. The scope of.the cAce3ederal cRepsteu, Sac 444 NORTH CAPITCL STREET WASHINGTON. D.C. 20000
1 19 plan is discussion of the types of incid:nts covarad in th's G
2 plan. A list of those contingencies covered in the plan 3 should be placed here. Definitions is a list of terms and their safeguards meanings used in the plan.
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5 The next category of information is the generic 6 planning base. This chapter identifies the events that signal 7 the start.of a safeguard contingency and it also identifies 8 the objectives determining the safeguards contingency. In 9 addition to events and contingency objectives the chapter 10 should include decision actions to be followed when a con-11 tingency situation develops and the chapter should contain 12 the data required to effect these decision actions.
13 The objectives should specify your goal to effective-G, i_) 14 ly satisfy the contingency situation and each one of these is objectives should be achievable. They should be clearly identi-16 fied and they should be measurable.
17 The next category of information is the licensee 18 planning base. This chapter contains site specific informatior, 19 used in contingency planning. The following topics should be 20 included, organization structure, physical layout, safeguard 21 system hardware, law enforcement assistance, policy constraints 22 and assumptions, and administrative and logistical considera-O~T 23 tions.
LJ 24 Your physical security plan may contain much of this 25 information already. Let me discuss bdefly each one of these cAce 9edeza( cAeporteu, Sac 444 NORTH CANTOL. STRCET WASHINGTON, D.C. 20001 f 202) 347 3700
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..1 topics. 'The organization structuratshould delineate.the 2-organization, the chain .of command, and . the delegation of 3
authority. Also'it should-contain minimum strength size.
4' J3 _ Physical layout-shouldLd escribe.the site and the V 5 nearby features.' Particular emphasis should be placed oniv 6
enforcement routes, location of contro1 pointti, and. location
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7 of safeguards hardware. Safeguards system hardware should' 8
describe all. equipment available'fbr-safeguard cont'ngencies.. i 9-This topic should address, at least, communication', intrusion 10 detection, surveillance, locks, weapons, and vehicles.
11 Law enforcement assistance. This section should 12 list each separate law enforcement agency that'may. provide
-13 assistance.. This section should provide a description of 14 their response, capabilities, and a. discussion of your' working 15 agreement with.each agency.
16 policy constraints and assumptions should discuss 17 state laws, locs,1 ordinances, company policies ~ and practices 18 that.may govern your response to safeguard contingencies..
19 This section may discuss.such constraints as the use of dead-20 ly force in jurisdictional boundaries.
21 Next, administrative and logistical considerations. '
22 This section should describe your practices that may influence 23 response to security contingencies. This section should high-24 light the procedures to keep all safeguard systems operable 25 -
, , and a method employed by you to assure that al'1 security per-cAce 9ederal cAeposteu, Anc 444 NORTH CAPITOL STREET WASHINGTON. D.C. 20001
.: I m
i .
21 1-sonnel ara currant with the present plang:recent changes, 2 present- procedures in -the general security situation at .the 3
site.< .
- p.
4 The next category of'information is the responsi-5 bility-matrix., This section should.be an' array of.information 6 .for-Leach safeguards event. Each array should identify the 7 responsible individu'al and their decision actions.- This array C
8 should display cn a single chart or a group of charts depending 9 on the size for each event all decision actions and the 10 responsible person.
11 The responsibility matrix should provide' an overall 12 picture'of response actions and their interrelationships.
. 13 The last category is, procedures. The procedures "O- 44 hould provide c1 ear concise direction for the execution of 15 the responsibility matrix. The responsibility matrix may meet 16- the requirement' for some procedures and this diould be stated 17 in the procedure section. Again, procedures are not submitted 18 with the plan. . . .
~
19 -I'll ~ explain the . basic relationship between the . con-20 tingency plan and the training and qualification plan. As 21 will be discussed in this session on training and, qualification, 22 security personnel must be trained and qualified to perform 23 critical security tasks. Contingency plan identifies potential 24 events that must b,e planned for. These events require the 25 - execution of certain decision actions'to meet the objective c:Acc. 9edeta{ cReposten, Onc.
444 NORTH CAPITOL. STREET WASHINGTON. D.C. 20001'
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22 1
of the security contingency. The ' events for safeguards con-2 tingencies are the same as the events to be- considered in con-3 tingency related guard training. The decision actions are the b 4 tasks'. LThe objectdves of the contingency plan relat'e directly
+n D 5 to qualification objectives in training plans.
6 The responsibility matrix is directly related to 7 the duty summary section.
8 .The contingency plans require identification of 9 events, decision actions, and objectives, and the training 10 qualification nlan prepares the guards . to resolve these inci-11 dents. Therefore, one set of events, tasks, objectives, 12 can be developed to meet both of the requirements in each of 13 the rules.
LG '
t/ 14 The contingency rule requires that the plan identify 15 those events that will be used for signaling the beginning of i
16 aggravation of the safeguards contingen::y. These events are 17 the same as the cues to be mentioned in guard training quali- !
18 fication. The event is what an individual sees, hears, reads, 19 or perceives, that signals him that there is a threat to the l.
l 20 site. In cases where the response is the same for several 21 events, the event should be grouped under a single event or C
'22 l event description. Care must be taken to select an event O 23 aeecription that indicates what events are covered. tver7 24 attempt should be made io reduce to a minimum the number of 1
25 l .
event categories covered by different responses. l l
c0cc. 9edera( cReporters, Sac 444 NORTH CAPITCL STMEET l WASHINGTON, D.C. 20001' 1
.. ., ,-, . W --- . . - - -Q
1
' As painted out-in:new Reg 219, racognition of 2 the , proper reaction to certain events can be critical. For 3 example, recognition of an actual covert intrusion can be O 4 very important to your site' security. Therefore, recognition V
O 5
and re. action to these critical cues identified in-the contin-6 gency plan should be tested as part of the qualification re-7 quirements for security personnel.
8 The rule requires that decision actions and support-9 ing information.needed to bring about a successful response 10 be identified. These decision actions are the critical tasks.
11 that are performed when dealing with the contingency. There-12 fore, the decision actions and the contingency.related tasks
, 13 in the training qualification plan should be the same, .al-P)
L 14 though some minor differences in format may be required since 15 the task statement does not indicate what will be done.
16 The staff feels that the decision actions or tasks 17 should be straight forwar d. It is unlikely the guards will 18 have available or will have time to follow detailed written 19 procedures during a fast break in emergency. There are two 20 types of~ decision actions or tasks. Some can be performed 21 successfully even if the individual takes time to look up 22 and follow written procedures while~other cannot. They require 23 immediate action based on training qualification.. Therefore, 24 time delay tolerance should be taken into consideration when 25-developing contingency procedures in performance objectives c: Ace Sederal cReporten, Onc 444 NORTM CAPITOL STREET
24 1
uwd for parconnr1 qualification.
I 2 , Contingency plan rule requires definition of specifio 3 objectives to be accomplished relative to each event. These 4 objectives are indicators of the site's ability to respond e4 5 successfully to an event. For example, it would be impossible 6 for a site to test its ability to respond to an actual attacl;.
7 However, demonstratable objectives could be set that indicate 8 that a site can repel an attack such as response time to any 9 point.on the site or the time required to request off site 10 law enforcement assistance. The objectives, th erefore, should 11 be demonstratable. They should be achievable. They should be 12 measurable, and an indicator of the site's ability to react 13 to an event.
ie i
'd 14 This rule also requires that as a part of the audit 15 procedures that the tests of safeguards systems be performed 16 yearly.
17 The contingency i
objectives will set the acceptable 18 level for performance of these tests and drills. They will be 19 defined what must be demonstrated to pass the drill.
20 A few more words about audit and test of the con-21 tingency plan. It should be noted that it is 7340 that re-22 quires the audit and test of the contingency plan and not 7355.
Ii 23 Part 7340 states, and I quote, "The licensee shall provide 24 for the development, revision, implementation, and maintenance 25 of a safeguards contingency plan. Licensees shall provide for c0ce. 9ederal cReporteu, Dnc 444 NORTM CAPITOL STREttT W ASHINGTON D.C. 20001
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25
'a review at'least every-12-~ months of the safeguards contingency s
2 plan by individuals independent of both security. program, 3
management, personnel who 'have ~ direct responsibility for im--
4-f.n plementation of the security program'. The review shall ire lude p ,
V 5 a review.and audit of safeguards contingency procedures and 6
practices and audit of the security system, testing in main-7 tenance program, and a. test of the safeguard system along 8
with commitments established-for response by local law en-9 forcement authorities.
10 "The results of the review and audit along with 11 recommendations for approval shall be documented and reported 12 to the licensee's corporate and plant management and kept 13 avail'able at the plant for inspection for a period of two lO N/ 14 years,n unquote.
15 As will be discussed, the qualification plan re-13 quires that for each critical security task performed, that" 17 a performance objective be established to test'the' ability.
18 of the individual to perform that task. As we have seen, the 19 Contingency plan requires that objectives be- established to 20 test the ability of a site to respond to events. Sites re-21 sponse is no more than the correct performance of decision 22 actions or tasks by each responsible individual. .It is ob-
{ 23 vious, therefore, that the qualification plan performance ob-24 jectives and the contingency plan objectives must be compati-l 25 ble and in many, many cases the same. If the objectives are l i
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the sam 3 to meet the requirements for a qualification per-o 2 formance objective, correct performance can be demonstrated 3 at the same time during the yearly drill or test required by 4 the contingency plan.
n s s )
5 The rule requires that for each event a tabulation 6 shall be made for each response entity or duty assignment de-7 picting the assignment responsibility for all decision actions 8 which are tasks to be' taken in response to an initiating 9 event. This is the chart that shows for each event what duty 10 assignment performs the critical contingency task. The 11 responsible matrix is a counterpart in the training and 12 qualification plan to the duty summary section that will be 13 discussed.
- > 14 The duty summary and responsibility matrix will be 15 checked during our review for compatibility.
16 The responsibility matrix should contain the same 17 decision actions identified in the generic planning base.
18 Every attempt should be made to keep the different responses 19 and tasks to a minimal. > -
20 Next I'm going to describe the different approaches 21 to submittal of contingency plans. There are basically three 22 approaches to submittal of contingency plans. First of all,
[(}) 23 a self-contained plan. Second, reference to physical security 24 plan and, third, tg revise the physical security plan.
25 The first approach is to submit a contingency plan c0cc- 9edera( cAeporten, $nc 444 NORTH C APITOL STREET W A SHINGTON. D.C. 20001
l l
27 1
that is self contained and does not reference any other 2
documents such as the physical security plan. This plan 1
3 shall include the five categories of information required by ;
'] 4 the rule with the procedure section kept of the site.
'~
5 A second method of meeting the contingency plan 6 requirement is suggested by the rule. The rule states, quote, 7 "The extent that the topics are treated in adequate detail !
8 and the licensees approve physical security plan, they may be 9 incorporated by cross reference to that plan," unquote. This 10 method will require the contingency plan to be prepared as 11 outlined in Regulatory Guide 554 that allows referencing of 12 the physical security plan in the licensee planning base
_ 13 section. If this approach is followed, an extensive revision
,: b
^~' 14 to Chapter 8 of the physical security plan will still be re-15 quired to make it compatible with the contingency plan that 16 you submit.
17 The third approach is to revise the physical security 18 plan. This will require rewriting Chapter 8 of the physical 19 security plan to follow the format shown in Regulatory Guide 20 554 and to include the background, the generic planning base, 21 the responsibility matrix that is required by the rule. The 22 information required in the licensee planning base will be
( [) 23 incorporatedinto the plan by revision and additions to the 24 appropriate sections of your previously submitted physical 25 security plan.
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28 l 1
This is the conclusion of my discussion on con-2 tingency planning. The summary shows the topics that we have 3 covered.
4
.F (The document referred to follows:)
'O 6 COMMITTEE INSERT 6
7 8
9 10 11 12 13 CO 14 15 l
16 17
- 18 1
19 20 21 22 ,
( 23 l 's ,
y4 25
\
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' MR. MILLER: With.that we would like to get into 2
guard'trtining, which will take'.the better part s the meeting, 3
to introduce y'uo to guard training rule and.make some general.
~
4 statements.- I introduce.Mr. Frank Pagano.. Frank is-the chief 5
, of.the Reactor Safaguards Development Branch. Frank.
1 6
STATEMENT OF FRANK PAGANO 7
MR. PAGANO: Good morning. -
8 Gentlemen, during the next few minutes I'am going 9
to-discuss how NRR came to-select the approach outlined in 10 NUREG 219 for implementing the training and qualification l
11 requirements in Appendix B. But'the basic reasons as to.why 12 we adopted this approach is as shown on this view. First, 13
, it assures,that the site security staff can.successfully.im-14
, plement their physical security and contingency plan and, 15 secondly, it is compatible with federal and state regulations.
16 Now, over a year ago NRR started its search for'an 17 approach for determining the adequacy of training. We reviewed 18
,. the existing literatare on training program development, dis-19 cussed the issues with organizations with similar problems,.
20 talked with other' federal agencies who have experienced regu-0 21 latory responsibility in the areas of training, personnel 22 selection, such as the Department' of. Labor, Civil Service Com-ih 23 mission, Equal Opportunity Commission. Then we reviewed the 24 comm ~ts received in address of Appendix B in NUREG 219 and 2s> discussed these issue's at length witt the'NRR staff.
~
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i l Traditionally tha NRC and tho security industry 2 have, discussed training and qualification in terms of complet-3 However, our experience ing course work on various subjects.
4 (7ns to date uncovered the fact that the course outline approach 3
g_)
5 provides no guarantee that an individual can, in fact, do his 6 or her job. It identifies the content to be learned or trained 7
but it does not establish what the trainee is able to do upon 8
completion of the course.
~
9 The course outline may suggest that guards and 10 watchmen complete 50 hours5.787037e-4 days <br />0.0139 hours <br />8.267196e-5 weeks <br />1.9025e-5 months <br /> of course work but what has to be 11 known is what can this security person do after completion of 12 this training. For example, can he or she respond to an alarm 13 in accordance ; tith the site contingency procedures? Do they 1
I ~)
~' 14 know how to support a suspicious event or how to detain a sus-15 pect? The basic questions are what standards must the trainee 16 meet and are these standards compatible with the site plans.
17 .Is the individual being adequately trained and evaluated of 18 the truly critical parts of his job? We feel that the course 19 outline approach does not answer these questions. The questior 20 that all of you are asking is why did the NRC publish its up-21 O
graded training and qualification requirements. The answer 22 is simply that the NRC determined that it needed assurance fron.
,,m
(,) 23 the people who perform the critical security tasks at the site, 24 can perform them adequately. Therefore, our regulatory ap-25 proach was designed to answer the question, can this individual c:Oce 9edeza{ cReportcu, Dnc. .
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do'his job.. Such quactions as how much training has this l
2 person received or what courses has he attended do not really j
~
I 3 I tell us anything about the successful performance.
4 We are interested in the ability of the person to do 7
A 5 the job to which he or she has been assigned and not neces-6 sarily how this ability was developed.
7 Now, what is the solution. How can it'be determined 8 that an individual can satisfactorily perform his or her 9 security duties. We found the solution that is well developed 10 and widely used and it's currently being used by all.of the 11 Armed Forces, by many police organizations, and in every 12 imaginable occupation for p r security to carpentry.
13 Briefly stated,,yt st analyze the individual's c0 14 job to determine what that individual must be able to do to 15 successfully perform the job. That is, you conduct an analysic 16 to determine what tasks are required to implement the site 17 physical security and contingency plans.
18 Next you outline in the form of a performance ob-19 jective how the ability to perform these tasks is demonstrated.
20 This objective outlines the test to be given to each individual.
I 21 Finally, personnel are then qualified to perform 22 their tasks by successfully achieving these objectives. For (O 23 exemp1e, your site contingency p1ane may require the use of 24 night vision equipment during a contingency. Therefore, the 25 site training and oualification plan should identify who would cGee 9ederaf cAeputen, Sac add NORTH CAPITOL STREET W ASHINGTON. D.C. 20099
32 1
usa tha equipment, what tasks h3 would have to perform, and a
2 how he must demonstrate this proficiency. NUREG 219 formalizer 3 this approach..
4 On July 5 of last year the Commission published
()
%> 5 draft requirements for upgraded guard training for comment.
6 This was the first draft of Appendix B and consisted of train-7 ing Courses requiring over 150 hours0.00174 days <br />0.0417 hours <br />2.480159e-4 weeks <br />5.7075e-5 months <br /> of instruction. In ad-8 dition it required that all individuals taking these courses 9 pass the test on the material, making at least a 70 per cent 10 score. Many NRC licensees who commented on that document ,
11 pointed out that these requirements do not comply with EEOC 12 guidelines on testing and selection which require that any 13 discriminatory requirements must be shown to be valid indi-G
'i_) 14 cators of an individual's ability to do his or her job. In 15 other words, it must be shown in a particular test score that 16 will indicate that the examinee can or cannot do the job.
17 This can be accomplished by requiring that the test represents q 18 samples of knowledge, skill, or ability necessary to do the 19 job and for the most part this can be accomplished by develop-20 ing tests that are miniature samples of the job. For example, 21 implementation of a site contingency plan may require the 22 guard to respond to any point on site within three minutes of 23 notification. A valid obvious test of this ability is simply
[x[^:')
24 to simulate the sounding of an alarm and see if that individual 25 can respond within three minutes and so on.
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444 NORTH C APITOL STREET W A S HI N GTO N, D.C. 20001 (101) 347-3700
33 1 Now, the EEOC guidelines point out that in order 2: to d,evelop tests that are valid,.you must first conduet a job-3 analysis.to determine what.makes up the job and based upon- l
=j r 4 this-information develop' tests that test the knowledge, skill, j O: 5' and abilities identified during the job analysis. This is 6 exactly what will be: accomplished when training and qualifica- ]
1 7 -tion programs are developed as-we:have outlined ".._ . NUREG 219. - l 8 You must first conduct the job analysis.and based on this 9 analysis develop performance objective that outlines' valid .
I 10 tests of the knowledge, skills, and abilities that have been 11 identified.
12 We can now see that the approach we have outlined .
13 in NdREG 219 does two things for us. First, it demonstrates 14 that the individual can perform his or her security duties 15 and,. secondly, it allows the development of a training and 16 qualification plan that. is compatible with the EEOC guidelineso 17 Your next speakar will be Tom McKenna from my of-18 fice who will present this job analysis technique in much more 19 detail.
-20 Thank you.
21 MR. MILLER: Before we. talk about specifics, why 22 don't we take 15 minutes and get a cup of coffee or,whatever
-( 23 else you want to do. Coffee is-in'the coffee shop and~the:
24 other things are right on the other side of this wall. 15 25- ' minutes. Let's- be back at 10:15. -
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Off tha record.
2
, (A short recess was taken.)
3 MR. MILLER: On the record.
g 4 We would now like to get a little more specific.
'/ 5 We have talked enough in generalities. When Mr. McKenna gets e through, I hope you are a lot more educated than I still am 7 and I' ve heard it four or five different times. I'm sure 8 with your background you will understand some of the words 9 and I think Tom explained a lot of them. With that let me 10 introduce to you Mr. Tom McKenna. Tom is in the Reactor 11 Safeguards Development Branch and the individual that has been 12 working on 219. Tom.
13 STATEMENT OF THOMAS MC KENNA
) 14 MR. MC KENNA: H1. Good morning.
15 As Jim just said, I work in the Reactor Safeguards 16 Development Branch, and I work for Frank Pagano, who is my 17 boss. I'm going to try to briefly explain how you can use job 18 analysis and performance objectives to meet the qualification 19 and training requirements contained in Appendix B. When I 20 talk about job analysis and performance objectives I essential-21 ly mean the brand of job analysis and performance objectives 22 outlined in 219. We will talk about that.
23 I am not going to try to discuss all of the require-
}']')
24 ments in Appendix B. I'm not going to talk about the selection.
25 I'm not going to talk about the physical requirements, the CC* C CTQf CyOffCTi, hnC.
444 NORTH CAPf70L STREET WASHINGTON, D.C. 20001 (202) 3d7 3700
1' 35 mental requiram:nts, the'equipm2nt'requiremants. I am going 2 to concentrate on qtmlification and training.
3 Now,,everybody. keeps talking about 219. some of you l 1
4 may not know what 219 is. This is it (indicating). What it
\ 5 is is an attempt by the staff to define terms, explain the 6 approach, and give an example to help you in developing .of 7 your plans. Here again, these are suggested approaches.
It 8
has been mailed out, once copy to each licensee and applicant.
9 The rule also states that l ou can get another copy by writing 10 us and copies can be bought from NTIS. If anybody needs the 11 address or anything, I've got that.
12 Next slide, please. Let's start with qualifisation 1
'~
13 requi'rements in Appendix B and those are contained in two
~ 1 LO 14 paragraphs. Next slide, please. The first paragraph is -
15 paragraph 2-B of Appendix B which is qualification requirements .
16 I hate to do this but I'm going to read and quote from the 17 rule. I quote,."Each person who performs security related job 18 tasks or job duties required to implement the-licensee's physi- l 19 cal security or contingency. plan shall' prior to being assigned 20 to such tasks or duties be requalified in accordance with the 21 licensee NRC approved training and qualification plan."
C 22 The second. paragraph I'm going to quote from is 23
({ paragraph 2-D and this is found in. security knowledge, skills, 24 and abilities. Again I quote, "Each individual assigned to 25 perform security related tasks identified in the licensee's cAce 9edesaf cReposteu, One.
444 NORTM CAPITOL STREET I WASMINGTON. O.C. 20099 l
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physical s:curity or contingency plan shall demonstrate the r
2 required knowledge, skill, and abilities in accordance with l 3 the specified standards for each task as stated in the NRC (3 4 approved licensee training and qualification plan." Now, one s
)
5 of the key ideas in these two paragraphs, first, personnel
- 6 must be qualified to perform their assigned tasks and duties.
7 Now, this is--I'm sorry. Let me have the next slide. ,
8 These are the site 5 s specific tasks and duties as-9 sociated with the implementation of your site's plans. The 10 second idea is that this qualification is done by demonstrat-11 ing, by having them demonstrate, the knowledge, skill, and 12 ability required to perform these tasks and abilities and, 13 thirdly, this demonstration must be done to standards speci-q
14 fled in your plans.
15 Now, 219 formalizes this process and it does it 16 based on job analysis of performance objectives. Bacically 17 we use these approaches because they are 'rell understood and 18 there is much work that has been done in these areas with a 19 lot of references available. In recent years it has become 20 even more popular although it has been around for years and 21 this recent popularity has been driven by EEOC, I believe, 22 probably even moie than any other-group since their guides
() 23 actually requires such type of analysis.
24 It's a good point I think to note that the level of 25 detail required or demonstrated and recommende'd in 219 is not cAce. 9edera( cReporters, Sac
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37 1
consistent with the level of detail normally required by 2 EEOC,or found in most of the literature. You can develop pro-3 grams and plans that meet EEOC guidelines while meeting our r;us 4 requirements by adding more detail and taking a more rigid
~.)
5 approach. I guess the thing to note is that our approach is 6 competible with theirs. You can meet ours while meeting 7 theirs.
8 But we've decided on a specific level of detail that 9 meets specific needs and I'll define those needs in a few 10 seconds. Next slide, please-.
11 To develop a plan that meets these requirements re-12 quires three specific steps. First, you have to define what 13 is required, what duties and tasks are required to successful-14 ly implement your physical security and contingency plans.
15 We don't want qualification programs done in a vacuum. We 16 want them to reflect the job at the site.and the job at the 17 Site is defined in your physical security and contingency plant .
18 Secondly, you have to outline the tests you will use 19 to show that the individuals can successfully perform these 20 tasks that have been identified during the first step. This 21 outline of the tests will be done in the form of a performance 22 objective and it should have two qualities. One, it should be
.o
(_) 23 a valid test. By valid we mean it should be a true indicator 24 of the person's ability to perform the task being tested.
25 Secondly, it should be a reliable test and by reliable essen-cAce. 9edera{ cRepsten, Sac 444 NORTH CAPITOL STREET W A S HIN G TO N, D .C. 20001
38 1
tially we mean that evaryone should be test;d the came way 2 to the same standards.
3 Finally, you qualify your personnel. The personnel y 4 are going to be qualified to perform duties and here again I E- 5 will discuss this in a few seconds why we chose duties. This 6 qualification is done by having them successfully demonstrate 7 these performance objectives that are asr,ociated with their 8 assigned duties. You don't have them do anything outside of 9
what they are assigned to do in your physical security con-10 tingency plans at your site. You decide what tasks they will '
11 perform, lump them together into duties, and then qualify them 12 to perform the duties. ,
13 219 contains an example,1Part 3. I have to stre'ss
, 5: ~ , ,
i.J 14 that that is all that is. It is a sample plan. It is pri-15 marily or its main purpose was to define the level of detail 16 that we envision. We have gotten a lot of criticism in the 17 past. You know, you guys write regulations, you put out 18 guides, but you never show us what you want so we have to go 19 through three iteration just to find out what level of detail 20 we're talking about. That is what its primary purpose is, to 21 demonstrate that. A lot of work was put into it and we hope 22 that it can help you in developing of your plans, but you have
(]}) 23 to conduct an analysis of your site to determine what is re-24 quired. You can't base it totally on.what is in that Part 3.
25 Next slide, please.
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39 1
Let's look at the first step of that thrso-st:p 2 procers and, as we showed, it is job analysis. Job analysis 3 is the process, of analyzing the jobs at your site to determine 4'
c what tasks, knowledge, and skills, and abilities are required
s to implement the plans,your site specific plans. The next 6 couple of slides I show will show the relationship between 7 duties, tasks, knowledge, skills, and abilities. Next slide, 8 please.
9 I stress once again that it is the site's duty, the 10 site's responsibility, to decide on this breakdown. These sug-11 gest demonstrations. These are examples. Let's take a look.
12 In this case here (indicating) we have the job as a search 13 wat chman. Now, what is the job? Well, the job is everything
,/-
- ' 14 the individual does at the site for you. It may included non-15 security functions. It may include any grouping of duties and 16 tasks but that is what he is hired to do. So it's really not 17 an appropriate level for you to develop qualification require-18 ments and for us to review them because there is not really a 19 direct relationship between the job'and what an individual may 20 be doing at any one particular time at the site.
.21 The second level are duties so in this case we have 22 a search watchman as the job and yet we have him performing
({]) 23 two duties. We have him searching vehicles and we have him 24 searching personnel, Now, what is a duty? The way we define 25 a duty is whatever an individual is assigned to do during a cAce 9ederaf cAeporteu, Sac 444 NORTM CAPftOL, STREET W ASHINGTON. D.C 2MOS (2n?) 3d7 3700
40 I specific shift on your duty roster,on'tha shift assignment 2 roster, and this is the level at-which we suggest that quali-3 fication requirements be established and demonstrated. The r+ 4 reason we do it at this level is because there is a direct fl-
5 relationship of what the individual is doing during a shift 6 at any one particular time with the duties.- In other words, ,
l 7 he is assigned a duty for a specific length of time on the duty 8 roster and we can check to see if he is qualified to perform 9 all of the tasks associated with that. duty, so there is a 10 relationship. For instance, I & E can go out and determine if i
11 a person is qualified to perform a particular duty that he is 12 performing at a particular time on the site. The relationship 13 is clear. . ,. :
14 Below duties we have tasks. Now, a task is what a 15 single individual does for a specific length of time. It is 16 measurable. It is achievab1'e. It is observable. In this 17 case we have while he is performing the duty of searching per-18 sonnel, he may have to perform the' task of calibrating the 19 metal detector, communicating with the radio, or that is 20 probably all personnel at the site, all security personnel at 21 the site might have to, and recognizing unauthorized material.
22 If he is searching personnel, his purpose is to be able to
(}{) 23 detect unauthorized material, he obviously has to be able to 24 recognize it. Finally, we have tmh ng notes. The tasks, up 25 through tasks the identification is probably not going to be j 1
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41 1
too difficult. Th3 naxt loval is words which is really going 2 to get more difficult when we talk about knowledge, skills, 3 and abilities.. But in 219 we talk about criticality. We say 4
gs, that your plan should only identify those critical tasks that U 5 cannot be considered universally performable. We put these 6 two bounds so that the plan wouldn' t be massive and that we 7 wouldn't get a lot of paper that wasn't really important to 8 our analysis and our determination of whether your personnel 9 and your analysis of whether your personnel can adequately per-10 form their jobs. So we said that you should only identify 11 the. critical . tasks and those that aren' t considered universal-12 ly performable.
13 Now, let me define criticality and I'm going to give
()
14 you the same definition that is in 219 "A task is considered 15 critical if its performance is essential to successful im-16 plementation of the site's physical security and contingency 17 plan when needed even though it may not be performed frequent-18 ly or is performed only during a contingency." How, this is 19 the key part of the definition. " Inadequate performance of a 20 critical task impacts on the ability of the site to detect, 21 assess, respond to and ne.tralize an unauthorized activity."
22 Now, in this example here I included as one of the 23 tasks that this individual performs during his duty of search-24 ing personnel as taking_ notes. Well,.this is probably not a 25 critical task because if the person does not adequately take c0ce 9ecleza( cAeposten, .Onc 444 NORTH CAPITOf, STREET WASHINGTON D.C. 20001
42 I
notes, for instance, after something has happened, it probably 2
does not directly impact on the ability of the site to respond; 3 detect, assess, and neutralize. There are probably a lot of 4
7, other tasks that belong in this area. Now, this determination
S is to a large extent going to be subjective and it will be an 6 operation that will be performed by you in close coordination 7 with the NRR reviewer who has intimate knowledge of your 8 particular site.
9 Other examples are maintenance records. Now, we're to not saying the personnel don't have to perform these tasks 11 correctly or that I & E isn' t going to go out to see that you 12 keep the records correctly. What we're saying is don' t include 13 in your qualification plan that is submitted to us because L' 14 we're trying to zero in on the truly critical tasks perfot .a d 15 at the site and not every task performed at the site. Next 16 slide, please. ,
17 This shows the total breakdown that must be identi-18 fied during your job Waalysis. You have your job at the top 9
19 and then you have your duties, in this case, searching person-20 nel and searching vehicles. Next you have the tasks that are 21 performed during performance of a specific dQty, in this case O
22 we've broken down a few of the tasks that a personnel search
}','; 23 officer may perform, for instance, calibration of the metal 24 detector, communications.with the radio, recognizing unauthorized 25 material and conducting an unarmed defense.
cAce3edeta( cReporteu, $nc.
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Wext we have broken it down into elem:nts. Now, 2 the term element as we use it, we mean the knowledge, skills, 3 and abilities required to perform the specific task. There 4
are other definitions but it's shorthand for knowledge, skill, s and ability in our case. In this case we say there are three 6 basic knowledges or abilities required to be able to recognize 7 unauthorized material and these are recognition of explosives, 8
explosive accessories are rot what we have here, accessories, 9 and recognition of incinerary devices. This is probably the 10 most difficult step in the analysis as we see it. It should 11 be based on something. You snould try to base your analysis 12 on either the expert' and prior experience of your plant per-13 sonnel in security or on various records that are available, 14 for instance, in the area of bomb threat, response. There are 15 tons of stuff available so I would hope that in taking this 16 final step that that sort of information is where the elements 17 are identified. Next slide, please.
18 Now, I've said that you conduct an analysis to 19 identify tasks, duties, knowledge, skills, and abilities re-20 quired to implement your site's physical security and contin-21 gency plans. Well, how do you do this? What do we mean by 22 analysis? This slide briefly shows what we think is required
((]') 23 to be our requirement. First, you conduct an analysis of your 24 site's physical security. and contingency plans tc identify the 25 tasks and knowledge, skills, and abilities required to imple-c0ce. Jederaf c.Reposteu, Snc.
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ment th:m. You look ct your plans. Now, to do that, two 2 steps, three steps. First, take a look at each paragraph of 3 your physical security plan and determine which tasks are n_ 4 critical to implementation of that paragraph.
/) '
5 Secondly, take a look at the decision actions in the o responsibility matrix of your contingency plan. As Jack noted.
7 the decision actions in the contingency plans, first of all, 8 should be critical to response of that contingency. Other-9 wise, they shouldn't be in the responsibility matrix and, 10 secondly, they may either be or be very closely related to the 11 tasks required to implement that response. So take a look at 12 each one of the decision actions in the responsibility matrix.
13 In many cases they may be the tasks. .
t / i
^
14 Finally, I have security literature up here. This 15 , is that final step of taking the tasks and identifying the 16 knowledge, skills, and abilities. .Like I said, I think this 17 should be an abasement, you know, the expert opinion of people 18 at your site or various literature that is available.
19 Now, when--I've listed a few things that you should 20 look for when you're going through the paragraphs and when a
21 you're taking a look at your decision actions in your 22 respansibility matrix. There may be others but here are some.
) 23 You should identify all of the critical tasks associated with 24 the use of security equipment, job aids, manuals. Now, a 25 piece of equipment that obviously has a critical task associ-cAce 9edesaf cReportcu, Sna 444 NORTH CAPtTOL STMEET WASHINGTON. D.C. 20001 femal a a s e sm a
45 1~-
ated with it'is wcapons, but thare are others, metal detectors,
-2 et cetera, any of the physical security equipment that 1s re-3 quired to implement your plans. You must identify which tasks
, 4 are critical to its successful use and the need should be (d,A 5 identified in your plant.
6 I have job aids up here. What is a' job aid? An' 7 example is some sites.might prepare SOP cards, small cards 8 that personnel carry around and have at their particular site 9 'that outline what they do on a specific incident. This is a 10 job aid. It requires that if its use is critical, here again, 11'- to implementation of your plans, then that task should be 12 identiified. 'As Jack noted, there are two basic types of tasks, 13 Some will allow time to look up, you know, go to a reference and 14 determine what you have to perform in.the next step. Some 15 don't and this should be reflected in your plans. For instance, 16 if an individual has time to look up the procedure, his ability 17 to look up and respond to that procedure should be tested. 'We 18 can't assume that he understands just because it is written 19 down actually how to perform that. There are other tasks that 20 he does not have time to look up a' procedure and, if that is 21 the case, then he has to have the knowledge and be able to 22 respond, here again, without using, for instance, a job aid
/' m 23 or a manual and manuals might.be anything. In calibration of-VJ 24- the metal detector, if you're going to say that he is going to 25 use the manual, then your task would allow him to look it up c0cc. ]edeta( cRepsteu, Sac 444 NORTH CAPf701. STREET WASMtNOTON, DA 20001
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~.in'.ths manual and use it but.it should'be demonstrated'tha't" h 2. ~ he}knows how to follow the manual.
l
'3. Next, critical tasksiassociated with implementation
- f. ,
4 of security' procedures. For.the most part most.of the proce-
"5 dures critical to theLsite are those found in your contingency 6 plan and aS" outlined in your responsibility' matrix so that 1
- 7 personnel.has to.demonstrateLtheir ability,to perform these
~
8 procedures. .There may be some other critical procedures, how-9 'ever, for instance,. search. procedures or.the' access control i
10 points, sign-in procedures,. bagging ~ procedures, that could:be-11 considered critica1' that are found in physical security plans i 12- so don't forget those..
13 Next we.have-the physical. abilities required to h 14 perform critical security tasks. As Ralph mentioned earlier, 15- we have in'the rule the requirement'that personnel demonstrate 16 their physical ability'to perform--the armed personnel have l I
-17 the physical ability _to perform their duties and that the-l 18 CAS operator demonstrate this ability to a practical examina-19 tion. Your job analysis should identify what will fom the 20 basis of this practical demonstration. You take a look at -
.21 .their job and-you identify what tasks they.. perform, what .
22 maximum task, for instance, in the case of responding, running;
!( -
23 et cetera, e.nd then that.will form the basis of your practical 24 demonstration. The example that Jack gave..was a classic-CAS.
25 - operator who may not be' required to walk so, therefore, that cAce. 9edesa[c:Reposten, One. .
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would not be onn of th physical abilities that he would hava 2 to demonstrate. Another one is a response to an alarm. Armed 3
personnel may have to respond to any one point in the plant in 4
c X number of minutes with all of his equipment. Your tasks 5
should identify that and when you test him, you have to test 6 him with his ability to respond with his equipment because 7 that is a condition under which he is going to do it in the 8 real world.
9 Finally, I have the kncwledge required to perform 10 critical tasks. It's obvicu s if he has to have a particular hunk of knowledge at the time the thing is required and he has
~
11 12 to know something to be able to correctly respond, then your 13 particular task should identify this. Next slide, please.
C) 14 Now, how do we summarize? You conduct this job 15 analysis at your site to determine your site requirements.
16 How do you summarize the results? What piece of paper do you 17 produce and submit as part of your plan that, here again, sum-18 mariZes the results of this analysis? Well, we suggest three 19 summaries. We suggest the task identification summary, a task 20 duty summary, and a duty description. Next slide, please.
1 21 I'll talk about each one.
22 his is the task identification summary. Remember we 1
23
] stated that you conduct an analysis of your physical security 24 and contingency plans to identify the critical tasks. Well, 25 this shows that relationship and ensures that'the critical task cAce. Jedeta( cReporteu, Onc 444 NORTN CAPiton. STREET WA$HINGTON, D.C. 20001 (202) 347 3700
48 1 has be n identified for cach paragraph 3 What it shows is how 2 the particular task relates to the paragraph in your physical 3 security plan for the event in your contingency plan. The
- e. 4 first example is communicate with a radio. Most plans--these 5 numbers, by the way, came from NUREG 20 Most plans in para-6 graph 1.4.5.0 states that all personnel have to have avail-7 able to them--all security personnel have available to them 8 a means of communications. In most cases this would be a radio 9 so, obviously, one of the tasks performed associated with that to paragraph is to be eble to communicate with a radio.
11 The second task here is receive and react to a bomb 12 threat. While that is associated with event 12 and it's 13 probably obvious that event 12 is receipt of a bomb threat
() 14 so the personnel has to know how to perform that task which 15 is how to properly receive and react to a bomb threat. Next 16 slide, please. .
17 So the first one shows the relationship of the tasks 18 with the plans. Now, we said earlier that we want people to 19 be qualified to perform duties, so now W3 have to show the l 20 relationship of tasks with duties and that is what this chart 21 does. I'm going to walk over there. I think I have to point 22 this out. It is a little hard to see so I'll talk up.
L:
+ )i 23 I can say here we have CAS operators. That is a duty 24 assignment and we have patrol which is also a duty assignment.
25 This matrix shows the relationship of the task with the as-cAce 9edesa( cAeposteu, $nc.
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. 49
'I . signments'- Now,: we have the-task, investigate a suspicious 2 person or. event. Well, the.CAS. operator won't have to do 3 that during the performance of his duties so it's not-indi-B- 4 cated. While the patrol guard will have to do that routinely, E 5 What.we're saying again is that this' demon-it.is indicated.
6 strates~which task the-person has to be qualified.to perform. -
7 Next slide, please..
8 And, finally, we have a duty description. This is 9 where you summarize in one place the results of the job anal-10 ysis. It shows the title, a summary of what the individual 11 has to do, the equipment he-is going.to use--in performance;of.
12 this duty. This is probably the only place ~where actually-21 3 all o'f the equipment san individual has .to use in the performanc e O i4 of a euty 1s summarized. what references he has to be able to 15 use and we mean here if you show a reference that means the 16 person has to be able to go to that reference, read the refer- ,
17 ence, and be able to, you know, follow the instructions found :
18 in that reference. <
19 What supervision he receives and gives. The next-20 slide, please. Now, we completed the first step. - We have'com- ,
21 pleted the analysis. We have identified the task,. knowledge, 22 skills, and ' abilities required and we've documented them with f{ 23 the use of the.three summaries.. The next step is to develop 24 a.. test: to test. the . person's ability to perform these tasks and
- 25
. duties and.we use . performance objectives to do this. .The-cOce 9edesal cReposten, $nc 444 NOMTH C APf?OL STREET ' ,
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50 1 next slide, pleasa.
2 Now, remember earlier I stated our performance ob-3 dective is designed to supply certain information to the NRC
- 4 and to you and these are the basic items of information we 5 hope it supplies. (1) It naturally should indicate that you 6 are going to have a valid test of the knowledge, skill, and 7 ability required to perform the task. Secondly, it tells the 8 examinee the standards he has to maintain. Some people think 9 'this is a little foreign. It's like giving the test to the 10 guy who has to take the test. Well, our performance objective 11 is not exactly the test. If you're going to give 11 written
- 12. test, your performance objective would not be that written 13 test. It would just be an indicator that you're going to give x,)
14 a written test. But'the examinee ought to be able to go to 15 the performance objective and see basically what is going to 16 be required of him in an outline fashion. We will talk about 17 it in a minute. It tells management, shift supervisors, what 18 standards he has to maintain. It defines how the site is going 19 to be tested by I & E. The rule says that at the request of 20 an authorized representative of the Nuclear Regulatory Com-s 21 mission, the site has to be able to demonstrate the ability 22 of their personnel to perform their security duties. Well,
'le'; 23 this demonstration will be done in accordance with the per-
.)
24 formance objective,s associated with those tasks and duties 25 being demonstrated as outlined in your approved physical
- c0cc 9ederaf cReposteu, Dnc 444 NORTH CAPITOL STRECT W ASHINGTON. D.C. 2000t (102) 347 37C4 l
51 1 security plan. Finally,. it supplies enough information to-r 2 assure the NRC reviewers that these are adequate tests of 3 tasks being performed. The next slide, please.
r$ 4 .This just shows the total relationship. Next slide, 5 please.
6 Now, performance objectives should have two quali-7 ties. It should be a valid test and it should be a reliable i
a test. Now, we think the most practical way to develop a valid 9 test is to have the test a mini sample of whatever you are to testing. If the . individual, for instance, is being testsd 11 on their ability to respond to an alarm,'then you have them 12 demonstrate their ability-to respond to an alarm. The example 13 is given that if you're testing a person's ability to type, n
-(J 14 then you give them a typing test.
15 Secondly, it has to be a reliable test. That is, 16 everybody should be tested the same way, the same standards. i 17 Now, to ensure that the test is reliable and valid we ask 18 that the performance objective supply information that states l l
1e two things. (1) States the conditions under which the test j
' 20 ' is given and states the standards to which the individual is l
l 21 being tested. The next slide, please. ;
a 22 Let's look at the condition part of the performance s(~ 23 objective. You have to state the conditions. Otherwise, how 3 i
24 can you have a reliable test because each person could be 25 tested under different conditions. Secondly, the condition cAce 9edera{ cAeporten, $nc 444 NORTH CAPITOL STREET 'I W A S Hf M O TO N. D.C. 20001 f aam) aa w. asnma . _ .
52 <
1 stat m}nt ensuraa that this will be a mini sample or salid testo 2 In other words, you state the conditions. We take a look at 3 it and say, yes, if he can perform that task under those con-4 ditions, it is a realistic test of his ability to perform s that task under site specific conditions that ndght be en-6 countered. The next slide, please.
7 So now let's take a look at a sample performance 4
8 objective, It is the first time you've seen one. We have the 9 task up at the top and then identified three elements. In 10 this case the task is use and calibrate a hand held metal ti detector and the elements are know the procedures for cali-12 brating a hand hd1d metal detector, use it, and, finally, 13 know the procedures to be followed if you find some unau-
[) 14 thorized material while using it.
15 Now, this performance cbjective is going to test 16 the ability to perform the last two elements. You can lump.as 17 many elements as you like or tasks under one performance ob-jective but the criteria is you have to be able to observe and:
~
is 19 here again, certify that the person successfully performs the 20 objective or successfully performed all of the elements. So 21 if you lump too many of them together in one point, they're 22 eping to start getting hidden in the crowd. So that is the
(^w) 23 criteria there. In this case the performance objective says 24 given an exercise with the plant hand held metal detector and 2s individual two hidde'n metal objects of the size described in cAce 9edetaf cReposteu, Snc 444 NORTH CAPROL STREET W A S HIN G TO N, D.C. 20005 f fan 21 u t.staa _
53 1
tha NRC raview guidelines. They could have said as described 2 in your site procedures if you wanted. It doesn't make any 3
difference. -
-^ 4 So the individual being tested is going to be given
.(y
\'J 5 the use of his metal detector and he is going to be given this 6 guy, girl, who has two hidden metal objects of that size as in 7 that review guideline. Next slide, please. So now we saw 8
what the condition statement looks like. Next we have the con.
9 dition, the criterion statement. This tells how well the guy 10 has to be able to do to successfully perform that objective.
11 It sets minimum standards. That is critical. Set minimum 12 standards. Do not try to set standards that, for instance, 13 e1ghty-five per cent of seventy-five per cent of your people "xJ 14 should pass or a class. Set mininmn standards. Set the 15 standards that if they perform below these standards, then it 16 will impact on the ability of your site. I realize this is 17 another subjective judgment. Next slide, please.
18 Thc Let's take a look at this. ~' performance 19 objective. We've given the individual an exercise and here I 20 mean a practical exercise. He is given the use of a hand held 21 metal detector which is used at the site and individual two 22 metal objects. What is the criteria? Well, using that he has I)
-s 23 to locate the two metal objects within a certain span of time 24 and has to alert the patrol guard, you may call him something 25 else, but alert the guard at that post in accordance with the cOce 9edesa( cReptten, Sac 444 NORTM CAPtTot. STRECT W A S HIN G TO N D.C. 10001 (202) 34 M too
54
'1- site's procedures. It ' tells us exactly what this. porson has 2 :to be able - to do to implement, to successfully pass this 3 performance objective. This criteria should--you can. state, e' 4- 'for instance, like in accordance with site procedures, but
^ t3
\
5 you have to~show some care.so that when the reviewer here re-e views your objective, he has sufficient information so that he 7 knows what this individual'is going to have'to do. In this-8 cdse it is very clear'what has'to be done but if you just say 9 that he is going to respond in accordance with site procedures; 10 that may be meaningless. You have to provide enough informa-11 tion in your objectives so it_ indicates to the. reviewer what 12 is required. .
13 One point I think should be noted is-that a lot of "C 14 this testing or objectives, performance' objectives, can be 15 done during the routine performance of duties. You could not 16 have a better test than having the-person successfully per-17 form a duty routinely at the site. So if, for instance, an 18 individual has to routinely contact the site's local law en-19 forcement in accordance with specific procedures, then that-20 could meet a performance objective associated with the ability 21 of the individual to do that duty and it can be demonstrated 22 during routine performance. You don't have.to cut it out and
- [(]) 23 have specific testing periods. Next slide.
24 The final step is . qualify the individual. As I just i
, 25 said, this could be done during routine performance. It can cAce 9edezal cAeporteu, $nc.
444 NORTH C APITOl. STMEET W A S HIN GTO N. D.C. 20008
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. 55 1' boLalso done.duringLan annual cuditLof your. contingency plans. ,
2 -It says;you have to demonstrate'the ability to implement your.
3 contingency plans. This requires the individuals to demon-
, j ,e 4 strate the ability to perform those decision actions in the 10 5 contingency plans. These decision actions in many cases'will-6 be-the-tasks.. So,,therefore, if properly struetured, you can 7 conduct your annual requalification during this' annual audit.
I 8 Next slide.
l
!9 -How dof we document qualification?' Well, we came up 10- with a suggested method. We suggest for each task-that an -
1 11 individual has to perform that you note'the date in which the
'1 12 performance objectives associated with that task were com- l 13 ple te d ,. Notice that we've changed.this from the performance h 14 objective level up to the task level. Next you have the indi-
~
15 vidual sign that, yes, he successfully performed that and you' 16 have the examiner sign, yes, ' he successfully demonstrated.
17 Next slide, l
18 One thing about qualification I' forgot to mention- -
19 was that you do not have to keep.the detailed materials used
)
20 during demonstrstion at your site to acutally complete it.
21 For instance, if a performance objective states that'he is-
)
O 22 going to complete successfully that~ demonstrates a certain
.( 23. knowledge by stating the following X number of things on a 24 written test, for instance, that specific written test used _I 25 does not--his completed test, does not have to be maintained l a
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.ctithe ssitai: You just signicff on the: record :that he- com- a O'
2 plated-that performance: object ue, bat a. sample test, in other 1 1
-3' words, if you have 304 people take the same test, pull'out one
~4 i 'E and: keepfit or a lienk _ one but the fact that all the other (O~
i '
5 people.successfully completed the test, all that has to be' a 6f done is certiff it on the record. The actua1' completed test, 7 the graded test,,for each individual does not.have.to be main-8 tained at your' site, i 9 Now,.this.just shows that there are other parts of q the requirements in Appendix B that can be met by a well'
~
10 11 developed qualification. plan.- In other words,'if you do a. j 12 good" job analysis and develop good performance objectives,.
you'll meeto other parts of Appendix B. 219 indicates'this 13 14 also. - But . just' quickly, the education development. . We state l l
15 that a person should have a high school diploma.or demonstrate 16 the reasoning, mathematical, and language' skills require'd to ;
i 17 do his' job. Well, naturally that requires two points. One, i I
18 you have to decide what those are and then you have to set 1 19 some sort of test which is'a performance objective. So a good 20 qualification program takes ' care of that.
21 Physical fitness, w'e mentioned this already. We have -
22 to have a practical test to demonstrate physical fitness for 23: armed , and CAS operators. This: is done by a good job. analysis 244 'and'performanc'e objectives. Next slide..
2s' Next,' qualification requirements.
That-is obvious, c4ce 9desaf cReposten, Onc 444 NORTH CAPITOL STREET W A9NINGTON. ' D.C. 38899 M .. .. .. .
57 1
, knowledg2, skills, and abilities. Maybe not so obvious.
?
.2 Knowiedge, skills, and abilities,- that paragraph in the rule 3 has'100 items ,that says something to the effect you should 7_
4 consider these or whatever. I don't know what it is. Don't
-3 o
]
(-) - 5 worry about 11 You conduct your job analysis and that will l
.)
6 meet that requ. ent.- Don't try to relate what you're doing 7 in your job analysis to those 100 items. You look at your 8 site and you decide what is critical.
9 Next, requalification. Weapons training and weapons o 10 requalification, when you think about it, weapons qualification l 11 1s no more than a performance objective here again and a task 1
12 except in this case we've taken out one task thatpeople think 13 is more critical than others and specifically identified it I
) 14 and that is the useful weapon. 'Next slide, please.
15 Let's talk about training and we are just going to 16 do this briefly. Our whole approach concentrates on qualifi-17 cation and not training. In training we may have a little I-18 broader meaning than is generally thought of. Training here 19 we mean it as how you bring this individual up to performing 20 where he can successfully perform his tasks. We don't care 21 how you do it. You can use formal training as outlined in the i
i f
i
- 22. lesson plans in the NUREG's. You can use some sort of a buddy
({]) 23 system. I think someone called it cubbing where you put one 24 individual who is not qualified along with an individual who 25' is qualified. They. follow each other around at the site and cAce 9edesaf cAeposten, Sne 444 NORTH CAPITOL STREET WASHINGTON. D.C. 20000 '
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-58
- 1. evantually'the second:. individual becomes qu2,11fied. .You can 2' hire people.who'already possess the necessary skills. You-3 probably.have a lot of them already on the site so we're not
- r. 4 saying you have to send them back to training courses again.
'5 If they can already successfully perform their duty assign-
. 6 ments-and they do s6 and they demonstrate this ability by 7 successfully demonstrating-these performance objectives which-8 can be done during routine performance of~their duties, then 9 that is all.that is required. So, therefore, your. training 10 plan or the submittal that you submit in response' to your 11 Appendix.B requirements does not have to include. lesson plans, 12 hours of instruction, or instructor qualification.
13 -People have asked is a program text, is the use . of JO u a progr- text en right: Yes. 1s the use of a computer 15 system? Yes. Is the use of the buddy system, OJT, to'a 16 certain extent as long as you don't have somebody performing 17 your job for which he is not qualified, yes. Hiring somebody J
18 who is already trained? Yes, it is allzight.
19 To talk about the training manual just briefly, 20 here again, they contain information that may be helpful in 21 developing of a formalized training program but that type of 22 information is not rvquired. You don't have to submit it.
23 I'd like to note one thing. 465 states in its 24 title that is. concerned with transportation, don't ignore it.
I 25 - Of the two manuals it was the only' one that was developed based c0ce 9edesaf cReposten, .Onc l 444 NORTH CAPITOL STREET i
. W A SH4 NSTO N. D.C. 30004 4wtmma . i
59.
1- on a job' analysic. psrformanca objactive appronch and sinco'
~2 many of the tasks and objectives associated'with protection 3 of transportation would be'the same for a reactor site, it r.s 4 probably has a lot of very useful information in it, so don't R
() s ignore it. Don't just order one. Get that'one. If I were s you, I would take a harder look at it then I would the first 7 one. Next slide.
8 So, in summary, the approach is site specific. For 9 that matter it demands site analysis. You determine what the to duty descriptions and tasks are.. You determine what the l
1 11 qualification standards are and how you're going to test it.
~
12 We review them for adequacy and, 1f we don't like it, you go-13 back and try again, but you determine. We're not setting i
(( )- 14 strict standards from this end.. , ,7 15 You test your individuals to see if they can suc-16 cessfully perform these particular tasks.by successfully per-- !
17 forming the performance objective.
18 219 says that we' re going to go out to the site and 19 test a few people according to your plan before we approve 20 a plan. We are not going to do it so that is a change in 219 r
21 I think it is site visits. We may conduct some site visits 22 and someone else will talk about that, but they won't be to j
~
23 test ' individuals .
{} } .
24 Finally, you determine the most cost effective "2s method of bringing your personnel up to standards identified c0ce 9ederaf cReposten, $m:
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in your plan a Thank you a 2 MR. MTTLER: At this time I think we should continue , l 3 You now have heard how to do this and you all are experts l
- 4 which we will talk about, in a minute but before we do that,
'--' 5 let me introduce Mr. Bob Clark who all of you know. Bob will 6 talk a little bit about schedules and how he intends to per-7 form the reviews. Bob.
8 STATEMENT OF ROBERT CLARK 9 MR. CLARK: It's good to have this opportunity of 10 talking to you again. As Jim indicated, it has been my privi-11 lege to meet with most of you at your sites or in Washington 12 in the past year and a. half or so, 20 months perhaps, and I 13 think we have made a great deal of progress. So for the few
( \.
V_/ 14 minutes I will speak to you today, I would like it if we 15 could have the first slide, please. I would like to discuss 16 the review schedule and some of the review procedures that we 17 foresee at this time for both the contingency planning require..
18 ment in Appendix C and for the training and qualification plann 19 in Appendix G. In addition to these two plans I'll also men-20 tion some of the related features of amendments and fees.
21 Some of the milestones which we will talk about today 22 come directly from the regulations and you'll be familiar with
' (]) 23 those and, as we look at the schedule for the contingency 24 plans, we are speaking now of specifically those for operating 25 power reactors. These are due on March 23, 1979 The con-c0ce- 9edezaf cReputeu, Snc 44d NORTH CAPITOL STREET W ASHINGTON, D.C. 20008 M3 P7 3D I
61 1 tingency plans become' effective 30 days after NRC. approval'O o.
2 Prior to the plan becoming effective, the licensee will have
'1 3 all safeguard capabilities specified in the safeguard con- l rm 4 tingency plan'available and functionable. You will have the
'Q 5 detailed procedures developed according to Appendix C. They J
6 should be complete and in place and, finally, all appropriate 7 personnel trained.to respond to safeguard incidents as out- 1 8 lined in the plan and specified in your procedures should be i
9 accomplished.
l 10 Now, neglected in the regulation, itself, is the 1
11 matter of guidance related to ccnstruction permits and operat-12 ing licenses. I know some of you are interested in those I
13 particular aspects and so let.me take just a moment to outline
- 14 to you some guidelines which we feel appropriate for submittal 15 of contingency plans if you are now applying, first of all, 16 for a construction permit. We believe that it is appropriate 17 if you're applying for a construction permit that you submit 18 with your PSAR an outline in commitment to Appendix C with 19 this application. I guess-we have not made this statement in 20 this particular meeting but we generally want it to be known 21 that we believe and will treat as such information in your 22 contingency plans and your training plans as 2790, Part B or
[ 23 Section B, of our regulations indicate that details of your 24 security plan should be withheld from public disclosure and 25 are identified as being limited in their availatiLity under cAceSederaf cReprieu, Sac 444 NORTH CAPITOL STREET W ASHINGTON. D.C. 20001
. h ______________
62 1 ths Fra; dom of Information Acto So wa will continuS to trcat 2 this infr ition under this type of protection.
3 . fou are planning to submit your FSAR, and when I .
4 speak of your final safety analysis report, I'm also including
_) 5 your security plan which should accompany that report, if you 6 are going to submit this prior to the effe'etive date and that 1
7 effective date for the contingency plan was June 6 of this 8 year, you should submit by March 23, 1979 If you're going 9 'to submit your FSAR security plan after the effective date, 10 that of June 6, but before March 23, 1979, your contingency 11 plan would be due on March 23,1979, or 180 days prior to 12 fuel loading, whichever date is later.
13 Finally, if your application for an operating license
) 14 or the submittal of your FSAR is after March 23, 1979, then 15 we believe that your contingency plan should be submitted with is the FSAR. The schedule for the submittal of your training 17 and qualification plans, as indicated on the slide, are to be 18 provided by August 18, 1979 The training and qualification 19 plan shall be followed by the licensee no later than 60 days 20 after NRC approval. The training and qualification plan shall 21 include a schedule to show how the security personnel will be 22 qualified within two years after the plan is approved.
'{} 23 You will note that in approaching these particular 24 additions to our regulations, two significant things have been 25 incorporated which I think result from our exp'erience together c0cc- 9ederaf cAeptieu, Onc.
444 N ORTH C A PITOL STREET WASHINGTON D.C. 20001 (202) 347 3700
63 over ths past two years. _ :Ons in that NRC approval is one of
~
1 2 the triggering _ events since-welre'ta m ng about events today 3 that sets things -in motion for your beginning to put into 4 effect and implement many of your procedures and training ,
s/. 5 plans and contingency plans. You will also note-that con-6 siderable time has been allowed for you to complete-the train-7 ing of all of your personnel. We. hope that we have provided-8 a reasonable arena for you to accomplish this work in--pardon 9 'me, timeframe, not arena.
10 One thing:that is important for-you to note is that 11 those physical secuhty plans we've been reviewing, as require 0 12 by 7355, currently'contain contingency planning information 13 and also commitments to a_ training program. Certainly these O 14 erenottobeabandonedbecauseyearego'ingtobewarhing 15 toward these new parts .of our regulations. We feel that this 16 1s a continuation of the process of working together to build 17 a security program which will be effective in meeting the goals; 18 we have and principally those are the performance objectives 19 of 7355. >
20 Let me speak to you just briefly about submittal of 21 guard training programs if you currently are:ft an operating .
22 plant or if you have plans for applying for a construction 23 permit or a well in the near future. If you are going to ap-(
24 ply for a construction permit, we again would suggest that your l 25 training program outline and the commitment to the objective-c0cc3ederal cRepalcu, Sac 444 NORTH CAPITOL STREET ;
W ASHINGTON, D.C. 20008
64' 1
of Appendix B be submitted with your application or with your 2
preliminary safety analysis report, PSAR. If you are going to 3
submit your application for an oprating license, or your 4
FSAR, prior to the effective date of the rule which is October l%s .
5 23, 1978, your plans would be due August 16, 1979 and, of 6 course, the 60 days after NRC approval and the two years for 7- your fully training all personnel to the requirements of this 8 plan of the program that you establish' would also apply.
9 If you are going to submit your'FSAR after October-10 23, 1970, but prior to August 16, 1979, your training plan 11 should be submitted-by August 10,1979, or 300 days prior to 12 fuel-loading, whichever date is later. And here we feel it 13 would be appropriate for you to have all of your personnel y
14 trained in accordance with your plan 10 months after NRC 15 approval and, finally, those of you who may submit an applica-16 tion for an operating license after August 16, 1979, the 17 training plan should be submitted wi.th the FSAR and your per-18 sonnel should be trained prior to fuel loading.
19 Now, these are not a part of the regulation. They 20 are suggestions to you as being perhaps a workable wn for us 21 to have the time we need to review and approve your plans 22 prior to your reaching critical milestones.in your schedule, 23 namely, the time ycumay want to load fuel.
24 Let's speak a little bit about the review procedure.
2s - Ifwecouldhavethe.nexf[ slide,please. I think fairly ob-c0cc 9edesaf cReporten, Onc 444 NORN C APITOL. STREET WASHINGts N. D.h. 20001
65 1 1 vious to you are the areas we are going to be looking in our
)
2 review because they've been mentioned both by Mr. Roe and Mr.
3 McKenna, but just to refresh your. memory we will indicate to 4 you as shown on this slide that we will be focusing on the 5 following areas, the events, the objectives, the decision 6 actions, the licensing planning base, and your responsibility 7 matrix.
8 In addition to our review of these areas the Office 9 of Inspection and Enforcement in your particular region will 1 10 be visidng your site to review the procedures that you have <
11 developed that are appropriate and are associated ~with this 12 plan.
13 We intend in reviewing your contingency plans to >
14 make full use of the reviewers that have been working with 15 you reviewing your security plans. So they will have the ad-is vantag of familiarity with the site layout, with your particu-17 lar security plan, that we might take advantage of this under-18 standing they have come to in reviewing your contingency plans.
19 They may or elect to visit your site'again i le course of 20 their review but it will not be r.equired of them to do so 21 if they feel that they h, ave adequate detailed knowledge of I o
22 your particular site and plan.
[() 23 In reviewing the training and qualification plans 24 we'll be looking at the task and elements that you have defined 25 in your program, the duty descriptions, your performance ob-cAce 9ede:a( cAeportcu, .One.
444 NORTH CAPITOL. STREET W A S HI N GTO N. D.C. 20001 fant) istTTan _ _J
66 1 jectives, and I don' t think wa can cmph2 size cnough how im'-
2 portant these are going to be in our review. We'll also deter-3 mine the equipment you've listed as consistent with that ap-C-- 4 propriate for your security plan, contingency plans, and here 5 again, the Office of Inspection and Enforcement will be visit-6 ing your sites to look at the test materials, the ways that 7 you're going to establish these qualification--pardon me, 8 qualify your individuals to show that they do have the know-9 ledge, skills, and abilities appropriate for their duty as-10 signments.
11 Here again, the reviewers we intend to assign to per-12 form the reviews of your training programs will be familiar
_ 13 with your site, with your security plan, with your contingency I,
" ' ')
14 plan. They may elect to visit your site again as a part of 15 their review. That will be a judgm. that will be made by 16 them in accordance with their fami -ity with the programs 17 from their previous reviews and visits to your sites. You 18 will note I haven't said a great deal about what is the 19 schedule for completing the NRC review. Certainly for the 20 guard training program we have not developed a schedule,some-21 what too far in the future for us at this point in time to 22 make commitments. However, it is our plan and program to
.o t) 23 move forward in the review of your contingency plans in a very 24 vigorous fashion and we intend if we receive the information of 25 the quality we feel you are capable of providing us that we cAce 9ederaf c. Reporters, Onc d44 NORTH CAplTOL. STREET W ASHINGTON, D.C. 20001
67 1 would plan to complata thora ravicwn in about six months.
2 You have to recognize that this may be optimistic since I'm 3 relying heavily upon the knowledge and the experience of the 4 reviewer in facilitating this task in reviewing your con-5 tir gency plans.
6 Sometimes our ability to maintain those people in 7 their current assignments is not always absolute and we will 8 have to adjust as required in these areas.
9 Let's move now into another area related to the 10 amendment procedures. I'm not going to speak at length on 11 this topic since we discussed it with you in Albuquerque as 12 it related to your security plans and it's quite similar for
_ 13 your contingency plan and guard training programs. Certainly q
'l
'- 14 it is our intent to work closely with the licensees and the 15 applicants to resolve all issues so that when we write our je security plan evaluation report these things will all be re-17 solved and we can indicate in our report that we have reached is a conclusion or judgment of the plan that it does meet the 19 requiA ements of our regulations and will provide the protection 20 for the health and safety of the public.
21 However, from our previous experience we know that O
22 there can be difficult issues that resist our resolution and
[) 23 if we find in the course of our review that it is necessary to 24 identify to you an area which we feel must be added to your 25 plan, information must be added to your plan, we will identify c4ce3cderaf cReporten, Dnc 444 NORTH CAPITOL. STREET W ASHINGTON, D.C. 20001
68 1
in a lottar to you that it is our intention to make this a 2 requirement. You then would have the opportunity to avail 3 yourself to the appeal process to our management that most of
" 4 you are familiar with and this, of course, provides you an
\')
5 opportunity to present the reasons you have for not adding 6 that to your plan and also the management will be aware of 7 the staff position on this subject. If at the conclusion of 8 thic appeal process it has been resolved and the staff has 9 accepted your plan or you have agreed to make additions to 10 your plan, then, of course, we will issue our security plan 11 evaluation report and the . matter will be taken care of.
12 If, however, differences persist, we then are pre-1 13 pared to go through the procedures of conditioning your license, 1
'# 14 making changes to your license by an order which will add that 15 requirement to your security plan--pardon me, to your con-16 tingency plan or your guard training program, and I think 17 you're all familiar with the various procedures that must go i
18 along with this process of allowing an opportunity for a 19 hearing and this type of activity.
20 Now, all those things that you have been reviewing 21 under 7355 to date predated the publication of a new fee 22 schedule which appeared in the Federal Register February 21, yy j ,) 23 1978, and there has been no fee associated with our review of 24 your security plan and as far as 7355 is concerned, there will 25 be no fee associated with it until it becomes a part of your c0cc3cderal cReprieu, Dac.
444 NORTH CAPITOL STREET W ASHINGTON. D.C. 20001 fnne m .tvre
69 1
license or. condition on your license. It represents our con-
~2 cluding, culminating activity, I guess you might say. How-3 .ever, in our judgment we look at the submittal of the con-4 S) tingency plans and the guard training programs as another 5 activ1ty associated with Part 73, Part 7355, of course, but 6 for these particular submittals it will be necessary for you
'7 to provide a determination of the amendment class, information 8 class, perhaps, is a.better phrase to use, and state the basis 9 that you Lused in arriving at that determination and then sub-10 mit with your contingency plan and guard training program, 11 these are' two separate submittals, of course, the -appropriate 12 fee associated with that class of amendment or class of in-13 formation.
7 14 Now, we will review that, the NRC will review that 15 and, if we agree with you, we will accept your application &nd 16 your fee and proceed with the review. However, if we disagree, 17 we will notify you wa find your determination is faulty for 18 the following reasons and we will suggest that you send us 19 more money, usually that is the way it goes anyway,- before 20 we begin the review of your plan.- Now, the staff's judgment, 21 and we have discussed this. with our branch which is responsible 22 for developing the fee schedule, and with our legal advisers,
,D u 23 and we believe that thds information you,will be submitting 24 falls in the category of Clasa 3. I might just read to you
.25. -
from this categorization this type.of information and the type c0ce- 9edeta[ cReporten, .Onc.
444 NORTH CAPITOL. STREET W A S HIN GTO N, D.C. 20001
70' 1
of information that is includade 4
2 It reads, " Amendments, exemptions, or required ap-3 provals'that involve-a single environmental' safety or other 4 task have acceptability for the issue clearly identified by O 5 an NRC position orc are deemed not to invclve the L significant 6 hazard consideration." Since we judged that these submittals 7 will have to have our approval, we, therefore, have categorized 8 them as Class 3. Let me ad'd at this time we do not have a 9 ~ written, legal opinion on this. At one of our previous meet-10 ings or with the licensees, it was. suggested they would like 11 to_see such a thing in writing. I guess.that you may obtain 12 that by submitting your own determination of classification 13 and you will have our legal' opinion when we respond with our 3
d- 14 determination of what.we feel is the appropriate classifica-15 tion.
16 'Let me say in conclusion that we appreciate the ,
17 working relationship we have established over the past two 18 years. It is certainly our intent to continue working with 19 the licensees and with the fellow workers we have in the I l
20 regions working toward our common goal of establishing the i 21 acceptable level of protection for all of your facilities. l 22 Thank you very much.
4-u('1i 23 MR. MILLER: Gentlemen, we appear to be quite a bit l 24 ahead of schedule.. I think it may be best if we take, say,
.25 maybe 10 minutes until we can get everybody up here unless cAce 9edew( cReputeu, Dnc. '
444 NORTH CAPf706 STREET WASHINGTON. D.C. 20001 (302) 347 3700
l 71 1
comebody:has c. violent objection. We will then just continue 2 on with the questions. Let's take 10..
3 (A short recess was taken.)
.3 4' MR. MILLER: On the record.
.O\/ 5 I don't know if we got more efficient this morning 6 or got started earlier or what happened but here we are.
7 This in our other meetings has been the time when we've opened 8 everything up for questioning. I suggest we continue on and 9 'we will see what happens. There was a remark made to me if 10 we would talk a little bit about the workshops. -This is some-11 thing we just discussed briefly at the other meetings. We do 12 have planned, if.I can get enough indication from you that you 13 think it's worthwhile, to hold small group workshops on the
.is
' l-)
14 development of the guard training plans, if you will, specif-15 1cally aimed at defining and working a little bit with job 16 analysis. As I mentioned to you before, I'm sure that you all 17 are now experts in job analysis. I'm not. I.still don't 18 understand the terms and I don't know any other way to do it I
19 but to either ask you for comment or ask for a show of hands. ]
l 20 We think we can get together with the people you will have l 21 actually writing the guard training plans, sit down and go 0 -
22 through a workshop kind of thing, a small group, two or three .)
I
~ /~') 23 from your facility and two or three from your neighbor's 1/
24 facility and essentially get a lot of the generic work out of 25 the way. I don't know. Can I get a feel from you? If some-cAce3ederaf cReporteu, Dna 444 NORTH CAPITOL STREET WASHINGTON, D.C. 20094 3W .-
j
1 1 72
. body:wants to make a. comment, I-will entertain that or if I 2'-
can'get a show of hands.- Why don't we try it with a show of 3
hands-firsti Can I see'those that think a worksh6p is a good
~
4 7 . 1' dea and want to go ahead? 0.K. Thank you.
~G.
L 5 With that let me open it up. 1 I think everybody is.
6 up.here that will be able to answer questions. Can we start 7
the questions? Again be sure. to identify yourself and ycur 8l i affiliation for the benefit of our transcribers. Yes, sir. l 9
MR. JOHNSON: Leonard Johnson, Public service Company to of Colorado.,
Addressing ourselves to the subject of background i 11 checks, we have attempted to secure this information through' 12 out local law enforcement agencies and they have denied u's 13 this including the safe depository of records.- I.made an in-(p WJ 14 quiry into the local FBI office. They made an inquiry into 15 Washington and they came back with the information that the '
16 ~
Nuclear Regulatory Commission had already made agreements with 17 the FBI whereby they could submit or the FBI would provide for 18 the NRC fingerprint cards. The fingerprint cards would then I
- i 19 be sent to the local agencies or the licensees where they would 20 be filled out, returned to the NRC, and that the NRC would'then 21 submit them to the FBI. The records would be returned to the :
0 22 .
NRC and'the NRC would then make the determination as to whether 1 23 or not any records would either fit the. individual for service 24 with the company or would deny that type of information.
My 25 i question is do we have any information on tM s from you people?
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444 NORTM CAPITOL. STREET WASMtMGTON. D.C. 30001 I (302) 347 3700 , , , _ ._
,j
1 i
l 73 1
MR. MILLER: Not really. I guess there was some
) l 2 liaison between us and the FBI. To my knowledge, but I will 3 check and get back to you if there is anything additional, e 4
, to my knowledge it was in the area of doing an NAC type check i
5 in conjunction with the, quote, " clearance rule," unquote.
6 It was not done to the best of my knowledge separate from that 7 action. As Mr. Jones utated this morning, we still don't know 8 the final outcome of that.
9 All right.
10 MR. DETTMAN: Bryan Dettman, PG & E. I have a couple 11 of questions. The first one is on contingency plans. We all 12 know that the best laid plan often goes astray and that some-13 times we're not going to have the time to follow a specific
- i
'~' 14 contingency plan. Will I be cited for it?
15 MR. NORDERHAUG: Bryan, we just have to see what 16 happens at the time. We trill have to judge that at the time.
17 Obviously we will review how you handled a particular contin-18 gency. If you deviated from the plan, we will determine if 19 that deviation was warranted and, if not, then we would argue 20 with you. Otherwise we would say nothing.
21 MR. DETTMAN: 0.K. The second question regards 22 training. We have ordered our CAS and SAS equipment and it l
_ ()
/~
23 appears it is going to take some extended training to make 24 people be able to operate this properly. It also appears 25 that it might be very difficult to make the entire force c0cc 9edew( cRepecu, Dnc 444 NORTH CAPITOL STREET W A S HI N G TON. D.C. 20000
1 J$
l Leapable of operating that equipment,iparticularly infteras 11'- 3 2> of the' training guides:or~outlinesithat you;have told 1us' 3- about. -By.the,same' token you made?us: commit to random duty: -j l
-g ' assignments to mitigate the'. problem lof theLinsider.
. :4' -
You men - 1 O
-5 ~ ti'oned this-morningithat=you'could put a. person in-a'wheelchaif -l 6 :at CAS.. Obviously~that is the only post they could work.
How do you equate that with random 4 duty assign-7- All right. .
8' ments? Obviously that man' knows. he is going to' work CAS. or .
.i 9 SAS. ,
1 l
to Well, I think the answer to~your. ques--
MR. CLARK:
i tion is rather straight forward.- There are several" things -
11 12 that you have to meet in providing the' protection that'is 13 required. 'Of' course we expect'you~to continue to meet the f.
14 performance:ob;fective of protecting against.the insider. It. ,
15 .has. been suggested 'in some reviews that. random selection and' <
16 assignment of personne1Lto the duty posts does provide a 17 measure of protection.against the insider. That is.not the 18 only way this may be protected against. If you choose to;make 19: a determination that you will limit the number of people to 20 be assigned to that' particular post when you no longer are able 21- to do it on a random basis, then we would expect.you to provide something that.would augment the protection against the ins 1dez-
~
22 23 in another way.
24 MR. DETTMAN: How about aisuggestion on what'that- '
'25 might be?-
cAce- 9edesaf cReporten, Anc 444 NORTM CAPITOR. STREET 4
WASHINGTON, D.C. SeeSt .
75
~1 MR.-CLARK:, We will be glad to review any suggestion 5
- 2. that,you make.
3 MR. DETTMAN: What training-program might I be in-
- 4 spected on in the next two years?
O' 5 MR. MILLER: What you will be expected against--
6 of course we expect you to implement your trainb g program 7 as soon as we have approved your plan. .However,'if that does B
not occur in the next two years you will be inspected against 9 that that you have committe'd in your physical. security plan 10 to date, 520, whatever you are now using. ,
11 MR. DETTMAN: One other question. What'does the 12 term immediately available mean in terms of weapons?
13 'MR. MILLER: Let me give you an example. I think-(~ -
- -} 14- that would be the best way. If your. armed responder must and.
15 is located,.let i s say, in the west side of your plan in his
. 16 normal duty, and he is required to respond to the far west i
17 side in X minutes, when he gets to the far west side or to ;
18 the position where he is supposed to be for that particular .
j 19 contingency or for that particular scenario, he must have his 20 weapon.
J 21 MR. DETTMAN: Thank you.
22 MR. HILLYARD: H. W. Hillyard, Public Service 'l l
( g- 23 ' Company. I have- several questions. The first one I would l
24 like to ask you to. respond to is that.a number of places in I
'2s:
, Appendix' B and C you refer to members of the security organiza -
I
,- c0cc3edesaf cAeposten, Snc l 444 NOMTM CAPITOL STREET WA9NINGTON, D.C. 20001 fanal nas.asma ... . ... ,,
76 1
tion being required to do various things or to meet various a
2 We're having touble identifying how high up in our criteria.
3 Would you care to give us organization you intend that to go.
4 an interpretation?
L
S MR. MILLER: I think it was briefly discussed but 6 let me try another shot. If you identify, for example, the 7 shift supervisor as the individual on your particular site 8 who must use a piece of complicated radio equipment to notify 9 the LLEA, I think that was an example that was used, then that 10 individual must be trained in using that piece of equipment.
11 By the same token if you say to us that the plant superintend-12 ent will not be immediately responsible 'or taking control of 13 the action necessary to stop the event, then he does not have
'~'
14 to be trained.
15 MR. HILLYARD: 0.K. In Section 1 of Appendix B 16 there are it appears to me in B-2, B, and C and Section G two 17 requirements that conflict. B-2., B, and C has to do with the 18 determination of emotional stability and a statement in G has 19 to do with prohibiting the investigation into certain feelings 20 in the person's political beliefs., religion, and so on and so 21 forth. Would you tell me, please, how we implement both of 22 those without violating either one?
23 MR. MILLER: The feeling of the Commission was that
[ _)
24 for an armed individual you need to do everything possible to 25 determine his trustworthiness and stability. Therefore, the cAce. 9edeza[ cReprieu, Snc.
Add NORTH C APITOL STRECT WASHINGTON. D4 AM41 f wel 1s*.imn
77 1
words were put in for an arm d individual who should hava som7 2 type of psychological test, if you will. I guess I'm not--
3 that is not too good an answer for the second part. However, r 4 we will come back to you on specifically what the inferences (3
J 5 are, 6 MR. HILLYARD: The third question I have refers to 7 your requirement for familiarization with night firing and in 8 our plant and I think most plants, we are required to maintain 9 a light level of two tenths of a foot to handle the horizontal 10 at night. Is it your thought that we should qualify the night 11 firing under those lighting conditions and, if not, what did 12 you have in mind when you required familiarization with night 13 firing?
14 MR. MILLER: If you'll notice, there is no word 15 in there that you have to qualify at night. You have to be 16 familiar with it. The intent is, and I'm sure if you have 17 ever fired a weapon at night, you know there is a flash or a 18 glow, the intent is to familiarize the individual and I would 19 prefer to see it lessened to point two-foot candles but to 20 familiarize the individual so that he knows what that weapon l
21 is going to look like when he fires it at night. That is all.
22 MR. HILLYARD: Thank you.
.%j(^l 23 MR. YOUNG: J. Young, Portland General Electric.
24 Can you give us any more guidance on the contingency 25 procedures as to how they will differ from the responsidlity cAce 9edeza( cReportcu, Soc.
444 NCRTH CAPITOL STREET W ASHINGTON. 04. 20001 (aoa) 347 370o
, j
. .T V 1
1$ . matris of[the'.contingeney plan? ,
'j 2
- 2' JMR. ROE:n The responsibility, matrix will basically;
- 3~
' highlight-the tasks.or decision" actions that each individual
< , .4 must have andiits by event and it indicates by a: responsible -
5:
~
person. ' You .might call this the broad: overview in 'the' inter- ,
6 relationship between those particular tasks and:the1responsi-7 'bility for:conductingLthose' tasks. The procedures: Will be' 8 basically detailed concise' directions for.-each one:of those 9 particular' types of events.. So you are basically talking-10 about a different format and a:1evel, different level of'detai' ..
'11 The responsibility matrix, I would think,Ewould~be i 12 fairly concrete and not. changing in-its form too'much but you-13 -
may have procedures that:you want-to change the way you ap-O 14' proach specific.. directions and.this would'be the difference bei .
tween the-level of detail that you-would-have in the responsi-15 i
16- .bility matr1x which would tell you. basically the decision: i
, 17 actions to reach the. ob,jectives and then the: conc'ise and' run - i l
18 of' detailed instructions that you do have.in procedures.
19-MR. YOUNG: 0.K. '
- 20 -MR. ROE: There is one point we should make that I 21 made in my presentation and that is 1n some instances the -l l
22 responsibility matrix provides sufficient detail.-to become a l
( ' 23 procedure so there needs.to be no follow on information given l
,24 in that:particular. case. Where'you'have'found'that the 25 1 responsibility matrix meets that requirement, you should state cAce 9eclesal cAeporten, $nc l
444 NORTH CAPITOL STREET
. WASHINGTON, D.C. 20000 s amm1 n==_m-mm
l' 79 it in tha~procedura scetion so it-doesn8t appear there has e
2 been,a gap in information.
3- Regarding'the stated. difference in for-MR~. YOUNG:
4 mat.that'they may take, for exmnple, let's say that CAS' .
1 R e J 5 actions are the same on many of the events, so that when you 6 went to writing the procedures you may write specific procedures 7
for CAS and it would cover a number of events but it would be 8
the same procedure, so'I guess I could kind of'see you having 9
a manual on site that may have the responsibility matrix in
-10 there and then you may- have subsections in there that would 11 identify each guard's station. Then it would give his indi-12 vidual responses for these events. Do you see.something like 13 that for a possibility?
~
14 MR, ROE: That is one approach and there are other 15 approaches and we do not want to take basically the latitude 16 away from you and tell you which approach to take.
17 MR. HILTZ: John Hiltz of SMUD.
18 You spoke of Des in predeterminations in regard to 19 contingency plans. Could you relate this to contingency plans 20 that have already been submitted with the security plans?
21 'MR. CLARK: I'll try to. As a part' of the security O
22 plan that you submitted, as I mentioned in my brief presenta-
'( {]J 23 tion, you currently are required to have sections which ad-24 dress contingency planning and to address training. We expect 25 -
those sections to be in and to be approved by the NRC. There
~
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_ . . .__a . ,. ..
'(SSS) 847 3790
I 80 are no fees associated with those particular documents. If 2
it ' turned out to be and we know of, I guess I can say, no case 3
where the section from the security plan am as complete as
~
4 x those requirements now stated in Appendix B and Appendix C, J S this constitutes a change and additional approval by NRC and 6 those are the areas we are speaking of that require a fee.
7 Those things which are currently in your security filing will 8
be spproved but you should understand that as we stated in the 9
regional meetings in early spring of '77 that these were 10 interim pending the development of the guidance and the ef-11 fective rules relating to contingency planning and to the 12 guard training. You don' t look satisfied, John.
13 MR. HILTZ: We have had no comments to date on that
()
14 section in the plan and it's presumed you were putting off 15 looking at those until you reviewed--until you got into actual 16 contingency plan review. It is my feeling that is what' is 17 in there does meet the guidance put out and the treatments l 18 taken from that gnide.
19 MR. CLARK: There may be some plans which have at-20 tempted to do that and certainly Lf it is complete and requires, 21 no further review, there should be no charge, but I would say 22 that is the exception rather than'the rule. I have some i) 23 familiarity with SMUD and other than going to site specifics 24 I will say that we will review it again when we get back home 25 and I'll have to correspond with you.
cAce 9ederal cReporters, Dac.
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..s
l
~1 81 MR. HILTZ:. I guess what I'm really asking is we 2
see: no action. on our part to meet - the contingency plans sub- l 3
mittal since we feel'we have submitted it. Unt11 we hear 4
1 back from you we would not submit'anything.
J 5
MR. CLARK: We agree to the approach that we will 6 return our response to you. However, I don't believe we can I 7
indicatc that you have no responsibility. I think that that 8
is not the case but we are quite willing to work with you 9
and I will investigate it when I return.
10 MR. . MTIMR :- Anything else'l 11 If there is nothing else, I would like to thank all 12 of you for coming. We are getting through awfully early.- We g 13 certainly do appreciate it and we will' be in touch and we en-
'O
'y 14 courage you to be in touch. Thank you.
15 Off the record.
16-(Whereupon, at 12:10 p.m., . the hearing was closed.)
17 18 19 20 21 22 rj x 9 23 24
' 25 cAce. 9edesaf cReporten, Dac.
444 NORTM CAPITOL' STREET WASHINGTON. D.C. AQ
a r
e CERTIFICATE OF' REPORTER W
O This is to certify that the attached proceedings
- before: U. S. Nuclear Regulatory Commission ,
In the' matter of:
Name of Proceeding:
Implementation ~of 10 CFF 73, Appendices B and C, Guard Training and Contingency Planning Docket No.:
San Francisco, California
] Place:
l Date: October 5,~1978 were held as herein appears, and that this is the i
1 ORIGINAL transcript thereof for the files of the' l
Department.
i! Reporter 9
O 4
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