ML20077F662
| ML20077F662 | |
| Person / Time | |
|---|---|
| Site: | Davis Besse  |
| Issue date: | 12/05/1989 |
| From: | Shelton D CENTERIOR ENERGY |
| To: | NRC OFFICE OF THE EXECUTIVE DIRECTOR FOR OPERATIONS (EDO) |
| References | |
| TAC-75234, NUDOCS 9106200103 | |
| Download: ML20077F662 (3) | |
Text
Nh/?$h0 tf 9/7A TOLEDO EDISON z c.wm_
DONuo C SHELTO'.
x, %, w - s my w m m:
Docket Number 50-346 License Number NPF-3 Serial Number 1728 December 5. 1989 United States Nuclear Regulatory Commission Executive Director for Operations Vashington, D. C. 20555
Subject:
Request for Exemption from 10CFR20 Appendix A to Allow Credit for Use of a Radioiodine Protection Factor for Mine Safety Appliance Company GMR-1 Filter Canisters (TAC Number 75234)
Gentlemen:
Appendix A to 10CFR20 establishes protection factors for air-purifying respirators for particulates only, and footnote d-2(c) states that "no allovance is to be made for the use of sorbents against radioactive gases or vapors." In accordance with 10CFR20.103(e), where a particular type of respiratory protection does not have current National Institute fot Occupational Safety and Health /Mine Safety and Health Administration (NIOSH/MSHA) certification, no allowance for protect 2on may be made without specific authorization by the Commission.
An application for this authorization must include a demonstration by testing or on the basis of reliable test information that the material and performance characteristics of the equipment are capable of providing the proposed degree of protection under anticipated conditions of use.
Adequate respiratory protection from airborne radiciodines is currently provided at Davis-Besse Nuclear Power Station (DBNPS) Unit 1 by the use of air lines or self contained breathing apparatus (SCBA).
However, the use of light veight, less cumbersome, air purifying respirators in lieu of air lines or bmc SCBA can provide increased worker comfort and mobility.
The corresponding 88.'
increase in efficiency and dect.ne in on the job time can result in y
overall dose savings.
co o mz In accordance with 10CFR20.501 and 10CFR20.103(e), Toledo Edison requests an 08 exemption from 10CFR20, Appendix A, footnote d-2(c), and authorization to
.Oo credit a radioiodine protection factor for the use of Mine Safety Appliance I@#
Company (MSA) GMR-I canister (Number 466220) at the DBNPS.
The following l h conditions, l bitations and restrictions vill apply to the use of MSA GMR-I l
Q canisters for radioiodine protection at the DBNPS:
}
- o. a n.
l IHE TOLEDO ED! SON COMPANY EDISON PLAZA 300 MADtSON AVENUE TOLEDO. OH:043652
/
I hd.'IVDD/D TfAb i EsiV...Dt-Qut l E f j c-. si m p sc n, f _ _ _ _ _ _ _ _ _ _
i Docket Number 50-346 License Number NPF-3 Serial Number 1728
'Page 2 A protection factor equal to 50 as a maximum value vill be used.
The maximum permissible use time vill be eight hours after which the canister vill be discarded.
The use time vill begin when the canister is unsealed and vill include periods of non-exposure.
Canisters vill not be used in the presence of organic solvent vapors.
Fainting or the ese of organic substances vill be prohibited while the GMR-I canister is in use.
Canisters vill be stored la sealed, humidity barrier packaging in a cool, dry environment. The GMR-I canisters vill be maintained in Class "A" storage (as defined in ANSI U45.2.2) except for those maintained for ready issuance in the respirator issue area.
Canisters vill be used only with a full facepiece proven capable of providing the individual with a protection factor greater than 100 by a quantitative respirator fit test.
Canisters vill not be used in total challenge concentrations of organic iodines and other halogenated compounds greater than 1 ppm, including non-radioactive compounds.
Canisters vill not be used in environments where temperatures exceed 130*F.
Temperatures at vork locations where GMR-I canisters are in use vill be measured each shift and/or coincidentally with operations which heat the work areas to assure that this limit is not exceeded.
The following program verification measures during initial GMR-I canister implementation vill be used:
a.
veekly whole body counts of individuals using the GMR-I canister for radiciodine protection vill be performed; b.
a whole body count vill be given to individuals who exceed 30 MPC hours in seven consecutive days prior to their next entry into a radioiadine atmosphere; c.
if an individual measures 35 nCi or greater iodine uptake to the thyroid during a whole body count, the individual vill be restricted from further entries into radiciodine atmospheres pending a health physics evaluation; d.
a whole body count survey data base vill be compiled to coordinate the results of the program.
These restrictions, limitations and controls applicable to the use of MSA GMR-I canisters are consistent with conditions applicable to similar exemptions granted by the Commission to Alabama Power, Southern California Edison and Union Electric.
l Toledo Edison references the results of previous testing conducted by MSA vhich demonstrate that the GMR-I canister is capable of providing the proposed
O
'k..
Docket Number 50-346 I
License Number NPF-3 Jeri.a1 Number 1728
- Page 3 degree of radioiodine protection, as satisfying 10CFR20.103(e) in support of this exemption request.
The results of this testing vere previously accepted by the NRC in conjunction with the review of similar exemption requests from other utilities.
The MSA test results are documented in the attachment to the Union Electric Company's October 22, 1985 letter to the NRC requesting a similar exemption.
Approval of this exemption is requested by February 1, 1990 to permit credit to be taken for use of MSA GMR-I canisters during the upcoming sixth refueling outage.
Pursuant to 10CFR20.103(g) this letter constitutes 30 days prior notification of an intent to use the MSA GMR-I canister (Number 466220) under conditions and limitations described above, pending NRC approval of this exemption request.
If you have any questions regarding this request, please contact Mr. R.
V. Schrauder, Nuclear Licensing Manager at (419) 249-2366.
Very truly yours,
,~,
^
s A
j
'A l
PVS/ssg cc: P. M. Byron, DB-1 NRC Senior Resident Inspector
- f. B. Davis, Regional Administrator, NRC Region III
/T. V. Vambach, NRC/NFR DB-1 Senior Project Manager l
.