IA-86-189, Marked-up Draft IE Info Notice 85-XXX, Licensee Control of Consulting Svcs Providing Training
| ML20197E634 | |
| Person / Time | |
|---|---|
| Issue date: | 10/31/1985 |
| From: | Jordan E NRC OFFICE OF INSPECTION & ENFORCEMENT (IE) |
| To: | |
| Shared Package | |
| ML20197E609 | List: |
| References | |
| FOIA-86-189, FOIA-86-A-51 NUDOCS 8605150291 | |
| Download: ML20197E634 (3) | |
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SSINS No.: 6835 IN 85-XX UNITED STATES NUCLEAR REGULATORY COPHISSION OFFICE OF INSPECTION AND ENFORCEMENT WASHINGTON, D.'C. 20555 October XX, 1985 IE INFORMATION NOTICE NO. 85-XX: LICENSEE CONTROL OF CONSULTING SERVICES PROVIDING TRAINING Addressees:
All nuclear power facilities holding an operating license (0L) or construction permit (CP).
Purpose:
This information notice is provided to inform licensees of two potential generic problems concerning the applicability of 10 CFR.Part 21 to certain ;
training activities provided by' subcontractors, and guidance given by consultants during training courses concerning licensees' interaction with the NRC. It is expected that recipients'will review the information for applicability to their facilities and consider actions, if appropriate, to preclude similar problems from occurring at their facilities. However, suggestions contained in this information notice do not' constitute NRC requirements and, therefore, no specific action or written response is required.
l Discussion:
1 On September 10 and 11, 1985, the Vendor Program Branch (VPB) performed an inspection of a company that supplies consulting services, including training, to the nuclear industry. Two significant problens were noted which have the I '
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l IN 85-XX October XX, 1985 t Page 2 of potential for being generic; (1) a failure of licensees to impo,e Part 21 C
requirements on consultants providing training which is important to safety, I and (2) course material which appears to suggest or condone practices that E [
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could be misleading to the NRC program of inspection.
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e 5 Y al Paragraph 21.3 (a)(3) of 10 CFR Part 21 states that consulting services
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important to safety that are associated with component hardware are included j T, E o under the definition of a " basic component". Training, which is provided as a eC consulting service, is therefore subject to the provisions of 10 CFR Part 21 3 :! k g 2Y' when the training is associated with component hardware which is important to 6- E *f
" a safety (e.g. nondestructive exanination training, inservice inspection (ISI) f j p.
or testing (IST) training, preparation of ISI/IST programs training etc.)
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- ,Iny " deviations" found in the training materiahm.. air dr.cs ust bevreported to the ets,4 --/, o r-licensee for evaluation,and any " defects" must be reported to the NRCQs pr.s.A,{
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Licensees are also responsible for the correctness of the material presented in. training courses given by consultants. All information and points of view should accurately reflect the ' licensee's position or philosophy. Part of the r dc ewod . A l..s c. A training material reviewed during the inspection dealt with ic'ensee interaction with the NRC. The inference that could be drawn from the training material was that licensees should, and do, consciously delay submittal of y
required infonnation to the NRC and consciously omit relevantf but non-esse k du 1.c.% c c 6% A c uira<d*4 tr$.s. at e.*t a reis infonnation. Althoughai.t eas nat the-intent ef' the licenscc in hwi ing the.
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a couesa-oe-thtmtmt of-timnsultant in taarhing tho coune-to tel1 1fcensee A1
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IN 85-XX October XX, 1985
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& cnose occa> a a n k.~.sh co moa.c.a n u s .a d L -f L c M R.c._ a ct e a c..n.a. n &-ac d w e c<yiary q>c. ws.s personnel how o mislead the NRC, the course attendees may have received this impression. 42veid 2ny fu ture ;" ohin=c of + hic nature, licensees should assure themselves that all training materials accurately reflect the licensee's position philosophy [ .4 C On 8"P-* b a#Y " I -
No specific action or response is required by this information notice. If you have any questions regarding this notice, please contact the Regional Administrator of the appropriate NRC regional office or the technical contract listed below. z Edward L .inrda n , Director Division of Emergency Preparedness and Engineering Response Office of Inspection and Enforcement Technical
Contact:
E. W. Merschoff, IE (402-9045)
Attachments: List of Recently Issued Information Notices
~ 1 VPB:DQAVT SC/VPB:DQAVT BC/VPB:DQAVT v DIR:DQAVT BC/EGCB:DEPER EBaker: sam EWMerschoff GGZech BKGrimes RBaer 1 /85 / /85 / /85 / /85 / /85 TECH ED:IE D/DIR:DEPER DIR:DEPER
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SSchwartz ELJordan
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