ML17258B173
| ML17258B173 | |
| Person / Time | |
|---|---|
| Site: | Ginna  |
| Issue date: | 06/22/1981 |
| From: | Joyner J NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION I) |
| To: | |
| Shared Package | |
| ML17258B171 | List: |
| References | |
| 50-244-81-07, 50-244-81-7, NUDOCS 8107100257 | |
| Download: ML17258B173 (4) | |
Text
APPENOIX A NOTICE OF VIOLATION Rochester Gas and Electric Company E. Ginna Nuclear Plant Oocket No. 50-244 License No.
DPR-18 As a result of the inspection conducted on March 22-26, 1981 and in accordance with the Interim Enforcement Policy, 45 FR 66754 (October 7, 1980),
the following violation was identified:
10 CFR 20.103(c),
"Exposure of individuals to concentrations of radioactive materials in air in restricted areas,"
requires in part that:
"When respiratory protective equipment is used to limit the inhalation of airborne radioactive material pursuant to paragraph (b)(2) of this section, the licensee may make allowance for such use in estimating exposure of individuals to such materials provided that such equipment is used as stipulated in Regulatory Guide 8.15, Acceptable Programs for Respiratory Protection."
1.
Section C.4 of Regulatory Guide 8.15 states in part, "The licensee is to maintain and implement a respiratory protection program that
- includes, as a minimum... d. Written procedures to ensure full effectiveness of respiratory protection equipment including procedures for... inspection repair and storage...
- e. Written operational and administrative procedures for control, issuance, proper use... of respirator protective equipment,...
g.
Records sufficient to permit periodic evaluation of the... program."
Contrary to the above, as of March 22, 1981 the licensee's respiratory protective equipment maintenance procedure did not contain provisions for proper storage of respirator facepieces.
Facepieces were stored 4-5 layers deep which could result in facepiece deformation no inspection procedures existed for new respiratory protective equipment inspection, maintenance procedures for used respiratory protective equipment did not prohibit interchanging of respirator components, and no repair procedures existed for respiratory protective equipment other than for self-contained breathing apparatus.
8107i00257 Si 0622 PDR ADOCK 05000244 PDR
1
Appendix A 2.
Section C.5 of Regulatory Guide 8.15 states, "The licensee is to use equipment approved under appropriate Approval Schedules in 30 CFR Part-ll of U.S.
Bureau of Mines/National Institute for Occupational Safety.
Contrary to the above, as of March 22,
- 1981, the licensee was using a non-approved respirator facepiece/filter combination and did make allowance for such use.
3.
Section C.8 of Regulatory Guide 8.15 states in part, "As a minimum the following additional technical items are to be observed:
- a. Respirable air 'of approved quality and quantity is to be provided and oxygen deficiency is to be avoided (NUREG-0041 Section... 5.2.4,1...)"
Section 5.2.4.1 of NUREG-0041 specifies acceptable limiting characteristics for breathing air.
Included in these characteristics is the requirement that breathing air have no pronounced odor.
Contrary to the above, as of March 22, 1981 the licensee was not performing or documenting odor tests.
This is a Severity Level IV Violation /Supplement IV).
Pursuant to the provisions of 10 CFR 2.201, Rochester Gas and Electric Company is hereby requi red to submit to this office within thirty days of the date of this Notice, a written statement or explanation in reply, including:
(1) the corrective steps which have been taken and the results achieved; (2) corrective steps which will be taken to avoid further violations; and (3) the date when full compliance will be achieved.
Under the authority of Section 182 of the Atomic Energy Act of 1954, as
- amended, this response shall be submitted under oath or affirmation.
'2.2 JUN 1gei a es H. Joyn, C ief chni'cal In ection Branch
b