ML20062B205
| ML20062B205 | |
| Person / Time | |
|---|---|
| Site: | Fermi  |
| Issue date: | 10/13/1978 |
| From: | James Keppler NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION III) |
| To: | Hines E DETROIT EDISON CO. |
| References | |
| NUDOCS 7810230343 | |
| Download: ML20062B205 (1) | |
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UNITED STATES
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NUCLEAR REGULATORY COMMISSION f-4
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REGION 111 5
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GLEN E LLYN. ILLINolS 60137 g.
...a OCT 13.378 Docket No. 50-341 (
The Detroit Edison Company ATTN:
Mr. Edward Hines, Assistant Vice President and Manager Quality Assurance 2000 Second Avenue Detroit, MI 48226 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, p hWb James G. Keppler Director
'Inclosures:
1.
IE Circular No. 78-17 2.
List of IE Circulars Issued in 1978 cc w/encls:
Central Files Director, NRR/DPM i
Director, NRR/ DOR
/PDR i
Local PDR NSIC TIC Ronald Callen, Michigan Public Service Comission Eugene 3. Thomas, Jr.,
Attorney 7 8 /o 2 3 o 3 yg g l
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U.S. NUCLEAR REGUU. TORY C0 EMISSION OFFICE OF INSPECTION AND ENFORCEMENT REGION III October 13, 1978 IE Circular No. 78-17
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L INADEQUATE GUARD TRAINING / QUALIFICATION AND FAL'SIFIED TRAINING REC 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.*
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 contained on records, and; (3) unannounced observation of training 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 performing duties as guards / watchmen, may not be adequately trained under existing requirements and/or that documentation may not give a true description of actual guard training nor individuals' abilities to perfom 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 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 rot imediately available.
The guards initially indicated that they had received the training.
Later, hcwever, they confirmed that their supervisors had instructed them to verbally verify the training regardless of actual training received.
- 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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IE Circular No. 78-17 October 13, 1978 Ex~amples of Weapons Qualifications Improprieties 7
In another instance, "certifjcation" 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 holes had oeen made with a pencil..In another case, a number of notarized firearms qualification forms were later discovered to contain information which did not accurately reflect facts.
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 required to return to the range in order to adequately qualify. The results of this second qualification attempt shewed that some individuals could not qualify, even after exten-sive range practice and training.
They were subsequently net allowed to c
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 required to be obtained from a distance of 25 yards, however, they were actually obtained frem less than 10 yards.
Also, an unanncunced visit to a range by a management representative revealed that individuals were being allowed to use " tench rests" and l
supports when they could not qualify without them. This practice was not l
included in the qualification procedure and is not an acceptable method for establishing firearms qualification.
4 Discussien Guards and watchmen, who are responsible for the protection of Nuclear
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Pcwer Plants must successfully complete a program of training and quali-fication prior to assignment of security duties.
Each guard or watchman, i
whether licensee employees or provided by contract must be tested and j
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 5 to 10 CFR Part 73)
IE Circular No. 78-17 October 13, 1978 Accurate records of training and qualificatio'n 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 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 In some cases audits of be either non-existent or severely deficient.
the actual quality of training prograes and practjces have never been In oth~er cases the audits consisted of a spot review of conducted.
lesson plans and individual guard's training records with no attempt Subsequently, in being made to verify the accuracy of those records.
the cases cited, records were verified as false and confirmation was obtained that training had not been given or was improperly administered.
Licensee management should monitor this training program so thht incen-sistencies in the record that suggest either a lack of, or inadequate training can be detected, irrespective of whether these inconsistences 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 adequate, decisive action to correct the identified problems.
Recommended Action The purpose of this circular is to inform all licensees; will be evaluated by NRR during licensing review of their Guard Qualificatien 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 protection for Nuclear Power Plants in accordance with the provisiens the Code of Federal Regulations, Title 10, Part 73.55 should verify thac guards, watchmen or armed response individuals to perform assigned duties. Among the courses of action that the licensee could take are:
Industrial
- See American National Standards Institute, " ANSI NIS.171973, Security for Nuclear Power Plants," Section 4.9 " Audits and Reports."
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IE Circular No. 78-17 October 13, 1978 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 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.
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 October 13, 1978 LISTING OF II CIRCULARS ISSL'ED IN 1978 e
Date Issued To Circular Subject of Issue No.
78-01 Loss of Well Logging 4/5/78 All Holders of Well Logging Source Source Licenses 78-02 Proper Lubricating 011 4/20/78 All Holders of Reactor OLs or for Terry Turbines cps 78-03 Packaging Greater Than 5/12/78 All Holders of Reactor OLs, C?s, Type A Quantities of Fuel Cycle, Low Specific Activity Priority I Material I'
Radioactive Material and Waste Disposal for Transport Licenses 78-04 Installation Error That 5/15/78 All Holders of Reactor OLs or Could Prevent Closing of cps Fire Doors 78-05 Inadvertent Safety Injection 5/23/78 All Holders of Reactor OLs or During Cooldown cps 78-06 Potential Common Mode 5/23/78 All Eciders of Reactor OLs or Flooding of ECCS Equipment cps Rooms at BWR Facilities 78-07 Danaged componer.ts of a 5/31/78 All Holders of Reactor CLs or Bergen-Paterson Series C?s 25000 Hydraulic Test Stand 78-08 Environ = ental Qualificatien 5/31/78 All Holders of Reacter OLs or of Safety Related Equip =ent cps at Nuclear Power Plants 78-09 Arcing of General Electric 6/5/78 All Holders of cps Co=pany Size 2 Contactors Enclesure Page 1 ef 2 y
II Circular No. 78-17 October 13, 1978 LISTING OF II CIRCULARS ISSUID IN 1978 Date of Issued to Circular Subject Issue No.
78-10 control of Sealed 6/14/78 All Medical Licensees in Sources Used in Categories G Radiation Therapy and G1 78-11 Recirculation M-G 6/15/78 All Holders of BWR OLs or cps Set Overspeed Stops 78-12 HPCI Tur"bine Control 6/30/78 All Holders of BWR OLs or cps Valve Lift Rod Bending
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for plants with HPCI Terry Turbine 78-13 Inoperability of Multiple 7/10/78 All Holders of Reactor OLs and cps Service Water Pu=ps 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 OLs or cps for Chamber Hold Down Bolting plants with a EPCI Terry Turbine excepting Duane Arnold and Monticello
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78-15 Checkvalves Fail to 7/20/78 All Holders of Reactor OLs or cps Close In Vertical Positien 78-16 Li=1 torque valve 7/26/78 All Holders of Reactor OLs or Actuators cps Enciesure Page 2 of 2 1
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