Information Notice 1985-88, Licensee Control of Contracted Services Providing Training

Licensee Control of Contracted Services Providing Training

ML031180189
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, 05000000, Zimmer, Fort Saint Vrain, Shoreham, Satsop, Trojan, Atlantic Nuclear Power Plant, Skagit, Marble Hill
Issue date:	11/18/1985
From:	Jordan E NRC/IE
To:
References
IN-85-088, NUDOCS 8511150107
Download: ML031180189 (4)

SSINS No.: 6835 IN 85-88 UNITED STATES

NUCLEAR REGULATORY COMMISSION

OFFICE OF INSPECTION AND ENFORCEMENT

WASHINGTON, D.C. 20555 November 18, 1985 IE INFORMATION NOTICE NO. 85-88: LICENSEE CONTROL OF CONTRACTED SERVICES

PROVIDING TRAINING

Addressees

All nuclear power facilities holding an operating license (OL) or a construction

permit (CP).

Purpose

This information notice is provided to emphasize to licensees their responsibility

for the content of safety-related training courses and materials provided by

consultants to utility employees. It is expected that recipients will review

the information for applicability to their facilities and consider actions, if

appropriate, to preclude the occurrence of similar problems at their facilities.

However, suggestions contained in this information notice do not constitute NRC

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

Discussion:

In August 1985, the NRC learned that potentially misleading course material was

presented to licensee employees by a consulting firm as part of a training course

on containment leak rate testing. This material appeared to suggest and/or

condone practices that could be misleading in the conduct of an NRC inspection.

The following are some excerpts from the training course material entitled

"Interactions With the NRC."

Should the utility inform the NRC of contemplated program

changes? This is debatable.

Alerting NRC-opens up utility for comments and second

thoughts.

Springing changes on NRC has benefit of surprise.

Encourage [NRC] inspector to witness a Type C test, but...

don't be foolish:

Note: *Perform demo on an "easy" valve which has

traditionally not been a "problem leaker."

8511150107

IN 85-88 November 18, 1985 *NRC will want to concentrate on past problem areas and pet

peeves.

Traditional industry approach to ILRT testing problems has been

predicated on not stating to NRC:

When the test began (thus allowing for repairs after

pressurization commenced)

The "Type A" test failed (since some smooth talkers have

managed to get out of failures)

We'll do it over (since it has been possible to obtain

NRC agreement with statements such as, "you saw the test

before and didn'.t comment; why this time when we've done

it even better?")

• These statements appeared in the revised (March 1984) version

of the course as well as the November 1983 version.

During an inspection of the consulting firm, which took place after the NRC

became aware of the problem, it was found that the development and presentation

of this course material was an isolated instance. However, the inappropriateness

of this material would have been detected had- the- consulting firm's management

reviewed the quality of their product or had the licensee's management reviewed

the training material before it was presented to their employees. Further, although several of the licensee's employees raised concerns (through course

evaluation forms) to the consulting firm about the appropriateness of the

presentation on interactions with the NRC, these concerns were apparently not

brought to the attention of licensee management in a timely fashion.

Licensees are responsible for the correctness of the material presented in

training courses at their facilities. All information and points of view

should accurately reflect a licensee's position. As a result of the described

incident, in addition to specific corrective actions, the involved licensees

are reviewing their internal controls over contractor-provided training and

training material. Although during NRC followup the licensees involved and the

consultant's training organization have stated that it was not their intent to

tell the licensee's personnel how to mislead the NRC, the course attendees may

have received this impression. Because open and honest communications with the

NRC are a cornerstone of the regulatory process, it is imperative that licensees

assure themselves that all safety-related training materials accurately reflect

their position and philosophy.

IN 85-88 November 18, 1985 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 contact

listed below.

dward L. a

Division Emergency Preparedness

and Engineering Response

Office of Inspection and Enforcement

E. W. Merschoff, IE

301-402-9045 Attachments: List of Recently Issued IE Information Notices

Attachment 1 IN 85-88 November 18, 1985 LIST OF RECENTLY ISSUED

IE INFORMATION NOTICES

Information Date of

Notice No. Subject Issue Issued to

85-87 Hazards Of Inerting 11/18/85 All power reactor

Atmospheres facilities holding

an OL or CP; and

fuel facilities

85-86 Lightning Strikes At Nuclear 11/5/85 All power reactor

Power Generating Stations facilities holding

an OL or CP

85-85 Systems Interaction Event 10/31/85 All power reactor

Resulting In Reactor System facilities holding

Safety Relief Valve Opening an OL or CP

Following A Fire-Protection

Deluge System Malfunction

85-84 Inadequate Inservice Testing 10/30/85 All power reactor

Of Main Steam Isolation Valves facilities holding

an OL or CP

85-83 Potential Failures Of General 10/30/85 All power reactor

Electric PK-2 Test Blocks facilities holding

an OL or CP

85-82 Diesel Generator Differen- 10/18/85 All power reactor

tial Protection Relay Not facilities holding

Seismically Qualified an OL or CP

85-81 Problems Resulting In 10/17/85 All power reactor

Erroneously High Reading facilities holding

With Panasonic 800 Series an OL or CP and

Thermoluminescent Dosimeters certain material

and fuel cycle

licensees

85-80 Timely Declaration Of An 10/15/85 All power reactor

Emergency Class Implementa- facilities holding

tion Of An Emergency Plan, an OL or CP

And Emergency Notifications

85-17 Possible Sticking Of ASCO 10/1/85 All power reactor

Sup. 1 Solenoid Valves facilities holding

an OL or CP

OL = Operating License

CP = Construction Permit