According to DOE 5632.7A, site-specific conditions can require the SRT to possess rappelling as a special skill to provide an effective and timely response as dictated by site- or activity-specific vulnerability assessments. The Board interviewed approximately 35 members of the SRT and determined that none have used rappelling to assess the adequacy of any SRS vital facility security posture, nor had they rappelled to assist in the development of establishing response timeliness in support of a vulnerability assessment, the key foundational analysis used to develop the SSSP. Conversely, the Board was informed that rappel skill retention has been performed on at least a quarterly basis at the ATTA Rappel Tower, at a deactivated SRS facility in 1988 (R-Reactor; see Section 2.1.1), and during helicopter (aerial) rappelling exercises. Aerial rappelling was suspended at SRS as a result of a February 1994 accident (see WSI-SRS Class "C" Accident Report, Appendix G). Some SRT personnel informed the Board that SR and WSRC personnel did not permit aerial/building rappelling operations at occupied SRS buildings because this activity posed a safety risk to the occupants.
The SSSP was developed jointly by SR, the lead cognizant secretarial office (at the time, Defense Programs), the Office of Nonproliferation and National Security (NN), WSRC, and WSI-SRS. This document formally establishes the protection strategy for vital SRS facilities.
The Board interviewed WSI-SRS Vulnerability Assessment representatives responsible for incorporating protective force performance test exercise results (that established response times) into vulnerability assessments for SRS vital facilities. The Board was informed that rappelling had not been used to determine response times necessary for protective force interdiction or interruption actions against the postulated adversary threat for vital SRS facilities.
The Board interviewed the SRT Commander and the WSI-SRS Senior Vice-President and General Manager and inquired if a study of rooftop access ports (i.e., doors, elevator shafts) had been performed. A study might have been an indicator to identify potential ascension/descension routes to ascertain possible rappel applications in support of the SRT recapture mission. Both individuals stated that such a study had not been conducted and asserted that SRT rappelling activities are performed primarily to meet a contract requirement, although there are secondary applications (e.g., insert a blocking force by helicopter to interdict fleeing adversaries).
The SRT Program Manager, NN, advised the Board that the Buddy Rappel was not a DOE-approved rappel technique, and was not taught at the CTA. Further, the SRT Program Manager stated that DOE sites must view CTA lesson plans as "an arm of policy" that clarifies and implements DOE policy in accordance with 10 CFR 1046. NN informed the Board that it is expected for DOE sites to either comply with CTA lesson plans in order to obtain their approval of protective force training operations or to formally request an exception from CTA lesson plan requirements. CTA reviewed and approved the WSI-SRS training program using a Training Approval Program process and, on another assessment, conducted an SRT Training Program Review (see Section 2.6), which included an analysis of SRT procedures, lesson plans, and safety aspects. As a result of these actions, NN certified the WSI-SRS SRT training program, which includes rappelling.
The SRT Program Manager advised the Board that only three WSI-SRS personnel had completed a CTA Rappel Instructor course and been "certified by the CTA" and, therefore, that these personnel were required to be present during rappel training activities in accordance with CTA lesson plans. It was uncertain if this provision or "requirement" had been documented or communicated because there is no DOE policy for rappel operations in DOE Orders. NN did not believe it necessary to disseminate a policy statement on rappelling requirements because it views CTA lesson plans as training criteria codified by 10 CFR 1046.
The Board interviewed the SR Security Management Division Team Leader. The Team Leader advised the Board that the June and November 1994 onsite assessments by NN and CTA of the implementation of DOE 5630.15, "Safeguards and Security Training," resulted in a NN/CTA November 4, 1994, memorandum that approved the WSI-SRS SRT training program.
The Board observed differences of opinion on the status of the CTA lesson plans. The Board interviewed the Director of the SR Office of Safeguards and Security and the WSI-SRS Senior Vice-President and General Manager in separate interviews. Both supported the SRT Program Manager's perception on the policy status of CTA lesson plans. However, the Board noted that all aspects of CTA lesson plans (i.e., fast rope, rock climbing, and elevator shaft cable climbing techniques) had not been incorporated into the WSI-SRS SRT training program.
The Board conducted a telephone interview with the Director of the DOE Office of Security Affairs (OSA), and members of his NN staff. During the interview, OSA advised the Board that CTA lesson plans should not be perceived as Department policy but as guidance. However, if a DOE site does not incorporate all aspects of a CTA lesson plan, it must forward an exception request to NN justifying its exclusion. The review of applicable DOE Orders found that this process is not delineated.
More recently, the Acting Director of NN informed the Board in a memorandum dated June 1, 1995, that "CTA lesson plans are Departmentally approved training procedures. They represent the approach to training the specified activity which has been researched and approved as best meeting Departmental requirements. It is expected that sites will train to CTA lesson plans. In the absence of a CTA lesson plan, sites may train to locally developed standards. This practice implements the DOE policy established in Title 10 Code of Federal Regulations, Part 1046 (10 CFR 1046) Appendix B to SUBPART B, B. (1) which requires that training and qualification programs be based upon criteria established by the CTA and approved by the Director, Office of Safeguards and Security (NN-51). Therefore, the policy is that Departmental training criteria will be followed. The applicable lesson plans implement this policy. We do not believe further clarification is required."
NN does not have a position on protective force participation in competitions because NN perceives participation is a local operations office decision. The Board discussed the potential DOE liability resulting from an injury sustained during a competition, especially if protective force members are not cognizant of all competition rules beforehand and CTA lesson plan training might not have properly prepared them for the event. NN recognized the potential liability and stated that it would be "poor judgment" for personnel to participate in competitions for which they are not trained.
WSI-SRS has been under contract to SR since 1983 and is currently under a "Management and Operating Contract for Paramilitary Security Services," which became effective September 30, 1993. The Board interviewed the SR Contracting Officer for the WSI-SRS contract and the Director of the SR Office of Safeguards and Security in separate interviews on the rationale for the contract provision that requires WSI-SRS to have an SRT that "shall be highly qualified and trained in aerial/building rappel techniques."
The 1988 version of the contract was the first under which the SRT was required to have this rappel capability. Neither person could provide a justification for the rappel contract provision remaining as a contract requirement since 1988. The Board later learned that DOE 5632.4, "Physical Protection of Security Interests," dated November 4, 1985, required that "prior to duty assignment, each SRT member shall successfully complete classroom and practical instruction that shall include...rappelling."
This requirement was subsequently eliminated in DOE 5632.7, "Protection Force Program," dated February 9, 1988, which made rappelling site mission oriented and justified in lieu of a generic SRT requirement. As discussed in Section 2.4.1, WSI-SRS management has stated that the primary reason for rappelling operations at SRS was to meet this contractual requirement.
The Board interviewed the SR Contracting Officer for the WSI-SRS contract and the Director of the SR Office of Safeguards and Security in separate interviews on the contract statement of work as it relates to SR authorizing WSI-SRS to participate in offsite SWAT competitions. The Director informed the Board that WSI-SRS participation in competitions "is strongly encouraged by the agency by the fact that our CTA also sponsors competitive type of activities." The Board noted that the contract does not have a provision that explicitly addresses competitions; however, the Contracting Officer stated that the contract was "very broadly written." Further, Section H.21 of the contract grants SR Division Directors the authority to provide "performance direction." In the absence of a DOE Headquarters policy governing participation in competitions, this section of the contract has been used as a basis for authorizing WSI-SRS participation in SWAT competitions. Section 2.7.3.1 discusses oversight and safety responsibilities related to competition preparation.
The SR correspondence to WSI-SRS entitled, "Authorization to Carry Weapons Off-Site During Calendar Year 1995," dated December 20, 1994, authorized WSI-SRS to remove DOE-owned firearms and ammunition from the SRS for a number of various reasons, one of which was to participate in unspecified competitions. The authorizing SR Division Director and the Director of SR-OSS advised the Board that this authorization letter has a lengthy historic precedence and is consistent with "past practices." The SR letter informed WSI-SRS that the authorization was considered to be within the scope of the contract. In general, the contract directs the contractor to be responsible "for the physical protection of DOE security interests and other such related duties at the Savannah River Site, the Central Savannah River Area, and on a case-by-case basis at other locations as directed by DOE." The Contracting Officer advised the Board that, by virtue of this correspondence, SR provided "performance direction" under the provisions of the contract and authorized WSI-SRS participation in the 2nd Annual SWAT Competition that was to be held at the Spartanburg County Detention Facility, Spartanburg, South Carolina, April 14-15, 1995. Historically, SR has funded participation in competitions as "mission travel" (Account No. 6520). Moreover, the contractor's performance in past competitions has been recognized by the SR Performance Evaluation Committee as an assessment factor (along with other performance indicators). This committee provides recommendations to the SR Award Fee Board because WSI-SRS performs under a Cost Plus Award Fee type contract. The Performance Evaluation Committee gave the following recognition:
During interviews with the WSI-SRS Senior Vice-President and General Manager, the Director of the SR-OSS, and the authorizing SR Division Director, the Board inquired about past derivative benefits to the Government for allowing WSI-SRS to participate in SWAT competitions. The responses all centered on such benefits as verification of SRT training skills, comparisons of SRT training levels against those of military or law enforcement SWAT forces, and enhancement of SRT morale.
The Board conducted a telephone interview with the sponsor of the SWAT Competition (the Spartanburg County Detention Facility, Spartanburg, SC) on the Rappel and Rescue Event rules for the (then upcoming) SWAT competition. This event was one of five included in the competition. The competition announcement contained the following Rappel and Rescue Event description:
The Board advised the sponsor that it had reviewed a videotape of last year's competition and inquired what changes, if any, would be made for this year's competition event. The sponsor stated that it is common practice not to disseminate all of the competition rules until a briefing that is conducted just prior to the start of the event and that this year would not be different. However, because the Board was not a competition participant, the sponsor stated that each rappeller would be required to rappel with two ropes (one rope was used in 1994) and that only the 165-pound "wounded hostage" dummy would be rappelled on a single rope from the top of the tower. The Board discussed the WSI-SRS preparations for the event utilizing the Buddy Rappel technique as a means to expedite personnel off the Rappel Tower. The sponsor advised the Board that if WSI-SRS had two individuals on the rappel rope at the same time, they would have been disqualified from the event.
The Board interviewed the SRT Training Lieutenant and determined that the Buddy Rappel technique was last taught to a cadre of SRT members in the late 1980s at the R-Reactor. Some of the WSI-SRS personnel who attended that training were current members of the WSI-SRS Spartanburg SWAT Competition Team, including the Team Coach (Shift Lieutenant). An undated and unsigned lesson plan that discussed the Buddy Rappel technique was later produced. This "plan" included a safety requirement for the rappeller to be "belayed from above" with a Muenter hitch. Although the relevance of the Buddy Rappel technique to DOE or SRT operations is obscure, some have associated the technique with rescuing injured personnel (although several other rescue techniques are available) or to quickly insert a person with mission-relevant technical skills who is unfamiliar with individual rappelling techniques. The Competition Team viewed the Buddy Rappel technique as a method to save time and increase their chances of winning the competition.
WSI-SRS Procedure 3-5617, "WSI-SRT National SWAT Competition Selection Process" provides a selection process for a competition team. Of the 10 competitors identified on the WSI-SRS Travel Authorization Request, dated February 15, 1995, six would actually participate in the events and, of the remaining four, one would be the Team Coach and the other the SRT Commander. The selection process stipulated that SRT shift "Upper 10" average scores on the semiannual SRT Tactical Proficiency Evaluation and the DOE weapons requalification would be the primary criteria for selection. The Buddy was a shift member assigned to the competition team as a result of an "Upper 10" shift score. For the Spartanburg SWAT competition, the SRT Training Relief Shift was selected and authorized to begin competition training.
The Board determined through interviews of the competition Team Coach that the Competition Team considered the use of the Buddy Rappel technique as an option to "get the team off the tower as quickly as possible" by eliminating the time needed for the final rappeller to hook up and descend individually. The team believed that this activity would "shave seconds off the timed event" and put the team in a better position to win the event and perhaps the entire competition. The team did not know that "putting two men on a rope" would result in immediate disqualification by the Spartanburg SWAT competition officials. The Board learned the following through document review and interviews of SRT, WSI-SRS management, and training management personnel:
When queried by the Team Coach before the accident about the use of the Buddy Rappel technique in the upcoming competition, the SRT Training Lieutenant did not reject the use of this technique during the Spartanburg competition. In fact, the SRT Training Lieutenant advised the Team Coach only to ensure the safety of the Buddy Rappellers during the SWAT competition training, not to exclude the use of the technique.
There are conflicting statements about whether the SRT Training Lieutenant advised the Team Coach to "top belay" (by using a safety line attached to both rappellers with control at the top of the tower) the Buddy Rappellers, or simply to attach another sling rope between the two rappellers to ensure their attachment to each other.
The Board interviewed the Team Coach and members of the Competition Team to ascertain the command and control structure in place at the time of the accident. The Team Coach (SRT Shift Lieutenant) described the multifaceted command and control structure at the ATTA facility on the morning of the accident. He further distinguished between routine SRT training activities (i.e., live fire weapons training), which require the presence of an SRT Instructor at the ATTA facility to open the range and direct training operations and other activities associated with SWAT competition training. Because the team was preparing for different competition events, activities were supported by the presence of various SRT Instructor specialists (e.g., rappelling operations). The Team Coach advised Board that some blocks of SWAT competition training fell under the responsibility of different personnel. WSI-SRS management differ with the Team Coach on this matter. The Board noted the absence of competition training procedures and lesson plans.
Interviews revealed that the Rappel Master had the final responsibility for the safety and proper execution of the rappelling operations; no single individual made the final decision to execute the Buddy Rappel. Rather, it was a group decision. Because WSI-SRS has no specific procedure that governs SWAT competition preparations, a multifaceted approach to command and control was in place and different individuals were in charge of separate activities. The normal chain of command was not in effect during SWAT competition preparations because the SRT Shift Lieutenant was acting as the Team Coach, and the SRT Training Shift Sergeant was acting as a team member.
Last Modified: Friday, 28-Feb-97 10:09:00