Verification of Plant Records (Generic Letter 93-03)

October 20, 1995


TO:  ALL HOLDERS OF OPERATING LICENSES OR CONSTRUCTION PERMITS FOR NUCLEAR     
     POWER REACTORS

SUBJECT:  VERIFICATION OF PLANT RECORDS (GENERIC LETTER 93-03)

PURPOSE

The U.S. Nuclear Regulatory Commission (NRC) is issuing this generic letter to
inform licensees of the results of the inspections conducted under Temporary
Instruction (TI) 2515/115, "Verification of Plant Records," which addressed
the potential for incomplete or inaccurate records at licensed facilities. 
This generic letter reminds licensees and individuals involved in licensed
activities that the NRC may take direct enforcement action against not only
the licensee but also any individual who deliberately causes a licensee to be
in violation of NRC requirements.  This includes the falsification of records
required by technical specifications and plant procedures developed pursuant
to Regulatory Guide 1.33, "Quality Assurance Program Requirements
(Operation)," or other regulatory requirements.

BACKGROUND  

Section 50.9, "Completeness and accuracy of information," of Title 10 of the
Code of Federal Regulations (10 CFR) requires that information maintained by
the licensee pursuant to Commission regulations, orders, or license conditions
be complete and accurate in all material respects.  The administrative section
of plant technical specifications requires that written procedures covering
applicable activities (typically in Appendix A of Regulatory Guide 1.33) be
developed, implemented, and maintained.  Activities for which Appendix A
recommends written procedures include surveillances and log entries. 

Section 50.5, "Deliberate misconduct," of 10 CFR provides that the NRC may
take enforcement action against an individual, including an unlicensed person,
who (1) deliberately causes or, but for detection, would have caused a
licensee to be in violation of the Commission's requirements; or (2)
deliberately provides information to the licensee concerning licensed
activities knowing that the information is incomplete or inaccurate in some
respect material to the NRC.

On April 23, 1992, the NRC issued Information Notice 92-30, "Falsification of
Plant Records," to alert the industry to concerns of the NRC regarding record
falsification that had occurred at several plants.  The notice specifically
reminded plant personnel, both licensed and unlicensed, that they are subject
to 10 CFR 50.5 and that individual penalties could result from deliberately
violating Commission requirements.  It also noted that the NRC was continuing
its evaluation of the individual cases discussed.  Although the NRC did not
request any action by means of this notice, many licensees initiated actions
to ensure that plant personnel were properly performing their assigned duties.

9310180013.

Generic Letter 93-03               - 2 -                 October 20, 1993


The NRC issued TI 2515/115 to provide guidance for NRC inspector evaluation of
the ability of each licensee to obtain complete and accurate log readings from
both licensed and unlicensed operators.  The inspection findings were 
documented in a routine resident inspection report for each facility.  The NRC
reviewed the inspection findings nationwide to determine how widespread the
problem was.

SUMMARY OF TI 2515/115 INSPECTION RESULTS

The NRC recognizes that it is difficult to compare the TI 2515/115 inspection
results among plants.  Many factors can affect the inspection findings, such
as the variation in the extent of computerized access areas within the
protected area from plant to plant and in the sample sizes reviewed by
licensees (some licensees greatly expanded their sample size in response to an
identified discrepancy).  However, the review showed that at approximately 30
sites at least one discrepancy between security computer records and
documented logs existed.

Several licensees found that not only auxiliary operators, but also contractor
fire watches and health physics technicians had been responsible for creating
incomplete or inaccurate records.  The NRC is concerned not only with
inaccurate and incomplete records regarding the status and condition of plant
equipment, but also with the failure of the fire watches to provide a required
compensatory action.

Several licensees discovered a number of other problems related to the conduct
of plant rounds, log taking, and record keeping.  In some instances, licensees
found that many of the unlicensed operators were performing certain rounds
much faster than management expected.  Other licensees found that unlicensed
operators did not have a clear understanding of what their signatures on a log
sheet meant.  Some believed that it attested to only the fact that the round
had been performed, whether by the log signatory or another operator.  Several
licensees found that when multiple rounds or log readings were required in a
single shift, the operators performed a generally rigorous first tour, but a
much less formal second tour.  Finally, at one facility, management review of
the tour and logging requirements revealed that the operators could not
reasonably be expected to conduct the specified rounds in the time provided
because of such factors as the number of times the operators had to don and
remove anticontamination clothing to enter and leave radiation-controlled
areas.

The NRC found that licensee responses to Information Notice 92-30 were
positive.  Licensees took advantage of the information to review records,
sensitize employees, and appropriately revise procedures and training.  They
also took various disciplinary actions against the involved individuals in
accordance with their internal programs and policies, commensurate with the
seriousness of the violations.  Disciplinary actions taken by the licensees
against the licensed operators ranged from employment termination to leave
without pay. .

Generic Letter 93-03              - 3 -                 October 20, 1993


ENFORCEMENT ACTION

The information from each site was reviewed to determine the appropriate
enforcement action.  In each case that involved logging falsifications, the
NRC has determined that enforcement action is warranted.  A Notice of
Violation without a civil penalty was issued to all licensees that had logging
violations in order to emphasize (1) that such misconduct cannot be tolerated
and (2) management responsibility to ensure the completeness and accuracy of
facility records.  However, escalated action is not being taken because: (1)
the licensees identified the violations either on their own initiative or as a
result of the audits and inspections conducted after Information Notice 92-30
was issued, (2) the licensees took appropriate corrective action for any
potential program weaknesses, and (3) the licensees took disciplinary action
against the individuals involved, as appropriate.  In addition, the NRC is not
taking any enforcement action against individuals because licensees already
have taken appropriate disciplinary action.  

Now that the NRC has reemphasized the need for licensees to ensure that
logging activities are being properly conducted, logging violations in the
future may result not only in enforcement action against licensees, but also
direct enforcement action against the individual involved in deliberate record
falsification, whether the individual is licensed or not and whether the
individual is a licensee employee or a contractor.

LESSONS LEARNED

Various licensees have reexamined their programs to ensure that management
expectations regarding the conduct of rounds and log keeping are clearly
articulated to plant personnel and are being implemented in the plant.  Some
of the actions taken include steps to (1) ensure that individuals clearly
understand the meaning of their signatures on log sheets and procedures, 
(2) ensure that plant personnel clearly understand who is responsible and
authorized to perform rounds, (3) ensure that individuals understand the
purpose of the rounds and are properly trained on how the rounds are to be
conducted, (4) perform periodic audits of field practices, and (5) verify that
round and log requirements can reasonably be met in the specified time.  Given
the turnover of auxiliary operators and others who perform these rounds, these
topics may be appropriate for consideration in licensee routine training and
auditing programs. 
.

Generic Letter 93-03                - 4 -               October 20, 1993


This generic letter requires no specific action or written response.  If you
have any questions about the information in this generic letter, please
contact the technical contact listed below or the appropriate Office of
Nuclear Reactor Regulation project manager.

                                      Sincerely,


                                      James G. Partlow
                                      Associate Director for Projects
                                      Office of Nuclear Reactor Regulation

Enclosure:
List of Recently Issued NRC Generic Letters

Technical contact:  James G. Luehman, OE 
                    (301) 504-3280