IE Circular No. 78-17, Inadequate Guard Training/Qualification and Falsified Training Records

  


                                UNITED STATES 
                        NUCLEAR REGULATORY COMMISSION 
                     OFFICE OF INSPECTION AND ENFORCEMENT 
                           WASHINGTON, D. C. 20555 

October 13, 1978                                       IE Circular 78-17 

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 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 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.

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 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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October 13, 1978                                     IE Circular 78-17  

Examples of Weapons Qualifications Improprieties  

In another instance, "certification" of firearms qualification was provided 
in the form of targets containing holes which were purported 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.

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 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 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 qualification prior to assignment of 
security duties. Each guard or watchman, 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) 

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October 13, 1978                                      IE Circular 78-17    


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 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 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 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 administered. Licensee management should monitor 
this training program so that inconsistencies 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; (1) of situations 
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 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 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 adequately demonstrated capability to perform 
assigned duties. Among the courses of action that the licensee could take 
are: 

*See American National Standards Institute, "ANSI N18.171973, Industrial 
Security for Nuclear Power Plants," Section 4.9 "Audits and Reports." 

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October 13, 1978                                      IE Circular 78-17  


     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.

     Interview or test guards, watchmen and response individuals in order to 
     confirm that the specific information contained in records is accurate.

     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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