Information Notice 1992-30, Falsification of Plant Records: Difference between revisions

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==Description of Circumstances==
==Description of Circumstances==
On March 1, 1992, the shift superintendent for the Public Service Company ofNew Hampshire's Seabrook Nuclear Station was conducting a surveillance, inaccordance with a personnel performance monitoring program, to verify thatoperations department personnel were properly performing their assigned duties.On this occasion, the shift superintendent reviewed the security department'scomputerized card key entry records against locations in which an auxiliaryoperator's (AO's) log entries had indicated that he had performed inspections.The shift superintendent found that the AO had logged "SAT" (satisfactory) forsome plant areas, indicating that he had performed the required periodicinspections, although the computerized security data indicated that some ofthese areas had not been entered.The shift superintendent's findings prompted the licensee to establish anindependent review team (IRT) to performi a comprehensive analysis of theroot cause(s) and the generic implications of this occurrence. The IRTinterviewed the individuals involved and the management and supervisorystaff and examined a wide range of historical records created or used sincethe issuance of the full power operating license, including security logs,92041701135/!
On March 1, 1992, the shift superintendent for the Public Service Company ofNew Hampshire's Seabrook Nuclear Station was conducting a surveillance, inaccordance with a personnel performance monitoring program, to verify thatoperations department personnel were properly performing their assigned duties.On this occasion, the shift superintendent reviewed the security department'scomputerized card key entry records against locations in which an auxiliaryoperator's (AO's) log entries had indicated that he had performed inspections.The shift superintendent found that the AO had logged "SAT" (satisfactory) forsome plant areas, indicating that he had performed the required periodicinspections, although the computerized security data indicated that some ofthese areas had not been entered.The shift superintendent's findings prompted the licensee to establish anindependent review team (IRT) to performi a comprehensive analysis of theroot cause(s) and the generic implications of this occurrence. The IRTinterviewed the individuals involved and the management and supervisorystaff and examined a wide range of historical records created or used sincethe issuance of the full power operating license, including security logs,92041701135/!  
IN 92-30April 23, 1992 operations logs and procedures, administrative program manuals, and traininglesson plans. Discrepancies were found by the IRT, and some involved violationsof technical specifications and some involved licensed operators.In response to the findings at Seabrook, random checks were conducted at theHaddam Neck Plant and Millstone Nuclear Power Station. To date, no dis-crepancies have been identified at Haddam Neck. At Millstone, the NortheastNuclear Energy Company (the licensee) determined that several non-licensedplant equipment operators (PEOs) had not completed certain inspection roundsas represented in their logs. The Millstone licensee has since expanded itsevaluation to verifying the accuracy of log entries recorded by all PEOs.The management at Millstone informed plant personnel of its findings andexpectations for recording log entries. The Millstone licensee alsoestablished an IRT (with a representative from the Seabrook IRT acting inan advisory status) to investigate its findings, to determine the extent ofthe problem, and to determine corrective actions that should be taken.At Oyster Creek, several non-licensed PEOs were involved with falsification ofrecords associated with routine plant log taking rounds. None of the recordsinvolved were related to technical specifications. The discovery of thefalsified log entries was from an ongoing random investigation comparingsecurity 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 VogtleElectric Generating Plant, Unit 1, performed a surveillance on a portion ofthe reactor trip system instrumentation. The Georgia Power Company (thelicensee) informed the NRC that the technicians failed to properly follow thesurveillance procedure and subsequently created the data that was entered onthe calibration data sheet.NRC evaluation of each of these matters is continuing.Discussion of Safety SignificanceMaintenance of shift records, log sheets, and surveillance records, attentionto detail, and work ethics are important factors which contribute to the safeoperation of nuclear power plants. Complacency, by mechanics, technicians, orlicensed or non-licensed operators, cannot be tolerated. Similarly, manage-ment expectations and supervisory overview of rounds need to be clearlycommunicated and monitored. All personnel involved in NRC-regulated activitiesare responsible for complying with applicable NRC regulatory requirements andother Federal laws. Log keeping activities as well as surveillancesperformed by licensed or non-licensed personnel are subject to therequirements of 10 CFR 50.9(a) regarding completeness and accuracy of informatio IN 92-30April 23, 1992 In addition, the administrative section of plant technical specificationsrequires that written procedures be implemented covering the applicable proce-dures in Appendix A of Regulatory Guide 1.33, Quality Assurance ProgramRequirements (Operation). Among the safety-related activities which Appendix Astates should be covered by written procedures are surveillances and logentries.Willful violations, committed by personnel at any level of a licensee'sorganization, are of regulatory concern because the NRC must have reasonableassurance that licensed activities will be conducted in a manner that willprotect the public health and safety. Such reasonable assurance is providedin large part by the integrity and conscientiousness of each individualperforming licensed activities. Deliberate violations concerning matterswithin the scope of an individual's responsibilities, including falsificationof records, will be considered for enforcement action against the individualas well as the facility licensee. As provided in 10 CFR 50.5, "DeliberateMisconduct by Unlicensed Persons," 56 Federal Register 40684, August 15, 1991,the NRC may take direct enforcement action against unlicensed personnel whodeliberately cause a licensee to be in violation of the Commission's regulationsor who provide false information to the licensee concerning licensed activities.
IN 92-30April 23, 1992 operations logs and procedures, administrative program manuals, and traininglesson plans. Discrepancies were found by the IRT, and some involved violationsof technical specifications and some involved licensed operators.In response to the findings at Seabrook, random checks were conducted at theHaddam Neck Plant and Millstone Nuclear Power Station. To date, no dis-crepancies have been identified at Haddam Neck. At Millstone, the NortheastNuclear Energy Company (the licensee) determined that several non-licensedplant equipment operators (PEOs) had not completed certain inspection roundsas represented in their logs. The Millstone licensee has since expanded itsevaluation to verifying the accuracy of log entries recorded by all PEOs.The management at Millstone informed plant personnel of its findings andexpectations for recording log entries. The Millstone licensee alsoestablished an IRT (with a representative from the Seabrook IRT acting inan advisory status) to investigate its findings, to determine the extent ofthe problem, and to determine corrective actions that should be taken.At Oyster Creek, several non-licensed PEOs were involved with falsification ofrecords associated with routine plant log taking rounds. None of the recordsinvolved were related to technical specifications. The discovery of thefalsified log entries was from an ongoing random investigation comparingsecurity 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 VogtleElectric Generating Plant, Unit 1, performed a surveillance on a portion ofthe reactor trip system instrumentation. The Georgia Power Company (thelicensee) informed the NRC that the technicians failed to properly follow thesurveillance procedure and subsequently created the data that was entered onthe calibration data sheet.NRC evaluation of each of these matters is continuing.Discussion of Safety SignificanceMaintenance of shift records, log sheets, and surveillance records, attentionto detail, and work ethics are important factors which contribute to the safeoperation of nuclear power plants. Complacency, by mechanics, technicians, orlicensed or non-licensed operators, cannot be tolerated. Similarly, manage-ment expectations and supervisory overview of rounds need to be clearlycommunicated and monitored. All personnel involved in NRC-regulated activitiesare responsible for complying with applicable NRC regulatory requirements andother Federal laws. Log keeping activities as well as surveillancesperformed by licensed or non-licensed personnel are subject to therequirements of 10 CFR 50.9(a) regarding completeness and accuracy of information.
 
IN 92-30April 23, 1992 In addition, the administrative section of plant technical specificationsrequires that written procedures be implemented covering the applicable proce-dures in Appendix A of Regulatory Guide 1.33, Quality Assurance ProgramRequirements (Operation). Among the safety-related activities which Appendix Astates should be covered by written procedures are surveillances and logentries.Willful violations, committed by personnel at any level of a licensee'sorganization, are of regulatory concern because the NRC must have reasonableassurance that licensed activities will be conducted in a manner that willprotect the public health and safety. Such reasonable assurance is providedin large part by the integrity and conscientiousness of each individualperforming licensed activities. Deliberate violations concerning matterswithin the scope of an individual's responsibilities, including falsificationof records, will be considered for enforcement action against the individualas well as the facility licensee. As provided in 10 CFR 50.5, "DeliberateMisconduct by Unlicensed Persons," 56 Federal Register 40684, August 15, 1991,the NRC may take direct enforcement action against unlicensed personnel whodeliberately cause a licensee to be in violation of the Commission's regulationsor who provide false information to the licensee concerning licensed activities.


==Addressees==
==Addressees==
Line 30: Line 32:


==Addressees==
==Addressees==
may alsowish to distribute copies of this information notice to all their employees.This information notice requires no specific action or written response. Ifyou have any questions about the information in this notice, please contactone of the technical contact(s) listed below or the appropriate Office ofNuclear Reactor Regulation (NRR) project manager.Charles E. Rossi, DirectorDivision of Operational Events AssessmentOffice of Nuclear Reactor RegulationTechnical contact(s): David C. Fischer, NRR(301) 504-1154Eugene M. Kelly, RI(215) 337-5183James A. Prell, RI(215) 337-5108
may alsowish to distribute copies of this information notice to all their employees.This information notice requires no specific action or written response. Ifyou have any questions about the information in this notice, please contactone of the technical contact(s) listed below or the appropriate Office ofNuclear Reactor Regulation (NRR) project manager.Charles E. Rossi, DirectorDivision of Operational Events AssessmentOffice of Nuclear Reactor RegulationTechnical contact(s): David C. Fischer, NRR(301) 504-1154Eugene M. Kelly, RI(215) 337-5183James A. Prell, RI(215) 337-5108Attachment: List of gecently I sued NRC Information Notices
 
mz,-0190rn Z0 FQ)m0>0CDCeI DmCC,0cn"3an02*oiG)C)z0=i CJ > 0O = a U)0 nU)G) m'ii >~s rsAttachmentIN 92-30April 23, 1992Page I of 1IIIIILIST OF RECENTLY ISSUEDNRC INFORMATION NOTICESInformation Date ofNotice No. Subject Issuance Issued to92-21, Spent Fuel Pool Re- 04/22/92 All holders of OLs or CPsSupp. 1 activity Calculations for-nuclear power reactors.92-29 Potential Breaker Mis- 04/17/92 All holders of OLs or CPscoordination Caused by for nuclear power reactors.Instantaneous TripCircuitry92-28 Inadequate Fire Suppres- 04/08/92 All holders of OLs or CPssion System Testing for nuclear power reactors.92-27 Thermally Induced Acceler- 04/03/92 All holders of OLs or CPsated Aging and Failure of for nuclear power reactors.ITE/GOULD A.C. Relays Usedin Safety-Related Applic-ations92-26 Pressure Locking of Motor- 04/02/92 All holders of OLs or CPsOperated Flexible Wedge for nuclear power reactors.Gate Valves92-25 Potential Weakness in 03/31/92 All holders of OLs or CPsLicensee Procedures for A for nuclear power reactorLoss of the RefuelingCavity Water92-24 Distributor Modification to 03/30/92 All holders of OLs or CPsCertain Commercial-Grade for nuclear power reactors.Agastat Electrical Relays92-23 Results of Validation Test- 03/27/92 All holders of OLs or CPsing of Motor-Operated Valve for nuclear power reactorsDiagnostic Equipment and all vendors of motor-operated valve (MOV) diag-nostic equipment.OL -Operating LicenseCP


===Attachment:===
* Construction Permit
List of gecently I sued NRC Information Notices mz,-0190rn Z0 FQ)m0>0CDCeI DmCC,0cn"3an02*oiG)C)z0=i CJ > 0O = a U)0 nU)G) m'ii >~s rsAttachmentIN 92-30April 23, 1992Page I of 1IIIIILIST OF RECENTLY ISSUEDNRC INFORMATION NOTICESInformation Date ofNotice No. Subject Issuance Issued to92-21, Spent Fuel Pool Re- 04/22/92 All holders of OLs or CPsSupp. 1 activity Calculations for-nuclear power reactors.92-29 Potential Breaker Mis- 04/17/92 All holders of OLs or CPscoordination Caused by for nuclear power reactors.Instantaneous TripCircuitry92-28 Inadequate Fire Suppres- 04/08/92 All holders of OLs or CPssion System Testing for nuclear power reactors.92-27 Thermally Induced Acceler- 04/03/92 All holders of OLs or CPsated Aging and Failure of for nuclear power reactors.ITE/GOULD A.C. Relays Usedin Safety-Related Applic-ations92-26 Pressure Locking of Motor- 04/02/92 All holders of OLs or CPsOperated Flexible Wedge for nuclear power reactors.Gate Valves92-25 Potential Weakness in 03/31/92 All holders of OLs or CPsLicensee Procedures for A for nuclear power reactorLoss of the RefuelingCavity Water92-24 Distributor Modification to 03/30/92 All holders of OLs or CPsCertain Commercial-Grade for nuclear power reactors.Agastat Electrical Relays92-23 Results of Validation Test- 03/27/92 All holders of OLs or CPsing of Motor-Operated Valve for nuclear power reactorsDiagnostic Equipment and all vendors of motor-operated valve (MOV) diag-nostic equipment.OL -Operating LicenseCP


* Construction Permit IN 92-30April 23, 1992 In addition, the administrative section of plant technical specificationsrequires that written procedures be implemented covering the applicable proce-dures in Appendix A of Regulatory Guide 1.33, Quality Assurance ProgramRequirements (Operation). Among the safety-related activities which Appendix Astates should be covered by written procedures are surveillances and logentries.Willful violations, committed by personnel at any level of a licensee'sorganization, are of regulatory concern because the NRC must have reasonableassurance that licensed activities will be conducted in a manner that willprotect the public health and safety. Such reasonable assurance is providedin large part by the integrity and conscientiousness of each individualperforming licensed activities. Deliberate violations concerning matterswithin the scope of an individual's responsibilities, including falsificationof records, will be considered for enforcement action against the individualas well as the facility licensee. As provided in 10 CFR 50.5, "DeliberateMisconduct by Unlicensed Persons," 56 Federal Register 40684, August 15, 1991,the NRC may take direct enforcement action against unlicensed personnel whodeliberately cause a licensee to be in violation of the Commission's regulationsor who provide false information to the licensee concerning licensed activities.
IN 92-30April 23, 1992 In addition, the administrative section of plant technical specificationsrequires that written procedures be implemented covering the applicable proce-dures in Appendix A of Regulatory Guide 1.33, Quality Assurance ProgramRequirements (Operation). Among the safety-related activities which Appendix Astates should be covered by written procedures are surveillances and logentries.Willful violations, committed by personnel at any level of a licensee'sorganization, are of regulatory concern because the NRC must have reasonableassurance that licensed activities will be conducted in a manner that willprotect the public health and safety. Such reasonable assurance is providedin large part by the integrity and conscientiousness of each individualperforming licensed activities. Deliberate violations concerning matterswithin the scope of an individual's responsibilities, including falsificationof records, will be considered for enforcement action against the individualas well as the facility licensee. As provided in 10 CFR 50.5, "DeliberateMisconduct by Unlicensed Persons," 56 Federal Register 40684, August 15, 1991,the NRC may take direct enforcement action against unlicensed personnel whodeliberately cause a licensee to be in violation of the Commission's regulationsor who provide false information to the licensee concerning licensed activities.


==Addressees==
==Addressees==
Line 41: Line 44:


==Addressees==
==Addressees==
may alsowish to distribute copies of this information notice to all their employees.This information notice requires no specific action or written response. Ifyou have any questions about the information in this notice, please contactone of the technical contact(s) listed below or the appropriate Office ofNuclear Reactor Regulation (NRR) project manager.Charles E. Rossi, DirectorDivision of Operational Events AssessmentOffice of Nuclear Reactor RegulationTechnical contact(s): David C. Fischer, NRR(301) 504-1154Eugene M. Kelly, RI(215) 337-5183James A. Prell, RI(215) 337-5108
may alsowish to distribute copies of this information notice to all their employees.This information notice requires no specific action or written response. Ifyou have any questions about the information in this notice, please contactone of the technical contact(s) listed below or the appropriate Office ofNuclear Reactor Regulation (NRR) project manager.Charles E. Rossi, DirectorDivision of Operational Events AssessmentOffice of Nuclear Reactor RegulationTechnical contact(s): David C. Fischer, NRR(301) 504-1154Eugene M. Kelly, RI(215) 337-5183James A. Prell, RI(215) 337-5108Attachment: List of Recently Issued NRC Information NoticesDocument Name: IN/GUNDECK LOGCONCURRENCES --- SEE NEXT PAGE
 
===Attachment:===
List of Recently Issued NRC Information NoticesDocument Name: IN/GUNDECK LOGCONCURRENCES --- SEE NEXT PAGE


*SEE PREVIOUS CONCURRENCEOEAB:DOEA:NRRDCFischer*04/07/92ADM:RPBJMain*04/08/92C:OEAB:DOEA:NRRAEChaffee*04/07/92C:LOLB:DLPQ:NRRRMGallo*04/08/92C:LHFB:DLPQ:NRRJSWenmiel*04/09/92RILBettenhausen*04/14/92D:DRP:RIILAReyes*04/15/92D: OEJLieberman*04/15/92C:OGCB:DOEA:NRRCHBerlinger*04/15/92D:D :CE04/ 9v
*SEE PREVIOUS CONCURRENCEOEAB:DOEA:NRRDCFischer*04/07/92ADM:RPBJMain*04/08/92C:OEAB:DOEA:NRRAEChaffee*04/07/92C:LOLB:DLPQ:NRRRMGallo*04/08/92C:LHFB:DLPQ:NRRJSWenmiel*04/09/92RILBettenhausen*04/14/92D:DRP:RIILAReyes*04/15/92D: OEJLieberman*04/15/92C:OGCB:DOEA:NRRCHBerlinger*04/15/92D:D :CE04/ 9v


*SEE PREVIOUS CONCURRENCEOEAB:DOEA:NRRDCFischer*04/07/92C:LHFB:DLPQ:NRRJSWermiel*04/09/92C:OGCCHBerjinger04/15 /92ADM:RPBJMa i n*04/08/92RI ter st'LBettenhausen04/14/92C:OEAB:DOEA:NRR C:LOLB:DLPQ:NRRAEChaffee* RMGallo*04/07/92 04/08/92D:DRP:RII ';*" M. I.LAReyes i rman04/15/92 04 /92D:DOEA:NRRCERossi ,304/ /92- IN 92-XXApril xx, 1992 This information notice requires no specific action or Written response. Ifyou have any questions about the information in this n ptice, please contactone of the technical contact(s) listed below or the propriate Office ofNuclear Reactor Regulation (NRR) project manager.Charles E. ossi, DirectorDivision f Operational Events AssessmentOffice o Nuclear Reactor RegulationTechnical contact(s): Davi C. Fischer, RR(301) 4-1154Eugene M. 1 , RI(215) 337-51
*SEE PREVIOUS CONCURRENCEOEAB:DOEA:NRRDCFischer*04/07/92C:LHFB:DLPQ:NRRJSWermiel*04/09/92C:OGCCHBerjinger04/15 /92ADM:RPBJMa i n*04/08/92RI ter st'LBettenhausen04/14/92C:OEAB:DOEA:NRR C:LOLB:DLPQ:NRRAEChaffee* RMGallo*04/07/92 04/08/92D:DRP:RII ';*" M. I.LAReyes i rman04/15/92 04 /92D:DOEA:NRRCERossi ,304/ /92- IN 92-XXApril xx, 1992 This information notice requires no specific action or Written response. Ifyou have any questions about the information in this n ptice, please contactone of the technical contact(s) listed below or the propriate Office ofNuclear Reactor Regulation (NRR) project manager.Charles E. ossi, DirectorDivision f Operational Events AssessmentOffice o Nuclear Reactor RegulationTechnical contact(s): Davi C. Fischer, RR(301) 4-1154Eugene M. 1 , RI(215) 337-51Attachment: List of Recently Issue NR Information NoticesDocument Name: IN/GUNDECK OG*SEE PREVIOUS CONCURRENCY p i\OEAB:DOEA:NRR ADM:RPB X C:OEAB:DOEA:NRR C:LOLB:DLPQ:NRRDCFischer* JMain AEChaffee* MGallo04/07/92) ¢p 04/.3/92 04/07/92 0 \ /92 CACILHFB:DLPQ:NRR DRP:RI C:OGCB:DOEA:NRR D:D A:NRRJSWermiel EMKell CHBerlinger CERos04/ '/92 04/ / 2 04/ /92 04/ /92 Document Name:OEAB:DOEA:NRRDCFischer04/7 /92C:LHFB:DLPQ:NRRJSWermiel04/ /92IN/GUNDECK LOGNRRC:LOLB:DLPQ:NRRRMGallo04/ /9204/ /':DOEA:NRR.Rossi4/ /9204/  
 
IN 92-XXApril xx, 1992 This information notice requires no specific action or written response. Ifyou have any questions about the information in this notice, please contact oneof the technical contact(s) listed below or th appropriate Office of NuclearReactor Regulation (NRR) project manager.Charl E. Rossi, DirectorDivis on of Operational Events AssessmentOffi e of Nuclear Reactor RegulationTechnical contact(s): D id C. Fisch , NRR(301 504-1154Eugene Kel y, RI(215) 337 1 3Attachment: List of Recently Iss e RC Information NoticesDocument Name: IN/GUNDECK LOGOEAB:DOEA:NRR ADM:RPB C:OEAB:DO :NRR C:LOLB:DLPQ:NRRDCFischer JMain Q AEChaffee RMGallo04/ /92 04/8 /9'2 04/ /92 04/ /92C:LHFB:DLPQ:NRR C:OGCB:DOE :NRR D/DOEA:NRRJSWermiel CBerlingej CERossi04/ /92 04/ /92 / 04/ /92I
===Attachment:===
List of Recently Issue NR Information NoticesDocument Name: IN/GUNDECK OG*SEE PREVIOUS CONCURRENCY p i\OEAB:DOEA:NRR ADM:RPB X C:OEAB:DOEA:NRR C:LOLB:DLPQ:NRRDCFischer* JMain AEChaffee* MGallo04/07/92) ¢p 04/.3/92 04/07/92 0 \ /92 CACILHFB:DLPQ:NRR DRP:RI C:OGCB:DOEA:NRR D:D A:NRRJSWermiel EMKell CHBerlinger CERos04/ '/92 04/ / 2 04/ /92 04/ /92 Document Name:OEAB:DOEA:NRRDCFischer04/7 /92C:LHFB:DLPQ:NRRJSWermiel04/ /92IN/GUNDECK LOGNRRC:LOLB:DLPQ:NRRRMGallo04/ /9204/ /':DOEA:NRR.Rossi4/ /9204/
IN 92-XXApril xx, 1992 This information notice requires no specific action or written response. Ifyou have any questions about the information in this notice, please contact oneof the technical contact(s) listed below or th appropriate Office of NuclearReactor Regulation (NRR) project manager.Charl E. Rossi, DirectorDivis on of Operational Events AssessmentOffi e of Nuclear Reactor RegulationTechnical contact(s): D id C. Fisch , NRR(301 504-1154Eugene Kel y, RI(215) 337 1 3


===Attachment:===
}}
List of Recently Iss e RC Information NoticesDocument Name: IN/GUNDECK LOGOEAB:DOEA:NRR ADM:RPB C:OEAB:DO :NRR C:LOLB:DLPQ:NRRDCFischer JMain Q AEChaffee RMGallo04/ /92 04/8 /9'2 04/ /92 04/ /92C:LHFB:DLPQ:NRR C:OGCB:DOE :NRR D/DOEA:NRRJSWermiel CBerlingej CERossi04/ /92 04/ /92 / 04/ /92I}}


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Revision as of 18:49, 6 April 2018

Falsification of Plant Records
ML031200393
Person / Time
Site: Beaver Valley, Millstone, Hatch, Monticello, Calvert Cliffs, Dresden, Davis Besse, Peach Bottom, Browns Ferry, Salem, Oconee, Mcguire, Nine Mile Point, Palisades, Palo Verde, Perry, Indian Point, Fermi, Kewaunee, Catawba, Harris, Wolf Creek, Saint Lucie, Point Beach, Oyster Creek, Watts Bar, Hope Creek, Grand Gulf, Cooper, Sequoyah, Byron, Pilgrim, Arkansas Nuclear, Three Mile Island, Braidwood, Susquehanna, Summer, Prairie Island, Columbia, Seabrook, Brunswick, Surry, Limerick, North Anna, Turkey Point, River Bend, Vermont Yankee, Crystal River, Haddam Neck, Ginna, Diablo Canyon, Callaway, Vogtle, Waterford, Duane Arnold, Farley, Robinson, Clinton, South Texas, San Onofre, Cook, Comanche Peak, Yankee Rowe, Maine Yankee, Quad Cities, Humboldt Bay, La Crosse, Big Rock Point, Rancho Seco, Zion, Midland, Bellefonte, Fort Calhoun, FitzPatrick, McGuire, LaSalle, Fort Saint Vrain, Shoreham, Satsop, Trojan, Atlantic Nuclear Power Plant  Entergy icon.png
Issue date: 04/23/1992
From: Rossi C E
Office of Nuclear Reactor Regulation
To:
References
IN-92-030, NUDOCS 9204170113
Download: ML031200393 (10)
v • d • e


I IUNITED STATESNUCLEAR REGULATORY COMMISSIONOFFICE OF NUCLEAR REACTOR REGULATIONWASHINGTON, D.C. 20555April 23, 1992NRC INFORMATION NOTICE 92-30: FALSIFICATION OF PLANT RECORDS

Addressees

All holders of operating licenses or construction permits for nuclear powerreactors and all licensed operators and senior operators.

Purpose

The U.S. Nuclear Regulatory Commission (NRC) is issuing this informationnotice to alert addressees to the NRC's concern that plant mechanics,technicians, and operators may have falsified plant logs at several nuclearpower plants. The NRC is reminding plant mechanics, technicians, and operators(both licensed and non-licensed) of the penalties that could result fromintentionally violating Federal regulatory requirements and criminal statutes.The NRC is also reminding addressees that all personnel are subject to therequirements of 10 CFR 50.9(a) which states that information required bystatute or by the Commission's regulations be complete and accurate in allmaterial aspects. It is expected that recipients will review the informationfor applicability to their facilities and consider actions, as appropriate, toavoid similar problems. However, suggestions contained in this informationnotice are not NRC requirements; therefore, no specific action or writtenresponse is required.

Description of Circumstances

On March 1, 1992, the shift superintendent for the Public Service Company ofNew Hampshire's Seabrook Nuclear Station was conducting a surveillance, inaccordance with a personnel performance monitoring program, to verify thatoperations department personnel were properly performing their assigned duties.On this occasion, the shift superintendent reviewed the security department'scomputerized card key entry records against locations in which an auxiliaryoperator's (AO's) log entries had indicated that he had performed inspections.The shift superintendent found that the AO had logged "SAT" (satisfactory) forsome plant areas, indicating that he had performed the required periodicinspections, although the computerized security data indicated that some ofthese areas had not been entered.The shift superintendent's findings prompted the licensee to establish anindependent review team (IRT) to performi a comprehensive analysis of theroot cause(s) and the generic implications of this occurrence. The IRTinterviewed the individuals involved and the management and supervisorystaff and examined a wide range of historical records created or used sincethe issuance of the full power operating license, including security logs,92041701135/!

IN 92-30April 23, 1992 operations logs and procedures, administrative program manuals, and traininglesson plans. Discrepancies were found by the IRT, and some involved violationsof technical specifications and some involved licensed operators.In response to the findings at Seabrook, random checks were conducted at theHaddam Neck Plant and Millstone Nuclear Power Station. To date, no dis-crepancies have been identified at Haddam Neck. At Millstone, the NortheastNuclear Energy Company (the licensee) determined that several non-licensedplant equipment operators (PEOs) had not completed certain inspection roundsas represented in their logs. The Millstone licensee has since expanded itsevaluation to verifying the accuracy of log entries recorded by all PEOs.The management at Millstone informed plant personnel of its findings andexpectations for recording log entries. The Millstone licensee alsoestablished an IRT (with a representative from the Seabrook IRT acting inan advisory status) to investigate its findings, to determine the extent ofthe problem, and to determine corrective actions that should be taken.At Oyster Creek, several non-licensed PEOs were involved with falsification ofrecords associated with routine plant log taking rounds. None of the recordsinvolved were related to technical specifications. The discovery of thefalsified log entries was from an ongoing random investigation comparingsecurity 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 VogtleElectric Generating Plant, Unit 1, performed a surveillance on a portion ofthe reactor trip system instrumentation. The Georgia Power Company (thelicensee) informed the NRC that the technicians failed to properly follow thesurveillance procedure and subsequently created the data that was entered onthe calibration data sheet.NRC evaluation of each of these matters is continuing.Discussion of Safety SignificanceMaintenance of shift records, log sheets, and surveillance records, attentionto detail, and work ethics are important factors which contribute to the safeoperation of nuclear power plants. Complacency, by mechanics, technicians, orlicensed or non-licensed operators, cannot be tolerated. Similarly, manage-ment expectations and supervisory overview of rounds need to be clearlycommunicated and monitored. All personnel involved in NRC-regulated activitiesare responsible for complying with applicable NRC regulatory requirements andother Federal laws. Log keeping activities as well as surveillancesperformed by licensed or non-licensed personnel are subject to therequirements of 10 CFR 50.9(a) regarding completeness and accuracy of information.

IN 92-30April 23, 1992 In addition, the administrative section of plant technical specificationsrequires that written procedures be implemented covering the applicable proce-dures in Appendix A of Regulatory Guide 1.33, Quality Assurance ProgramRequirements (Operation). Among the safety-related activities which Appendix Astates should be covered by written procedures are surveillances and logentries.Willful violations, committed by personnel at any level of a licensee'sorganization, are of regulatory concern because the NRC must have reasonableassurance that licensed activities will be conducted in a manner that willprotect the public health and safety. Such reasonable assurance is providedin large part by the integrity and conscientiousness of each individualperforming licensed activities. Deliberate violations concerning matterswithin the scope of an individual's responsibilities, including falsificationof records, will be considered for enforcement action against the individualas well as the facility licensee. As provided in 10 CFR 50.5, "DeliberateMisconduct by Unlicensed Persons," 56 Federal Register 40684, August 15, 1991,the NRC may take direct enforcement action against unlicensed personnel whodeliberately cause a licensee to be in violation of the Commission's regulationsor who provide false information to the licensee concerning licensed activities.

Addressees

may wish to take actions as appropriate to ensure that plantpersonnel are properly performing their assigned duties.

Addressees

may alsowish to distribute copies of this information notice to all their employees.This information notice requires no specific action or written response. Ifyou have any questions about the information in this notice, please contactone of the technical contact(s) listed below or the appropriate Office ofNuclear Reactor Regulation (NRR) project manager.Charles E. Rossi, DirectorDivision of Operational Events AssessmentOffice of Nuclear Reactor RegulationTechnical contact(s): David C. Fischer, NRR(301) 504-1154Eugene M. Kelly, RI(215) 337-5183James A. Prell, RI(215) 337-5108Attachment: List of gecently I sued NRC Information Notices

mz,-0190rn Z0 FQ)m0>0CDCeI DmCC,0cn"3an02*oiG)C)z0=i CJ > 0O = a U)0 nU)G) m'ii >~s rsAttachmentIN 92-30April 23, 1992Page I of 1IIIIILIST OF RECENTLY ISSUEDNRC INFORMATION NOTICESInformation Date ofNotice No. Subject Issuance Issued to92-21, Spent Fuel Pool Re- 04/22/92 All holders of OLs or CPsSupp. 1 activity Calculations for-nuclear power reactors.92-29 Potential Breaker Mis- 04/17/92 All holders of OLs or CPscoordination Caused by for nuclear power reactors.Instantaneous TripCircuitry92-28 Inadequate Fire Suppres- 04/08/92 All holders of OLs or CPssion System Testing for nuclear power reactors.92-27 Thermally Induced Acceler- 04/03/92 All holders of OLs or CPsated Aging and Failure of for nuclear power reactors.ITE/GOULD A.C. Relays Usedin Safety-Related Applic-ations92-26 Pressure Locking of Motor- 04/02/92 All holders of OLs or CPsOperated Flexible Wedge for nuclear power reactors.Gate Valves92-25 Potential Weakness in 03/31/92 All holders of OLs or CPsLicensee Procedures for A for nuclear power reactorLoss of the RefuelingCavity Water92-24 Distributor Modification to 03/30/92 All holders of OLs or CPsCertain Commercial-Grade for nuclear power reactors.Agastat Electrical Relays92-23 Results of Validation Test- 03/27/92 All holders of OLs or CPsing of Motor-Operated Valve for nuclear power reactorsDiagnostic Equipment and all vendors of motor-operated valve (MOV) diag-nostic equipment.OL -Operating LicenseCP

  • Construction Permit

IN 92-30April 23, 1992 In addition, the administrative section of plant technical specificationsrequires that written procedures be implemented covering the applicable proce-dures in Appendix A of Regulatory Guide 1.33, Quality Assurance ProgramRequirements (Operation). Among the safety-related activities which Appendix Astates should be covered by written procedures are surveillances and logentries.Willful violations, committed by personnel at any level of a licensee'sorganization, are of regulatory concern because the NRC must have reasonableassurance that licensed activities will be conducted in a manner that willprotect the public health and safety. Such reasonable assurance is providedin large part by the integrity and conscientiousness of each individualperforming licensed activities. Deliberate violations concerning matterswithin the scope of an individual's responsibilities, including falsificationof records, will be considered for enforcement action against the individualas well as the facility licensee. As provided in 10 CFR 50.5, "DeliberateMisconduct by Unlicensed Persons," 56 Federal Register 40684, August 15, 1991,the NRC may take direct enforcement action against unlicensed personnel whodeliberately cause a licensee to be in violation of the Commission's regulationsor who provide false information to the licensee concerning licensed activities.

Addressees

may wish to take actions as appropriate to ensure that plantpersonnel are properly performing their assigned duties.

Addressees

may alsowish to distribute copies of this information notice to all their employees.This information notice requires no specific action or written response. Ifyou have any questions about the information in this notice, please contactone of the technical contact(s) listed below or the appropriate Office ofNuclear Reactor Regulation (NRR) project manager.Charles E. Rossi, DirectorDivision of Operational Events AssessmentOffice of Nuclear Reactor RegulationTechnical contact(s): David C. Fischer, NRR(301) 504-1154Eugene M. Kelly, RI(215) 337-5183James A. Prell, RI(215) 337-5108Attachment: List of Recently Issued NRC Information NoticesDocument Name: IN/GUNDECK LOGCONCURRENCES --- SEE NEXT PAGE

  • SEE PREVIOUS CONCURRENCEOEAB:DOEA:NRRDCFischer*04/07/92ADM:RPBJMain*04/08/92C:OEAB:DOEA:NRRAEChaffee*04/07/92C:LOLB:DLPQ:NRRRMGallo*04/08/92C:LHFB:DLPQ:NRRJSWenmiel*04/09/92RILBettenhausen*04/14/92D:DRP:RIILAReyes*04/15/92D: OEJLieberman*04/15/92C:OGCB:DOEA:NRRCHBerlinger*04/15/92D:D :CE04/ 9v
  • SEE PREVIOUS CONCURRENCEOEAB:DOEA:NRRDCFischer*04/07/92C:LHFB:DLPQ:NRRJSWermiel*04/09/92C:OGCCHBerjinger04/15 /92ADM:RPBJMa i n*04/08/92RI ter st'LBettenhausen04/14/92C:OEAB:DOEA:NRR C:LOLB:DLPQ:NRRAEChaffee* RMGallo*04/07/92 04/08/92D:DRP:RII ';*" M. I.LAReyes i rman04/15/92 04 /92D:DOEA:NRRCERossi ,304/ /92- IN 92-XXApril xx, 1992 This information notice requires no specific action or Written response. Ifyou have any questions about the information in this n ptice, please contactone of the technical contact(s) listed below or the propriate Office ofNuclear Reactor Regulation (NRR) project manager.Charles E. ossi, DirectorDivision f Operational Events AssessmentOffice o Nuclear Reactor RegulationTechnical contact(s): Davi C. Fischer, RR(301) 4-1154Eugene M. 1 , RI(215) 337-51Attachment: List of Recently Issue NR Information NoticesDocument Name: IN/GUNDECK OG*SEE PREVIOUS CONCURRENCY p i\OEAB:DOEA:NRR ADM:RPB X C:OEAB:DOEA:NRR C:LOLB:DLPQ:NRRDCFischer* JMain AEChaffee* MGallo04/07/92) ¢p 04/.3/92 04/07/92 0 \ /92 CACILHFB:DLPQ:NRR DRP:RI C:OGCB:DOEA:NRR D:D A:NRRJSWermiel EMKell CHBerlinger CERos04/ '/92 04/ / 2 04/ /92 04/ /92 Document Name:OEAB:DOEA:NRRDCFischer04/7 /92C:LHFB:DLPQ:NRRJSWermiel04/ /92IN/GUNDECK LOGNRRC:LOLB:DLPQ:NRRRMGallo04/ /9204/ /':DOEA:NRR.Rossi4/ /9204/

IN 92-XXApril xx, 1992 This information notice requires no specific action or written response. Ifyou have any questions about the information in this notice, please contact oneof the technical contact(s) listed below or th appropriate Office of NuclearReactor Regulation (NRR) project manager.Charl E. Rossi, DirectorDivis on of Operational Events AssessmentOffi e of Nuclear Reactor RegulationTechnical contact(s): D id C. Fisch , NRR(301 504-1154Eugene Kel y, RI(215) 337 1 3Attachment: List of Recently Iss e RC Information NoticesDocument Name: IN/GUNDECK LOGOEAB:DOEA:NRR ADM:RPB C:OEAB:DO :NRR C:LOLB:DLPQ:NRRDCFischer JMain Q AEChaffee RMGallo04/ /92 04/8 /9'2 04/ /92 04/ /92C:LHFB:DLPQ:NRR C:OGCB:DOE :NRR D/DOEA:NRRJSWermiel CBerlingej CERossi04/ /92 04/ /92 / 04/ /92I


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