ML20027A191
| ML20027A191 | |
| Person / Time | |
|---|---|
| Site: | Point Beach  |
| Issue date: | 10/13/1978 |
| From: | James Keppler NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION III) |
| To: | Burstein S WISCONSIN ELECTRIC POWER CO. |
| References | |
| NUDOCS 7810230332 | |
| Download: ML20027A191 (1) | |
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- "'Ut UNITED STATES g
., w NUCLEAR REGULATORY COMMISSION f,.k..s1 REGION lli hx - e 799 ROOSEVELT RoAo
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3 OCT13 78 Docket No. 50-266 Docket No. 50-301 Wisconsin Electric Power Company ATTN:
Mr. Sol Burstein Senior Executive Vice President
.PowsY Plants 231 West Michigan l
Milwaukee, WI 53201 s
Gentlemen:
The enclosed IE Circular No. 78-17 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, 55 James G. Keppler Director
Enclosures:
1.
IE Circular No. 78-17 2.
List of IE Circulars Issued in 1978 cc w/encls:
Mr. G. A. Reed, Plant Manager Central Files Director, NRR/DPM Director, NRR/ DOR
/PDR Local PDR NSIC TIC 7Pr a 23 6 33 2.
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U.S. NUCLEAR REGULATORY COMMISSION l
OFFICE OF INSPECTION AND ENFORCEMENT i
REGION III October 13, 1978 f
IE Circular No. 78-17
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INADEQUATE GUARD TRAINING / QUALIFICATION AND FAL'SIFIED TRAINING RECORDS l
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.*
l These items were disclosed through:
(1) a review of existing guard training records; (2) interviews with guards and guard force supervisors which were conducted to detemine the accuracy of specific information i
contained on records, and; (3) unannounced observation of training r
activities.
In a number of situations, combinations of the above listed efforts were require ~d to thoroughly identify the magnitude of the problems.
The circumstances described below illustrate that individuals, who are perfoming duties as guards / watchmen, may not be adequately trained under existing requirements and/or that documentation may not l
give a true description of actual guard training nor individuals' abilities l
to perfom job-related duties.
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Examples of Qualification Records Falsification At one facility, a " record of certification" indicated that a guard had
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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.
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Interviews with guards were conducted, at one location, to determine if they had, in fact, received required training, even though records of l
that training were not imediately available.
The guards initially indicated that they had received the training.
Later, however, they i
confimed that their supervisors had instructed them to verbally verify l
the training regardless of actual training received.
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- 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 73.55(b)(4)).
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i IE Circular No. 78-17 October 13. 1978 j
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7 Examples of Weapons Qualifications Improprieties In another instance " certification" of firearms qualification was provided in the form of targets containing holes which were purported to have been made by guards during range firing.
It was later determined that the f
holes had oeen made with a pencil..In another case, a number of notarized firearms qualification forms were later discovered to contain information f
which did not accurately reflect facts.
At other locations, records provided'as evidence of training appeared adequate. They contained information which indicated that individuals j
had qualified in the use of firearms with specific range scores.
Further j
investigation showed that the scores had been achieved by someone other m
than the individual who was certified.
In fact, other guards and guard
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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 required to return to the range in order to adequately qualify. The results of this second qualification attempt showed that some individuals could not qualify, even after exten-1
- sive range practice and training. They were subsequently not allowed to perform duties as guards.
In another instance, persons who were not able to achieve a qualifying score from a required distance were allowed to reduce that distance and I
then fire for qualification.
Minimum qualifying scores were required to l
be obtained from a distance of 25 yards, however, they were actually obtained from less than 10 yards.
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Also, an unannounced visit to a range by a management representative revealed that individuals were being allowed to use " bench rests" and l
supports when they could not qualify without them.
This practice was not t
included in the qualification procedure and is not an acceptable method
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for establishing firearms qualification.
Discussion Guards and watchmen, who are responsible for the protection of Nuclear I
Power Plants must successfully complete a program of training and quali-fication prior to assignment of security duties.
Each guard or watchman, l
whether licensee employees or provided by contract must be tested and i
later requalified to ensure that they are capable of meeting and main-taining minimum levels of performance.
(10 CFR 73.55 and effective October 23, 1978 Appendix B to 10 CFR Part 73) i t
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IE Circular No. 78-17 October 13, 1978 l
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" Accurate records of training and qualificatioh 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 performance l
1evel s.*
l The previously listed examples demonstrated that the potential for a i
significant reduction in the effectiveness of the security organization f
may exist and, further, that responsible management personnel may not be i
aware of this reduction.
This lack of awareness could compound the severity and duration of the vulnerability.
Management audits of guard training have been found, in some cases, to be either non-existent or severely deficient.
In some cases audits of i
the actual quality,of training programs and practjces have never been j
conducted.
In other cases the audits consisted of a spot review of lesson plans and individual guard's training records with no attempt
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being made to verify the accuracy of those records.
Subsequently, in i
the cases cited, records were verified as false and confirmation was i
obtained that training had not been given er was improperly administered.
f Licensen management should monitor this training program so that incon-sistencies in the record that suggest either a lack of, or inadequate training can be detected, irrespective of whether these inconsistences j
are inadvertent or deliberate.
e It should be noted that, in limited instances where a licensee conducted a comprehensive audit of records and actual training, management did l
identify significant problems and examples of apparent falsification.
In those cases, the disclosures enabled management to take adequate.
l decisive action to correct the identified problems.
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Recomended Action The purpose of this circular is to inform all licensees; (1) of situations that have been found; (2) that their program to preclude similar situations i
will be evaluated by NRR during licensing review of their Guard Qualification and Training Plan submitted in accordance with Appendix B to Part 73, and; (3) to alert them that I&E inspectors will be assessing their situation. Therefore all licensees who are required to provide physical l
protection for Nuclear Power Plants in accordance with the provisions of the Code of Federal Regulations, Title 10 Part 73.55 should verify that guards, watchmen or amed 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 l
- See American National Standards Institute, " ANSI N18.171973, Industrial
~l Security for Nuclear Power Plants." Section 4.9 " Audits and Reports."
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Y IE Circular No. 78-17 October 13, 1978 r
A.
Review training records, certifications' and supporting documentation to verify that the records are accurate and complete and that they adequately reflect the demonstrated abilities of
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individuals currently performing duties as guards, watchmen or armed response personnel.
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B.
Interview or test guards, watchmen and response individuals in l
order to confirm that the specific information contained in records is accurata.
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 l
of tests and range training and qualification.
This direct observation
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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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II Circular No. 78-17 October 13, 1978 LISTING OF II CIRCULARS ISSUED IN 1978 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 Holo'srs 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 Rooms at BWR Facilities cps 78-07 Damaged Components of a 5/31/78 All Holders of Bergen-Patersen Series Reactor OLs or 25000 Hydraulic Test cps Stand 78-08 Environmental Qualification 5/31/78 All Holders of of Safety Related Equip =ent Reactor OLs or se 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 2 l
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p IE Circular No. 78-17 October 13, 1978 LISTING OF IE CIRCULARS ISSUED IN 1978 i
Circular Subject Date of Issued to No.
Issue 78-10 control of Sealed 6/14/78 All Medical l
Sources Used in Licensees in Radiation Therapy Cate8eries G j
and G1 l
78-11 Racirculation M-G 6/15/78 All Holders of Set Overspeed Stops BWR OLs or cps i
i 78-12 HPCI Turbine Control 6/30/78 All Holders of Valve Lift Rod Bending RWR OLp or cps i
for plants with i
f EPCI 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
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Terry Turbine excepting Duane Arnold and Monticello 78-15 Checkvalves Tail 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 Ynclosure Page 2 of 2 i
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