Information Notice No. 85-101: Applicability of 10 CFR 21 to Consulting Firms Providing Training
SSINS No.: 6835
NUCLEAR REGULATORY COMMISSION
OFFICE OF INSPECTION AND ENFORCEMENT
WASHINGTON, DC 20555
December 31, 1985
Information Notice No. 85-101: APPLICABILITY OF 10 CFR 21 TO CONSULTING.
FIRMS PROVIDING TRAINING
All nuclear power facilities holding an operating license (OL) or a
construction permit (CP).
This information notice is provided to inform licensees and consultants of a
potential generic problem concerning the applicability of 10 CFR 21 to
certain training activities provided by consultants. It is expected that
recipients will review the information for applicability to their facilities
and consider actions, if appropriate, to preclude similar problems from
occurring at their facilities. However, suggestions contained in this infor-
mation notice do not constitute NRC requirements; therefore, no specific
action or written response is required.
Recently, the NRC performed a vendor inspection of a company that supplies
consulting services, including training, to the nuclear industry. During
this inspection, it was noted that licensees had failed to appropriately
impose 10 CFR 21 on the consultant providing training. The Commission is
taking this opportunity to remind licensees of their responsibilities under
10 CFR 21.
Paragraph 21.3(a)(3) of 10 CFR 21 states: "In all cases 'basic component'
includes design, inspection, testing, or consulting services...." Training,
which is provided as a consulting service, is therefore subject to the pro-
visions of 10 CFR 21 when the training is associated with a basic component
as defined in paragraph 21.3(a)(1) of 10 CFR 21 [for example, nondestructive
examination training, inservice inspection (ISI) or testing (IST) training].
Licensee procurement of such training services must therefore specify the
applicability of 10 CFR 21. Any "deviations" found in the training material
by consultants must be evaluated by the contractor or reported to the
licensee for evaluation, and any "defects" which could have an impact on the
component hardware must be reported to the NRC as provided in 10 CFR 21.
December 31, 1985
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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
Attachments: List of Recently Issued Information Notices
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