ML19282A905
| ML19282A905 | |
| Person / Time | |
|---|---|
| Site: | 07001308, 07001309 |
| Issue date: | 02/23/1979 |
| From: | James O'Reilly NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION II) |
| To: | Zahn L GENERAL ELECTRIC CO. |
| References | |
| NUDOCS 7903080284 | |
| Download: ML19282A905 (1) | |
Text
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PDR cf UNITED STATES
,MI ), t NUCLEAR REGULATORY COMMISSION l)
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ffB 2 1 1979 Docket No. 70-1308 Docket No. 70-1309 General Electric Company ATTN:
Mr. L. L. Zahn, Jr.
Manager, Spent Fuel Services Operation 175 Curtner Avenue San Jose, CA 95125 Gentlemen:
The enclosed IE Circular No. 79-03 is forwarded to you for infor-mation.
If there are any questions related to your understanding of the suggested actions, please contact this office.
Sincerely, G
_a m L MeeOw hames~G.Kepfl$r Director
Enclosures:
1.
IE Circular No. 79-03 2.
List of IE Circulars issued in the last i
12 montht cc w/encls:
Mr. E. E. Voiland, Manager Morris Operation Mr. D. M. Dawson, Manager Licensing and Transportation Fuel Recovery Operations Central Files Director, NRR/DPM Director, NRR/ DOR PDR Local PDR NSIC Mr. Dean Hansell, Office of Assistant Attorney General 7903080,16f
U.S. NUCLEAR REGULATORY COMMISSION OFFICE OF INSPECTION AND ENFORCEMENT REGION III February 23, 1979 IE Circular No. 79-03 INADEQUATE GUARD TRAINING / QUALIFICATION AND 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 on 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 an accurate description of guard training or individuals' abilities to perforb 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 training were not inmediately 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 raderal Regulations, Part 73 (10 CFR 73.50(a)(4) and 10 CFR 73.55(b)(4)).
IE Circular No. 79-03 February 23, 1979 indicated that they had received the training. 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 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 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 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 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 appeared on the record, had qualified. When discovered, these individuals were returned to the range in order to valid ste their qualifications. The results of this second qualification attempt showed that some individuals could not qualify, even af ter ext msive 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 thet.
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.
9 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 thereaf ter 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 atte=pt 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.
Reco= mended 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."
. February 23, 1979 IE Circular No. 79-03 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 anc complete and that they adequately reflect the demonstrated abilities of individuals currently performing duties as guards, watchmen or armed response personnel.
Interview or test guards, watchmea and response individuals in B.
order to confirm that the specific information contained in records is accurate.
Observe pertinent aspects of the training program to verify that C.
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 inf ormation regarding this matter, contact the Director of the appropriate NRC Regional Office.
IE Circular No. 79-03 February 23, 1979 LISTING OF IE CIRCULARS ISSUED IN LAST TWELVE MONTHS Circular Subject Date Issued To No.
of Issue 78-01 Loss of Well Logging 4/5/78 All Holders of Source Well Logging Source Licenses 78-02 Proper Lubricating 011 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 Waste Disposal Licenses 78-04 Installation Error That 5/15/78 All Holders of Could Prevent Closing of Reactor OLs or Fire Doors cps 78-05 Inadvertent Safety Injection 5/23/78 All Holders 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 Roo=s at BWR Facilities cps 78-07 Damaged Components of a 5/31/78 All Holders of Bergen-Paterson Series Reactor OLs or 25000 Hydraulic Test cps Stand 78-08 Environmental Qualification 5/31/78 All Holders of of Safety Belated Equipment Reactor OLs or at Nuclear Power Plants cps 78-09 Arcing of General Electric 6/5/78 All Holders of Company Size 2 Contactors cps Enclosure Page 1 of 3
IE Circular No. 79-03 February 23, 1979 LISTING OF IE CIRCULARS ISSUED IN LAST TWELVE MONTHS Circular Subject Date of Issued to No.
Issue 78-10 control of Sealed 6/14/78 All Medical Sources Used in Licensees in Radiation Therapy Categoriec G and G1 78-11 Recirculation M-G 6/15/78 All Holders of Set Overspeed Stops BWR 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 plants located in: AL, AK, CA, FL, GA, LA, MS, SC 78-14 HPCI Turbine Reversing 7/12/78 All Holders of BWR 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 Position 78-16 Limitorque Valve 7/26/78 All Holders of Actuators Reactor OLs or cps 78-17 Inadequate Guard Training /
10/13/78 All Holders of Qualification and Falsified and applicants Training Records for Reactor OLs.
Enclosure Page 2 of 3
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IE Circular No. 79-03 February 23, 1979 LISTING OF IE CIRCULARS ISSUED IN LAST IVELVE MONTHS Circular Subject Date of Issued To No.
Issue 78-18 UL Fire Test 11/6/78 All Holders of Reactor OLs or cps 78-19 Manual Override (Bypass) 12/28/78 All Holders of of Safety Actuation Signals cps 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 1/16/79 All Holders of AC Power Supplies Reactor OLs and cps Enclosure Page 3 of 3 4