ML20045E647
| ML20045E647 | |
| Person / Time | |
|---|---|
| Issue date: | 06/25/1993 |
| From: | Marcus G Office of Nuclear Reactor Regulation |
| To: | Vanduser K NRC OFFICE OF INFORMATION RESOURCES MANAGEMENT (IRM) |
| References | |
| GL-93-03, GL-93-3, NUDOCS 9307020269 | |
| Download: ML20045E647 (5) | |
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o UNITED STATES
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NUCLEAR REGULATORY COMMISSION
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WASHINGTON, D. C. 20S55 q.
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June 25, 1993 MEMORANDUM FOR:
Karen VanDuser, Chief Document Management Branch Division of Information Support Services Office of Information Resources Management FROM:
Gail H. Marcus, Chief Generic Communications Branch Division of Operating Reactor Support Office of Nuclear Reactor Regulation
SUBJECT:
DRAFT DOCUMENT INADVERTENTLY MADE PUBLIC The attached draft generic letter was inadvertently placed on an NRC electronic bulletin board on April 13, 1993. The draft generic letter had been given a number (Generic Letter 93-03), an issue date (April 6, 1993) and an accession number in the Nuclear Documents System (NUDOCS) in preparation for signature and issuance. However, the draft generic letter was not signed i
at that time and was placed on hold. The draft generic letter was removed l
from the bulletin board as soon as the error was discovered on April 14, 1993.
Bulletin board users were sent a message to inform them that the draft generic letter was not issued and that they should destroy all copies that they might have made.
The staff intends to issue this document in the future as Generic Letter 93-03 after it is revised.
z Because members of the public :::ay have gained access to the draft generic letter during the time it was on the bulletin board, or through dissemination by the users, we want to place a document into the Public Document Room that will answer any questions that may be asked by members of the public regarding this situation.
This memorandum and the attachment will serve this purpose.
The NUDOCS entry for this memorandum should show that it is related to Generic Letter 93-03.
If you have any questions concerning this matter please contact me or the contact listed below.
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Gail H. Marcus,' Chief Generic Communications Branch Division of Operating Reactor Support Office of Nuclear Reactor Regulation I
CONTACT:
Andrew J. Kugler (301) 504-2828
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Attachment:
Draft Generic Letter b
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DRAFT NOT ISSUED
, 1993 T0:
ALL HOLDERS OF OPERATING LICENSES OR CONSTRUCTION PERMITS FOR NUCLEAR POWER REACTORS
SUBJECT:
VERIFICATION OF PLANT RECORDS (GENERIC LETTER 93-XX)-
PURPOSE The U.S. Nuclear Regulatory Commission (NRC) is issuing this generic letter to inform licensees of the results of the inspections conducted under Temporary Instruction (TI) 2515/115, " Verification of Plant Records," which addressed the potential for falsification of records at licensed facilities.
This generic. letter reminds licensees and individuals involved in licensed activities that the NRC may take direct enforcement action.against not only.
the licensee but also any individual who deliberately causes a-licensee to be i
in violation of NRC requirements. This includes the falsification of records required by technical specifications and plant procedures: developed pursuant to Regulatory Guide 1.33, " Quality Assurance Program Requirements (Operation)," or other regulatory requirements.
BACKGROUND Section 50.9, " Completeness and Accuracy of Information," of Title 10 of the O
Code of Federal Regulations (10 CFR) requires that information' maintained by.
the licensee pursuant to commission. regulations, ' orders,.or license conditions be complete and accurate in all material respects. The ' administrative section.
of plant technical specifications' requires that written' procedures covering i
the applicable activities in Appendix A of. Regulatory Guide 1.33 be developed, implemented, and maintained. Activities for which Appendix A recommends written procedures include surveillances and log entries.
Section 50.5, " Deliberate Misconduct," of 10 CFR states that^the NRC may take direct enforcement action against' an individual, including an unlicensed person, who (1) deliberately causes or, but for detection would have caused, a licensee to be in violation of the Commission's requirements; or (2)~ who deliberately provides information to the licensee concerning licensed activities that the person providing the information knows to be incomplete or.
inaccurate in some respect material to the NRC.
On April 23, 1992, the NRC issued Information Notic'e 92-30, " Falsification:of Plant Records," to alert the industry' to concerns of the NRC.regarding record falsification that had occurred at several plants. The notice specifically' reminded plant personnel, both licensed and unlicensed, that they-'are subject to -10 CFR 50.5 and that individual penalties could result from deliberately violating Commission requirements.
It also noted that the NRC was continuing y
its evaluation of the individual. cases discussed.
In response to this notice, 0
7 Attachment
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DRAFT
- NOT ISSUED Generic Letter 93-XX
- 2.-
-,-_1993 -
many licensees initiated actions to ensure that plant ' personnel were properly performing'their assigned duties.
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The NRC issued TI 2515/115 to provide guidance for NRC inspectors' evaluation of the ability of each licensee to obtain complete and accurate log readings-from both licensed and unlicensed operators. -The inspection findings.were documented in a routine resident inspection report _for each facility. The NRC-reviewed the inspection findings nationwide to determine how widespread the-problem was.
SUMMARY
OF TI 2515/115 INSPECTION RESULTS The NRC recognizes that it is difficult to compare the inspection results among plants. Many factors can affect the inspection findings, such as the variation in the extent of_ computerized access areas within the protected area from plant to plant and in the sample sizes reviewed by licensees:(some.
licensees greatly expanded their sample size.in response ~ to an. identified-discrepancy). However, the review showed that at approximately_32' sites at least one discrepancy.between security computer records and documented logs existed; at most sites the number of discrepancies was less than.5. : At eight-o sites, the number of falsified ' records identified indicated-the existence-of-a-broader problem.
In addition,11 licensed operators at 4 plants' had ' falsified at least one plant round sheet or log.
Several licensees found that records and logs had_ been falsified no_t only. by auxiliary operators during their rounds, but also by contractor f_ ire watches and health physics' technicians.
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Several licensees discovered a number of other problems related'to the~ conduct of plant rounds, log taking,. and record keeping.
In some instances, licensees found that many of the unlicensed operators were performing certain rounds much faster than management expected. 'Other licensees found that unlicensed operators did not have a clear understanding of what their signatures.on a -log-sheet meant.
Some believed that it attested to'only the fact that the round t
had been performed, whether by the log signatory or another operator.
Several licensees found that when multiple rounds or log readings ~ were required in a single shift, the operators performed a generally rigorous' first tour,- but a much less formal second tour.
Finally, at one facility, management review of-the tour and logging requirements revealed that the operators could not reasonably be expected to conduct the specified rounds.in the time provided because of such factors as the number of times the operators had to don and remove anticontamination clothing to enter ar.d leave radiation-controlled areas.
The NRC found that licensee responses to Information Notice _92-30 were
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positive.
1.icensees took advantage of the information to review records,
- sensitize employees, and appropriately revise procedures and training. They also took various disciplinary actions.against the involved individuals in; accordance with their internal programs' and policies, commensurate with.the-l j
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Attachment H
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-DRAFT NOT? ISSUED.
N Generic Letter 93-XX 13-
, 1993 seriousness of the violation. - Disciplinary actions taken by. the licensees-against-the licensed operators ranged from employment-termination to license :
suspension or leave without pay.
-i ENFORCEMENT ACTION' The information from each site was reviewed on a case-by-case. basis to determine the appropriate enforcement action.
Because, in each: case, licensees took appropriate corrective action for any potential program weaknesses and took disciplinary action against the individuals involved,:as appropriate, the NRC did not take further enforcement action against.the facility licensees for violations identified as a result of. the audits and inspections conducted after the information notice was issued.
In addition, the NRC is-not taking any enforcement action against individuals because licensees have already taken appropriate discipl.inary action.
Now that the NRC has reemphasized-the need for licensees to be aware'of the
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need to ensure that logging activities are' being properly conducted, logging violations _in the future may result not only in enforcement action against licensees, but also' direct enforcement action against the individual. involved in~ deliberate record falsification, whether the. individual is licensed or not and whether the' individual is a licensee' employee = or a contractor.
LESSONS LEARNED Various licensees have reexamined their programs to-ensure that management expectations regarding the conduct of rounds and log' keeping are clearly articulated to plant personnel and are being implemented in-the plant. 'Some of-the actions taken include. steps to (1) ensure that -individuals-clearly understand the meaning of.their signatures on log sh'eets:and' procedures, (2) ensure that plant personnel clearly. understand who is responsible and..
authorized to perform rounds, (3) ensure that individuals understand the.
i purpose of'the rounds and are properly trained on how the rounds are to be conducted, (4) perform periodic audits of field practices, and (5) verify that.
round and log requirements can reasonably. be met in the specified time.. Given-the turnove. of auxiliary operators and others who perform these rounds, these-topics may be appropriate for consideration in licensee routine training;and auditing programs.
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Attachment j
NOT ISSUED Generic Letter 93-XX, 1993 This generic letter requires no specific action or written response.
If you have any questions about the information in this generic letter, please contact the technical contact listed below or the appropriate Office of-Nuclear Reactor Regulation project manager.
i James G. Partlow L Associate Director for Projects Office of Nuclear Reactor Regulation
Enclosure:
List of Recently Issued Generic Letters Technical contact: William M. Troskoski, OE (301) 504-3281
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