ML19224A522
| ML19224A522 | |
| Person / Time | |
|---|---|
| Site: | 05000000, Barnwell, Crane |
| Issue date: | 02/23/1979 |
| From: | NRC OFFICE OF INSPECTION & ENFORCEMENT (IE) |
| To: | |
| Shared Package | |
| ML19224A523 | List: |
| References | |
| IEC-79-3, NUDOCS 7903020368 | |
| Download: ML19224A522 (4) | |
Text
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UNITED STATES NUCLEAR REGULATORY CCMMISSION OFFICE OF INSPECTION AND ENFORCEMENT
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WASHINGTON, D.C.
20555 February 23, 1979 IE Circular No. 79-03 INADEQUATE GUARD TRAINING / QUALIFICATION AND FALSIFIED TRAINING fECORDS Description of Circumstances Recent physical protection inspections and investigations of allegations pertaining to guard training have dsclosed evidence of irprcper guard training practices and possible Isification of training records.*
Some of the items discussed below are related to power reactors; hcwever, it was thought advantageous to present a comprehensive analysis.
The items were disclosed through: (1) reviews of guard training records; a (2) interviews with guards and guard force supervisors regarding specific information contained on records; (3) unannounced observation e,f training activities; (4) allegations,~.. oy guards and subsequent investigations; and, (5) an investigation of training programs, policies, and procedures for cualification and recualification.
In a number of situations, combinations of the above listed efforts were used to identify the magnitude or severity of the problems.
The circumstances described below illustrate. that individuals, who are performing duties as guards /
'.'atchmen, may not be adequately trained to meet existing requirements and/or that documentation may not give an accurate desc;iption of guard trainin or individuals' abilities to perform their duties.
3 Examples of Qualification Records Falsification At one facility, a " record of certificatic i" indicathd that a guard had achieved a specific, passing score on a written test.
An examination of the actual test showed that:
(1) the test hd never been fully completed by the individual, and (2) those portions of th: test which had been completed were not corrected nor graded.
Interviews with guarcs were conducted, at one location, to determine if they had, in fact, received required training, even though records of that training were not immediately available.
The guards initially
- The regulatory bases for providing adequate training to guards /
watchmen and for adequately documenting that. : raining are included in Title 10, Code of Federal Regulations, h.e. 73 (10 CFR 73.50(a)(a) and 10 CFR 73.55(b)(4)).
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IE Circular No. 79 03 Februa ry 23, 1979 indicated that they had received the tri.ining.
Later, however, they confirmed that their supervisors had instructed them to verbally verify the training regardless of actual training received.
Examples of Irregularities in Guard Training and Qualificatien Guards were allcwed to fire at targets that were closer than the prescribed qualification distance and scores were sometimes computed in such a way as to assure qualification even when a passing score was not received.
Additionally, holes were sometimes pc!:ed in targets to falsify a passing score.
Several persons alleged that some members of the guard force were armed even though they did not legitimately qualify.
In another case, a number of notarized firearms qualification forms were later discovered to contain information which was not factual.
Also, an unannounced visit to a range by a canagement representative revealed that individuals were being allowed to use " bench rests' cnd suppo-ts when they could not qualify without them.
This practice was not included in the quali fication procedure and is not an acceptable method for establishing firearms qualification.
At other locations, reccrds provided as evidence of training acpeared adequate.
They contained information which indicated that individuals had qualified in the use of firearms with specific range scores.
Further investigation showed that the scores had been achieved by someone other than the individual who was certified.
In fact, other guards and guard supervisors or range instructors had fired the qualifying scores, but certified that the person, whose name appearest on the record, had quali fi ed. When discovered, these individuals were returned to the range in crder to validate their qualifications.
The results of this second qualification attempt showed that some individuals could not qualify, even after extensive range practice and training.
'hese individuals were subsequently not allowed to perform duties P guards.
At cne site supervisors instructed guards to practice dry-firing their weapons on post after unicading them.
This had the effect of placing unarmed guards on post.
This practice continued until an inddent occurred in which a guard following this procedure dropped his apparently unload-:d weapon and it accidentally discharged.
Instructors provided the answers to test questions in advance to assure a passing score.
Guards were placed on certain posts (such as the Primary Central Alarm Station (FCAS)) before passing the examination required fur the post.
Cert..in pcst training records had been falsified
. to indicate that training was received when it in fact was- "ot.
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IE Circular No. 79 03 February 23, 1979 Discussion Accurate recoros of training and r;aalification scores are necessary in order to provide management a means for determining whether or not an individual is able to initially meet and thereafter maintain required performance levels.*
The examples listed above demonstrate that m unacceptable reduction in the effectiveness of the security organiza Ny exist and, further, that responsible management personnel may nou e aware of this reduc-ti o n. This lack of awareness could result in a deviation from the intent and purpose of guard training requirements.
Management audits of guard training have been #cund, in some cases, to be either non-existent or severely deficient.
In some cases audits of the actual quality of training programs and practices have never been conducted.
In other cases the audits consisted of a spot review of lesson plans and individual guard training records with no attempt being made to verify the accuracy of those records.
In the cases cited, some records were verified as false and confirmation was cbtained ihat training had not been given or was improperly administered.
Licensee v 3gement should monitor the training program so that inconsi;tencies in the record that suggest either a lack of, or inadequate tra ning can be detected, irrespective of whether these inconsistencies are inad-vertent or deliberate.
It should be noted that, in those instances whcre a comorehensive audit of records and actual training was croperly conducted, manacement was able to identify significant problems and examples of apparent falsifi-cation.
In those cases, the disclosures enabled nanagement to take adequate, corrective action.
Recommended Action The purpose of this circular is to inform all licensees: (1) of unacceptable situations that have been found; (2) th9 9:ir program to preclude similar situations will be evaluated during licensing review of their~ Guard Qualification and Training Plan submitted in accordance witn poendix 3 to Part 73; ad, (3) that IE inspectors will be assessing all as:ects of their existing 31uard training and qualification programs.
Tnerefore, all licensees w1o are required to provide physical protection for fuel cycle facilities and nuclear power plants in accordance witn
- See American National Standards Institute, "A:iSI N18.171973, Industrial Security for Nuclear ?cwer Plants," Section 0.9 " Audits and Re: orts."
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IE Circular No. 79-v3 Feb rua ry 23, 1979 the provisions of the Code of Federal Regulations, Title 10, Part 73 should take steps to assure that guards, watchmen or armed resoonse inoividuals (as applicable) have been properly trained and qualified and have adequately demonstrated capability to perform assigned duties.
Among the courses of action that the licensee could tak'e are:
A.
Review training records, certifications, and supporting documentation to determine whether the records are accurate and ccmplete and that they adequately reflect the demonstrated abilities of individuals currently performing duties as guards, watchmen or armed respc.1se perscnnel.
B.
Interview or test guards, watchmen and response ind'viduals in order to confirm that the specific information contained in records is accurate.
C.
Observe perti' ent aspects of the training program to verify that the actual t aining being given is adequate. This should include, J
but not be 'imited to:
classroom presentations, ad.7,inistraticn of tests and range training and qualification.
The direct observa-tion should include both initial trailing /cualification and retraining /requalificatior activi:ies.
No written response to this circular is required.
If you desire additional information regarding this matter, contact tne Director of the appropriate NRC Regional Offic-.
e a of 4 es;::
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IE Circular No. 79-03 Feb rua ry 23, 1979 LISTING 0F IE CIRCULARS ISSUED IN LAST TWELVE MONTHS Circular Subject Cate Issued To No.
of Issue 78-02 Proper Lubricating Oil 4/20/78 All Holders of for Terry Turbines Reactor OLs or cps 78-03 Packaging Greater Than 5/12/78 All Holders of Type A Quantities of Reactor OLs, cps, Low Specific Activity Fuel Cycle, Radioactive Material Priority I Material for Transport and Naste Disposal Licenser 73-04 Installation Error That 5/15/78 All Holders of
- Could Prevent Closing of Reactor CLs or Fire Doors cps 78-05 Inadvert nt Safat) Inject;;n 5/23/78 All Holder; of During Cooldown Reactor OLs or cps 78-06 Potential Common Mode 5/23/78 All Holders of Flooding of ECCS Equipment Reactor OLs or Rooms at EWR Facilities cps 78-07 Damaged Components of a 5/31/78 All Holders of Bergen-Paterson Series Reactor OLs or 25000 Hydraulic Test cps' S tand 78-08 Environmental Qualification 5/31/78 Ali Holders of of Safety Related Eouipment Reactor CLs or at Muclear Power Plants cps 78-09' Arcing of General Electric 6/5/78 All Holders of Company Size 2 Contactors cps 78-10 Control of Sealed 6/1a/79 All "edical Sources Used in
. Licensees in Radiation Therapy Categories G and G1 Enclosure Cage 1 of 3 6,9 m e
IE Circular f:o. 79-03 February 23, 1979 LISTING OF IE CIRCULARS ISSUED IN LAST TWELVE MONTHS Circular Subject Date of Issued to No.
Issue 78-11 Recirculation M-G 6/15/78 All Holders of Set Overspeed Stops EWR OLs or cps 78-12 HPCI Turbine Control 6/30/78 All Holders of Valve Lift Rod Bending BWR OLs or cps for plants with HPCI Terry Turbine 78-13 Inoperability of Multiple 7/10/78 All Holders of Service Water Pumps Reactor OLs and cps except for plan,ts located in: AL, AK, CA, FL, GA, LA, MS, SC 78-14 HPCI Turbine Reversing 7/12/78 All Holders of SWR Chamber Hold Down Bolting OLs or cps for plants with a HPCI Terry Turbine excepting Duane Arnold and Monticello 78-15 Checkvalves Fail to 7/20/78 All Holders of Close In Vertical Reactor OLs or cps Pos i ti c r.
78-16 Limito que Valve 7/26/78 All Holders of Actuators Reactor OLs or cps 78-17 Inadequate Guard Training /
10/13/78 All Holders of
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Qualification and Fal;ified and appli car '.s Training Records for Reactor OLs.
78-18 UL Fire Test 11/6/78 All Holders of Reactor Ols or cps 78-19 Manual Override (3vcass) 12/23/78 All Holders of of Safety Actuation Signals
.C P s Enclosure Page 2 of 2
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IE Circular NC. 79-01 Feoruary 23, 1979 LISTING OF IE CIRCULARS ISSUED IN LAST TNELVE MONTHS Circular Subject Date of Issued To No.
Issue 79-01 Administration of 1/12/79' All Medical Unauthorized Byproduct Licensees except Material to Humans Teletherapy Medical Licensees and each Radiopharmaceutical Suppliers 79-02 Failure of 120 Volt Vital 2/16/79 All Holders of AC Power Supplies Reactor OLs and cps a
E".CI C s u r ?
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