ML20148E245

Forwards IE Circular 78-17.(See ANO:7810230221,Docket 50-133,781013.)

ML20148E245
Person / Time
Site:	Pilgrim
Issue date:	10/13/1978
From:	Grier B NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION I)
To:	Andognini G BOSTON EDISON CO.
References
NUDOCS 7811060176
Download: ML20148E245 (1)

Text

- .s . l' M l pSMo u UNITED STATES l

y. .,g NUCLEAR REGULATORY COMMISSION

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• • • • • October 13, 1978 Docket No. 50-293 l Boston Edison Company M/C Nuclear ATTN: Mr. G. Carl Andognini, Manager Nuclear Operations Department 800 Boylston Street Boston, Massachusetts 02199  !

Gentlemen: i The enclosed IE Circular No. 78-17 is forwarded to you for informa-tion. Should you have any questions related to your understanding of l l

this matter, please contact this office. l Sincerely,

/ /Scyce N H. Grier b" l I

bra Director

Enclosures:

l IE Circular No. 78-17 1.

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

P. J. McGuire, Pilgrim Station Manager A. Z. Roisman, Natural Resources Defense Council 787l.06 Ol7b 1

UNITED STATES 1

NUCLEAR REGULATORY COMMISSION OFFICE OF INSPECTION AND ENFORCEMENT ,

WASHINGTON, D. C. 20555 IE Circular No. 78-17 i Date: October 13, 1978 )

Page 1 of 4 INADEQUATE GUARD TRAINING / QUALIFICATION AND FALSIFIED TRAINING RECORDS 1

Description of Circumstances: l 1

Recent physical protection inspections and investigations of allegations l 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 l activities. In a number of situations, combinations of the above listed I efforts were required to thoroughly identify the magnitude of the prob- i 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.

Examples of Qualification Records Falsification:

At one facility, a " record of certification" indicated that a guard had l achieved a specific, passing score on a written test. An examination of l the actual test showed that: (1) the test had never been fully completed l by the individual, and (2) those portions of the test which had been i 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 l indicated that they had received the training. Later, however, they I confirmed that their supervisors had instructed them to verbally verify l the training regardless of actual training received. l l

• 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)). l l

IE Circular No. 78-17 Date: October 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 holes which were purported to have been made by guards during range firing. It was later determined that the holes had been made with a pencil. In another case, a number I of notarized firearms qualification forms were later discovered to i contain information which did not accurately reflect facts.

At other locations, records provided as evidence of training appeared l adequate. They contained information which indicated that individuals had qualified in the use of firearms with specific range scores. i Fur:her investigation showed t%t the scores had been achieved by some- l one other than the individual who was certified. In fact, other guards I and guard supervisors or range instructors had fired the qualifying I scores, but certified that the person, whose name appeared on the I record, had qualified. When discovered, these individuals were required  !

to return to the range in order to adequately qualify. The results of I this second qualification attempt showed that some individuals could not i qualify, even after extensive range practice and training. They were l 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 l 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.

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-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)

4 IE Circular No. 78-17 Date: October 13, 1978 Page 3 of 4 s 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 l evel s . *

The previously listed examples demonstrated that tne potential for a significant reduction in the effectiveness af the security organization

may exist and, further, that responsible management personnel may not be 4 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 j be either non-existent or severely deficient. In some cases audits of the actual quality of training programs and practices have never been conducted. In other cases tFe audits consisted of a spot review of lesson plans and individual guard's training records with no attempt being made to verify the accuracy of those records. Subsequently, in j the cases cited, records were verified as false and confirmation was i obtained that training had not been given or was improperly adminis-7 tered. Licensee management should monitor this training program so that

, inconsistencies in the record that suggest either a lack of, or inade-4 quate training can be detected, irrespective of whether these inconsis- '

tencies are inadvertent or deliberate.

i It should be noted that, in limited instances where a licensee conducted i 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:

i The purpose of this Circular is to inform all licensees: (1) of si tua-tions that have been found; (2) that their program to preclude similar situations will be evaluated by NRR during licensing review of their Guard Qualification and Trainin Appendix B to Part 73; and, (3)gtoPlanalert submitted in accordance them that I&E inspectors willwith be assessing their situation. Therefore all licensees who are required to provide physical 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 armed response individuals (as applicable) have been properly trained and qualified and have ade-quately 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 Security.for Nuclear Power Plants," Section 4.9, " Audits and Reports."

, IE Circular No. 78-17 l Date: October 13, 1978 '

Page 4 of 4 A. Review training records, certifications and supporting documenta-tion 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 i is accurate.

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C. Observe pertinent aspects of the training program to verify that i 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 should include both initial training / qualification and retrain- i ing/requalification activities.  !

l No written response to this Circular is required. If you desire add 1- l tional information regarding this matter, contact the Director of the appropriate NRC Regional Office. ,

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