ML19309D421

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Responds to NRC Re Violations Noted in IE Insp Rept 50-334/79-26.Corrective Actions:Type of Respiratory Equipment Cited in Violation Has Been Removed from General Issue
ML19309D421
Person / Time
Site: Beaver Valley
Issue date: 02/13/1980
From: Dunn C
DUQUESNE LIGHT CO.
To: Grier B
NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION I)
Shared Package
ML19309D414 List:
References
NUDOCS 8004100358
Download: ML19309D421 (3)


Text

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'Af (412) 456-6000 435 Sixth Avenue Pittsburgh, Pennsylvania 15219 February 13, 1980 United States Nuclear Regulatory Commission Office of Inspection and Enforcement Attn: Boyce H. Grier, Regional Director Region I 631 Park Avenue King of Prussia, Pennsylvania 19406

Reference:

Beaver Valley Power Station, Unit No. 1 Docket No. 50-334, License No. DPR-66

.E.

Inspection No. 79-26

Dear Mr. Grier:

In response to your letter of January 18, 1980 and in accordance wita 10 CFR 2.201, the attached reply addresses the Notice of Violation which was included as Appendix A of the referenced Inspection Report. The noted violation was failure to follow procedures.

We have reviewed the referenced Inspection Report for infor-mation subject to claim from withholding from disclosure u. der 10 CFR 2.790 and no such information was identified.

If you have any questions concerning this response, please contact my office.

Very truly yours, f

C. N. Dunn Vice President, Operations Attachment 8 0041003 5T

~.

DUQUESNE LICHT COMPANY Beaver Valley Power Station Unit No. 1 Reply to Notice of Violation Inspection No. 79-26 Letter Dated January 18, 1980 Description of Infraction (79-26-01)

Technical Specification 6.11 requires that " 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." 10 CFR 20.103(c) states in part "When respiratory protective equipment is used to limit the inhalation of airborne radioactive material.

. the licensee may make allowance for such use.

. provided that such equipment is used as stipulated in Regulatory Guide 8.15.

." Regulatory Guide 8.15 requires in section C.4.e " Written operational and administrative procedures for control, issuance, proper use and return of respiratory protective equip-ment.

." The licensee's maintenance manual Chapter 1 Section Y " Control and Maintenance of Respiratory Equipment" states that when issuing respirators, "The house and yard personnel at the issue / storage location shall assure that each individual of the work force has completed the required training using the training list."

Contrary to the above requirements, during the period November 21-23, 1979, on three occasions respirators were issued to personnel who were not on the training list and on one occasion a respirator was issued to an individual who was not listed for that type of respirator.

Corrective Action A review of all Radiological Work Permits issued for the time period November 21-23, 1979 were reviewed. The review indicated that respiratory protection equipment issued to personnel was for precautionary measures only and the protection factors were not required.

Action Taken to Prevent Recurrence The logging and issuance of respiratory protection equipment was reviewed with the personnel responsible for issuance at the time the noncompliance was discovered. The procedure under which respiratory. equipment is issued has been reviewed and signed off b'y all ' personnel responsible for issuance of the respiratory equipment.

For the portion of this infraction where a respirator was issued' to an individual who was not listed for that type of respirator, the respirator actually issued is quite similar in design and identical in operation to the type for which that

Reply to Notice of Violation Inspection No. 79-26 Letter Dated January 18, 1980 Page 2 Action Taken to Prevent Recurrence - Continued individual had been trained. To avoid this type of error in the future, the type of respirator involved in this infraction has been removed from general issue and will only be issued in those instances where its special design features are advantageous (ie: welding) and only upon the approval of the Radiation Control Foreman who shall assure that a proper fit is achieved on the individual to whom this respirator is to be issued.

Date On Which Pull Compliance Will Be Achieved Full compliance has been achieved at this time.

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