ML20059D402
| ML20059D402 | |
| Person / Time | |
|---|---|
| Site: | South Texas  |
| Issue date: | 12/30/1993 |
| From: | Adensam E Office of Nuclear Reactor Regulation |
| To: | HUDSON LIGHT & POWER DEPT. |
| Shared Package | |
| ML20059D405 | List: |
| References | |
| NUDOCS 9401070248 | |
| Download: ML20059D402 (4) | |
Text
J 7590-01 UNITED STATES OF AMERICA NUCLEAR REGULATORY COMMISSION In the Matter of
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HOUSTON LIGHTING & POWER COMPANY
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Docket Nos. 50-498
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and 50-499 (South Texas Project, Units 1 and 2)
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EXEMPTION I.
On March 22, 1988, and March 28, 1989, the Commission issued Facility Operating License Nos. NPF-76 and NPF-80 to Houston Lighting & Power Company, et al. (the licensee)_for South Texas Project, Unit Nos. I and 2, respectively. These licenses provided, among other things, that the facilities are subject to all rules, regulations, and orders of the Commission.
II.
Appendix A of Part 20 of Title 10 of the Code of Feder il Regulations,
" Protection ractors for Respirators," establishes protection factors of air-purifying respirators for protection against particulates only. Furthermore, footnote d-2(c)
.tes, "No allowance is to be made for the use of sorbents against radioactive material in the form of gases or vapors." This restriction was needed since an inadequate' data base has existed for evaluating the complex interaction of many factors affecting the service life and removal efficiency of radioactive' gases and vapors by-sorbent canisters.
Also, due to the lack of a data base, a National Institute for Occupational Safety and Health /Mine Safety and Health Administration (NIOSH/MSHA)-
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certification schedule has not been established to ensure that the canisters meet acceptable performance criteria.
Section 20.103(e) of 10 CFR Part 20 allows the Commission to authorize I
the use of respiratory equipment in lieu of an NIOSH/MSHA certification when such an action is justified based on adequate testing of material and performance characteristics.
By letter dated December 19, 1991, as supplemented by letters dated l
July 1, 1993, and November 3, 1993, HL&P requested an exemption based on 10 CFR 20.501 to allow the use of radioiodine Mine Safety Appliance Company (MSA) GMR-1 canisters with a protection factor of 50 for personnel respiratory protection.
In support of the exemption request, HL&P cited test'results and a quality assurance plan that satisfies the recommended qualification process l
of NUREG/CR-3403, " Criteria and Test Methods for Certifying Air-Purifying Respirator Cartridges and Canisters Against Radioiodine."
III.
The NRC staff evaluated the information provided by HL&P.
The licensee provided reliable test information verifying that the MSA GMR-1 canister is capable of providing a protection factor of 50 over a period.of 8 hours9.259259e-5 days <br />0.00222 hours <br />1.322751e-5 weeks <br />3.044e-6 months <br /> of continuous use, provided that the total challenge of radioactive and non-radioactive iodine and other halogenated compounds-does not exceed 1 ppm, and temperature does not exceed 110*F provided the dewpoint does not exceed 107'F.
The data showed the breakthrough point to be well beyond 8 hours9.259259e-5 days <br />0.00222 hours <br />1.322751e-5 weeks <br />3.044e-6 months <br />.
Testing has been conducted under acceptable conditions of cyclic flow and under worst-case conditions for those environmental factors affecting 4
service life (i.e., temperature, relative humidity, and challenge L
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' concentration of CH 1 (methyliodide/ methyl radiciodide), the most penetrating 3
of the challenge forms). The data showed that the MSA GMR-I canisters performed adequately under acceptable test conditions. These conditions, including criteria and test methods, are consistent with those. derived by the NRC staff from NUREG/CR-3403, " Criteria and Test Methods for Certifying Air-Purifying Respirator Cartridges and Canisters Against Radioiodine."
HL&P, through acceptance of MSA QA controls, has provided commitments that the MSA GMR-1 canisters will meet standards for quality assurance and quality control that are recognized by NIOSH and are compatible with NRC staff positions. This includes a commitment to establish a 1 percent AQL (acceptable quality limit) in a 5 to 10 ppm challenge concentration of CH 1, 3
90 percent relative humidity,110*F, 64 liters per minute cyclic flow, for a service life of 8 hours9.259259e-5 days <br />0.00222 hours <br />1.322751e-5 weeks <br />3.044e-6 months <br /> or more at a penetration equal to 1 percent of the challenge concentration. Test data referenced by HL&P demonstrate that performance (i.e., service life) of canisters at 100 percent relative humidity is acceptable.
IV.
Accordingly, the Commission has determined that, pursuant to 10 CFR 20.501, this exemption is authorized by law and will not result in undue hazard to life or property.
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Accordingly, the Commission hereby grants an exemption as described in
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Section III above from 10 CFR Part 20, Appendix A, footnote d-2(c) to authorize the use of the MSA GMR-1 canister at South Texas Project, Units 1 and 2.
For additional details regarding the basis of this exemption, including usage limitations and restrictions, see the staff's safety evaluation dated December 30, 1993 available for.public inspection at the i
. Commission's Public Document Room, the Gelman Building, 2120 L Street, N.W.,
Washington, D.C., and at the Wharton County Junior College,'J.M. Hodges Learning Center, 911 Boling Highway, Wharton, Texas 77488.
Pursuant to 10 CFR 51.32, the Commission has determined that the granting of the Exemption will have no significant impact on the environment' (58 FR 42112).
This Exemption is effective upon issuance.
Dated at Rockville, Maryland, this 30th day of December 1993.
FOR THE NUCLEAR REGULATORY COMMISSION Elinor G. Adensam, Acting Director Division of Reactor Projects III/IV/V Office of Nuclear Reactor Regulation 4
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