ML20205T672
| ML20205T672 | |
| Person / Time | |
|---|---|
| Site: | Fort Saint Vrain  |
| Issue date: | 11/04/1988 |
| From: | Robert Williams PUBLIC SERVICE CO. OF COLORADO |
| To: | NRC OFFICE OF ADMINISTRATION & RESOURCES MANAGEMENT (ARM) |
| References | |
| P-88370, NUDOCS 8811140347 | |
| Download: ML20205T672 (8) | |
Text
- - - - - -
h/ Public Service' 51% b P.o. Box 840 Denver, Co Br01 0640 16805 WCR 19 1/2, Platteville, Colorado 80651 November 4, 1988 Fort St. Vrain Unit No. 1 P-83370 U. S. Nuclear Regulotury Commission ATTN:
Document Control Desk Washington, D.C.
20555 Docket No. 50-267
SUBJECT:
Response to NRC Inspection Report 88-17
REFERENCE:
- 1) NRC letter, Callan to Williams, dated September 21, 1988 (G-88382)
- 2) NRC letter, Callan to Williams, dated September 28, 1988 (G-88404)
Gentlemen:
This letter is in response to the Notice of Violation (Reference 1) received as a result of an inspection conducted by Mr. H.
D.
Chaney during the period July 24 through August 2, 19P8.
This inspection was re-transmitted to PSC (Reference 2) to include infomation omitted from Reference 1.
By telecon on October 28, Mr. Chaney granted PSC an extension to November 4,1988, to the response to this inspection.
PSC's responses to the Notice of Violation are contained in Attachment I to this letter.
Additionally, Mr.
Chaney identified some overall weaknesses in the PSC respiratory protection program.
The following infomation is provided to address these concerns.
G811140347 GG1104 PDR ADOCK 05000267 0
P-88370 Page 2 November 4, 1988
- 1) The overall respiratory protection program and lines of responsibility are not adequately defined in the Fort St. Vrain Administrative Procedures.
The Radiation Protection orgar.f zation administers the radiological respiratory protection program, and the corporate sa fety organization administers the non-radiological / industrial safety respira tory protection program.
This situation has resulted in confusion between the two organizations as to who is responsible for what portions of the program and uncertainty at the working level as to what requirements apply under any given condition.
- 2) The respiratory protection program training is inadequate due to the lack of program definition as stated above, isolated instances where attention to detail was overlooked, and the relative inexperience of some of the training instructors in this specific area.
PSC has initiated corrective actions to resolve these weaknesses, and thus far, the following actions have been completed:
- 1) PSC ceased taking credit for protection factors as requested by Mr. Chaney until all corrective actions have been completed.
- 2) As an interim measure, a standing order has been given to all Health Physics personnel who issue respiratory protection equipment requiring that they provide instructions in the proper methods for conducting negatise pressure fit testing and low bottle pressure alarm checks prior to issuance of respirators.
- 3) The training instructors responsible for respiratory protection training have completed a four day nuclear respiratory protection seminar to increase their familiarity with the issues and regulatory guidance associated with radiological and non-radiological applications of respiratory orotection.
- 4) The respiratory protection training lesson plans have been revised to include proper methods for conducting negative pressure fit testing and low bottle pressure alarm checks.
- 5) Coordination meetings have been held with the corporate safety organization, and program responsibilities and integration plans have been agreed to in concept.
i l
s.
i P-88370
)
Page 't November 4, 1988 Additional actions will be taken to ensure complete resolution of the weaknesses identified and preclude similar occurrences.
These actions and their target dates for completion are provided below.
- 1) Respiratory protection retraining to address proper methods for conducting negative pressure fit testing and low bottle pressure alann checks will be completed for all respirator qualified personnel by November 30, 1988.
- 2) Appropriate regulatory guidance will be reviewed and used to evaluate the Fort St. Vrain respiratory protection program.
T re results of this evaluation will be used in the development ;f procedures that will more clearly define the overall respiratory protection progra, and organizational lines of responsibility.
These procedures will be developed and implemented by December 31, 1988.
- 3) The respira tory protection training program will be further enhanced to reflect the improvements made in the overall program definition discussed above, to correct isolated training lesson plan omissions, and integrate corporate safety organization training for non-radiological / industrial safety applications of respiratory protection equipment.
The enhanced training lesson plans will be developed by January 31, 1989.
- 4) Remedial respiratory protection training will be provided to all respirator qualified personnel using the enhanced lesson plans by March 31, 1989.
Upon completion of the above corrective actions, Public Service Company will again begin utilizing Protection Factors as allowed by 10 CFR 20.103(c).
Should you have any further questions, please contact Mr. M. H.
Holmes at (303) 480-6960.
Sincerely, wk w
Cu R.O. Williams,Jh Senior Vice President Nuclear Operations R0W:FJN/pjb Attachment
P-88370 Page 4 November 4, 1988 cc: Regional Administrator, Region IV ATTN: Mr. T. F. Westennan Projects Section 8 Mr. Robert Farrell Senior Resident Inspector Fort St. Vrain
Attachment to P-88370 Page 5 November 4, 1988 The following responses to the items contained in the Notice of Violation are hereby submitted:
A.
Failure to Follow Administrative Procedures No response required as noted in the Notice of Violation.
B.
Failure To Follow Procedures Licensee Health Physics Procedure HPP-16 requires, in part, that prior to use, full face air purifying respirators be negatively pressure fit tested by the wearer to ensure air tightness at respirator sealing points.
Contrary to the above, the NRC inspector observed on July 26, 1988, two individuals improperly perform fit tests when donning full-face air purifying respiratory protection equipment prior to entering an airborne radioactivity area.
This is considered a Severity Level IV violation.
(Supplement IV) (267/8817-04)
(1) The Reason For The Violation If Admitted:
The violation is admitted.
Proper negative pressure fit testing procedures were not emphasized in the retraining program.
(2)
The Corrective Steps Which Have Been Taken And The Results Achieved:
The acting Health Physics Supervisor innediately issued a notice that informed all Health Physics personnel of the proper way to check a full-face respirator prior to use.
The training program was upgraded to emphasize proper fit testing procedures.
Until all personnel complete respiratory protection retraining, the Health Physics unit provides documented instructions in proper negative pressure i
fit testing procedures prior to issuance of respirators.
1 (3)
The Corrective Steps Which Will Be Taken To Avo_id Further Violations:
Instructions on conducting proper negative pressure fit tests will be maintained in the training and retraining programs.
l.
l t
Attachment to P-88370 Page 6 November 4,1988 (4) The Date When Full Compliance Will Be Achieved:
The identified respiratory protection retraining will be completed for all respirator qualified personnel by November 30, 1988.
C.
Respiratory Protection 20.103 10 CFR Part 20.103(c) requires, in part, "When respiratory protective equipment is used to limit the inhalation of airborne radioactive material....
The licensee may make allowance for this use of respiratory protective equipment in estimating exposures of individuals to this material provided that:
l The licensee maintains and implements a respiratory protection program that includes, fitting,... and testing of respiratory l
for operability inmediately prior to each use; written procedures i
regarding supervision and training of personnel."
l Licensee HPP-16 defines the licensee's available respiratory protection equipment, selection
- criteria, preuse
- testing, available protection factors, and equipment limitations. Also, licensee training lesson plan GE 018.03 defines the licensee presentation for respiratory protection training.
Contra ry to the above, the NRC inspector determined on July 28, 1988, during the presentation of respiratory protection training that instructions on both radiological and industrial applications of respiratory protection equipment were inadequate regarding fitting and testing for operability immediately prior to each use, and that HPP-16 did not implement adequate use instructions on all available respiratory protection equipment.
l This is considered a Severity Level IV violation.
(Supplement j
IV)(267/8817-02) l l
(1) The Reason For The Violation If Admitted:
l The violation is admitted.
Proper instructions for fitting and testing for operability were not adequately addressed in the training program. Also, Health Physics procedure, HPP-16, does not provide use instructions on all available respiratory protection equipment, more specifically those used for non-radiological / industrial safety application.
Attachment to P-88370 Page 7 November 4, 1988 (2) The Corrective Steps Which Have Been Taken And The Results Achieved:
In addition to the corrective action taken as described in the response to Violation 8817-04, the training and retraining programs were upgraded on August 4, 1988, to provide adequate instructions for testing for operability imediately prior to each use including the low pressure alarm test for the Self Contained Breathing Apparatus.
(3) The Corrective Steps Which Will Be Taken To Avoid Further Violations:
Procedures will be revised or developed as necessary to provide adequate use instructions for respiratory protection equipment, specifically, those used for non-radiological / industrial safety applications.
The training program will be revised to incorporate the changes as a result of the procedure revisions / development resulting from the programatic review described in the cover letter.
(4) The Date When Full Compliance Will Be Achieved:
Procedures will be revised and/or developed by December 31, 1988; subsequent training will be completed by March 31, 1989.
D.
Radiation Area posting 20.203 10 CFR Part 20.203 requires, in part, "Each radiation area shall be conspicuously posted with a sign or signs bearing the radiation caution symbol and the words: Caution Radiation Area."
10 CFR Part 202(b)(2) defines "Radiation Area," in part, "...
as any area accessible to personnel, in which there exists radiation
.. at such levels that a major portion of the body could receive in any one hour a dose in excess of 5 millirem, or in any 5 con *ecutive days a dose in excess of 100 millfrem;"
This requirement is for protection of personnel entering a 10 CFR Part 20.5 "Restricted Area," and is considered to encompass a nomal 40-hour, 5-day work week.
Contrary to the above, the NRC inspector determined on July 26, 1988, that the if censee's procedure for posting of radiation areas required posting only if general area radiation levels exceeded 2.5 millfrem per hour, and that some licensee personnel
Attachment to P-88370 Page 8 November 4,1988 were working a mandatory 6-day work week, with 91/2-hour work days. The combination of radiation levels and the 47.5 hours5.787037e-5 days <br />0.00139 hours <br />8.267196e-6 weeks <br />1.9025e-6 months <br /> in a 5-day period could cause an individual to exceed the 100 millfrem limitation.
This is considered a Severity Level IV violation.
(Supplement IV) (267/8817-03)
(1) The Reason For The Violation If Admitted:
The violation is admitted. HPP-9 Establishing and Posting Controlled Areas, did not consider working beyond a 40 hour4.62963e-4 days <br />0.0111 hours <br />6.613757e-5 weeks <br />1.522e-5 months <br /> week.
(2) The Correc tive Steps Which Have E.en Taken And The Results Achieved:
HPP-9 was revised on August 10, 1988 to require posting of Radiation Areas at 2.0 millfrem/ hour within the Restricted Area and 0.6 millirem / hour outside the Restricted Area based on PSC's evaluation contained in PPC-88-2564, attached.
(3) The Corrective Steps Which Will Be Taken To Avoid Further Violations:
The posting requirements now contained in HPP-9 will be maintained.
(4) The Date When Full Compliance Will Be Achieved:
Full compliance was achieved on August 10, 1988, when the revisions to HPP-9 were completed.
j I
i
!