Information Notice 2014-15, Inadequate Controls of Respiratory Protection Accessibility, Training, and Maintenance
| ML14217A041 | |
| Person / Time | |
|---|---|
| Site: | Hatch, Watts Bar, Ginna, Robinson, Quad Cities  |
| Issue date: | 12/01/2014 |
| From: | Camper L, Michael Cheok, Kokajko L Division of Decommissioning, Uranium Recovery and Waste Programs, Division of Construction Inspection and Operational Programs, Division of Policy and Rulemaking |
| To: | |
| M Banic, 301-415-2771 | |
| References | |
| IN 2014-15 IN-14-015, IR 2003003, IR 2006003, IR 2007002, IR 2009003 | |
| Download: ML14217A041 (7) | |
ML14217A041 UNITED STATES
NUCLEAR REGULATORY COMMISSION
OFFICE OF NUCLEAR SECURITY AND INCIDENT RESPONSE
OFFICE OF NUCLEAR REACTOR REGULATION
OFFICE OF NEW REACTORS
OFFICE OF NUCLEAR MATERIAL SAFETY AND SAFEGUARDS
WASHINGTON, DC 20555-0001
December 1, 2014
NRC INFORMATION NOTICE 2014-15:
INADEQUATE CONTROLS OF RESPIRATORY
PROTECTION ACCESSIBILITY, TRAINING, AND
MAINTENANCE
ADDRESSEES
All holders of an operating license or construction permit for a nuclear power reactor or a
non-power (research or test) reactor under Title 10 of the Code of Federal Regulations
(10 CFR) Part 50, Domestic Licensing of Production and Utilization Facilities, including those
that have permanently ceased operations and have certified that fuel has been permanently
removed from the reactor vessel.
All holders of and applicants for a power reactor early site permit, combined license, standard
design certification, standard design approval, or manufacturing license under 10 CFR Part 52, Licenses, Certifications, and Approvals for Nuclear Power Plants.
PURPOSE
The U.S. Nuclear Regulatory Commission (NRC) is issuing this information notice (IN) to
inform addressees of inspection findings related to weaknesses in licensee respiratory
protection programs supporting emergency preparedness. Inadequate controls of
accessibility, training, and maintenance of self-contained breathing apparatuses (SCBAs) has
led to numerous violations since 2001. Specifically, this IN intends to inform licensees of the
importance of having adequate procedures to properly implement and maintain an effective
respiratory protection program
The NRC expects 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 do not constitute NRC requirements; therefore, no specific
action or written response is required.
DESCRIPTION OF CIRCUMSTANCES
The findings detailed below (additional findings included as an attachment) represent various
weaknesses in respiratory protection programs that the NRC identified subsequent to
distribution of information notices discussed below.
Missing SCBA Spectacle Kit at Clinton Power Station
On May 12, 2011, during an observation of SCBA maintenance inspection activities in the
control room, the inspectors identified that one of the operating shift crew who wore eyeglasses
did not have a corrective lens kit in the designated storage location. A licensee investigation
determined that the missing spectacle kit was the result of a program weakness. Specifically, the process used for establishing the medical readiness of control room operators did not
ensure operators had received SCBA corrective lens inserts before assuming watch
responsibilities.
Additional information appears in Clinton Power Station, NRC Integrated Inspection Report 05000461/2011-004, dated November 3, 2011, available on the NRCs public Web site in the
Agencywide Documents Access and Management System (ADAMS) under Accession
No. ML11308A056.
Failure to Provide Adequate SCBA Respirator Masks at Columbia Generating Station
During an inspection completed on July 23, 2009, NRC inspectors evaluated the adequacy of
SCBA units staged in the control room for emergency use. The licensee staged six SCBA units
for emergency use. The units contained medium respirator masks. On top of the units were
staged one small mask, one large mask, and one extra-large respirator mask. NRC inspectors
identified that three of the licensed control room operators on the day shift on July 22, 2009, were fit-tested for small respirator masks. In the event of an emergency requiring immediate
respiratory protection, two of the three licensed operators who were fit-tested in small respirator
masks would not have been qualified to use the pre-staged SCBA equipment and may have
been unable to function in the event the control room became uninhabitable.
Additional information appears in Columbia Generating StationNRC Radiation Safety Team
Inspection Report 05000397/2009009, dated September 15, 2009, on the NRCs public Web
site in ADAMS under Accession No. ML092600874.
Expired SCBA Qualifications at Diablo Canyon Power Plant
On August 7 through 9, 2011, an operator filled an on-shift emergency response organization
position for three consecutive shifts with expired SCBA respiratory protection qualifications. The
licensee did not ensure the operator obtained the proper requalification training, an action that
did not provide the emergency worker the full range of available protective actions as specified
in 10 CFR 50.47(b)(10). Although the licensee was aware that the operators respiratory
qualification had expired, the operators supervisor determined that the licensee met its
technical specification minimum complement of qualified operators and considered that the
minimum emergency response organization complement did not require respiratory
qualification. The Diablo Canyon technical specification required number of operators is less than the Emergency Plan required number of operators. The licensees determination was in
error because the required minimum of emergency response organization on-shift staff
personnel is required to respond to all emergencies and, therefore, requires that staff members
be fully qualified for their response functions.
Additional information appears in Diablo Canyon Power PlantNRC Integrated Inspection
Report 05000275/2011004 and 05000323/2011004, dated November 18, 2011, on the NRCs
public Web site in ADAMS under Accession No. ML113220067.
Failure to Properly Test and Maintain SCBA Bottles at Quad Cities Nuclear Power Station
During walkdowns of in-service SCBA equipment on February 8, 2007, the inspectors identified
that several SCBA air bottles did not have current hydrostatic tests. The SCBA equipment was
strategically located in various areas of the plant to support emergency response activities
including the main control room. Following the inspectors identification of the problem, the
licensee determined that approximately 12 percent of the SCBA air bottles (26 bottles) in the
stations in-service inventory had not been tested for periods ranging from just over 3 years up
to nearly 7 years. According to the licensees preliminary evaluation, the bottles were acquired
in 2001 and placed into service without the knowledge of the radiation protection staff
responsible for SCBA equipment inspection. Consequently, those particular bottles were not
tracked as part of the licensees bottle inventory. While the licensee performed monthly
inspections of all in-service SCBA equipment, including all air bottles, those inspections failed to
identify the problem because the procedure governing the inspection activity did not require that
bottles be checked to ensure current hydrostatic testing.
Additional information appears in Quad Cities Nuclear Power Station, Units 1 and 2, NRC
Integrated Inspection Report 05000254/2007002 and 05000265/2007002, dated May 3, 2007, on the NRCs public Web site in ADAMS under Accession No. ML071230732.
BACKGROUND
Self-contained breathing apparatuses (SCBAs) are used in the event the control room
operators, who are key responders identified in the emergency plan, must perform licensed
duties while wearing respiratory protection during certain postulated accidents. As such, SCBAs must be properly maintained and accessible to trained individuals in the event of an
emergency that requires respiratory protection.
The NRC issued Information Notice 98-20, Problems with Emergency Preparedness
Respiratory Protection Programs, on June 3, 1998. That notice informed licensees of various
weaknesses in licensee respiratory protection programs, including but not limited to the various
weaknesses that are reemphasized in this IN. Specifically, this IN addresses recurring
problems relating to the availability of corrective lenses, availability of masks in the proper sizes, manufacturer-specified maintenance and testing, as well as appropriate licensed operator
training. In addition, the NRC issued Information Notice 97-66, Failure to Provide Special Lenses for
Operators Using Respirator or Self-Contained Breathing Apparatus during Emergency
Operations, on August 20, 1997, to address the accessibility of SCBA to licensed operators
during emergency response.
DISCUSSION
The NRC requires licensees to comply with 10 CFR 50.54(b)(10), which states, in part, that a
licensee must provide adequate protective measures for emergency workers. Each of the
above descriptions (and those included in the attachment) resulted in a violation of NRC
regulations.
The NRC has consistently dispositioned inadequate controls of accessibility, training, and
maintenance of SCBAs as more than minor safety significance. SCBAs are an integral piece of
emergency response equipment for radiological and oxygen deficient atmospheres. As such, SCBAs are an integral piece of safety equipment for Fire Protection Plans and Emergency
Response Plans. They are used extensively by Onsite Fire Brigades for immediate fire-fighting
response and emergency workers for radiological protection. When they cannot provide
adequate personnel protection, a degradation of emergency response is likely to occur and the
consequences could be life-threatening. The examples used in this IN, that have all been cited
following the release of IN 98-20, detail the varied nature of issues that have been identified
related to respiratory protection programs. The NRC believes that the nature of these findings
may be indicative of an ongoing trend that was not adequately addressed following the
publication of the previous INs.
This IN informs licensees that they may benefit from further evaluating the adequacy of controls
for their respiratory protection program. Regulations in 10 CFR 20.1703, Use of Individual
Respiratory Protection Equipment, require, in part, that each worker that may be required to
wear an SCBA be fit tested and properly trained. It is important that licensees maintain current
and comprehensive oversight. A strong oversight program would ensure not only that each
worker is appropriately fit tested, trained, and qualified, but also that respirator mask sizes are
staged and available to meet any potential demand, and that corrective lens kits are available at
all times to all users who require them. A strong oversight program would also ensure that each
piece of equipment is systematically tested and maintained in accordance with guidelines
agreed to by the manufacturer and licensee.
CONTACT
S
This information notice requires no specific action or written response. Please direct any
questions about this matter to the technical contact listed below or the appropriate NRC
project manager.
/RA/
/RA/
Lawrence E. Kokajko, Director
Larry W. Camper, Director
Division of Policy and Rulemaking
Division of Decommissioning, Uranium Recovery
Office of Nuclear Reactor Regulation
and Waste Programs
Office of Nuclear Material Safety and Safeguards
/RA/
Michael C. Cheok, Director
Division of Construction Inspection
and Operational Programs
Office of New Reactors
Technical Contact:
Jonathan Fiske, NSIR/DPR/DDEP/IRIB
301-287-9228 E-mail: Jonathan.Fiske@nrc.gov
Note: NRC generic communications may be found on the NRC public Web site, http://www.nrc.gov, under Electronic Reading Room/Document Collections.
ML14217A041 *concurred via email
TAC MF4551 OFFICE PM:NSIR*
Tech Editor*
BC:IRIB:NSIR* D:DPR:NSIR
BC:DUWP:NMSS* LA:PGCB:NRR*
NAME JFiske
RKahler
RLewis
BWatson
CHawes
DATE
04/21/14
07/09/14
10/22/14
09/12/14
10/22/14
11/12/14 OFFICE PM:PGCB:NRR BC:PGCB:NRR DD:DCIP:NRO DD: DUWP:NMSS DPR:NRR
DPR:NRR
NAME MBanic
SStuchell
MCheok
LCamper
AMohseni
LKokajko
DATE
11/14/14
11/17/14
11/20/14
11/18/14
11/24/14
12/01/14
Attachment
Additional Findings
Operators Did Not Have Corrective Lens Kits Available to Implement Emergency Plan
Requirements at Ginna Nuclear Power Plant
Information available in Ginna Nuclear Power PlantU.S. Nuclear Regulatory Commission
(NRC) Integrated Inspection Report 05000244/2009003, dated July 27, 2009, on the NRCs
public Web site in Agencywide Documents Access and Management System (ADAMS) under
Accession No. ML092080369.
Failure to Provide Proper Size Respirator Masks for Respiratory Protection at H.B. Robinson
Information available in H.B. Robinson Steam Electric PlantNRC Integrated Inspection Report 05000261/2007002, dated April 20, 2007, on the NRCs public Web site in ADAMS under
Accession No. ML071100293.
Failure to Perform Air Quality Test for Compressors Used to Supply Emergency Preparedness
SCBA Breathing Air Tanks at Watts Bar
Information available in Watts Bar Nuclear PlantNRC Integrated Inspection Reports
05000390/2006003 and 05000391/2006003, dated July 25, 2006, on the NRCs public Web site
in ADAMS under Accession No. ML062060218.
SCBA Training Procedure Did Not Require Users To Demonstrate Changing Bottles at Edwin I.
Hatch
Information available in Edwin I. Hatch Nuclear Power PlantNRC Integrated Inspection
Reports 50-321/02-03 and 50-366/02-03, dated July 26, 2002, on the NRCs public Web site in
ADAMS under Accession No. ML022100427.