ML18043A324

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Informs NRC of Filter Testing Condition in Respiratory Protec Equip Which Is Different from Regulaion in Reg Guide 8.15, But Which Meets the Regulatory Requirements
ML18043A324
Person / Time
Site: Palisades, Big Rock Point  File:Consumers Energy icon.png
Issue date: 12/08/1978
From: Bixel D
CONSUMERS ENERGY CO. (FORMERLY CONSUMERS POWER CO.)
To: Ziemann D
Office of Nuclear Reactor Regulation
References
TASK-08-04, TASK-8-4, TASK-RR NUDOCS 7812120182
Download: ML18043A324 (1)


Text

e consumers REGULATORY DOCKET FILE COPY Power company General Offices: 212 West Michigan Avenue, .Jackson, Michigan 49201

  • Area Code 517 788-0550 December 8, 1978 Director of Nuclear Reactor Regulation Att: Mr D L Ziemann, Chief Operating Reactor Branch No 2 US Nuclear Regulatory Commission Washington, DC 20555 DOC:IG;TS 50-155 & 50-255 - LICENSES DPR-6 & DPR BIG ROCK POINT &

PALISADES PLPJ~TS - RESPIRATORY PROTECTIVE EQUIPMENT TESTING Consumers Power Company uses respiratory protective equipment in accordance with the requirements of 10 CFR 20.103(c). This regulation stipulates the use of Regulatory Guide (RG) 8.15, 11 Acceptable Programs for Respiratory Protection. 11 In reviewing our program, we have identified a filter testing condition which is different from that giYen in reference mate:!'ial associated with RG 8.15. While we have concluded that our testing condition meets the regulatory requirements, we believe the difference should be brought to your attention.

The "advice 11 given in NUREG-0041, 11Manual of Respiratory Protection Against Air-bor:::ie Radioactive Materials, 11 suggests that filter canisters should be tested to the same efficiency requirements as specified for unused filters (99.97% effi-ciency ¥ith 0.3 µm DOP). Prior to the issuance of RG 8.15 and NUREG-0041, Consumers Power Company purchased equipment for retesting filters which utilize a particulate size slightly different from that specified for new filters. Our equipment uses a Frontier Enterprise Model FE-259 DOP Aerosol test system. This system produces a mean diameter particle in the 0.5 to 0.6 µm range. In re-viewing this difference, we note that HEPA filter efficiencies exhibit little efficiency variations over the range of 0.1 to 3.0 µm and have concluded that our equipment will assure that canister and cartridges are not used beyond service life limitation as stipulated in RG 8.15, Section C.8.h.

David A Bixel (Signed)

David A Bixel

Nuclear Licensing Administrator CC: JGKeppler, USNRC 781212 a~ o2-