IR 05000266/1991007
| ML20024G893 | |
| Person / Time | |
|---|---|
| Site: | Point Beach  |
| Issue date: | 04/24/1991 |
| From: | Creed J, Madeda T NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION III) |
| To: | |
| Shared Package | |
| ML20024G889 | List: |
| References | |
| 50-266-91-07, 50-266-91-7, 50-301-91-07, 50-301-91-7, NUDOCS 9105020059 | |
| Download: ML20024G893 (10) | |
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V.S. HUCLEAR REGULATORY C0f tMISS10N REGION 111 Reports No. 50-266/91007(DRSS);50-301/91007(DRSS)
Licenses No. DPR-24; DPR-27 Licensee: Wisconsin Electric Power Company 231 West Michigan Milwaukee, WI 53201 facility Name:
Point Beach Nuclear Plant, Units 1 and 2 Inspection Att Plant Site, Two Rivers,llege, Appleton, Wisconsin Wisconsin Fox Valley Technical Co-NRCRegion-lllOffice(In-OfficeReview)
Inspection Dates:
Between March 18 and 28 -1991 hY[f/
Inspector:
fm
,2 T. 4/. Mafeda Dater
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Physical Security Inspector Approved By:
kkuh kJ/9/
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Q.fR. Creed. Chief Date STifeguards Section
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Inspection Summary
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Ingection between March 18 and 28,1991 (Reports !!o. S0-266/91007(DRSS);
Fo. 50-301/91007(DR55))
Areas Inspected:
Included review of information pertaining.to the following specific allegations:
(1) students at Fox Valley Technical College.(FVTC)
have been cheating on examinations since 1984 and recent licensee-findings of cheating are not isolated; (2) licensee management oversight of the security trainingprogramhasbeeninadequate;(3) administrative-controlsoftraining
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at FVTC are weak; and (4) accurate assessment of student's shooting ability-is
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precluded by firing range practices. We reviewed the extensive investigation completed by the licensea and independently verified selective facts..
Results:
No violations of NRC requirements were noted during the. inspection.
Dur review showed, however, that.some students cheated on intermediate progress tests to varying degrees since about 1986, but that they had successfully passed final tests and demonstrated their ability to successfully perform their duties.
Licensee management oversight of the training program was weak. Administrative controls of tests at the training contractor s facility were weak which 9105020059 910426 PDR ADOCK 05000266
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contributed to the opportunity for cheating.
However, it was r.ct substantiated
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that students have slept in class or that no one fails. We determined that
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sor.ie firearms range practices were inconsistent but that the inconsistencies l
did not affect the accurate assesstnent of a student's ability to shoot.
The
licensee began taking action to correct the weaknesses when they were initially
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identified as a result of their internal investigation.
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DETAll.S 1.
Key persons Contacted In addition to the key members of the licensee's staff listed below, the inspector interviewed other members of the security organization.
The asterisk (*) denotes those present at a meeting conducted onsite on March 20, 1991, to discuss initial inspection findings.
- G. Maxfield, Plant Manager, Point Beach t!uclear plant
- J. Zach, Corporate Director
- R. Seizert, Superintendent-Regulatory and Support Services
- J. McCullum, Security Supervisor
- C. Meyer, Corporate Security Officer J. Makowski, Security Specialist / Investigation, Corporate T. Ec11s, Security Representative, Corporate B. Alm, Training Officer, Stanley Smith Security Company police Science-Department Coordinator, Fox Valley Technical E.Krueger(FVTC)
College N. Strehlow, Instructor, FVTC J. Antoon, Instructor, FVTC K. Schneider, Weapons Instructor, FVTC
'J. Gadzala, Resident inspector, ilRC 2.
Entrance and Exit Interviews a.
At the beginning of the inspection, the Superintendent-Regulatory and Support Services was informed of the purpose of this visit and the areas to be examined.
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The inspector met onsite with the licensee representatives denoted
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in Section 1 on March 20, 1991, to discuss preliminary inspection results and to indicate that additional in-office review would be necessary to complete our evaluation of relevant documents and licensee corrective actions. On March 28, 1991, a telephone exit interview was held with the Corporate Security Officer. A general description of the scope of the inspection was provided.
Briefly listed below are the findings discussed during the exit interview.
The details of each finding, HRC review, and our conclusions are discussed and referenced in Section 4 of this report, included below is a statement provided by or describing licensee management's
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response.
l No violations were identified.
However, based on inspection results, two weaknesses were identified in the security training program. One involved inadequate proctoring and grading of examinations by instructors at the Fox Valley Technical College.
This weakness manifested by cheating by some students on some progress tests. This type of behavior was verified to have
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I existed since 1986. The itRC considers the action of cheating in any form to be a serious problem, which must be aggressively
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addressed and positively resolved.
As referenced in Section 4, the licensee recognized the scope and seriousness of the issues noted above and has developed corrective measures to address the problems of student cheating during the examination process.
The second weakness identified that licensee oversight of the security training progrtm lacked an adequate level of monitoring of some aspects of the training program particularly in classroom overview activities.
The licensee recognized and acknowledged the weakness.
The licensee has implemented actions, as referenced in Section 4, that will strengthen classroom oversight monitoring activities for the security training program. This action also required FVTC to improve their oversight of training activities at the college.
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3.
Program Areas inspected (MC 0610)
Listed below are the areas which were examined by the inspector within the scope of these inspection activities.
These areas were reviewed and evaluated as deemed necessary by the inspector to meet the licensee's approved security plan.
Sampling reviews included interviews, observations and document reviews that provided independent verification of your ability to meet security commitments. The depth and scope of activities were conducted as deemed appropriate and necessary for the program area inspected, pumber Program Area and Inspection Requirements Reviewed 81501 Training and Qualification - General Requirements:
(01)
General Requirements; (02) Training and Qualification program; (03)GeneralTraining;(04)DemonstrationofAbilities;(05)
Documentation; (08) Security r.nowledges Skills, and Abilities; (11) Weapcas Qualification and RequalifIcation Program.
Training and Qualification - General Requirements (IP 81501):
(Closed)
Allegation No. Rill-91-b 0011.
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1he inspector's review of the above allegations was conducted between March 18 and 28, 1991.
Inspection activities were conducted at the Point Beach site and at fox Valley Technical College which is located in Appleton, Wisconsin, between liarch 18-20, and at the NRC Region !!!
office between March 25 and 28, 1991.
The specific allegations, NRC review action, and conclusions are described below:
Allegation No. 1:
Students at the Fox Valley Technical College (FVTC)
have been cheating on examinations since 1984 and recent licensee findings of cheating are not an isolated case.
NRC Review: On December 21, 1990, during a. routine backshift inspection, l
I the Point Beach Nuclear Plant (PDNP) Security Supervisor (SS) was told by a plant employee that individuals in the August 1990 security officer recruit cless cheated on tests.
This issue was reported to plant
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management and the licentee's corporate security department.
On January 3,1991, the licensee initiated an investigation to determine the validity of the alleged cheating issue.
The licensee notified pegion III of the concern.
The licensee investigation included interviews with all security recruits (10)intheAugust1990trainingclassandcognizantsecurity instructors at FVTC.
The licensee investigation of the class of August 1990 identified inappropriate behavior that resulted in confirmed significant acts of cheating relating to progress tests. The acts of cheating included:
(1) changing answers while correcting tests; (2) changing answers after testingwescompleted;(3)lookingforanswer' in class manuals and handouts while taking tests; and (4) discussions of test questions during testing.
The above information was documented in a series of voluntary statements provided to the licensee by the class of August 1990. All ten merbers of the class signed the statement.
Class members also acknowledged
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in statements that at the beginning of recruit school they were verbally advised by the FVTC instructor that tests were not open book and that they were to report anyone involved in cheating.
However, no member of the class voiced a concern regarding the practice of cheating or reported their observations to FVTC, PBNP or the security contractor.
After confirming and evaluating the acts of cheating, the licensee suspended site area access to the 10 individuals on January 11, 1991, and the security contractor terminated their employment on January 15, 1991, for cheating.
The licensee expanded the scope of their investigation to review the actions of previous classes because some members of t h August 1990 class alleged that cheating took place in previous training classes at FVTC.
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Specific names of individuals were provided to the licensee.
They interviewed 17 security officers from previous classes.
Members of the Parch 1990 class confirmed that open discussions between students occurred during progress tests. Statements showed that class members would openly discuss clarification of specific test questions, resulting in discu nion and opinions of answers.
in addition, based on licensee interviews with members of the recruit classes of July 1986, July 1989 and November 1989, they verified that open discussions were conducted for the purpose of clarifying ambiguous test questions. Most of the officers interviewed recalled that at the start of the recruit school, the FVTC instructor told them tests were not open book and any cheating was to he reported.
None was reported.
The licensee investigation concluded that significant acts of student cheating as referenced above occurred at FVTC pertaining to the August 1990 recruit class and that inappropriate testing behavior consisting of only group discussions by students in previous recruit training classes at FVTC was identified. The above noted behavior was
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confin'ed to only progress tests. The licensee determined inappropriate testing behavior to mean cheating was to a lesser degree than the actions (
of the August 1990 class.
The licensee's investigation concluded that the testing protocol followed by FVTC for recruit classes was inadequate to prevent cheating as described.
During progress tests, the FVTC instructor would generally leave the classroom and students would be left on their honor not to cheat.
The licensee investigation identified no acts of cheating or inappropriate testing behavior by students regarding class final examinations conducted at FVTC.
The licensee investigation was concluded on January 12, 1991.
Af ter the investigation, a complete retest of the security force was conducted by the licensee on January 15 and 17,1991, using an entirely (
newcertificationtest(finalexamination). The retest was intended l
to innediately establish the knowledge and abilities of security officers to conduct their duties in an appropriate and effective manner.
All officers successfully passed the retest.
In addition, licensee review of all previous onsite training records for the retested officers identified no past training concerns or problems in officer performance.
The members of the August 1990 class had their site access suspended 3rior to the retest and did not participate.
The licensee concluded t1at the significance of the acts of cheating was reduced based on the demonstrated ability that guards passed a retest and their onsite performance was
evaluated to be adequate.
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The inspector's review of this allegation, consisted of a detailed review of the licensee's investigation, review of related documents and selected interviews of current security force members that the licensee had interviewed during their investigation.
The inspector also interviewed cognizant site and corporate security licensee staff members FVTC personnel, and some site security contractor management personnel, inspection results confirmed the accuracy and conclusions of the licensee's investigation report pertaining to cheating on progress tests by current and past security force members. The inspector confirmed through review of the licensee's investigation report and interviews with cognizant licensee investigators that the acts of cheating occurred only during progress tests.
Interviewed guards also confirmed this fact.
Review of the licensee investigation and interviews did not confirm or identify any potential acts of cheating or inappropriate test behavior during final examinations.
progress tests are given by FVTC at the completion of each topic / unit of study. The FVTC training program consists of approximately 22 progress tests followed by a comprehensive final examination which encompasses all study material.
Our review of the licensco's security plan, training and qualification plan, security procedures and the appropriate portions of 10 CFR 73 showed no specific requirenents or mention of the issue of honesty in testing.
However, Section 2.B.I. of Appendix B to Part 73 states that security personnel shall demonstrate the capability to exercise good judgment C
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i during assigned job dsties.
NRC review, notwithstanding the facts of confirmed acts of cheating, concluded that no information was identified during personnel interviews or review of security training records to show that personnel did not show good judgment or perform inadequately during onsite security duties. Therefore, no violation of an NRC requirement was identified.
However, the NRC does not condone the act of cheating.
Recognizing weaknesses in their training program, the licensee initiated corrective actions.
These actions included: (1) all tests (progress and final oeminations) proctored by FVTC will be continuously monitored by instructors to assure that cheating does not take place; (2) all student recruit classes will be advised orally and in writing that cheating is prohibited, define cheating and require students to report any acts of cheatingt and (3) the security contractor Will begin administering a personality inventory test to all new recruits. The test is designed to evaluate personal integrity end honesty.
The above actions will be implemented prior to the next recruit school.
This is an Open item.
Licensee action will be reviewed during a future inspection.
(50-266/91007-01; 50-301/91007-01)
Conclusion:
Inspection results substantiated that students cheated on some progress tests that were administrated at FVTC between July 1986 and
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August 1990, and that the cheating was not isolated to one case or one class.
Cheating prior to July 1986 was not identified and therefore was not substantiated.
The security significance of the cheating was low because no indication of cheating was alleged, identified or confirmed on final examinations and no significant failures in onsite security officer performance was noted.
No regulatory violations were noted.
However, the NRC does not condone the act of cheating.
The licensee has initiated action to reduce the possibility of cheating on future examinations.
Implementation of these actions will be reviewed during
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future NRC inspections.
Allocation No. 2:
Oversight of the security training program by licensee
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management has been inadequate.
NRC Review:
Interviews with the Corporate Security Officer and the Site i
5ecurity Supervisor showed that about each four-to-six weeks, meetings are held onsite or at the training school with representatives of Fox Valley
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Technical College to discuss the security training program. Discussions concentrated on reviewing and evaluating program content and discussions of new training classes and techniques. The Corporate Security Officer indicated that the specific allegations described in Items 1, 3, and 4, noted in this report, apply to very specific elements of the training program and since there has been no indication of problems in those areas they would not generally be a topic at the meetings.
Licensee monitoring activities at FVTC are conducted on an infrequent, non-scheduled basis by the Corpnrate Security Officer and the Site Security Supervisor. These activities were not documented. Monitoring activities usually involved attending a-specific class at FVTC for several hours tn evaluate class content and instructor pretentation techniques.
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Both individuals rtcall conducting monitoring activitiet at FVTC, two-to-three times in the last two years.
Neither could recall monitoring the conduct of tests, hormal training at FVTC is epproximately four weeks in duration.
The licensee's Quality Assurance (0A) Departmat aes not have audit responsibility for the security training piocram. They only conduct onsite activities to evaluate securit; us.
- eeformance.
The licensee physical security plan and NRC security reput tous do not specifically require that the licensee conduct overs 7ht a' vities of the security training program, only that the securir m W
>be reviewed.
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As a result of their investigation, the licensee recognized that the scope of their oversight activities needed to be strengthened.
To facilitate this effort, QA will expand their security audit program to include the monitoring of security training both at TVTC and onsite.
The Corporate Security Officer and Site Security Supervisor will schedule increased announced and unannounced audits of the fVTC security training program.
Part of the unannounced audit program will be to inonitor class activities during testing and examination periods. These efforts will start during the next training class.
reviewed during a future inspection.ThisisanOp(50-266/9100702;50301/91007-02)
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licensee action will be Conclusion:
Inadequate licensee management oversight of the security training program was partially substantiated.
Our review showed that the licensee has adequate overview activities as it applies to monitoring gereral treining activities at FVTC.
However, the licensee has an unstructured and less than aggressive oversight program of monitoring classroom activities at TVTC.
No NRC regulatory requirements were violated. The licensee appears to be tahing adequate action to improve performance in this area, t.icensee action will be reviewed during future NRC inspections.
Allegation No. 3:
Administrative controls at FVTC were weak as
'demensliated by inconsistencies in proctoring and grading of examinations, students sleeping in class and the fact that no one ever flunks.
Review of written statements provided to the licensee by the two nuclear security instructors at FVTC showed that during progress tests one instructor recalled being in the classroom approximately 10% of the time.
The other instructor recalled being in the classroom during progress tests approximately 50% of the time.
Both instructors indicated that when final examinations were given they would remain in the classroom monitoring the students 957 to 97% of the time.
Both instructors stated that they utilized students to correct and grade progress tests. The tests would be exchanged between students in the class and a student would not grade his own test. Both instructors indicated that they alone are responsible for grading final examinations and students are not involved in this process.
Our interviews with the two instructors independently confirmed the above facts pertaining to the proctoring and grading of tests. The instructors indicated that the testing procedure followed for the Point Beach recruit classes is the same used for police recruit training. Neither instructor was aware if FYTC or the licensee had a policy on proctoring or grading
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of tests.
Both instructors felt the college allowed them professional latitude in class activities relating to proctoring and testing sctivities.
Neither instructor was aware or had been told that students sleep in class.
Both instructors were aware that some individuals had failed the training program.
Our interview with the FVTC Department Coordinator for Point Beach Security Training confirmed that FYTC has no specific policy or requirements instructors 3roctoring and grading tests.
However, it is his personal philosophy tiet all tests be proctored and that this issue had been discussed with the staff at FVTC.
Neither instructor could recall these issues being discussed. The Coordinator could not recall any occasion of a student being found or reported asleep in class.
The Coordinator did believe several students had not passed the course.
He stated that the low rate of failure could be attributed, in part, to individual screening conducted during the niring process by the security
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contractor and screening conducted by FVTC to identify individual student weakness in the areas o' reading, studying, and writing skills.
If a problem is noted, the student is given remedial training.
Review of security officer statements in the licensee investigation and interview results of random security officers by the inspector, showed that generally, instructors were not present in the classroom when students were taking progress tests and that students graded the progress tests.
However, during the final certification examination, an instructor would monitor the class and students were not involved in grading activities.
No individuals interviewed could recall students sleeping in class or if any student flunkcd the course.
Interviews of the site security supervisor and corporate security officer verified that the licensee was not aware of FVTC proctoring and grading practices until their investigation of guard cheating, which is referred to in Allegation No. 1.
When these practices were identified licensee evaluation showed them to be weak and contributed significantly to the acts of cheating identified in Allegation No. 1.
To correct this weakness, the licensee requested that FVTC develo) a policy that requires proctors to remain in the examination room throug1out all testing.
The proctor will be required to control the examination environment as well as all testing material and grading of all tests.
FVTC is in the process of developing and formalizing such a policy. This policy will be implemented for the next recruit training school. This is an Open Iten.
Licensee action will be reviewed during a future inspection.
(50-266/91007-03; 50-301/91007-03)
Interview results of the licensee personnel referred to above indicated that they were not aware of students sleeping in class. The licensee did confirm that at least three individuals have been terminated from the course for poor performance.
Conclusion:
Inspection results substantiated that administrative controls at FVTC pertaining to the proctoring and grading of examinations were weak.
It was not substantiated that students sleep in class.
Inspection results substantiated that at least three students did fail training activities at FVTC.
The licensee recognized the deficiencies in the FVTC program pertaining to proctoring and grading of examinations and has developed measures which should resolve those deficiencies.
Implementation of these measures will be reviewed in future NRC inspections, i
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allows security officers three attempts on each course to qualify.
If any individual fails to qualify he can not act as an armed guard. When the i
inspector discussed the different qualification standards between initial
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qualification at FTVC and requalification at the Point Beach site, with the corporate security officer, he was not aware of the program at FVTC.
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He thought both programs were the same.
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l Review of the licensee's NRC approved Appendix B Security Force Training and Qualification Plan identified no requirements as to the number of attempts an individual has to qualify with a weapon.
NRC regulations or guidance do not address this issue.
The inspector determined, from the weapons instructor at FVTC, that students at FVTC are not routinely advised of the number of practice or qualification attempts they are allowed. This lack of communication, in the opinion of the weapon instructor, could result in confusion to the student, that he believes he can shoot until he qualifies.
i conclusio_n:
The allegation was partially substantiated.
One specific type of target is reused.
However, the method of reusing the target, as determined by our review, does not affect the accurate assessment of a student's shooting ability. Target scoring in some specific cases is inconsistent but assessment of a student's shooting ability is not
negatively af fected by the scoring practice.
It was not substantiated
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that students are allowed to shoot until they qualify.
However, consunications with the students pertaining to weapons qualification at FVTC is weak.
Review of this allegation identified no violation of HRC requirements.
Review showed and the licensee recognized that documenting weapons qualification requirements and communicating weapons qualification standards to the students would improve the effectiveness
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of the program. The licensee will be establishing a procedure for firearms qualification and requalification to include a policy on reusing
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and scoring of targets, the number of attempts to qualify and requiring instruction to all security officers regarding the firearms qualification program.
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