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
IE Files
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Mike Atsalinos, DSB:TIDC:ADM Phil-050
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