ML20082Q511
| ML20082Q511 | |
| Person / Time | |
|---|---|
| Site: | Davis Besse  |
| Issue date: | 08/29/1991 |
| From: | Office of Nuclear Reactor Regulation |
| To: | |
| Shared Package | |
| ML20082Q501 | List: |
| References | |
| NUDOCS 9109120210 | |
| Download: ML20082Q511 (5) | |
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I SAFETY EVALUATION BY THE OFFICE OF NUCLEAR REACTOR REGULATION, RELATED TO THE USE OF A RADIO 10 DINE PROTECTION FACTOR FOR SORBENT CANISTERS AT DAVIS-BESSE NUCLEAR POWER STATION, UNIT _1, DOCKET NO. 50-346 INTRODUCTIO_N, By submittal dated Decenter 5,1989, supplemented July 12 and 29,1991, Toledo Edison Company (the licensee) requested an exemption from 10 CFR Part 20, Appendix A, footnote d-2(c), and authorization to use equipment which has not been certified bv National Institute for Occupational Safety and Health /Mine Safety and He:Ith Administration (NIOSH/MSHA) at Davis-Beste Nuclear Power Station, Unit 1.
The licensee submitted this request in accordance with 10 CFR Parts 20.501 and 20.103(e).
Test data and canister qualification information have been provided by the
-licensee. The exemption and authorization would allow the use of a radiciodine protection factor of 50 for Mire Safety Appliance Company (MSA)
GMR-I canisters at Davis-Besse. Criteria and background information used for this evaluation include 10 CFR 20.103; 10 CFR 19.12; Regulatory Guide 815, " Acceptable-Programs for Respiratory Protection;" Regulatory Guide 3.20, " Applications of Bioassay for 1-125, and 1-131;" NUREG/CR-3403,
" Cartridges a,nd Test Methods for Certifying Air Purifying Respirator Cartridges and Canisters Against Radiciodine," and Regulatory Guide B.8, "Infermation Relevant to Ensuring That Occupational Radiation Exposures at Nuclear Power Stations Will Be As Low As !s Reasonably Achievable."
DISCUSSION AND EVALUATION, Since an NIOSH/MSHA testing and certification schedule for sorbents for ute for protection against radioiodine gases and vapors has not been developed, the NRC staff-has evaluated the licensee's request'and vartfied that the licensee has demonstrated through reliable test data and adequate quality assurance measures that the material and performance characteristics of the MSA GMR-I canister can provide the proposed degree of protection (i.e., a protection factor of 50) under the anticipated conditions of use, as required by 10 CFR 20.103(e), for 8 hours9.259259e-5 days <br />0.00222 hours <br />1.322751e-5 weeks <br />3.044e-6 months <br />.
The staff considered canister efficiency and service life, and the effects of temperatore, poisons relative humidity, challenge concentration and breathing rates on canister efficiency and service life. The programmatic evaluation considered quality control /qus11ty assurance, and radiation protection /ALARA consideratiens, including task preparation and planning, on-the-job and post-task evaluations, use of engineering controls, radiological surveillance, and radioiogical training.
9109120210 910829 PDR ADOCK 050 6
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- The licensee has provided reliable test information which verifies that the
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MSA GMR-1 canister will provide 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 temperatur does not exceed 110'F.
The data provided by MSA demonstrate the breakthrough point to be weli 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 ecceptable conditions of cyclic flow, and under worst case conditions for those environmental factors affecting service life:
temperature, relative humidity, and challenge concentration CH I (methyliodide/ methyl radicior'ide), which is the most penetrating of the ch$11angeforms. Data provided from MSA indicate that the MSA GMR-1 canisters perform adequately under the acceptable test conditions, lhese i
conditions - the criteria and test methods - are consistent with those derived for the canisters by the NRC staff from NUREG/CR-3403, and are acceptable.
i The licensee, through acceptance of MSA QA controls, has provided commitments that the MSA GMR-1 canisters will meet standards for avality assurance and quality control which are recognized by NIOSH, compatible with NRC staff positions, and are the efore acceptable. This includes a commitment by MSA to establish a 11 AQL (Acceptable Quality Limit) in a 5 to 10 ppm challenge concentration of CH 1, 90% relative humidity,110*F, 64 LPM cyclic flow, for 3
a service life of 8 hours9.259259e-5 days <br />0.00222 hours <br />1.322751e-5 weeks <br />3.044e-6 months <br /> or more at penetration equal to 1% of the challenge i
cor. centration. Testing data referenced by the licensee demonstrated that perform 4nce (i.e., service life) of canisters at 1001 relative humidity is acceptable.
P Coupled with the use of a full facepiece with the capability of providing a l
fit factor equal to or greater than 500 by quantitative fit test, the protection factor of 50 is acceptable. Canister efficiency will be retained for. the radiciodine gas or vapors of interest (CH 1,1, HW for this time period.
Toprecludeaging,servicelifewillbecalc$latedfrom 3
unsealing time, including periods of non-use, and the canister will not be l
used in the presence of organic' solvents or in temperatures in excess of 110'F.
In addition, the licensee will preclude exposures to organic vapors l
and chemicals (such as decontamination compounds, lubricancs, volatilized paint, alcohols, Freon) which could cause aging, poisoning or desorption of the absorbed radiciodines. Also, workers will be trained on the proper use i
and limitations of the GMR-I-canisters prior to canister issuance.
l Certain limitations'and precautions based on NUREG/CR-3403 guidance are necessary for utilization of the sorbent canisters.
The :taff agrees with 3
the following limitations and usage restrictions as proposed by the licensee:
l 1.
A protection factor equal to 50 as a maximum value will be used.
2.
The maximum permissible use time will be 8 hours9.259259e-5 days <br />0.00222 hours <br />1.322751e-5 weeks <br />3.044e-6 months <br /> after which the canister will be discarded.
The use time will begin when the i
canister is unsealed and will include periods of non-exposure.
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3 3.
Canisters will not be used in the presence of organic solvent
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vapors. Painting or the use of organic substances will be prohibited while the GMR-1 canister is in use.
4 Canisters will be stored in sealed, humidity barrier packaging in a cool, dry environment.
The GMR-1 canisters will be maintained in Class "A" storage (as defined in ANSI N45.2.2) except for those maintained for ready issuance in the respirator issue area.
5.
Canisters will be used only with a full facepiece proven capable of providing the individual with a fit factor greater than 500 by a quantitative respirator fit test.
I 6.
Canisters will not be used in total challenge concentrations of Organic iodines and other halogenated compounds greater than 1 ppm,
' including non-radioactive compounds.
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7.
Canisters will not be used in environments where temper 6tures exceed '10*F.
Temperatures at work locations where GMR-1 L
canisters 4.re in use will be measured each shift and/or
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coincidentally with operations which heat the work areas to assure that this limit is not exceeded.
t in addition to the limitations and usage restrictions noted e
above the following program verification measures during initial
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GMR-I canister implementation will be used:
i a.
weekly whole body counts of individuals using the GMR-1 canister for radiciodine protection will be performed; b.
a whole body count will be given to individuals who exceed 4.
10 MPC hours in 7 consecutive days prior to their next. entry into a radiciodine atmosphere; c.
if an individual mehsures any iodine uptake to the thyroid during a whole body count following use of GMR-I canisters, the individual will be restricted from further entries into i
radioicdine atmospheres pending a health physics evaluation; i
-d.
a w ole _bcdy count survey data base will be compiled to evaldate the results of the program.
The' primary basis for the licensee's request for exemption is the potential for dose reduction. The utilization of air purifying respirators in lieu of air-supplied or self-contained apparatuses, where possible, can result in person-ram reductions estimated overall at 25% for tasks requiring respirators (i.e., sorbent canisters) ght, less cumbersome sir purifying radiciodine protection. The light wei can provide increased comfort and mobility in most cases, and result in increased worker efficiency and decreased time on-the-job.
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Other acsions taken by the licensee to assere that exposures to radiciodine are as iow as reasonably achievable (ALARA) are:
containment purging, removal of contaminants from the reactor coolant system during cooldown, performance of ALARA reviews for planned jobs, weekly whole body counts, and training of workers on the proper ;te and limitations of sorbent canisters for radfaiodine protection.
The licensee's efforts to keep exposure ALARA are cs'sistent wit'n staff positions in Regulatory Guide 6.8 and are acceptable.
_ CONCLUSION The NRC staff review of the licensee's proposal indicated that the actions proposed by the licensee :an result in significant dose savings over alternative metboos while still providing effective protection.
This exemption would enable the licensee to us a protection factor for air purifying radiciodine gas and vapor respirators in estimating worker exposures from radioiodine gases end vapors. The licensee has provided usage restrictions and controls which can assure an effective radiciodine protection program. The oroposed criteria and test methods for verifying _
the effectiveness and quality of GMR-1 canisters are consistent with the staff's criteria. The licensee's proposed exemption, with the controls-and limitations, meets the NRC staff's positions in the Standard Review Plan (NUREG-0800), NUREG/CR-3403 and Regulatory Guide 8.8 and is acceptable.
The actions preposed by)the licensee are consistent with the requirements of 10 CFR Part 20.103(e and form an acceptable basis to authorize the use of equipment (MSA GMR-1 canisters) in accordance with 10 CFR 20.103(e) and t
to authorize the granting of an exemption in ar.cordance with the provisions of 10 CFn. Part 20.501.
Principal Contributor:.lon B. Hopkins, NRR f
Dated:
August 29, 1991 i
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- e 8ptemb;r 3,1991 DOCKET NO.
50-3%
Regulatory Publications Branch htEMoRANDUM FOR.
Division of Freedom olinfortnation and Publicspons Services Office of Administ'etion and Resources Management P
FROM:
C%ce of Nuclear Roactor Regulation TOLEDL EDISON COMPANY, CENTERIOR SERVICE COMPANY AND THE CLEVELAND ELECTRIC ILLUMINATli4G COMPANY (DAVIS-BESSE suas CT:
POWER STATION, UNIT NO. 1)
One sigrid oteginal of the Federas Regisfer Notice idenUf.cd below is enclosed for your transwttal tc the Office of the Federal Registm for pubhcation Additional conformed copie 2 ( 6
) of the Notice are enclosed f or your use
.40tice of Rect,tet of Appheation for Construcuon Permitist and Operating Utenseisi 5
Notice of Receipt of Partial Apchcation for Cor t.truction Permitts) and Facihty Ucenseis): Tit.e for Submission of Views on Antitrust Matters Notice of Considostion of issuance of A.mendment to Facihty Operating Ucense,(Call with day insert cateL Notice of Recetot of Application for Facthty Ucense(s), Notice of Avaitastity of Applicant's Environmental R sport, and Notice of Consideration of issuance of Facility Ucensets) a Td No9cn of Opportunity for Hearing Notice of Availability of N8C Drsit!Fina Enytronmental Statement.
Notice of Limittd Work Authoti;ation Notice of Availab6hty of Saf ety Evaluation Report Notice of issuance of Construction Permit (s)
Notice of Issuance of Facility Operating Ucensets)or Aniendment(n Order.
Exemption.
Notics of Gra.iting Exemption.
Environtrental Assessment.
Notice of Deeparation of Erivironmental Assessment.
Receipt of Petition f or Director's C9eision 'Jnder 10 OF R 2.206.
O issuance oi Fi,,i ai,.ctor s oecision under iO CFn 2.20s.
O other-John N, HanrKm. Director Project Directorate Ill-3 En:tosure:
Ao statud PRt KrfititICT Cen9 set rmone:
49-21392
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unc ron. sie no noi acu osao OFFICIAL RECORD COPY
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