ML19341D523

Responds to NRC 801222 Ltr Re Violations Noted in IE Insp Rept 50-333/80-03.Corrective Actions:Policy Statement on Respiratory Usage Issued.Acceptability of Supplied Breathing Air Verified Per Reg Guide 8.15

ML19341D523
Person / Time
Site:	FitzPatrick
Issue date:	01/19/1981
From:	Pasternak R POWER AUTHORITY OF THE STATE OF NEW YORK (NEW YORK
To:	Grier B NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION I)
Shared Package
ML19341D521	List: ML19341D523
References
JAFP-81-0044, JAFP-81-44, NUDOCS 8103050752
Download: ML19341D523 (2)

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V POWER AUTHORITY OF THE STATE OF NEW YORK JAMES A. FITzPATRICK NUCLEAR POWER PLANT RAYMOND J. PASTERNAK Resident Menegar S P.O. BOX 41 Lycoming. New York 13093 315-342 3840 January 19, 1981 SERIAL: JAFP-81 -0044 Boyce H. Grier United States Nuclear Regulatory Commission Region I 631 Park Ave.

King of Prussia, PA 19406

Subject:

INSPECTION NO. 50-333/80-03 -

Dear Mr. Grier:

With reference to the inspection conducted by Mr. R. Nimitz of your office on March 11-14, 1980 at the James A. FitzPatrick Nuclear Power Plant, and in accordance with the provisions of Section 2.201 of Part ll of Title 10 of the Code of Federal Regulations, we are submitting our response to Appendix A, Notice of_ Violation transmitted by your letter dated December 22, 1980 as received by the undersigned on January 2, 1981.

APPENDIX A NOTICE OF VIOLATION Based upon the results of an NRC inspection conducted on March 11-14, 1980 it appears that one of your activities was not conducted in full compliance with NRC regulations as indicated below. This item is an infraction.

10 CFR 20.104(c), " Exposure of individuals to concentrations of radioactive materials in air it restricted area" requires in part that: When respiratory protective equipment is used to limit the inhalation of airborne radioactive material pursu'nt to paragraph (b)(2) of this section, the licensee may make allowance for such use in estimating exposure of individuals to such materials provided that such equipment is used as stipulated in Regulatory Guide 8.15.

" Acceptable Programs for Respiratory Protection."

1. Section C.1 of Regulatory Guide 8.15 states in part, "A wri tten policy statement on respirator usage is to be issued from a high management level.

Subjects to be covered by the policy statement include the use of practicable engineering controls instead of respirators, routine, nonroutine, and emergency situations..."

Contrary to the above, as of March 11, 1980 allowance was being made for use of respiratory protective equipment and no written policy statement on respirator usage had been issued from a high management level.

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2. Section C.8 of Regulatory Guide 8.15 states in part, "As a minimum, the following additional technical items are to be observed: a. Respirable ai r of approved quality and quantity is to be provided and oxygen deficiency is to be avoided..."

Contrary to the above, as of March 11, 1980 allowance was being made for use of respiratory protection equipment and the licensee falled to determine that breathing air of approved quality, quantity and air not deficient in oxygen was being provided workers using the facility breathing air system.

Response To items 1 and 2 A policy statement on respiratory usage was written and issued in accordance with Regulatory Guide 8.15 " Acceptable Programs for Respiratory Protection". The policy statement contained in Plant Standing Order No. 2 "JAFNPP ALARA and Respiratory Protection Policies", section 7.2 was patterned after NUREG-0041 Chapter 2 " Basic Policy Regarding Use of Respirators. Section 7.2 was reviewed and accepted by the Plant Operations Review Committee on 11/4/80 and was implemented by 11/15/80.

As noted in the inspection details, the supplied breathing air was tested in accordance with Regulatory Guide 8.15 " Acceptable Program for Respiratory Protection".

The results of this test verified that breathing air supplied by this system met or exceeded Grade D air as described in Compressed Gas Association, "Cummodity Specification for Air", G-7.1-1966.

The completion of these actions resulted in the FitzPatrick Plant beino in full compliance by 11/15/80.

Very truly yours, f '

RJP: EAM:j lk Raymond J. Pasternak Resident Manager CC: Gcsrge T. Berry - NYO J. P. Bayne - NYO J. F. Davis - NYO G. M. Vilverding - NY0 J. Kelly - NY0 R. Baker - J4F M. C. Cosgrove - JAF E. A. Mulcahey HRC Resident inspector - JAF Documert Control Center l

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