05000454/FIN-2011002-03
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Finding | |
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| Title | Out of Date/Expired Respirator Cartridges |
| Description | An NRC-identified finding of very low safety significance and an associated NCV of TS 5.4.1 was identified by the inspectors when out of date respirator cartridges were found available for use. Radiation protection procedures that cover respiratory protection program did not require cartridges to be replaced after the manufacturer specified shelf-life had expired. The manufacturer of the respirator canister recognized that it was possible that chemical cartridges, which were more than a year old, might lose some of their efficiency in their ability to absorb contaminants. The manufacturer prescribed an expiration date of 3 years from the date of the canister manufacture and this date was stamped on to the canister label. The regulatory authority for respiratory protection is the Occupational Safety and Health Administration (OSHA). The regulations are defined in 29 CFR 1910.134 titled Respiratory Protection. Title 29 CFR 1910.134(d)(3)(iii) provides requirements for the protection against gases and vapors. These requirements include that air purifying respirators be equipped with an End-of-Service Life Indicator (ESLI) or the employer implements a change schedule for canisters and cartridges that is based on objective information or data that will ensure that canisters and cartridges are changed before the end of their service life. The employer shall describe in the respirator program the information and data relied upon and the basis for the canister and cartridge change schedule and the basis for reliance on the data. The inspectors reviewed the guidance in IMC 0612, Appendix E, Examples of Minor Issues, but did not identify any examples similar to the performance deficiency. However, in accordance with IMC 0612, the inspectors determined that the finding was more than minor because if left uncorrected the performance deficiency would have the potential to lead to a more significant safety concern. Specifically, cartridges that were beyond the recommended shelf-life could lose some of their efficiency in their ability to absorb contaminants and result in additional radiation doses to the users. The finding was assessed using the Occupational Radiation SDP and was determined to be of very low safety significance because these problems were not as-low-as-is-reasonably-achievable (ALARA) planning issues, there were no overexposures, nor substantial potential for overexposures and the licensees ability to assess dose was not compromised. Corrective actions planned by the licensee included replacing the expired cartridges and adding guidance to procedures for checking expiration dates during routine inventories. The inspectors determined that the cause of this incident involved a cross-cutting component in the human performance area for inadequate resources. Specifically, the licensee did not have complete, accurate and up-to-date procedures. |
| Site: | Byron  |
|---|---|
| Report | IR 05000454/2011002 Section 2RS3 |
| Date counted | Mar 31, 2011 (2011Q1) |
| Type: | NCV: Green |
| cornerstone | Or Safety |
| Identified by: | NRC identified |
| Inspection Procedure: | IP 71124.03 |
| Inspectors (proximate) | R Ng C Thompson B Bartlett J Robbins J Cassidy M Jones E Duncan J Gilliam W Lyon C Tilton J Miller J Whitman |
| CCA | H.7, Documentation |
| INPO aspect | WP.3 |
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Finding - Byron - IR 05000454/2011002 | |||||||||||||||||||||||||||||||||||||||||||||||||||||||||||||||||||||||||||||||||||||||||||||||||||||
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Finding List (Byron) @ 2011Q1
Self-Identified List (Byron)
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