IE Circular No. 79-03, Inadequate Guard Training-Qualification and Falsified Training Records

CR79003 

MEMORANDUM FOR:     B. H. Grier, Director, Region I 
                    J. P. O'Reilly, Director, Region II 
                    J. G. Keppler, Director, Region III 
                    K. V. Seyfrit, Director, Region IV 
                    R. H. Engelken, Director, Region V 

FROM:               E. M. Howard, Director 
                    Division of Safeguards Inspection, IE 

SUBJECT:            IE CIRCULAR NO. 79-03, INADEQUATE GUARD TRAINING-
                    QUALIFICATION AND FALSIFIED TRAINING RECORDS 

The subject document is transmitted for issuance on February 23, 1979 and is
a follow-up to IE Circular 78-17. The contents of the circular should be 
discussed by you during the forthcoming meetings with the licensees 
concerning the implementation of Appendix B to Part 73. The circular should 
be issued to all holders of and applicants for Special Nuclear Material 
Licenses in Safeguards Group I. Also enclosed is a draft copy of the 
transmittal letter. 


                                        E. Morris Howard, Director 
                                        Division of Safeguards Inspection 
                                        Office of Inspection and Enforcement

Enclosures:
1.   IE Circular No. 79-03
2.   Draft Transmittal Letter 

CONTACT:  D. Rosano 
          (49-28080) 
.

(Transmittal letter for IE Circular No. 79-03, to each holder of and 
applicant for Special Nuclear Material Licenses in Safeguards Group I.) 

                                                      IE Circular No. 79-03 

Addressee: 

The enclosed IE Circular No. 79-03 is forwarded to you for information. If 
there are any questions related to your understanding of the suggested 
actions, please contact this office. 


                                        Signature 
                                        (Regional Director) 

Enclosure:
1.   IE Circular No. 79-03
2.   List of IE Circulars 
       issued in the last 12 months 
.

                              UNITED STATES 
                       NUCLEAR REGULATORY COMMISSION 
                   OFFICE OF INSPECTION AND ENFORCEMENT 
                          WASHINGTON, D.C. 20555 
                                     
                             February 23, 1979 

                                                      IE Circular No. 79-03 

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.* Some of 
the items discussed below are related to power reactors; however, it was 
thoughts advantageous to present a comprehensive analysis. The items were 
disclosed through: (1) reviews of guard training records; (2) interviews 
with guards and guard force supervisors regarding specific information 
contained on records; (3) unannounced observation of training activities; 
(4) allegations made by guards and subsequent investigations; and, (5) an 
investigation of training programs, policies, and procedures for 
qualification and requalification. In a number of situations, combinations 
of the above listed efforts were used to identify the magnitude or severity 
of the problems. The circumstances described below illustrate that 
individuals, who are performing duties as guards/watchmen, may not be 
adequately trained to meet existing requirements and/or that documentation 
may not give an accurate description of guard training or individuals' 
abilities to perform their 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 

* 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 73.50(a)(4) and 10 CFR 73.55 
  (b)(4)) 

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IE Circular No. 79-03                                      February 23, 1979

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. 

Examples of Irregularities in Guard Training and Qualification 

Guards were allowed to fire at targets that were closer than the prescribed 
qualification distance and scores were sometimes computed in such a way as 
to assure qualification even when a passing score was not received. 
Additionally, holes were sometimes poked in targets to falsify a passing 
score. Several persons alleged that some members of the guard force were 
armed even though they did not legitimately qualify. In another case, a 
number of notarized firearms qualification forms were later discovered 
contain information which was not factual. 

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. 

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 returned to the range in order to 
validate their qualifications. The results of this second qualification 
attempt showed that some individuals could not qualify, even after extensive 
range practice and training. These individuals were subsequently not allowed 
to perform duties as guards. 

At one site supervisors instructed guards to practice drying their weapons 
on post after unloading them. This had the effect of placing unarmed guards 
on post. This practice continued until an incident occurred in which a guard
following this procedure dropped his apparently unloaded weapon and it 
accidentally discharged. 

Instructors provided the answers to test questions in advance to assure a 
passing score. Guards were placed on certain posts (such as the Primary 
Central Alarm Station (PCAS)) before passing the examination required for 
the post. Certain post training records had been falsified to indicate that 
training was received when it in fact was not. 

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IE Circular No. 79-03                                      February 23, 1979

Discussion 

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 required performance 
levels.* 

The examples listed above demonstrate that an unacceptable 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 result in a deviation from the intent and purpose of
guard training requirements. 

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 training records with no attempt being made to verify the 
accuracy of those records. In the cases cited, some records were verified as
false and confirmation was obtained that training had not been given or was 
improperly administered. Licensee management should monitor the training 
program so that inconsistencies in the record that suggest either a lack of,
or inadequate training can be detected, irrespective of whether these 
inconsistencies are inadvertent or deliberate. 

It should be noted that, in those instances where a comprehensive audit of 
records and actual training was properly conducted, management was able to 
identify significant problems and examples of apparent falsification. In 
those cases, the disclosures enabled management to take adequate, corrective
action. 

Recommended Action 

The purpose of this circular is to inform all licensees: (1) of unacceptable
situations that have been found; (2) that their program to preclude similar 
situations will be evaluated during licensing review of their Guard 
Qualification and Training Plan submitted in accordance with Appendix B to 
Part 73; and, (3) that IE inspectors will be assessing all aspects of their 
existing guard training and qualification programs. Therefore, all licensees
who are required to provide physical protection for fuel cycle facilities 
and nuclear power plants in accordance with 

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

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IE Circular No. 79-03                                      February 23, 1979

the provisions of the Code of Federal Regulations, Title 10, Part 73 should 
take steps to assure 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: 

A.   Review training records, certifications, and supporting documentation 
     to determine whether 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 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 and 
     range training and qualification. The direct observation should include
     both initial training/qualification and retraining/qualification and 
     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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IE Circular No. 79-03 
Inadequate Guard Training Qualification and Falsified Training Records 

Distribution: L. V. Gossick, EDO                                               
MNBB-6209 J. R. Shea, Dir., OIP                                            
MNBB-8103 J. J. Fouchard, Dir., PA                                         
MNBB-3709 N. M. Haller, Director, MPA                                      
MNBB-12105 R. B. Minogue, Dir., SD                                            
NL-5650 W. J. Dircks, Dir., NMSS                                           
SS-958 
S. Levine, Dir., RES                                               SS-1130 
H. R. Denton, Dir., NRR                                          Phil-428  
R. S. Boyd, Dir., DPM:NRR                                        Phil-268  
D. F. Ross, Deputy Director, DPM:NRR                             Phil-278  
V Stello, Dir., DOR:NRR                                          Phil-542  
J. R. Miller, DOR:NRR                                            Phil-216  
D. G. Eisenhut, Dep. Dir., DOR:NRR                               Phil-266  
G. C. Lainas, Chief, PSB:DOR:NRR                                 Phil-416  
B. K. Grimes, Asst. Dir., E/P:DOR:NRR                            Phil-370  
R. J. Mattson, Dir., DSS:NRR                                     Phil-202  
W. P. Haass, Chief, QAB:OAO:NRR                                     P-320 
R. F. Fraley, ACRS                                                  H-1016 
V. Harding, Legal Assistant, OCM                                    H-1149 
G. Wayne Kerr, Asst. Dir., SA:SP                                 MNBB-7210A 
J. Lieberman, ELD                                                MNBB-9604 
J. G. Davis Acting Dir., OIE 
S. E. Bryan, XOOS:OIE 
R. C. Paulus, XOOS:IE 
L. N. Underwood, XOOS:IE (Original) 
H. D. Thornburg, RCI:IE 
G. W. Reinmuth, RCI:IE 
N. C. Moseley, ROI: IE 
E. L. Jordan, ROI:IE 
G. R. Klingler, Act. Asst., ROI:OIE 
J. H. Sniezek, FFMSI:IE 
L. B. Higginbotham, FFMSI:IE 
E. M. Howard, SI:IE 
L. I. Cobb, XOMA:IE 
R. P. Rosano, SI:IE 
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