View source for 05000237/FIN-2016002-01

{{finding
| title = Failure to Implement and Maintain Written Procedures Regarding Breathing Air Quality Testing
| docket = 05000237, 05000249
| inspection report = IR 05000237/2016002
| finding integer = 01
| quarter = 2016Q2
| IR section = 2RS3
| finding type = NCV
| significance = Green
| cornerstone = Or Safety
| violation of = 10 CFR 20, 10 CFR 20.1703
| identified by = NRC
| Inspection procedure = IP 71124.03
| Inspector = C Zoia, E Sanchez-Santiago, G Roach, J Cameron, J Seymour, M Learn, N Fields, R Elliott, R Ruiz, T Go
| CCA = H.1
| INPO aspect = LA.1
| description = A finding of very-low safety significance and an associated NCV of Title 10 of the Code of Federal Regulations (CFR), Part 20.1703, was an NRC-identified finding for failure to implement and maintain written procedures regarding breathing air quality that resulted in the failure to perform a continuous in-line breathing air quality test during filling of self-contained breathing apparatus (SCBA) cylinders since 2009. Specifically, on May 4, 2016, during an inspection of the licensees air compressor, the inspectors identified that the in-line carbon monoxide (CO) detector located at the compressor highpressure filling station was inoperable since 2009, the procedure does not specify an alternative method of CO monitoring during the filling of the SCBA cylinders. Without specifying an alternative method of monitoring and only relying on the high-temperature safety shut-off, hazardous CO gas could be introduced into the SCBA cylinders, thus degrading the Grade-D air quality, during a compressor malfunction. The licensees corrective actions included but were not limited to revising the applicable procedures, servicing or replacing the CO monitor by the manufacturer, and installing a new air compressor at the facility.  The inspectors determined that that the finding was more than minor in accordance with Inspection Manual Chapter (IMC) 0612, in that the finding impacted the program and process attribute of the Occupational Radiation Safety Cornerstone and adversely affected the cornerstone objective of ensuring adequate protection of worker health and safety from exposure to radiation through the use of SCBAs during an emergency response use by maintaining certified air quality. Specifically, the licensee failed to implement and maintain written procedures regarding an alternative method of monitoring air quality testing to maintain the Grade-D air quality during filling of SCBA cylinders. The finding was determined to be of very-low safety significance in accordance with IMC 0609, Appendix C, Occupational Radiation Safety Significance Determination Process, because it was not an as-low-as-reasonably-achievable planning issue, there was no overexposure nor substantial potential for an overexposure, and the licensees ability to assess dose was not compromised.  The inspectors concluded that the cause of the issue involved a cross-cutting component in the area of human performance, resources, in that, the license did not ensure the adequacy of the procedure describing the alternate methods of CO monitoring during filling of Grade D air into the SCBA cylinders. [H.1]
}}