05000373/FIN-2016002-02
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Finding | |
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Title | Failure to Implement and Maintain Written Procedures Regarding Respirator Fit Testing |
Description | A finding of very-low safety significance and an associated NCV of 10 CFR 20.1703 was identified by the inspectors on May 11, 2016, for the licensees failure to implement and maintain written procedures regarding respirator fit testing. The issue was entered into the licensees CAP as AR 2668632. Corrective actions included invalidating the results for the observed test, removing the qualification from the technician that performed the tests, reaffirmed the procedure requirements with all technicians through a read and sign process, and requested several changes to the fit test procedure RPAA444, Controlled Negative Pressure (CNP) Fit Testing to improve alignment to requirements in 29 CFR 1910.134, Appendix A, Fit Testing Procedures (Mandatory). The inspectors determined that not consistently performing fit tests in accordance the methods described in 29 CFR 1910.134, Appendix A, was a performance deficiency, the failure of which was reasonably within the licensees ability to foresee and prevent. This performance deficiency was determined to be more than minor, because it was associated with program and process attribute of the Occupational Radiation Safety cornerstone and affected its objective to ensure adequate protection of the worker health and safety from exposure to radiation from radioactive material during routine civilian nuclear reactor operation. Specifically, the respirator fit testing was being used to certify respirator protection factors of workers which were relied upon to provide protection of workers and any discrepancy affected the licensee's ability to control and limit radiation exposures from airborne sources. The inspectors determined that the finding had a very-low safety significance (Green) because the finding did not involve: (1) as-low-as-is-reasonably-achievable planning and controls, (2) a radiological overexposure, (3) a substantial potential for an overexposure, or (4) a compromised ability to assess dose. This finding had a cross-cutting aspect in the area of Human Performance, Resources. Specifically, the licensee did not ensure that personnel equipment, procedures, and other resources were available and adequate to support nuclear safety [IMC 0310 H.1]. |
Site: | LaSalle |
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Report | IR 05000373/2016002 Section 2RS3 |
Date counted | Jun 30, 2016 (2016Q2) |
Type: | NCV: Green |
cornerstone | Or Safety |
Identified by: | NRC identified |
Inspection Procedure: | IP 71124.03 |
Inspectors (proximate) | B Dickson D Chyu G Hansen J Cassidy J Robbins R Ruiz R Zuffa |
Violation of: | 10 CFR 20, Standards for Protection Against Radiation 10 CFR 20.1703, Use of individual respiratory protection equipment |
CCA | H.1, Resources |
INPO aspect | LA.1 |
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Finding - LaSalle - IR 05000373/2016002 | |||||||||||||||||||||||||||||||||||||||||||||||||||||||||||||||||||||||||||||||||||||||
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Finding List (LaSalle) @ 2016Q2
Self-Identified List (LaSalle)
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