Text

Discusses Possible Use of Natl Draeger BG-174AP Respirator by Util.Due to Lack of Approval Schedule,Device Not Yet Recommended by Niosh.Respirator Test Data Encl for NRC Review,Per L Hendricks Suggestion
	ML20117F564
Person / Time
Site:	Beaver Valley
Issue date:	05/02/1985
From:	Sieber J; DUQUESNE LIGHT CO.
To:	Liza Cunningham; NRC OFFICE OF INSPECTION & ENFORCEMENT (IE)
References
	ND1MNS:4218, NUDOCS 8505130282
	Download: ML20117F564 (15)
	v • d • e

b de

'Af Telephone (412) 393-6000 U."o*.'*Bo?I ",'

Shippingport PA15077-0004 May 2, 1985 ND1MNS:4218 1

Mr. LeMoine J. Cunningham, Chief Section 2 Operating Reactor Programs Branch Division of Inspection Programs Office of Inspection and Enforcement Washington, DC 20555

Reference:

Beaver Valley Power Station, Unit No.1 Docket No. 50-334, License No. DPR-66 National Draeger Respirator Test Data Gentlemen:

Beaver Valley Power Station is considering the use of the National Draeger BG-174AP respirator.

At this time, NIOSH cannot determine whether any closed circuit breathing apparatus could be approved or recommended as a positive pressure device, due to the lack of an approval schedule.

However, NIOSH previously determined that the BioPak 30P and 60P respirators man-ufactured by BioMarine Industries (now Rexnord) are regarded as positive pressure devices (letter from J. A.

Oppold, Director, Division of Safety Research,6/18/79).

In light of this, Ms. L. Hendricks, Office of Inspection and Enforcement, suggested that the National Draeger test data be submitted for NRC evaluation as to whether the BG-714AP may be considered a positive pressure device. The pertinent test data is attached for your review.

NIOSH is currently considering establishment of a new approval category and test criteria for positive pressure closed circuit breathing apparatus.

Should the NRC determine that the BG-174AP may be considered a positive pressure device, and Beaver Valley incorporates it into the respiratory program, what would be the consequences should the respirator later fail the NIOSH test criteria?

Your consideration in these matters is requested.

Very truly yours, A

. D. Sieber 850 Senior Manager pDR khgg Nuclear Group PDR

/" 9 Attachment i\\

r

~ '

' Beaver Valley Power Staticn, Unit No.1 Docket No. 50-334, Lic:nst No. DPR-66 National Draeger Respirator Test Data Page 2 cc: Mr. W. M. Troskoski, Resident Inspector U. S. Nuclear Regulatory Comission Beaver Valley Power Station Shippingport, PA 15077 U. S. Nuclear Regulatory Comission c/o Document Management Branch Washington, DC 20555 U. S. Nuclear Regulatory Comission Attn: Dr. Thomas E. Murley, Regional Administrator Region 1 631 Park Avenue King of Prussia, PA 19406 Director, Safety Evaluation & Control Virginia Electric & Power Company P.O. Box 26666 One James River Plaza Richmond, VA 23261 Ms. L. Hendricks U. S. Nuclear Regulatory Comission Office of Inspection and Enforcement Washington, DC 20555-

.e

~

&, };..,

wM$t" ~

h RTMEN9'OFNEII'TH IHUM AN SERVICES Public HIalth Service gW

.r Out

Reference:

TN 01801 Centers for Disease Control E

National Institute for Occupational Safety and Health - ALOSH

, _md.. f;' ~

N 944 Chestnut Ridge Road i

Morgantown, WV 26505-2888 October 29, 1984 Mr. Les Board National Draeger, Inc.

101 Technology Drive P. O. Box 120 Pittsburgh, Pennsylvania 15230

Dear Mr. Boord:

This reply is with reference to your resubmittal letter of August 10, 1984, requesting approval of the BG-174AP (P/N R32200) self-contained breathing apparatus.

Approval TC-13F-176 is granted to cover the 2-hour closed-circuit, compressed oxygen, entry and escape, self-contained breathing apparatus, for respiratory protection during entry into and escape from oxygen deficient atmospheres, gases, and vapors at temperatures above 14 F.

Approved only when the compressed oxygen container is fully charged with oxygen meeting the minimum purity requirements for medical or breathing oxygen set forth in the U.S.

Pharmacopoeia. The container shall meet applicable DOT specifications.

In making renewals or repairs, parts identical with those furnished by the manufacturer under the pertinent approval shall be maintained.

The approved assembly consists of the following Dragerwerk parts: M174A Mask &

Hoses; BG174 AP Harness and Frame Assembly; C174 A-4 Cylinder and Valve; and, 9 x 18-28 CO2 canister. These parts are to be marked with the indicated nurr,bers in a legible and permanent manner (marking cannot be removed without evidence of its previous presence).

The enclosed approval label designs are to be used in preparing the approval labels. Label TC-13F-176 shall be prepared for use on the harness assembly.

Canister label TC-13F-176 shall be prepared for use on the carbon dioxide canister scrubber assembly. Designs of your labels must be submitted to NIOSH for approval before printing, and proofs of the printed labels must be submitted to NIOSH for further approval before their final production.

Your quality control plans for the Model Number BG174AP self-contained breathing apparatus were reviewed by NIOSH. On the basis of that review, your quality control plans are accepted as a part of this approval.

Your drawing lists dated September 1984, apply to this approval.

J,.

Gr>

Page 2 - Letter to Mr. Les Board, TN 01801 This Certificate of Approval is not an endorsement of the respirator by the Mine Safety and Health Administration or the National Institute for Occupational Safety and Health, and such endorsement shall not be stated or implied in advertisements or other publicity. However, you may publicize the fact that the product has met the requirements of 30 CFR Part 11.

Any changes you wish to make to this respirator shall be submitted, and a modification of this approval shall be granted before any changes are made.

(

Reference:

Part 11, Section 11.35.)

Please submit samples of respirator packaging, bearing all required labels, instructions, and markings, for our approval, before adopting them. Please send us TC-13F-176 approved SCBA to be made a part of the record of this approval. We shall retain several other items as additional record material.

All other material will be discarded unless we are otherwise advised by you.

Sincerely yours, h

MM Kenneth P. Klouse, Supctvisor, Nancy J.(Balfingef, Chief Office of Quality Assurance Certification Branch Approval and Certification Center Division of Safety Research MSHA NIOSH Enclosures (3)

i

...v k ~. w

&......,.,..m.,..,, ~. -. m..,. i.

-- n,e.u_.,c...m y-uu

_ 22,5 _

..q.

gg,5

~ ~.

v.

. =

p.

n

~

PERMISSIEsLE TW6-HOUR SELF-CONTAINM COMPRESSED-OXYGEN BREf' \\G APFARATUS X idt., W u -

L r-gg. =2 nn

~-

9 sn 3.

D' Ci 7

C5 1 r:

p l

l

=

fbE__ _ -.

o MINE SAFETY AND h ALIH ADMINISTRATION NATIONAL INSTITUTE FOR OCCUPt"l0NAL SAFETY AND HEALTH APPROVAL NO 7C-13I-/N ISSUED TO Drdgerwerk AG c

LUbeck,. GERMANY L'MITATIONS Approved for respiratory protection during entry into and escape from oxygen deficient atmospheres, goses,

N

(

cnd vapors at temperatures above

+ 1/.* F.

Approved for use only when the cylinder is charged with compressed oxygen meeting U.S P. specifications Cylinder N

shott meet applicable DO T specification.

CAUTION N

Use with odequate skin protection when worn in vapors or gases o

that poison by skin absorption (for excmple.hydrocycnic-ocd ges) l In making renewats or repairs, parts identical with those furnished by the manufacturer under this approval i

shcit be maintcined. The respirator shcll be selected, fitted, used, and mcintained in accordance with Mine Safety to and Hecith Administration, Occupational Safety and Health y

Administration, and other applicable regulations.

l l

l MSH A-NIOSH Approval lssued to

/o[2.9[EY

(

Drdgerwerk AG l

LUbeck, GERMAN Y)

E-The cpproved cssembly consists of part numbers M174 A mask and hoses,8G174 AP harness and f rame essembly, C174 A-4 cylinder and volve and the 9x18-28 CO2 canister.

q

[

h sn

/

Antiqua -Mittelschrift 1.6

.,_.-_.__-..__,_.,.-....,_,,m__

m_ _. _. - _ _ _,. -.,. _. _ _, _. -

9' PERMISSIBLE l

.~

'u us a

w, ei Mate Safety and Health heatson furenal Inshfuf.

w om.at.no se e,as em MINE SAFETY AND HEALTH ADMINISTRATION NATIONAL INSTITUTE FOR OCCUPATIONAL SAFETY AND HEALTH APPROVAL NO. TC-ISSUED TO LIMITATIONS CAUTION MSHA - NIOSH Approval Issued to The opproved assembly consists of the following part numbers:

TN01801 Draegerwerk BG174AP - 2 Hour Closed Circuit SCBA October 24, 1984 I.

Background:

In a letter dated July 28, 1983, Draegerwerk AG Luebeck requested NIOSH approval for their BG 174AP. The unit was rated as a 4-hour, closed circuit, S CB A.

During testing (detailed in respirator test report TN 01801, December 6, 1983), the units passed all applicable bench testing. However, the units failed by exceeding the maximum temperature level during man test #1.

In a letter dated February 28, 1984, Draegerwerk resubmitted the same units, this time seeking a 2-hour approval.

During testing (detailed in respirator test report TN01801, May 15, 1984) the units passed the man testing but the alarms failed to activate.

In a letter dated August 10, 1984, Draegerwerk resubmitted the units for testing.

In this submittal the 02 Pressure was changed from 3135 psig to 1700 psig and the alarms set to activate between 20 and 25% of the cylinder pressure.

II.

Test Outline:

A.

Special Test - 11.63(c)

Requirement -

To insure the units would still meet the duration during man testing the 02 cylinder at the new pressure must have the same amount of 02 available as the greatest amount used during man testing.

~d Procedure -

The 02 cylinder is connected to a regulator and bled down from the old sylinder pressure (3135 psig) to the least amount of pressure recorded during man testing (1500 psig). This procedure is then repeated from the new cylinder pressure (1700 psig) down to O psig.

Results -

Pressure Range 1 psig Liters /02 3135 - 1500 235.91 1700 - 0 244.97 The units pass the requirement.

j

B.

Remaining Service Life Indicator - Section ll.82(F)

Requirement -

Each remaining service life indicator or warning device shall give an alarm when the remaining service life of the apparatus is reduced within a range of 20 to 25% of its rated service time or pressure.

Procedure -

To measure the pressure at which the alarm sounds, a calibrated gauge is connected in line between the air supply bottle and the regulator.

The unit is then bled down through the regulator by pass valve. When the alarm sounds, the pressure on the gauge is noted. This procedure is repeated six times.

The time at which the alarm sounds is noted during the rated service time test.

Results -

The pressure range for this unit is 340 psig to 425 psig.

Time (min)

Pressure (psig)

PASS FAIL

. Unit 1 350 X

350 X

Time (min)

Pressure (psig)

PASS FAIL Unit 2

.375 X

375

.X

.c 375 I

375 X

The units pass the requirement.

C.

Man Test 5 - 11.85-16 Due to the change in the cylinder pressure and based on the average 02 consumption of the test subjects during man test 5 (respirator test report TN01801, May 5, 1984).

The following calculations indicate the possible maximum service life of each unit.

2 Unit #1 Average 0 consumption = 467.50 psi 8/hr.

1700 psig = 3.64 hours7.407407e-4 days 0.0178 hours 1.058201e-4 weeks 2.4352e-5 months 2

Unit #2 Average 0 consumption = 180 psig/hr.

1700 psig = 9.44 hours5.092593e-4 days 0.0122 hours 7.275132e-5 weeks 1.6742e-5 months

III. Recommendations:

Due to the units meeting the minimum performance requirements of 30 CFR, Part 11, I' recommend this request be approved.

In support of my recommendations is the QC acceptance memo dated 10-1-84.

IV.

References:

December 6, 1983 - Respirator Test Report TN01801 May 15 - 1984 - Respirator Test Report TN01801 August 10, 1984 - Draeger Letter August 16, 1984 - CB Letter September 26, 1984 - Draeger Letter September 28, 1984 - Draeger Letter October 1, 1984 - QC Memo October 22, 1984 - Draeger Letter 1

1 I

l l

4 I

I l

i l

i

TN01801 Draegerwark BG 174 AP - 4 hour4.62963e-5 days 0.00111 hours 6.613757e-6 weeks 1.522e-6 months , closed circuit, SCBA Mike Commodore December 5, 1983 I.

Background:

In a letter dated July 28, 1983, Draegerwerk AG Luebeck requested NIOSH appr 4 for W htr BG 174 AP.

The unit in a four hour, closed circuit, SCBA.

II.

Test Outline:

A.

Breathing Resistance - 11.85-5 Inhalation Requirement -

(a) Resistance to inhalation airflow will be measured in the facepiece or mouthpiece while the apparatus is operated by a breathing machine as described in Section 11.85-3.

k/

(c) The inhalation resistance of closed circuit apparatus ahall not exceed the differe'nce between exhalation resistance [Section ll.85-6(e)) and 10 cm (4 inches) water-column height.

Section 11i85-6 Exhalation Resistance to exhalati~ n airflow will be measured in the f acepiece or (e) o mouthpiece of closed-circuit apparatus with a breathing machine as described in Section 11.85-3, and the exhalation resistance shall not exceed Simm (2 inches) water-column height.

Procedure -

A breath {ng machine with a 622 kg-m/ min. cam operating at 24 RPM with a 40L-min vol. is connected to an anthropometric head for cycling. A pressure tap in the head is connected to a transducer which in turn is connectei to a strip chart recorder for recording the pressure tracing for calculation and record purposes.

Results -

Inhala_ tion Exhalation Unit il 0"H O 1.66"H O 2

2 Unit #2

-0.10*H O 1.77"H O 2

2 The units pass the requirement.

B.

Gas Flow Test:

11. 85-9 (c)

Requirement -

)

All demand-flow devices shall provide at least 30 liters of 02 per minute when in the fully open position.

i

n,...

Page 2 - Draegerwerk Report, TN01801 Procedure -

The demand valve was tied down in the fe'.1 open position with the 0 2 supply tube connected to a calibrated dry test meter. Flow is averaged from full cylinder pressure to 100 psig.

Results -

Flow e-n w

JLPM)

Unit il 126.47 Unit #2 94.94 The units pass the requirement.

c.

Safety Relief Valve Operations:

11.83(i)

Require.sent -

The relief yalve shall operate automatically when the pressure in the breathin; circuit reaches one-half inch above the minimum pressure required to fill the bag.

Procedure -

A transducer is connected to the mouthpiece of the unit in order to obtain a pressure tracing. As pressure builds in the breathing ba,g, the recorder pen gradually moves until a state of full bag is reached. At this point the slope of pressure over time increases to a sharp linear line until the relief' valve opens.

Since from the relief valve opening pressure point back toward a state of full bag the line is linear, the difference between full bag and relief valve opening can be determined graphically.

Results -

Unit 61

(,j Bag Full Release Difference (inches of H90)

(_ inches of H90)

(inches of H90) 1.66 1.87 0.21 Unit #2 Bag Full Release Difference (inches of H90)

(inches of H90)

(inches of H90) 1.77 2,08 0.31 1

The units pass the requirement.

D.

Gas Tightness Test; minimum requirements.

Sec. 11.85-19 l

Requirement / Procedure -

(a) Each apparatus will be tested for tightness by persons wearing it in

. c_. '

,u.y.

fqg+

I l

~

Pega3-DrcohstwerkReport,TN01801 (b) Six persone sill each wear the apparatus in the test concentrations specified in paragraph (a) of this section for 2-minutes and none shall detect the odor or taste of the test vapor.

l Results =

1 None of the test subjects detected the odor or taste of the test vapor.

The. units pass the requi;ement.

...:v.

,16.

L' '-

auwa E.

11.85-4 Weight Requirement.

Requirement -

(a)

The completely assembled and fully charged apparatus shall not weigh more than 16 kg. (35.28 pounds); however, where the weight decreases by more than 25 percent of its initial charge weight during its rated service life, the maximum allowable weight of a completely assembles and fully charged apparatus shall be 18 kg. (40 pounds).

(_,

(b)

Where an apparatus employs equipment which contributes materially to the wearer's comfort, e.g., a cooling sys, tem, the completely assembled and fully charged apparatus shall not weigh more than 18 kg. (40 pounds) regardless of the decrease in weight during use.

Procedure -

The unit must be fully charged and ready for use before being weighed.

Results -

Unit 1 35 lbs.

Unit 2 3 5 lbs.

t i

The units pass the requirement.

F.

Man tests; testing conditions; general requirements - 11.85-14

(,,

General Requirements -

(a) The man tests described in Tables 1, 2, 3, and 4 represent the workload performed in the mining, mineral or allied industries by a person wearing the apparatus tested.

(b) The apparatus tested will be worn by Institute personnel trained in the use of self-contained breathing apparatus and the wearer will, before participating in these tests, pass a physical examination conducted by a qualified physician.

(c) All man tests will be conducted by the Institute.

. Laundes. L --

1

cr i

c... lf.

+,@

h-Page 4 - Draegerwerk Report, TN01801 (d) The apparatus will b'e examined before each man test to ensure that it j

is in proper working order.

(e) Breathing resistance will be measured within the facepiece or mouthpiece and the wearer's pulse and respiration rate will be recorded during each 1 minute sample period prescribed in tests 1, 2, 3, and 4.

(f) Man tests 1, 2, 3, and 4 will be conducted in duplicate.

. ~ = -

n.

(gi'If ma.;ttests are not completed through no fault of the apparatus, the test will be repeated.

Man tests 1, 2, 3, and 4 - 11.85-15 Requirements -

(a) Man tests 1, 2, 3, and 4 set forth in Tables 1, 2, 3, and 4 respectively, prescribe the duration and segaence of specific activities.

These tests will be conducted to:

C (1) Familiarise the weares with the apparatus during use; m..

(2) Provide for a gradual increase in activity; (3) Evaluate the apparatt s under different types of work i

and physical orientation; and (4) Provide information on the operating and breathing characteristics of the apparatus during actual use.

Man tests; performance - 11.85-18 Requirements -

(a) The*-apparatus shall satisfy the respiratory requirements of the wearer for the classified service time.

(b) Fogging of the eyepiece shall not obscure the wearer's vision, and the k=/

wearer shall not experience undue discomfort because of fit or other characteristics of the apparatus.

(c) When the ambient temperature during testing is 24 + 6 C.

(750+

0 0

10 F.), the maximum temperature of inspired air recorded during man tests shall not exceed the following, after correc, tion for deviation from 0

24 C.

(75 F.) :

i

'I

-E -

=

_..,,n

, ~, _ _,,,, _., _ _ _,

-,e, p,,

m.

\\

l Paga 5 - Drcsgarwark Report, TN01801 Where percent Maximum permissible htere service life of relative humidity temperature of inspired of apparatus is--

of inspired air shall not exceed--

air is-W 1/4 hour or less 0-100 135 57 1/2 hour to 3/4 hour 0-50 125 52 ui'*-

ch 50-100 1110 143 d~

m.

1 to 2 hours2.314815e-5 days 5.555556e-4 hours 3.306878e-6 weeks 7.61e-7 months 0-50 115 46 50-100 1105 141 3 hours3.472222e-5 days 8.333333e-4 hours 4.960317e-6 weeks 1.1415e-6 months 0-50 110 43 50-100 1100 138 4 hours4.62963e-5 days 0.00111 hours 6.613757e-6 weeks 1.522e-6 months 0-50 105 41 50-100 1 95 135 L

1Where percent relative humidity is 50-100 and apparatus is designed for escape only, tfiese maximum permissible temperatures will be increased by 50C.(100F.).

Procedure -

I Man testa 1-4 will be -un in duplicate.

Results -

Man Test No.1 Schedule Limit Unit i 1 Unit #2 0 >19.5%

55.20% to 93.87%

41.81% to 86.01%

2 CO2 0.5% max.

0.10% to 0.16%

0.06% to 0.14%

AT

<950F 0

0 0

0

80.3 P to 95.8 F 82.6 F to 96.0 F C

AP (in inches

-0.02 to + 0.93

-0.29 to +0.99 of H O) 2 Temperature values are corrected.

Because of the high temperatures Unit 1 failed at 238 minutes and the test on Unit 2 was stopped at 162 minutes.

Further testing was discontinued until the manufacturer can find a satisf actory cure for the problem.

The units fail the requirement.

- Na. u.i......

j

-N-$

1 14fJ e.

P293 6 - Drccg rwork Report, TN01801 III.

References:

July 28, 1983 - Draeger Letter July 25, 1983 - Draeger Letter October 28, 1983 - Q.C. Memo October 12, 1983 - Draeger Letter b

x

?

l

)

- _ = =..

r

ML20117F564

Contents

Text

Reference:

Reference:

Dear Mr. Boord:

Reference:

Background:

References:

Background:

References:

Navigation menu

ML20117F564

Text

Reference:

Reference:

Dear Mr. Boord:

Reference:

Background:

References:

Background:

References:

Navigation menu

Search