ML20126G458

Applying for Respirator Exemption Signed

ML20126G458
Person / Time
Site:	University of Missouri-Columbia
Issue date:	05/04/2020
From:	Doenges D, Robertson J Univ of Missouri
To:	Document Control Desk, Office of Nuclear Reactor Regulation
References
Download: ML20126G458 (10)

Text

May 04, 2020 U.S. Nuclear Regulatory ComlDission Attentipii: Document Control Desk Washington, DC 2055~-0001

REFERENCE:

Docket No. 50-186 University ofMis_sotiri-Columbia Research Reactor Renewed Facility License Operating Licen.se No. R-103

SUBJECT, Written communication as specified by IO C.F.R. 50.4(b)(l) requesting U.S. Nuclear Regulatory Commission approval for exeinption from l O CFR 20.1703( c)(6.).

l.

Introduction The University of Missouri Research Reactor (MURR) is requesting an exemption from 10 CFR 20.I 703(c)(6) per instructions outlined in a letter' dated April 27111, 2020 from Ho K. Nieh and :John W.

Lubinski. MURR implements a respiratory protection program through MURR Policy POL-252, pursuant to 10 CFR 20.1703, for plannt!d maintenance work on the MURR Iodine-131 production facility. As part of MURR's mission to supply the United States with lodine-131, MURR has routine and scheduled maintenance periods for the lodine,.131 facility during 2020. These maintenance periods will require the use of the M1'..JAA rei;piratocy prot_ection program and the requirements defined in IO CFR 20; l 703(c )( 6).

2.

Fit.,testing requirements.of 10 CFR i0.1703(c)(6)

MURR corttra~ts out fit-testing pursuant to 10 CFR 20.l 703(c )( 6) through the University of Missouri Environmental Health and Safety (EHS) office.The University is following practic_es recommended by the Ce1iters for Disease Control and Prevention (CDC) to limit the spread ofCOVID-19, and therefore will.riot be offering fit-testing until further notice. For this reason, MURR is requesti11g an exemption from the requirements to JO CFR 20.1703(c){6).

3.

Managing*personnel during the exemption period MURR personnel included in the exemption request include only individuals that have had _a fit-test within the last 12 months with the models of respirat9r~ implemented at MURR. New employees will not be included in the exemption request because there is no history of quantitfltive data suggesting the seal to their face is ac;c:eptable for respirator issuance. The ten (10) MURR employees who are e,tempted per Section 4 of this letter will be monitored, in accordance with MURR POL-25 section 8.42, for changes that 1 of 3

may inadvertently. affe¢t the seal of a respirator. If such cond_itions ~xist -ciUDhg the exeriiptjon period, th9se

• individuals will not be iss4ed a respirator "9ntil sµch aJime a new fit-test c~n be performed, All indivi<lual~

ih the MURR respirat9ry. prote9tion program have alr~dy received medical evaluatio11s per 1 Q CfR 20.1703(c)(5), and therefore tl,1eir contjntied use of a respirator during the exempticm period h11s bee.n approved by a medical professional. -As paq of the hnplementation of the MlJRR respiratory protection progrilm, users perform negative pressure seal checks prior to commencing v.;01:k If an jndivid~l can not pass a n_egative pressure check; they ?re not permitted to commence work with the respirator.

4.

Persotmei requested for exemption Personne.l requested for exemption include ten "(1 O) individuals. The number of individuals and th_eir associated titles are:

H¢altli Physicist, one individual Health Physics Supervisor; one individual J-Ieahh Physic~. Technician, :(oµr indiyiduaJs Hot Cell Manager, one individual Hot Cell Technician, three individuals

5.

Requested exemption period MURR is requ~sting exemption from the requirements of 10 CFR 20.l 703(c)(6) forthe period outlined in a letter1 9ate9 April 27th, 2020 from Ho K. Nieh and John W. Lubinski. The letter states:

"Exe111ptioi1~ tl,at are (!pproved tmder this process would be i11 effect 1111til 9Q days after the e11d of the PHE, oi* 1~11,U Dece!i,her 31, 2()20, whichever is soo11er. Lic,msl!es 11111stco111e back i11to complia11ce with the reg1ilatio11sor receiiie approval/or a,, additio11iil exemptio11 period from the NRC before-the e11d of e.ach exe111ptiQ1i period."

If the PHE exists past the exemption -date or Df;celllb~r 31, 2020 and MURR requires further exemption; a new application for an additional exemption from the applicable NRC requirements wiH be created_.

All MURR staff listed in section 4 above have currently.received tit testing that is valid through August 1 si 2020. The exemption* would be.necessary for the period August 1 si 2020 tltrough December 3 Pt, 2020, at the latest.

6.

Summary In summ~ry, MURR implements a respiratory protection program for scheduled maintenance of the MURR Iodine-131 production facility. Through the*use of MURR POL-252, annual fit-testing is completed through the University of Missouri EHS department. Due to CDC guidelines, EHS will not be administering fit-testing tliltil allowed to do so via University Administration's return to work policy in compliancewith the

. CDC recomi11eJ).dat!on$. In order to fulfil the MURR mission of providing the United States Iodine-I 31, 2 of3

I.

routine maintenance mcorporating the use ofrespirators is required. MURR is.requesting exemption to Hi CfR 20.1703(6)(6) fodndividuals 1n tjie MURR respiratory program that have baa a quantitative fit te:;st within' the pa!rt* *12 months but whose fit test expiration date may be: impacted by the unavailability of fit

• testing servicesJltovided.by tlie University-due to the COVIIJ-19 pahdelll.ic~ Tl1ese i~dividuals have already been cleared by a ineciical professio~al per 20.J 703( c )(5);.and will continue.to be monitoredforanyphysical changes that may' affect the seal ofthein;~pirator*tO their face. As part'ofthe MORR:respirator program,

jndividuals must pass a negative pressure' seal te!st prior to cqmmencing wqrk, ;o.,ihich will.c::ontinue to confirm they h?ve. a~ effective seal durh1g the exemption period: For*the t~ihdivi<iuals listed in s~ction 4, M~ ~s.r~qu~sting exemptio_nfortbe period defi~ed in a lett¢r1 datedApril 27111, ~020 fro~ J-Io J<.. Nieh and}qhn \\V.Jubin!:.ki, and will re-apply for any additional exempt1on p~fiod~ :after the defined duration periocument requesti(lg. ()f r~quiring the collection displays a currently valid Office of Management_ and Budget cpntrol number.

Sincerely, Ho K.

Nieh

Digitally. signed by Y Ho K. Nieh

, Da~: 2020:04.27 10:13:48 °04'00' Ho K. Nieh, Director Office of Nuclear Reactor Regulation Sincerely, JO h n W f:- Digitally signed by

• J\\John W. Lubinski Lub' 1'n* s*'kt_J)at~:2020.04.27

'/

09:55:51 -04'00' John W. Lubinski, Director Office of Nuclear Material Safety and Safegua-rds

SUBJECT:

U.S. NUCLEAR REGULATORY COMMISSION PLANNED ACTIONS RELATED Td THE RESPIRATORY PROTECTION REQUIREMENTS FOR ALL LICENSEES DURING THE CORONAVIRUS DISEASE 2019 PUBLIC HEALTH EMERGENCY DATED APRIL 27, 2020 Identical letters sent to:

Dr. Jennifer L. Uhle Vice President, Generation & Suppliers Nuclear Energy Institute 1201 F Street, NW, Suite 1100 Washington, DC 20004 Mr. Chris Bakken Executive Vice President Nuclear Operations & Chief Nuclear Officer Entergy Nuclear 1340 Echelon Parkway Jackson, M.S 39213 Mr. Don Moul*

Executive Vice President, Nuclear Division and Chief Nuclear Officer Florida Power & Light Company Mail Stop: NT3/JW 15430 Endeavor Drive Jupiter, FL 33478 Mr. Clive Townsend Chair, National Organization of Test, Research, and Training Reactors 1611 Lionheart Ln West Lafayette, IN 47906

ML20099G7S7 RidsOpaMail Resource BHolian, NSIR

[;)Lew, RI LDudes; RII DRoberts, RIii SMorris, RIV GBowman, NRR/DRA RFelts; NRR/DRO GSuber, NRR/DORL MShams NRR/DORL MO;Banion, NRR/DORL DGarmon, NRR/DRA KHsueh, NRR/DRA OFFICE NSIR/DRA/ARCB*

NSIR/DRA/ARCB/BC* NRR/DORUD*

NAME DGarmon KHsueh CErlanger DATE 4/16/2020 4/16/2020 4/16/2020 OFFICE NRR/DRA/D*

OE/D*

OGC - NLO*

• via email NRR/DRO/DD(A)*

MYoung 4/16/2020 NMS$/D*

NAME MFranovich GWilson TCampbell Jlubinski DATE 4/16/2020 4/16/2020 4/20/2020 4/27/2020 OFFiCE NRR/D*

NAME HNieh OATE 4/27/2020

7.0 AIR SAMPLING AND BIOASSAY POL-25 Revisi.on 5 7.1 Air sampling <la.ta will be monitored prior to each entry into a potentially contaminated area where respiratory protection is intended to be used, and will be conducted in accordance with established MURR procedures.

7.2 Bioassay will be obtained after each use of a respirator in a potentially contaminated area and will be completed in accordance with MURR procedures.

8.0 RESPIRATOR FIT TEST 8.1 A Qualified Fit Testing Facility will conduct initial a!_ld subsequent fit tests in

. accordance with MURR procedures.

8.2 Each individual shall be fit tested with the applicable make, model and size of respirator before receiving a respirator for use during nom1al operations.

8.3 Fit testing will be conducted on an annual basis per OP-HP-233, "Respirator Fit Test" (Reference 15. 7).

8.4 Retesting will be performed when an individual has a weight change of+/- I 0% or more; significant facial injury or scarring in area of facial seal; significant dental changes; reconstructive or cosmetic facial surgery in area of facial seal; or any other condition that might affect the seal of the respirator.

9.0 MEDICAL EVALUATIONS 9.1

• Physical exams will be perforn1ed on an ann.ual basis. The physical exam shall be repeated if the individual reports signs and/or symptoms related to the ability to use a respirator, such as shortness of breath, dizziness, chest pains, or wheezing; the physician informs the Health Physics Manager that the individual requires re-evaluation; information from this*program, including observations made during fit test and program evaluation, indicates a need for rc-evaluatioi1; or a change occurs in the workplace that may result in an increased physical burden on the individual.

9.2 Individuals required to wear a respirator must pass a physical exam before being permitted to wear a respirator. Any individual failing or refusing a physical exam will not be allowed or permitted to wear a respirator. Individuals must complete the Respirator Review and Medical Clearance Form (Reference 15.11 ), and the OSHA Respirator Medical Evaluation Questionnaire (Reference 15.12) prior to their physical exam.

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