ML20037B262
| ML20037B262 | |
| Person / Time | |
|---|---|
| Site: | Dresden  |
| Issue date: | 03/13/1964 |
| From: | Lowenstein R US ATOMIC ENERGY COMMISSION (AEC) |
| To: | Bower D COMMONWEALTH EDISON CO. |
| References | |
| NUDOCS 8009100800 | |
| Download: ML20037B262 (14) | |
Text
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J MAR 131964 Docket Fo. 50-10 I
Commonwealth Edison Company 72 West Adams Street Chicago 90 Illinois j
Attentionr Mr. D. Robert Bowee Treasurer I
Gentlemen:
his letter la in reply to your application, dated July 30,1%3, for authorization to make allowance for the use of respiratory protective equipment in determining whether an individual is exposed to concentrations of airborne radioactive smeterial in excess of the y
limits specified in Appendix B. Table I of 10 CFR 20.
his request, l
which was made pursuant to the provisions of Section 20.103(c)(3) of 10 CFR 20, is based on representations in Exhibits C, D, E and F l
attached to your application.
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. We have reviewed the information submitted concerning the equipment
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and procedures to be used and have concluded that, subject to the additional requirements itemized in Annex "N' to this letter, credit may be allowed for the use of protective equipment during the forth-l coming Dresden refueling operation. Accordingly, you are hereby authorised, pursuant to Section 20.103(c)(1) and (3),10 CFR 20, to make allowance for the use of respiratory protective equipment in determining whether individuals in restrictd areas are exposed to i
concentrations of airborne radioactive material in excess of the limits specified in Appendix L, Table I of 10 CFE 20 his cuthor-tration is conditioned upon observance of the provicions of Exhibits C, D, E and F of your Ictter of July 30, 1963, as amended by /.nncx " A" attached hereto. No change in these requirements may bc :-:dc without prior AEC approval.
his authorization applies only to the forthco=ing Dresden refueling.
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4 cameonwealth Edison company MAR 13 E$i We appreciata receiving the report of Dresden experience during the past refueling period. A report of your further experience under the authorisation contained.in this letter would be helpful g
to us in establishing general criteria and requirecaents.
-l Eincersly yours.
- %gnd} R. Lowenstela R. Imwenstein Director Division of Licensin; and Eegulation Attachments Annem "A" i
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Mr. A. G. Thomas j
President - Local Union #1460 j
15 O'Neill Street i
Joliet, Illinois I
Distribution:
R. J. Catlin E. G. Case R. Bryan j
Division of Compliance Office of the General Counsel Formal Suppl.
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b Corenonwealth Edison Company.
A more general authorization, as requested, to take credit for the use of protective equipment has not been granted at this t16e. We i
are evaluating the requirements fer issuance of such en euthorization; and we appreciate the report of Dresden experience during Khe past refueling period. A report of your further experience under the authorisation contained in this letter would be helpful tp us in establishing the over-all requirements for a more general authorization,
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4 A copy of this letter and attachesnt is being sent to Mrs A. C. Thomas, President of Local Union (1460. \\
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Sincerel yours,
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i Robert Lowenstein j
j Director i
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Mr. A. G. Thomas l
President 14 cal Union #1460 l
15 O'Neill Street Joliet, Illinois
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Docket No. 50-10 Cocronwealth Edison Company 72 West Adams Street Chicago 90, Illinois
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i Attenticn:
Mr. D. Qbert Ewer Treasurerg Genticeen:
This letter is in reply to\\your application, dated July 30, 1963, for authorization to make a(louance for the use of respiratory protective equipment in detsmining diether an individual is exposed to concentrations of airbornekedioactive 1ert.erial in excess of the which was inade pursuant to the p\\ Table I of 10 CFR 20.
limits specified in Appendix B, This request, rovisions of Section 20.103(c)(3) of 10 CFR 20, is based on represchtstions in Exhibits C, D, E and T sttached to your present request, %ich arc censideral to supersede your previous application of Novecibeg 2,1962 as modified by the Commission's letter of Detsaber 11, 1 2 We have reviewed the information submithed concerning the equipment and procedures to be used and have conc 10ded that, subject to the additional requirementa iteutzed in Acnem Ma to this letter, credit may be allowed for the une of protective eqdipment during the forth-coming Dresden refueling operation. Accordingly, you arc hereby authorized, pursuant to Section 20.103(c),10 CW. 20, to enke allowance for the use of respiratory protective equiperce lydetermining whether individoals in restricted areas are exposed to concentrations of air-borne radioactive material in excess of the limits specified in Appendix B. Table I of 10 CFR 20 This authorization is conditioned upco observance of the provisions of Exhibits C, D, E cnd F of your Ictter of July 30,1%3, as arnended by Annex "A" attached hereto. bo chance in these requirements any be sede without prior air cyprovc1.
This cuthorization applits only to the forthcoming Ercaden rcrucling.
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l Cormnwecith Edison Company 2-A ture general authorization, as requested, to take credit for the use of protective equipment has not been granted at this titne. We zare evalunting the requirements for issuance of such an authorir.ation; and we cypreciate the report of Dresden experience during the past refueling period. A\\ report of your further experience under the authori:stion' contained in this letter would be helpful to us in establishing the over-all requirements for a more general authorization.
Sincerely yours, 6
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rem Lowmstein Director Division of I.icensing med P.egulatten
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Attediment:
Annex "A" 1
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4 ANNEK "A" i
ADDITIGlAL CQ DITICES RELATING TO AUIIIGIIZATIQ
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TO COMMONEAL*DI EDISQi COMPANY _
10 M% ALLOudiCE FOR USE &
l RESPIRATORY PROTECTIVE EQUIPMENT The edditional conditions to which the referenced authori: tion is subject f
pertain to and nodify the Commonwealth Edison Company application dated d
July 30,1%3 and are listed below with the indexing system used in the said submittal.
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1.
Exhibit C - Section I A Ihc following is added as a part of Section I A:
"It shall also be the responsibility of the plant mcnagement s
personnel to ascertain that competent, qualified personnci conduct the respiratory protective equipment progrrrn."
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2 Exhibit C - Section I C Section I C is revied to read 1
- Training sessions shall be presented in such a manner that l
y personnel are adequately instructed in the use of respiratory I
I protective equipenent. These training sessions are presented by the RPE, his designated, qualified management alternate, or radiation protection men who are quelif(od to give this in-struction. See Exhibit C, Section
- .t voz content of training
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prograa."
3.
Eyhibit C - Section I D Utc cecond sentence is revised to read:
" Instructions for the fitting procedures cnd for the seicetien of the proper cartridge shall be prepared by the he,.ith phyeieirt, the Radiation Protection Engincer or their qualified, tesignr.ted alternate, and shall include a simple and c1carly stated eethod of verifying leaktightness by the wearer."
Annex "A" Page 2 4
Exhibit C - Section 1 E Section 1 E is revised to read:
" Initial inspections and subsequent periodic inspections for proper fit will be made by the RPE, his designated, qualified elternate, and/or radiation protection men who are qualified to perform this inspection. However, field inspection for proper fit is performed by the individual, with assistance as required, after he has donned the equipment and made the adjustments as instructed."
5.
Exhibit C - Section I F Section I F is revised to read:
" Cleaning and maintenance of equipment shall be performed 17 radiation protection men or qualified altemates follmdng procedurcs and instructions prepare.d by the Rediation Protection Engineer er his designated, qualified management citernate."
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6 Exhibit C - Section II A (2)
Section II A (2) is revised to read:
"All the persons using respiratory protective equipment shall have received adequate instruction in respirator use prior to such use in Airborne Radioactivity Areas."
7.
Ev.hibit C - Section II B (1)
Section II B (1) is revised to read:
"Instructio.s and procedures for the cdjuster.t cnd fitting of rcspirators to the face shall be prepared by the r.:dictien Prot ection Engineer or his designcted, qualified citer.nt c, e.:
shall follow the recencendations of the re.nufacturer."
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Fage 3 E.
Exhibit C - Section II B (2)
Section 11 B (2) is revised to rendr
Initial fitting of respirators vill be performed by using cryl ecetate or stannous chloride compounds according to instructions and procedures prepared by the Radiation Protection Engineer or his designated, qualified alternate."
" Field inspection for proper fit will be made by stopping flow of air through cartridge or otherwise interrupting the air supply and then noting any leakage around face piece."
9.
Exhibit C - Section II 3 (4) (b)
The following is added as a part of Section II B (4) (b):
"he nature and frequency of these tests shall be specified by the Radiation Protection Engineer or his designcted, qualificd alt ernat e."
10.
Exhibit C - Section II E (5)
We second sentence of Section II B (5) is revised to rend:
" Selection of the proper cartridge will be based upon results of air sample analysis, according to instructions and procedures prepared by the Radiation Protection Engineer or his designated, qualified alternate."
11.
Exhibit C '- Section III A We last sentence of paragraph 1 of Section III A is revised to ruu:
"Ihis r.inor maintenance shall be performed by the Lctiction Trctcetion Man, st.o is under the supervision of the Ecdiction
- rct cetion Engineer or his designated, qualified r: neger.t c1t cinct c."
he second paragraph is revised to read:
" Equip:nent requiring certcin major repairs such an replacement cf lens rmy be returned to the manufceturer for this work.
Cc-tcin rcpcir opcretions, such cs repcir or cujurteent of prescure regulators or reducing valve acchcnir--7, th:11 bc 7 crferred by the nanufacturcr or by a factory-traincd technician,
Annex "N' Fage 4 12 D'.hibi t C - S ecti on III E The following is added as a part of Section III B:
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"Instruccions and procedures for decontamination cnd saniticing shall be prepared by the Radiation Protection Engineer or his i
designsted, qualified alternate."
13.
Exhibit C - Section III C
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Section III C is changed to read:
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"All respiratory protective equipment shall be curveyed for the presence of radioactive contemination prior to decontccincting and/or sanitizing.
(1) If levels of radioactive contamination cre found f
on a mask or hood such that the radioactivity on a t-swipe exceeds a value of 100 dpm for alpha or 1. COO dpm for beta-gansna per 100 cm2, the ucsk or hood shall be decontaminated to less than these limits before release.
l (2) Face pieces or hoods may be reused by the scre individual on the same working day, provided that:
(a) The beta-gam:nc contamination 1cvel on any surface of the face piece or hood is censured and found not to exceed 0.2 millirem per hour above background at I cm.
Such monitoring i
is not required if beta-gama contaminstion is known to be absent from the aren in which the face piece or hood is used.
(b) The alpha contamination IcVel is accsured end found not to exceed the I! its stated in perngraph III 3 (b) (1) cbevc.
Such renitering is not required if cipha centc:-inntion in lmeva to be absent frc= the arec in thich the fcec ccch cr hood is used.
(3) A cartridge or a cenister shall be replaced sfacn:
(a) The cartridge or canister has a battcre<i or damaged appearence.
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l'cse 5 i-(b) The cartridge or canister har been er. posed j
in cuch a renner that the filtea media ic returated or def ective.
(c) The cartridge or canister has been in use for a period of 24 hours2.777778e-4 days <br />0.00667 hours <br />3.968254e-5 weeks <br />9.132e-6 months <br />.
(d) he cartridge or canister measures a radiation level of 1 millires: per hour et a distance of I cm f
from the surface."
1 14 hhibit C - Section IV We first paragraph of Section TV is revised to read:
"In order to determine the effectiveness of the respirctory prot ective equipecnt program, nasal recars, bio-csscy sc=ples, thyroid counts, whole body counts or any other recognized methods of estimation of internal deposition of radionctive ruterials will be performed as necessary to de:mnstrate that no individual has inhaled, ingested or absorbed quentities of radioactive material in excess of those which might otherwise be permitted under the provisions of 10 CFR I' art 20 for ernloyees in restricted areas during a 4G-hour week."
15.
Exhibit C - Section IV A (3) he first sentence of Section IV A (3) is revised to read:
"A bio-assey will be performed when positive nasal contamination is obtained."
16.
E-hibit C - Section V A E c i n!. t c ent er.c c o f R ect ion V A i n r ev i.ud to rend :
"If during s verk cssign:nent, he bcco es unco.fortt.';1c cr uncc.
hc n.y exit fro-- the work cree fcr relief from thc disconfert and for rc-cvaluatien of the equip =crt es nects cry.'-
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J Annex "A" Page 6 17.
Exhibit C - Section V B (2)
Section V B (2) is revised to read:
" Credit shall be taken for Types 1 and 2 respiratory protective equipment for protection from radioactive halogen isotopes only what said types are equipped with canisters cr cartridges as specified in Table II, and it has been detemined by air sc=ple analysis that the capacity of the cartridges or canisters for halogens will not be exceeded."
4 I
18 Exhibit C - Table II shall be revised, as follows:
TABLE II i
TABLE T PROIECTIGI FACTmS FOR VARIOUS TYPES & RESPIRATmY PROIEETIVE DD' ICES I
Protection Facter 1 i
T,espirator Type Description Particulates Particulates Ges es I;o.
Eigh
!bderat e-Low and 2
Toxicity Toxicity Vapors 4
I Air-purifying Type 1
10 10 (Filter)
MSA Comfo Ralf-Mask 2
Air-purifying Type 100 ICU 100 (Full-Tace)
Willson Full-Face 3
Supplied-Air Demend-100 100 100 l
Type Scott Airlinc F5A Uciding Mask j
4 Supplied-Air Positive 1000 I?'O la Pre.ecurc I
42n.selding Mask Scott Air-Fok (!bdified)
Polyethylene Hood MSA Cheeryx rcr :
1 (c) 'Ihe Protection Factor is the reciprocal of the ccru.cd pcnctrrtien for the coq 1cte respircter. It is cpriicJ tc the iricrrc can-
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cecordinr to the followinc fer- :Ic:
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Annex " A" Fage 7 Airborne Concentration C w.W W Mh' rTotection 1 actor (b) 'Ihe Protection Factors listed above do not opply to cirborne radioactive contaminants that present an absorptier. cr sub-g raersion har.ard (such as tritium or argon).
i (c) The Protection Factors apply only for fitted respirators worn i
by trained individuals.
l (d) The Protection Factors for Types 1 and 2 respiraters apply only t
when high efficiancy particulate and/or chemical serbent canisters appropriate to the har.ard are used.
2 1:igh toxicity nuclides are as follows: Ac 227, Ac 22C, Ag 105, L; 110m, Ag 111, Am 241, Am 243, Ar 37, Ar 41, As 73, As 74, As 76, As 77, At 211, Au 1%, Au 19S, Au 199, Ba 131, Ba 140, Ec 7, Ei 206, Ei 207, Ili 210 Bi 212, Bk 249, Br 82, C 14, Ca 45, Ca 47, Cd 109, Cd 115m, Cd 115.
f 19.
Exhibit D - Section V l
Exhibit D,Section V is changed to read:
" Analytical results in excess of 4 dpci/ml shall re,uire en emency notification to Cormornrealth's P.edical Directer by telephone or telegram. All results Icss than this licit shall be reported via mail in standard report format."
i 20 F.xhibit D_
An additional section is added to Exhibit D as follows:
"VI.
Elo-Assav Pecords Eccordc of bio-assay enclyticci results chr.11 bc raintcinci cc pr.rt of the personnci er.posure records cthentisc rcc,uired b; 10 CTR 20.431 (c). Such records s. hall be cvailcbic for h pcetica by the Co r-ission upon ressencbic notice."
Anner. "/"
Page 8 f
21.
U.hibit E - Ecction II A (1)
Le last sentence of the first paragraph of Section II A (1) is f-changed to read l
"Ihe collecting filter is replaced every 24 hours2.777778e-4 days <br />0.00667 hours <br />3.968254e-5 weeks <br />9.132e-6 months <br /> et which I..
titae the filter is rc=nved end the average cirborne pcrticulate concentrations of the previous dcy arc deterrined."
f 22 Exhibit E - Section III l
he following consideratice is added to Section III l
"/.ppropricte cir cr:plcrs vill be used to deterninc the concentrction of airborne radiciodine or other radioactive gescs and vapors."
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23.
Exhibit E Section IV i,
Section IV is revised to read as follows:
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" Instructions and procedures for interpretetion of air i
sa=ples and the application of the results will be prepered l
by the Radiation Protection Engineer or his designr.ted, qualified altexuste."
i 24.
Exhibit F - Section I A ne third sentence of Section I A is corrected to read:
I "he canister absorbs carbon dior.ide fr om the ucer'r breath and evolves sufficient oxygen to meet the breathing requirementc."
I 25.
Ehibit F Section II E Sc. ncxt to 1cct scntence of Section II E in rc eised to rend:
';ne cir supply is r:aintained ct or ct vc r. ::.inin.n cf 4 cfr.
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Exhibit 7 Section III C
%c second sentence is revised to remd:
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breathing hose, and flow control valve which e.aintains pressure betwcen 8 to 15 psig st a flow rate at or above a mini:2:n of
.J 4 cfm."
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