ML20084L735

Forwards Response to 840217 Request for Addl Info in Support of 840113 Exemption Request Re Iodine Filter Respiratory Protection

ML20084L735
Person / Time
Site:	Farley
Issue date:	05/08/1984
From:	Mcdonald R ALABAMA POWER CO.
To:	Varga S Office of Nuclear Reactor Regulation
References
NUDOCS 8405150013
Download: ML20084L735 (30)

Text

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Malling Address Af;bims Power Comp ny 600 North 18th Street Post Office Box 2641 Birmingham, Alabama 35291 Telephone 205 783-6090 R. P. Mcdonald Senior Vice President AlabamaPower t

i tre saatwrn electre system May 8, 1984 Docket Nos. 50-348 50-364 i

Director, Nuclear Reactor Regulation U. S. Nuclear Regulatory Commission Washington, D.C.

20555 l

Attention: Mr. S. A. Varga Joseph M. Farley Nuclear Plant - Units 1 and 2

,e 10CFR20 Exemption Request; Iodine Filter Respiratory Protecition Additional Infonnation for Radiological Assessment Branch Gentlemen:

The attached responses are provided to 'the request for additional information enclosed in your letter dated February 17, 1984. This information is submitted in support of our January 13, 1984 request for exemption to 10CFR20, Appendix A, footnote (c) to allow credit for a protection factor when using the MSA 466220 GMR-I canister in atmospheres containing radiofodine.

Your truly,

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R. P. Mcdonald RPM /WCC:grs-D8 Attachment cc: Mr. L. B. Long Mr. J. P. O'Reilly Mr. R. E. Alexander Mr. E. A. Reeves Mr. W. H. Bradford

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Dr. I. L. Myers

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471.0 RADIOLOGICAL ASSESSMENT BRANCH - REQUEST FOR ADDITIONAL INFORMATION Question:

471.11 Provide additional details for the limitations for use for the GMR-I canisters as follows:

a.

What specific organic vapors are of concern at the Farley 1 & 2 facilities in both. storage and proposed usage areas (e.g.,

freons, alcohols, carbon tetrachloride, paint fumes, EDTA, etc)?

How will levels of concern be established for such vapors?

b.

How will such vapors be precluded and/or detected in storage

and/or work areas so as to prevent aging and impacts on service life / capacity?

t c.

How will environmental temperature and humidity be initially determined and then subsequently measured and controlled throughout the (ourse of work, particularly during changing r

conditions?

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Response

(a & b)

FNP procedures preclude the indiscriminate use of chemical products for health and system contamination concerns.. In general, the following compounds or products are permitted which may result in organic vapor release: paint; paint remover (methylethylketone); freon cleaning agent

~ (trichlorotrifluoroethane); isopropyl alcohol; and methyl chloroform.

Safety related ventilation filtration systems at FNP contain charcoal for radioatmospheric iodine removal and require measures to prevent organic vapor contamination for reasons similar to the GMR-I concerns. Areas served by these f

i ventilation systems include the Containment Building and Penetration Rooms (within the Auxiliary Building). Measures have been implemented and are required to restrict painting and chemical releases in these areas per the FNP j

Technical ~ Specification (3/4.7.8 & 3/4.9.14) which will also provide adequate i

restriction for the GMR-1 canister.

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T Use of the GMR-I canister in the remaining portion of the Auxiliary Building is unlikely. However, if a situation dictates use of the GMR-I l

t canister in these remaining areas,. painting or the use of organic substances i

will be prohibited while the canister is in use.

In addition, the canister will-l not be used after recent painting or use of organic substances. Additionally, for those occasions when painting is permitted in areas served by safety related ventilation systems, use of the GMR-I canister will be restricted. These provisions will be included in GMR-I canister use procedures.

Organic vapor exposure is not a concern in. respirator storage areas. The

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canisters are purchased in a hermetically sealed condition and are not opened until placed in use at the work location.

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-Response:

(c)

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1 Temperature will be measured at the beginning of a shift in which the GMR-I canister will be utilized. Thereafter, temperature will be measured once per j

i shift or. coincident with evolutions.which could impact temperature such as RCS

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'heatup or equipment hatch closure to assure that the temperature limitation e (110*F) determined by MSA is not exceeded.

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h Additional Testing by MSA has determined that the canister is acceptable for use at 100% relative humidity for eight hours, therefore, the need to.

L monitor humidity h'as been eliminated.

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4 The time and temperature limitations will be included in the GMR-I use

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procedures.

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Question:

l 471.12 Provide a commitment to verify the effectiveness of this special

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respiratory. protection pr ogram, including the following:

r t-a.

weekly whole body counts for individuals using the GMR-I canister for radiof odine protection; b.

for individuals who exceed 10 ffC hours, a whole body count will be required prior to the individual's next entry into a i

radioiodine atmosphere; c.

establish an uptake level beyond which further entry into a l

l radioiodine atmosphere would be restricted, pending health

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physics evaluation (e.g., 70 nCi);

d.

establish a whole body count / survey data base to be used to evaluate the results of the program, identify additional necessary restrictions, or provide recommendations for reduced requirements.

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Response

i For initially implementing use of the GMR-I canister where an iodine protection factor is used, Alabama Power Company proposes the following effectiveness verification measures:

l a.

weekly whole body counts for individuals using the GMR-I canister for radioiodine protection.

b.

for individuals who exceed 20 MPC hours, a whole body count will be required prior to the individuals next entry into a radiofodine atmosphere.

c.

if an individuals measures 70 nCi or greater iodine uptake to the thyroid during a whole body count, his entry into radiciodine atmospheres will be restricted pending health physics evaluation.

d.

A whole body count / survey data base will be compiled to evaluate the results of this program.

Upon collection of a data base which, in our judgement, is adequate to judge the results of the above verification program, we propose to relax these limitations in a stepwise fashion, if necessary, to controls commensurate with the hazard involved and within our current respiratory protection program.

Question:

471.13 Provide specific information for selected tasks which compares data on dose rate, manpower, task time, and total dose for the use of GMR-I canisters and air line respirators (as previously requested in Q471.2).

. Comparison of Airline Respirator

Response

or SCBA with GMR-I Canister Task Time Man hours Airline Respirator Task Dose Rate Manpower or SCBA/SMR-I Canister Total Dose (MR/hr)

(hrs)

(MR) 1.

Pressure Safe,ty Valve Testing 26 6/6 7/5 182/130 2.

Containmer.t

-Sump Work 11 6/6 57/37 627/407 3.

RCS Seal Inspect

& Replace 55 12/9 180/135 9900/7425 4.

Reactor Cavity Decon 22 18/18 314/235 6908/5170 5.

RHR Check Valve Repair 37 5/4 52/39 1924/1443 6.

Accumulator Check Valve Repair 45 8/6 77/58 3465/2610 7.

RHR Heat Exchanger Gasket Replacement 59 13/10 144/100 8496/5900 8.

Spent Fuel Pool Transfer Canal Work 12 4/4 21/16 252/192 9.

Containment Entry at 100% Power 75 9/6 27/12 2025/900 10.

Incore Thimble Cleaning 17 16/12-90/68 1530/1156 Totals 97/81 969/705 35,309/25,333

Question:

471.14 Perform batch QC tests under cyclic flow test conditions (e.g., 56 L/M) or provide sufficient test data under testing conditions of worst case temperature and relative humidity to show the absence of a-cyclic flow effect, i.e., service life under cyclic flow test conditions is not significantly less (95% confidence) than service life under steady state conditions.

(Reference Q471.5)

Response

As described in the attached letter from MSA (April 13,1984), the test methodology has been changed from steady flow to cyclic flow condition.

Question:

471.15 (a) Perform quality control testing under the conditions of worst case temperature at worst case relative humidity, or worst case temperature at two lower relative humidities with extrapolation to worst case relative humidity, when computing service life per QC test conditions listed in (b) below.

(Reference Q471.6, 471.8) i l

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(b) Provide a commitment to establish a 1% AQL for test conditions of 25' ppm challenge concentration of CH 1; worst case relative 3

humidity (or via extrapolation); 30*C; 45 L/m cyclic flow (or 64 L/m steady state flow), (as established in Q471.14), 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.25 ppm penetration.

(Reference (Q471.8)

Response

(a) MSA has conducted qualification tests at 110*F and two relative humidities (60% and 90%). The extrapolation to 100% relative humidity indicates satisfactory performance for the intended use conditions with a wide margin of conservatism. The data for these tests, which was presented at the April 25, 1984 meeting between the NRC, MSA and Alabama Power Company, is included in the April 13, 1984 MSA letter and supplemented by MSA letter dated April 26, 1984, both of which are attached.

(b) MSA has demonstrated that lot-to-lot acceptability is proven by selecting lot sample sizes and conducting QC testing in accordance with MIL-STD 414. The QC test parameters (included in the attached MSA letter) are sumarized below:

Methodology MIL-STD 414, Level II AQL 1%

Challenge 5-10 ppm Temperature 110*F Humidity 90%

Flow rate 64 Lpm Cyclic Service Life Endpoint 1% Breakthrough

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Note.that the original exemption request specificed that th"e canister would not be used in environments with greater than 90%

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relative humidity. However, the testing conducted by MSA has

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indicated that humidity is not the limiting factor and that the f

i GMR-I canister performs satisfactorily with 100% relative i

humidity. The intended use limitations are restated below as revised to remove the humidity limitation:

i 1.

protection factor = 50 f

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 which the canister f

would be discarded I

3.

not to be used in the presence of organic solvent vapors

4..to be stored in sealed, humidity barrier packaging in a cool, dry environment.

i 5.

. service life to be calc'ulated from the time of unsealing l

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including periods of non-exposure 1

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to be used with a facepiece capable of providing protection I

factors greater than 100 7.

not to be used in challenge concentrations of total organic l

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' iodine', includino nonradiometric iodine greater than 1 ppm 8.

not to be used in environments greater than 110*F

.L-The conditions and limitations' discussed herein will be f

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applicable'when using.the GMR-I canister and taking credit for a I

protection factor.- In instances when credit is not taken for a i

i protection factor, use of the canister will be governed by Farley Nuclear Plant's current respiratory protection program.

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A Mine Safety Appliances Company 600 Penn Center Boulevard Pittsburgh, Pennsylvania 15235 412/273-5000 Wnter's Direct Dial Number 412-273-5140 Mr. Wayne Carr Health Physics Alabama Power Company 600 North 18th St.

P. O. Box 2641 Birmingham, AL 35291

Dear Mr. Carr:

In accordance with our agreement, the following report is submitted for your approval.

1.

General It was agreed with Alabama Power Company on March 8,1984, that MSA would test GMR-I cans to compiegion in order to be able to statistic-ally project performance at 110 F and 100% RH.

In addition, other tests had been run prior to the March 8th agreement and the data are shown in Table I.

The tests were conducted under the following con-ditions:

Challenge Conc.: 5 - 10 ppm CH I Humidity: 60 + 3% and 90 + 3% 3(minimum of six cans at eacfi hgmidity) -

Temperature:

110 F Cyclic Flow:

192 LPM for 0.82 sec.; 0 LPM for 1.64 sec.,

repeating this cycle throughout the test.

This gives a minute volume of 64 L.

Breakthrough Conc.:

1% of the challenge concentration 2.

Test Results During this program, 48 GMR-I cans have been tested (47 valid tests).

These cans came from six production lots made over the period April 14, 1983, to February 2. 1984. Sixteen cans were tested from lot April 14, 1983, 10 at 90% RH and 6 at 60% RH. Only eight results at 90% RH were used in the statistical analysis given below, as one test was invalid (No. 47) and another was stopped before completion. Only a few cans were available from the other lots, so they could not be statistically analyzed; however, all cans run to completion had a service time of

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Mr. Wayne Carr Page Two April 13, 1984 20 hours2.314815e-4 days <br />0.00556 hours <br />3.306878e-5 weeks <br />7.61e-6 months <br />.or greater. The results are shown in Table 1.

The original 14 cans not run to completion had service times well in excess of 12 hours1.388889e-4 days <br />0.00333 hours <br />1.984127e-5 weeks <br />4.566e-6 months <br /> - much in excess of the eight hours desired.

3.

Statistical Analysis of Lot 4/14/83. Table 2 shows the data used and the statistical analysis to give the 99% prediction interval for individual values of Log Y (log service time), when X (relative humidity) is 100%. The lower limit of this interval is calculated to be 15.8 hours9.259259e-5 days <br />0.00222 hours <br />1.322751e-5 weeks <br />3.044e-6 months <br />. This predicts that over 99% of the individual GMR-I can service times would be greater than 15.8 hours9.259259e-5 days <br />0.00222 hours <br />1.322751e-5 weeks <br />3.044e-6 months <br /> at 100% RH and the other test parameters used in this program. This givas a considerable safety margin over the eight hours desired.

One other interesting point to note from the data in Table 2, as well as all of the test data on the GMR-I cans, is that humidity has little or no effect on the service time over the humidity range studied, 60 to 90%. This would indicate that results at 100% RH would be very close to those at 90% on a log service time--log RH plot, unless the slope were extremely steep--which is not the case.

4.

Proposed Acceptance Plan. The extremely long service times experienced in this program for the GMR-I cans run to completion, an average of over 29 hours3.356481e-4 days <br />0.00806 hours <br />4.794974e-5 weeks <br />1.10345e-5 months <br />, makes testing to completion for routine lot acceptance impractical; therefore, the following plan is proposed.

4.1 Interim Plan. On an interim basis, until more data can be gathered as explained in section 4.2, the proposed lot acceotance would be as follows:

4.1.1 MIL-STD 414. Level II, AQL 1% would be used to (1) select and (2)per number of cans to test, depending on lot size, the pro to interpret the results regarding lot acceptance or failure.

4.1.2 The cans would be tested under the conditions of section 1; however, all tests would be conducted at 90% RH. Tests would be stopped at eight hours and the percent leakage recorded at this time.

From evidence presented in the preceding sections, results at 90% are not significant1v different from those at 100%.

r 4.1.3 The percent leakage values would be compared to the spec.

limit of 1.0%, using the single spec. limit, variables unknown, standard deviation method of MIL-STD 414.

Acceptance would be based on this analysis.

4.2 Future. Because the tests in section 4.1 are very time consuming and somewhat difficult to run for regular quality assurance lot acceptance testing, we plan to do further testing on the GMR-I can in an attempt to reduce the time required for testing and also to simplify the test.

Parameters that will be investigated are:

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Mr. Wayne Carr Page Three April 13, 1984 4.2.1 Increasing the challenge concentration of CH,I in an effort to reduce the time to test. Under current conditions, a test to completion might run 40 hours4.62963e-4 days <br />0.0111 hours <br />6.613757e-5 weeks <br />1.522e-5 months <br />; we would like to reduce this to about two hours.

If there were a simple, straight-line relationship between service time to a 1%

breakthrough and challenge concentration, it would indi-cate that a challenge concentration of approximately 200 ppm would be required to do.this. We wish to firmly establish the service time---challenge concentration re-lationship over a range of challenge concentrations from 1 ppm to 500 ppm.

4.2.2 Constant Flow vs. Cyclic Flow.

Constant flow tests are much simpler to conduct than cyclic flow tests. From some preliminary information, it appears that constant flow gives similar service times as cyclic flow.

If, by further tests, this can be verified, constant flow would be used in lot acceptance tests.

4.2.3 Temperature and Humidity Effects. Further tests will be run to study the effects of temperature and humidity on the performance of the GMR-I can.

It would be preferable o

to test cans for lot acceptance at 25 C and 85% RH (standard NIOSH conditions), if it can be proven that these conditions are as severe as 43 C and 90% RH, or if a good correlation between these two conditions can be established.

5.

Conclusion.

5.1 Forty-seven GMR-I cans have been validly tested under the conditions specified in section 1.

All of these cans had service times well in excess of 12 hours1.388889e-4 days <br />0.00333 hours <br />1.984127e-5 weeks <br />4.566e-6 months <br />. This compares to a desired service time of eight hours.

5.2 Therewere14validtestsrunonlot4/f4/83. Statistical analysis of this data, projected to 100% RH,110 F, indicate that over 99%

of the GMR-I cans in this lot have service times well over eight hours (15.8 hours9.259259e-5 days <br />0.00222 hours <br />1.322751e-5 weeks <br />3.044e-6 months <br />).

Incidentally, from the data of Table 1, this lot appears to have the shortest average service time of the lots tested.

5.3 In light of sections 5.1 and 5.2, the GMR-I can should be considered qualified to give service times over eight hours under the con-ditions:

1%gbreakghrough,cyclicflow(peak 192 LPM, average 64 LFM), 110 F (43 C) and 100% RH.

Mr. Wayne Carr Page Four April 13,1984 5.4 Lot Acceptance will be determined by using MIL-STD-414, Level II, AQL 1%. The percent leakage at eight hours service time will be compared to the spec. limit of 1.0%, using the single spec. limit, variables unknown, standard deviation method.of MIL-STD-414.

5.5 Further tests will be run studying the effects of challenge concentration, constant flow rate, temperature and humidity on the service time of GMR-1 cans. This program is intended to shorten the required test time and simplify the test procedure.

5.6 From data in this investigation, it appears that relative humidity between 60 to 90% has little effect on service time of the GMR-1 canister. Projecting the service time to 100% RH, using a log-log plot, suggests that the service times at 90% and 100% RH are not significantly different.

If you have any further questions, please do not hesitate to contact me Very truly yours, dd WaydeT./.

. Miller, Jr.

Director of Product & Sales Planning

/jw Attachments / Tables I and 2 cc: Mr. E. J. Beck Dr. W. P. King Dr. E. S. McKee Mr. J. C. Sheehan Mr. J. H. Wylie

Table 1.

Service Time of GMR-I Canisters Test Conditions: As given.in section 1 60% RH-Can #-

Mfg. Date Service Time' Comment Can #

Mfg..Date Service Time.

Comment min.

hrs.

min.-

hrs.

Leak 9 12 hrs. l['

5 11/30/83

>>720

>>12 0.25-34.

4/14/83 1410 23.5 6

0.07' yg 35 2/2/84 1680~

28.0 7

0.33 g eb 36 4/14/83 1530

-25.5 29 2/2/84 2160 36.0.

37

~1410 23.5 30 2520 42.0 38 1/9/84.

1890 31.5 31 2670 44.5 39-4/14/83 1080

.18.0 32 4/14/83 1200

.20.0 40 1/9/84 2220 37.0 33 1500 25.0 90% RH Leakage 3

11/30/83

>>1215 >>20.3 0.30

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23 10/21/83 2490 41.5 4

>>1215 >>20.3 0.15 24-2910 48.5 8

10/21/83

>> 990 >>16.5 0.45 25 2490 41.5 9

0.25 lE 26 2/2/84 1560 26.0 0.43 E

27-2070 34.5 10 Leak 9 12 hrs.3 11 11/30/83

>>720-

>>12 0.67' 28 2220 37.0 12 10/21/83 0.04L tl 41 4/16/83 1230 20.5 13 11/30/83 0.47 sf 42 1320 22.0 14 1/9/84

>>795 >>13.3 0.64 43 1650 27.5-15 0.34 44 1320-

.22.0 16 0.35-45 1500 25.0 17 1/9/84 1890 31.5 Const. Flow.

46 1260 21.0 18 3180 53.0 47 Test Invalid 19 2530 42.2 48.

1350 22.5 20 9/13/83 2390 39.8 49 1290 21.5 21 1530* 25.5*

• Test Stopped 50 840*

14.0*

Test Stopped 22 2280* 38.0*

.No Breakthrough No Breakthrough

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Table 2.

Statistical Analysis of Lot 4/14/83 X (% RH)

Y (Svc. Time)

Log X Log Y 60 1200 min.

1.77815 3.07918 Ave. Y60 = 1355 min. (22.6 hrs.)

60 1500 3.17609-60 1410.

3.14922 Ave. Y 1365 min. (22.7 hrs.)

=

90 60 1530 3.18469 60 1410 3.14922 60 1080 3.03342 90 1650 1.95424 3.21748 90 1230 3.08991 90 1320 3.12057 90 1500 3.17609 90 1260 3.18037 90 1350 3.13033 90 1290 3.11059 4

'90 1320 3.12057 99% Prediction Interval for Log Y, givenlog X = 2 (100%'RH) 99%' Interval = h+t [IS9/23 -2 bh n

A Where Y = bo + b X and bo = 3.08231, by = 0.02606 i

= 3.13443 (1362 min., 22.7 hrs.)

Sp=gE [1+1/n+(x-R)2,7 =. 05543 S

EX2 99% Interval = 3.13443 + (3.055)-(.05543) = 3.13443 +.16934

= 3.30377 to 2.96509 Y = 33.5 hrs to 15.4 hrs.

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Mine Safety Appliances Company. 800 Penn Center Boulevard Pittsburgh Pennsyfvania 15235 412/273-5000 Writer's Grect Det Number April 26, 1984 412-273-5140 I

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Mr. Wayne Carr Health Physics Alabama Power Company j

600 North 18th St.

P. O. Box 2641 Birmingham,AL 35291

Dear Mr. Carr:

GMR-I CANS-SERVICE TIME ~- TABLE 1 STATISTICAL ANALYSIS OF LOT 4/14/84 - TABLE 2 i

We are sending you the latest revision of Table 1 and Table 2 pertaining to the subject and our letter to you of April 13. 1984.

t Very ly yours.

A. - - &k, Y

l Wayd

. Miller, Jr.

I Director of Product & Sales Planning i

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Table 1.

Service Time of 98t-I Canisters Test Conditions: As given in section 1 605 M Can 4 Mfg. Date Service Time Comunent Can #

Mfg. Date Service Time Comuneet j

min.

hrs.

min, hrs.

i Leak 912 hrs.

5 11/30/83 n720 n12 0.25 34 4/14/83 1410 23.5 i

6 0.07 g

35 2/2/84 1680 28.0 7

0.33 g

36 4/14/83 1530 25.5 l

E 29 2/2/84 2160 36.0 37 1410 23.5 30 2520 42.0 38 1/9/84 1890 31.5 I

31 2670 44.5 39 4/14/83 1080 18.0 32 4/14/83 1200 20.0 40 1/9/84 2220 37.0 33 1500 25.0 j

i 90% M N

Leakap E

3 11/30/83 n1215 n20.3 0.30 A

23 10/21/83 2490 41.5 y

4 n1215 n20.3 0.15 24 2910 48.5 C

8 10/21/83 a 990 n16.5 0.45 25 2490 41.5 9

0.25

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26 2/2/84 1560 26.0 j

'27 2070 34.5 P

10 0.43 g

Leak 9 12 hrs.e

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11 11/30/83 a 720 n12 0.67*

28 2220 37.0 12 10/21/83 0.04 41 4/14/83 1230 20.5 i

13 11/30/83 0.47 4

42 1320 22.0

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14 1/9/84 n795 n13.3 0.64 43 1650 27.5 15 0.34 44 1320 22.0 45 1500 25.0 y

16 0.35 17 1/9/84 1890 31.5 Const. Flow 46 1260 21.0 Test Invalid I

18 3180 53.0 47 19 2530 42.2 48 1350 22.5 20 9/13/83 2390 39.8 49 1290 21.5 i

21 1530* 25.5*

• Test Stopped 50 B40*

14.D*

Test Stopped 22 2280* 38.0*

No Breakthrough No Breakthrough l

4/26/84

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Tabla 2.

4 Statistical Analysis of Lot 4/14/83

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X (5 RH)

Y (Sve. Time)

Los X Los Y g

60 1200 min.

1.77815 3.07918 Ave. Y60 = 1355 min. (22.6 hrs.)

i 60 1500 3.17609 i

60 1410 3.14922 Ave. Y90 = 1365 min. (22.7 hrs.)

a 60 1530 3.18460 60 1410 3.14922 F

60 1000 3.03342 i

90 1650 1.95424 3.21748 i

l 90 1230 3.08991

,1 90 1320 3.12057 90 1500 3.17609 90 1260 3.18037 90 1350 3.13033 i

90 ~

1290 3.11059 90 1320 3.12057 995 Prediction Interval for Log Y. given Lo9 X = 2 (1005 RH) 995 Interval = $+t [1.99/h Ik e2 A

h Y = bo + b X and bo = 3.08231, by = 0.02606 j

= 3.13443 (1362 min. 22.7 hrs.)

5(=[S (1+1/n+{X-X)2]=.05543 S

" "II-I E

E g 2 n-2 g

x = X-1 995 Interval = 3.13443 i (3.055)

(.05543) = 3.13443 +.16934

= 3.30377 to 2.96509 Y = 33.5 hrs. to 15.4 hrs.

Revision 4/2C/84 i