ML20151Z239

Forwards Request for Addl Info Re 880227 Request for Exemptions to Allow Util to Take Credit for Respirators Fitted W/Sorbent Cartridges for Protection Against Airborne Radioidine.Response Requested within 30 Days

ML20151Z239
Person / Time
Site:	Salem, Hope Creek, 05000000
Issue date:	08/25/1988
From:	Rivenbark G Office of Nuclear Reactor Regulation
To:	Miltenberger S Public Service Enterprise Group
References
TAC-67637, NUDOCS 8808290256
Download: ML20151Z239 (3)

Text

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August 25',.1988 Docke,t No. 50-354

'Mr. Steven E. Miltenberger Vice President and Chief Nuclear Officer Public Service Electric & Gas Company Post Office Box 236 Hancocks Bridge, New Jersey 08038

SUBJECT:

REQUEST FOR ADDITIONAL INFORMATION (TAC N0. 67637)

RE: HOPE CREEK GENERATING STATION By letter dated February 27, 1988, Public Service Electric and Gas (FSE&G) requested exemptions from 10 CFR 20 for Salem Units 1 & 2 and Hope Creek Unit

1. These exemptions would allow PSE&G to take credit for respirators fitted with sorbent cartridges (specifically MSA-GMR-I canisters) for protection against airborne radioiodine. Currently the use of sorbents is prohicited by Appendix A to 10 CFR 20.

We have reviewed the submittal and identified additional information that is needed to complete the review. We request that the information in the enclosed request for additional information be submitted within 30 days of the date of this letter.

The reporting and recordkeeping requirements of this letter affect fewer than ten respondents; therefore, OMB clearance is not required under P.L.96-511.

t Please contact us if you have any questions concerning this RAI.

Sincerely,

/S/

8808290256 880825 2 George Rivenbark, Project Manager t PDR ADOCK 0500 Project Directorate I-2 l P Division of Reactor Projects I/II Office of Nuclear Reactor Regulation 1

Enclosure:

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% ,,,,,* August 25, 1988 Docket No. 50-354 Mr. Steven E. Miltenberger Vice President and Chief Nuclear Officer Public Service Electric & Gas Company Fost Office Box 236 Hancocks Bridge, New Jersey 08038

SUBJECT:

REQUEST FOR ADDITIONAL. INFORMATION (TAC N0. 67637)

RE: HOPE CREEK GENERAT!dG STATION By letter dated February 27, 1988, Public Service Electric and Gas (PSE&G) requested exemptions from 10 CFR 20 for Salem Units 1 & 2 and Hope Creek Unit

1. These exemptions would allow PSE&G to take credit for respirators fitted with sorbent cartridges (specifically MSA-GMR-I canisters) for protection against airborne radioiodine. Currently the use of sorbents is prohibited by Appendix A to 10 CFR 20.

We have reviewed the submittal and identified additional information that is needed to complete the review. We request that the infonnation in the enclosed request for additional information be submitted within 30 days of the date of this letter.

The reporting and recordkeeping requirements of this letter affect fewer than ten respondents; therefore, OMB clearance is not required under P.L.96-511.

Please contact us if you have any quest'ons concerning this RAI.

Sincerely,

/

G orge R nbar , Project Manager Project Directorate I-2 Division of Reactor Projects I/II Office of Nuclear Reactor Regulation

Enclosure:

As stated cc: See next page

l

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. 1 Mr. S.teven E. Miltenberger Hope Creek Generating Station Public Service Electric & Gas Co.

cc:  !

M. J. Wetterhahn, Esquire Conner & Wetterhahn Suite 1050 1747 Pennsylvania Avenue Washington, D.C. 20006 R. Fryling, Jr., Esquire Law Department - Tower SE 80 Park Place Newark, New Jersey 07101 Resident Inspector U.S. Nuclear Regulatory Commission P.O. Box 241 Hancocks Bridge, New Jersey 08038 Mr. S. LaBruna General Manager - Hope Creek Operations Hope Creek Generating Station P.O. Box 118 Hancocks Bridge, New Jersey 08038 Mr. B. A. Preston, Manager Licensing and Regulation Nuclear Department P.O. Box 236 Hancocks Bridge, New Jersey 08038 Regional Administrator, Region I U.S. Nuclear Regulatory Comission 475 Allendale Road King of Prussia, Pennsylvania 19406 Mr. David M. Scott, Chief Bureau of Nuclear Engineering Division of Environmental Quality Department of Environmental Protection State of New Jersey CN 411 Trenton, New Jersey 08625

, l 1

RE0 VEST FOR ADDITIONAL INFORMATION

1. Item #4 of the February 27, 1988 exemption request indicates that the GMR-I canisters would only be used with a full face piece respirator proven to provide a protection factor of greater than 100. What fit factor will be used as the acceptance criterion for the quantitative fit test to ensure that the stated level of protection will be provided?

2. Item #5 of the request states that .ioassay will be perfonned on users who "exceed the level specified by procedures." At what level and at what frequency will bioassay be performed? How does PSE&G intend to check the effectiveness of its use of GMR-I canisters?

3. Item #7 states that "each canister will be inspected in accordance with the appropriate procedure" prior to issue. What is the purpose of this inspection?

4. How does PSE&G intend to ensure the quality of the canisters? Absent a NIOSH certification, a quality assurance program comparable to mil.

Standard 444 (with an acceptable quality limit equal to 1) should be provided.

5. What precautions on the storage of canisters prior to use will PSE&G implement to ensure that the sorbent is not degraded?

6. What temperature and/or humidity limitations will PSE&G propose for the use of sorbent canisters?

7. PSE&G states that this exemption request is justified due to ALARA considerations. Data presented, concerning the Hope Creek vessel head lift operation (Table 1 of Attachment 1), indicate that the use of'GMR-I equipped respirators would have a net savings of 998 person-mrem over the use of SCBA or air line respirators for this task. However, this table also indicates a net savings of 1335 person-mrem would be realized by not using any respirator for this task. How does PSE&G justify that using GMR-I equipped respirators is ALARA when wearing no respirator at all will save an additional 335 person-mrem?

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