ML20070C967
| ML20070C967 | |
| Person / Time | |
|---|---|
| Site: | Nine Mile Point  |
| Issue date: | 10/22/1982 |
| From: | Lempges T NIAGARA MOHAWK POWER CORP. |
| To: | Starostecki R NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION I) |
| Shared Package | |
| ML20070C940 | List: |
| References | |
| NMP-5422, NUDOCS 8212140406 | |
| Download: ML20070C967 (3) | |
Text
.,e M Y NIAGARA R uMOHAWK NMP-5422 NIAGARA MOHAWK POWER CORPORATION /300 ERIE BOULEVARD WEST, SYRACUSE, N.Y.13202/ TELEPHONE (315) 4741511 October 22, 1982 bit. Pichard W. Starostecki, Director Division of Profeet and Residertt Programs United States Nuclear Regulatory Comission Region I 631 Park Avenue Icing of Prussia, Pennsylvania 19406 RE: 00cket No. 50-220 Inspection Report 82-14 Ocar blt. Starostecki This refers to.the routine, safety inspection conducted by bit. S. Hudson of yowt office on August 1-31, 1982 at Kine blite Point, Unit 1, Sotiba, New York of activities authorized by NRC License No. OPR-63 and to the discussions of yout findings hcid by blt. S. Hudson WLth bit. T. Roman of ont staf f at the conciasion of the inspection.
ITFJi A Technical Specification 6.11 states: " Procedures for per-sonnel 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."
Radiation Pretection Procedure RP-2, " Radiation Work Permit Procedure," Revision 1, dated February 13, 1979 requires in Section 5.6, that if a qualitative fit test is specified on the RWP, indication of having passed the test must be indicated by a "/ " in the " Passed Fit Test" column when signin! in.
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i 8212140406 021207 PDR ADOCK 05000220 i
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a Page 2 10/22/82' IR 82-14 R'JP #1166 dated August 26, 1982 for work inside the drywell and on. Reactor Building elevation 237', required a fit test-for those individuals wearing full face respirators.
Contrary to the above, on August 26, 1982, ten individuals required to wear full face respirators had not indicated that a qualitative-fit test had been performed.
This is a Severity Level V Violation (Supplement IV).
RESPONSE
in response to Appendix A of de above referenced Inspection Report, de following actiorts have beat taken:
The RWP ptocedure tats reviewed with respect to be necessity.
fot de ptocedure step cited in de violation. Although it is a recommended ptactice (NUREG 0041, Section 8.5.2.3).to perform a qualitative fit test whenever dontting a reophator, this is only one of a dozen o,t more ptocedural steps hat are performed in ne course of using a reophator.
In an attempt to assure dat a fit test is perfarmed, ne ptocedure step to require documattalion uf the fLt test sats added to de pro-cedure some years ago.
In ytaetice this has placed an unneces-sary administrative bwtden on workers using resphatory equip-ment, since donning a mask rarely, if ever, occurs at ne RWP tocation (access control point). The requited documerttation would have to be accomplished by danning ue mask at ne access point before it tats required.to be used (so de record could be made after ne test sats performed), or returning to be access poistt ptior to entering the airborne area or begingting ne task which would lead.to tJie creation of he airborne i
activity. Since neither of nese alterttatives are conveniertt, dere have been occasions Mien de " Passed Fit Test" column has been teft blank.
l We do not believe dat this ptocedural tapse actually reptesertts fallate to perform the recommended fit test.
l The RWP ptocedate tats revued (SORC reviewed 9/15/82) to ptovide a more reasonable and enforceable documentation requirement.
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Since seat tealutge is more likely to occur when using a haif-face respitator uan when using a fuit face respirator, ptocedure j
scetion 5.10 of RP-2 now requltes documentation of the perfor-mance of de fLt test only what using a half-face resphator when a ptotection factor u required.
To atswte de test has l
been performed, Section 5.11 requites de technician witnessing ue test to petfarm the documentation.
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'Page 3 10/22 /82 IR 82-14 ITEM A RESPONSE (Continued)
Since the above changes constltate a slight procedural relaxa-tion of requirements, tJie procedure change will be included in the General Employee Training revision currently being formulated, rather than by holding special training sessions. -Technicians will be informed of the change via supervisory insttuction and routed reading.
Full compliance wt.ll be considered achieved when.the supervisory insttuction has been routed to all technicians responsible for RWP. implementation.
This will be accomplished by October 31, 1982.
Very Ltuly yours
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t trr*r AL p~ff L Thomas E. Lempges Vice President, Nuclear Generation TEL/EFD/jm
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