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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 perform 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 . IN 92-30 April 23, 1992 Page 2 of 3 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 individual had his employment terminated, several individuals 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, management 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. . IN 92-30 April 23, 1992 Page 3 of 3 In addition, the administrative section of plant technical specifications requires that written procedures be implemented covering the applicable procedures 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 .
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