ML19345E411

Forwards Request for Authorization to Make Allowance for Use of Protective Equipment Per 10CFR20.103(G).Request Previously Made 621005

ML19345E411
Person / Time
Site:	Big Rock Point File:Consumers Energy icon.png
Issue date:	04/01/1966
From:	Wall H CONSUMERS ENERGY CO. (FORMERLY CONSUMERS POWER CO.)
To:	Doan R US ATOMIC ENERGY COMMISSION (AEC)
References
NUDOCS 8101160380
Download: ML19345E411 (18)

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1 BIG ROCK POTNT NUCLEAR PLAI;T 2

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Application for Authorization To Make Allowance for Use jh*

of Protective Equipnent Pursuant to 10 CFR 8 20.lO3(c) siy;[$e $5 -

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Dr. R. L. Doan, Director 2

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Dear Dr. Doan:

By letter of October 53 962 "mm Mr. H. P. Graves _to Mr. Robert Lovenstein, Consumers Power Compau,, applied under 10 CFR. 9 20.lO3(c) for authorization to expose individuals in restricted areas at the Big Rock Point Nuclear Plant to airborne concentrrtions of radioactive material in excess of the limits specified in 10 CFR, Part 20, Appendix B, Table I.

An attachment to that letter described equipment and procedures proposed to be used for respiratory protection

-in restricted areas. Aside from ackncvledgement of receipt of the request on October lo, 1962, we have received no further communication from the AEC concerning it.

We presently have leaking fuel it the reactor and an-ticipate a need to take credit for the use of respiratory protective equipment in order to perform maintenance work in an orderly and ex-peditious manner.

Since our next refueling is scheduled to begin on April 11, i k 5, we are renewing our request of October 5, 1962 with thd hope that it will receive your prompt attention. The attached Amendment No. 1 to Attachment A revises certain portions of Attach-ment A appended to the October 5, 1962 letter application.

Yours very truly, G.W/dmb H. R. Wall Attach.

Vice President

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AMENDMELT NO.1 TO ATTACHMELT A 1.

Change "C.

Compressed Air Mask" on Page 2 to read as follows:

"C.

Supplied Air Mask 1.

Acme Fu11 face Mask This supplied air mask utilizes the same basic facepiece, Acme CM-602S, as does the fullface canister mask, except that a flow control valve is added. The compressed air is supplied from either bottled air or plant compressed fresh air supply lines. In either case, the air travels through a pressure regulator, with safety pop-off and oil filter, into about 50 feet of hose, through the flow control valve, and into the mask. A compressed air unit is utilized in the same manner for work in areas of gross wet contamination.

These units are considered to be 100 percent efficient for

<reventing inhalation of radioactive material.

2.

Scott Air-Pak Compressed air cylinder, pressure-demand, and demand type, Scott Air-Pak Model 6000A 2MS, is manufactured by the Scott Aviation Corporation, Lancaster, New York. This equipment consists of a fullface respirator (known as the Scottoramic Fullvue-Face Piece) with corrugated rubber breathing tube, demand and pressure-demand regulator, air supply and suitable harness. Air supply tanks contain 38 ft3 (free air) at 1980 psi with a 30-minute average and 45-minute maximum supply.

A regulator bypass valve is provided to permit continuous supply in event of regulator failure. Efficiency of this

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2 respiratr* '- 100 percent when operated in the pressure-demar; mode as the air is supplied from an 'ir cylinder a

under pressure and independent of the work area environte.t.

The pressure regulator for this equipment has been modified such that it can be operated in the pressure demand mode only.

3 Polyethylene Hood Continuous flow-positive pressure type respirator, polycthylene hood,Model 6P, is manufactured by the Snyder Protective Apparel Ccapany, New Philadelphia, Ohio. This unit is an air-supplied hood (respirator) which functions :n the continuous supply principle to differentiate it from the demand supply principle.

Tests of this hood have demonstrated that it is safe, convenient, exceptionally comfortable by comparison to other types of res-pirators and permits use of eyeglasses without compromising sealing ability.

The hood is fitted with a dravstring at the neck which is tightened to the limit of comfort. Air is sup-plied to the hood from either compressed air cylinders through a pressure-reducing regulator or from the plant service air system in which case the air is passed through a manifold filter where cartridges are pre,ent for the removal of partic-ulate material, organic vapors, and moisture, and then a pres-sure-reducing regulutor. The air supply is maintained at or above a minimum of h cfm. The efficiency for this respirator is 100 percent."

2.

Insert the following new paragraph at the beginning of "Ill.

Procedures, Goveening Use" on Page 6:

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?Wheneve._ possible, close-capture and controlled-flow ventilatir,n, containment, isolation and dilution shall be ussd-to minimize the

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need for respiratory protection.1' Personnel' entries into' areas re-quiring respiratory protection shall.be minimized as to frequency,-

duration and' level of airborne concentrations by every reasonable-s

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means."

3.. Add Tables I.and II and change "IV.

Average Concentrations" to read-aas follows:

"IV.

Average Concentrations

~ The average. concentrations of a% rtcrne radioactivity in areas

'normally occupied by employees have-been consistently less_than any applicable MFC as listed in Appendix B, Table I, of 10 CFF, j :.

~ Part 20.

Recent experiences at Big Rock Point have shown that p

in contined areas of the containment sphere, the presence of primary system steam-leaks under leaking fuel conditions can j

raise the airborne radioactivity level to about 1000 MFC. A j

gamma spectrum analysis of the airborne radioactivity-under these conditions has been made and the nuclides detected are listed on Table I.

In addition to the nuclides actually-detected, reactorf

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vater sample analyses indicate that other nuclides surely must also be present in very small quantities wherever there is a primary system steam leak. These nuclides are listed on Tatle r

II. - It will be noted that there are no nuclides either actually detected or suspected which are generally' considered to have high toxicity."

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TABLE I Radionuclides Detected in Air San.ples a' M !"

Isotope

• 5 Solubility Half-Life

+MPBB, pc N 13 10m 1 x 10 Irrmersion Cr $1 I

2Td 2 x 10 60

-8 Co 58 I

Tid 5 x 10 h.2

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-Co M I

5 3y 9 x 10 2.2

-6 Cu 64 I

12.8h I x 10 g,g

-5 Rb 88 17m 1 x 10 Immercion

-7 Mo 99 I

2.8d 2 x 10 2.7

-5 Tc 99n I

6h 1 x 10 2h

-9 1 131 S

8d 9 x 10 0.7

-I I 132 S

2 3h 2 x lo 03 I 133 S

21h 3 x 10~

03

-5 Cs 138 32m 1 x 10 I=ersion

-7 Up 239 I

2 3d 8 x 10 4

+MPBB = Maximum Permissible Body Burden. For insoluble a:aterials it is the lun2 burden.

W *I = Insoluble, S = Soluble TAKE II Additional Radionuclides Detected in Reactor Water a' E !*

Isotope

• "Salubility Half-Life

• MI M. pc

-6 F 18 S

1 9h 5 x 10 gg Na 2h S

15 6h 1 x 10 7

~7 Mn 56 I

2.6h 5 x 10 0.65 Fe 59 I

45d 5 x lo-2

~7 Sb 122 I

2.8d 1 x 10 1,2

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Sb 12h I

60d 2 x 10 09 W 181 1

140d 1 x 10 to

-I W 185 I

79d 1 x lo 6

~I W 187 I

24h h x 10 1.0

• MPb3 = Maximum I'ermiscible Body burden. For insoluble m'aterials it la the lung burden.

• *I = Incoluble, S = Soluble 4.

Eeplace " Table I, Limitations," with " Table III, Conditions and Limitations for Use of Recpiratory Protective Equipment," as follows :

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TABLE III-Conditions and Limitations for Use of_ Respiratory Protective Equipment j

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• Frotection Factors

. Maximum.

-Maximum, 4

Type 1 Vapors and Cases Time for Exposure Time

-Maximum-Levels-Tritium.

Maximum Continuous During i.ny LFor. Welding or-Particulates Oxide Other Concentration Exposure Workweek

- Flame Cutting-No contamination / 7 Cone x Time or activation 4-I No Bespirator - Reference 2 x MPC

. MPC x 40 Hr (1 measured or suspected-7 Mouthpiece Respirator:

American Optical Co.

Model R-9925,With R-925 Cartridge and'Mine Safety 100 2

100 20 x MPC 30 Minutes 30 Hours Not Used Appliances Co., Nose Clip, Model CR 16860 c.

4 Equivalent Fullface Canister Mask:

100 x MPC Acme Protection' Equipment Fitting test

<!4000c/m O

l Co., Model CM-602S, With 1000 2

1000 required for 3 Hours 30 Hours loose or fixed Chin Style Canister Model concentrations contamination or 4

282-OAP-R or Equivalent

> 20 x MPC, activation Compres,w. Air Mask:

'i Same Acme Facepiece as Above Limited.by Required for With Flow Control Valve, 1000 2

1000 whole-body 3 Hours 30 Hours contaminatien er-Scott Air Pack, Polyethylene dose rate activation Hood or Equivalent

> h000 c/m.

• The protection T-tor is the reciproca1'of the assumed penetration of the complete respirator, t

Assured concentration inhaled = ^ Protection Factor

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Protection factors apply for fitted' respirators wor n by trained personnel

They do not apply to airborne contaminants that preserit an absorption or submersion hazard.

- Consumers Pcwer 'Compu;y April 1, 19C6

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CONSUM ERS POWER COM PANY GENERAL OFFICES e JACKSON, MICifIGAN October 5, 1962 g

g (EMER AL cot'N9EL DIG ROCK POIIE UUCLEAR PLANT -- Dkt. No. 50-155 Request for Authorization To Make Allowance for Use of Protective Equipment Pursuant to 10 CFR 8 20.103(c)

Mr. Robert Lowenstein Director, Division of Licensing and Regulation U. S. Atomic Energy Commission Washington 25, D. C.

Dear Mr. Lowenstein:

Appended hereto, as " Attachment A", is infe. ation describing equipment and procedures proposed to be utilized for respiratory protection in restricted areas at the Big Rock Point Nuclear Plant.

Pursuant to 10 CFR li 20.103(c)(3), Consumers Power Company hereby applies for authorization to expose individuals in restricted areas to airborne concentrations in excess of the limits specified in 10 CFR, Part 20, Appendix B, Table I.

Yours very truly,

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ATTACic/2!!T A I.

Dcocription Three types of reopiratory protection are available and intended for use at the Big Rock Point Nuclear Plant:

A.

Mouthpiece Respirator The mouthpiece respirator, American Optical Company, Model R-9925, with R-925 cartridge, is a compact, lightweight, low breathing resistance unit, which can be readily fit to provide a perfect scal for nearly any individual. The R-925 cartridge contains both particulate and iodine filters. The particulate filter removen virtually all particles down to one-micron size.

The iodine filter conoints of one-half inch thickness of 400-mech charcoal.

The none clip normally suptdied with the R-9925 reopirator has been replaced with the Mine Safety Appliances Company, Model CR-46860, none clip. The latter provides more effective scaling of the nostrils and 10 less likely to slip off the noac than the clip normally provided.

The mouthpiece respirator, properly fitted, is considered to be 100% efficient for removal of' particleo down to one-micrun size.

Iodine absorption tests have demonstrated the ability of the cartridge for removal of iodine from large quantities of iodine-vapor naturated air.

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Fullface Canister Mack The fullface canister mack intended for use ioI the Acmc.

Protection Equipment Company, Model CM-6323, with Model 282-0AP-R chin-style canioter. This unit is belic red to provide the greatest undiotorted peripheral vision, lowest breathing resis-tance, least distorted cpeech trancmissicn, and greatest assurance for fitting all individuals, of all fullface macks precently availabic. The 282-GAP-R canister provides both par-ticulate and iodine filters. Dioctyl Phthalate tests show that thecanistertoatleast9995%efficientforremovingparticles down to 0 3 micron cite. The iodine filter contains 300 CC of 814 mesh charcoal for removal of radiciodine.

C.

Comprecccd Air Mack The compressed air mask utilizca the came basic facepiece, Acme CM-6023, as does the fullface canister mask, except that a flow control valve in added. The compressed air is supplied from bottled air, through a pressure regulator, with cafety popoff and oil filter, into 50 ft. hose, through the flow control valve, and into the mask. Thio unit is considered to be 100% efficient for preventing inhalation of radioactive material.

II.

Fitting, Maintenance, Cleaning A.

Mouthpiece Resnirator Each individual, permanently assigned to the Plant, whose work might require the use of respiratory equipment, vill be 9

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each individual vill have been thoroughly trained in its proper use. The training procedure includes demonstration and partici-

. pation in fitting the respirator to obtain a perfect ceal. The mouthpiece of the reapirator is placed in the mouth and occured by the teeth. The seal is obtained with the lips around the mouthpiece. The extent to which the lips can be moved and re-laxed without interrupting the seal is studied by each individual.

After each use the mouthpiece respirator vill be cleaned.

The minimum cleaning procedure vill include immercing the res-pirator, minuo the cartridge, into a mild detergent solution and then into a sanitir.ing solution. Each individual vill be responsible for corducting this minimum cleaning procedure on his own mout.hpiece respirator after each use. After the res-pirator has been allowed to dry, Radiation Protection personnel vill ourvey it for contamination, put a plastic cap over the mouthpiece, and place the respirator on the individual's hanger.

In the event the contamination survey revealo contamination in exccooof400c/m,strongerdecontaminatingagentsandcerubbing vill be employed.

(NOTE: The surveys will be conducted with a THYAC II GM survey meter. Acountrateof400c/monthisinstru-O mentcorrespondsto0.1mr/hrascalibratedwithaCo gamma ray 1

source.)

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The exhaust valves will be checked by visual inspection i

as the respirators are surveyed, and replaced as necessary.

Cartridges vill be removed from service when the v' carer notices significantly increased breathing resistance or when the cartridge producco a radiation reading in excess of 4000 c/m.

B.

Fall-Face Canister Mask Each individual whose work might require the use of a full-face canister mask will have been trained in the proper method of fitting the mask. The fitting procedure, as outlined below, will have been repeated at least three tines for each individual concerned:

The mask is placed on the face, and the straps tightened in the proper sequence, until the individual believen he has a good fit. A cotton suab moistened with cmyl acetate is then passed around the edges of the mask to detemine the effectiveness of the seal. The individual is instructed to adjust the utraps until the' odor no longer persists.

(HCffE: Approximately one person in one hundred may not be able to obtain a perfect seal.

Any such person would be restricted from using the full-face canistermask.)

The full-face canister masks vibl. be routinely surveyed for contamination by Radiation Protection personnel. Surveys will be conducted at least daily on <>ach mask which has been used in an airborne radioactivity arcs within the preceding em* w ee T r".._*** % 2

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5 24-hour period. Maximum ellowabic radiation readings will be:

400c/mincidethefacepiece 2000 c/m outside the face piece (except canister) 4000c/mfromcanister The nonnal decontaminating procedure will utilize light ocrubbing in a mild detergent. Strong decontaminating agento and vigorous cerubbing will be utilized with discretion to prevent damage to the surfaces which provide scaling against the face.

Routine maintenance on the masks will be conducted by Radiation Protection personnel no the need becomeo apparent, resulting from visual inspection during contamination surveys and decontamination.

Each mask will periodically be tected by Radiation Pro-t e tion personnel for the ability to obtain a perfect scal with the mask. The fitting procedure deocribed above will be utilized for this purpose.

The canictor will be removed from service when the wearer notices oignificantly increaced breathing resistance or when thecanisterproducesaradiationreadingof4000c/m.

C.

Compresced Air Mack The fitting of the compressed air mask to the face in done in the came manner as for the full-face canister maok. Thus, no additional training in required for thoce individualo who have undergone the fitting procedure outlined in II.B above.

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'Each individual whose work might require the use of the compressed air maak will, however, be instructed in the. proper method [of connecting the mask' to the comprecoed air supply.

The emyl acetate procedure vill be conducted at this time for the purpose of demonstrating the.cffectivences of positive preocure for climinating the possibility of in-leakage.

The allowable contamination limito and cleaning procedure for the compressed air mask vill be the same ao described for the full-face canister mack. In addition, the hose connection and the hooc within 5 feet of the connection to the mask will be kept free of contamination in exccas of W c/m.

Ucccoonry routine maintenance vill be conducted by Radia-tion Protection peroonnel no the need is detemined throu6h visual inspection during curveys and cleaning.

Ihe compresoed air maako vill periodically be Ibnctionally teoted by Radiation Protection personnel.

III. procedurco Governing Une Supervisory procedurco chall require that a continuous air monitor be in operation in areno of potential airborne radioactivity og that an air comple be taken with a portable cumpler and analy cd prior to allowing individuals to work in auch areau of potential airborne radio-activity. Continuous air monitors shall be cet to cound an " alert" when the airborme radioactivity reachen approximately one-half the applicable MPC, established in Appendix B, Table I, of 10 CFR, Part 20, and to cound an "alam" when the activity reaches approximately twice MPC. While the p. _ -,.....

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" alert" is on and the " alarm" han not counded, the working time for

-individualc in the area chall'bc co controlled that the airbome con-centration, averaged over 140 hours0.00162 days <br />0.0389 hours <br />2.314815e-4 weeks <br />5.327e-5 months <br />, does not exceed MPC. In areas where continuous air monitors are not provided, comples taken with portable air camplers will provide the basis for detemining concen-trations; and the working time chall be co' controlled that the con-centration times the time, divided by the applicable MPC times 140 hours0.00162 days <br />0.0389 hours <br />2.314815e-4 weeks <br />5.327e-5 months <br />, doco not exceed ur.ity. Thus, respiratory protection will not be required for airborne-concentrations which are leco than twice the applicable MPC.

.The crecifications for uoe and limitations, as tabulated I

in Table I, attached hereto, for concentrations in exccoc of twice MPC, are ao follows:

A.

Mouthpiece liccpirator The mouthpiece respirator may be used, by individuals who have been trained in its proper use, for reapiratory protection in airborne ~ concentrations of radioactivity up to 20 times the applicable MPC.

e The mouthpiece respirator shall not be worn by any one individual for a continuous period greater than 2 hours2.314815e-5 days <br />5.555556e-4 hours <br />3.306878e-6 weeks <br />7.61e-7 months <br />, nor shall it be worn by any individual for more than 30 hours3.472222e-4 days <br />0.00833 hours <br />4.960317e-5 weeks <br />1.1415e-5 months <br /> dur-i in6 any_vork week.

The mouthpiece respirator chall not be worn for welding or flame-cutting of _ contaminated or activated surfaces.

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Full-Face Cuninter 14ack The full-face canister mask may be used, by individualo who have been trained in its proper use, for recpiratory pro-tection in airborne concentrations of radioactivity up to 100 timeo the applicable 14PC. For concentrationo in exceso of 20 x 14PC, however, the vcarer muot undergo the amyl acetate fitting procedure after donning the mask and prior to enter-ing the area.

The full-face canister maok chall not be vorn by any one individual for a continuoua period greater than 3 houra, nor chall it be worn by any individual for more than 30 houra during any work veck.

The full-face canister maak, with velding lensco attached, may be used for velding or flame-cutting on contaminated or activated curfacco, provided t!.at sucli contamination or activa-tiondoesnotproducearadiationreadinginexcecoof4000c/m.

The ourvey vill utilize a THYAC II G4 counter which has been O

calibratedsuchthat4000c/mcorrespondoto1mr/hr.ofCo gamma rayo. The readings vill be taken at approximately two inchen from the surface intended for velding or cutting.

C.

Compreoned Air Mack The compreoced air maok may be used, by individuals who have been trained in ito proper uce, for reapiratory protection -

in airborne concentrations of radioactivity which are known or suspected to be in exccan of 100 times the applicable MPC.

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Uhen the wearer and his supervisor or Radiation Protection personnel have been accured that the fitting of the mask-is proper and that the inside of the mask is under positive pressure, the wearer may enter an area in which the concen-tration exceeda -100 x 14PC.

The compressed air mask chall not be worn by any one individual for a continuous period greater than 3 hours3.472222e-5 days <br />8.333333e-4 hours <br />4.960317e-6 weeks <br />1.1415e-6 months <br />, nor chall it be vorn by any individual for more than 30 houro during any work veck. The actual time allowed for exposure to concentrations greater than 100 x 14PC will be reduced from the above-stated maximuma in accordance with supervicory procedures ccntrolling whole body radiation exposure, as the whole body doco rate accociated with very high airborne con-centrationo 10 likely to restrict exposure time to a greater extent than will mask limitations.

The compressed air mask must be worn for velding or flame--

cutting on surfaces where contcmination or activation produces radiation readingo in exccas of 4000 c/m. The readingo shall be detemined as deceribed under III.B above.

IV. Average Concentrations The average concentrations of airborne radioactivity of plant origin, in arcan nomally occupied by employeco, is expected to be considerably icos than the applicable !!PC, established in Appendix B, Table I, of 10 CFR, Part 20. Some areas within the plant, not nonna11v y..

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3n occupied, could be expected to have airborne concentrations in execca of the applicable limit. These arcan.might periodically require entry by plant personnel to insure cafe operation of the plant. Persons.

-entering such' areas, or othervice becoming exposed to airborne radio-activity in exceso of twice the applicable MPC, will be required to

'vear appropriate respiratory protective equipnent.

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n TABLP,I LIMITATI0lls Maximum Maximum liaximum Leveln Type llaximum Time for Exposure Time For ifelding or Concentration Continuous During Any Flame Cutting Exposure Work Week No contamination r a tivation No Conc x Time Eerpirator 2 x MPC MFC x 40 hrs. f measwed or suspected Mouthpiece 20 x MPC 2 hours2.314815e-5 days <br />5.555556e-4 hours <br />3.306878e-6 weeks <br />7.61e-7 months <br /> 30 hours Not used Respirator 100 x IIPC Full-Face Fitting teot

<l+000 c/m Canist2r required for 3 hours3.472222e-5 days <br />8.333333e-4 hours <br />4.960317e-6 weeks <br />1.1415e-6 months <br /> 30 hours loose or fixed Mask concentrations contamination or

> 20 x MPC activation Required for Compressed Limited by contamination or Air Ma k whole-body 3 hours3.472222e-5 days <br />8.333333e-4 hours <br />4.960317e-6 weeks <br />1.1415e-6 months <br /> 30 hours activation

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U REG NO ole DESC9i9fiON. (Mwe B. Uaciosodi.tj REFERRED 10 DATE aECElvED Sy DATE l

Ltr./spn1. for authorization to maae allowance for use of pmtective 3973:

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equipNnt, pursucnt to 10CFR s w/7 F t 20.103(c) ava trt.nt t y)h ra cysur E,2 J]

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