05000443/FIN-2012004-03
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Finding | |
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Title | Inadequate Calibration of Respirator Fit Test Equipment |
Description | Inspectors identified an NCV of Technical Specification (TS) 6.7.1.a, Procedures and Programs, which requires that written procedures be established and implemented, to include administrative procedures, which includes radiation protection procedures. Specifically, procedure HD 0965.10, Respirator Fit Testing Using TSI Portacount Plus, Revision 10, did not specify a calibration frequency requirement for the respirator fit test equipment. The equipment vendor recommended annual calibration frequency, which was exceeded by over two years, and the current as-found condition of the specified equipment when tested was found out of calibration. This issue was entered into NextEras CAP as CR 1785134. This performance deficiency was determined to be more than minor, because it was associated with program and process attribute of the Occupational Radiation Safety cornerstone and affected its 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 certify respirator protection factors of workers which were relied upon to provide protection of workers due to airborne radioactivity during the previous refueling outage. Additionally, it was similar to example 6.b in IMC 0612, Appendix E, Examples of Minor Issues, which states that failing to calibrate radiation instruments was more than minor if the as-found condition was not within the acceptance criteria for the calibration and did not provide a conservative measurement. The issue was evaluated using IMC 0609, Significance Determination Process (SDP), and was determined to be of very low safety significance. Specifically, when evaluated with IMC 0609, Appendix C, Occupational Radiation Safety Significance Determination Process, the performance deficiency was not an ALARA issue, did not involve an overexposure or a potential overexposure, and did not impact NextEras ability to assess dose. The inspectors determined that this finding had a cross-cutting aspect in the area of Problem Identification and Resolution - CAP because NextEra did not identify that vendor recommended calibration requirements had not been met or evaluated when this equipment was returned by the vendor for routine cleaning. |
Site: | Seabrook |
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Report | IR 05000443/2012004 Section 2RS3 |
Date counted | Sep 30, 2012 (2012Q3) |
Type: | NCV: Green |
cornerstone | Or Safety |
Identified by: | NRC identified |
Inspection Procedure: | IP 71124.03 |
Inspectors (proximate) | P Cataldo J Noggle J Furia T Burns W Raymond A Burritt J Greives K Dunham M Jennerich |
CCA | P.1, Identification |
INPO aspect | PI.1 |
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Finding - Seabrook - IR 05000443/2012004 | |||||||||||||||||||||||||||||||||||||||||||||||||||||||||||||||||||
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Finding List (Seabrook) @ 2012Q3
Self-Identified List (Seabrook)
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