ML19281A710
| ML19281A710 | |
| Person / Time | |
|---|---|
| Site: | Framatome ANP Richland |
| Issue date: | 02/23/1979 |
| From: | Engelken R NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION V) |
| To: | Nilson R SIEMENS POWER CORP. (FORMERLY SIEMENS NUCLEAR POWER |
| References | |
| NUDOCS 7904040025 | |
| Download: ML19281A710 (1) | |
Text
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UNITED STATES
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0 1990 N. C ALIFOHNf A DOULEV A R D 9***p*9 W ALNUT CREEK, C AL6FORNI A S t.5 3 6 February 23, 1979 Docket flo. 70-1257 Exxon fluclear Company, Inc.
2101 Horn Rapids Road Richland, Washington 99352 Attention:
Dr. R. Nilson, Manager Quality Assurance and Licensing Gentlemen:
The enclosed IE Circular fio. 79-03 is forwarded to you for information.
If there are any questions related to your understanding of the suggested actions, please contact this office.
Sincerely, nlO&.~,dL.
R. H. Engelken Director
Enclosures:
1.
IE Circular flo. 79-03 2.
List of IE Circulars issued in 1979 cc w/ enclosures:
R. Purcell 79040 6
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Mar flVCLEAR REGULATORY COMMISSION OFFICE OF IflSPECTION ATID EllFORCEflENT WASHIllGTON, D.C.
20555 February 23, 1979 IE Circular fio. 79-03 INADEQUATE GUARD TRAINING / QUALIFICATION Af!D FALSIFIED TRAINING RECORDS Description of Circumstances Recent physical protection inspections and investigations of allegations pertaining to guard training have disclosed evidence of improper guard training practices and possible falsification of training records.*
Some of the items discussed below are related to power reactors; however, it was thought advantageous to present a comprehensive analysis.
The items were disclosed through: (1) reviews of guard training records; (2) interviews with guards and guard force supervisors regarding specific information contained in records; (3) unannounced observation of training activities; (4) allegations made by guards and subsequent investigations; and (5) an investigation of training programs, policies, and procedures for qualification and requalification.
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 /
watchmen may not be adequately trained to meet existing requirements and/or that documentation may not give en accurate description of guard training or individuals' abilities to perforn their duties.
Examples of Qualification Records Falsification At one facility, a " record of certification" indicated that a guard had achieved a specific, passing score on a written test. An examination of the actual test showed that:
(1) the test had never been fully completed by the individual, and (2) those portions of the test which had been completed were not corrected nor graded.
Interviews with guards were conducted at one location to determine if they had, in fact, received required training, even though records of that trainir.g were not immediately available. The guards initially
- The regulatory bases for providing adequate training to guards /
watchmen and for adequately documenting that training are included in Title 10, Code of Federal Regulations, Part 73 (10 CFR 73.50(a)(4) and 10 CFR 73.55(b)(4)).
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hECircularNo.79-03 February 23, 1979 indicated that they had received the training.
Later, however, they confirmed that their supervisors had instructed them to respond affirmatively regardless of actual training received.
Examples of Irregularities in Guard Training and Qualification Guards were allowed 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 poked in targets to falsify a passing Several persons alleged that some members of the guard force score.
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 management representative revealed that individuals were being allowed to use " bench rests" and supports when they could not qualify without them. This practice was not included in the qualification procedure and is not an acceptable method for establishing firearms qualification.
At other locations, records provided as evidence of training appeared adequate. They contained information which indicated that individuals Further had qualified in the use of firearms with specific range scores.
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 appeared on the record had qualified. When discovered, these individuals were returned to the range in order 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. These individuals were subsequently not allowed to perform duties as guards.
At one site supervisors instructed guards to practice dry-firing their weapons on post after unloading them. This had the effect of placing unarmed guards on post. This practice continued until an incident occurred in which a guard following this procedure dropped his apparently unloaded 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 (PCAS)) before passing the examination required for the post. Certain post training records had been falsified to indicate that training was received when it in fact was not.
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IE Circular No. 79-03 February 23, 1979 Discussion Accurate records of training and qualification 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 an unacceptable reduction in the effectiveness of the security organization may exist and, further, that responsible management personnel may not be aware of this reduc-tion. 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 found, 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 obtained that training had not been given or was improperly administered.
Licensee management should monitor the training program so that inconsistencies in the record that suggest either a lack of or inadequate training can be detected, irrespective of whether these inconsistencies are inad-vertent or deliberate.
It should be noted that in those instances where a comprehensive audit of records and actual training was properly conducted management was able to identify significant problems and examples of apparent falsifi-cation.
In those cases, the disclosures enabled management 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) that their program to preclude similar situations will be evaluated during licensing review of their Guard Qualification and Training Plan submitted in accordance with Appendix B to Part 73; and, (3) that IE inspectors will be assessing all aspects of their existing guard training and qualification programs.
Therefore, all licensees who are required to provide physical protection for fuel cycle facilities and nuclear power plants in accordance with
- See American National Standards Institute, " ANSI N18.171973, Industrial Security for Nuclear Power Plants," Section 4.9 " Audits and Reports."
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IE Circular No. 79-03 February 27, 1979 the provisions of the Code of Federal Regulations, Title 10, Part 73, should take steps to assure that guards, watchmen or armed response individuals (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 take are:
A.
Review training records, certifications, and supporting documentation to determine whether the records are accurate and complete and that they adequately reflect the demonstrated abilities of individuals currently performing duties as guards, watchmen or armed response personnel.
B.
Interview or test guards, watchmen and response individuals in order to confirm that the specific information contained in records is accurate.
C.
Observe pertinent aspects of the training program to verify that the actual training being given is adequate. This should include, but not be limited to:
classroom presentations, administration of tests and range training and qualification.
The direct observa-tion should include both initial training / qualification and retraining /requalification activities.
No written response to this circular is required.
If you desire additional information regarding this matter, contact the Director of the appropriate NRC Regional Office.
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IE Circular f o. 79-03 February 23, 1979 LISTING OF IE CIRCULARS ISSUED Ill 1979 Circular Subj ect 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 Rcdiopharmaceutical Suppliers.
79-02 Failure of 120 Volt Vital 1/16/79 All Holders of AC Power Supplies Reactor OLs and cps Enclosure Page 1 of 1