ML20150E778
| ML20150E778 | |
| Person / Time | |
|---|---|
| Site: | Peach Bottom  |
| Issue date: | 03/28/1988 |
| From: | Gallagher J PECO ENERGY CO., (FORMERLY PHILADELPHIA ELECTRIC |
| To: | Kane W NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION I) |
| References | |
| NUDOCS 8804040091 | |
| Download: ML20150E778 (4) | |
Text
...
4 PHILADELPHIA EL'2CTRIC COM PANY 2301 MARKET STREET P.O. BOX 8699 PHIL ADELPHI A, PA 19101 (as s) s4i sooi March 28, 1988 Joss;j,$,,jA g,(AGHER Docket Nos. 50-277 yCLEAR S E RVIC E.
50-278 I
W Mr. William F. Kane, Director Division of Reactor Projects Region I U.S. Nuclear Regulatory Ccmmission Attn: Document Control Desk Washington, DC 20555
Subject:
Response to Combined Inspection Report Nos. 50-277/88-01; 50-278/88-01
Dear Mr. Kane:
Your letter of February 26, 1988 transmitted Combined Inspection Report Nos. 50-277/88-01; 50-278/88-01 concerning the i
routine resident safety inspection conducted January 1, 1988 to i
February 5, 1988.
Appendix A of the letter identified one activity which appeared not to have been conducted in full compliance with NRC requirements.
3 Attachment A of this letter pr^vides a restatement of this i
item, followed by the Philadelphia Electric Company's response.
If you have any questions or require additional information, please do not hesitate to contact us.
l Very truly yours, 1
Attachment l
cc:
Addressee W.
T. Russell, Administrator, USNRC Region I T. P. Johnson, USNRC Resident Site Inspector p{
T.
E. Magette, State of Maryland
' \\
8804040091 880328 PDR ADOCK 05000277 G
~.---
- ~.
1
-Attachmant A'
.i Pags 1 of 3 t
Docket Nos. 50-277 50-278 i
Restatement of Violation A.
Technical Specification section 6.8.1 requires that written procedures be established, implemented, and maintained that meet the requirements of section 5.1 of ANSI-N18.7-1972, and Appendix A of Regulatory Guide 1.33 (November 1972).
ANSI N18.1-1972, section 5.1 requires the station to be operated ~in accordance with written procedures.
Regulatory Guide 1.33, Appendix'A, section G, part 5, requires-procedures for respirator equipment.
Health Physics (HP) procedure HP-500, Rev. O, "Respiratory 3
Protection Program," requires all individuals.to be responsible for using respiratory. protective equipment for I
which they are qualified, and supervisors to be responsible i
for assuring that workers under their authority are using the j
correct respiratory equipment.
HP-512. Rev. O, "Issue and Control of Respiratory Protection Equipment," raquires issue control point attendants to issue respiratory equipment for which the individual is qualified.
Contrary to the above, on January 20, 1988, a worker was issued and used a mask which the worker was not qualified to
)
wear with the apparent knowledge of the worker's supervisor; 1
and, the issue control point attendant issued a respirator l
(Ultraview mask) to an individual who was not qualified to wear it.
This is a Severity Level IV violation (Supplement IV) i I
Response to Violation Admission or Denial of Alleged Violation:
I
)
Philadelphia Electric Company admits that the violation did occur, as described above.
i Reason for the Violations i
This violation occurred as described in the Notice of I
Violation because the worker was not refitted for the proper size I
"Ultraview Respirator".
The refit was needed as the worker had gained j
an appreciable amount of weight in the seven months since his initial qualifications and fit.
The worker requested the medium "Ultraview j
Respirator", although he was qualified to wear a small.
Procedure HP-2 512 requires that the issue control point attendant refer to the 4
h 4
I
f Attachment A Page 2 of 3 4
Docket Nos. 50-277 50-278 computerized "Respiratory Qualification List" to verify a worker's qualifications before issuing him respiratory equipment.
For each l
worker, the l'ist shows which of six types of respiratory equipment, as well as what size "Ultraview Respirator" he is qualified to wear.
4 Despite this, the issue control point attendant issued the medium respirator and the worker proceeded.
The supervisor violated i
procedure HP-500 by not assuring that the worker used the correct equipment.
Additionally, the inspector's report shows that the supervisor assigned the worker duties where the "Ultraview Respirator" I
was required on January 20, 1988 and delayed his refitting.
PECo records show the first refit request was made on January 26, 1988.
The inspector's report goes on to state that when the worker received the medium respirator that the supervisor was cognizant of this activity and did not act to prevent it.
Extent of Significance of the Violation:
Use of respiratory equipment by unqualified workers could result in internal radiological contamination.
In this case, however, radiological air samples and the worker's post-incident whole body count reveal that he received no internal contamination as a result of the violation.
The air samples indicated the contamination concentration to be 4.89E-12 uCi/cc, 0.7% of the administrative limit a
requiring respiratory protection.
Health physics records show that he worked in the area for 1.75 hours8.680556e-4 days <br />0.0208 hours <br />1.240079e-4 weeks <br />2.85375e-5 months <br />.
Corrective Actions Taken and Results Achieved:
The worker involved was suspended from the "Respiratory Qualification List" until he was re-fitted for the "Ultraview i
Respirator" on January 26.
By February 9, 1988, all issue control point attendants were notified of this event.
They participated in a re-training session i
where details of this event were discussed, the procedure (HP-512) and the importance of following the procedure were emphasized.
Additionally, signs were posted at all respiratory equipment issue locations to outline pre-issue checks and requirements, t
The procedure which governs the issuing of respiratory i
equipment, HP-512, was revised on February 11, 1988.
The revision i
requires written authorization from health physics supervision to issue respiratory equipment if a discrepancy exists on the list.
At i
the time of the incident, the issue control point attendant could accept verbal confirmation of the apparent error from a clerk in the dosimetry office and issue the approved equipment.
This written l
approval provides assurance that only properly qualified workers receive respiratory equipment.
Strengthening the procedural controls i
Y l
)
Attachment A Page 3 of 3 Docket Nos. 50-277 50-278 j
will reduce this type of personnel error / deviation.
Since S
iraplementation of these corrective actions, no other similar incidents have been reported.
I t
Corrective Actions to be Taken to Avoid Future Non-Compliance i
Issue control point personnel will be re-trained to the s
requirements for written approval in accordance with the revised s
procedure.
In addition, health physics personnel will review the ld 4
revisions with station work groups and their supervisors.
.)
~
s t.:
Date When_ Full Compliance Will Be Achieved:
- yp The additional staff training, posted guides and work group reviews will assure compliance with the NRC regulations.
These
!M measures are underway and will be complete by April 29, 1988.
g.$.g b
R m
'M 3
- _ _ _ - - _