ML20079E313
| ML20079E313 | |
| Person / Time | |
|---|---|
| Site: | Farley  |
| Issue date: | 01/13/1984 |
| From: | Clayton F ALABAMA POWER CO. |
| To: | Varga S Office of Nuclear Reactor Regulation |
| References | |
| RTR-NUREG-CR-3403 NUDOCS 8401170235 | |
| Download: ML20079E313 (6) | |
Text
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w-MJiling Addross Alabama Power Company 600 North 18th Street Post Othee Box 2641 Birmingham, Alabema 35291 Telephone 205 7834081 F. L Clayton, Jr.
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AlabamaPower January 13, 1984 Docket Nos. 50-348 40-?SM Director, Nuclear Reactor Regulation U. S. Nuclear Regulatory Commission Washington, D.C.
20555 Attention: Mr. S. A. Yarga Joseph M. Farley Nuclear Plant - Units 1 and 2 10CFR20; Respiratory Protection; Iodine Filter Exemption Request Gentlemen:
Alabama Power Company's Farley Nuclear P1 ant, Unit 1 will commence an extended outage in February,1984. Major work to be accomplished in addition to refueling includes lower control rod guide tube split pin replacement and steam generator tube sheet repair.
It is also anticipated that significant levels of radioiodine will be encountered henceforth due to remaining contamination from a previous cycle in which failed fuel cladding was encountered. Satisfactory respiratory protection for radioiodine can be afforded by the use of air supplied or self contained breathing apparatuses; however, these appliances are cumbersome and contribute to worker fatigue and efficiency loss. The net result is increased man-rem exposure and a reduced personnel safety margin when compared to the use of air-purifying respirators which enhance worker comfort and allow greater mobility, We estimate that air-purifying respirators would enable a 25-50% reduction in the time required to conduct tasks requiring respiratory protection.
Likewise, a 25-50% reduction in man-rem exposure would be realized for these tasks.
10CFR20, Appendix A, " Protection Factors for Respirators" does not recognize the use of air-purifying respirators for protection against radioiodine and footnote (c) specifically prohibits this practice. However, we are aware of research that has been accomplished to certify air-purifying respirators against radioiodine sponsored by the USNRC-Occupational Radiation Protection Branch and reported in NUREG-CR 3403.
We have communicated with Mr. Eric Beck of Mine Safety Appliance Company (MSA) who has provided test results, a proposed test protocal and a quality assurance sampling plan (attached) for the MSA 466220 GMR-I gter that satisfies the recommended qualification process of NUREG-CR 8401170235 840J13 Ch DR ADOCK 05000348 i
PDR j
Mr. S. A. Varga January 13, 1984
.U. S. Nuclear Regulatory Commission Page 2 Pursuant to 10CFR20.103(e) and 10CFR20.501, Alabama Power Com hereby applies for exemption to 10CFR20, Appendix A, footnote (c) pany to allow 4'
credit for a radiciodine protection factor-in employing the MSA 466220 GMR-I Canister. The limitations and precautions noted in the attached MSA letter and NUREG-CR 3403 summarized below will apply:
1.
protection factor =50 2.
8 hour9.259259e-5 days <br />0.00222 hours <br />1.322751e-5 weeks <br />3.044e-6 months <br /> maximum continuous use time after wnich the canister would be discarded.
3.
not to be usec in the presence of organic solvent vapors.
4.
to be stored in sealed, humidity barrier packaging in a cool, dry environment.
5.
service life to be calculated from the time of unsealing including periods of non-exposure.
~6.
to be used with a facepiece capable of providing protection factors greater than 100.
.7.
not to be used in challenge concentrations of total crganic iodine, including nonradiometric iodine greater than 1 ppm.
8.
not to be used in environments greater than 110*F or 90% relative humidity.
Per 10CFR20.103(g), this letter represents notification of our intent to use the MSA 466220 Gi1R-I-Canister 30 days from this date pending USNRC approval of this exeirption request.
Yours very truly, F. L. Clayton J r.
FLCJr/WCC:ddr-D37 cc:.Mr. R. A. Thomas Mr. G. F. Trowbridge Mr. J. P. - O' Reilly Mr. R. E. Alexander Mr. E. A. Reeves Mr. W. H. Bradford
bec: Mr. R. P. Mcdonald Mr. O. D. Kingsley, Jr.
Mr. W. G. Hairston, III.
Mr. C. D. Nesbitt Mr. E. J.
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A Mine Safety Appliances Company 600 Penn Center Bculevard Pittsburgh, Pennsylvania 15235 412/274 5000 Wnter's Direct Dial Number 412/273-5194 January 12, 1984 Alabama Power Company 600 North 18th Street P.O. Box 2641 Birmingham, Ah ?5291 ATTN:
Mr. Wayne Carr Health Physics
Dear Wayne:
Enclosed are the results of the tests, from MSA Engineering, in accordance with the parameters agreed on in our recent meeting and subsequent telephone conversations.
Also enclosed is a summary of the proposed protocol for lot testing of the GMR-I Canister.
Based on our test results (assuming favorable variance consideration by the NRO), MSA would recommend the GMR-I #466220 for use in areas not exceeding 110*F 90% RH at <1 ppm CH 1 for up to one 8-hour shift.
The canister must be 3
discarded at the completion of each 8-hour shift (i.e. one use per canister).
If you need further information, please don't hesitate to call.
Sincerely,
.f )
Eric J. Beck Nuclear Industry Specialist car Enclosure 1
F.99635ET teF74
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GHR-I CANISTER TESTING T
Average Inlet -
Outlet Test Conditions Concentration Time Concentration 110*F 50% RH
-- 46 p pm 510 min.
<.03 ppm
.64 Lpm.
Tbelow aetection) 110*F 90% RH 12 ppm 600 min.
<.003 ppm i
64 Lpm-Thelow detection) 50*F 50% RH 31 ppm 480 ein.
<.003 ppm 64 Lpm Tbelow detection) 510 win.
.03 ppm 660 min.
.09 ppm 4
J a
t 3
2
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PROPOSED PROTOCOL FOR LOT TESTING OF THE MSA GMR-I CANISTER #466220 T
~
Summary (Complete protocol has been sent to the NRC)
Challenge vapor:
CH 1 3
Challenge concentration: 25 ppm -
- Breakthrough concentration: 0.25 ppm Flow rate: 64 L/ min Test temperature: 25 +1*C
- Test relative humidity: 85 +2%
Equilibration:
(a) none (as received)
(b) 85% RH, 64 L/ min for 6 hours6.944444e-5 days <br />0.00167 hours <br />9.920635e-6 weeks <br />2.283e-6 months <br /> No. of tests: : 4 at-each condition for a total of 8 per MIL STD-105 f
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