05000341/FIN-2017004-03
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Finding | |
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Title | Failure to Perform Fit Testing on Self-Contained Breathing Apparatus Respirators |
Description | A finding of very-low safety significance (Green) and associated NCV of Title 10 of the Code of Federal Regulations (CFR), Part 20.1703(c)(6) was identified by the inspectors for the licensees failure to perform fit testing for the self-contained breathing apparatus (SCBA) style of respirators utilized. The licensee entered this issue into the Corrective Action Program as Condition Assessment Resolution Document (CARD) 1725155. Corrective actions included working with MSA to get both the air purifying and SCBA respirators National Institute for Occupational Safety and Health approved for both the rubber and Kevlar harnesses, and replacing all face pieces with the same style harness. The performance deficiency was determined to be more-than-minor because it was associated with the program and process attribute of the Occupational Radiation Safety cornerstone and adversely affected the cornerstone objective to ensure adequate protection of the worker health and safety from exposure to radiation from radioactive material during routine civilian nuclear reactor operation. Specifically, the respirator fit testing was being used to verify respirator protection factors for workers and the failure to verify the appropriate protection factor for the SCBA style of respirator affected the licensees ability to control and limit the intake of airborne radioactivity and other hazards. The finding was determined to be of very-low safety significance (Green) because the finding did not involve: (1) as-low-as-reasonably-achievable 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 finding had a cross-cutting aspect of human performance, conservative bias. Specifically, although the licensee questioned the practice on multiple occasions, the licensee was not able to determine that the practice was unsafe, and therefore continued the practice [IMC 0310, H.14]. |
Site: | Fermi |
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Report | IR 05000341/2017004 Section 2RS3 |
Date counted | Dec 31, 2017 (2017Q4) |
Type: | NCV: Green |
cornerstone | Or Safety |
Identified by: | Self-revealing |
Inspection Procedure: | IP 71124.03 |
Inspectors (proximate) | T Briley P Smagacz B Bergeon G Hansen V Myers R Walton B Dickson |
Violation of: | 10 CFR 20.1703, Use of individual respiratory protection equipment |
CCA | H.14, Conservative Bias |
INPO aspect | DM.2 |
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Finding - Fermi - IR 05000341/2017004 | |||||||||||||||||||||||||||||||||||||||||||||||||||||||||||||||||||||||||||||||||||||
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Finding List (Fermi) @ 2017Q4
Self-Identified List (Fermi)
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