Regulatory Issue

                    Misrepresenting Documentation is Not Good


The NRC’s LICENSEE NEWSLETTER, Fall 2010, relayed a citation that sometimes is not appreciated as a non-compliance issue.  It is being repeated here for the benefit of the reader and enforcement of the idea that misrepresentation of issues to the regulators is not a good practice.


Specifically, a licensee stated that three written directives were written prior to administrations, when in fact, the written directives were signed and dated after the administrations. Proper Written Directives are required to be maintained by 10 CFR 35.40(a), and were therefore, material to the NRC’s findings of misrepresentation of documentation.  This equivalent regulation is found in most Agreement States as well. The RSO was directed to step down from his duties for two years and a civil penalty of $5,000 was issued with the Notice of Violation (NOV) for a Severity Level III violation of 10 CFR 30.9.  


The NRC's enforcement program can be accessed at under Recently Issued Significant Enforcement Actions.  Documents related to cases can be accessed through the NRC's Agency  wide Document Access and  Management System (ADAMS) at Help in using ADAMS is available by contacting the NRC Public Document Room staff at 301-415-4737 or 1-800-397-4209 or by sending an e-mail to  (Contact: Michele Burgess, FSME, 301-415-5868 or e-mail:





is Not Good

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