ML20150A672

Designs Including Pressure Suppression Containments Can Be Licensed Since There Is Adequate Assurance of Their Safety. There Is No Basis for Advocating Elimination of Pressure Suppression Containments.(Encl to 7810060200)

ML20150A672
Person / Time
Site:	Mcguire, Pilgrim, McGuire
Issue date:	06/20/1978
From:	Hanauer S NRC OFFICE OF THE EXECUTIVE DIRECTOR FOR OPERATIONS (EDO)
To:	Hendrie J NRC COMMISSION (OCM)
References
CON-#487-5002 2.206, NUDOCS 7810060203
Download: ML20150A672 (2)

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US F 38 OCT -5 P2 :19 October 1,1998 O. l h.

AD. t Secretary > M ETNUMf.f8 p U. S. Nuclear Regulatory Commission oROPOSED RULE r3 o?O _.

Washington, D.C. 20555-0001 Attention: Rulemakings and Adjudications Staff (G3FR38'6ll)

Subject:

Comments on Proposed Rulemaking, " Respiratory Protection and Controls to Restrict Internal Exposures"

Reference:

Volume 63, Federal Register, Page 38511 (63FR38511), dated July 17, 1998.

This letter provides the Commonwealth Edison (Comed) Company comments on the subject Nuclear Regulatory Commission (NRC) proposed rulemaking published in 63FR38511. Comed generally supports the proposed changes with the exceptions discussed in the comments below.

General In the proposed rule's Federal Register summary, the NRC requested comments on whether the technical aspects of the rule should be addressed through other approaches. In response to that request, Comed does endorse the development and use of simple risk-informed, performance-based rules. Comed supports development of regulations and Regulatory Guides that directly endorse industry standards. These nuclear industry standards, in turn, need to be developed through nuclear industry participation.

Regarding the planned revision to NUREG-0041, " Manual of Respiratory Protection Against Airborne Radioactive Materials," consideration should be given to elimination of the NUREG. The information contained in the current NUREG-0041 is in many cases redundant with the type of information found in other industry documents such as American National Standards Institute (ANSI) Standard Z88.2-1992, "American National Standard for Respiratory Protection." If certain aspects of the NUREG are considered crucial by the NRC in terms of respiratory protection-related guidance, then those few items should be added to the Proposed Revision 1 to Regulatory Guide 8.15, " Acceptable Programs for Respiratory Protection." Comed believes this approach would be consistent with the strategy of formulating a more simple regulatory oversight process, that is, p

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October 1,1998 U. S. Nuclear Regulatory Commission Page 2 )

having two regulatory-related documents on respiratory protection rather than three such documents.

Some specific comments on the proposed rule are provided below.

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( c)(5) Per the proposed rule, non-face sealing respirators do require a medical l evaluation before the first field use, except as noted for single-use disposable respirators in Note e. to Appendix A. However, this exemption is inconsistent with Occupational and Safety Health Administration (OSHA) 29 CFR 1910.134(e), which requires a medical evaluation prior to use for all respirators. Since the use of this type of respirator would not normally be used fbr protection against airborne radioactive material, NRC regulations should not provide an exemption for these medical evaluation requirements.

( c)(6) The proposed Fit Factor of > 100 for any positive pressure, continuous l flow, and pressure demand devices is different than OSHA 29 CFR 1910.134. Since quantitative fit tests are performed in the negative pressure mode, the fit factor of a full facepiece cartridge respirator could be the same as the half mask cartridge respirator, i.e.,100. OSHA 29 CFR 1910.134 requires a minimum fit factor of 500 for full facepiece respirators. It is recommended that OSHA regulations and NRC regulations be the same regarding this issue.

Appendix A to Part 20 Note c. There is an apparent typographical error in the note. The second use of the "less than or equal" sign should actually be a " greater than" sign.

Note e. The medical evaluation exemption may be inappropriate due to the fact that a medical exemption is inconsistent with OSHA 29 CFR 1910.134(e) as was discussed in the comments to the proposed 10 CFR 20.1703(c)(5) above.

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Some models of single-use respirators are equipped with seal enhancing I material, and, therefore, in those cases, there should be no difficulty in l

achieving a facial seal. This is in conflict with the blanket statement in the note that it is difficult to perform an effective fit check on these devices.

Respectfully, j R.M. ' i i Vice President - Regulatory Services 1

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