NRC Generic Letter 1978-30
| ML031280381 | |
| Person / Time | |
|---|---|
| Issue date: | 08/04/1978 |
| From: | Miller J R Office of Nuclear Reactor Regulation |
| To: | |
| References | |
| NUREG-0219 GL-78-030 | |
| Download: ML031280381 (4) | |
-eIREG(,eI -C~..AW***.46 A-A UNITED STATESNUCLEAR REGULATORY COMMISSIONWASHINGTON. 0. C. 20555August 4, 1978G;L- 7g-3c)All Power Reactor LicenseesGast 74p SGentlemen:This letter and enclosed NUREG-0219 titled "Nuclear Security Personnel forPower Plants, Content and Review Procedures for a Security Training andQualification Program," dated July 1978, are being sent to all licenseesauthorized to operate a nuclear power reactor and to all applicants withapplications for a license to operate or construct a power reactor.Within the next few weeks the Commission is scheduled to publish in finalform amendments to 10 CFR 73 to impose upgraded qualification, training,and equipping requirements for security personnel protecting against theftof special nuclear material and industrial sabotage of nuclear facilities ornuclear shipments. The enclosed document provides a basis on which commercialnuclear reactor applicants and licensees can develop acceptable programs toimplement these new requirements.A second draft of this document was published for comment on April 21, 1978and as a result the staff has considered the comments received and incorporatedmany changes. The following summarizes the major comments received and howthe NRR staff addressed them in preparing the final document:1. Approximately one third of the 32 that commented stated that thesample plan indicated an excessive amount of detail and theguidance should not exceed that currently given for safety relatedtraining.The final document contains only 25 pages of guidance (Parts 1&2);the remainder is a sample plan. The sample was provided to assistthe applicants and licensees in preparation of a plan based on a newapproach. As noted in item 3 below, the sample should not beconsidered a requirement.The staff reformated the sample plan to reduce the amount ofdetail and removed many tasks based on the ratings submitted inresponse to the request in Draft 2. This resulted in a reductionof 46% in the number of pages devoted to performance objectives(173 vs. 94) and a reduction of 44% in the number of performanceobjectives (344 vs. 191). A further reduction should be realizedwhen the site analysis is completed, since the sample plan includesmany tasks that are not appropriate for all sites.WbCA S
-2-2. Many comments stated that the number of onsite evaluations bythe NRC was excessive (i.e., 1 by NRR every 2 years and 3each year by I&E).The I&E schedule set forth in the draft was based on theestablished frequency of onsite I&E physical securityinspections with the assumption that these inspectionswould be expanded to include training and personnelqualification. However, all references to I&E inspectionhave now been deleted from the final version since thisdocument addresses NRR policy only.3. Some commented that although we state that each site isrequired to develop a qualification program based on a sitespecific job analysis, that the NRR reviewers would treat thesample plan in NUREG-0219 as the only acceptable approach.The NRR staff feels that the sample plan provides valuableguidance and should remain in the document. However, the finalversion was revised to stress that the sample is not a require-ment. One example is found on page 1-1 and reads:"It must be stressed that it is the responsibilityof each site, using the methodology described in thisdocument, to identify its site-specific tasks, elements,and performance objectives. The security programselected must evaluate each individual's ability toimplement the site-approved physical security andcontingency plans. Training and evaluation are notdone for their own sake.The sample qualification plan found in part 3 shouldnot be considered a requirement, but only a guide;Each specific site plan is reviewed on its own merits."4. Other comments stated that tasks shown in the sample were tooextensive. They indicated that the sample program exceededthat required by most military and police organizations and/orthe requirements to meet the 73.55 threat level. A few commentedthat the type of response indicated in the sample plan is outsidethe responsibility and capabilities of private security.The applicants and licensees are required to identify in theirqualification plan only those security tasks critical tosuccessful implementation of the site contingency and physicalsecurity plans. If a licensee can develop acceptable contingencyplans that meet the threat and do not require police or militarytactics, then the tactical tasks can be deleted. However, itmust be realized that the military and police are the onlyorganizations with experience dealing with such problems. Thevast majority of the military and police related tasks containedin the sample are at the basic training level.
-3 -5. Finally, a few commented that the NRC should hold workingsessions with the utilities to develop its detailed requirements.Although the actual development of training and qualificationplans are the responsibility of each licensee, NRR is planningto hold a series of workshops with the utilities to develop amutual understanding of how to implement the methodologydescribed in NUREG-0219. These workshops will be small anddevoted to actual plan development.Additional copies of NUREG-0219 can be obtained from the National TechnicalInformation Service, Springfield, Virginia 22161 at current prices.Sincerely,,-'; " ,James R. Miller, Assistant Directorfor Reactor SafeguardsDivision of Operating ReactorsEnclosure:NUREG-0219cc w/o enclosure:Service List Consolidated Edison Company of -2 50-3New York, Inc. 50-274.cc: White Plains Public Library100 Martine AvenueWhite Plains, New York 10601Leonard M. Trosten, EsquireLeBoeuf, Lamb, Leiby & MacRae1757 N Street, NW.Washington, D.C. 20036Anthony Z. RoismanNatural Resources Defense Council917 -15th Street, NWWashington, D.C. 20005Paul S. Shemin, EsquireAssistant Attorney GeneralState of New YorkDepartment of LawTwo World Trade CenterNew York, New York 10047Sarah Chasis, EsquireNatural Resources Defense Council122 East 42nd StreetNew York, New York 10017I