IR 05000206/1989028
| ML20005D889 | |
| Person / Time | |
|---|---|
| Site: | San Onofre  |
| Issue date: | 12/04/1989 |
| From: | Cicotte G, Wenslawski F NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION V) |
| To: | |
| Shared Package | |
| ML20005D885 | List: |
| References | |
| 50-206-89-28, 50-361-89-28, 50-362-89-28, NUDOCS 9001020153 | |
| Download: ML20005D889 (16) | |
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U.S. NUCLEAR REGULATORY COMMISSION
REGION V
Report Nos.
50-206/89-26, 50-361/89-28, and 50-362/89-28
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License Nos.
DPR-13, NPF-10, and NPF-15 Licensee:
Southern California Edison Company 2244 Walnut Grove Avenue Rosemead, California 91770 Facility Name:
San Onofre Nuclear Generating Station Inspection at:
San Clemente, California Inspection Conducted:
October 16-20 October 30-November 3, and November 8,1$89 Inspected by:
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G. R. Cicotte, Radiation Specialist Date Signed
/4d'/d'f Approved by:
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F. A. Wenslawski, Chief Uite Signed Facilities Radiological Protection Section
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Summary:
Inspection during the period of October 16-20, October 30-November 3, and November 8, 1989 (Report Nos. 50-206/89-28, 50-361/89-28, and 50-362/89-28)
Areas Inspected:
Routine unannounced inspection by a regionally based Inspector of occupational exposure, including internal exposure and outage activities; follow-up of open items, and tours of the facility.
Inspection procedures 30702, 30703, 83729, 83750, and 92701 were addressed.
Results:
Of the three areas addressed, no violations were identified in two
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In one area, several procedural violations, related to administration and implementation of the Respiratory Protection Program pursuant to Technical Specification 6.11 and 10 CFR 20.103 were identified (paragraph 2.F),
With the exception of respiratory protective equipment the licensee's programs g
appeared fully capable of meeting their safety objectives.
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DETAILS 1.
Persons Contacted i
- H. Morgan, Station Manager
+R. Krieger, Operations Manager (Acting Station Manager)
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+*D. Brevig Onsite Nuclear Licensing (ONL) Supervisor
- +*R. Baker,, Compliance Engineer
T. Cooper, Health Physics (HP) Engineer
'+*B. Czajkowski, Supervisor of Dosimetry
+*J. Fee, Assistant Operational HP Manager S. Folsom, ALARA Supervisor
+*G. Gibson, ONL Eng/3 HP Supervisor ineer
+J. Madigan, Unit 2
- S. Jones, QA Engineer
- P.
Knapp, HP Manager
+*R. Plappert,imetry SupervisorTechnical Support and Compliance Supervis
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+J. Pope Dos
- J.Reilly Station Technical Manager
+J. Shipwas,h, Supervisor, Technical Support
'+*R. Warnock, Assistant HP Manager NRC
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- C, Caldwell Senior Resident Inspector
+A. Hon.ResIdentInspector Denotes those personnel present during the telephone conversation conducted on November 8,1989.
- Denotes those personnel present at the exit interview held on October 20, 1989.
+ Denotes those personnel oresent at the exit interview held on November 3, 1989.
In addition, t1e ins other members of the licensee'pector met and held discussions with s staff.
2.
Occupational Exposure and Outage Activities (83729 and 83750)
A.
Audits One audit was reviewed, in conjunction with paragraph 2.F, below.
On November 8, 1989, pursuant to a telephone conversation between the licensee and the inspector, the licensee provided to the inspector an audit summary, "HP&E Appraisal Report-Respiratory Protection," dated October 27, 1989.
The audit had been conducted October 5-26, 1989, by the Nuclear Engineering, Safety and. Licensing (NES&L) Department.
The Assistant HP Manager stated he had not been
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aware of the audit findin s at the time of the on site portion of the inspection as it had ust been issued and was in distribution.
The audit stated the foll wing conclusions:
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Respirator users were properly trained.
2.
Respirators were properly cleaned, maintained, selected and
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issued.
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Program documentation was less than adequate.
4.
The need for formal documented training for the Respiratory Protection Coordinator (RPC), Dosimetry Specialists, and Radioactive Material Control Specialists, had already been identified prior to the audit.
No formal respirator maintenance training had been conducted in over a year.
The audit made the following recommendations:
1.
Improve content of corporate respiratory protection policy statement.
The inspector noted that the elements recommended were well stipulated in the licensee's Respiratory Protection Program.
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Revise respiratory protection program maintenance procedures promptly.
With respect to specific findings in this area, the audit stated in part:
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"...I) obsolete equipment is described in some procedures;
2) in some procedures the responsibilities are not clearly l
identified; 3) slang terms are occasionally utilized.
Respiratory protection procedures are in compliance with the most recent revisions of NRC, ANSI, INPO and NIOSH
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1)gulations and guidelines with the following/h at SONGSexcepti
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re respirator facepieces are released at 1 mr versus 0.2 mrad /h recommended in NuReg0041, ANSI Z 88.2 and utilized by most other stations; 2) HRC I.E. Notice 84-60 suggests DOP testing some new filters... Songs has D0P filter testing equipment but is not utilizing the equipment at this time."
The inspector noted that the audit did not include recommendations related to NRC findings as described in i
paragraph 2.F, below.
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Respirator maintenance training lesson plans need to be completed to support classroom instruction.
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Initiate formal retraining for 00simetry Specialists, and contractor nosimetry Specialists should be trained to the same level as utility personnel.
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The audit stated in part that while storage of respirators was examined, cleaning and maintenance were not observed.
The audit stated that this would be observed at a later date.
No findings in l
that area were stated.
Based on a review of the audit and the t
telephone conversation on November 8, 1989 the inspector concurred intheiicensee'sconclusionthatthefindIngsregardingtraining
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had adequately identified deficiencies in that area.
The inspecten noted that the RPC had attended a formal vendor training course
prior to the completion of the audit.
B.
Changes Nomajorchangesinequiamentorprocedureshadtakenplacesince the last inspection of t11s program area.
The licensee stated that the RPC responsibilities had been added to those of the Dosimetry Supervisor in April, 1989, when the individual who had held the position of RPC had left.
C.
Planning and Preparation for Outages Maintenance requests, work scheduling / post-job briefing records for documents, radiation exposure i
permits (REP)Intenancetaskswerereviewed.
ALARA reviews, and pre-five maior ma No concerns were identifled.
Licensee procedure 50123-VII-3, "ALARA Job Review,"
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Revision 10, dated August 9, 1989 describes responsibilities and sequenceforreviewtoassureearlyinvolvementofHPpersonnelin the planning of radiological work.
Mock-up training provisions were reviewed.
The licensee used several mock-ups of major components in order to minimize exposure Building (RB)performingworkintheUnit2ReactorContainment to personnel
Adequate HP personnel were hired, and a review of
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the licensee s requirements identified no concerns regarding) with qualifications of contractor personnel.
HP technicians (HPT whom outage activities were discussed appeared familiar with tasks scheduled to be performed.
l The licensee's Respiratory Protection Program contained provisions for use of engineering controls to limit intake of airborne radioactive materials, and portable filter units were observed to be
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in extensive use.
Use of robotics equipment to automate in service inspection of steam generator internal components had not been fully (
successful, resulting in additional radiation exposure to personnel.
The licensee stated that mock-up training had been used to reduce exposure times, and review of ALARA post-job review and dose summaries supported that statement.
D.
Training and Qualifications of New Personnel
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l Qualifications of HPTs hired for the outage were briefly reviewed.
l Discussions with plant workers regarding HP requirements and the l
training provided to them identified no concerns.
The licensee uses an acceptance test to help determine whether contractor HPTs are
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qualified to work at the site.
Training of Dosimetry Specialists is
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E.
External Exposure Control i
Radiation exposure records for 20 personnel who had been permitted j
to receive radiation dose in excess of 10 CFR 20.101(a) were reviewed.
Forms equivalent to NRC-4 and NRC-5 were contained in the
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licensee's computerized files.
Although some errors in recording of data were observed, they appeared to be typographical in nature and did not result in any errors in dose authorizations.
Several special dosimetry packages were reviewed, and personnel in the radiologically controlled area (RCA) of Unit 2/3 and in Unit I were observed to be correctly wearing their personal dosimetry.
Licensee investigations of two anomalous thermoluminescent dosimeter (TLD) measurements were reviewed.
No concerns were identified.
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Dose status reports are provided to individuals via their Radiation Exposure Permit (REP) entry sheets, which they obtain upon entry to the RCA.
The licensee also had provided dose summary reports for i
supervisory review.
The licensee's computerized access control i
system automatically screens for qualifications, remaining l
permissible exposure, respiratory protection requirements, and task authorization.
Access control practices at the control points and in the plant were observed to be consistent with good practice and licensee
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procedures.
HP personnel who had been assigned responsibility for monitoring of personnel frisking, issuance of dosimetry, and briefing of workers, were generally observed to conscientiously require adherence to HP work rules.
The licensee administratively limits occup' Exposure of minors "
ationally exposed minors to below the standards of 10 CFR 20.104,
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F.
Internal Exposure Control Records of airborne radioactivity sampling, Maximum Permissible Concentration (MPC) calculations, assignment of MPC-hours of exposure, and bioassay results, were reviewed for personnel who were reported to have received over 30 MPC-hours of exposure during September and October, 1989.
No concerns regarding the licensee's methodology for calculating internal exposure were identified.
Breathing zone air sampling appeared adequate to evaluate airborne hazards.
The licensee had experienced problems with tabulation of exposures due to lack of knowledge by Dosimetry Clerks who hed been hired specifically for the outage, and who were not fauiliar.,with work area descriptions provided by personnel exiting the RBJ However, the licensee had provided additional instructions to those personnel.
Some of the exposures had been recalculated.
No examples of personnel approaching action levels without correct recording of work area / radioactivity concentrations were observed.
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On October 31, 1989 the inspector examined ready-for-issue
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respiratory protection equipment, which the licensee provided for their personnel to meet 10 CFR 20.103, " Exposure of individuals to concentrations of radioactive materials in air in restricted areas."
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The inspector noted that at least 13 of 50 full-face air purifying respirators, examined in the Respiratory Protective Device (RPD)
j Room on the 68' elevation of the Unit 2/3 Radwaste Building (RWB),,
appeared deficient.
The respirators appeared to have parts which were not identical to the original manufacturer's parts facepiece and lens together.specifically the face seal ring o whichholdsthe A Dosimetry Spec matter was discussed, stated that the procedure for maintenance of
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the respirators in question was licensee procedure 50123-VII-2.4,
"Use, Cleaning, Inspection and Maintenance of Full-Facepiece Air Purifying Respirators " Revision 6, dated June 10, 1988, a copy ofwhichhadbeeninuseIntheRPDroom.
The inspector subsequently noted that the current procedure was Revision 7, dated May 18, 1989 cleaningequIpmentandmonitoringofrespirators.and that the change Technical Specification 6.11. " Radiation Protection Program,"
states:
" Procedures for personnel radiation protection shall be prepared consistent with the requirements of 10 CFR Part 20 and shall be approved, maintained and adhered to for all operations involving personnel radiation exposure."
'7 All the licensee procedures which the inspector reviewed, including Revision 6 of S0123-VII-2.4, contained a requirement to verify prior to use whether the procedure is the current revision, by contacting the licensee's document management group "COM-SONGS," or by other specified means.
The use of Revision 6 of 50123-VII-2,4 from May 18, 1989, to October 31, 1089, without verifying Revision 7, appears to be a violation of Technical Specification 6.11 (50-361/89-28-01, 50-362/89-28-01).
The following licensee procedures were reviewed:
S0123-VII-2, " Respiratory Protection Program," Revision 8, dated August 15, 1989
S0123-VII-2.2.2 "Use, Cleaning and Maintenance of the National Draeger Compress,ed Air Breathing Apparatus," Revision 7, Temporary Change Notice (TCN) 7-2, dated September 29, 1989
S0123-VII-2.3, "Use, Cleaning and Maintenance of Supplied Air (Air Line) Systems," Revision 5, dated December 30, 1987'
S0123-VII-2.4, Revisions 6 and 7, as noted above
S0123-VII-2.4.1, "Use, Cleaning, Inspection and Maintenance of MSA Powered Air Purifying Respirators," Revision 6, dated May 18, 1989
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S0123-VII-2.4.2, "Use Cleaning, Inspection and Maintenance of MSAPressureDemandAlr-LineRespirators," Revision 6, dated May 18, 1989
S0123-VII-2.5 " Selection and Issue of Respiratory Protection Devices," Revision 9,TCN9-1,datedAugust7,1989
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S0123-VII-2.6, " Inventory and Control of Respiratory Protection Equipment," Revision 4. TCN 4-1, dated August 10, 1989 10 CFR 20.103 states in part:
"(c) When respiratory, protective equipment is used...the licensee shall use equipment that is certified or had certification extended by the National Institute for Occupational Safety and Health /Mine Safety and Health Administration (NIOSH/MSHA).
The licensee may make allowance for this use of respiratory protective equipment in estimating exposures of individuals to this material provided that:
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"...(2) The licensee maintains and implements a respiratory protection program that includes, as a minimum:..."
"... written procedures regarding selection, fitting, and maintenance of respirators....."
Licensee procedure 50123-VII-2 states in part:
"The Respiratory Protection Program will be established in accordance with References 2.1.1, 2.1.2, 2.1.4, and 2.1.5."
"... Additionally, specific use and maintenance procedures for respiratory protection equipment will be p Physics 50123-VII-2.xxxseriesprocedures.{ovidedintheHealth References 2.1.1, 2.1.2, 2.1.4, and 2.1.5 of 50123-VII-2 are, respectively, 10 CFR 20 " Standards for Protection Against Radiation," 29 CFR 1910.134, " Respiratory Protection," Regulatory Guior i.15 " Acceptable Programs for Respiratory Protection," and NUREG-u041, " Manual of Respiratory Protection Against Airborne Radioactive Materials." S0123-VII-2 also states in part that all i
respiratory protection equipment issued for protection against the inhalation of radioactive materials at the facility shall have beeq approved under appropriate approval schedules in 30 CFR 11.
30 CFR 11 states in part:
"... approved respirators shall be selected, fitted, used and maintainedinaccordancewiththeprovisionsoftheAmerIcan National Standard Practices for Respiratory Protection, 288.2,...."
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ANSI Z88.2-1980 states in part:
"2. Definitions..."
" approved.Testedandlistedassatisfactory...jointlyby
the...(MSHA)...andthe...(NIOSH)...."
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"3.5.4 Approved Respirators.
Approved respirators shac1 be used...Any modification that is not authorized by the a agenciesofanapprovedrespiratorvoidstheapproval..pproval
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"8.4 Part Replacement and Repair.
Replacement of partt or repairs shall be done only by persons trained in proper
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respirator assembly and correction of possible respirator malfunctions and defects.
Replacement parts shall be only those designed for the specific respirator being repaired...."
- Regulatory Guide 8.15, "Acce Jrotection,"andNUREG0041,gtableProgramsforResairatory Manual of Respiratory Protection Against Airborne Radioactive Materials," contain similar wording and
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requirements regarding how NIOSH/MSHA approval is maintained by respiratory protective equipment users.]
The "NIOSH Certified Equipment List" (NIOSH CEL) describes approved respirators limitations for use, end the approved applications.
ThelimitatIonsstatedintheNIOSHCELwere,inpart:
" Refer to approval label and instruction and maintenance manuals for additional information on use and maintenance of these respirators."
"...In making renewals and repairs, parts identical with those furnished by the manufacturer under the pertinent approval shall be maintained."
The inspector verified that the licensee's respirator models in active use were referenced in the NIOSH CEL issued as of December 31, 1988, with the applicable approvals and limitations.
Licensee procedure 50123-VII-2.4 states in part that the purpose of
the procedure is to provi'fe instructions for maintenance and inspection of full-face air purifying respirators.
The procedure included an approved parts list for Nos. 2 and 3 of the 5 respirator facepiece models in use at the time of the inspection:
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Natiom i Dra er, model " Panorama Nova," silicone rubber 2.
Mine Safety pplicances (MSA) model "Ultratwin" 3.
MSA model U travue" 4.
Norton Safety Products (subsequently North Safety'
Products] model 7500 8, silicone rubber mask 5.
Norton/ North model 7500-8, neoprene rubber mask The inspector determined that the licensee's specific procedures :
for use, cleaning and maintenance of the respirators which were examined, were tiose reviewed as noted above.
50123-VII-2.2.2 and
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50123-VII-2.4.1 list the manufacturers' operating manuals as i
references.
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50123-VII-2.4 states in part that respirators are to be inspected to ensure that fittings and attachments are securely in place, that seals are clean, that to be considered acce) table for use the respiratormustbetaggedwit5acompletedRespiratorEqulpment
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Inspection Tag, and that:
" Replacement parts will only be those provided by the respirator manufacturer as maintaining the NIOSH or MSHA approval for the respirator.
Parts will not be interchanged between different respirator types."
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The inspector requested that the RPC provide the respirator approval and/or manufacturer's description of proper assembly, the approved
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parts lists, and other supporting documentation for maintenance and inspection of all full-facepiece air purif Self-Contained Breathing Apparatus (SCBA) ying respirators andrespira
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the inspector to be in use pursuant to 10 CFR 20.103.
Based on the licensee's efforts to obtain those records, further examination of respiratory 'rotection equipment in use or ready for issue at Units p
2/3 and at Unit 1, discussions with respirator maintenance personnel, and review of licensee procedures, the following observations were made:
Observations with Respect to Respirator Maintenance Procedures
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The requirement to use only replacement parts identical to the manufacturer's was discussed with Dosimetry Specialists who stated that they routinely maintained and inspected rapirators.
The Dosimetry Specialists were familiar with the requirement, and stated that they depended on the supply of parts provided by the supplier, to assure that the parts were correct.
An examination of replacement parts available in the RPD Room, determined that part numbers and descriptions were not available for all respirator ty;es in use, but were available for most parts of the most-used types of respirators.
However, for many res)irators, Dosimetry Specialists had no method available to t1em for comparing parts to the manufacturer's requirements.
- The licensee stated they had hired contractor Dosimetry Clerks to aerform simple tasks such as issuing respirators, in order to 1 ave sufficient staff to provide routine training to their own Dosimetry Clerks and Specialists.
Although the Dosimetry Clerks were adequately trained to perform the tasks assigned to them, the O nimetry Clerks with whom the matter was,
discussed were unable to recognize when incorrectly in'spected or maintained respirators were supplied to them for issuance.
- The licensee had provided training which was consistent with manufacturer's recommendations for the MSA negative pressure air purifying (NPAP) respirators.
Dosimetry Specialists with
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whom training was discussed stated that they had been trained to maintain and inspect some respirator types by verbal instruction and demonstration.
The respirators for which only on-the-job training, without written references, was provided, were those in whic1 the most discrepancies were observed.
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manufacturer's aarts were not contained in any of the licensee
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procedures whic1 were reviewed, with the exception of a parts list for MSA Ultravue and MSA Ultratwin style respirator facepieces.
None of the above noted licensee procedures contained specific written instructions or illustrations
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regarding how to assemble the different models of respirators.
The manufacturer's literature referenced in the air-supplied respirator maintenance procedures, which did contain part identifications and assembly illustrations, was not available to personnel performing inspection and maintenance.
For example, The parts list for National Draeger model PA-80 SCBA units was not available to Dosimetry Specialists or the RPC, except for a copy of the Panorama Nova mask portion, which was available to the RPC.
Some of the listed part numbers on that
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document were hand written in by the licensee.
The air supply / regulator portion was not available.
- Licensee procedure 50123-VII-2.4, which governs maintenance of all models of full-face air purifying respirators, did not contain assembly instructions for the National Draeger Panorama Nova, MSA Ultratwin and Ultravue, or the Norton/ North 7500-8 series respirator facepieces, and contained parts lists for only the MSA models.
The manufacturers' instructions were not referenced therein.
The failure to provide specific use and maintenance procedures for respiratory protection equipment in the Health Physics
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S0123-VII-2.xxx series procedures, or to provide alternate means of instruction in maintenance and inspection of resairators, such as available manufacturer's references, appears to >e a violation of licensee procedure 50123-VII-2 and Technical Specification 6.11 (50-206/89-28-01,50-361/89-28-02,50-362/89-28-02).
Observations with Respect to Respirator Majntenance
For National Draeger Panorama Nova masks, mooel PA-80 SCBAs and NPAP respirators, the mask body is the same, but the gusset (on
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SCBA) and the support plate (on NPAP) are visibly different.
The part is used to provide structural support, particularly on silicone masks which are more pliable than neoprene rubber masks.
The licensee uses silicone masks.
Of approximately 40 such masks examined by the ins)ector, 8 were observed t'o have the part missing, and 4 were o) served to have the part for the other type.
- Of the Norton/ North model 7500-8 respirators which were first examined by the inspector,13 had lens frames by one
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manufacturer of respirators (Scott part G51-01), and the
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remaining lens frames were of indeterminate manufacture, not i
Norton/ North.
The licensee was unable to demonstrate that any
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of the parts were correct, in that the parts list and description were not available to Dosimetry Specialists or to the RPC.
The subject lens frames did not appear to be part of any NIOSH/MSHA approval or extension of approval for
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Norton/ North respirators listed in the NIOSH CEL
Of the five SCBA respirators available for issue at the control point in Unit 1 on November 1, 1989, ail had Respiratory Equipment Inspection Tags which included a check for the cartridge [ filter), which is not a part of that
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respirator.
For two NPAP respirators available fur isst.2, of
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eight examined, the su) port plate appeared to be installed incorrectly, in that t1ey appeared to be distorted.
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On November 1, issue, were observed to have been satisfactorily 1989 three NPAP respirators which were available for inspectedforcleanliness,andthefilter-to-masksealingareas had adhesive tape remnants on them.
- On November 2,1989, approximately 50 Respiratory Equipment Inspection Tags were observed in the RPD Room, with the checklist already filled out, and the previous day's date.
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l additional 100 Respiratory Equipment Inspection Tag checklists were observed to have been filled out without the date.
- At approximately 11:00 a.m., PST, November 1 1989, the licenseeissuedaNationalDraegerPA-80SCBdtoaworkerfor initial entry to the Unit 1 Reactor Containment Building.
The worker operated the hatch airlock and was given credit for protection from exposure to airborne H-3 exposure.
The SCBA was later observed by the inspector to have the facepiece gusset missing.
At approximately 7:38 a.m., PDT, September 9, 1989, a worker was issued one of the Norton masks for use in l
the Reactor Cavity in Unit 2 and was given credit for the protection factor afforded thereby.
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The failure to maintain respirstors according to manufacturer's parts requirements, in accordance with licensee procedures 50123-VII-2, 50123-VII-2.2.2. and S0123-VII-2.4, appears to be a
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violation of Technical Specification 6.11(50-206/89-28-02, 50-361/89-28-03,50-362/89-28-03).
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The above observations were brought to the attention of the RPC on November 1 and 2, 1989, and were discussed with the Assistant HD Manager on November 2, 1989.
The Assistant HP Manager stated that the RPC would assure that all respirators which could not tie determined to have met the requirements for continued approval would not be used and that all Norton respirators had been removed from service.
The licensee acknowledged that the vtrious deficient respirators observed by the inspector were routinely used for protection from airborne radioactivity and to make allowance for the
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protection factors used.
The inspector asked for additional information regarding whether training had been conducted for maintenance of respirators, and whether the licensee would be able
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to verify what replacement parts to use or inspect on their respirators.
The inspector further asked what actions the licensee intended to take to (.ssure that future respirator maintenance, inspection, and use would be in accordance with regulatory
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requirements and licensee procedures.
The licensee stated that respirators ready for issue would be reinspected to assure the NIOSH/MSHA approval had not been voided.
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The inspector noted that the licensee had available an adequate supply of NPAP respirators which, if inspected in accordance with i
manufacturer's recommendations and licensee procedure, appeared to meet NIOSH/MSHA approval limitations.
Also, the licensee s atmosphere-supplying, air-line hood respirators were supplied with the NIOSH/MSHA approval, are single use, and thus appeared to meet the requirements noted above.
At the exit interview at 10:00 a.m., PST, on November 3,ings to the 1989, the inspector brought the nature and scope of the above find attention of the licensee, including the Acting Station Manager.
The inspector stated to the licensee that the effectiveness of
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reinspection of respirators noted above, would be verified pri :r to theinspectorleavingthesIte.
The licensee acknowledged the
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findings and stated the following:
All Norton/ North respirators were taken out of service prior to the time of the exit interview.
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Respirator Eculpment Inspection Tags for all respirators ready for issue hac been reviewed for completeness and accuracy.
- Training of Dosimetry Specialists and Clerks was a previously-identified problem, which was being addressed.
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The RPC had been relieved of responsibilities, other than l
maintenance of respiratory protection equipment, in order to allow sufficient time to correct the problems.
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A corporate audit had been initiated to address the same areas as the findings of the inspection, to determine the full extent and root cause.
At least 40 respirators, which had not passed the review /
reinspection noted above, had also been removed from service in accordance with licensee procedure.
All respirators which were
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ready for issue at the time of the exit interview had been L
reinspected.
Both MSA and National Draeger had been contacted to schedule
l retraining of personnel in maintenance and inspection of their respect.ive respirator types, i
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The insaector reiterated to the Assistant HP Manager the concern as to whet 1er they could be assured that approved respirators would in future be used beginning at the time of the exit interview.
After consultationwIth11sstaff,hestatedthatsuchassurancewas possible.
The inspector reminded the licensee of the importance of providing fully functional and procedurally adequate respiratory
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protection equipment.
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At approximately 12:30 p.m. PST, on November 3 1989 the inspector reexaminedthoserespiratorswhichwerereadyforiss,ueattheRPD Room.
All Norton/ North respirators had been removed from service.
Of 20 MSA Ultravue respirators examined by the inspector, and which the Dosimetry Clerk on duty stated were ready for issue, I had no coupling assembly, coupling gasket, or gasket / valve spider, identified as required parts by MSA and S0123-VII-2.4, and 2 had band clamps which did not appear to be properly seated on the facepiece.
Of 43 National Draeger Panorama Nova silicone facepiece NPAP respirators examined by the inspector, 3 had the gusset instead of the required support plate as previously identified, 1 appeared to be incorrectly installed, and I had adhesive tape remnants on the filter-to-mask sealing areas.
Of five National Draeger Panorama Nova silicone SCBA masks, three were missing the gusset, and one had the gusset, but it appeared to be misaligned.
The inspector discussed these additional findings with the RPC, who stated that it had been his responsibility to aerform the reinspection of resairators, and acknowledged t1at the reinspection did not appear to 1 ave been sufficiently detailed to preclude the problem of respirators which did not meet NIOSH/MSHA limitations and licensee procedures being issued.
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The inspector examined respirators which were being collected after use and found one additional NPAP respirator of four inspected, which had the mask body partially curled under the tightening strap,
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a part which performs the same function as the band clamp on the MSA facepiece.
The licensee later determined that the respirator had been issued but not used.
The above additional findings were brought to the attention of the Assistant HP Manager, who had discussed the matter with the RPC.
The Assistant HP Manager reiterated the commitment, or committed to;
remove from service, effective immediately as of 1:50 p.m. PST,
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November 3, 1989, all full-facepiece respirators,
not return SCBA respirators to service until the correct
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manufacturer's parts list / assembly description for the air supply / regulator portion could be obtained,
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and return to service full-facepiece NPAP, positive pressure, l
and air supplied respirators, only after thorough reins 7ection under the direct supervision of manufacturer-trained personnel, i
l with the use of manufacturer's data, incorporated in revised 50123-VII-2.xxx procedures.
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In a telephone conversation conducted on November 8,1989 between thelicenseeandtheinspector,thelicenseeprovidedadditional information regarding their corrective actions.
The licensee i
provided a telecopy of the results of an audit which had been conducted in this pro i
paragraph 2.A,above)gramareajustpriortotheinspection(see j
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G.
Control of Radioactive Materials and Contamination, Surveys, and l
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Monitoring
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Licensee radiation detection, dose rate, and contamination monitoring equipment was inspected.
All equipment which was inspected was in current calibration and quality control checks were being performed in accordance with licensee procedures.
Portal monitor and frisker use is routinely monitored during the outage by licensee HP personriel to assure that personnel perform proper frisks.
HPTs with whom principles and practices of instrument use
were discussed appeared to be knowledgeable in their areas of responsibility.
Activities to minimize solid radioactive waste and control radiological work were observed.
The inspector conducted independent radiation surveys of areas near but not in the licensee's restricted area.
No radioactive material outside the licensee's designated radioactive material storage areas or RCA was detected.
Except as noted in paragraph 4, below, regarding removal of material from the Unit 2 RB, no concerns were identified.
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Maintaining Occupational Exposures ALARA Workers with whom ALARA princiales were discussed were familiar with licensee efforts to minimize t1eir exposure, and understood how their efforts could contribute to the program.
The licensee stated that they had established a goal for the Unit 2 outage which would result in a calendar year 1989 station total of 750 person-rem.
Outage reports as of October 15, 1989, were reviewed.
The licensee's estimates of exposure, with few exceptions, appeared to be directed toward accurate summation of task-oriented dose, and resulted in realistic goals.
The inspector noted that the station dose for calendar year 1988 was 731 person-rem,isor stated that the slightly less than the projected total for 1989.
The ALARA Superv goal for calendar year 1990 was expected to be 750 person-rem.
Although this would remain the same as the two previous years, she stated that additional major tasks such as spent fuel pool re-rack in Units 2/3, reactor vessel thermal neutron shield repair in Unit 1,andamajoroutageduringrefuelingofUnit3,wereincludedin that estimate.
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Shipping of Low-Level Wastes for Disposal, and Transportatio'n Licensee preparations for shipping and packaging of solid radioactive wastes were briefly observed.
Discussions of packaging and shipping requirements with Radioactive Material Control
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Handlers and other personnel performing waste handling activities
identified no concerns.
With the exception of the Respiratory Protection Program, the licensee's
program appeared fully capable of meeting its' safety objectives.
No other violations or deviations were identified.
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Follow-up 50-206/IN-89-47, 50-361/IN-89-47, and 50-362/IN-89-47(Closed):
This item refers to NRC Information Notice 89-47, " Potential Problems with Worn or Distorted Hose Clamps on Self-Contained Breathing Apparatus." The licensee had incorporated inspection for the described problem in maintenance procedures for their SCBAs.
Although other problems with SCBA maintenance were identified in paragraph 2.F, above, this matter is considered closed.
50-206/89-26-02(Closed):
This item refers to an NRC concern regarding whether the Unit 1 Post Accident Sampling / area (se(e System PASS) laboratory, located under was a confined space The
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The licensee concluded that the Unit 1 PASS laboratory was not a confined
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area.
The inspector toured the laboratory, noted the size of openings in the ceiling and door, noted that although the nitrogen supply had not been specifically leak tested, there did not appear to be any leaks sufficient to displace any significant volume of air in the room, without natural convection air changes adequate to maintain the laboratory with a non-hazardous oxygen concentration.
The inspector noted that although the ventilation fan was not running, entry to the small room caused considerable air change due to the opening of the door.
The matter of a confined area in the Unit 1 PASS laboratory is considered closed.
No violations or deviations were identified.
4.
Tours of the Facility
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i Tours of the Auxiliary (AUX), RB, RWB, and Turbine Buildings (TB), for all three units, were conducted.
Independent radiation surveys were performed with NRC ion chamber survey instrument model #R0-2, serial
- 015844, due for calibration on December 27, 1989, and NRC micro-R meter modei #PRM-7, serial #008596, due for calibration on April 17, 1990.
Radiological postings, barricades, gates, and locks for high radiation areas were observed to be c.onsistent with licensee Technlcal Specification 6.12. "High Radiation Areas.grocedures andOne posting Unit 2 RB, next to a reactor coolant pump, was not very consaicuous, but was immediately corrected when brought to the attention of t1e licensee.
Generally, housekeeping in Unit 2 appeared good, considering the. outage condition.
Other areas appeared better than Unit 2.
- Removal of radioactive material from the Unit 2 RB was observed.
Although other operations involving control of contamination were observed throughout the inspection, and were consistent with licensee
procedure and good practice, the activities at the Unit 2 RB equipment
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hatch were poor.
Several personnel were observed leanin i
posted contaminated area, into the uncontaminated area. g out of the Concurrentl several personnel were observed leaning into the contaminated area, y, touching areas which had previously been contacted by personnel inside
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the area.
A radioactive material container which was being used to transport highly contaminated waste meteria,ls from the RB, had been decontaminated by the HPT, when a Radioactive Material Control Handler -.
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reached out of the contaminated area to perform a radiation survey on the container, and touched several places on the container.
The HPT did not challenge the activities of the personnel who were in the areas.
Large area wipes of the floor in the uncontaminated area were periodically performed by the HPT.
However, the HPT did not survey all the wipes thus obtained.
When the above observations were brought to the attention of the HP Supervisor, an additional HPT was sent to the work area to assist in monitoring of worker activities.
Later activities in this work location were observed to have improved.
Overall, the licensee's program appeared fully capable of meeting its'
safety objectives.
No violations or deviations were identified.
5.
Exit Interview The inspector met with those individuals, denoted in paragraph 1, at the conclusion of the inspection on November 3, 1989.
The scope and findings of the inspection were summarized. The licensee was informed that the multiple examples, in paragraph 2.F. of failure to adhere to procedures, to provide procedures consistent with the Respiratory Protection Program, and to verify procedures prior to use appeared to be violations of their Technical Specifications and 10 CFR 20.103.
As a result of review of additional infcrmation provided on November 8 1989, the problems in training of Dosimetry Specialists were determined to have been identified by the licensee.
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