- About NRC           - The Commission
      - Statutory Authority
      - Strategic Plan
      - Budget &  Performance
      - Organization & Functions
      - Locations
      - History
      - Values
      - Policymaking
      - Radiation Protection
      - Fire Protection
      - How We Regulate
      - Grants
      - Civil Rights
      -     
    - NuclearReactors           - Operating Reactor Locations
      - Reactor Quick Links
      - Power Reactors
      - Research and Test Reactors
      - Operating Reactors
      - Operator Licensing
      - New Reactors
      - Operator Licensing for New Reactors
      - Reactor Safety Research
      - Advisory Comm (ACRS)
      - Decommissioning of Nuclear Facilities
      -     
    - NuclearMaterials           - Fuel Cycle Facility Locations
      - Uranium Recovery Locations
      - Materials Quick Links
      - Special Nuclear Material
      - Source Material
      - Byproduct Material
      - Med, Academic & Ind Uses
      - Source Materials Facilities
      - Uranium Recovery
      - Fuel Cycle Facilities
      - Materials Transportation
      - Materials Research
      - Advisory Comm (ACMUI)
      - Decommissioning of Nuclear Facilities
      - Materials Environmental Reviews
      -     
    - RadioactiveWaste           - Waste Quick Links
      - Low-Level Waste
      - Waste Incidental to Reprocessing
      - Incidental Waste Criteria
      - High-Level Waste
      - Uranium Mill Tailings
      - LLW Disposal
      - HLW Disposal
      - Spent Fuel Storage
      - Spent Fuel Transport
      - Waste Research
      -     
    - NuclearSecurity           - Security Spotlight
      - NRC Responsibilities
      - Domestic Safeguards
      - Radioactive Material Security
      - Facility Protection
      - Nuclear Material Control
      - International Safeguards
      - Information Security
      - Emergency Preparedness
      - &;   
    - Public Meetings& Involvement           - Public Meeting Schedule
      - Commission	    Schedule
      - Conferences & Symposia
      - Documents for Comment
      - Brochures & Fact Sheets
      - Involving Stakeholders
      - Info Quality Guidelines
      - Rulemaking Process
      - Licensing
      - Enforcement
      - Hearing Process
      - Hearing Applications
      -     

**UNITED STATESNUCLEAR REGULATORY COMMISSIONOFFICE OF NUCLEAR REACTOR REGULATIONWASHINGTON, D.C. 20555-0001**

June 3, 1998

**Addressees**

All holders of operating licenses for nuclear power reactors; non-power reactors; all fuel cycle and material licenseesrequired to have an NRC-approved emergency plan.

**Purpose**

The U.S. Nuclear Regulatory Commission (NRC) is issuing this information notice to alert addressees to multiple genericweaknesses in respiratory protection programs supporting emergency preparedness (EP). It is expected that recipients willreview the information for applicability to their facilities and consider actions, as appropriate, to avoid similar problems.However, suggestions contained in this information notice are not NRC requirements; therefore, no specific action orwritten response is required.

**Background**

NRC Information Notice (IN) 97-66, "Failure To Provide Special Lenses for Operators Using Respirator or Self-Contained Breathing Apparatus (SCBA) During Emergency Operations," was issued on August 20, 1997. That noticealerted licensees to a generic problem in which some licensed operators had not been provided required lenses for visioncorrection while wearing SCBA. A lack of required vision correction could hamper the control room operator'sperformance of licensed duties, including timely and effective response to emergencies. Subsequent to the issuance of IN97-66, follow up by licensees and NRC inspectors identified numerous problems and deficiencies in the respiratoryprotection programs supporting licensee emergency response programs.

**Description of Circumstances**

The 12 event summaries (Attachment 1) detail a broad spectrum of EP respirator program weaknesses. The discussionbelow focuses on these problems in generic functional areas.

During the NRC's review of emergency plan changes made by the licensees of the McGuire and Summer plants under 10CFR 50.54(q), the staff found that both plants had significantly reduced or eliminated the respiratory protection capabilityduring emergencies. The NRC informed licensees of both facilities that these changes had reduced the EP effectiveness.

In response to the NRC findings, the plants reinstated effective EP respirator programs. Given the potential radiologicalhazards and potentially more hazardous immediately dangerous to life or health (IDLH) nonradiological airborneenvironments (e.g., toxic gases, oxygen deficiency, smoke), the NRC staff found it unacceptable to weaken or remove avital protective function for emergency response workers (and the plant).

Another important area involved inadequate or incomplete evaluations of emergency situations and their impact on controlroom operators. The licensee for the Calvert Cliffs facility had not developed or implemented a procedure for handling anonsite spill of ammonia - no plans had been made that specified needed protective actions for workers on the scene or forthe control room operators. At the Enrico Fermi plant during a self-initiated engineering review follow up, the licenseeidentified the need to stage dedicated SCBA in the auxiliary building to ensure that operators could implement thededicated shutdown (remote) procedure. At San Onofre Nuclear Generating Station, in response to an NRC inspection, thelicensee initiated a self-assessment that identified the need to develop a plan to provide for refilling and transporting SCBAair bottles to and from the control room during emergency situations.

Several shortcomings in the training area were noted throughout the industry. Most significant was the failure to providecontrol room operators with periodic, hands-on training and practice with donning and wearing SCBA. Additionally,operators were not trained to change out bottles, nor, in some cases, did they know where the spare charged bottles werestored for their emergency use.

A number of facilities had allowed on-shift, operating personnel, who would be required to wear a SCBA during certainemergencies, to have beards. When the NRC inspector discussed the problems that a beard could cause to respiratorperformance (fit degradations, interference with proper operation of the SCBA, shortened period of air supply, degradedoperator emergency response), all licensees initiated timely action to meet the technical specification requirements inhaving sufficient number of clean-shaven operating crew.

Several licensees had no established effective oversight or controls for tracking and maintaining operators', and otherworkers' required periodic retraining and SCBA fit testing. This programmatic deficiency led to numerous failures tomaintain timely emergency worker qualification. At one facility, only 81 of the 235 members of the emergency responseorganization met the requirements of the station and 10 CFR Part 20 for worker training and fit testing at the time of theinspection.

**Discussion**

Since the major revision of 10 CFR Part 20, effective in 1993, licensees have significantly reduced the numbers ofrespirators used by orders of magnitude during normal plant operations and maintenance outages. This significant shiftaway from the use of respirators is a result of better job planning, more effective use of work area decontamination, andclose-capture containments. This shift resulted from the new Part 20 requirement to maintain the total effective doseequivalent as low as reasonably achievable.

Optimization of the internal and external doses often results in the determination that the use of respirators to avoid a smallintake can result in a larger external dose as a result of worker inefficiency.

However, it appears that this de-emphasis of respiratory protection for normal operations may have contributed to apotential decrease in the effectiveness of emergency response capabilities involving respiratory protection. Along with thisde-emphasis, the ongoing restructuring and downsizing of the electric utility industry places significant emphasis on costsavings efforts. While no area of nuclear plant operation is immune from this cost scrutiny, licensees need to ensure thatthe effectiveness of EP response capabilities are maintained. As previously discussed, plant operators and emergencyresponse workers can face not only radiological airborne hazards, but, in many cases, are challenged by unknown andpotentially IDLH conditions. Maintaining an adequate respiratory program is vital to their safety and, thus, to their abilityto respond in a timely fashion to emergencies.

This information notice requires no specific action or written response. If you have any questions about the information inthis notice, please contact the technical contacts listed below or the appropriate Office of Nuclear Reactor Regulation(NRR) project manager or appropriate Office of Nuclear Material Safety and Safeguards (NMSS) Project Manager.

Attachments:  1. Event Summaries

----

----

ATTACHMENT 1

EVENT SUMMARIES

The licensee made changes to its emergency plan under 10 CFR 50.54(q) and deleted the requirement for members of theemergency response organization (ERO) to be qualified to use respirators. The follow up NRC review found that thischange constituted a decrease in EP effectiveness, and the licensee reinstated the respiratory requirements. In its reviewand justification, the NRC cited 50.47(b)(8), which requires adequate emergency equipment to support EP response,including respirator protection equipment (NUREG-0654, Revision 1 Sections II.H.9 and J.6).

The NRC inspectors found numerous weaknesses in the control room operators capability to effectively use self-containedbreathing apparatus (SCBA). Following a postulated ammonia spill on site, no procedure had been formalized to directresponse activities, including control room ventilation alignment and the need to don SCBA. Some operators had facialhair and some did not know the location of SCBA designated for emergency use. Other than those designated as firebrigade members, operators had had no practical hands-on training with SCBA for 5 years. As a result, the licenseeestablished an improved, practical training plan on SCBA for the operators.

The NRC inspectors noted that some shift technical advisors had not kept their respirator qualifications current. Inresponse to Information Notice 97-66, the licensee determined that approximately 25 licensed operators who requiredcorrective lenses either did not have special frames or did not have current lens prescriptions. Some operators had beardsdespite the need to don and wear SCBA within 2 minutes after the initiation of an emergency. In response, the licenseeissued station-wide instructions that required personnel filling minimum staffing requirements to be clean shaven.

NRC inspectors noted that the air cylinder pressure for all SCBA was not in accordance with industry standards which wasa final safety analysis report commitment. The required pressure should be at least 90 percent of the rated cylinderpressure. Several air cylinders, staged for service, were found at pressures less than 4000 psig. Instead of the acceptable

minimum pressure of about 4000 psig, the licensee's minimum acceptable pressure was only 3500 psig. At this lowerpressure, the rated use-time is only about 23 minutes, instead of the rated normal 30-minute air supply. Appendix R of 10CFR Part 50, requires SCBA rated for at least 30 minutes of air supply. The licensee responded by changing procedures,retraining workers, and ensuring all in-service cylinders were charged to at least 4000 psig.

The licensee discovered during an engineering review that, assuming a design-basis fire and loss of offsite power, certainareas in the auxiliary building could become uninhabitable, immediately dangerous to life and health (IDLH) due to loss ofpower resulting in failed open smoke/CO2 dampers. Access to these affected areas may be necessary to complete theshutdown procedures during plant accidents. Plant procedures and SCBA are now in place to provide timely workerprotection and access and to implement necessary shutdown actions.

During the follow up in response to an industry generic communication, the licensee discovered that a number of operatorswere not provided corrective lens inserts for respirator use. The licensee broadened its investigation and found that therespirator program contained no provisions for tracking worker qualification. Of the 234 ERO, only 81 of the membershad maintained their qualifications (annual fit testing and medical evaluations). The licensee initiated proper short-termcorrective actions and the inspectors noted that no respirators had been issued to unqualified ERO members.

In response to an NRC inspection finding of failure to provide annual fit testing requalification (in two cases, no testinghad been performed since 1994), the licensee identified 21 plant staff and 24 security contractors had not received periodicfit testing. In these cases, all staff members had completed their training and medical evaluations. Other than some firebrigade members who wore respirators during required training exercises, no worker with out-of-date fit testing had beenrequired to wear a respirator. As part of the licensee corrective action follow up, the licensee determined that the primarycauses of the program weaknesses were (1) program responsibility was not assigned to a single person or group and (2) theplant lacked an administrative control procedure to track qualification.

The NRC identified that the licensee had not maintained an adequate supply of properly sized SCBA face pieces for theoperating staffs for the control room and the technical support center. Aside from being uncomfortable to the user, wearinga grossly mis-sized face piece could reduce the duration of the rated air supply. The licensee promptly corrected thisdeficiency.

NRC inspectors noted that annual retraining for operators in the donning and use of SCBA did not require each operator toexperience hands-on training. As a result, except for fire brigade members, few operators had donned SCBA for severalyears.

During an NRC inspection, the inspectors noted that the licensee had failed to develop a formal issue and tracking processto ensure that corrective lenses (of the appropriate type) for SCBA use were provided to licensed operators. Although aprocedure had been in place to require either contact lenses or prescription spectacle kits (specific to the SCBA type), thisprocedure was revised to ensure that personnel will be issued corrective lenses.

The NRC inspector discovered that control room operators had not been trained to change out SCBA air cylinders whilewearing a SCBA in a hostile environment. The inability to effectively change out an air bottle during a toxic gas accidentcould hamper operator response to the emergency. Although members of the fire brigade were trained on change-outprocedures, the licensee initiated an evaluation to identify needed improvements in the respiratory training program.

While observing a full-scale, biennial EP exercise, the NRC inspectors identified a weakness in the plant's ability tomonitor and maintain adequate supplies of SCBA (air bottles and face pieces) for the operations support center over thelong term. This weakness could jeopardize the licensee's ability to provide continued respiratory protection for theresponse teams dispatched into the plant. Critical remediation actions related to worker and plant safety could be seriouslyhampered unless air bottles are recharged on a timely basis.