ML20128F344

Requests Exemption to 10CFR20,App A,Footnote (C) to Allow Credit for Radioiodine Protection Factor in Employing MSA 466220 GMR-I Canister for Respiratory Protection.Exemption Will Reduce Potential for Manrem Exposure

ML20128F344
Person / Time
Site:	Wolf Creek
Issue date:	07/01/1985
From:	Koester G KANSAS GAS & ELECTRIC CO.
To:	Harold Denton Office of Nuclear Reactor Regulation
References
KMLNRC-85-167, TAC-59366, NUDOCS 8507080213
Download: ML20128F344 (3)

Text

.._

, KANSAS GAS AND ELECTRIC COMPANY THE ELECTF*C COMPANY OLENN L MOESTER vice pas s, DENT . MucLean July 1, 1985 Mr. Harold.R. Denton, Director Office of Nuclear Reactor Regulation U.S. Nuclear Regulatory Commission Washington, D.C. 20555 KMLNRC 85-167 Re: Docket No. STN 50-482 Subj: 10CFR20 Respiratory Protection, Iodine Filter Exemption Request

Dear Mr. Denton:

Pursuant to 10CFR20.103(e) ard 10CFR20.501, Kansas Gas and Electric Company (KG&E) hereby applies for exemption to 10CFR20, Appendix A, footnote (c) to allow credit for a radiciodine protection factor in employing the MSA 466220 GMR-I Canister for respiratory protection.

This exemption is desirable since it will reduce potential man-rem exposure.

Throughout the lifetime of the plant, at different times, airborne concen-trations of radioiodine may be encountered. Worker respiratory protection for radiciodine can be accomplished by the use of air supplied or self-contained breathing apparatuses. However, this equipment is cumbersome to the worker, contributes to fatigue and efficiency loss which may result in increased man-rem exposure and a reduced personnel safety margin when compared to air-purifying respirators.

Appendix A of 10CFR20, " Protection Factors for Respirators" does not recogni e ,

the use of air-purifying respirators for protection against radiciodine and footnote (c) specifically prohibits this practice. However, KG&E is aware of research sponsored by the USNRC-Occupational Radiation Protection Branch reported in NUREG-CR 3403 that has been accomplished to certify air-purifying respirators against radiciodine.

The limitations and precautions noted in NUREG-CR 3403 will apply. These limitations and precautions are summarized below:

1. Protection factor = 50.

2. Eight-hour maximum continuous use time after which the canister would be discarded.

3. Not to be used in the presence of organic solvent vapors.

h G 8507080213 850701 i0 PDR ADOCK 05000482 P PDR 201 N. Market - Wichtta Kansas - Mail Address: PD. Box 206 l Wichita, Kansas 67201 - Telephone: Area Code (316) 261-6451

Mr. !!arold Denton KMLNRC 85-167 July 1, 1985

4. To be stored sealed in a cool, dry environment.

5. Service life to be calculated from the time of unsealing including periods of non-exposure.

6. To be used with a facepiece capable of providing protection factors greater than 100.

7. Not to be used in challenge concentrations of total organic iodine, including nonradiometric iodine greater than 1 ppm.

8. Not to be used in environments greater than 120 degrees F.

or 90% relative humidity.

It is felt that with the above restrictions supported by reliable test information, the use of a protection factor of 50 for radiciodine would be within the law and would not result in undue hazard to life or property.

If you have any questions, please contact me or Mr. Otto Maynard of my staff.

Yours very truly, Glenn L. Koester Vice President - Nuclear GLK:bb xc:PO'Connor (2)

JCummins J

STATE OF KANSAS )

) SS CITY OF WICHITA )

Glenn L. Koester, of lawful age, being first duly sworn upon oath says that he is Vice President - Nuclear and an Officer of Kansas Gas and Electric Company; that he has road the foregoing document and knows the content thereof; that he has executed the same for and on behalf of said Company with full power and authority to do so; and that the facts therein stated are true and correct to the best of his knowledge, information and belief.

By A M

'Gle"nn' L. Koester Vice President - Nuclear SUBSCRIBED and sworn to before me this 1st day of July , 198 5 .

Notary Public handa/w, g Yb ~

p ... .... .. .

v. . d .>% ..

r/ Q- i.c-:i e !El 1.rf+:.

q 9 's .:

, .. ... .a.

e o.?

l