United States Nuclear Regulatory Commission - Protecting People and the Environment

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
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 94-13, Supp. 2
                                                            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."

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:
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