Information Notice No. 85-101: Applicability of 10 CFR 21 to Consulting Firms Providing Training

                                                           SSINS No.:  6835
                                                            IN 85-101 

                                UNITED STATES
                        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 

Addressees:  

All nuclear power facilities holding an operating license (OL) or a 
construction permit (CP). 

Purpose: 

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. 

Discussion: 

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. 



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                                                       IN 85-101 
                                                       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 
                    301-492-9045 

Attachments:   List of Recently Issued Information Notices