05000331/FIN-2013002-03
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Finding | |
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Title | Failure to Implement and Maintain Procedures Regarding Breathing Air Quality |
Description | A finding of very low safety significance and associated non-cited violation of 10 CFR 20.1703 was identified by the inspectors on January 18, 2013, for the licensees failure to implement and maintain written procedures regarding breathing air quality and self-contained breathing apparatus (SCBA) inspections. These issues were entered into the licensees CAP as CRs 01840046, 01839697, and 01839666. Corrective actions included air quality tests that were subsequently performed resulting in Grade D or better, and completing breathing air and monthly SCBA inspections. Additionally, the licensee was in the process of establishing a tracking mechanism to ensure these tests and inspections were appropriately scheduled for completion. The inspectors determined that not consistently performing the Grade D air quality tests or SCBA monthly inspections was a performance deficiency, the cause of which was reasonably within the licensees ability to foresee and correct, and should have been prevented. The performance deficiency was determined to be of more than minor safety significance because if left uncorrected, not performing testing of breathing air quality and SCBAs would have the potential to lead to a more significant safety concern. In accordance with IMC 0609, Appendix C, Occupational Radiation Safety Significance Determination Process, the inspectors determined that the finding had very low safety significance (Green) because the finding did not involve: (1) as-low-as-is-reasonably-achievable (ALARA) planning and controls, (2) a radiological overexposure, (3) a substantial potential for an overexposure, or (4) a compromised ability to assess dose. The inspectors determined that the performance characteristic of the finding that was the most significant causal factor of the performance deficiency was associated with the cross-cutting aspect of Human Performance, having Work Practices components, and involving the licensee ensuring supervisory and management oversight of work activities, including contractors, such that nuclear safety is supported. Specifically, ownership and accountability to perform air quality testing was not well established or controlled within the work schedule process to ensure the tests would be performed as required. |
Site: | Duane Arnold |
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Report | IR 05000331/2013002 Section 2RS3 |
Date counted | Mar 31, 2013 (2013Q1) |
Type: | NCV: Green |
cornerstone | Or Safety |
Identified by: | NRC identified |
Inspection Procedure: | IP 71124.03 |
Inspectors (proximate) | J Corujo Sandin L Haeg R Murray S Bell B Orlikowski |
Violation of: | 10 CFR 20.1703, Use of individual respiratory protection equipment |
CCA | H.2, Field Presence |
INPO aspect | LA.2 |
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Finding - Duane Arnold - IR 05000331/2013002 | ||||||||||||||||||||||||||||||||||||||||||||||||||||||||||||||
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Finding List (Duane Arnold) @ 2013Q1
Self-Identified List (Duane Arnold)
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