Information Notice No. 92-30: Falsification of Plant Records
NUCLEAR REGULATORY COMMISSION
OFFICE OF NUCLEAR REACTOR REGULATION
WASHINGTON, D.C. 20555
April 23, 1992
NRC INFORMATION NOTICE 92-30: FALSIFICATION OF PLANT RECORDS
All holders of operating licenses or construction permits for nuclear power
reactors and all licensed operators and senior operators.
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,
April 23, 1992
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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.
April 23, 1992
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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
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
Eugene M. Kelly, RI
James A. Prell, RI
Attachment: List of Recently Issued NRC Information Notices
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