ML20098D996

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Documents Util Intention to Apply Interpretation Re Periodic Requirement for Physical Exams for Users of Respiratory Equipment,Per 10CFR20.103(c)(2).Respirator Physicals Will Be Scheduled W/Licensed Operator Exams,Per 10CFR55.21
ML20098D996
Person / Time
Site: Crane Constellation icon.png
Issue date: 05/28/1992
From: Broughton T
GENERAL PUBLIC UTILITIES CORP.
To:
NRC OFFICE OF INFORMATION RESOURCES MANAGEMENT (IRM)
References
C311-92-2073, NUDOCS 9206010169
Download: ML20098D996 (2)


Text

._

i 3. '0 Nuclear

=,o==pcration GPU Nuclear Cor eo Middletown, Pennsylvania 17057-0191 717 944 7621 TELEX B4 2386 Wnter's Direct Dial Number-(717) 948-8005 May 28, 1992 C311-92-2073 U.S. Nuclear Regulatory Conmissior Attn: Document Control Desk Washington, DC 20555

Dear Sir:

Subject:

Three Mile :sland Nuclear Station, Unit 1 (TMI-1)

Operating License No. DPR-50 Docket No. 50-289 l

Physical Examinations for Users of Respiratory Protective Equipment 10 CFR 20.103(c)(2)

The purpose of this letter is to document 6PU Nuclear's intent to apply an interpretation relative to the periodic requirement for the subject physicals.

This position was receatly released by the NRC in a compilation of Health Physics Position Papers; we understand this document is soon to be issued as a NUREG.

GPU Nuclear was made aware of the availability o# the Health Physics Position Papers in a letter from the NRC dated February 27, 1992.

10 CFR 20.103(c)(2) specifies a 12 month time interval for physical examinations to assure that an individual is pnp (cally able t-)

protective equipment in an environment containing airborne radioactiveuse respiratory material.

GPU Nuclear is aware that the NRC has previously interpreted this regulation which states "at least every 12 months" to ma n "every 9 to 15 months; provided that the total time over any three con wcutive physical examination periods does not exceed 39 months "

in a letter to Pennsylvania Powcr and light Company's Susqu hThis NRC position was state o.

pg@a.

g g Electric Station, dated May e anna Steam 30, 1989.

The NRC stated that an exemption was not needed to implement this interpretation, but offered to process a request if submitted by the licensee.

oo 00 h5 It is our understanding, based on discussion with TMI-l NRC Project Manager, R. W. (!ernan, that the NRC no longer intetids to process exemption requests

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relative to this issue, Therefore, we are advising the NRC of our intent to apply the NRC interpretation which allows flexibility in scheduling respirator physicals.

The 1213 month periodicity for respirator physicals will allow In$

GPU Nuclear the administrative flexibility to schedule these examinations-so M(tf(jGQp individual need be administered two physicals during the same calendar

- a-GPU Nuclear Corporation is a subs of General Pubhc UtMes Corporation p8/

a

Docum'ent Control Desk

  • C311-92-2073 Page 2 year and allow us to coordinate the scheduling of respirator physicals wits the licensed operator physical examinations required by 10 CFR 55.21.

Sincerely, b0 T. G. Brou ton Vice President and Director, THI-1 MRK cc:

Region I Administrator TMI-1 Senior Project Manager THI Senior Resident In pector l

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