ML20148E299
| ML20148E299 | |
| Person / Time | |
|---|---|
| Site: | Maine Yankee |
| Issue date: | 10/13/1978 |
| From: | Grier B NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION I) |
| To: | Groce R Maine Yankee |
| References | |
| NUDOCS 7811060192 | |
| Download: ML20148E299 (1) | |
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% 'p*. ~, "'j 631 PARK AVENUE t,Sf,y KING OF PRUS$l A, PENNSVt V ANI A i9406 October 13, 1978 Docket No. 50-309 Maine Yankee Atomic Power Company ATTN:
Mr. Robert H. Grace Licensing Engineer 20 Turnpike Road Westborough, Mas.;achusetts 01581 Gentl emen:
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, e9
' ' /ktRbhn 3
oyce H. Grier V ' Director
Enclosures:
1.
IE Circular No. 78-17 2.
List of IE Circulars Issued in 1978 cc w/encis:
E. Wood, Plant Superintendent E. W. Thurlow, President 78 2100 O l(/ 7-
e 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 j
training practices and possible falsification of training records.*
l These items were disclosed through:
(1) a revie'. of existing guard training records; (2) interviews with guards and caard force supervisors which were conducted to determine the accuracy of specific information contained on rccords; and, (3) unannounced observation of training activities.
'n 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.
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 comcleted by the individual, and (2) those portions of the test which had been completed were not corrected nor graded.
l 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 hvailable.
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 received.
- The regulatory bases for providing adequate training to guards / watchmen and for adequately documenting that training are included in Title 10, l
Code of Federal Regulations, Part 73 (10 CFR 73.55(b)(4)).
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 of notarized firearms qualification forms were later discovered to contain information which did not accurately reflect facts.
J At other locations, records provided as evidence of training appeared 1
adequate.
They contained information which indicated that individuals had qualified in the use of firearms with specific range scores.
i Further investigction 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 i
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 individua's could not qualify, even after extensive 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 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 managemenc representative revealed that individuals were being allowed to use " bench rests" anc 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) l
)
IE Circular No. 78-17 Date:
October 13, 1978 Page 3 of 4 Accurate records of training and qualification scores are necessary in order to provide management a means for determining whether or not an individue is able to initially meet and thereafter maintain performance leve' The listed examples demonstrated that the potential for a sigt luction in the effectiveness of the security organization may -
further, that responsible management personnel may not be aware eduction.
This lack of awareness could compound the severi duration of the vulnerability.
Manage dits of guard training have been found, in some cases, to be eit, sn-existent or severely deficient.
In some cases audits of the actual quality of training programs and practices have never been conducted.
In other cases the 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 the cases cited, records were verified as false and confirmation was obtained that training had not been given or was improperly adminis-tered. Licensee management should nonitor this training program so that inconsistencies in the record that suggest either a lack of, or inade-quate training can be detected, irrespective of whether these inconsis-tencies 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 acequate, decisive action to correct the identified problems.
Recommended Action:
The purpose of this Circular is to inform all licensees: (1) of situa-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)g Plan submitted in accordance with 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 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," $2ction 4.9, " Audits and Reports."
IE Circular No. 78-17 Date:
October 13, 1978 Page 4 of 4 i
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.
j 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, range training and qualification.
This direct observation 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.
j