ML20062C117
| ML20062C117 | |
| Person / Time | |
|---|---|
| Site: | Peach Bottom  |
| Issue date: | 10/13/1978 |
| From: | Grier B NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION I) |
| To: | Daltroff S PECO ENERGY CO., (FORMERLY PHILADELPHIA ELECTRIC |
| References | |
| NUDOCS 7811060203 | |
| Download: ML20062C117 (1) | |
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.2 naan Av Nur g,,,, g p xiNa or paussia,,ENNsVLVANIA t$406 October 13, 1978 Docket Nos. 50-277 50-278 Philadelphia Electric Company ATTN: Mr. S. L. Daltroff Vice President Electric Production 2301 Market Street Philadelphia, Pennsylvania 19101 Gentlemen:
.g-The enclosed _ IE Circular No. 78-17 is forwarded to you for informa-tion. Should you have any questions related to your understanding of this matter, please contact this office.
Sincerely, n-oyce H. Grier Z
' Director i.
Enclosures:
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1.
IE Circular No. 78-17 iJ
- 2. ' List of IE Circulars
~ 1 55ued in 1978 cc w/encls:
W. T. Ullrich, Station Superintendent Troy B. Conner, Jr., Esquire i
Eugene J. Bradley, Esquire Raymond L. Hovis, Esquire Warren Rich, Esquire d
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UNITED STATES NUCLEAR REGULATORY COMMISSION OFFICE OF INSPECTION AND ENFORCEMENT WASHINGTON, D. C.
20555 IE Circular No. 78-17 Date: October 13, 1978 Page 1 of 4 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.*
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 determine 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 required to thoroughly identify the magnitude of the prob-lems. 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' abil-ities to perform job-related duties.
l 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 immediately available.
The guards initially 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 receivyd.
- 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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s IE Circular No. 78-17 Date: G:tober 13, 1978 Page 2 of 4 Examples of Weapons Qualifications Improprieties:
In another instance, " certification" of firearms qualification was provided in the form of targets containing tolas which were purported to have been made by guards duririg 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 which did not accurately reflect facts.
At other locations, records provided as evidence of training appeared adequate. They contained inf:rmation 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 some-one 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 nata 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 extensive range practice and training..They were subsequently not allowed to perform duties as guards.
Ia 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 from less than 10 yards.
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.
i Discussion:
Guards and watchmen, who are responsible for the protection of nuclear power plants must successfully complete,a program of training and quali-fication prior to assignment of security duties.
Each guard or watch-4 man, whether licensee employees or provided by contract must be tested and later requalified to ensure that they are capable of meeting and maintaining minimum levels of performance.
(10 CFR 73.55 and effective October 23, 1978 Appendix B to 10 CFR Part 73) t t
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b IE Circular No. 78-17 Date: October 13, 1978 Page 4 of 4 1
A.
Review training records, certifications and supporting documenta-tion to verify that the records are accurate and complete and that they adequately reflect ths 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 contair4ed 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, range training and qualification.
This direct observation i
should include both initial training / qualification and retrain-ing/requalification activities.
No written response to this Circular is required.
If you desire addi-tional information regarding this matter, contact the Director of the appropriate NRC Regional Office.
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