Independent Spent Fuel Storage Installation Inspector

Appendix XIII

Independent Spent Fuel Storage Installation Security Inspector Technical Proficiency

Training and Qualification Journal

TABLE OF CONTENT

INTRODUCTION………………………………………………………………………………………….3

Required ISFSI Security Inspector Training………………..…………………………………3 Supplemental Training…………………………………………………………………………..3 Refresher Training……………………………………………………………………………….4

ISFSI SECURITY INSPECTOR INDIVIDUAL STUDY ACTIVITIES………………………………..5

(ISA-IS-1) CFRs………………………………………………………………………………….5 (ISA-IS-2) Security Plan and Implementing Procedures…………………………………….8 (ISA-IS-3) Licensee Physical Security System…………………………..………………….11 (ISA-IS-4) Physical Barrier System………………………………….……………………….13

ISFSI SECURITY INSPECTOR ON-THE-JOB ACTIVITY…………………………………………16

(OJT-IS-1) Licensee Security Training Program……………...…………………………….16 (OJT-IS-2) Physical Barrier Systems……………………………………………………..….18 (OJT-IS-3) Access Authorization ………………………………………………………….20 (OJT-IS-4) Intrusion Detection and Assessment Equipment…....………………………...22 (OJT-IS-5) Access Control.…..……………………………………………………..………...24

ISFSI Security Inspector Technical Proficiency Level Signature Card and Certification (Regional)……………………………………………………………………………………………..26 ISFSI Security Inspector Technical Proficiency Level Signature Card and Certification (Headquarter)…………………………………………………………………………………….…..27 ISFSI Security Inspector Technical Proficiency Level Equivalency Justification (Regional)………………………………………………………………………………..……………28 ISFSI Security Inspector Technical Proficiency Level Equivalency Justification (Headquarter)……………………………………………………………………………..………….30

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INTRODUCTION

This journal includes the certification requirements for Independent Spent Fuel Security Storage Installation (ISFSI) security inspectors. The courses and technical proficiency areas are identified in the signature cards and equivalency justification forms at the end of this Appendix. Personnel looking to qualify as ISFSI security inspectors should not begin the activities or complete the courses in this qualification journal until they have completed a Basic Inspector Certification Journal. On-the-job-training is expected to take place in the company of a qualified senior inspector. Inspectors qualified under a previous security qualification journal (1246 (B3), 1247 or 1248) or as a reactor security inspector (1245, appendix C) are not required to complete another qualification board. All qualifications and training will be credited and indicated in the current qualification journal. Supervisors should complete an equivalency justification whenever an inspector is exempted from a course or requirement. However, if an inspector and their supervisor determine that any or all of these courses or requirements may be beneficial to enhance the inspector’s abilities, then those courses should be taken by previously qualified inspectors. Supervisors with security responsibilities having little or no previous security experience, although not required, should consider taking those courses listed below to enhance their knowledge and skills and to assist them in the performance of their duties. Supervisors may also designate another qualified individual to oversee this training and qualification journal process. REQUIRED ISFSI SECURITY INSPECTOR TRAINING Nuclear Technology for Security Course (R-105) Security Fundamentals Course (S-301) Safeguards Information Course (self-study) Explosives, Blast Effects and Breaching Field Course (S-502) Weapons and Tactics Fundamentals Field Course (S-501) Introduction to Emergency Preparedness (H-107) Advanced Intrusion Detection Course (S-503) Site Access Training (H-100) NRC Materials Control & Security Systems & Principles (S-201) If an inspector cannot attend one or more of the required courses listed above because of circumstances beyond his/her control, an alternative acceptable course may be substituted with documented management approval. Courses selected as an alternative should contain the fundamental information that will provide the inspector the basic knowledge, skills, and abilities as the courses identified above. SUPPLEMENTAL TRAINING Additional training beyond that identified as Required Training. This training will be determined by the individual's supervisor and will depend on the individual's previous work experience and

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planned inspection or licensing activities in specific areas. REFRESHER TRAINING Refresher training will be taken as needed. Site Access Training (H-100 or H-101)

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ISFSI Security Inspector Individual Study Activities TOPIC: (ISA-IS-1) CFRs PURPOSE: The Nuclear Regulatory Commission (NRC) requires that ISFSI licensees

establish, operate, and maintain a physical protection system and security organization in accordance with prescribed requirements identified in

10 CFR. The licensees’ must comply with applicable requirements, license conditions and/or NRC security orders or need to request and receive NRC approval to deviate from the requirements. Based on the aforementioned, it is imperative and mandatory that all security inspectors gain a comprehensive knowledge of the contents of applicable security requirements within the CFR, specific license conditions applicable to the licensee and NRC security-related orders. This activity will provide the inspector with detailed knowledge of the applicable requirements and how to inspect to ensure that licensees are complying with the appropriate security regulatory requirements.

COMPETENCY AREA: REGULATORY REQUIREMENTS LEVEL OF EFFORT: 48 hours REFERENCES: 10 CFR Part 2.390 (d), Public Inspections, Exemptions, Request for Withholding 10 CFR Part 25, Access Authorization 10 CFR Part 50.7, Employee Protection 10 CFR Part 50.9, Completeness and Accuracy of Information 10 CFR Part 50.54 (p), Conditions of Licenses

10 CFR 50.59, Changes, Tests, and Experiments 10 CFR Part 72, Licensing Requirements for the Independent Storage of Spent Nuclear Fuel, High-Level Radioactive Waste, and Reactor-Related Greater than Class C Waste

10 CFR Part 73.1, Purpose and Scope 10 CFR Part 73.2, Definitions 10 CFR Part 73.21, Requirements for the Protection of Safeguards Information

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10 CFR Part 73.22, Protection of Safeguards Information: Specific Requirements

10 CFR Part 73.23, Protection of Safeguards Information—Modified Handling: Specific Requirements

10 CFR Part 73.46, Fixed Site Physical Protection Systems, Subsystems, Components, and Procedures 10 CFR Part 51, Requirements for the Physical Protection of Stored Spent Nuclear Fuel and High-level Radioactive Waste 10 CFR Part 73.55, Requirements for the Physical Protection of Licensed Activities in Nuclear Power Reactors Against Radiological Sabotage 10 CFR Part 73.56, Personnel Access Authorization Requirements for Nuclear Power Plants 10 CFR Part 73.57, Requirements for Criminal History Checks of Individuals Granted Unescorted Access to a Nuclear Power Facility or Access to Safeguards Information (SGI) by Power Reactor Licensees 10 CFR Part 73.70, Records 10 CFR Part 73.71, Reporting of Safeguards Events 10 CFR Part 73, Appendices B, C, G, and H 10 CFR Part 75, Posting

EVALUATION CRITERIA: At the completion of this activity, and as determined by the supervisor, the

inspector should be able to:

1. Identify, recognize, and locate specific security related topics presented in the CFR and Appendices referenced above.

2. Describe the general objective of a licensee’s security program.

3. Recognize and discuss the definitions of terms and elements of a

security program identified in the CFR and Appendices referenced above

4. Delineate specific testing frequencies for security equipment

identified in the CFR. Delineate the qualification and requalification for security personnel and weapons. Recognize and discuss security event reporting requirements.

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5. Recognize and discuss security licensing activities. 6. Describe the role of the Federal Bureau of Investigation (FBI) with

respect to the licensee’s access authorization program. 7. Discuss the purpose of performing background checks and

fingerprint checks. 8. Discuss access authorization requirements. 9. Discuss activities regarding the proper control of classified,

safeguards, and other sensitive information.

TASKS: 1. Locate and review general and specific security activities described in the CFR. 2. Review the definition of classified information, SGI, and other

sensitive information, and understand the appropriate control measures for the information.

3. Review the information in the CFR related to the physical protection, access authorization, and training requirements for ISFSIs.

4. Determine what types of licensing actions can be submitted by

licensees using 10 CFR Part 50.54(p), 10 CFR Part 72 and 10 CFR Part 73. 5. Review the description and application of the design basis threat for

radiological sabotage and adversary characteristics. 6 Meet with your supervisor or a qualified reactor security, ISFSI

security or physical security inspector to discuss any questions you may have as a result of this activity. Discuss the answers to the questions listed under the Evaluation Criteria section of this study guide with your supervisor

DOCUMENTATION: ISFSI Security Inspector Proficiency Level Qualification Signature

Card Item ISA-IS-1

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ISFSI Security Inspector Individual Study Activity TOPIC: (ISA-IS-2) Security Plan and Implementing Procedures PURPOSE: The NRC requires certain ISFSI licensee to establish and implement

Physical Security, Training and Qualification and Safeguards Contingency Plans. Each licensee is also required to have procedures to implement their security plans. The security plans describe how the licensee will implement regulatory and license requirements. Because the security plans provide the basis for the implementation of the regulatory requirements in 10 CFR Parts 72 and 73, security inspectors shall be familiar with a licensee’s security plans before conducting an inspection at the facility. This activity will provide guidance on how to review the ISFSI’s security plans, which are available in the regional offices and in Headquarters, before an inspection; and how to review the site’s security implementing procedures available at the licensee’s facility.

COMPETENCY AREA: INSPECTION LEVEL OF EFFORT: 24 Hours REFERENCES: The NRC-approved Physical Security Plan for an ISFSI designated by

your supervisor

The NRC-approved Training and Qualification Plan for an ISFSI designated by your supervisor

The NRC-approved Contingency Plan for an ISFSI designated by your supervisor 10 CFR Part 50.54(p), 72 and appendices, 73.1, 73.2, 73.21, 73.22, 73.23, 73.55, 73.56, 73.57, 73 Appendix B and Appendix C Inspection Procedure 81311, “Physical Security Requirements for ISFSIs”

Regulatory Guide (RG) 5.12, “General Use of Locks in the Protection and Control of Facilities and Special Nuclear Materials”

RG 5.20, “Training, Equipping, and Qualifying of Guards and Watchmen”

RG 5.43, “Plant Security Force Duties” RG 5.44, “Perimeter Intrusion Alarm Systems”

RG 5.65, “Vital Area Access Controls, Protection of Physical Security Equipment, and Key and Lock Controls”

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RG 5.66, “Access Authorization Program for Nuclear Power Plants” RG 5.75, “Training and Qualification of Security Personnel at Nuclear Power Facilities” Draft Regulatory Guide DG-5033, “Security Performance (Adversary) Characteristics for Physical Security Programs for 10 CFR Part 72 Licensees.” (located in SLES)

NUREG–0908, “Acceptance Criteria for the Evaluation of Nuclear Power Reactor Security Plans”

NEI 03-01 “Nuclear Power Plant Access Authorization Program”

NEI 99-02 “Regulatory Assessment Performance Indicator Guideline”

NEI implementation Guidance for ICMs for ISFSIs located inside operating reactors PA, October 18, 2002, SLES NS100051-03

NEI Implementation Guidance for ICMs for ISFSIs not co-located at an operating reactor, October 18, 2002, SLES NS100051-05

NEI Implementation Guidance for ICMs for ISFSIs located on the OCA, October 18, 2002, SLES NS100051-06

EVALUATION CRITERIA: At the completion of this activity, you should be able to:

1. Discuss the general content of each of the security plans and their

regulatory basis. 2. Discuss specific areas where you would expect the licensee to have

developed more detailed implementing procedures (e.g., access authorization, compensatory measures, equipment testing, etc.)

3. Describe the components of protected area access controls,

physical security equipment, and key and lock controls. Describe how these are used by licensees to satisfy 10 CFR Part 72 Subpart H and 10 CFR Part 73.55 requirements.

4. Discuss the definition of terms provided in the security plans. 5. Discuss recent changes made to the security plans in accordance

with 10 CFR Part 50.54(p), and the reasons for the changes. 6. Discuss security plan commitments that may be more or less

restrictive than the applicable regulatory requirements.

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TASKS: 1. Locate a copy of the security plans for the assigned facility NOTE:

The Physical Security Plan and the Safeguards Contingency Plan generally contain safeguards information and should be controlled accordingly. The Training and Qualifications Plan may contain either safeguard or proprietary information and should also be controlled accordingly.

2. Locate copies of the regulatory requirements, regulatory guides, and

NUREG documents identified in the reference section above.

3. Review the security program plans, regulatory and guidance documents, and any other supporting documentation necessary to be able to discuss the topics identified in the Evaluation Criteria above.

4. Meet with your supervisor or a qualified inspector to discuss any

questions you may have as a result of this activity. Discuss the answers to the questions listed under the Evaluation Criteria section of this study guide with your supervisor.

DOCUMENTATION: Security Inspector Proficiency Level Qualification Signature Card

Item ISA-IS-2

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ISFSI Security Inspector Individual Study Activity TOPIC: (ISA-IS-3) Licensee Physical Security System PURPOSE: The NRC requires that a licensee be able to provide high assurance that

activities at the ISFSI do not constitute an unreasonable risk to public health and safety as addressed in 10 CFR Parts 73.51 and 73.55. This chapter specifies the specific elements which each licensee is required to address in the physical security plan to ensure their capability to detect, assess and communicate with their response force. For this reason, it is essential that all security inspectors gain a detailed knowledge of the actions that a licensee must complete to meet these requirements. This activity will provide security inspectors with detailed knowledge of the contents of the regulatory requirements and how to apply the requirements.

COMPETENCY AREAS: TECHNICAL AREA EXPERTISE LEVEL OF EFFORT: 24 hours REFERENCES:

10 CFR Parts 73.1, 73.51, 73.55 and Appendices B and C Inspection Procedure IP 71130.05 “Protective Strategy Evaluation” Inspection Procedure 81311, “Physical Security Requirements for ISFSIs” Draft Regulatory Guide DG-5033, “Security Performance (Adversary) Characteristics for Physical Security Programs for 10 CFR Part 72 Licensees.”

EVALUATION CRITERIA: At the completion of this activity, you should be able to perform the

following for the facility designated by your supervisor:

1. Discuss the regulatory requirements for the design, development, and implementation of a security defense strategy.

2. Discuss the threat and its associated design basis characteristics. 3. Demonstrate the ability to review and evaluate a licensee’s overall

Physical Protection System. This should include an evaluation of the licensee’s ability to respond to an external threat by focusing on: (a) the procedures developed to assess alarms (b) mitigative measures used when necessary, and (c) results of communication checks and liaisons with an offsite response force.

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4. Demonstrate the ability to evaluate the level of security officers’ regulatory and site-specific training to include proper access authorization, weapons employed, overall weapons training, manipulation of weapons, and marksmanship proficiency.

5. Demonstrate the ability to evaluate the effectiveness of licensee’s communication system, security alarm stations, detection and assessment aids, and physical barrier systems.

TASKS: 1. Read and obtain an in-depth understanding of the regulatory

requirements included in 10 CFR Parts 73.1, 73.51, 73.55, 73 App B and Part 73 App C.

2. Meet with your supervisor or a senior security inspector to discuss

any questions that you may have regarding the above activity and demonstrate that you can meet the evaluation criteria listed above.

DOCUMENTATION: Security Inspector Proficiency Level Qualification Signature Card,

Item ISA-IS-3

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ISFSI Security Inspector Individual Study Activity TOPIC: (ISA-IS-4) Physical Barrier System PURPOSE: The NRC requires that ISFSI licensees establish and implement physical

barriers in accordance with 10 CFR Parts 73.51 and 73.55(c). A description of the physical barrier system is provided in licenses’ security plans. Operation, maintenance, and testing of the physical barrier system should be described in the facility’s Security Plan Implementing Procedures. Security plans provide the basis for the implementation of the regulatory requirements in 10 CFR Part 73 associated with physical barriers, ISFSI security inspectors need to have a good understanding of the licensee’s security plans before conducting an inspection. This activity will provide guidance on how to review a facility’s security plans, available in the NRC’s regional offices and in Headquarters, before an inspection and the security implementing procedures associated with the physical barrier system, which are available at the facility, during an inspection.

COMPETENCY AREA: TECHNICAL AREA EXPERTISE LEVEL OF EFFORT: 16 Hours REFERENCES: NRC-approved Physical Security Plan for a facility designated by your

supervisor

NRC-approved Training and Qualification Plan for a facility designated by your supervisor

NRC-approved Safeguards Contingency Plan for a facility designated by your supervisor

10 CFR Parts 50.54(p), 73.51, 73.55(c), 73.71, 73 Appendix B, C and G Regulatory Guide 5.44 “Perimeter Intrusion Detection Systems’

Regulatory Guide 5.68, “Protection against Malevolent Use of Vehicles at Nuclear Power Plants”

NUREG/CR-6190, Vol. 1, “Protection against Malevolent Use of Vehicles at Nuclear Power Plants—Vehicle Barrier System Siting Guidance for Blast Protection”

NUREG/CR-6190, Vol. 2, “Protection against Malevolent Use of Vehicles at Nuclear Power Plants—Vehicle Barrier System Selection Guidance”

NUREG/CR-5722, “Interior Intrusion Detection Systems”

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GL 89-01 Supplement 1 and NUREG/CR-4250 Vehicle Barriers: Emphasis on Natural Features RIS 08-06 Protection against the Malevolent Use of Vehicles When Utilizing Landform Obstacles PDC-TR 06-03 Vehicle Barrier Maintenance Guide available in ADAMS ML070590251

SAND77-0777, “Barrier Technology Handbook,” Sandia National Laboratories, April, 1978

EVALUATION CRITERIA: At the completion of this activity, you should be able to:

1. Discuss the general content of the applicable portions of the security plans related to physical barriers and their regulatory basis.

2. Discuss specific areas where you would expect the licensee to have

developed more detailed implementing procedures. (I.e. compensatory measures, physical barrier testing and surveillance, etc.)

3. Discuss the definition of terms associated with physical barriers

provided in the security plans. 4. Discuss in general terms the operation of various types of physical

barrier systems currently used at nuclear facilities. 5. Discuss design goals of the vehicle barrier system. Describe how

licensees use barriers and vehicle controls to satisfy the requirements of 10 CFR Parts 73.51 and 73.55.

6. Discuss the concept of multiple physical barriers to protect a

protected area. 7. Discuss security plan commitments associated with physical

barriers that may be more or less restrictive than the applicable regulatory requirements.

TASKS: 1. Locate the regulatory requirements, guides, and NUREG

documents identified in the References section above.

2. Locate Security Plans for the assigned facility. Note:

The Physical Security Plan and the Contingency Plan generally contain safeguards information, and should be controlled accordingly. The Training and Qualifications Plan may contain either safeguards or proprietary information, and also should be controlled accordingly.

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3. Review the security plans, regulatory and guidance documents, and any other supporting documentation necessary to be able to discuss the topics identified in the Evaluation Criteria section, above.

4. Meet with your supervisor or a qualified inspector to discuss any questions you may have as a result of this activity. Discuss the answers to the questions listed under the Evaluation Criteria section of this study guide with your supervisor.


Card Item ISA-IS-4

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ISFSI Security Inspector On-the-Job Activity TOPIC: (OJT-IS-1) Licensee Security Training Program PURPOSE: The purpose of this activity is to prepare the inspector to independently

perform NRC inspections of security training programs to ensure that personnel assigned security duties meet the criteria in accordance with

10 CFR Part 72.180 and 10 CFR Part 73. COMPETENCY AREA: TECHNICAL AREA EXPERTISE LEVEL OF EFFORT: 16 hours REFERENCES:

Licensee Training and Qualification Plan

Licensee Physical Security Plan

Licensee Safeguards Contingency Plan

10 CFR Part 73.51, Requirements for physical protection of stored spent nuclear fuel and high-level radioactive waste

10 CFR Part 73, Appendices B and H 10 CFR Part 72, Subpart H--Physical Protection 10 CFR Part 72.180, Physical protection plan. 10 CFR Part 72.182, Design for physical protection. 10 CFR Part 72.184, Safeguards contingency plan. 10 CFR Part 72.186, Change to physical security and safeguards contingency plans.

EVALUATION CRITERIA: When you have completed this activity you will be able to do the following: 1. Determine which aspects of licensee training relate to regulatory

requirements. 2. Describe the training and qualification criteria that must be met by

personnel assigned to the licensee’s security organization before assuming security related duties.

TASKS:

1. Review the security officer training-related requirements in 10 CFR Part 73 App B and the licensee’s Security Training and Qualification plan.

2. Before visiting a site, meet with a qualified security inspector or your

supervisor and discuss the following:

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a. NRC policy related to handling licensee weapons. b. NRC policy on evaluating licensee staff shooting at the firing

range. c. NRC expectations on basic firearm safety.

3. Review previous inspection reports for items related to security

training. Remember to look for issues where corrective action involved security officer training.

4. Identify and review security implementing procedures related to

training.

5. Discuss with your supervisor or senior staff member, the NRC Enforcement Policy, enforcement expectations, processes, etc.

6. Review the security officer training schedule to identify training or

qualification activities that will be occurring during the inspection. 7. Review training records to determine if they reflect the approved

Security Training and Qualification Plan.

8. Meet with a qualified security inspector to discuss your independent assessment of the licensee performance relative to the tasks above. Be prepared to defend you assessment and provide examples to support your conclusions.

9. Meet with your supervisor or qualified security inspector to discuss

any questions you may have as a result of this activity and to demonstrate that you can meet the evaluation criteria listed in this activity.


Card Item OJT-IS-1.

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ISFSI Security Inspector On-the-Job Activity TOPIC: (OJT-IS-2) Physical Barrier Systems PURPOSE: ISFSI facilities are required to install and maintain physical barriers that

protect the facility, high-risk facility equipment and spent nuclear fuel in compliance with regulatory requirements and/or license conditions. It is vital that the inspector obtain the necessary information to make an informed and knowledgeable judgment regarding the effectiveness of security barriers. Upon completion of this activity, you will be able to identify information sources that could be used to assess the adequacy of security barriers.

COMPETENCY AREA: INSPECTION LEVEL OF EFFORT: 40 hours REFERENCES: Licensee security plan and implementing procedures.

10 CFR Part 73, “Physical Protection of Plants and Material” Inspection Procedure (IP) 71130.04 ‘Equipment Performance Testing and Maintenance” Regulatory Guide 5.68, “Protection Against Malevolent Use of Vehicles at Nuclear Power Plants” NUREG/CR-6190, Vol. 1, “Protection Against Malevolent Use of Vehicles at Nuclear Power Plants” NUREG/CR-6190, Vol. 2, “Protection Against Malevolent Use of Vehicles at Nuclear Power Plants”

EVALUATION CRITERIA: Upon completion of the tasks, you should be able to: 1. Describe and categorize required physical barrier systems

2. Describe how you would verify the effectiveness of physical barriers. 3. Describe which reference documents you would consult to verify

that physical barriers were installed and maintained in accordance with requirements and/or license conditions.

4. Describe how you would verify security organization activities to

evaluate physical barrier effectiveness.

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TASKS 1. Read security plan commitments that identify and describe physical barriers installed and maintained to ascertain that the barriers are in conformance with regulatory requirements.

2. Observe physical barriers to ascertain whether the barriers are

adequate and appropriately installed for their intended function. 3. Review appropriate licensee documentation that identifies

maintenance-related activities, problem identification and resolution of identified problems. Verify that maintenance and testing activities are conducted in accordance with 10 CFR Part 73.55(g) and licensee procedures.

4. Interview selected security personnel to determine their duties and

responsibilities related to physical barrier testing and maintenance. 5. Compare your evaluation results regarding physical barrier

effectiveness against those reached by the licensee. If there are differences, discuss the differences with your supervisor or a senior security inspector to understand why the difference exists.

DOCUMENTATION: Security Inspector Proficiency Level Qualification Signature Card

Item OJT-IS-2.

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ISFSI Security Inspector On-the-Job Activity TOPIC: (OJT-IS-3) Access Authorization PURPOSE: Each collocated ISFSI, decommissioning site ISFSI and away from reactor

ISFSI is required to ensure that only authorized personnel are granted unescorted access to the protected area. The purpose of this activity is to provide the security inspector information and guidance to adequately review the licensee’s access authorization program to ensure that unescorted access is granted only to approved personnel.

COMPETENCY AREAS: REGULATORY FRAMEWORK TECHNICAL AREA EXPERTISE ASSESSMENT AND ENFORCEMENT LEVEL OF EFFORT: 24 hours REFERENCES: 10 CFR Part 25, Access Authorization 10 CFR Part 73.21, “Requirements for the Protection of Safeguards

Information” 10 CFR Part 73.51, “Requirements for Physical Protection of Stored Spent

Nuclear Fuel and High-Level Radioactive Waste” EA -02-261,”Issuance of Order for Compensatory Measures Related to

Access Authorization’ IP 81311, “Physical Security Requirements for ISFSI’s” NEI 03-01, “Nuclear Power Plant Access Authorization Program” EVALUATION CRITERIA: Complete the tasks specified in this on-the-job training (OJT) guide and

meet with your supervisor or a senior security inspector to discuss any questions that you may have. Upon completion of this activity, you should be able to:

1. Generally describe the process licensees would use for granting an

individual unescorted access to the facility, ISFSI or stand-alone ISFSI.

2. Describe the elements of the required background investigation that

licensees must complete on all individuals seeking unescorted access to protected and vital areas.

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3. Describe the other areas that a licensee must complete prior to issuing an individual a security badge granting unescorted access (e.g., fitness-for-duty, radiation safety training, etc.).

TASKS:

1. Read 10 CFR Part 73.21, “Requirements for the Protection of Safeguards Information”

2. Read IP 81311, “Physical Security Requirements for ISFSI’s”

3. Read 10 CFR Parts 73.56, and 73.57

4. Read information notices regarding access authorization.

5. Read NEI 03-01, ‘Nuclear Power Plant Access Authorization

Program”

Meet with your supervisor or a senior security inspector to discuss any questions you may have as a result of this activity. DOCUMENTATION: Security Inspector On-the-Job Qualification Signature Card, Item

OJT-IS-3.

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ISFSI Security Inspector On-the-Job Activity TOPIC: (OJT-IS-4) Intrusion Detection and Assessment Equipment PURPOSE: The NRC requires each ISFSI licensee (including stand-alone ISFSIs) to

establish, maintain, and implement/use onsite intrusion detection and assessment equipment as part of a physical protection system designed to protect against the threat of radiological sabotage. The detection and assessment of penetration or attempted penetration of the protected area or the isolation zone adjacent to the protected area barrier is required to assure that licensee’s security staff can adequately respond as necessary. The licensee’s Physical Security Plan describes the required equipment, specifications and capabilities of the detection and assessment equipment. Consequently, it is mandatory that all security inspectors have a detailed understanding of the design, capability, and applicable requirements and license conditions related to the licensee’s intrusion detection and assessment equipment. The purpose of this on-the-job activity is to provide the inspector with the knowledge and understanding of security equipment and the applicable requirements needed to independently conduct security inspection activities in this area, including evaluation, assessment, and the review of associated supporting material.

COMPETENCY REGULATORY FRAMEWORK AREAS: TECHNICAL AREA EXPERTISE INSPECTION PROBLEM ANALYSIS ASSESSMENT AND ENFORCEMENT

NOTE: The following courses must be completed before beginning this

activity:

1. Physical Security Fundamentals Course (S-301).

2. Introduction to Physical Security Systems Course (S-118S) self study course.

3. SGI self-study course.

LEVEL OF EFFORT: 32 hours REFERENCES: IP 81311, “Physical Protection Requirements for ISFSIs” 10 CFR Part 73.51, “Requirements for Physical Protection of Stored Spent

Nuclear Fuel and High-Level Waste” RG 5.44, “Perimeter Intrusion Alarm Systems”

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RG 5.61, “Intent and Scope of the Physical Protection Upgrade Rule Requirements for Fixed Sites”

W-A-450C/1, “Federal Specification Components for Interior Alarm

Systems, Balanced Magnetic Switches” W-A-450B, “Federal Specification Interior Security Components for Alarm

Systems” EVALUATION CRITERIA: At the completion of this activity, you should be able to demonstrate your

ability to conduct an on-site inspection of an NRC ISFSI licensee’s intrusion detection and assessment equipment and support equipment by performing the following:

1. Discuss the fundamental principles of operation and typical design

features associated with commonly used protected area perimeter and vital area detection devices including:

• E-field detection devices • Infrared detection devices • Microwave detection devices • Motion detection devices • Vibration detection devices • Balanced Magnetic Switches • Any other intrusion detection systems sensors and devices utilized by licensees

2. Discuss the fundamental principles of operation and typical design

features associated with commonly used protected area perimeter and intrusion assessment equipment including: • Pan-tilt-zoom cameras (PTZ) • Closed circuit televisions (CCTV) • Video Image Capture systems (VICS) • Video and digital recording systems • Any other assessment systems and devices utilized by l licensees

3. Identify the 10 CFR Parts 73.51and 73.55 requirements for ISFSIs

associated with the above intrusion detection and assessment devices and equipment.

4. Explain how a licensee incorporates applicable requirements into its

specific requirements.

5. Explain how an NRC security inspector inspects the above intrusion detection and assessment devices and equipment through use of the associated NRC inspection procedures.

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6. Explain how licensees test equipment to ensure compliance TASKS: These required tasks should be performed in NRC offices or on site, as

appropriate, in conjunction with participation in an on-site security inspection.

1. Conduct on-site system walk downs and gain a practical understanding

of the fundamental principles of the operation and typical design features associated with the following commonly used protected area perimeter and vital area detection devices (subject to on-site availability of the devices):

• E-field detection devices • Infrared detection devices • Microwave detection devices • Motion detection devices • Vibration detection devices • Balanced Magnetic Switches • Any other intrusion detection systems sensors and devices utilized

by licensees

2. Conduct on-site system walk downs and gain a practical understanding of the fundamental principles of the operation and typical design features associated with of the following commonly used protected area perimeter and vital area intrusion assessment equipment (subject to on-site availability of the equipment):

• PTZ • CCTV • VICS • Video and digital recording systems • Any other assessment systems and devices utilized by licensees

3. Read 10 CFR 73.51 and gain a comprehensive understanding of the

requirements for an ISFSI associated with the above intrusion detection and assessment devices and equipment.

4. Review licensee documents to identify where the licensee has

incorporated applicable requirements into its specific requirements.

5. Accompany an NRC security inspector in the performance of an on-site inspection and gain an understanding of how to inspect the above intrusion detection and assessment devices and equipment through use of the associated NRC inspection procedures (subject to on-site availability of the devices and equipment). Discuss those which may not be available

DOCUMENTATION: ISFSI Security Inspector Proficiency Level Qualification Signature Card Item OJT IS-4.

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TOPIC: (OJT-IS-5) Access Control PURPOSE: Each ISFSI is required to ensure that only authorized and cleared

personnel, materials, and vehicles enter the protected area and vital areas. Licensees are required to check personnel, materials, and vehicles for proper identification and authorization, and search for devices such as firearms, explosives, and incendiary devices or other items which could be used for radiological sabotage prior to admittance into the protected area. The purpose of this activity is to provide information and guidance for a security inspector to adequately review the licensee’s Access Control program and methods in place to ensure that personnel controlling access points properly identify, authorize, and search all personnel, materials and vehicles entering the protected area.

COMPETENCY AREAS: REGULATORY FRAMEWORK

TECHNICAL AREA EXPERTISE INSPECTION ASSESSMENT AND ENFORCEMENT

LEVEL OF EFFORT: 12 hours REFERENCES: 10 CFR Part 73.51, “Requirements for Physical Protection of Stored Spent

Nuclear Fuel and High-Level Waste” IP 81311, “Physical Protection Requirements for ISFSIs”

Regulatory Guide 5.7, “Entry/Exit Control for Protected Areas, Vital Areas, and Materials Access Areas” ASTM F792-82, “Standard Practice for Design and Use of Ionizing Radiation Equipment for the Detection of Items Prohibited in Controlled Access Areas” NEI Personnel Access Data System (PADS)

EVALUATION CRITERIA: Complete the tasks specified in this OJT guide and meet with your

supervisor or a senior security inspector to discuss any questions that you may have as a result of this activity. Upon completion of this activity, you should be able to:

1. Describe which reference documents you would consult to verify

that hardware devices and physical barriers in place to control access were installed and maintained in accordance with commitments.

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2. Describe how you would verify the effectiveness of the access control methods.

3. Describe the purpose and use of an electronic key card system for

gaining access to the facility protected area. 4. Describe the purpose, use, and types of available biometric devices

in use at many facilities. 5. Describe the functions served by the central and secondary alarm

stations in ensuring that only authorized personnel are granted unescorted access.

6. Describe “tailgating” and methods that licensees may use to prevent

or minimize it. 7. Describe NEI PADS and its interfaces with licensees’ access

authorization programs. 8. Describe the importance of always wearing a security badge while

inside the facility protected. Describe what occurs if an individual loses his/her security badge.

9. Describe the importance of the licensee updating their approved

access control log. TASKS: 1. Read Inspection Procedure (IP) 81311, “Physical Protection Requirements for ISFSIs.” 2. Read 10 CFR Part 73.51 and 10 CFR Part 73.55.

3. Read information notices regarding access control. 4. RG 5.7, “Entry/Exit Control for Protected Areas, Vital Areas, and

Materials Access Areas.” Meet with your supervisor or a senior security inspector to discuss any questions you may have as a result of this activity

DOCUMENTATION: ISFSI Security Inspector On-the-Job Qualification Signature Card, Item OJT-IS-5.

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Regional ISFSI Security Inspector Technical Proficiency Level Signature Card and Certification

Inspector’s Name

Employee Initials / Date

Supervisor’s Signature / Date

Required Training Courses

Nuclear Technology for Security Course (R-105)

Security Fundamentals Course (S-301)

Introduction to Physical Security Fundamentals (S-101)

Explosives, Blast Effects and Breaching Field Course

(S-502)

Weapons and Tactics Fundamentals Field Course

(S-501)

Introduction to Emergency Preparedness (H-107)

Advanced Intrusion Detection & Assessment Course

(S-503)

Safeguards Information Course (self study)

Materials Control & Security Systems & Principles (S-201)

Individual Study Activities (ISA-IS-1) Code of Federal Regulations (CFRs)

(ISA-IS-2) Security Plan and Implementing Procedures

(ISA-IS-3) Licensee Protective Strategies

(ISA-IS-4) Physical Barrier System

On-the-Job Activities

(OJT-IS-1) Licensee Security Training and Qualification

(OJT-IS-2) Physical Barrier Systems

(OJT-IS-3) Access Authorization

(OJT-IS-4) Intrusion Detection and Assessment Equipment

(OJT-IS-5) Access Control

Supervisor’s signature indicates successful completion of all required courses and activities listed in this journal and readiness to appear before the Oral Board. Supervisor’s Signature: ________________________________ Date: ____________

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Headquarters ISFSI Security Inspector Technical Proficiency Level Signature Card and Certification

Inspector’s Name:

Employee Initials / Date

Supervisor’s Signature / Date

Required Training Courses Nuclear Technology for Security Course (R-105)



Explosives, Blast Effects and Breaching Field Course

(S-502)

Weapons and Tactics Fundamentals Field Course

Introduction to Emergency Preparedness (H-107)

Advanced Intrusion Detection & Assessment Course (S503)

Safeguards Information Course (self study)

NRC Materials Control & Security Systems & Principles (S-201)

Individual Study Activities (ISA-IS-1) Code of Federal Regulations (CFRs)



(ISA-IS-4) Physical Barrier System


(OJT-IS-1) Licensee Security Training and Qualification





Supervisor’s signature indicates successful completion of all required courses and activities listed in this journal and readiness to appear before the Oral Board. Supervisor’s Signature: ________________________________ Date: ____________

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Form 1:

Regional ISFSI Security Inspector Technical Proficiency Level

Equivalency Justification


Inspector Name: Identify equivalent training and experience for which the inspector is to be given credit.

Nuclear Technology for Security Course

(R-105)



Explosives, Blast Effects and Breaching Field Course (S-502)

Weapons and Tactics Fundamentals Field Course (S-501)

Introduction to Emergency Preparedness

(H-107)

Advanced Intrusion Detection & Assessment Course (S-503)


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Individual Study Activities

(ISA-IS-1) Code of Federal Regulations (CFRs)



(ISA-IS-4) Physical Barrier Systems


(OJT-IS-1) Licensee Security Training Program





Supervisor’s Recommendation: Signature / Date Division Director’s Approval: Signature / Date Copies to: Inspector and official training file

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Form 2:

Headquarters ISFSI Security Inspector Technical Proficiency Level

Equivalency Justification

Inspector Name: Identify equivalent training and experience for which the inspector is to be given credit.


Nuclear Technology for Security Course (R-105)



Explosives, Blast Effects and Breaching Field Course (S-502)

Weapons and Tactics Fundamentals Field Course (S-501)

Introduction to Emergency Preparedness

(H-107)

Advanced Intrusion Detection & Assessment Course (S-503)


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Supervisor’s Recommendation: Signature / Date Division Director’s Approval: Signature / Date Copies to: Inspector and official training file

Individual Study Activities

(ISA-IS-1) Code of Federal Regulations (CFRs)



(ISA-IS-4) Security Barrier System


(OJT-IS-1) Licensee Security Training and Qualification Plan

(OJT-IS-2) Security Barrier Systems

(OJT-IS-3) Access Control (of personnel, materials, and vehicles



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Documents

Independent Spent Fuel Storage Installation Inspector