Information Notice No. 92-30: Falsification of Plant Records

                                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, 

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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.  

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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 
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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