ML18093B192

Forwards Addl Info Re 10CFR20 Exemption for Use of MSA-GMR-I Canisters,Per 880825 request.One-wk Extension Provided

ML18093B192
Person / Time
Site:	Salem, Hope Creek, 05000000
Issue date:	10/03/1988
From:	Miltenberger S Public Service Enterprise Group
To:	NRC OFFICE OF ADMINISTRATION & RESOURCES MANAGEMENT (ARM)
References
NLR-N88159, NUDOCS 8810100072
Download: ML18093B192 (5)

Text

• Public Service Electric and Gas Company Steven E. Miltenberger Public Service Electric and Gas Company P.O. Box 236, Hancocks Bridge, NJ 08038 609-339-4199 Vice President and Chief Nuclear Officer October 3, 1988 NLR-N88159 United States Nuclear Regulatory Commission Document Control Desk Washington, DC 20555 Gentlemen:

10CFR20 EXEMPTION REQUEST - ADDITIONAL INFORMATION SALEM GENERATING ST~TION UNIT NOS. 1 & 2 AND HOPE'CREEK GENERATING STATION DOCKET NOS. 50-272, 50-311 AND 50-354 Public Service Electric and Gas Company {PSE&G) has received your letter dated August 25, 1988 concerning the use of MSA-GMR-I canisters. The additional information requested is provided in the attachment. Your prompt review of this request is appreciated.

Per a phone conversation on September 26, 1988 with Mr. G. Rivenbark, NRC Project Manager, a one week extension was granted to provide this information. Please contact us if you have any questions.

Sincerely, Attachment 0010100072*

PDR ADOCK -05000272 asooat;-- ----~,

p PNU

• 10-03-88 Document Control Desk 2 C Mr. J. C. Stone Licensing Project Manager - Salem Mr. R. w. Borchardt Senior Resident Inspector - Salem Mr. G. w. Rivenbark Licensing Project Manager - Hope Creek Mr. G. w. Meyer Senior Resident Inspector - Hope Creek Mr. w. T. Russell, Administrator Region I Mr. D. M. Scott, Chief Bureau of Nuclear Engineering Department of Environmental Protection 380 Scotch Road Trenton, NJ 08628

• 10-03-88 Document Control Desk 3 BC Vice President - Nuclear Operations General Manager - Salem Operations General Manager - Hope Creek Operations General Manager - Engineering and Plant Betterment General Manager - Nuclear Services General Manager - Quality Assurance/Safety Review Manager - Licensing and Regulation (cover letter only)

Manager - Offsite Safety Review Manager - Radiation Protection Services Radiation Protection/Chemistry Manager - Salem Radiation Protection/Chemistry Manager - Hope Creek Onsite Safety Review Engineer - Salem Onsite Safety Review Engineer - Hope Creek Associate General Solicitor Conner & Wetterhahn J. B. Caldwell (Action Tracking)

P. Glennon F. X. Thomson Microfilm Copy File No. 1. 2. 1 Concurrences: (For accuracy of information only)

General Manager - Salem Operations General Manager - Hope Creek Operations

ATTACHMENT Your letter dated August 25, 1988 requested additional information concerning PSE&G's submittal for an exemption to 10CFR20, Appendix A, footnote d-2 (c). This exemption would allow the use of MSA 466220 GMR-I canisters for respiratory protection. PSE&G's response to each of your concerns is addressed below.

1. Item #4 of the February 27,1988 exemption request indicates that the GMR-I canisters would only be used with a full face piece respirator proven to provide a protection factor of greater than 100. What fit factor will be used as the acceptance criterion for the quantitative fit test to ensure that the stated level of protection will be provided?

RESPONSE

A fit factor of 100 will be used. This is the current factor for full face respirators in our M12-ROP-Ol Procedure.

2. Item #5 of the request states that bioassay will be performed on users who "exceed the level specified by procedures." At what level and at what frequency will bioassay be performed?

How does PSE&G intend to check the effectiveness of its use of GMR-I canisters?

RESPONSE

Procedural guidelines for initiation of a bioassay include a suspected uptake of greater than 20 MPC-hrs in a week, 100 MPC-hrs in a quarter, or any other indication that, in the judgement of a Radiation Protection Supervisor, may indicate a possible uptake.

We intend to perform bioassays (whole body counts) on an initial statistically valid group of GMR-I canister users.

We will compare the results of these bioassays to the air sample data to verify that the GMR-I canisters perform as expected. The ongoing effectiveness of the protection provided by the GMR-I canisters will be performed through our routine annual bioassay program as well as through the special bioassays performed as stated in the previous paragraph.

3. Item #7 states that "each canister will be inspected in accordance with the appropriate procedure" prior to issue.

What is the purpose of this inspection?

RESPONSE

The purpose of the inspection is to ensure that the canisters have not exceeded the their expiration date, have not been physically damaged during shipment and that the plastic bag containing the canister is intact.

4. How does PSE&G intend to ensure the quality of the canisters?

Absent a NIOSH certification, a quality assurance program comparable to mil. Standard 444 (with an acceptable quality limit equal to 1) should be provided.

RESPONSE

Quality Assurance will review the Vendors manufacturing process (including sight inspection of the vendors process control) and ensure that the program meets acceptable standards.

5. What precautions on the storage of canisters prior to use will PSE&G implement to ensure that the sorbent is not degraded?

RESPONSE

The canisters will be stored in plastic bags. The Vendor has performed storage tests that show that no further storage precautions are needed other than the normal storage and handling procedures for respirator type equipment. The bags will be verified intact prior to issuance.

6. What temperature and/or humidity limitations will PSE&G propose for the use of sorbent canisters?

RESPONSE

We propose to limit the use of sorbent canisters to locations with an ambient temperature below 110 degrees F.

We do not propose any limitations on humidity, as the Vendor does not recommend any humidity limitations.

7. PSE&G states that this exemption request is justified due to ALARA considerations. Data presented, concerning the Hope Creek vessel head lift operation (Table 1 of Attachment 1),

indicate that the use of GMR-I equipped respirators would have a net savings of 998 person-mrem over the use of SCBA or air line respirators for this task. How does PSE&G justify that using GMR-I equipped respirators is ALARA when wearing no respirator at all will save an additional 335 person-mrem?

RESPONSE

The example provided in the exemption request was intended only to demonstrate the dose savings between the GMR-I canister and the air line or SCBA respirators. In this specific instance the decision to not use a respirator may be appropriate; however, each case must be evaluated individually for the specific hazards and conditions as specified in the ALARA program.