Information Notice 1996-71, Licensee Response to Indications of Tampering, Vandalism, or Malicious Mischief: Difference between revisions

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{{#Wiki_filter:UNITED STATES NUCLEAR REGULATORY
{{#Wiki_filter:UNITED STATES


COMMISSION
NUCLEAR REGULATORY COMMISSION


OFFICE OF NUCLEAR REACTOR REGULATION-
OFFICE OF NUCLEAR REACTOR REGULATION-
WASHINGTON, DC 20555-0001 December 27, 1996 NRC INFORMATION
                                WASHINGTON, DC 20555-0001 December 27, 1996 NRC INFORMATION NOTICE NO. 96-71: LICENSEE RESPONSE TO INDICATIONS OF


NOTICE NO. 96-71: LICENSEE RESPONSE TO INDICATIONS
TAMPERING, VANDALISM, OR MALICIOUS


OF TAMPERING, VANDALISM, OR MALICIOUS MISCHIEF
MISCHIEF


==Addressees==
==Addressees==
All holders of operating
All holders of operating licenses or construction permits for nuclear power reactors.
 
licenses or construction
 
permits for nuclear power reactors.


==Purpose==
==Purpose==
This information
This information notice is being issued to alert licensees to the benefits of planning a
 
notice is being issued to alert licensees
 
to the benefits of planning a response to indications
 
of tampering, vandalism, or malicious
 
mischief.
 
It is expected that recipients
 
will review the information
 
for applicability
 
to their facilities
 
and consider actions, as appropriate.
 
However, suggestions
 
contained
 
in this information
 
notice are not NRC requirements;
therefore, no specific action or written response is required.Description
 
of Circumstances
 
Recent events at operating
 
reactors indicate that some licensee personnel
 
may not recognize
 
the potential
 
significance
 
of early indications
 
of potential
 
tampering, vandalism, or malicious
 
mischief.
 
As a result, licensee response may be untimely and of limited scope and depth. Failure to promptly question, resolve the significance
 
and implement
 
an appropriate
 
strategy to mitigate the consequence
 
of a potential
 
tampering, vandalism, or malicious
 
mischief situation, could leave the plant in a vulnerable
 
state for a significant
 
period of time. Lack of detailed planning, procedures, and training frequently
 
plays a role in the quality of response to these events. Brief accounts of two events illustrate
 
the issue: Improperly
 
Positioned
 
Valve at Beaver Valley During the conduct of a quarterly
 
surveillance
 
on Friday, July 14, 1995, to verify the position of certain safety-related
 
locked valves; the licensee determined
 
that the service water cross-connect
 
valve at the discharge
 
of the recirculation
 
spray heat exchanger
 
was in the incorrect
 
position (shut in lieu of open), that the chain used to secure the valve in the proper position had been cut, and that the lock appeared to have been placed back on the chain in a manner that made it difficult
 
to detect the condition.
 
The licensee's
 
staff initially
 
assumed the valve had been inadvertently
 
mispositioned
 
during earlier operational
 
evolutions, but subsequent
 
interviews


and analysis were unable to confirm this assumption.
response to indications of tampering, vandalism, or malicious mischief. It is expected that


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recipients will review the information for applicability to their facilities and consider actions, as appropriate. However, suggestions contained in this information notice are not NRC


'I 11 I T2D4t ICG
requirements; therefore, no specific action or written response is required.


IN 96-71 December 27, 1996 Licensee management
==Description of Circumstances==
Recent events at operating reactors indicate that some licensee personnel may not


first learned of the event on Tuesday, July 18, 1995. Consequ-ently, licensee management
recognize the potential significance of early indications of potential tampering, vandalism, or malicious mischief. As a result, licensee response may be untimely and of limited scope


was not able to oversee the licensee evaluation
and depth. Failure to promptly question, resolve the significance and implement an


of the event until considerable
appropriate strategy to mitigate the consequence of a potential tampering, vandalism, or


time had elapsed. The licensee's
malicious mischief situation, could leave the plant in a vulnerable state for a significant


determination
period of time. Lack of detailed planning, procedures, and training frequently plays a role


that potential
in the quality of response to these events. Brief accounts of two events illustrate the


tampering could not be ruled out was not made until six days after the incorrect
issue:


valve position was identified.
===Improperly Positioned Valve at Beaver Valley===
During the conduct of a quarterly surveillance on Friday, July 14, 1995, to verify the


Thorough valve lineup checks and locked valve surveillances
position of certain safety-related locked valves; the licensee determined that the service


were not completed
water cross-connect valve at the discharge of the recirculation spray heat exchanger was


for both Beaver Valley units until after the plant staff made an emergency notification
in the incorrect position (shut in lieu of open), that the chain used to secure the valve in


system (ENS) call on Thursday evening, July 20, 1995. The similarity
the proper position had been cut, and that the lock appeared to have been placed back on


of this event to an event in the early 1 980s heightened
the chain in a manner that made it difficult to detect the condition. The licensee's staff


the concern of both licensee and NRC personnel
initially assumed the valve had been inadvertently mispositioned during earlier operational


who knew of the previous events.Misadjusted
evolutions, but subsequent interviews and analysis were unable to confirm this


Valves and Disabled Locks at St. Lucie In May 1996, St. Lucie personnel
assumption.                                                                                     2  I1
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identified
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two pressure-relief
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valves which, when tested, were found to have pressure setpoints
41 -A,-
                                                T2D4t ICG


55 percent and 9 percent above their design values.These valves also had broken wire seals. The root cause could not be determined.
IN 96-71 December 27, 1996 Licensee management first learned of the event on Tuesday, July 18, 1995. Consequ- ently, licensee management was not able to oversee the licensee evaluation of the event


Although tampering
until considerable time had elapsed. The licensee's determination that potential tampering


could not be ruled out, it was concluded
could not be ruled out was not made until six days after the incorrect valve position


that the more likely cause for the misadjusted
was identified. Thorough valve lineup checks and locked valve surveillances were not


valves was poor maintenance.
completed for both Beaver Valley units until after the plant staff made an emergency


Licensee management
notification system (ENS) call on Thursday evening, July 20, 1995. The similarity of this


decided to alert the Security force; however, site Security was not notified.
event to an event in the early 1980s heightened the concern of both licensee and NRC


The failure to follow through on alerting site Security precluded
personnel who knew of the previous events.


coordinated
Misadjusted Valves and Disabled Locks at St. Lucie


actions of Operations
In May 1996, St. Lucie personnel identified two pressure-relief valves which, when tested, were found to have pressure setpoints 55 percent and 9 percent above their design values.


and Security staffs to enhance awareness
These valves also had broken wire seals. The root cause could not be determined.


to other possible tampering
Although tampering could not be ruled out, it was concluded that the more likely cause for


events.On July 26, 1996, St. Lucie staff identified
the misadjusted valves was poor maintenance. Licensee management decided to alert the


nine padlocks and two door locks in vital areas that were intentionally
Security force; however, site Security was not notified. The failure to follow through on


damaged to inhibit opening the locks. These locks controlled
alerting site Security precluded coordinated actions of Operations and Security staffs to


personnel
enhance awareness to other possible tampering events.


access to various pieces of plant equipment.
On July 26, 1996, St. Lucie staff identified nine padlocks and two door locks in vital areas


The licensee did not identify keylock switches as needing to be checked; consequently, these switches were not checked until August 1996. Although the tampering
that were intentionally damaged to inhibit opening the locks. These locks controlled


of components
personnel access to various pieces of plant equipment. The licensee did not identify


within a vital area indicated
keylock switches as needing to be checked; consequently, these switches were not


the need to be alert to additional
checked until August 1996. Although the tampering of components within a vital area


tampering, other than alerting Security, the licensee failed to consider additional
indicated the need to be alert to additional tampering, other than alerting Security, the


measures to detect tampering.
licensee failed to consider additional measures to detect tampering. On August 14, 1996, St. Lucie staff identified three additional examples of tampering in vital areas that inhibited


On August 14, 1996, St. Lucie staff identified
the opening of locks associated with safety-related equipment.
 
three additional
 
examples of tampering
 
in vital areas that inhibited the opening of locks associated
 
with safety-related
 
equipment.


Discussion
Discussion


The following
The following factors may have contributed to these events:
 
(1)     The licensees' contingency plans required by 10 CFR 73.55(h)(1) and the
factors may have contributed
 
to these events: (1) The licensees'  
contingency
 
plans required by 10 CFR 73.55(h)(1)  
and the implementing
 
procedures
 
required by Appendix C to Part 73 did not adequately


address tampering, vandalism, and malicious
implementing procedures required by Appendix C to Part 73 did not adequately


mischief.
address tampering, vandalism, and malicious mischief. Other licensee procedures


===Other licensee procedures===
touched some aspects of these situations; however, no plan or process was used to
touched some aspects of these situations;  
however, no plan or process was used to evaluate the potential


malevolent
evaluate the potential malevolent event and determine its importance. Factors such


event and determine
as safety significance, overtness, intent, sophistication of method, and the history


its importance.
of similar incidents were not considered. Information Notice 83-27, "Operational


Factors such as safety significance, overtness, intent, sophistication
Response to Events Concerning Deliberate Acts Directed Against Plant Equipment,"
        described events in which licensees were not prepared to assess the situation and


of method, and the history of similar incidents
take necessary steps to ensure the operability of systems important to safety or


were not considered.
make decisions concerning continued operation. The information notice indicated


Information
that guidelines or procedures prepared by the licensee outlining a process of


Notice 83-27, "Operational
i


Response to Events Concerning
IN 96-71 December 27, 1996 following up on both deliberate and inadvertent acts with respect to plant operation


Deliberate
should be available.


Acts Directed Against Plant Equipment," described
(2)    The licensees' actions were limited in scope and depth, at least initially, in pursuing


events in which licensees
the events.


were not prepared to assess the situation
(3)    The licensees' Operations staff were not sensitive to abnormalities identified earlier


and take necessary
and apparently assumed no malice. Since the Operations staff may be the first to


steps to ensure the operability
encounter signs of tampering, vandalism, or malicious mischief during its tours and


of systems important
surveillance activities, sensitivity to precursors plays a key role in timely response to


to safety or make decisions
events of this nature. Therefore, licensees may wish to periodically refresh their


concerning
Operations staff's sensitivity to and awareness of the evaluation process to ensure


continued
effective response to these acts.


operation.
(4)    The licensee's Security staff was not told about these problems until well into the


The information
sequence of events at St. Lucie. Security's ability to identify the perpetrators and


notice indicated that guidelines
institute other protective measures diminishes severely as time elapses.


or procedures
Events of this nature are required by Appendix G to Part 73 of 10 CFR to be reported to


prepared by the licensee outlining
the NRC Operations Center within one hour of discovery.


a process of
This information notice requires no specific action or written response. If you have any


i IN 96-71 December 27, 1996 following
questions about the information in this notice, please contact one of the technical contacts


up on both deliberate
listed below or the appropriate Office of Nuclear Reactor Regulation project manager.


and inadvertent
Thomas T. Martin, Director


acts with respect to plant operation should be available.
Division of Reactor Program Management
 
(2) The licensees'
actions were limited in scope and depth, at least initially, in pursuing the events.(3) The licensees'
Operations
 
staff were not sensitive
 
to abnormalities
 
identified
 
earlier and apparently
 
assumed no malice. Since the Operations
 
staff may be the first to encounter
 
signs of tampering, vandalism, or malicious
 
mischief during its tours and surveillance
 
activities, sensitivity
 
to precursors
 
plays a key role in timely response to events of this nature. Therefore, licensees
 
may wish to periodically
 
refresh their Operations
 
staff's sensitivity
 
to and awareness
 
of the evaluation
 
process to ensure effective
 
response to these acts.(4) The licensee's
 
Security staff was not told about these problems until well into the sequence of events at St. Lucie. Security's
 
ability to identify the perpetrators
 
and institute
 
other protective
 
measures diminishes
 
severely as time elapses.Events of this nature are required by Appendix G to Part 73 of 10 CFR to be reported to the NRC Operations
 
Center within one hour of discovery.
 
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
 
contacts listed below or the appropriate


Office of Nuclear Reactor Regulation
Office of Nuclear Reactor Regulation


project manager.Thomas T. Martin, Director Division of Reactor Program Management
Technical contacts: Loren Bush, NRR


===Office of Nuclear Reactor Regulation===
(301) 415-2944 E-mail: llb(nrc.gov
Technical


contacts:
David Skeen, NRR
Loren Bush, NRR (301) 415-2944 E-mail: llb(nrc.gov


David Skeen, NRR (301) 415-1174 E-mail: dls@nrc.gov
(301) 415-1174 E-mail: dls@nrc.gov


Attachment:  
Attachment: List of Recently Issued NRC Information Notices
List of Recently Issued NRC Information


Notices AM -chrobL~A
AM -chrobL~A           4?f-r


4?f-r S
S


W-Attachment
W-
                                                                          Attachment


IN 96-71 December 27, 1996 LIST OF RECENTLY ISSUED NRC INFORMATION
IN 96-71 December 27, 1996 LIST OF RECENTLY ISSUED


NOTICES Information
NRC INFORMATION NOTICES


Date of Notice No. Subject Issuance Issued to 96-70 96-69 96-68 96-67 Year 2000 Effect on Computer System Software Operator Actions Affecting Reactivity
Information                                        Date of


Incorrect
Notice No.            Subject                      Issuance      Issued to


Effective
96-70          Year 2000 Effect on Computer      12/24/96      All U.S. Nuclear


Diaphragm Area Values in Vendor Manual Result in Potential
System Software                                  Regulatory Commission
 
Failure of Pneumatic
 
Diaphragm Actuators Vulnerability
 
of Emergency Diesel Generators
 
to Fuel Oil/Lubricating
 
Oil Incom-patibility
 
===Recent Misadministrations===
Caused by Incorrect
 
Cali-brations of Strontium-90
 
===Eye Applicators===
Undetected
 
===Accumulation===
of Gas in Reactor Coolant System and Inaccurate
 
Reactor Water Level Indication
 
During Shutdown 12/24/96 12/20/96 12/19/96 12/19/96 12/13/96 12/11/96 All U.S. Nuclear Regulatory
 
Commission


licensees, certificate
licensees, certificate
Line 458: Line 235:
holders, and registrants
holders, and registrants


All holders of OLs or CPs for nuclear power reactors All holders of OLs or CPs for nuclear power reactors All holders of OLs or CPs for nuclear power reactors All U.S. Nuclear Regulatory
96-69          Operator Actions Affecting        12/20/96      All holders of OLs


Commission
Reactivity                                      or CPs for nuclear


Medical Use Licensees authorized
power reactors


to use strontium-90 (Sr-90)eye applicators
96-68            Incorrect Effective Diaphragm    12/19/96      All holders of OLs


All holders of OLs or CPs for nuclear power reactors 96-66 96-65 OL = Operating
Area Values in Vendor Manual                    or CPs for nuclear


License CP = Construction
Result in Potential Failure                      power reactors


Permit
of Pneumatic Diaphragm


IN 96-71 December 27, 1996 following
Actuators


up on both deliberate
96-67            Vulnerability of Emergency        12/19/96      All holders of OLs


and inadvertent
Diesel Generators to Fuel                        or CPs for nuclear


acts with respect to plant operation should be available.
Oil/Lubricating Oil Incom-                      power reactors


t (2) The licensees'
patibility
actions were limited in scope and depth, at least initially, in pursuing the events.(3) The licensees'
Operations


staff were not sensitive
96-66          Recent Misadministrations          12/13/96      All U.S. Nuclear


to abnormalities
Caused by Incorrect Cali-                        Regulatory Commission


identified
brations of Strontium-90                          Medical Use Licensees


earlier and apparently
Eye Applicators                                  authorized to use


assumed no malice. Since the Operations
strontium-90 (Sr-90)
                                                                  eye applicators


staff may be the first to encounter
96-65          Undetected Accumulation            12/11/96      All holders of OLs


signs of tampering, vandalism, or malicious
of Gas in Reactor Coolant                        or CPs for nuclear


mischief during its tours and surveillance
System and Inaccurate                            power reactors


activities, sensitivity
Reactor Water Level


to precursors
Indication During Shutdown


plays a key role in timely response to events of this nature. Therefore, licensees
OL = Operating License


may wish to periodically
CP = Construction Permit


refresh their Operations
IN 96-71 December 27, 1996 following up on both deliberate and inadvertent acts with respect to plant operation


staff's sensitivity
should be available.                        t


to and awareness
(2)        The licensees' actions were limited in scope and depth, at least initially, in pursuing


of the evaluation
the events.


process to ensure effective
(3)        The licensees' Operations staff were not sensitive to abnormalities identified earlier


response to these acts.(4) The licensee's
and apparently assumed no malice. Since the Operations staff may be the first to


Security staff was not told about these problems until well into the sequence of events at St. Lucie. Security's
encounter signs of tampering, vandalism, or malicious mischief during its tours and


ability to identify the perpetrator(s)
surveillance activities, sensitivity to precursors plays a key role in timely response to
and institute


other protective
events of this nature. Therefore, licensees may wish to periodically refresh their


measures diminishes
Operations staff's sensitivity to and awareness of the evaluation process to ensure


severely as time elapses.Events of this nature are required by Appendix G to Part 73 of 10 CFR to be reported to the NRC Operations
effective response to these acts.


Center within one hour of discovery.
(4)        The licensee's Security staff was not told about these problems until well into the


This information
sequence of events at St. Lucie. Security's ability to identify the perpetrator(s) and


notice requires no specific action or written response.
institute other protective measures diminishes severely as time elapses.


If you have any questions
Events of this nature are required by Appendix G to Part 73 of 10 CFR to be reported to


about the information
the NRC Operations Center within one hour of discovery.


in this notice, please contact one of the technical
This information notice requires no specific action or written response. If you have any


contacts listed below or the appropriate
questions about the information in this notice, please contact one of the technical contacts


Office of Nuclear Reactor Regulation
listed below or the appropriate Office of Nuclear Reactor Regulation project manager.


project manager.original signed by D.B. Matthews Thomas T. Martin, Director Division of Reactor Program Management
original signed by D.B. Matthews


===Office of Nuclear Reactor Regulation===
Thomas T. Martin, Director
Technical


contacts:
Division of Reactor Program Management
Loren Bush, NRR David Skeen, NRR (301) 415-2944 (301) 415-1174 E-mail: llb@nrc.gov


E-mail: dls@nrc.gov
Office of Nuclear Reactor Regulation


Tech Editor has reviewed and concurred
Technical contacts: Loren Bush, NRR                    David Skeen, NRR


on 9/27/96 Attachment:  
(301) 415-2944          (301) 415-1174 E-mail: llb@nrc.gov E-mail: dls@nrc.gov
List of Recently Issued NRC Information


Notices DOCUMENT NAME: 96-71.IN To receive a copy of this document.
Tech Editor has reviewed and concurred on 9/27/96 Attachment: List of Recently Issued NRC Information Notices


hIdlcate I the box: 'C' -Copy w/o attachmentlenclosure
DOCUMENT NAME: 96-71.IN


'E' -Copy wfattachmentlenclosure
To receive a copy of this document. hIdlcate I the box: 'C' - Copy w/o


'N' -No copy OFFICE TECH CONTS I C/PECB:DRPM
attachmentlenclosure 'E' - Copy wfattachmentlenclosure 'N' - No copy


I D/DRP I I NAME LBush* AChaffee*
OFFICE        TECH CONTS                I     C/PECB:DRPM I        D/DRP   I     I
TMart DSkeen* L ' I DATE 10/31/96 11/01/96 12 OFFICIAL RECORD COPY


* IN 96-December , 1996 following
NAME            LBush*                           AChaffee*            TMart


up on both deliberate
DSkeen*                                                      L    '    I


and inadvertent
DATE            10/31/96                          11/01/96              12 OFFICIAL RECORD COPY


acts with respect to plant operation should be available.
*                                                                                IN 96- December    , 1996 following up on both deliberate and inadvertent acts with respect to plant operation


(2) The licensees'
should be available.
actions were limited in scope and depth, at least initially, in pursuing the events.(3) The licensees'
Operations


staff were not sensitive
(2)        The licensees' actions were limited in scope and depth, at least initially, in pursuing


to abnormalities
the events.


identified
(3)        The licensees' Operations staff were not sensitive to abnormalities identified earlier


earlier and apparently
and apparently assumed no malice. Since the Operations staff may be the first to


assumed no malice. Since the Operations
encounter signs of tampering, vandalism, or malicious mischief during its tours and


staff may be the first to encounter
surveillance activities, sensitivity to precursors plays a key role in timely response to


signs of tampering, vandalism, or malicious
events of this nature. Therefore, licensees may wish to periodically refresh their


mischief during its tours and surveillance
Operations staff's sensitivity to and awareness of the evaluation process to ensure


activities, sensitivity
effective response to these acts.


to precursors
(4)        The licensee's Security staff was not told about these problems until well into the


plays a key role in timely response to events of this nature. Therefore, licensees
sequence of events at St. Lucie. Security's ability to identify the perpetrators and


may wish to periodically
institute other protective measures diminishes severely as time elapses.


refresh their Operations
Events of this nature are required by Appendix G to Part 73 of 10 CFR to be reported to


staff's sensitivity
the NRC Operations Center within one hour of discovery.


to and awareness
This information notice requires no specific action or written response. If you have any


of the evaluation
questions about the information in this notice, please contact one of the technical contacts


process to ensure effective
listed below or the appropriate Office of Nuclear Reactor Regulation project manager.


response to these acts.(4) The licensee's
Thomas T. Martin, Director


Security staff was not told about these problems until well into the sequence of events at St. Lucie. Security's
Division of Reactor Program Management
 
ability to identify the perpetrators
 
and institute
 
other protective
 
measures diminishes
 
severely as time elapses.Events of this nature are required by Appendix G to Part 73 of 10 CFR to be reported to the NRC Operations
 
Center within one hour of discovery.
 
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
 
contacts listed below or the appropriate


Office of Nuclear Reactor Regulation
Office of Nuclear Reactor Regulation


project manager.Thomas T. Martin, Director Division of Reactor Program Management
Technical contacts: Loren Bush, NRR                      David Skeen, NRR


===Office of Nuclear Reactor Regulation===
(301) 415-2944        (301) 415-1174 E-mail: llb@nrc.gov E-mail: dls@nrc.gov
Technical


contacts:  
Tech Editor has reviewed and concurred on 9/27/96 Attachment: List of Recently Issued NRC Information Notices
Loren Bush, NRR David Skeen, NRR (301) 415-2944 (301) 415-1174 E-mail: llb@nrc.gov


E-mail: dls@nrc.gov
DOCUMENT NAME: G:\DLS\96-XXX


Tech Editor has reviewed and concurred
To receive a copy of this document. indicate In the box: 'C - Copy w/o


on 9/27/96 Attachment:
attachment/enclosure WE- Copy wlettachmenlenClosure N - No copy
List of Recently Issued NRC Information


Notices DOCUMENT NAME: G:\DLS\96-XXX
OFFICE          TECH CONTS                        C/PECB:DRPM l        D/DRPJ-       I


To receive a copy of this document.
NAME            LBush*                            AChaffee*            Toard n


indicate In the box: 'C -Copy w/o attachment/enclosure
DSkeen1                          A a e                  haW


WE -Copy wlettachmenlenClosure
10/31/96                          11/01/96            12/zo /96 DATE


N -No copy OFFICE TECH CONTS C/PECB:DRPM
Al. -r. .. - .


l D/DRPJ- I NAME LBush* AChaffee*
U11l.IWAL KLLUKU      HUrY        4 AIn-nn/I
Toard n DSkeen1 A a e haW DATE 10/31/96 11/01/96 12/zo /96 Al. -r ... -.A In-n n/I U11l.IWAL


KLLUKU HUrY 4 t
t


* IN 96-XX November xx, 1996 available.
*                                                                                         IN 96-XX


Furthermore, the licensee contingency
November xx, 1996 available. Furthermore, the licensee contingency plans requiredby 10 CFR


plans requiredby
73.55(h)(1) and the implementing procedures required by Appendix C to Part 73 did


10 CFR 73.55(h)(1)
not adequately address tampering, vandalism, and malicious mischief.
and the implementing


procedures
(2)        The licensee actions were limited in scope and depth, at least initially, in pursuing the


required by Appendix C to Part 73 did not adequately
events.


address tampering, vandalism, and malicious
(3)        The Operations staff was not sensitive to abnormalities identified earlier and


mischief.(2) The licensee actions were limited in scope and depth, at least initially, in pursuing the events.(3) The Operations
apparently assumed no malice. Since the Operations staff may be the first to


staff was not sensitive
encounter signs of tampering, vandalism, or malicious mischief during its tours and


to abnormalities
surveillance activities, sensitivity to precursors plays a key role in timely response to


identified
events of this nature. Therefore, licensees may wish to periodically refresh their


earlier and apparently
Operations staffs sensitivity to and awareness of the evaluation process to ensure


assumed no malice. Since the Operations
effective response to these acts.


staff may be the first to encounter
(4)        The licensee's Security staff was not told about these problems until well into the


signs of tampering, vandalism, or malicious
sequence of events. Security's ability to identify the perpetrator(s) and institute other


mischief during its tours and surveillance
protective measures diminishes severely as time elapses.


activities, sensitivity
Events of this nature are required by Appendix G to Part 73 of 10 CFR to be reported to the


to precursors
NRC Operations Center within one hour of discovery.


plays a key role in timely response to events of this nature. Therefore, licensees
This information notice requires no specific action or written response. If you have any


may wish to periodically
questions about the information in this notice, please contact one of the technical contacts


refresh their Operations
listed below or the appropriate Office of Nuclear Reactor Regulation (NRR) project manager.


staffs sensitivity
Thomas T. Martin, Director


to and awareness
Division of Reactor Program Management


of the evaluation
Office of Nuclear Reactor Regulation


process to ensure effective
===Technical Contact:===


response to these acts.(4) The licensee's
===Loren Bush, NRR===
                                              (301) 415-2944 E-mail: llb@nrc.gov


Security staff was not told about these problems until well into the sequence of events. Security's
David Skeen, NRR


ability to identify the perpetrator(s)  
(301) 415-1174 E-mail: dls@nrc.gov
and institute


other protective
Attachment: List of Recently Issued NRC Information Notices


measures diminishes
DOCUMENT NAME: G:MDLS\IN96-XX.TPR


severely as time elapses.Events of this nature are required by Appendix G to Part 73 of 10 CFR to be reported to the NRC Operations
To receive a copy of this document. hIdicate hI the box: 'C' - Copy w/o


Center within one hour of discovery.
attachmenVenclosure 'E' - Copy wlattachmentlenclosure 'N' - No copy


This information
OFFICE          PECB:DRPM                    IC PSGB:DRPM              C/PSGB:DRPM          C/PECB:DRPM ,      D/DRPM


notice requires no specific action or written response.
NAME            DSkeenZot-C                        LBush*              LCunninghamnM      AChaffeeCifv-' TMartin


If you have any questions
DATE            10/3//96                          10/xv/96            10/ /96              1l// /96 3y9 10/ /96
    -i


about the information
*-pervias                                  OFFICIAL RECORD COPY                                              44I  1i


in this notice, please contact one of the technical
K.IN                                                                                          96-XX


contacts listed below or the appropriate
October xx, 1996 available. Furthermore, the licensee contingency plans requiredby 10 CFR


Office of Nuclear Reactor Regulation (NRR) project manager.Thomas T. Martin, Director Division of Reactor Program Management
73.55(h)(1) and the implementing procedures required by Appendix C to Part 73 did


===Office of Nuclear Reactor Regulation===
not adequately address tampering, vandalism, and malicious mischief.
Technical


Contact: Loren Bush, NRR (301) 415-2944 E-mail: llb@nrc.gov
(2)         The licensee actions were limited in scope and depth, at least initially, in pursuing the


David Skeen, NRR (301) 415-1174 E-mail: dls@nrc.gov
events.


Attachment:
(3)        The Operations staff was not sensitive to abnormalities identified earlier and
List of Recently Issued NRC Information


Notices DOCUMENT NAME: G:MDLS\IN96-XX.TPR
apparently assumed no malice. Since the Operations staff may be the first to


To receive a copy of this document.
encounter signs of tampering, vandalism, or malicious mischief during its tours and


hIdicate hI the box: 'C' -Copy w/o attachmenVenclosure
surveillance activities, sensitivity to precursors plays a key role in timely response to


'E' -Copy wlattachmentlenclosure
events of this nature. Therefore, licensees may wish to periodically refresh their


'N' -No copy OFFICE PECB:DRPM
Operations staffs sensitivity to and awareness of the evaluation process to ensure


IC PSGB:DRPM
effective response to these acts.


C/PSGB:DRPM
(4)        The licensee's Security staff was not told about these problems until well into the


C/PECB:DRPM , D/DRPM NAME DSkeenZot-C
sequence of events. Security's ability to identify the perpetrator(s) and institute other


LBush* LCunninghamnM
protective measures diminishes severely as time elapses.


AChaffeeCifv-'
Events of this nature are required by Appendix G to Part 73 of 10 CFR to be reported to the
TMartin DATE 10/3//96 10/xv/96 10/ /96 1l// /96 3y9 10/ /96-i OFFICIAL RECORD COPY*- pervias 44 1i I


K.IN 96-XX October xx, 1996 available.
NRC Operations Center within one hour of discovery.


Furthermore, the licensee contingency
This information notice requires no specific action or written response. If you have any


plans requiredby
questions about the information in this notice, please contact one of the technical contacts


10 CFR 73.55(h)(1)
listed below or the appropriate Office of Nuclear Reactor Regulation (NRR) project manager.
and the implementing


procedures
Thomas T. Martin, Director


required by Appendix C to Part 73 did not adequately
Division of Reactor Program Management


address tampering, vandalism, and malicious
Office of Nuclear Reactor Regulation
 
mischief.(2) The licensee actions were limited in scope and depth, at least initially, in pursuing the events.(3) The Operations
 
staff was not sensitive
 
to abnormalities
 
identified
 
earlier and apparently
 
assumed no malice. Since the Operations
 
staff may be the first to encounter
 
signs of tampering, vandalism, or malicious
 
mischief during its tours and surveillance
 
activities, sensitivity
 
to precursors
 
plays a key role in timely response to events of this nature. Therefore, licensees
 
may wish to periodically
 
refresh their Operations
 
staffs sensitivity
 
to and awareness
 
of the evaluation
 
process to ensure effective
 
response to these acts.(4) The licensee's
 
Security staff was not told about these problems until well into the sequence of events. Security's
 
ability to identify the perpetrator(s)
and institute
 
other protective
 
measures diminishes
 
severely as time elapses.Events of this nature are required by Appendix G to Part 73 of 10 CFR to be reported to the NRC Operations
 
Center within one hour of discovery.
 
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


contacts listed below or the appropriate
===Technical Contact:===


Office of Nuclear Reactor Regulation (NRR) project manager.Thomas T. Martin, Director Division of Reactor Program Management
===Loren Bush, NRR===
                                              (301) 415-2944 E-mail: llbenrc.gov


===Office of Nuclear Reactor Regulation===
David Skeen, NRR
Technical


Contact: Loren Bush, NRR (301) 415-2944 E-mail: llbenrc.gov
(301) 415-1174 E-mail: dIs@nrc.gov


David Skeen, NRR (301) 415-1174 E-mail: dIs@nrc.gov
Attachment: List of Recently Issued NRC Information Notices


Attachment:  
DOCUMENT NAME: G:IDLSIN96-XX.TPR
List of Recently Issued NRC Information


Notices DOCUMENT NAME: G:IDLSIN96-XX.TPR
To receive a copy of this document,. Indicate i the box: 'C' - Copy w/o


To receive a copy of this document,.
attachment/enclosure 'E' - Copy w/attachmenVenclosure 'N' - No copy


Indicate i the box: 'C' -Copy w/o attachment/enclosure
OFFICE        PECB:DRPM              - I        PSGB:DRPM            C/PSWJ    RM/ )C/PECB:DRPM        I  D/DRPM


'E' -Copy w/attachmenVenclosure
INAME


'N' -No copy OFFICE PECB:DRPM
DATE


-I PSGB:DRPM
US-keen A50L-
                  10/6/4/96 ILBush Xx:i'
                                                    10t796 ILCurh&FaIIt V AChaffee


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910/   -         /96 TMartin


V AChaffee TMartin DATE 10/6/4/96
10/ /96 OFFICIAL RECORD COPY}}
10t796 10 9E -910/ /96 10/ /96 OFFICIAL RECORD COPY}}


{{Information notice-Nav}}
{{Information notice-Nav}}

Latest revision as of 04:41, 24 November 2019

Licensee Response to Indications of Tampering, Vandalism, or Malicious Mischief
ML031050461
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: 12/27/1996
From: Martin T
Office of Nuclear Reactor Regulation
To:
References
IN-96-071, NUDOCS 9612300051
Download: ML031050461 (8)


UNITED STATES

NUCLEAR REGULATORY COMMISSION

OFFICE OF NUCLEAR REACTOR REGULATION-

WASHINGTON, DC 20555-0001 December 27, 1996 NRC INFORMATION NOTICE NO. 96-71: LICENSEE RESPONSE TO INDICATIONS OF

TAMPERING, VANDALISM, OR MALICIOUS

MISCHIEF

Addressees

All holders of operating licenses or construction permits for nuclear power reactors.

Purpose

This information notice is being issued to alert licensees to the benefits of planning a

response to indications of tampering, vandalism, or malicious mischief. It is expected that

recipients will review the information for applicability to their facilities and consider actions, as appropriate. However, suggestions contained in this information notice are not NRC

requirements; therefore, no specific action or written response is required.

Description of Circumstances

Recent events at operating reactors indicate that some licensee personnel may not

recognize the potential significance of early indications of potential tampering, vandalism, or malicious mischief. As a result, licensee response may be untimely and of limited scope

and depth. Failure to promptly question, resolve the significance and implement an

appropriate strategy to mitigate the consequence of a potential tampering, vandalism, or

malicious mischief situation, could leave the plant in a vulnerable state for a significant

period of time. Lack of detailed planning, procedures, and training frequently plays a role

in the quality of response to these events. Brief accounts of two events illustrate the

issue:

Improperly Positioned Valve at Beaver Valley

During the conduct of a quarterly surveillance on Friday, July 14, 1995, to verify the

position of certain safety-related locked valves; the licensee determined that the service

water cross-connect valve at the discharge of the recirculation spray heat exchanger was

in the incorrect position (shut in lieu of open), that the chain used to secure the valve in

the proper position had been cut, and that the lock appeared to have been placed back on

the chain in a manner that made it difficult to detect the condition. The licensee's staff

initially assumed the valve had been inadvertently mispositioned during earlier operational

evolutions, but subsequent interviews and analysis were unable to confirm this

assumption. 2 I1

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IN 96-71 December 27, 1996 Licensee management first learned of the event on Tuesday, July 18, 1995. Consequ- ently, licensee management was not able to oversee the licensee evaluation of the event

until considerable time had elapsed. The licensee's determination that potential tampering

could not be ruled out was not made until six days after the incorrect valve position

was identified. Thorough valve lineup checks and locked valve surveillances were not

completed for both Beaver Valley units until after the plant staff made an emergency

notification system (ENS) call on Thursday evening, July 20, 1995. The similarity of this

event to an event in the early 1980s heightened the concern of both licensee and NRC

personnel who knew of the previous events.

Misadjusted Valves and Disabled Locks at St. Lucie

In May 1996, St. Lucie personnel identified two pressure-relief valves which, when tested, were found to have pressure setpoints 55 percent and 9 percent above their design values.

These valves also had broken wire seals. The root cause could not be determined.

Although tampering could not be ruled out, it was concluded that the more likely cause for

the misadjusted valves was poor maintenance. Licensee management decided to alert the

Security force; however, site Security was not notified. The failure to follow through on

alerting site Security precluded coordinated actions of Operations and Security staffs to

enhance awareness to other possible tampering events.

On July 26, 1996, St. Lucie staff identified nine padlocks and two door locks in vital areas

that were intentionally damaged to inhibit opening the locks. These locks controlled

personnel access to various pieces of plant equipment. The licensee did not identify

keylock switches as needing to be checked; consequently, these switches were not

checked until August 1996. Although the tampering of components within a vital area

indicated the need to be alert to additional tampering, other than alerting Security, the

licensee failed to consider additional measures to detect tampering. On August 14, 1996, St. Lucie staff identified three additional examples of tampering in vital areas that inhibited

the opening of locks associated with safety-related equipment.

Discussion

The following factors may have contributed to these events:

(1) The licensees' contingency plans required by 10 CFR 73.55(h)(1) and the

implementing procedures required by Appendix C to Part 73 did not adequately

address tampering, vandalism, and malicious mischief. Other licensee procedures

touched some aspects of these situations; however, no plan or process was used to

evaluate the potential malevolent event and determine its importance. Factors such

as safety significance, overtness, intent, sophistication of method, and the history

of similar incidents were not considered. Information Notice 83-27, "Operational

Response to Events Concerning Deliberate Acts Directed Against Plant Equipment,"

described events in which licensees were not prepared to assess the situation and

take necessary steps to ensure the operability of systems important to safety or

make decisions concerning continued operation. The information notice indicated

that guidelines or procedures prepared by the licensee outlining a process of

i

IN 96-71 December 27, 1996 following up on both deliberate and inadvertent acts with respect to plant operation

should be available.

(2) The licensees' actions were limited in scope and depth, at least initially, in pursuing

the events.

(3) The licensees' Operations staff were not sensitive to abnormalities identified earlier

and apparently assumed no malice. Since the Operations staff may be the first to

encounter signs of tampering, vandalism, or malicious mischief during its tours and

surveillance activities, sensitivity to precursors plays a key role in timely response to

events of this nature. Therefore, licensees may wish to periodically refresh their

Operations staff's sensitivity to and awareness of the evaluation process to ensure

effective response to these acts.

(4) The licensee's Security staff was not told about these problems until well into the

sequence of events at St. Lucie. Security's ability to identify the perpetrators and

institute other protective measures diminishes severely as time elapses.

Events of this nature are required by Appendix G to Part 73 of 10 CFR to be reported to

the NRC Operations Center within one hour of discovery.

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 contacts

listed below or the appropriate Office of Nuclear Reactor Regulation project manager.

Thomas T. Martin, Director

Division of Reactor Program Management

Office of Nuclear Reactor Regulation

Technical contacts: Loren Bush, NRR

(301) 415-2944 E-mail: llb(nrc.gov

David Skeen, NRR

(301) 415-1174 E-mail: dls@nrc.gov

Attachment: List of Recently Issued NRC Information Notices

AM -chrobL~A 4?f-r

S

W-

Attachment

IN 96-71 December 27, 1996 LIST OF RECENTLY ISSUED

NRC INFORMATION NOTICES

Information Date of

Notice No. Subject Issuance Issued to

96-70 Year 2000 Effect on Computer 12/24/96 All U.S. Nuclear

System Software Regulatory Commission

licensees, certificate

holders, and registrants

96-69 Operator Actions Affecting 12/20/96 All holders of OLs

Reactivity or CPs for nuclear

power reactors

96-68 Incorrect Effective Diaphragm 12/19/96 All holders of OLs

Area Values in Vendor Manual or CPs for nuclear

Result in Potential Failure power reactors

of Pneumatic Diaphragm

Actuators

96-67 Vulnerability of Emergency 12/19/96 All holders of OLs

Diesel Generators to Fuel or CPs for nuclear

Oil/Lubricating Oil Incom- power reactors

patibility

96-66 Recent Misadministrations 12/13/96 All U.S. Nuclear

Caused by Incorrect Cali- Regulatory Commission

brations of Strontium-90 Medical Use Licensees

Eye Applicators authorized to use

strontium-90 (Sr-90)

eye applicators

96-65 Undetected Accumulation 12/11/96 All holders of OLs

of Gas in Reactor Coolant or CPs for nuclear

System and Inaccurate power reactors

Reactor Water Level

Indication During Shutdown

OL = Operating License

CP = Construction Permit

IN 96-71 December 27, 1996 following up on both deliberate and inadvertent acts with respect to plant operation

should be available. t

(2) The licensees' actions were limited in scope and depth, at least initially, in pursuing

the events.

(3) The licensees' Operations staff were not sensitive to abnormalities identified earlier

and apparently assumed no malice. Since the Operations staff may be the first to

encounter signs of tampering, vandalism, or malicious mischief during its tours and

surveillance activities, sensitivity to precursors plays a key role in timely response to

events of this nature. Therefore, licensees may wish to periodically refresh their

Operations staff's sensitivity to and awareness of the evaluation process to ensure

effective response to these acts.

(4) The licensee's Security staff was not told about these problems until well into the

sequence of events at St. Lucie. Security's ability to identify the perpetrator(s) and

institute other protective measures diminishes severely as time elapses.

Events of this nature are required by Appendix G to Part 73 of 10 CFR to be reported to

the NRC Operations Center within one hour of discovery.

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 contacts

listed below or the appropriate Office of Nuclear Reactor Regulation project manager.

original signed by D.B. Matthews

Thomas T. Martin, Director

Division of Reactor Program Management

Office of Nuclear Reactor Regulation

Technical contacts: Loren Bush, NRR David Skeen, NRR

(301) 415-2944 (301) 415-1174 E-mail: llb@nrc.gov E-mail: dls@nrc.gov

Tech Editor has reviewed and concurred on 9/27/96 Attachment: List of Recently Issued NRC Information Notices

DOCUMENT NAME: 96-71.IN

To receive a copy of this document. hIdlcate I the box: 'C' - Copy w/o

attachmentlenclosure 'E' - Copy wfattachmentlenclosure 'N' - No copy

OFFICE TECH CONTS I C/PECB:DRPM I D/DRP I I

NAME LBush* AChaffee* TMart

DSkeen* L ' I

DATE 10/31/96 11/01/96 12 OFFICIAL RECORD COPY

  • IN 96- December , 1996 following up on both deliberate and inadvertent acts with respect to plant operation

should be available.

(2) The licensees' actions were limited in scope and depth, at least initially, in pursuing

the events.

(3) The licensees' Operations staff were not sensitive to abnormalities identified earlier

and apparently assumed no malice. Since the Operations staff may be the first to

encounter signs of tampering, vandalism, or malicious mischief during its tours and

surveillance activities, sensitivity to precursors plays a key role in timely response to

events of this nature. Therefore, licensees may wish to periodically refresh their

Operations staff's sensitivity to and awareness of the evaluation process to ensure

effective response to these acts.

(4) The licensee's Security staff was not told about these problems until well into the

sequence of events at St. Lucie. Security's ability to identify the perpetrators and

institute other protective measures diminishes severely as time elapses.

Events of this nature are required by Appendix G to Part 73 of 10 CFR to be reported to

the NRC Operations Center within one hour of discovery.

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 contacts

listed below or the appropriate Office of Nuclear Reactor Regulation project manager.

Thomas T. Martin, Director

Division of Reactor Program Management

Office of Nuclear Reactor Regulation

Technical contacts: Loren Bush, NRR David Skeen, NRR

(301) 415-2944 (301) 415-1174 E-mail: llb@nrc.gov E-mail: dls@nrc.gov

Tech Editor has reviewed and concurred on 9/27/96 Attachment: List of Recently Issued NRC Information Notices

DOCUMENT NAME: G:\DLS\96-XXX

To receive a copy of this document. indicate In the box: 'C - Copy w/o

attachment/enclosure WE- Copy wlettachmenlenClosure N - No copy

OFFICE TECH CONTS C/PECB:DRPM l D/DRPJ- I

NAME LBush* AChaffee* Toard n

DSkeen1 A a e haW

10/31/96 11/01/96 12/zo /96 DATE

Al. -r. .. - .

U11l.IWAL KLLUKU HUrY 4 AIn-nn/I

t

  • IN 96-XX

November xx, 1996 available. Furthermore, the licensee contingency plans requiredby 10 CFR

73.55(h)(1) and the implementing procedures required by Appendix C to Part 73 did

not adequately address tampering, vandalism, and malicious mischief.

(2) The licensee actions were limited in scope and depth, at least initially, in pursuing the

events.

(3) The Operations staff was not sensitive to abnormalities identified earlier and

apparently assumed no malice. Since the Operations staff may be the first to

encounter signs of tampering, vandalism, or malicious mischief during its tours and

surveillance activities, sensitivity to precursors plays a key role in timely response to

events of this nature. Therefore, licensees may wish to periodically refresh their

Operations staffs sensitivity to and awareness of the evaluation process to ensure

effective response to these acts.

(4) The licensee's Security staff was not told about these problems until well into the

sequence of events. Security's ability to identify the perpetrator(s) and institute other

protective measures diminishes severely as time elapses.

Events of this nature are required by Appendix G to Part 73 of 10 CFR to be reported to the

NRC Operations Center within one hour of discovery.

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 contacts

listed below or the appropriate Office of Nuclear Reactor Regulation (NRR) project manager.

Thomas T. Martin, Director

Division of Reactor Program Management

Office of Nuclear Reactor Regulation

Technical Contact:

Loren Bush, NRR

(301) 415-2944 E-mail: llb@nrc.gov

David Skeen, NRR

(301) 415-1174 E-mail: dls@nrc.gov

Attachment: List of Recently Issued NRC Information Notices

DOCUMENT NAME: G:MDLS\IN96-XX.TPR

To receive a copy of this document. hIdicate hI the box: 'C' - Copy w/o

attachmenVenclosure 'E' - Copy wlattachmentlenclosure 'N' - No copy

OFFICE PECB:DRPM IC PSGB:DRPM C/PSGB:DRPM C/PECB:DRPM , D/DRPM

NAME DSkeenZot-C LBush* LCunninghamnM AChaffeeCifv-' TMartin

DATE 10/3//96 10/xv/96 10/ /96 1l// /96 3y9 10/ /96

-i

  • -pervias OFFICIAL RECORD COPY 44I 1i

K.IN 96-XX

October xx, 1996 available. Furthermore, the licensee contingency plans requiredby 10 CFR

73.55(h)(1) and the implementing procedures required by Appendix C to Part 73 did

not adequately address tampering, vandalism, and malicious mischief.

(2) The licensee actions were limited in scope and depth, at least initially, in pursuing the

events.

(3) The Operations staff was not sensitive to abnormalities identified earlier and

apparently assumed no malice. Since the Operations staff may be the first to

encounter signs of tampering, vandalism, or malicious mischief during its tours and

surveillance activities, sensitivity to precursors plays a key role in timely response to

events of this nature. Therefore, licensees may wish to periodically refresh their

Operations staffs sensitivity to and awareness of the evaluation process to ensure

effective response to these acts.

(4) The licensee's Security staff was not told about these problems until well into the

sequence of events. Security's ability to identify the perpetrator(s) and institute other

protective measures diminishes severely as time elapses.

Events of this nature are required by Appendix G to Part 73 of 10 CFR to be reported to the

NRC Operations Center within one hour of discovery.

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 contacts

listed below or the appropriate Office of Nuclear Reactor Regulation (NRR) project manager.

Thomas T. Martin, Director

Division of Reactor Program Management

Office of Nuclear Reactor Regulation

Technical Contact:

Loren Bush, NRR

(301) 415-2944 E-mail: llbenrc.gov

David Skeen, NRR

(301) 415-1174 E-mail: dIs@nrc.gov

Attachment: List of Recently Issued NRC Information Notices

DOCUMENT NAME: G:IDLSIN96-XX.TPR

To receive a copy of this document,. Indicate i the box: 'C' - Copy w/o

attachment/enclosure 'E' - Copy w/attachmenVenclosure 'N' - No copy

OFFICE PECB:DRPM - I PSGB:DRPM C/PSWJ RM/ )C/PECB:DRPM I D/DRPM

INAME

DATE

US-keen A50L-

10/6/4/96 ILBush Xx:i'

10t796 ILCurh&FaIIt V AChaffee

10 9E

910/ - /96 TMartin

10/ /96 OFFICIAL RECORD COPY