ML20062B207
| ML20062B207 | |
| Person / Time | |
|---|---|
| Site: | La Crosse File:Dairyland Power Cooperative icon.png |
| Issue date: | 10/13/1978 |
| From: | James Keppler NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION III) |
| To: | Madgett J DAIRYLAND POWER COOPERATIVE |
| References | |
| NUDOCS 7810230346 | |
| Download: ML20062B207 (1) | |
Text
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UNITED STATES d
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fe NUCLEAR REGULATORY COMMISSION f,I L REGION Ill e, 5 gg f
799 acessystr ace.o j.
ocas ettvs. tuseis sois7 OCi 13.378 Docket No. 50-409 Dairyland Power Cc; perative ATTN:
Mr. J. P. Madgett General Manager 2615 East Avenue - South La Crosse, WI 54601 Gentlemen:
The enclosed IE Circular No. 78-17 is forwarded to you for infor-mation. If there are any questions relatad to your understanding of the suggested actions, please contact this office.
Sincerely,
/
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James G. Keppler 1
Director
Enclosures:
1.
IE Circular No. 78-17 2.
List of IE Circulars Issued in 1973 l
ec w/encis:
Mr. R. E. Shimshak, Plant Superintendent Central Files Director, NRR/DPM Director, NRR/ DOR v ?DR Local PDR NSIC TIC Anthony acisman, Esq.,
Attornay 7? /0 L3 c 5Y6 p
I U.S. NUCLEAR REGULATORY COMMISSION OFFICE OF INSPECTION AND ENFORCEMENT REGION III October 13, 1978 IE Circular No. 78-17 INADEQUATE GUARD TRAINING / QUALIFICATION AND FAL'51FIED 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.*
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 infonratic'1 contained on records, and; (3) unannounced observation of training activities.
In a number of situations, combinatiens 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, ray 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 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 completed by the individual, and (2) those portions of the test which had been completed were not corrected nor graded.
d 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 incediately 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 regulat:ry 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)).
7&lu3 o n/
IE Circular No. 78-17 October 13, 1978 Ex~amples 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 beer made by guards during range firing.
It was later determined that the holes had caen made with a pencil..In another case, a number of notarized firearms qualification forms were later discovered to contain informatien 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 showed that some individuals could not qualify, even after exten-i sive range practice and training.
They were subsequently net allowed to perform duties as guards.
In another instance, persons who were not able to achieve a qualifying score frcm a required distance were allowed to reduce that distance and
'then fire for qualification. Minimum qualifying scores were required t:
be obtained frc: a distance of 25 yards, hcwever, they were actually obtained frem less than 10 yards.
Also, an unanncunced visit to a range by a canagement representative revealed that individuals were being allowed to use " bench rests" and supports when they could not qualify withcut them.
This practice was net-included in the qualification precedure and is not an acceptable method for establishing firearms qualification.
4 Discussicn Guards and watchman, who are responsible for the protection of Nuclear Pcwer Plants cust successfully cceplete a pregram of training and qualt-ficatien prior to assignment of security duties.
Each guard or watchman, whetner licensee employees or previded by contract must be tested and later recualified to ensure that they are ca:able of meeting and main-taining minimum levels of performance.
(10 CFR 73.53 and effective Octcber 23, 1973 Appendix 3 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 perforr.ance l evel s.*
The previously listed examples demonstrated that the potential for a significant reduction in the effectiveness of the secarity 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 be either non-existent or severely deficient.
In some cases audits of the actual quality of training programs and practices have never been s
conducted.
In oth'er cases the audits consisted of a spot review cf 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 obtained that training had not been given or was improperly administered.
Licensee management should monitor this training program so that incon-sistencies in the record that suggest either a lack of, or inadequate trainini can be detected, irrespective of whether these inconsistences are inadvertent or deliberate.
It should be noted that, in limited instances where a licensee c:nducted 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 proolems.
Recorrended Acti:n The purp se of this circular is to inform all licensees; (1) of situatiens that have been found; (2) that their program to preclude similar situatiens
)
will be evaluated by NRR during licensing review of their Guard Qualificacion l
and Trair;ing Plan submitted in accordance with Accendix B to Parc 73, and; (3) to alert them tnat I&E inspectcrs will be assessing tnsic situation. Therefore all licensees who are recuired to provide chysical protection for Nuclear Pcwer Plants in accordance with the cc visicns cf the Ccde of Federal Regulations Title 10. Part 73.55 should verify trat guards, watchmen or armed response individuals (as applicable) have been properly trained and qualified and have adecuately demonstrated ca:acility to perform assigned duties.
Among the courses of action that tne licensee c:uld take are:
- See American Natienal Standards Institute, " ANSI NIS.171973, Industrial Security for Nuclear Pcwer Plants," Section 4.9 " Audits and Repcrts."
c.
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 i
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 recceds is accurate.
C.
Observe pertinent aspects of the training pregram to verify that the actual training being given is adequate. This should include, but not be limited to:
classrcom presentations, administratien 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 Directer of the appropriate NRC Regional Office.
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II Circular No. 78-17 October 13, 1978
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LISTING OF II CIRCL'LARS ISSL*ED IN 1978 Circular Subject Date Issued To No.
cf Issue 78-01 Loss of Well Logging 4/5/78 All Holders of Source Well Logging Source Licenses 78-02 Proper Lubriesting 011 4/20/78 All Holders of for Terry Turbines Reactor OLs or C?s 78-03 Packaging Greater Than 5/12/78 All Holders cf Type A Quantities of Reactor OLs, C?s, Low Specific Activity Fuel Cycle, Radioactive Material Priority I Material for Transport and Waste Dispesal Licenses 78-04 Insta11atien Error That 5/15/78 All Holders of Could Prevent Closing of Reacter OLs er Fire Doors C?s 78-05 Inadvertent Safety Injection 5/23/78 All Holders of During Coeldcun Reactor OLs er C?s 78-06 Potential Co==en Mede 5/23/78 All Holders cf 71ooding of ECCS Equip =ent Reactor OLs er Roccs at B'a'R Tac 111 ties C?s l
78-C?
Da: aged Ce:penents of a 5/31/78 All Holders cf Bergen-Patersen Series Reactor CLs er l
25000 Hydraulic Test C?s t
Stand 73-08 Enviren= ental Qualificatien 5/31/78 All Helders cf of Safety Related Equip =ent Reacter CLs er at Nuclear Pcwer Plants C?s 78-C9 Arcing of General Electric 6/5/78 All Helders cf i
Conpany Size 2 Centactors C?s Enclesure Page 1 ef l
IE Circular No. 78-17 October 13, 1978 LISTING OF II CIRCULARS ISSUID IN 1978 Circular Subj ect Date of Issued to No.
Issue 78-10 Control of Sealed 6/14/78 All Medical Sources Used in Licensees in Radiatien Therapy Categories G and G1 78-11 Recirculation M-G 6/15/78 All Holders of Set Overspeed Steps BWR OLs or C?s 78-12 HPCI Turbine Control 6/30/78 All Holders of Valve Lift Rod Bending BWR OLs or C?s 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 ef 3%7 Chanbar Hold Devn Bolting OLs or C?s fer plants with a EPCI Terry Turbine excepting Duane Arnold and Menticelle 78-15 Checkvalves Tail te 7/20/78 All Holders of Close In Vertical Reacter OLs er C?s Positten 75-16 Linitorque valve 7/26/78 All Helders of Reactor CLs cr Actuators cps Inclesure Page 2 cf 2
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