Information Notice 1998-20, Problems with Emergency Preparedness Respiratory Protection Programs

Problems with Emergency Preparedness Respiratory Protection Programs
	ML031050152
Person / Time
Site:	Beaver Valley, Millstone, Hatch, Monticello, Calvert Cliffs, Dresden, Davis Besse, Peach Bottom, Browns Ferry, Salem, Oconee, Mcguire, Nine Mile Point, Palisades, Palo Verde, Perry, Indian Point, Fermi, Kewaunee, Catawba, Harris, Wolf Creek, Saint Lucie, Point Beach, Oyster Creek, Watts Bar, Hope Creek, Grand Gulf, Cooper, Sequoyah, Byron, Pilgrim, Arkansas Nuclear, Three Mile Island, Braidwood, Susquehanna, Summer, Prairie Island, Columbia, Seabrook, Brunswick, Surry, Limerick, North Anna, Turkey Point, River Bend, Vermont Yankee, Crystal River, Haddam Neck, Ginna, Diablo Canyon, Callaway, Vogtle, Waterford, Duane Arnold, Farley, Robinson, Clinton, South Texas, San Onofre, Cook, Comanche Peak, Yankee Rowe, Maine Yankee, Quad Cities, Humboldt Bay, La Crosse, Big Rock Point, Rancho Seco, Zion, Midland, Bellefonte, Fort Calhoun, FitzPatrick, McGuire, LaSalle, Fort Saint Vrain, Shoreham, Satsop, Trojan, Atlantic Nuclear Power Plant
Issue date:	06/03/1998
From:	Roe J, Teneyck E; NRC/NMSS/FCSS, Office of Nuclear Reactor Regulation
To:	;
References
	IN-98-020, NUDOCS 9805280261
	Download: ML031050152 (13)
	v • d • e

UNITED STATES

NUCLEAR REGULATORY COMMISSION

OFFICE OF NUCLEAR REACTOR REGULATION

WASHINGTON, D.C. 20555-0001 June 3, 1998 NRC INFORMATION NOTICE 98-20: PROBLEMS WITH EMERGENCY PREPAREDNESS

RESPIRATORY PROTECTION PROGRAMS

Addressees

All holders of operating licenses for nuclear power reactors; non-power reactors; all fuel cycle

and material licensees required to have an NRC-approved emergency plan.

purpose

The U.S. Nuclear Regulatory Commission (NRC) Is Issuing this Information notice to alert

addressees to multiple generic weaknesses in respiratory protection programs supporting

emergency preparedness (EP). It Is expected that recipients will review the Information for

applicability to their facilities and consider actions, as appropriate, to avoid similar problems.

However, suggestions contained In this information notice are not NRC requirements; therefore, no specific action or written response Is required.

Background

NRC Information Notice (IN) 97-66, uFailure To Provide Special Lenses for Operators Using

Respirator or Self-Contained Breathing Apparatus (SCBA) During Emergency Operations," was

issued on August 20, 1997. That notice alerted licensees to a generic problem In which some

licensed operators had not been provided required lenses for vision correction while wearing

SCBA. A lack of required vision correction could hamper the control room operator's

performance of licensed duties, including timely and effective response to emergencies.

Subsequent to the Issuance of IN 97-66, follow up by licensees and NRC inspectors Identified

numerous problems and deficiencies In the respiratory protection programs supporting licensee

emergency response programs.

Description of Circumstances

The 12 event summaries (Attachment 1) detail a broad spectrum of EP respirator program

weaknesses. The discussion below focuses on these problems In generic functional areas.

During the NRC's review of emergency plan changes made by the licensees of the McGuire

and Summer plants under 10 CFR 50.54(q), the staff found that both plants had significantly

reduced or eliminated the respiratory protection capability during emergencies. The NRC

98052809 rV#

IN 98-20

June 3, 1998

- informed licensees of both facilities that these changes had reduced the EP effectiveness.

In response to the NRC findings, the plants reinstated effective EP respirator programs. Given

the potential radiological hazards and potentially more hazardous Immediately dangerous to life

or health (IDLH) nonradiological airborne environments (e.g., toxic gases, oxygen deficiency, smoke), the NRC staff found It unacceptable to weaken or remove a vital protective function for

emergency response workers (and the plant).

Another important area involved Inadequate or incomplete evaluations of emergency situations

and their impact on control room operators. The licensee for the Calvert Cliffs facility had not

developed or implemented a procedure for handling an onsite spill of ammonia - no plans had

been made that specified needed protective actions for workers on the scene or for the control

room operators. At the Enrico Fermi plant during a self-Initiated engineering review follow up, the licensee identified the need to stage dedicated SCBA In the auxiliary building to ensure that

operators could Implement the dedicated shutdown (remote) procedure. At San Onofre Nuclear

Generating Station, In response to an NRC Inspection, the licensee Initiated a self-assessment

that identified the need to develop a plan to provide for refilling and transporting SCBA air

bottles to and from the control room during emergency situations.

Several shortcomings In the training area were noted throughout the Industry. Most significant

was the failure to provide control room operators with periodic, hands-on training and practice

with donning and wearing SCBA. Additionally, operators were not trained to change out bottles, nor, In some cases, did they know where the spare charged bottles were stored for their

emergency use.

A number of facilities had allowed on-shift, operating personnel, who would be required to wear

a SCBA during certain emergencies, to have beards. When the NRC Inspector discussed the

problems that a beard could cause to respirator performance (fit degradations, Interference with

proper operation of the SCBA, shortened period of air supply, degraded operator emergency

response), all licensees initiated timely action to meet the technical specification requirements

in having sufficient number of clean-shaven operating crew.

Several licensees had no established effective oversight or controls for tracking and maintaining

operators', and other workers' required periodic retraining and SCBA fit testing. This

programmatic deficiency led to numerous failures to maintain timely emergency worker

qualification. At one facility, only 81 of the 235 members of the emergency response

organization met the requirements of the station and 10 CFR Part 20 for worker training and fit

testing at the time of the Inspection.

Discussion

Since the major revision of 10 CFR Part 20, effective in 1993, licensees have significantly

reduced the numbers of respirators used by orders of magnitude during normal plant operations

and maintenance outages. This significant shift away from the use of respirators is a result of

better job planning, more effective use of work area decontamination, and close-capture

containments. This shift resulted from the new Part 20 requirement to maintain the total

effective dose equivalent as low as reasonably achievable.

IN 98-20

June 3,1998 Optimization of the internal and external doses often results In the determination that the use of

respirators to avoid a small intake can result in a larger external dose as a result of worker

inefficiency.

However, it appears that this de-emphasis of respiratory protection for normal operations may

have contributed to a potential decrease In the effectiveness of emergency response

capabilities involving respiratory protection. Along with this de-emphasis, the ongoing

restructuring and downsizing of the electric utility Industry places significant emphasis on cost

savings efforts. While no area of nuclear plant operation is Immune from this cost scrutiny, licensees need to ensure that the effectiveness of EP response capabilities are maintained. As

previously discussed, plant operators and emergency response workers can face not only

radiological airborne hazards, but, In many cases, are challenged by unknown and potentially

IDLH conditions. Maintaining an adequate respiratory program Is vital to their safety and, thus, to their ability to respond In a timely fashion to emergencies.

This information notice requires no specific action or written response. If you have any

questions about the information in this notice, please contact the technical contacts listed below

or the appropriate Office of Nuclear Reactor Regulation (NRR) project manager or appropriate

Office of Nuclear Material Safety and Safeguards (NMSS) Project Manager.

orig AN by o-ig /s/'d b D.1 litthes FOR

Elizabeth Q. Ten Eyck, Director Jack W. Roe, Acting Director

Division of Fuel Cycle Division of Reactor Program Management

Safety and Safeguards Office of Nuclear Reactor Regulation

Office of Nuclear Material

Safety and Safeguards

Technical contacts: James E. Wigginton, NRR Lawrence K. Cohen, NRR

301-415-1059 301415-2923 E-mail: Jew2@nrc.gov E-mail:lkc@nrc.gov

Michael A. Lamastra, NMSS

301-415-8139 E-mail: mxl2@nrc.gov

Attachments:

1. Event Summaries

2. Ust of Recently Issued NMSS Information Notices v 4TA it's-1.

3. Ust of Recently Issued NRC Information Notices.47T7#CH1 U V 7AF, L E&D LM

See previous concurrence DOCUMENT NAME: G:lTXKAINRESPAI.con

To receive a coov of this docrnent Indicate In the box C=Coov wlo attachmentlenclosure EsCooy with attachmentlencfosure N = No coDY

OFFICE PECB _ PERB IE C:PECB I NMSSJ I D:DRPM

NAME TKoshy CMiIler* JStolz JRoe*

DATE 04130/98 05105/98 05113/98 198 _0512298 ech Ed Concurred an 4/2/98 OFFICIAL RECORD COPY

Attachment I

IN 98-20

June 3, 1998 EVENT SUMMARIES

McGuire The letter of February 6. 1996. to Duke Power Company

Accession Number (AN) 9602210358 The licensee made changes to its emergency plan under 10 CFR 50.54(q) and deleted the

requirement for members of the emergency response organization (ERO) to be qualified to use

respirators. The follow up NRC review found that this change constituted a decrease In EP

effectiveness, and the licensee reinstated the respiratory requirements. In its review and

justification, the NRC cited 50.47(b)(8), which requires adequate emergency equipment to

support EP response, Including respirator protection equipment (NUREG-0654, Revision I

Sections lI.H.9 and J.6).

Calvert Cliffs Inspection Report(IR) Nos. 50-317/97-06 and 50-318197-06 AN 9712170365 The NRC inspectors found numerous weaknesses in the control room operators capability to

effectively use self-contained breathing apparatus (SCBA). Following a postulated ammonia

spill on site, no procedure had been formalized to direct response activities, Including control

room ventilation alignment and the need to don SCBA. Some operators had facial hair and

some did not know the location of SCBA designated for emergency use. Other than those

designated as fire brigade members, operators had had no practical hands-on training with

SCBA for 5 years. As a result, the licensee established an Improved, practical training plan on

SCBA for the operators.

SONGS IR Nos. 50-361/97-20 and 26 and 50-362/97-20 and 26 ANs 9712110162 and 9801070286 The NRC Inspectors noted that some shift technical advisors had not kept their respirator

qualifications current. In response to Information Notice 97-66, the licensee determined that

approximately 25 licensed operators who required corrective lenses either did not have special

frames or did not have current lens prescriptions. Some operators had beards despite the need

to don and wear SCBA within 2 minutes after the Initiation of an emergency. In response, the

licensee issued station-wide Instructions that required personnel filling minimum staffing

requirements to be cdean shaven.

Washington Nuclear IR Nos. 50-397/97-014 Prolect-2 AN 970919Q17 NRC Inspectors noted that the air cylinder pressure for all SCBA was not in accordance with

industry standards which was a final safety analysis report commitment. The required

pressure should be at least 90 percent of the rated cylinder pressure. Several air cylinders, staged for service, were found at pressures less than 4000 psig. Instead of the acceptable

minimum pressure of about 4000 psig, the licensee's minimum acceptable pressure was only

Attachment 1 IN 98-20

-June 3, 1998 3500 psig. At this lower pressure, the rated use-time Is only about 23 minutes, Instead of the

rated normal 30-minute air supply. Appendix R of 10 CFR Part 50, requires SCBA rated for at

least 30 minutes of air supply. The licensee responded by changing procedures, retraining

workers, and ensuring all In-service cylinders were charged to at least 4000 psig.

Fermi 2 Licensee Event Report No. U7-0029. Rev. I

AN 9705190046 The licensee discovered during an engineering review that, assuming a design-basis fire and

loss of offsite power, certain areas In the auxiliary building could become uninhabitable, immediately dangerous to life and health (IDLH) due to loss of power resulting In failed open

smokelCO 2 dampers. Access to these affected areas may be necessary to complete the

shutdown procedures during plant accidents. Plant procedures and SCBA are now In place to

provide timely worker protection and access and to Implement necessary shutdown actions.

D.C.Cook IR Nos. 50-315197015 & 97018 ANs 9711040026 and 9801210199 During the follow up In response to an industry generic communication, the licensee discovered

that a number of operators were not provided corrective lens Inserts for respirator use. The

licensee broadened Its Investigation and found that the respirator program contained no

provisions for tracking worker qualification. Of the 234 ERO, only 81 of the members had

maintained their qualifications (annual fit testing and medical evaluations). The licensee

Initiated proper short-term corrective actions and the Inspectors noted that no respirators had

been Issued to unqualified ERO members.

Kewaunee IR Nos. 50-305/97015 AN 8801020145 In response to an NRC Inspection finding of failure to provide annual fit testing requalification (in

two cases, no testing had been performed since 1994), the licensee Identified 21 plant staff and

24 security contractors had not received periodic fit testing. In these cases, all staff members

had completed their training and medical evaluations. Other than some fire brigade members

who wore respirators during required training exercises, no worker with out-of-date fit testing

had been required to wear a respirator. As part of the licensee corrective action follow up, the

licensee determined that the primary causes of the program weaknesses were (1) program

responsibility was not assigned to a single person or group and (2) the plant lacked an

administrative control procedure to track qualification.

Waterrord IR No.50-38219803 AQ803230145 The NRC Identified that the licensee had not maintained an adequate supply of properly sized

SCBA face pieces for the operating staffs for the control room and the technical support center.

Aside from being uncomfortable to the user, wearing a grossly mis-sized face piece could

reduce the duration of the rated air supply. The licensee promptly corrected this deficiency.

Attachment I

IN 98-20

June 3,1998 Prairie Island IR Nos. 50-282 & 306197-018 AN 9711250332 NRC Inspectors noted that annual retraining for operators In the donning and use of SCBA did

not require each operator to experience hands-on training. As a result, except for fire brigade

members, few operators had donned SCBA for several years.

RierBend IR Nos. 50-458197-010

AN 9709100212 During an NRC Inspection, the inspectors noted that the licensee had failed to develop a formal

Issue and tracking process to ensure that corrective lenses (of the appropriate type) for SCBA

use were provided to licensed operators. Although a procedure had been In place to require

either contact lenses or prescription spectacle kits (specific to the SCOA type), this procedure

was revised to ensure that personnel will be Issued corrective lenses.

South Texas Project IR No. 50-498 and 499/97-13 AN 9 101 302 The NRC inspector discovered that control room operators had not been trained to change out

SCBA air cylinders while wearing a SCBA In a hostile environment. The inability to effectively

change out an air bottle during a toxic gas accident could hamper operator response to the

emergency. Although members of the fire brigade were trained on change-out procedures, the

licensee initiated an evaluation to Identify needed improvements In the respiratory training

program.

Grand Gulf Station IR No. 50-416197-15 AN 971 016011 While observing a full-scale, biennial EP exercise, the NRC Inspectors identified a weakness In

the plant's ability to monitor and maintain adequate supplies of SCBA (air bottles and face

pieces) for the operations support center over the long term. This weakness could jeopardize

the licensee's ability to provide continued respiratory protection for the response teams

dispatched Into the plant. Critical remediation actions related to worker and plant safety could

be seriously hampered unless air bottles are recharged on a timely basis.

I>

Attachment 2 IN 98-20

June 3, 1998 LIST OF RECENTLY ISSUED

NMSS INFORMATION NOTICES

Information no_

Udle OT

Notice No. Subject Issuance Issued to

98-18 issuance- Isue tn

Recent Contamination Incidences IW

o3f Part 35 Medical Licensees

Resulting from Failure to Perform

Adequate Surveys

98-17 Federal Bureau of Investigations 5/7/98 All U.S. Nuclear Regulatory

(FBI) Awareness of National Commission fuel cycle and power

Security Issues and Responses and non-power reactor licensees

(ANSIR) Program

98-16 Inadequate Operational Checks 4130/98 All Industrial Radiography

of Alarm Ratemeters Licensees

98-12 Licensees' Responsibilities 413/1998 All U.S. Nuclear Regulatory

Regarding Reporting and Commission nuclear pacemaker

Follow-up Requirements for licensees

Nuclear-Powered Pacemakers

98-10 Probable Misadministrations 4/3/98 All Medical Licensees

Occurring During Intravascular

Brachytherapy With The

Novoste Beta-Cath System

98-09 Collapse of an Isocam II, Dual- 3/5/98 All medical licensees

Headed Nuclear Medicine Gamma

Camera

98-08 Information Likely to be Requested 3/3/98 All parts 30, 40, 70, 72 and 76 If an Emergency Is Declared licensees and certificate holders

required to have a Nuclear

Regulatory Commission approved

Emergency plan.

98-06 Unauthorized use of License 219198 All NRC Licensees authorized

to Obtain Radioactive Materials, to Possess Licensed Materials

and its Implications Under The

Expanded Title 18 of the JU-S. Code

98-04 1997 Enforcement Sanctions for 2/9/98 All U.S. Nuclear Regulatory

Deliberate Violations of NRC Commission licensees.

Employee Protection

Requirements

Attachment 3 IN 98-20

June 3, 1998 Page 1 of I

LIST OF RECENTLY ISSUED

NRC INFORMATION NOTICES

Information Date of

Notice No. Subject Issuance Issued to

98-19 Shaft Binding In General Electric 613198 All holders of operating licenses

Type SBM Control Switches for nuclear power reactors

98-18 Recent Contamination Incidences 5/13/98 Part 35 Medical Licensees

Resulting from Failure to Perform

Adequate Surveys

98-17 Federal Bureau of Investigations 5)7/98 All U.S. Nuclear Regulatory

(FBI) Awareness of National Commission fuel cycle and power

Security Issues and Responses and non-power reactor licensees

(ANSIR) Program

98-16 Inadequate Operational Checks 4/30/98 All Industrial Radiography

of Alarm Ratemeters Licensees

98-15 Intergrity of Operator Ucensing 4120198 All holder of operating licenses

Examinations for nuclear power reactors except

those that have permanently

ceased operations and have

certified that fuel has been

permanently removed from the

reactor vessel

98-14 Undocumented Changes to 4/20/98 All holders of operating licenses

Non-Power Reactor Safety or construction permits for test

System Wiring research reactors

98-13 Post-Refueling Outage Reactor 4120/98 All holders of operating licenses

Pressure Vessel Leak Testing for nuclear power reactors except

Before Core Criticality those that have permanently

ceased operations and have

certified that fuel has been

permanently removed from the

reactor vessel

OL = Operating Ucense

CP = Construction Permit

IN 98-20

June 3, 1998 Optimization of the internal and external doses often results in the determination that the use of

respirators to avoid a small intake can result in a larger external dose as a result of worker

inefficiency.

However, it appears that this de-emphasis of respiratory protection for normal operations may

have contributed to a potential decrease in the effectiveness of emergency response

capabilities involving respiratory protection. Along with this de-emphasis, the ongoing

restructuring and downsizing of the electric utility Industry places significant emphasis on cost

savings efforts. While no area of nuclear plant operation is immune from this cost scrutiny, licensees need to ensure that the effectiveness of EP response capabilities are maintained. As

previously discussed, plant operators and emergency response workers can face not only

radiological airborne hazards, but, in many cases, are challenged by unknown and potentially

IDLH conditions. Maintaining an adequate respiratory program is vital to their safety and, thus, to their ability to respond in a timely fashion to emergencies.

This information notice requires no specific action or written response. If you have any

questions about the information in this notice, please contact the technical contacts listed below

or the appropriate Office of Nuclear Reactor Regulation (NRR) project manager or appropriate

Office of Nuclear Material Safety and Safeguards (NMSS) Project Manager.

orig /s/'d by arig /s/'d by D.B Mathews FOR

Elizabeth Q. Ten Eyck, Director Jack W. Roe, Acting Director

Division of Fuel Cycle Division of Reactor Program Management

Safety and Safeguards Office of Nuclear Reactor Regulation

Office of Nuclear Material

Safety and Safeguards

Technical contacts: James E. Wigginton, NRR Lawrence K. Cohen, NRR

301-415-1059 301-415-2923 E-mail: jew2@nrc.gov E-mail:lkc@nrc.gov

Michael A. Lamastra, NMSS

301-415-8139 E-mail: mxl2@nrc.gov

Attachments:

1. Event Summaries

2. List of Recently Issued NMSS Information Notices

3. List of Recently Issued NRC Information Notices

See previous concurrence DOCUMENT NAME: G:\TXK\INRESPAl.con

To receive a copy of this document, indicate Inthe box C=Copy wlo attachmentlenclosure E=Copy with attachmentlenclosure N = No copy

OFFICE IPECB I C:PERB lIE C:PECB I NIVS~i l D:DRPMll

NAME TKoshy* _ CMiller*JStolz* yc JRoe*

DATE 04/30/98 j 05/05/98 [05/13/98 5 g /98 05/22/98

_EdjICOP

_nr

1 _/-c - =_ A RE __ _

Tech La Loalrde On 4/Z/9% OFFICIAL RECORD COQPY

IN 98-xx

May xx, 1998 Optimization of the internal and external doses often results in the determination that the use of

respirators to avoid a small intake can result in a larger external dose as a result of worker

inefficiency.

However, it appears that this de-emphasis of respiratory protection for normal operations may

have contributed to a potential decrease in the effectiveness of emergency response

capabilities involving respiratory protection. Along with this de-emphasis, the ongoing

restructuring and downsizing of the electric utility industry places significant emphasis on cost