ML20199F032

Confirms 850823 Telcon Re Containment Sys Leakage Testing Course.Course Outline from Facility Obtained.Meeting Requested.Related Info Encl

ML20199F032
Person / Time
Site:	Oyster Creek
Issue date:	08/23/1985
From:	Taylor J NRC OFFICE OF INSPECTION & ENFORCEMENT (IE)
To:	James Whitney GENERAL PHYSICS CORP.
Shared Package
ML20199F019	List: ML20199F013 ML20199F032 ML20199F049
References
FOIA-86-37 NUDOCS 8603270508
Download: ML20199F032 (18)

Text

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August 23, 1985 aw" de [ f.L(

g WN Mr. J. Whitney, Vice President g gc cd '

A General Physics Corporation 10650 Hickory Ridge Road hP

-Columbia, MD 21044 gA

Dear Mr. Whitney:

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This will confirm my telephone conversation with you today concerning the

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General Physics' course " CONTAINMENT SYSTEMS LEAKAGE TESTING." The NRC has

, obtained a copy of the course outline which was taught at Oyster Creek Nuclear Station in November 1983. The course contains information which is of con-cern to the NRC and its regulatory mission. Therefore, as I requested on the telephone, I would like to meet on this subject with senior managers of the General Physics Corporation as soon as convenient.

Further, I would appreciate your providing me the list of utilities and

' nuclear stations at which this same course was taught. Thank you for your cooperation in this matter.

Sincerely.

Original Signed By:

James M. Taylor James M. Taylor, Director Office of Inspection and Enforcement 1

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GENERAZ. PHYSICS CORPORATION MEMORANDUM DATE: September 4, 1985 GP-M-010270 TO: All Employees FROM: R. W. Deutsch QwT)

SUBJECT:

Press Report Concerning General Physics " Containment Leakage System Testing" Course on September 1,1985, the New York Times and several other newspapers throughout the country carried articles concerning a course on " Containment Leakage System Testing," which General Physics conducted for GPU Nuclear Corporation at Oyster Creek on November 29 and 30, 1983. The articles were the result of a letter from Representative Edward J. Markey, Chairman of the House Subcommittee on Energy, Conservation, and Power, to Dr. Nunzio Palladino, Chairman of the Nuclear Regulatory Commission, that was critical of certain statements in the training materials for this course.

The course consisted of ten lectures and the accompanying text contained in excess of 350 pages. One of the lectures in the course entitled, " Inter-actions with the NRC," contained three viewgraphs referred to industry experi-ence and used wording which could be interpreted as suggesting ways to circum-vent NRC regulations. These viewgraphs were followed by a disclaimer which stated, " Discussion of the above experience should in no way indicate endorse-ment of any of the observed approaches." Although some of the wording on these three viewgraphs was ambiguous and could be considered to be inappro-priate, all of the many other references to the NRC specifically stressed diligently following NRC regulations and procedures. When taken in context, the course emphasized working with the NRC in fulfilling the public health and safety responsibilities associated with containment system leakage testing.

Af ter reviewing the contents of the course and the course evaluations in late 1983, following the session.at Oyster Creek, the course material was revised to change or delete the viewgraphs which contained the questionable wording. The revised material was used to conduct the course a second and last time on March 1 and 2, 1984, in Columbia, Maryland, for employees of several other utilities. The course evaluations prepared by the attendees following the second session of the course indicated that, while the course provided many good ideas for leak rate testing and performance, it needed to be more specific. As a result, the course was discontinued and is no longer offered.

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' tn I. if September 4, 1985 All Employees GP-M-010270 Page 2 General Physics has been involved in nuclear power plant training for more than 15 years. We have developed and presented hundreds of courses involving NRC requirements. We have been involved in several NRC research projects whose purpose was to improve nuclear power plant safety and effi-ciency. Several of our key executives are former AEC or NRC employees. Long before the Three Mile Island accident, General Physics was advocating advanced operator training programs including the use of plant-specific simulators that have now been adopted and implemented by the NRC. In all of the hundreds of nuclear power plant training programs developed and implemented by General Physics over the past 15 years, public health and safety have always been of paramount importance, and we have not had a single case in which our strong support for NRC regulations has in any way been questioned.

This incident indicates that no matter how much care we have taken in the past to ensure that the training materials are in accordance with NRC regula-tions and procedures, we all must increase our efforts to prevent a similar incident in the future. I want to reinforce It has what has always been the Company's always been the policy of General policy regarding regulatory matters.

Physics that protection of public health and safety is the paramount objective for all nuclear power plant training programs associated with plant activities developed and conducted by the Company. It is our goal to assist our clients so that they are in compliance with NRC regulations. Further, in regard to NRC requirements as well as industry codes and standards, we have always implemented procedures which require careful review of course materials to ensure that they are not only technically correct but that they fully support the spirit as well as the letter of the regulations governing the operation of nuclear power plants. I wish to encourage all members of the Company to bring to my attention any situation which may give the appearance of a lack of sup-port for regulatory requirements.

The Company had provided a full accounting of the circumstances involving the GPU course to the NRC prior to Chairman Markey's letter and the resulting newspaper articles. Subsequently, we have provided the same full accounting to GPU. We are cooperating fully with both GPU and the NRC to resolve this matter to their satisfaction.

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e NOTICE October 5, 1984 To: All Company Personnel From: Chief Quality Engineer

Subject:

Reporting of Defects and Noncompliances Identified in Nuclear Power Plant Projects Your attention is called to the following excerpt from Section 15 of the General Phyics Corporation Quality Assurance Manual:

"15.4 Reporting of Defects and Noncompliance General Physics Corporation performs work for electric utilities i and is in frequent contact with nuclear generating stations. The owners of nuclear power plants under construction'(holders of construction permits) are required, under the requirements of the Code of Federal Regulations, Title 10 CFR 50.55(e), to notify the Nuclear Regulatory Commission (NRC) of each deficiency found in design and construction, which, were it to have remained uncorrected, could have affected adversely the safety of operations of the nuclear power plant at any time throughout the expected lifetime of the plant. In addition, under the requirements of the Code of Federal Regulations, Title 10 CFR 21, any individual director or responsible officer of a firm constructing, owning, operating, or supplying the components of any such facility, who obtains information indicating that substantial safety hazards exist or that the facility contains defects which could create a substantial safety hazard, shall immediately notify the NRC of the condition.

Any Company personnel who discover such deficiencies or defects, as defined in 10 CFR 50.55(e) or 10 CFR 21, shall immediately report the condition to the Project Manager. The Project Manager shall immediately notify the President and Executive Vice President who shall immediately notify the client (owner, or holder of the construction permit or operating license) in writing, and provide all known information pertinent to the condition.

Any modification to the reporting method defined herein shall be described in a Quality Assurance Procedure (QAP) as authorized by the President or the Executive Vice President, and~ identified in the Project Quality Plan."

The above requirements are mandated by Federal law. If you have any questions about the requirements, you may contact the Chief Quality Engineer at extension 6065.

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GENERAL PHYSICS CORPORATION Qu lity Azurcnca Manu21 Revicirn 5 (Drcf t)

FOREWORD General Physics Corporation provides engineering and specialized technical services to industry and government. The Company offers the complete range of services needed by organizations involved in the design, construction, operation and maintenance of power plants. In addition, the Company provides tactics, analysis, and training services for the United States Government Department of Defense, and consulting services for other United States Government agencies.

General Physics Corporation is committed to achieving high quality in all the services and related products it provides. The Company realizes this goal through selective employment of experienced engineers and technical specialists coupled with effective project management. In addition, the Company recognizes the fundamental importance of quality assurance practices in achieving this goal and has established a Quality Assurance Program to provide for these practices. The primary responsibility for the quality of the services and related products provided by the Company rests with the individuals doing the work. Accordingly, all employees are responsible for knowing and implementing the quality assurance practices of the Quality Assurance Program which are applicable to their work.

The President and CEO of General Physics Corporation has the overall responsibility for establishing the policies, and requirements of the Quality Assurance Program. The Vice President and CAO, who reports to the President, has the responsibility for implementing the Program. The Chief Quality Engineer, who reports to the Vice President and CAO, has the responsibility and organizational freedom to audit the implementation of the Program, to identify quality problems, to initiate corrective actions and to verify implementation of the Program, to identify quality problems, to initiate corrective actions to verify implementation of these solutions. The Quality Advisory Committee, which reports to the Vice President and CAO, has the responsibility for advising the Vice President and CAO and the Chief Quality Engineer on quality matters and policy and for conducting reviews and audits of quality-affecting activities.

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• - GENERAL PHYSICS CORPORATION Quality A3:urcnca Manu21 Revision 5 (DrEf t)

The Quality Assurance Program consists of the Quality Assurance Manual together with related Project Procedures and Quality Assurance Procedures.

The Quality Assurance Manual is the top level document which establishes the policies and requirements of the Quality Assurance Program. Because the Company provides services and related products for clients involved in the design, construction, operation, and maintenance of nuclear power plants, the Quality Assurance Manual addresses each of the 18 Criteria of Title 10, Code of Federal Regulations, Part 50 (10 CFR 50), Appendix B, ' Quality Assurance Criteria for Nuclear Power Plants and Fuel Reprocessing Plants." The policies and requirements of the Quality Assurance Manual are invoked to the extent determined by the Project Manger and consistent with client requirements.

Applicable policies and requirements are mandatory for projects having 10 CFR 50, Appendix B, requirements are used as a guide in developing quality assurance procedures for other Company projects.

President and CEO General Physics Corporation i

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GENERAL PHYSICS CORPORATION Quality ACCurtnca Manuni ,

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SECTION 2. QUALITY ASSURANCE PROGRAM 2.1 Scope This section describes how the General Physics Corporation Quality Assurance Program is designed to control quality-affecting activities on Company projects.

2.2 General This Quality Assurance Manual (QA Manual) defines the requirements of the General Physics Corporation Quality Assurance Program. It is presented in 19 sections as follows: 18 sections corresponding to and addressing each of the 18 Criteria of 10 CFR 50, Appendix B, and one section addressing other requirements.

General Physics Corporation provides services and related products and does not normally produce, install, replace, repair, or otherwise handle hardware products. Many of the sections of this Manual are not applicable to Company services projects in most cases, but are provided in the event that an expansion of business activities leads into any of these areas. The sections which not normally required ares o Section 8 Identification and Control of Materials, Parts and Components o Section 9 Control of Special Procesces o Section 10 Incpection o Section ll Test Control o Section 12 Control of Measuring and Test Equipment o Section 13 Handling, Storage and Shipping o Section 14 Inspection, Test and Operating Status Specific instructions and requirements for complying with applicable Criteria and parts thereof of the 18 Cr.iteria of 10 CFR 50, Appendix B, for each project for which applicability is determined as described in Section 2.1

-are contained in the implementing procedures which are identified in the Project Quality Plan, as' described in Section 2.4. These procedures include Quality Assurance Procedures (QAPs) and Project Procedures (PPs).

1. QAP's define how the administrative requirements of the QA Manual are to be implemented, and address the subjects which are conunon to all project activities of the Company, including such items as document control, quality assurance records, nonconformances/ corrective action, and quality assurance audits.

2. PP's describe how the quality-affecting activities of each specific work task are performed, including such items as the control of 2-1 r

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4 GENERAL PHYSICS CORPORATION Quality AD2urenca Minual i R2 vision 5 (Draft) i documents and records, independent reviews and approvals, control of I procurement activities, control of engineering evaluation and l

design, and the preparation of drawings, instructions and procedures.

When applicable, the PP's also (1) specify the prerequisites which apply to specific work tasks or related activities, (2) address the requirements for controlled conditions such as environmental and/or special equipment or processes, and (3) establish measures for assuring that the prerequisites and i other requirements have been met.

2.3 QA Manual Applicability

} The applicability of the QA Manual to each Company project shall be determined and effected as follows:

j 1. The requirements of Section 19 are applicable to all Company I activities as described therein.

i 2. The requirements of Sections 1 through 18 are applicable to Company projects as determined by a specific applicability review.

When a contract is received, it shall be reviewed by the designated f Project Manager to evaluate the project tasks and identify the quality assurance requirements. The Project Manager shall document the results of the l

applicability review by checking the appropriate block on the Contract Pricing Analysis form, Exhibit 1, prepared for that project. If a quality assurance

, plan is not required, the "No" block shall be checked, and'the only quality

assurance requirements applicable to the project are those defined in Section 19.

If a quality assurance plan is required, the "YES" block shall be checked, and the following additional actions taken

a. The Project Manager shall complete a Quality Assurance Manual Applicability form as shown in Exhibit 2, indicating whether each section is (1) " Applicable, in accordance with 10 CFR 50, Appendix

] B", (2) " Applicable, limited to specific project requirements," or

! (3) "Not applicable", consistent with the quality assurance 1 requirements specified in the contract.

(1) " Applicable, in accordance with 10 CFR 50, Appendix B":

1 j 10 CFR 50, Appendix B quality assurance requirements have been invoked in the contract by the client, and the project activities l

shall be performed, reviewed, and documented in full compliance with l

the designated sections of the QA Manual and the QAP's and PP's j

identified in the Project Quality Plan (par. 2.4).

i j (2) " Applicable, limited to specific project requirements":

10 CFR 50, Appendix B has not been invoked by the client, but j quality assurance requirements have been either specified in the

! contract or desinated by the cognizant Project Manager. In this hbN 1 2-2 i

i GENERAL PHYSICS CORPORATION Qu311ty A2curcnca M:nu21 Rsvicien 5 (Draf t) 1

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situation, the designated sections of the QA Manual shall be used only as a guide for controlling quality-affecting project activities, except as identified in the Project Quality Plan (par.

2.4). The specific requirements for reviews and documentation shall be contained in the QAP's and PP's identified in the Project Quality i Plan. (Any exceptions to specific provisions in the QA Manual sections invoked shall be listed on the Project Quality Plan form by 1 the Project Manager. (See par. 2.4.)

j ~(3) "Not applicable":

! The Project Manager shall sign and date the form when each' section has been checked, and forward it to the Chief Quality i Engineer for review and approval.

i The CQE shall review the form along with the contract and all b.

}{ reference documents, and take the following actions (1) Document the review results by checking the appropriate

"; blocks on the bottom section of the form, and attach all

. recommendations in writing.

(2) Sign and date the form, retain a copy, and. return the 1 original and attachments to the Project Manager for retention with the project records.

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(3) Obtain concurrence with, or resolution of, recommendations

from the Project Manager in writing, rnd sign the form, i indicating " Final Approval". The completed form with all l

back-up documentation attached, shall be filed with the l project records.

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c. The CQE shall monitor contract review activities and periodically review Contract Pricing Analysis forms to assure

! compliance with the requirements specified herein. 4 i 2.4 Project Quality Plan i Following the determination of applicability of the QA Manual, as described in Section 2.3, the Project Manager shall prepare a Project Quality Plan by reviewing the project task requirements and identifying the

description of each on a Project Quality Plan form, Exhibit 3. The applicable I sections of the QA Manual, as listed on the Quality Assurance Manual l Applicability form, shall be listed. The applicable implementing procedure or

! procedures, corresponding to each listed task description or required QA I Manual section, shall be identified in the " Applicable Procedure" column. Any j exceptions to the applicable sections of the QA Manual shall be listed in the appropriate space provided. The form shall be signed and dated by the Project Manager and signed and dated by the Chief Quality Engineer, following his review and approval. This' completed document summarizes the applicability of '

the QA Manual, project task requirements, and implementing procedures for i controlling the quality-affecting project activities, and shall be filed with l the Project Official Records, in accordance with Section 17.

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GENERAL PHYSICS CORPORATION l Quslity Assurance Minual Rsvision 5 (Draf t) l 2.5 Assessment of QA Manual' It is the responsibility of the CQE to assess the implementation of the QA Manual and to report the status and effectiveness thereof to the Executive l

Vice President on a regular basis, at least annually. A revision to the QA Manual, which requires review and approval by both the CQE and-the Executive Vice President, can be considered documentary evidence of that assessment.

Implementation and effectiveness of the QA Manual and compliance to the

! applicable criteria of 10 CFR 50, Appendix B, and other applicable Codes and l specifications shall be assured through project audits performed by the CQE or his designee.

2.6 Revision of the QA Manual Revisions to the QA Manual shall be approved by the CQE and the Executive Vice President.

2.7 QA Manual Distribu*. ion The.CQE is responsible for the issue, recall, revision, and reissue of the QA Manual, which is a oc'ntrolled document. These issue and control actions shall be documented and performed in accordance with the applicable QAP for " Quality Assurance Document Control". When QA Manuals and revisions to the QA Manual are distributed, a receipt acknowledgement form shall be requested from each holder of controlled copies.

2.8 Personnel Assignments All personnel assignments to project organizations shall be made by the cognizant Project Director, consistent with client requirements. All project work assignments shall be made by the cognizant Project Manager.

2.9 Personnel Qualifications The qualification requirements for project personnel shall be established by the cognizant Project Manager consistent with client requirements.

2.10 Project Personnel Indoctrination and Training It is the responsibility of the cognizant Project Manager to assure that all project personnel performing quality-affecting activities be indoctrinated in the provisions of the QA Manual and all' applicable documents and procedures. The indoctrination shall include the followings o General Phycles Corporation management policy for quality assurance l o Project Quality Plan t

f o Discussion of 10 CFR 50, Appendix B, and other Codes, Standards, and l Specifications, when applicable o Details and mandatory nature of the QA Manual and implementing procedures (QAP's and PP's) 2-4

GENERAL PHYSICS CORPORATION Quclity A;;urInca Minuni R: vision 5 (Drcf t) o verification of compliance to QA Manual requirements The CQE shall be available to personnel to answer quality-related questions and/or provide explanation or clarification when needed.

Completion of the quality assurance indoctrination shall be certified in writing for each individual by the Project Manager.

The training requirements for project personnel shall be evaluated by the Project Manager and provided on an as-needed basis. It is the policy, where possible, to assign personnel who are fully qualified and do not require additional training, to perform specific work tasks.

2.11 Project Organization Responsibility The Project Manager is responsible for the quality of all work performed by the Project Staf f under his jurisdiction. Individuals who are assigned verifying and checking tasks are independent of those individuals responsible for performing the work. In addition, design verification, audits and surveillance are performed by individuals or groups other than those who performed the original dasign work.

2.12 Quality Assurance Auditor Qualification and Training It is the responsibility of the Chief Quality Engineer to assure that quality assurance auditors are properly qualified in accordance with the applicable QAP. It is also the responsibility of the CQE to provide specific training to assigned auditors, relating to the applicable quality-affecting project activities. Records of auditor qualification and training shall be maintsined by General Physics Corporation.

2.13 Certification It is the responsiblity of the Chief Quality Engineer to prepare and sign certificates of conformance and/or compliance when they are required.

2.14 Resolution of Disagreement Differences of opinion on quality requirements, between the Chief Quality Engineer and Division Directors, Division Vice Presidents or Senior Vice Presidents, will normally be resolved by the Executive Vice President, when recessary. If he is unavailable, differences will be resolved by the President.

2.15 Contractors' Quality Assurance Program To assure that contractors providing items or services under the scope of this QA Manual have acceptable quality assurance programs, specific requirements for these programs are contained in procurement documents. These programs are subject to review prior to contract award and during contract life. Sections 4 and 7 of this Manual further define this activity. l l

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! GENERAL PHYSICS CORPORATION Quality A2curEnca MKnunl i Revision 5 (Draf t) 2.16 Inspections and Test Requirements Appropriate requirements are imposed on contractors in the procurement documents to assure that inspections and tests are performed with appropriate equipment and under suitable environmental conditions. Inspection and test ,

I procedures for these activities are reviewed prior to use and the work j

activities monitored for conformance to the procedures.

4 2.17 Management Review of QA Program A management review of the General Physics Corporation QA Program shall be conducted periodically, once every two years as a minimum, to assure its continued effectiveness. The review shall be directed by, and the results j reported to the President.

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GEN 3RAL PHYSICS CORPORATION- Quality A':curtnce Manual

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SECTION 19. GENERAL REQUIREMENTS 19.1 Scope This section describes the requirements of the Quality Assurance Program applicable to all Company projects and all Company activities. These requirements are in addition to any requirements specified in the Project Quality Plan if such a Plan is required in accord 9nce with Section 1.3.

19.2 Reporting of Defects and Noncompliances General Physics Corporation performs work for electric utility companies and United States Government agencies, and is in frequent contact with nuclear generating stations or involved with furnishing various services for nuclear generating stations. The owners of nuclear power plants under construction (holders of construction permits) are required, under the requirements of the Code of Federal Regulations, Title 10 CFR 50.55(e), to notify the Nuclear Regulatory Commission -(NRC) of each deficiency found in design and construction, which, were it to have remained uncorrected, could have affected adversely the safety of operations of the nuclear power plant at any time throughout the expected lifetime of the plant. In addition, under the requirements of the Code of Federal Regulations, Title 10 CFR 221, any individual director or responsible officer of a firm constructing, owning, operaing, or supplying the components of any such facility, who obtains information indicating that substantial safety hazards exist or that the facility contains defects which would create a substantial safety hazard, shall inunediately notify the NRC of the condition.

This regulation applies specifically to nuclear power plant " basic component" materials and activities, including design, inspection, testing, ,

and consulting services important to safety that are associated with the [

comoennt hardware, whether the services are performed by the component supplier or others.

The following terms are defined in 10 CFR 21:

(1) Defect - means any of the followings o a deviation in a basic component (including consulting services) which could create a substantial safety hasard, or the installation of such a component (Note the dissemination of faulty information also considered a " defect").

o a deviation in a system or portion of a facilty which could create a substantial safety hazard o a condition or circumstance involving a basic component that ,

l could contribute to the exceeding of a safety limit, as defined in the facility's technical specifications f ~19-1 wut

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. . GENERAL PHYSICS CORPORATION Quality As:ur:nce Manual

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R vicion 5 (Drcf t) o a deficiency in design and construction, which, were it to remain uncorrected, cold adversely affect the safety of plant operations at any time throughout the expected lifetime of the facility (2) Noncompliance - a failure to comply with the Atomic Energy Act of 1954, as amended, or any applicable rule, regulation,~ order of license of the Nuclear Regulatory Commission (the " Commission")

(3) Basic component - nuclear plant structure, system, component or part thereof necessary to assure; o the integrity of the reactor coolant pressure boundary o the capability to shut down the reactor and maintain it in a safe shut down condition o the capability to prevent or mitigate the consequences of accidents which would result in potential unacceptable offsite radiation exposures

" Basic component" includes design, inspection, testing, or consulting services important to safety that are associated with the component hardware.

(4) Substantial safety hazard - a loss of safety function to the extent that there is a major reduction in the degree of protection provided to public health and safety for the facility or associated activities.

Any Company personnel who discover a deficiency, defect, or condition of noncompliance, as defined above and which may represent a substantial safety hazard, shall immediately notify the Proejct Manager or his designee verbally and relate all known, pertinent information. Following the verbal communication, the individual shall document the information, in writing, in a memorandum to the Project Manager within 24 hours2.777778e-4 days <br />0.00667 hours <br />3.968254e-5 weeks <br />9.132e-6 months <br />. The Project Manager or his designee shall take immediate action to review the design bases or other requirements which constitute the basis for the alleged defect or noncompliance, examine the information presented, and confirm that a reportable condition exists.

If the reportable condition is the responsibility of the Owner (such as a defect or noncompliance detected in an operating facility or in existing materials representing an operating facility), reporting shall be handled as follows:

(1) When the reportable condition is identified and confirmed, the Project Manager or his designee shall immediately notify the owner verbally of the existir.g conditions and relate all known, pertinent information. The Project Manager shall also notify the Project Director verbally, and discuss all information that was obtained and related to the Owner.

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(2) Following the verbal communication, the Project Manager or his designee shall prepare a written report describing the existing conditions and transmit the report to the owner within five (5) days, along with a request that a copy of the resulting submittal l

to the Commission be forwarded to General Physics Corporation.

Copies of the written reort to the Owner shall be routed to the Project Director, the CQE, the Vice President and CAO, and the President and CEO.

(3) In this case, it is the responsibility of the Owner of the facility to notify the Commission of any reportable defects and noncompliances. If, however, it is determined that the Ownwer faciled to notify the Commission following the detection and reporting of such conditions by General Physics Corpoatin, then it is the responsibility of General Physics Corporation to notify the Commission and present all facts and information pertinent to the conditions.

If the reportable condition is the responsibility of General Physics Corporation (such as a defect or noncompliance detected in training materials or other consulting services which represent a substantial safety hazard), the following actions shall be taken:

(1) When the reportable condition is identified and confirmed, the Project Manager or his designee shall immediately notify the President and CEO or the Vice President and CAO verbally of the existing conditions and relate all known, pertinent information.

The President and CEO or Vice President and CAO shall then either -

nctify the Owner verbally of the reportsbic condition, or direct the Project Manager or his designee to immediately notify the Owner.

(2) The Project Manager or his designee shall also inform the Project Director of the identification, confirmation, and Owner-notification status of the reportable conditions.

(3) Fv11owing the verbal communication, the Project Manager or his designee shall prepare a written report describing the existing conditions for the President and CEO and the Vice President and CAO. The written report shall be prepared within 2 days after the information is obtained.

(4) Intiial notification by the President and CEO or the Vice President and CAO shall be made to the Director, Office of Inspection and Enforcement, or to the Administrator of the Regional Office within 2 days following receipt of the information. If the initial notification is by means other than written communication, a written report will be submitted within 5 days af ter the information is obtained. All reports to the Commission shall conform to the regruiements of 10 CFR 21.21,

" Notification."

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GENERAL PHYSICS CORPORATION Quality As urtnce Manual Revision 5 (Drtf t)

Copies of all relevant memoranda, reports or other documents shall be retained by the Project Manager or his designee for inclusino in the project quality assurance records file.

Copies of all relevant memoranda and reports of defects or noncompliances shall be routed by the Project Manager or his designee to the CQE for review and inclusion in the quality assurance records file.

19.3 Nuclear Power Plant Training Program Review General Physics Corporation performs work for electric utility companies and other clients which involves development and implementation of training programs for nuclear power plant personnel. The construction and operation of these power plants is regulated by the Nuclear Regulatory Commission (NRC) in accordance with the Code of Federal Regulations. It is the policy of the Company in its work related to nuclear power plants to support and promote the regulatory responsibilities of the NRC and the client. Accordingly, all nuclear power plant training porgram materials prepared by the Comany which are not reviewed by the client prior to presentation shall be reviewed by a member of the Training Material Review. Committee, as a minimum, for consistency with this policy. Any inconsistencies shall be corrected immediately, and all review activities 'shall be reported to the President and CEO and the Vice President and CAO.

It is also the policy of the Company to obtain course evaluations from all trainees ~who participate in neulear power plant training programs i conducted by the Company. All such course evaluations shall be reviewed by {'

the Project Manager and independently revie w ed by the cognizant supervision of the Project Manager. Any deficiencies or defects identified by these course evaluations shall be corrected immediately by the Project Manager. Any reportable deficiencies or defects which are identified shall be reported immediately to the President and CEO and to the Vice President CAO in accordance with Section 19.2.

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GENERAL PHYSICS CORPORATION 10630 HICKOR Y RfDGE ROAD COLUMBIA, MARYLAND 2l044 301 964-6000-301 932 1240 ROBERT W. DEUTSCH President and Chainnan of the Board September 4, 1985 GP-L-010747

Dear,

On November 29-30, 1983, you attended a course-on " Containment Leakage System Testing" given by General Physics Corporation at the Oyster Creek Station. An article in several papers and the television news on September 1, 1985, states that all participants in the course were coached by General Physics to possibly deceive the NRC in regard to the leakage test programs.

The basis for these charges are three pages in the lecture, " Interactions with the NRC". In reviewing the course comments from you and other course partici-pants, there was no indication that any of the course participants considered this information as mechanism to circumvent NRC regulations. This course was taught one additional time, and General Physics changed the content of the three slides that could be misinterpreted.

Based on the notoriety that has been given to the lecture, " Interaction with the NRC", it is suggested that all of this material be totally deleted from the course manual in your possession.

This deletion does not detract from the objective of the course which was to instruct individuals in Nuclear Regulatory Requirements, in particular Appendix J to the Code of Federal Regulations, Part 50, as well as industry codes and standards. This course was designed to be generic in nature and present information on how to perform, calculate, and determine the accept-ability of the integrated leak rate test and the leak rate test on specific valves. Based on the course comments, we believe we accomplished this objective.

Sincerely yours, GENERAL PHYSICS CORPORATION Robert W. Deutsch President RWD tl l

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d The Company shall insure that the quality of the items and services it Providea conforms to established requirements. The Company recognizes the fundamental importance of quality assurance policies, plans, procedures and activities in contributing to the overall quality of these items and services. Accordingly, the Company will operate in accordance with a Quality Assurance Program as defined in the Quality Assurance Manual, which establishes the policies and practices for the assurance of quality on Company projects.

The Vice President and CAO shall be responsible to the President for all matters related to the quality of Company products and services with authority as established in the Quality Assurance Manual. He or she shall be responsible for the issuance and control of the Manual. He or she shall designate the members of the Quality Advisory Committee, which shall review and audit the implementation of quality assurance policies and practices in accordance with the Quality Assurance Manual.

All Corporate management personnel shall be fully knowledgeable of the policies and practices described in the Quality Assurance Manual. All Company l

project personnel are responsible for knowing and implementing the quality

! assurance requirements established for their respective projects.

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)- k' 4, UNITED STATES 8 c,% NUCLEAR REGULATORY COMMISSION i

• E WASHINGTON, D. C. 20555 J /

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August 26, 1985 MEMORANDUM FOR: File FROM: James M. Taylor, Director

. Office of Inspection and Enforcement

SUBJECT:

GENERAL PHYSICS CORPORATION With reference to the attached letter to General Physics Corporation, I was called at my home on Saturday, August 24, 1985 by Mr. Whitney, Vice President. Mr. Whitney told me the following:

1. Theccurse,"ContainmentSystemsLeakageTesting7asdescribed in the outline of Lecture #3 had been taught only once.

That had been for the Oyster Creek Station of GPU on November 29 and 30, 1983.

2. Based on a student's coments which were critical of a portion on interaction with the NRC, the course had been revised.

The revised course was taught only one more time in Columbia, Md.

Personnel from BG&E, HL&P, CP&L, Duquesne, Vepco, Texas Utilities, and Consumers had attended.

3. He (Mr. Whitney) will send me a copy of the revised course.with further details.

\ _

Et ."Ta r, irector Of ice of spection and Enforcement cc: W. Dircks -

V. Stello H. Denton G. Cunningh m B. Grimes J. Partlow E. Jordan J. Blaha Regional Administrators

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