ML20062B197

Forwards IE Circular 78-17, Inadequate Guard Training/ Qualification & Falsified Training Records

ML20062B197
Person / Time
Site:	Summer
Issue date:	10/13/1978
From:	James O'Reilly NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION II)
To:	Mary Johnson SOUTH CAROLINA ELECTRIC & GAS CO.
References
NUDOCS 7810230303
Download: ML20062B197 (1)

Text

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h X* 8 I UNITED STATES

• • "' Cut,'o NUCLEAR REGULATORY COMMISSION '

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[ ,h( kr 101 M ARIETT A STREET. N.W ATLANT A. GEORGI A 30303 o, [

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..... ^7 J 3 1978 In Reply Refer To:

RII:JPO 50-395 South Carolina Electric and Gas Company Attn: Mr. M. C. Johnson, Vice President and Group Executive - Special Services and Purchasing P. O. Box 764

. Columbia, South Carolind 29218 Q

Gentlemen:

t The enclosed circular 78-17 is forwarded to you for information.

If there are any questions related to your understanding of the g ri . - -

suggested actions, please contact this office. y '..:. -.,

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Enclosures:

1. IE Circular 78-17

2. List of IE Circulars Issued in 1978 cc w/ encl:

H. I. Donnelly, Jr.

Quality Assurance P. O. Box 8 Jenkinsville, South Carolina 29065 T. B. Conners, Jr.

Conners, Moore and Corber 1747 Pennsylvania Avenue, N. 'a'. _ . ,

Washington, D. C. 20006 l 1

7F/013 0 3 0 3 9 -

__ ._.. _ _ . . . _ . . _ _ . _ . . . . . _ _ . . _ . . _ _ _ _ u. . _ _ _ .

/ UNITED STATES

• NUCLEAR REGULATORY COMMISSION OFFICE OF INSPECTION AND ENFORCEMENT WASHINGTON, D. C. 20555 October 13, 1978 IE Circular 78-17 INADEQUATE GUARD TRAINING /GUALIFICATION AND FALSIFIED TRAINING RECORDS Dascription of Circumstances Recent physical protection inspections and investigations of allegations

(])partainingtoguardtraininghavedisclosedevidenceofimoroperguard training practices and possible falsification of training records.*

These items were disclosed through: (3) a review of existing guard training records; (2) interviews with guards and guard force supervisors which were conducted to determine the accuracy of specific information contained en records, and; C3) unannounced observation of training activities. In a number of situations, combinations of the above listed offorts were required to thoroughly identify the magnitude of the problems. The circumstances described below illustrate that individuals, who are performing duties as guards / watchmen, may not be wdequately trained under existing requirements and/or that documentation may not give a true description of actual guard training nor individuals' abilities to perform job-related 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 comoleted 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 immediately available. The guards initially indicated that they had received the training. Later, however, they confirmed that their sucervisors had instructed them to verbally verify the training regardless of actual training received.

oThe regulatory basis 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 October 13, 1978 IE Circular 78-17

'4 Examples of Weapons Qualifications Improprieties In another instance, " certification" of firearms cualification was provided in the form of targets containing holes which were purported to have been cade b'y guards during range firing. It was later determined that the holes had been made with a pencil. In another case, a number of notarized firearms qualification forms were later discovered to contain information uhich did not accurately reflect facts.

At other locations, records provided as evidence of training appeared adequate. They contained information which indicated that individuals had cualified in the use of firearms with specific range scores. Further investigation showed that the scores had been achieved by someone other In fact, other guards and guard O than the individual who was certified.

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 g

in order to adequately qualify. The results of this second qualification attempt showed that some individuals could not qualify, even after exten-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 then fire for qualification. Minimum qualifying scores were recuired to be obtained from a distance of 25 yards, however, they were actually obtained from less than 10 yards.

to a range by a management representative

(~_) Also,revealed an thatunannounced visitindividuals were being allowed to use " bench rests" and succorts when they could not qualify without them. This practice was not included in the Qualification procedure and is not an acceptable method I

for establishing firearms qualification.

Discussion G uards and watchmen, who are responsible for the protection of Nuclear Power Plants must successfully conolete a program of training and cuali-fication prior to assignment of security duties. Each guard or watchman, whether licensee employees or provided by contract must be tested and 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)

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l October 13, 1978 IE Circular 78-17

.' 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 performance levels.*

The previously listed examples demonstrated that the potential for a significant reduction in the effectiveness of the security organization may exist and, further, that responsible management personnel may not be auare of this reduction. This lack of awareness could comcound the severity and duration of the vulnerability.

Management audits of guard training have been found, in some cases, to b2 either non-existent or severly deficient. In some cases audits of Othe actual quality of trainin'g programs and practices have never been conducted. In other cases the audits consisted of a scot review of lesson plans and individual guard's training records with no attempt being made to verify the accuracy of those records. Subsequently, in

- the cases cited, records were verified as false and confirmation was cbtained that training had not been given or was improperly administered.

Licensee management should monitor this training program so that incen-sistencies in the record that suggest either a lack of, or inadequate training can be detected, irrespective of whether these inconsistencies are inadvertent or deliberate.

It should be noted that, in limited instances where a licensee conducted a comprehensive audit of records and actual training, management did identify significant problems and examples of apparent falsification. In those cases, the disclosures enabled management to take adecuate, decisive action to correct the identified problems.

.f)RecommendedAction v

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 uilt be evaluated by NRR during licensing review of their Guard Qualification I

and Training Plan submitted in accordance with Appendix e to Part 73, and; l

(3) to alert them that ISE inspectors will be assessing their situation.

! Therefore all Licensees who are required to provide physical orotection for Nuclear Power Plants in accordance with the provisions of the Code of Federal Regulations, Title 10, Part 73.55 should verify that guards, uatchmen or armed response individuals (as applicable) have been procerly trained and qualified and have adequately demonstrated capability to perform assigned duties. Among the courses of action that the licensee could take are:

~

• See American National Standards Institute, " ANSI N18.17-1973, Industrial l

Security for Nuclear Power Plants," Section 4.9 " Audits and Report s."

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i October 13, 1978 IE Circular 78-17 e .

A. Review training records, certifications and supporting documentation to verify that the records are accurate and comclete and that they adequately reflect the demonstrated abilities of individuals currently performing duties as guards, watchmen or armed response personnel.

. 8. 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 bevng given is adequate. This should include,

(_) but not be limited to: classroom presentations, administration of tests and range training and qualification. This direct observation 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 No. 78-17

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• october 13, 1978 LISTING OF IE CIRCULARS ISSUED IN 1978 Circular Subject Date Issued To No. .

of Issue 78-01 Loss of WelL Logging 4/5/78 AlL Holders of WelL Logging Source Source Licenses 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 Reactor OLs, cps,

' Type A tuantities of Low Specific Activity Fuel Cycle, Priority I Material Radioactive Material and Waste Disposal 8 for Transport Licenses 78 Installation Error That 5/15/78 ALL Holders of Could Prevent Closing of Reactor OLs or cps j Fire Doors Inadvertent Safety Injection 5/23/78 ALL Holders of 78-05 Reactor OLs or During Cooldown cps 78-06 Potential Common Mode 5/23/78 AlL Holders Of

{~'N # Flooding of ECCS Ecuipment Reactor OLs or cps Rooms at BWR Facilities 78-07 Damaged comoonents of a 5/31/78 All Holders of Bergen-Patersen Series Reactor OLs or cps 25000 Hydraulic Test

Stand Environmental Qualification 5/31/78 AlL Holders of 78-08 Reactor OLs or of Safety Related Equipment cps at Nuclear Power Plants Arcing of General Electric 6/5/78 Att Holders of 78-09 cps Company Size 2 Contactors Enclosure Page 1 of 2

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IE Circular No. 78-17 October 13, 1978 LISTING OF IE CIRCULARS ISSUED IN 1978 Circular Subject Date of Issued to No. .

Issue 78-10 Control of Seated 6/14/78 ALL Medical Sources Used in Licensees in Radiation Therapy Categories G and G1 78-13 Recirculation M-G 6/15/78 All Holders of Set overspeed Stgps BWR OLs or cps 78-12 HPCI Turbine Control 6/30/78 All Holders of Valve Lift Red Bending BWR OLs or cps e

for plants with I HPCI Terry Turbine 78-13 Insperability 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 Botting OLs or cps for plants with a HPCI Terry Turbine

{~Tl excepting Duane Arnold and Monticello 78-35 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 Enclosure Page 2 of 2 I

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