IE Circular No. 80-21, Regulation of Refueling Crews

                                                           SSINS No.: 6820 
                                                           Accession No.: 
                                                           IEC 80-21      

                                UNITED STATES
                           WASHINGTON, D.C. 20555

                             September 10, 1980


Description of Circumstances: 

Recent inspections of refueling activities indicate that some licensees have
misinterpreted the regulatory requirements applicable to fuel handling 
activities. Therefore, it appears appropriate to identify those specific 
regulatory requirements that are applicable to core alterations which 
include reactivity manipulations that may result from the handling of fuel 
elements, control rods, etc. 

A.   10 CFR Requirements 

     1.   10 CFR 50.2(f) and 10 CFR 55.4: 

          "Controls" when used with respect to a nuclear reactor means 
          apparatus and mechanisms, the manipulation of which directly 
          affect the reactivity or power level of the reactor. 

     2.   10 CFR 50.54(i): 

          Except as provided in 55.9 of this chapter, the licensee shall not
          permit the manipulation of the controls of any facility by anyone 
          who is not a licensed operator or senior operator as provided in 
          Part 55 of this chapter. 

     3.   10 CFR 55.3: 

          No person may perform the function of an operator as defined in 
          this part except as authorized by a license issued by the 

     4.   10 CFR 55.4: 

          "Operator" is any individual who manipulates a control of a 
          facility. An individual is deemed to manipulate a control if he 
          directs another to manipulate a control. 

          "Senior Operator" is any individual designated by a facility 
          licensee under Part 50 of this chapter to direct the licensed 
          activities of licensed operators. 

     5.    10 CFR 55.9: 

           Nothing in this part shall be deemed to require a license for: 

           a.   An individual who manipulates the controls of a research or 
                training reactor as part of his training as a student in a 

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                                                        September 10, 1980 
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          nuclear engineering course under the direction and in the presence
          of a licensed operator or senior operator; 

     b.   An individual who manipulates the controls of a facility as a part
          of his training to qualify for an operator license under this part
          under the direction and in the presence of a licensed operator or 
          senior operator. 

B.   Technical Specifications 

     Standard Technical Specifications require that all core alterations be 
     directly supervised by either a Licensed Senior Reactor Operator or 
     Senior Reactor Operator limited to fuel handling, who has no other 
     concurrent responsibilities during this operation. The NRC interprets 
     the term "directly supervised" to mean that the SRO is supervising the 
     core alterations from the refueling deck. 

     We note that the Licensed Senior Reactor Operator limited to fuel 
     handling classification was developed for specialized fuel handling 
     crews. In this case an individual identified as a Refueling Foreman is 
     responsible for refueling activities subject to the following 

     1.   The foreman shall have a Senior Operator's License limited to the 
          fuel handling duties. 

     2.   The foreman shall directly supervise (from the refueling deck) the
          movement of fuel in and out of the reactor. 

     3.   The unlicensed members of the crew shall participate in 
          appropriate facility administered training programs and be 
          facility certified to perform their duties. 

     4.   Direct communication will be maintained with a licensed individual
          in the control room when fuel movements over the core are being 

     5.   The foreman will exercise indirect supervision over all other fuel
          handling operations. 

Based on the NRC regulations delineated in Item A above, the individual 
manipulating the fuel-handling equipment over the reactor must be an NRC 
Licensed Reactor Operator (RO) unless the facility Technical Specifications 
include provisions for the operation to be supervised by an SRO or SRO 
limited to fuel-handling as described in Item B. During any core alteration,
a licensed individual must also be observing reactivity monitors in the 
Control Room with appropriate communications established with personnel on 
the fuel handling equipment. In addition, personnel participating directly 
in the core alternations must meet the qualification and training 
requirements committed to in the FSAR or fuel loading application, i.e., 
ANSI N18.1-1971 or ANSI/ANS 3.1-1978. 

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                                                        September 10, 1980 
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Recommended Action for Licensee Consideration 

Our routine inspection program for refueling activities is based on the 
above NRC requirements. Therefore, we recommend that all reactor licensees 
review procedures and practices to assure that the individuals responsible 
for and participating in refueling activities are in conformance with the 
above requirements. 

No written response to this Circular is required. If you require additional 
information with regard to this subject, please contact this office. 


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