Information Notice No. 85-88: Licensee Control of Contracted Services Providing Training

                                                         SSINS No.: 6835 
                                                            IN 85-88       

                                UNITED STATES
                        NUCLEAR REGULATORY COMMISSION
                    OFFICE OF INSPECTION AND ENFORCEMENT
                           WASHINGTON, D.C. 20555

                              November 18, 1985

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 
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          *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. 
.

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                                                       November 18, 1985 
                                                       Page 3 of 3      

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. 


                                   Edward L. Jordan Director 
                                   Division of Emergency Preparedness 
                                     and Engineering Response 
                                   Office of Inspection and Enforcement 

Technical Contact:  E. W. Merschoff, IE
                    301-402-9045

Attachments: List of Recently Issued IE Information Notices