ML20236Q091
| ML20236Q091 | |
| Person / Time | |
|---|---|
| Issue date: | 11/17/1987 |
| From: | Haass W, Potapovs U Office of Nuclear Reactor Regulation |
| To: | |
| Shared Package | |
| ML20236Q065 | List: |
| References | |
| REF-QA-99900403 NUDOCS 8711190175 | |
| Download: ML20236Q091 (14) | |
Text
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ORGANIZATION:
GENERAL ELECTRIC COMPANY NUCLEAR ENERGY BUSINESS OPERATIONS SAN JOSE, CALIFORNIA 95125 REPORT INSPECTION INSPECTION NO.:
99900403/87-04 DATE:
9/15-16/87 ON-SITE HOURS:
36 CORRESPONDENCE ADDRESS: General Electric Company Nuclear Energy Business Operations ATTN: Mr. N. L. Felmus, Vice President and General Manager 175 Curtner Avenue San Jose, California 95125 ORGANIZATIONAL CONTACT: Mr. James Fox, Senior Program Manager, QA TELEPHONE NUMBER:
408-925-6195 NUCLEAR INDUSTRY ACTIVITY:
Design and manufacture of BWR-NSSSs and related systems, components and services.
Primary current activity is supply of spare and replacement parts and services.
ASSIGNED INSPECTOR:
('d
///S/87 cw Walter P. Haass, Special Projects Inspection Date Section(SPIS)
OTHER INSPECTOR (S):
Robert L. Pettis, Jr. (SPIS)
APPROVED BY:
fl-1 1-f /
Uldis Potapovs, Chief,ISPIS, Vendor Inspection Branch Date INSPECTION BASES AND SCOPE:
A.
BASES:
10 CFR Part 50, Appendix B, and 10 CFR Part 21 B.
SCOPE: This inspection was performed to determine General Electric's conformance to the requirements of 10CFR50, Appendix B, and 10CFR Part 21 in the performance of contractual work involving training of nuclear plant personnel (other than reactor operators).
The inspection was prompted in part by an allegation by a former employee regarding deficiencies in i
the training services areas.
PLANT SITE APPLICABILITY: All BWR-type nuclear plants for which General Electric provides training of plant personnel.
8711190175 871117 PDR GA999 ENVGENE 99900403 PDR
4 2
ORGANIZAT10N: GENERAL ELECTRIC COMPANY NUCLEAR ENERGY BUSINESS OPERATIONS RAN.109F CAI T 0RNI A REPORT INSPECTION N0.: 99900403/87-04 RESULTS:
PAGE 2 of 8 A.
VIOLATIONS:
There were no violations. identified as a result of this inspection.
B.
NONCONFORMANCE:
There were no nonconformances identified as a result of this inspection.
C.
UNRESOLVED ITEMS:
There were no unresolved items identified as a result of this inspection.
]
D.
STATUS OF PREVIOUS INSPECTION FINDINGS:
This is the first NRC inspection of the vendor's training activity.
E.
OTHER FINDINGS AND COMMENTS:
1 1.
Training Services Offered at San Jose General Electric's Maintenance and Technical Training Services organization in San Jose offers training courses in maintenance, engineering, instrumentation and control, and refueling floor activities with a total instructor staffing level of 16. The training courses address system and components supplied to utilities by General Electric as an NSSS vendor. The courses are offered to utilities operating BWRs for training of their nuclear plant personnel (other than reactor operators) either at the plant site or in San Jose. Appropriate hardware training aids and facilities are provided at either location.
General Electric also offers other courses at training centers located at Shorewood, Illinois; Vallecitos Nuclear Center; and Morris, Illinois as well as at customer sites.
The inspectors toured the training facilities at San Jose. The facilities included classrooms; a simulated refueling floor including a reactor vessel, cranes, BWR internals, and refueling platform; maintenance areas for jet pumps, stud tensioner, control rod drives, main steam isolation valves, standby liquid control system explosive valves, safety / relief valves, recirculation pump seals, and reactor water cleanup pumps; 18C equipment including a neutron monitoring system; and I&C maintenance areas including source range monitoring /
intermediate range monitoring detector drive, and traversing incore probe system.
l ORGANIZATION: -GENERAL ELECTRIC COMPANY NUCLEAR ENERGY BUSINESS OPERATIONS RAN JORF. CALI 0RNIA
. REPORT INSPECTION l
NO.: 99900403/87-04 RESULTS:'
PAGE 3 of 8 2.
Quality Assurance General Electric indicated that appropriate QA controls from their NRC approved topical report, NED0-11209 (QA program description),
have been applied to the training services activity even though no aspects of this activity were considered to be safety-related up until mid-to-late 1986.
In mid-1986, a purchase order was received from utility licensee (LILCO) for safety-related training. This prompted action to consider and develop more specific requirements and safety-related QA for training activities.
By December 1986, General Electric had established some safety-related requirements for training services and had developed initial procedures and pertinent forms for the implementation of QA controls.
The controls established requirements for proposal authorizations, software files, instructor qualifications, and the anticipated need for purchaser audits. Sign-off forms were made available for course materials.
j In January 1987, General Electric initiated the categorization of training courses into safety-related and non-safety-related groups.
The basis for this categorization was the Master Parts List (MPL)-
if the training course addressed a safety-related item from the MPL, then it in turn was categorized as safety-related.
General Electric classifies all hardware training aids (i.e.,
simulators) as non-safety-related because such items do not directly I
perform a safety function. A procedure to control the quality of such training aids was issued in January 1987.
In March 1987, a set of forms to document the quality of the various, training course materials and a more comprehensive list of safety-related courses were issued.
The forms attest to the quality of text training material, lesson plans, test material, course reference material, and instructor qualifications.
In September 1987, Nuclear Training Services (NTS) management issued q
a memorandum that announced the initiation of development of a quality assurance program for the NTS business area. This resulted apparently from a recent internal audit.
The memorandum continued the implementation of certain QA requirements previously promulgated and instituted other new guidelines for immediate impleme.ntation.
The memorandum directed that the new NTS QA program be in place by December 31, 1987 for implementation.
[
ORGANIZATION: GENERAL ELECTRIC COMPANY NUCLEAR ENERGY BUSINESS OPERATIONS RAN.10%F. CAI T ~0RNI A REPORT INSPECTION NO.: 99900403/87-04 RESULTS:
PAGE 4 of 8
. Based on the above, it is concluded that General Electric is actively pursuing the development of a formalized QA program for the San Jose training services activity that is intended to satisfy NRC require-l ments for safety-related training. The inspectors found the i
approach to safety-related QA and the schedule objective for develop-ment of the program to be acceptable subject to later confirmatory review.
3.
10CFR Part 21 With the NRC's issuance of Information Notice 85-101, " Applicability of 10CFR21 to Consulting Firms Providing Training", dated December 31, 1985, General Electric NTS recognized the need to implement the requirements of Part 21 in their training services business area.
In December 1986, a memorandum was issued to NTS personnel directing the implementation of Part 21 for identified nonconformances, errors, and defects in training course text material, proposals and instructor qualifications.
It invoked NEB 0 Policy and Procedures 70-42, previously available for. the manufacturing of basic components including related design, procurement and test activities, for the training services activity. While the policy was applied to training, it did not result in any potentially reportable conditions.
It was noted that General Electric issues annual reminders to their personnel regarding the need for renewed familiarity with Part 21 requirements and for reporting of identified defects and non-compliances in training software.
The inspectors concluded that General Electric had adequately committed to the implementation of Part 21 in the training services area.
4.
Purchase Orders The inspectors reviewed ten purchase orders (P0s) from utilities for procurement of training services. These P0s were accepted by General Electric during the period of April 21, 1986 to August 17, 1987.
The earlier P0s included no requirements for the implementation of safety-related QA or 10CFR Part 21 while the later ones tended to include both. This is consistent with General Electric's, and the utility licensees', increasing commitment to safety-related QA and compliance to 10 CFR Part 21 for the training service area.
i..
ORGANIZATION: GENERAL ELECTRIC COMPANY NUCLEAR ENERGY BUSINESS OPERATIONS SAN JOSF. CALIFORNIA REPORT
. INSPECTION NO.: 99900403/87-04 RESULTS:
PAGE 5 of 8 5.
Training Documents Several folders of training documents for courses delivered to utilities were reviewed to determine the degree of conformance to management directives on safety-related QA.
It was observed that in several folders, the required forms were not always present or completed as directed. The inspectors also noted course critiques offered by students that identified incorrect instructions, and a lack of consistency between the training aid and the actual plant hardware. General Electric stated that many of the training courses present the general concepts of operation of a component or system rather than the specifics of the plant equipment, and therefore might even employ equipment from another plant or BWR series. The inspectors suggested that this is an area that needs to be clarified and that, if a concepts course is presented, a portion of the class time should be devoted to explaining the relationship between the concepts and the plant specific hardware. The need for concepts or plant-specific information should be clarified in the P0.
The inspectors found the training documents to be in a state of transition regarding the implementation of safety-related QA.
6.
Instructor Training / Certification The inspectors reviewed several General Electric programs fcr the training of instructors. These included a workshop for classroom instructor techniques, principles for development of training systems, and a program for the qualification of instructors.
Instructor certification records were reviewed; these records include educa-tional background, identification of courses qualified to teach, instructional capability certification, and the means by which the qualification requirements are satisfied (i.e., job performance reviews, NTS basic instructor course, or other formal courses).
It was concluded that the program for training and certification of instructors was adequate.
7.
Audits General Electric had performed annual internal audits of its training services area beginning in 1980 relative to commitments contained in the NRC accepted QA topical report. However, only thr.ee, in 1981, 1983, and 1987, addressed the San Jose training services activity.
No significant deficiencies were identified in the 1987 audit report.
I I
ORGANIZATION:
GENERAL ELECTRIC COMPANY NUCLEAR ENERGY BUSINESS OPERATIONS 9AN JOSF. CAtTFORNIA REPORT INSPECTION N0.: 99900403/87-04 RESULTS:
PAGE 6 of 8 No audits of the GE/NTS activities were performed by utility customers. However, initiation of outside auditing is anticipated to occur in the near future as more utilities include requirements for safety-related QA and 10CFR Part 21 in their P0s.
The inspectors concluded that internal auditing of the General Electric's training services activities is expected to increase as the new safety-related QA program is developed and implemented.
Auditing by utility customers is also anticipated to increase.
8.
INPO Guidelines The Institute of Nuclear Power Operations (INP0) has established procedures, objectives, and criteria for the production of well-qualified and competent personnel to operate nuclear power plants.
INP0 is in the process of accrediting the nuclear utilities' plant personnel under this program which is described in INPO 85-002, Rev 1, "The Accreditation of Training on the Nuclear Power Industry" dated September 1985. Areas of training accreditation also offered by GE/NTS-San Jose include instrumentation and control, electrical maintenance, mechanical maintenance, radiation protection, and chemistry.
In reviewing utility P0s and General Electric's training documentation, the inspectors noted some recognition of the need to specify and satisfy the INP0 objectives and criteria. General Electric indicated that programmatic changes are planned for incor-portation into the developing training program controls that will ultimately assure conformance of General Electric's offerings to the INP0 objectives and criteria. The inspectors concluded that this approach is satisfactory subject to further review in subsequent inspections.
9.
Interview of Instructor The inspectors briefly interviewed one of the NTS instructors who was involving with Nuclear Measurements Analysis and Controls (NUMAC) training. The instructor indicated the following:
the training courses offered are generally conceptual or generic in nature rather than plant specific. The inspectors believe this needs to be recognized and emphasized by the instructor.
i
' ORGANIZATION: GENERAL ELECTRIC COMPANY NUCLEAR ENERGY BUSINESS OPERATIONS 9AN.1n9F. rAlTTORNIA REPORT INSPECTION NO.: 99900403/87-04 RESULTS:
PAGE 7 of 8 l
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the instructors generally have an adequate amount of time l
to prepare for up' coming courses.
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the additional paperwork to satisfy safety-related QA l
requirements can be prepared in 1 to 2 hours2.314815e-5 days <br />5.555556e-4 hours <br />3.306878e-6 weeks <br />7.61e-7 months <br />.
L hardware training afds are generally functional, and it is useful if the instructor can correct problems as they arise.
there was a lack of familiarity by the instructor inter-viewed with the provisions for implementation of 10CFR i
Part 21.
- 10. Conclusions As a result of this inspection, it was concluded that General Electric's program for providing training services to utility-licensees is currently in a state of transition in which the quality assurance controls are being formalized and revised to conform better to safety-related requirements. This action was prompted by the NRC's issuance of Information Notice 85-101 (dated December 31, 1985) and the receipt of a utility purchase order for safety-related training in mid-1986.
Until that time frame, General Electric, and their utility customers, did not consider training services to be safety-related although it was stated by General Electric that the appropriate provisions of their QA topical report, NEDO-11209,
" Quality Assurance Program," were always applied.
In December 1986, General Electric issued directions to its employees for implementa-tion of 10 CFR Part 21 in the training services area.
The inspec-tion substantiated that the allegation regarding deficiencies in the.
training services area were in part valid.
General Electric has committed to the establishment of more formalized safety-related quality assurance programmatic controls for the training services area by the end of 1987.
F.
PERSONS CONTACTED:
- # James Fox, Senior Program Manager, QA
- # Ted Krishisky, Senior Program Manager, NTS
- # John A. Berry, Senior Program Manager, NTS
- # Barton A. Smith, Counsel, Legal
- # Charles Lanham, Acting Manager, M&T Training William Chittenden, Program Manager, M&T Training
ORGANIZATION: GENERAL ELECTRIC COMPANY NUCLEAP. ENERGY BUSINESS OPERATIONS SAN JOSF. CALI 0RNIA REPORT INSPECTION N0.: 99900403/87-04 RESULTS:
PAGE 8 of 8 Caroline Smith, Senior Instructor, Eng'g Training
- # Joe M. Case, System Manager, QA
- # Ivan F. Stuart, Manager, QA
- # George Stramback, Safety Evaluations Program Manager, Licensing
- James C. Larrew, Nuclear Services QA Manager
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.Dl General Electric Company 2-November 17, 1987 In accordance with 10 CFR 2.790 of the Commission's regulations, a copy of this letter, and the enclosed inspection' report will be placed in the NRC's Public Document Room.
Should'you have any questions concerning this inspection, we will be pleased to discuss them with you.
Sincerely, James C. Stone Acting Chief Vendor Inspection Branch Division of Reactor Inspection and Safeguards Office of Nuclear Nuclear Reactor Regulation DISTRIBUTION:
/,R4CS Code IE:09 DRIS Reading VIB Roading JPartlow BGrimes JStone UPotapovs WHaass(2)
RPettis LParker JPetrosino RBrady JPersenky
- See previous page for concurrences.
OFC :VIB:DRIS
- SC/VIB:DRIS :ABC/VIB:DRIS:
NAME :WHaass:jh*
- UPotapovs*
- JStone*
DATE :11/06/67-
- 11/09/87
- 11/16/87
)
i General Electric Company
-2 November 17, 1987 In accordance with 10 CFR 2.790 of the Commission's regulations, a copy of this letter and the enclosed inspection report will be placed in the NRC's Public Document Room.
Should you have any questions concerning this inspection, we will be pleased to discuss them with you.
Sincerely, James C. Stone, Acting Chief Vendor Inspection Branch Division of Reactor Inspection and Safeguards Office of Nuclear Nuclear Reactor Regulation DISTRIBUTION:
RIDS Code IE:09 DRIS' Reading VIB Reading JPartlow BGrimes JStone UPotapovs WHaass (2)
RPettis LParker JPetrosino RBrady JPersenky
- See previous page for concurrences.
OFC :VIB:DRIS
- SC/VIB:DRIS :ABC/VIB:DRIS:
NAME :WHaass:jh*
- UPotapovs*
- JStone*
DATE :11/06/87
- 11/09/87
- 11/16/87 i
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