ML19254E417
| ML19254E417 | |
| Person / Time | |
|---|---|
| Site: | Peach Bottom  |
| Issue date: | 09/14/1979 |
| From: | Gallagher J PECO ENERGY CO., (FORMERLY PHILADELPHIA ELECTRIC |
| To: | Brunner E NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION I) |
| Shared Package | |
| ML19254E415 | List: |
| References | |
| NUDOCS 7911010066 | |
| Download: ML19254E417 (3) | |
Text
a.
v PHILADELPHIA ELECTRIC COMPANY 2301 MARKET STREET P.O. BOX 8699 PHILADELPHI A. PA.19101 JOSEPH W. GALLAC HER stactmic enoou"cv c'a esenatusar (215)841 5003 September 14, 1979 Re:
Docket Nos.:
50-277 50-278 Inspection No.:
50-277/79-15 50-278/79-17 Mr. Eldon J.
Brunner, Chief Reactor Operati,ns and Nuclear Support Branch U.S.
Nuclear Regulatory Commission Region I 631 Park Avenue King of Prussia, PA 19406
Dear Mr. Brunner:
Your letter of August 24, 1979, forwarded Combined Inspection Report 50-277/79-15 and 50-278/79-17.
Appendix A to your letter addresses one item which did not appear to be in compliance with Nuclear Regulatory Commission requirements.
The item is categorized as an infraction and is restated below with our response.
10 CFR 20.103, " Exposure of individuals to concentrations of radioactive materials in air in restricted areas," requires in Section (C) that when respiratory protective equipment is used to limit inhalation of airborne radioactive material, allowance may be made for such use in estimating exposure provided that such equipment is used as stipulated in Regulatory Guide 8.15.
Section C.4.e of Regulatory Guide 8.15 requires that "The licensee is to maintain and implement c respiratory program that includes, as a minimum written operationa?, and administrative procedures for control, issuance, proper use, and return of respiratory protective equipment..."
Health Physics Procedure HP0/CO-9a, Revision 3,
dated December 27, 1978, " Respiratory Protection Training and Fitting" describes 1282.:~
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Mr. Eldon J.
Brunner Page 2 the Peach Bottom Respiratory Protection Trainini Program.
Section 3.0 states, "After completion of training and fitting, the instructor shall complete a respiratory equipment qualification label reflecting the individual's qualifications and the label must be attached to the back of the individual's security badge."
Health Physica Procedure HP0/CO-9, Revision 6, dated December 27, 1978, " Respiratory Protection Program" which describes the licensee's program. Section 4.3 states " Records of training and fitting shall be maintained for documentation and use in program evaluation.
A qualification label on the reverse of the security badge shall be used as a means of verifying each individual's qualification."
Contrary to the above, during the week June 11-15, 1979, one individual was identified, whose prior qualification had expired March, 1979, who had been issued a respiratory equipment qualification label valid through 1980 (no monthly expiration date) by a person or persons unknown, without receiving requisite retraining and qualification by an instructor and whose name did not appear on a current Respiratory Qualification List.
Response
The respiratory equipment qualification labels are preprinted labals wherein the expiration date and appropriate respiratory equipment qualifications are indicated by means of a hole punch In this case, the incorrect expiration year, 1980, had been mistakenly punched by the person issuing the label.
The individual in question had previously undergone a satisfactory fit test to demonstrate the ability of the respiratory equipment to provide the expected protection.
Additionally, the MPC-hour exposure records are calculated based on the current Respiratory Qualification List so that application of a protection factor to an unqualified individual will not occur.
For these reasons, it is highly unlikely the individual in question could have been exposed to airborne radiation levels in excess of those recorded.
As immediate corrective action, the production and validatirn of duplicate or replacement qualification labels, which had been a shared responsibility, has been assigned specifically to the training section.
Additionally, a review of all personnel records for respiratory protection was performed to ensure that respiratory equipment qualification labels in the field were correct.
1282.:.
e Mr. Eldon J.
Brunner Page 3 As an additional corrective action, a review of the respiratory protection program and implementing procedures has been commenced.
Appropriate program and procedure modifications, as necessary to clarify control of high airborne j ob s, MPC-hour calculations and documentation will be completed by January 1,
1980.
Very truly yours, j,f A -
1282 T