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Information Notice No. 94-13, Supplement 2: Control And Oversight of Contractors During

Refueling Activities and Clarification of Applicability of Section 50.120 of Title 10 of the Code Of

Federal Regulations to Contractor Personnel

 UNITED STATES

 NUCLEAR REGULATORY COMMISSION

 OFFICE OF NUCLEAR REACTOR REGULATION

 WASHINGTON, D.C. 20555-0001

 November 28, 1995

NRC INFORMATION NOTICE 94-13, SUPPLEMENT 2: CONTROL AND OVERSIGHT OF

 CONTRACTORS DURING REFUELING 

 ACTIVITIES AND CLARIFICATION OF

 APPLICABILITY OF SECTION 50.120

 OF TITLE 10 OF THE CODE OF

 FEDERAL REGULATIONS TO CONTRACTOR

 PERSONNEL

Addressees

All holders of operating licenses or construction permits for nuclear power

reactors.

Purpose

The U.S. Nuclear Regulatory Commission (NRC) is issuing this information

notice supplement to alert addressees to recent plant events that involved

inadequate control and oversight of contractor activities and to advise

licensees of the applicability of NRC regulations on personnel training and

qualification to contractor personnel. It is expected that recipients will

review the information for applicability to their facilities and consider

actions, as appropriate, to avoid similar problems. However, suggestions

contained in this information notice supplement are not NRC requirements;

therefore, no specific action or written response is required.

Background

The NRC issued Information Notice (IN) 94-13, "Unanticipated and Unintended

Movement of Fuel Assemblies and Other Components Due to Improper Operation of

Refueling Equipment," on February 22, 1994, to alert addressees to problems

that could result from inadequate oversight of refueling operations and

inadequate performance on the part of refueling personnel. Following its

issuance, the NRC received numerous informal comments from licensees

indicating that a statement in IN 94-13 implied a broader applicability to

contract personnel than was supported by the regulation at Title 10, Code of

Federal Regulations, Part 50.120. One purpose of this supplement of IN 94-13

is to clarify this point.

IN 94-13 described various refueling events at the Vermont Yankee, Peach

Bottom, Susquehanna, and Nine Mile Point plants. These events demonstrated

the importance of proper controls over, and operation of, refueling equipment

during use. IN 94-13, Supplement 1, issued on June 28, 1994, described an

event at the Waterford Steam Electric Station that demonstrated the potential

for fuel damage or personnel hazards that could result from fuel-handling

equipment that is not properly stored and not secured from unauthorized use. 

9511210402. IN 94-13, Supp. 2

 November 28, 1995

 Page 2 of 4

Since Supplement 1 was issued, events have occurred at Edwin I. Hatch Nuclear

Plant, Units 1 and 2, that demonstrate the potential for equipment damage and

personnel hazards as a result of inadequately supervised contractor activities

on the refueling floor. A second purpose of this supplement of IN 94-13 is to

address these events.

Description of Circumstances

At Hatch Unit 1, on December 28, 1994, seven shroud head bolts that had been

replaced during the November 1994 refueling outage were being removed from the

Unit 1 spent fuel pool (SFP) by contract personnel for shipment off site. As

the first bolt was rigged and lifted about 1 foot above the water surface, the

rigging failed and the bolt fell back into the SFP, puncturing the stainless

steel liner of the SFP. Water from the SFP drained into the area between the

stainless steel liner and the outer concrete wall causing the SFP water level

to drop about 3 inches. Operations personnel were not initially informed of

the dropped bolt but after determining that the liner was punctured, closed

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the outer concrete structure tell-tale drain valve, which stopped most of the

SFP water leakage to the reactor building drains.

A review of this event (NRC Inspection Report 50-321/94-31, dated 

February 2, 1995) indicated that a licensee supervisor was not present on the

refueling floor when the bolt was dropped. In preparation for the bolt

removal activity, seven rigging slings were fabricated on site. Some of the

rigging slings were fabricated incorrectly by contract personnel who were not

trained or qualified to construct them. The steps required to correctly

fabricate rigging slings were provided through vendor-supplied instructions

rather than by plant procedures.

In another event at the Hatch plant, on November 11, 1994, contract personnel

were preparing spent control rod blades for shipment off site. Highly

radioactive stellite ball bearings were removed and transported through the

transfer canal, to be placed in a storage cask in the cask pit. Not finding

the correct tool to unbolt the storage cask lid, the contract foreman decided

to transfer the bearings into a different container and continue the

collection process. The licensee refueling floor supervisor, who was

contacted at home, concurred with the plan. However, this container transfer

occurred in the transfer canal rather than in the cask pit and several

bearings were dropped onto the transfer canal floor, producing a high

radiation field in the adjacent accessible area beneath the transfer canal. 

The personnel involved in this activity failed to inform the refueling floor

coordinator (RFC), their immediate supervisor, the HP supervisor, or the

control room operators that the bearings had been dropped.

A review of this event (NRC Inspection Report 50-321/94-31, dated 

February 2, 1995) indicated a deficiency in management oversight of refueling

floor activities. Contract personnel failed to immediately inform supervision

when abnormal conditions exist. In addition, plant procedures did not contain

steps detailing how the stellite ball transfer should be conducted, nor did

they contain any precautions for personnel protection.. IN 94-13, Supp. 2

 November 28, 1995

 Page 3 of 4

In a third incident at the Hatch plant on November 8, 1994 (NRC Inspection

Report 50-321/94-28, date December 29, 1994), during a routine "quality check"

and subsequent surveys, the licensee discovered approximately 50 pieces of

contaminated scaffolding in the scaffolding yard, which is not a

radiologically controlled area. The material had been passed through the

automated materials frisker (AMF) by contract personnel.

A review of this event by the licensee determined that the contract personnel

responsible for operating the AMF were not fully trained or qualified to

perform the task. In addition, plant procedures did not provide specific

instructions for performing the frisking activities. An inspection of the

equipment indicated that the material frisker contained damaged detectors and

that the setpoint had drifted. Although the equipment damage and malfunctions

contributed to this event, they did not result from contractor actions. 

Discussion

Contract personnel frequently perform activities that are safety significant

but that are not conducted on a routine basis. These activities are often

performed by contractor personnel at the direction of the licensee, but

frequently not under the direct supervision of licensee personnel. As shown

by the events described above, licensee supervision of fuel handling

personnel, including contractors, proved to be inadequate to ensure proper and

safe performance of safety significant activities. 

Questions have arisen concerning the applicability of Section 50.120,

"Training and Qualification of Nuclear Power Plant Personnel," of Title 10 of

the Code of Federal Regulations (10 CFR 50.120) to contractor personnel. The

rule requires that nine categories of nuclear power plant personnel be trained

by programs developed, implemented, and maintained using a systems approach to

training (SAT). As discussed in the supplementary information section of the

publication of the final rule (58 FR 21904), this rule applies to the licensee

personnel who operate or supervise the operation of the refueling equipment

and applies to the training and qualification of some categories of contractor

personnel. "Qualification" in the context of the training rule means

demonstration by an individual for evaluation purposes of the ability to

successfully perform specific tasks, including operation of refueling

equipment.

Contractor personnel occupying regular positions and working independently

within the licensee organization take the place of licensee personnel and,

therefore, are covered by the requirements of 10 CFR 50.120. Short-term

contractors, if assigned to work independently, must be qualified to perform

the assigned tasks. Short-term contractor personnel assigned to work under

the direct supervision of licensee personnel are not required to comply with

the requirements for SAT-based training identified in 10 CFR 50.120.. IN 

 November 28, 1995

 Page 4 of 4

In the original IN 94-13, in the second paragraph of the discussion section,

the statement, "This rule applies to the personnel (including contractors) who

operate or supervise the operation of the refueling equipment," thus should

read, "This rule applies to the personnel, which may include contractors, who

operate or supervise the operation of the refueling equipment."

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The cases discussed in IN 94-13 included instances of licensees failing to

conduct appropriate training in the use of refueling equipment, particularly

with respect to design modifications made to the controls for the fuel mast. 

These cases also indicated that fuel-handling personnel, including

contractors, were occasionally not aware that licensee management expected

them to identify deviations from anticipated results, cease operations under

unexpected or abnormal conditions, and notify the licensee operations or plant

management staff of those conditions.

This information notice requires no specific action or written response. If

you have any questions about the information in this notice, please contact

one of the technical contacts listed below or the appropriate Office of

Nuclear Reactor Regulation (NRR) project manager.

 /S/'D BY BKGRIMES/FOR

 Dennis M. Crutchfield, Director

 Division of Reactor Program Management

 Office of Nuclear Reactor Regulation

Technical contacts: Mary Ann Biamonte, NRR

 (301) 415-1073

 Vern Hodge, NRR

 (301) 415-1861

 Bob Holbrook, RII

 (912) 367-9881

Attachment:

List of Recently Issued NRC Information Notices

Page Last Reviewed/Updated Friday, May 22, 2015

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