Information Notice 1992-30, Falsification of Plant Records
I
I
UNITED STATES
NUCLEAR REGULATORY COMMISSION
OFFICE OF NUCLEAR REACTOR REGULATION
WASHINGTON, D.C.
20555
April 23, 1992
NRC INFORMATION NOTICE 92-30: FALSIFICATION OF PLANT RECORDS
Addressees
All holders of operating licenses or construction permits for nuclear power
reactors and all licensed operators and senior operators.
Purpose
The U.S. Nuclear Regulatory Commission (NRC) is issuing this information
notice to alert addressees to the NRC's concern that plant mechanics, technicians, and operators may have falsified plant logs at several nuclear
power plants. The NRC is reminding plant mechanics, technicians, and operators
(both licensed and non-licensed) of the penalties that could result from
intentionally violating Federal regulatory requirements and criminal statutes.
The NRC is also reminding addressees that all personnel are subject to the
requirements of 10 CFR 50.9(a) which states that information required by
statute or by the Commission's regulations be complete and accurate in all
material aspects.
It is expected that recipients will review the information
for applicability to their facilities and consider actions, as appropriate, to
avoid similar problems.
However, suggestions contained in this information
notice are not NRC requirements; therefore, no specific action or written
response is required.
Description of Circumstances
On March 1, 1992, the shift superintendent for the Public Service Company of
New Hampshire's Seabrook Nuclear Station was conducting a surveillance, in
accordance with a personnel performance monitoring program, to verify that
operations department personnel were properly performing their assigned duties.
On this occasion, the shift superintendent reviewed the security department's
computerized card key entry records against locations in which an auxiliary
operator's (AO's) log entries had indicated that he had performed inspections.
The shift superintendent found that the AO had logged "SAT" (satisfactory) for
some plant areas, indicating that he had performed the required periodic
inspections, although the computerized security data indicated that some of
these areas had not been entered.
The shift superintendent's findings prompted the licensee to establish an
independent review team (IRT) to performi a comprehensive analysis of the
root cause(s) and the generic implications of this occurrence. The IRT
interviewed the individuals involved and the management and supervisory
staff and examined a wide range of historical records created or used since
the issuance of the full power operating license, including security logs,
9204170113
5/!
April 23, 1992 operations logs and procedures, administrative program manuals, and training
lesson plans.
Discrepancies were found by the IRT, and some involved violations
of technical specifications and some involved licensed operators.
In response to the findings at Seabrook, random checks were conducted at the
Haddam Neck Plant and Millstone Nuclear Power Station. To date, no dis- crepancies have been identified at Haddam Neck. At Millstone, the Northeast
Nuclear Energy Company (the licensee) determined that several non-licensed
plant equipment operators (PEOs) had not completed certain inspection rounds
as represented in their logs. The Millstone licensee has since expanded its
evaluation to verifying the accuracy of log entries recorded by all PEOs.
The management at Millstone informed plant personnel of its findings and
expectations for recording log entries. The Millstone licensee also
established an IRT (with a representative from the Seabrook IRT acting in
an advisory status) to investigate its findings, to determine the extent of
the problem, and to determine corrective actions that should be taken.
At Oyster Creek, several non-licensed PEOs were involved with falsification of
records associated with routine plant log taking rounds. None of the records
involved were related to technical specifications. The discovery of the
falsified log entries was from an ongoing random investigation comparing
security door entry records with operator rounds.
As a result of discrepancies found at Seabrook, Oyster Creek, and Millstone, at least one indivie-a-yn his e-pT
tte-rmnn
iniated,-s-everaltudiv-tduals-
-
resigned, and several other individuals were suspended.
On January 28, 1992, two Instrumentation and Control technicians at the Vogtle
Electric Generating Plant, Unit 1, performed a surveillance on a portion of
the reactor trip system instrumentation. The Georgia Power Company (the
licensee) informed the NRC that the technicians failed to properly follow the
surveillance procedure and subsequently created the data that was entered on
the calibration data sheet.
NRC evaluation of each of these matters is continuing.
Discussion of Safety Significance
Maintenance of shift records, log sheets, and surveillance records, attention
to detail, and work ethics are important factors which contribute to the safe
operation of nuclear power plants. Complacency, by mechanics, technicians, or
licensed or non-licensed operators, cannot be tolerated. Similarly, manage- ment expectations and supervisory overview of rounds need to be clearly
communicated and monitored. All personnel involved in NRC-regulated activities
are responsible for complying with applicable NRC regulatory requirements and
other Federal laws.
Log keeping activities as well as surveillances
performed by licensed or non-licensed personnel are subject to the
requirements of 10 CFR 50.9(a) regarding completeness and accuracy of information.
April 23, 1992 In addition, the administrative section of plant technical specifications
requires that written procedures be implemented covering the applicable proce- dures in Appendix A of Regulatory Guide 1.33, Quality Assurance Program
Requirements (Operation). Among the safety-related activities which Appendix A
states should be covered by written procedures are surveillances and log
entries.
Willful violations, committed by personnel at any level of a licensee's
organization, are of regulatory concern because the NRC must have reasonable
assurance that licensed activities will be conducted in a manner that will
protect the public health and safety. Such reasonable assurance is provided
in large part by the integrity and conscientiousness of each individual
performing licensed activities. Deliberate violations concerning matters
within the scope of an individual's responsibilities, including falsification
of records, will be considered for enforcement action against the individual
as well as the facility licensee. As provided in 10 CFR 50.5, "Deliberate
Misconduct by Unlicensed Persons," 56 Federal Register 40684, August 15, 1991, the NRC may take direct enforcement action against unlicensed personnel who
deliberately cause a licensee to be in violation of the Commission's regulations
or who provide false information to the licensee concerning licensed activities.
Addressees
may wish to take actions as appropriate to ensure that plant
personnel are properly performing their assigned duties.
Addressees
may also
wish to distribute copies of this information notice to all their employees.
This information notice requires no specific action or written response. If
you have any questions about the information in this notice, please contact
one of the technical contact(s) listed below or the appropriate Office of
Nuclear Reactor Regulation (NRR) project manager.
Charles E. Rossi, Director
Division of Operational Events Assessment
Office of Nuclear Reactor Regulation
Technical contact(s):
David C. Fischer, NRR
(301) 504-1154
Eugene M. Kelly, RI
(215) 337-5183
James A. Prell, RI
(215) 337-5108 Attachment:
List of gecently I sued NRC Information Notices
mz
,-
0190
rn Z
0 FQ)
m
0>
0
CD
C
e
I D
mC
C,0
cn
"3 an
0
2
- oi
G)C)
z0
=i CJ >
0
O = a U)
0 nU)
G)
m
'ii
>~
s
r
s
Attachment
April 23, 1992
Page I of 1 I
II
I
I
LIST OF RECENTLY ISSUED
NRC INFORMATION NOTICES
Information
Date of
Notice No.
Subject
Issuance
Issued to
92-21, Spent Fuel Pool Re-
04/22/92
All holders of OLs or CPs
Supp. 1 activity Calculations
for-nuclear power reactors.
92-29 Potential Breaker Mis-
04/17/92
All holders of OLs or CPs
coordination Caused by
for nuclear power reactors.
Instantaneous Trip
Circuitry
92-28 Inadequate Fire Suppres-
04/08/92
All holders of OLs or CPs
sion System Testing
for nuclear power reactors.
92-27 Thermally Induced Acceler-
04/03/92
All holders of OLs or CPs
ated Aging and Failure of
for nuclear power reactors.
ITE/GOULD A.C. Relays Used
in Safety-Related Applic- ations
92-26 Pressure Locking of Motor-
04/02/92
All holders of OLs or CPs
Operated Flexible Wedge
for nuclear power reactors.
Gate Valves
92-25 Potential Weakness in
03/31/92
All holders of OLs or CPs
Licensee Procedures for A
for nuclear power reactor
Loss of the Refueling
Cavity Water
92-24 Distributor Modification to
03/30/92
All holders of OLs or CPs
Certain Commercial-Grade
for nuclear power reactors.
Agastat Electrical Relays
92-23 Results of Validation Test-
03/27/92
All holders of OLs or CPs
ing of Motor-Operated Valve
for nuclear power reactors
Diagnostic Equipment
and all vendors of motor- operated valve (MOV) diag- nostic equipment.
OL - Operating License
- Construction Permit
April 23, 1992 In addition, the administrative section of plant technical specifications
requires that written procedures be implemented covering the applicable proce- dures in Appendix A of Regulatory Guide 1.33, Quality Assurance Program
Requirements (Operation). Among the safety-related activities which Appendix A
states should be covered by written procedures are surveillances and log
entries.
Willful violations, committed by personnel at any level of a licensee's
organization, are of regulatory concern because the NRC must have reasonable
assurance that licensed activities will be conducted in a manner that will
protect the public health and safety. Such reasonable assurance is provided
in large part by the integrity and conscientiousness of each individual
performing licensed activities. Deliberate violations concerning matters
within the scope of an individual's responsibilities, including falsification
of records, will be considered for enforcement action against the individual
as well as the facility licensee. As provided in 10 CFR 50.5, "Deliberate
Misconduct by Unlicensed Persons," 56 Federal Register 40684, August 15, 1991, the NRC may take direct enforcement action against unlicensed personnel who
deliberately cause a licensee to be in violation of the Commission's regulations
or who provide false information to the licensee concerning licensed activities.
Addressees
may wish to take actions as appropriate to ensure that plant
personnel are properly performing their assigned duties.
Addressees
may also
wish to distribute copies of this information notice to all their employees.
This information notice requires no specific action or written response. If
you have any questions about the information in this notice, please contact
one of the technical contact(s) listed below or the appropriate Office of
Nuclear Reactor Regulation (NRR) project manager.
Charles E. Rossi, Director
Division of Operational Events Assessment
Office of Nuclear Reactor Regulation
Technical contact(s): David C. Fischer, NRR
(301) 504-1154
Eugene M. Kelly, RI
(215) 337-5183
James A. Prell, RI
(215) 337-5108 Attachment:
List of Recently Issued NRC Information Notices
Document Name:
IN/GUNDECK LOG
CONCURRENCES ---
SEE NEXT PAGE
- SEE PREVIOUS CONCURRENCE
OEAB:DOEA:NRR
DCFischer*
04/07/92 ADM:RPB
JMain*
04/08/92 C:OEAB:DOEA:NRR
AEChaffee*
04/07/92 C:LOLB:DLPQ:NRR
RMGallo*
04/08/92 C:LHFB:DLPQ:NRR
JSWenmiel*
04/09/92 RI
LBettenhausen*
04/14/92 D:DRP:RII
LAReyes*
04/15/92 D: OE
JLieberman*
04/15/92 C:OGCB:DOEA:NRR
CHBerlinger*
04/15/92 D:D
04/
9v
- SEE PREVIOUS CONCURRENCE
OEAB:DOEA:NRR
DCFischer*
04/07/92 C:LHFB:DLPQ:NRR
JSWermiel*
04/09/92 C:OGC
CHBerjinger
04/15 /92 ADM:RPB
JMa i n*
04/08/92 RI ter st'
LBettenhausen
04/14/92 C:OEAB:DOEA:NRR
C:LOLB:DLPQ:NRR
AEChaffee*
RMGallo*
04/07/92
04/08/92 D:DRP:RII ';*"
M. I.
LAReyes
i
rman
04/15/92
04
/92 D:DOEA:NRR
CERossi ,3
04/ /92-
IN 92-XX
April xx, 1992 This information notice requires no specific action or Written response. If
you have any questions about the information in this n
ptice, please contact
one of the technical contact(s) listed below or the
propriate Office of
Nuclear Reactor Regulation (NRR) project manager.
Charles E. ossi, Director
Division f Operational Events Assessment
Office o Nuclear Reactor Regulation
Technical contact(s): Davi C. Fischer, RR
(301)
4-1154
Eugene M. 1 , RI
(215) 337-51 Attachment: List of Recently Issue NR
Information Notices
Document Name:
IN/GUNDECK OG
- SEE PREVIOUS CONCURRENCY p i\\
OEAB:DOEA:NRR
ADM:RPB X
C:OEAB:DOEA:NRR
C:LOLB:DLPQ:NRR
DCFischer*
JMain
AEChaffee*
MGallo
04/07/92)
¢p
04/.3/92
04/07/92
0 \\
/92
CA
CILHFB:DLPQ:NRR
DRP:RI
C:OGCB:DOEA:NRR
D:D A:NRR
JSWermiel
EMKell
CHBerlinger
CERos
04/ '/92
04/ / 2
04/ /92
04/ /92
Document Name:
OEAB:DOEA:NRR
DCFischer
04/7 /92 C:LHFB:DLPQ:NRR
JSWermiel
04/ /92 IN/GUNDECK LOG
C:LOLB:DLPQ:NRR
RMGallo
04/ /92
04/ /'
- DOEA:NRR
.Rossi
4/ /92
04/
IN 92-XX
April xx, 1992 This information notice requires no specific action or written response.
If
you have any questions about the information in this notice, please contact one
of the technical contact(s) listed below or th appropriate Office of Nuclear
Reactor Regulation (NRR) project manager.
Charl
E. Rossi, Director
Divis on of Operational Events Assessment
Offi e of Nuclear Reactor Regulation
Technical contact(s): D id C. Fisch , NRR
(301
504-1154 Eugene
Kel y, RI
(215) 337 1 3 Attachment:
List of Recently Iss e
RC Information Notices
Document Name:
IN/GUNDECK LOG
OEAB:DOEA:NRR
ADM:RPB
C:OEAB:DO
- NRR
C:LOLB:DLPQ:NRR
DCFischer
JMain Q
AEChaffee
RMGallo
04/ /92
04/8 /9'2
04/ /92
04/ /92 C:LHFB:DLPQ:NRR
C:OGCB:DOE :NRR
D/DOEA:NRR
JSWermiel
CBerlingej
CERossi
04/ /92
04/ /92 /
04/ /92 I