ML20195B537
| ML20195B537 | |
| Person / Time | |
|---|---|
| Site: | Vogtle  |
| Issue date: | 10/27/1988 |
| From: | Office of Nuclear Reactor Regulation |
| To: | |
| Shared Package | |
| ML20195B535 | List: |
| References | |
| NUDOCS 8811020065 | |
| Download: ML20195B537 (5) | |
Text
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NUCLEAR REGULATORY COMMISSION y *...* )!
t wAsmorow, o. c. rosse SAFETYEVALUATIONBYTHEOFFIC(OFNUCLEARRFACTORREGULATION j
RELATED TO THE USE OF A l
l RAD 1010 DINE PROTECTION FACTOR FOR SORBENT CANTSTERS i
AT V0GTLE ELECTRIC GENERATING PLANT. UNIT 1 l
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DOCKET NO. 50-424 i
INTRODUCTION l
j By submittal dated August 26, 1988 as supplemented October 6. 19R8 Georgia Power Company, et 41.. (the licensee) requested an exemption to 10 CFR Part
- 20. Appendix A. footnote d-2(c). and for authorization to use equipment which has not been certified by NIOSH/MSHA. The licensee submitted is request in accordance with 10 CFR Parts 20.501 and 20.103(e).
Test data and canister cualification infomation have been provided by the i
i licensee. The exemption and authorization would allow the use of a radiciodine l
protection factor of 50 for MSA GMR-! canisters at Vogtle Electric Generating l
Plant. Unit 1 (Vogtle 1). Criteria and background infoncation used for our i
evaluation include 10 CFR Part 20.103; 10 CFR Part 19.1?; Regulatory Guide 8.15
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"Acceptable Programs for Respiratory Protection;" Regulatory Guide 8.20.
1 "Applications of Bioassay for I-125, and 1 1311" NUREG/CR-3403. "Cartridges and Test Methods for Certifying Air Purifying Respirator Cartridges and Canisters s
Against Radioiodine." and Regulatory Guide 8.8. "Infomation Relevant to Ensuring j
j That Occupational Radiation Exposures at Nuclear Power Stations Will Be As low As !s Reasonably Achievable."
DISCUS $10N AND EVALVATION Since a NIOSH/MSHA testino and certification schedule for sorbents for use for protection against radiciodine gases and vapors has not been developed. the NRC l
staff has evaluated the licensee's request and verified that the licensee has i
i demonstrated through reliable test data and adequate quality assurance measures that the material and perfomance characteristics of the MSA GMR-1 canister can i
l provide the proposed degree of protection (i.e., a protection factor of 50) under the anticipated conditions of use, as required by 10 CFR Part 20.103(e),
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for 8 hours9.259259e-5 days <br />0.00222 hours <br />1.322751e-5 weeks <br />3.044e-6 months <br />. We considered canister efficiency and service life, and the effects j
of temperature, poisons, relative humidity, challenge concentration and i
breathing rates on canister efficiency and service life. The programatic i
evaluation considered quality control / Quality assurance, and radiation protection /
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ALARA considerations, including task preparation and planning, on the-job and j
post-task evaluations, use of engineering controls, radiological surveillance.
and radiological training.
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The licensee has provided reliable test information which verifies that the
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j MSA GMR-! canister will provide a protection factor of 50 over a period of 8 hours9.259259e-5 days <br />0.00222 hours <br />1.322751e-5 weeks <br />3.044e-6 months <br /> of continuous use provided that the total challenge of radioactive and non-radioactive iodine and other halogenated conapounds does not exceed 1 ppm.
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and temperature does not exceed 110'F. or up to 120'F provided the dewpoint I
does not exceed 107'F. The data provided by PSA showed the breakthrough point l
to be well beyond 8 hours9.259259e-5 days <br />0.00222 hours <br />1.322751e-5 weeks <br />3.044e-6 months <br />, g
j Testing has been conducted under acceptable conditions of cyclic flow, and i
under wnrst case conditions for those environmental factors affecting service life:
temperature, relative humidity, and challenge concentration of CH !
(methyliodide/ methyl radiciodide), which is the most penetrating of the 3 i
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challenge foms.
Data provided from MSA indicate that the MSA GMR ! canisters
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j perform adequately under the acceptable test conditions. These conditions the j
criteria and test methods - are consistent with those derived for the canisters by the NRC staff from NUREG/CD-3403, and are acceptable.
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The licensee, through acceptance of MSA QA controls, has provided comitments t
i that the MSA GMM-1 canisters will meet standards for quality assurance and j
quality control which are recognized by NIOSH. compatible with NRC staff positions, and are therefore acceptable.
This includes a commitment by PSA i
i to establish a 1% AQL (Acceptabla Quality Limit) in a 5 to 10 ppm cha11ence i
i concentration of CH ! 90% relative humidity.110'F. 64 LPM cyclic flow. for 3
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a service life of 8 hours9.259259e-5 days <br />0.00222 hours <br />1.322751e-5 weeks <br />3.044e-6 months <br /> or more at penetration equal to 1% of the challenge concentration.
Testing data referenced by the licensee demonstrated that perfomance (i.e.
service life) of canisters at 100% relative humidity is f
acceptable.
t Coupled with the use of a full facepiece with the capability of providing a protection factor equal to or greater than 500 by quantitative fit test, the 1
protection factor of 50 is acceptable. Canister efficiency will be retained for To preclude aging, service life will be calcuia!.1. H01) for this time period.
the radiciodine gas or vapors of interest (CH 7
ted from unsealing time, j
including periods of non-use, and the canister will not be used in the presence of organic solvents or in temperatures in excess of 107'F dewpoint. Canisters a
j will be stored in sealed humidity-barrier packaging in a cool, dry environment, j
and discarded after the 8-hour uso period to prevent reuse. Through usage
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restrictions and air sampling, the licensee will preclude exposures to organic j
vapors and chemicals (such as decontamination compounds, lubricants, volatized paint, alcohols, freon) which could cause aging, poisoning or desorption of the j
absorbed radioiodines, i
Certain limitations and precautions based on NUREG/CR-3403 guidance are j
recessary for utilization of the sorbent canisters. We agree with the following limitations and usage restrictions as proposed by the licensee:
1.
Protection factor equal to 50 as a maximum value.
2.
The maximum permissible continuous use time is eight hours after i
which the canister will be discarded.
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3.
Canisters are not to be used in the presence of organic solvent vapors.
4 Canisters are to t,e stored in a Class A or better environment as defined in ANS! N45.2.2.
5.
The allowable service life for sorbent canisters is to be calculated from the time of unsealing the canister. including periods of non-erposure.
6 Canister is to be used with a full facepiece capable of providing a protection factor equal to or greater than 500.
7.
Canisters are not to be used in total challenge concentrations of organic todines and other halogenated compounds greater than I ppm.
including nonradioactive compounds.
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Canisters are not to be used in environments where temperatures are greater than 110' or up to 120'F. if the dewpoint is equal to or i
J 1ess than 107'F.
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In addition to the liinitations and usage restrictions noted above. the following l
additional controls will be utilized by the licensee:
1.
Temperatures will be tocasured prior to and/or during the use of GPR-!
l canisters to assure that work temperatures are within limits.
1 2.
Air samples will be taken prior to and during any activities that involve the use of the GMR-! canister for protection against radioactive iodine.
3.
A GMR-! canister found to have exceeded 3 years from date of, manufacture will not be used for protecti9n against radioactive iodine.
4 In the initial implementaion of the GMR-! program, the follnwing l
verification measures will be in effect:
a.
Weekly whole body counts for individuals using the GMR-! canisters for radiciodine protection.
b.
A whole body count for individuals that exceed 10 MPC in a week l
and used the GMR-! canister for respiratory protection in that l
ported.
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c.
Anyone that measures 70 nCi or greater iodine uptake to the thyrold during a whole body count will be restricted from entering a i
radiutodine atmosphere pending Fealth Physics evaluation.
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d.
The radiological survey and whole body count information will be compiled to evaluate the effectiveness of the program, l
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5.
Vogtle Technical Specification 4.7.7. "piping penetration Area Filtration and Exhaust System." defines the availability and surveillance requirements related to the auxiliary building radiation area filter r
exhaust and continuous exhaust system.
The containment purification and clean-up system and the aux. building radiation area filter exhaust and continuous exhaust system plant procedures, governing the operability and functioning of charcoal beds, are in compliance with Regulatory Guides 1.140 and 1.5? for design, testing, and maintenance of filtration i
systems. These requirements are utilized to demonstrate system oper-ability with respect to HEpA and charcoal filters.
Since GMR-l canisters will be in the same areas served by these systems, assurance of coriti-nuing operability of these systems will provide assurance of a proper
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environment (i.e., no organic vapors or chemicals) for GMR-l l
canister use.
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Specific plant procedures will incorporate the limitations and usage
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restrictions. listed as 1 through 8 above, prior to GMR-1 canister l
l use. Additionally, training of workers on the proper use and the limitations of the GMR ! canisters will be perfomed prior to i
canister issuance.
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I 7.
Existing licensee engineering controls to relieve the needs for l
respiratory protection as required in 10 CFR 20.103(b)(1) will still l
apply.
These measures include but are not limited to, degasification j
of the reactor coolant system crud burst clean up, process to confine or eliminate airborne radioar,tivity, delay breaches of primary systems to allow decay of radioisotopes and area decontamination to decrease 4
possibilities of generating airborne radioactive material.
i The primary bases for the licensee's reouest for exemption are the potentials i
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for both increased worker safety and dose reduction. The utilization of air purifying respirators in lieu of air-supplied or self-containad apparatuses, where possible, can result in person-rem reductions estimated overall at 30%
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for tasks requiring radiciodine protection, in a range of from 25% to 50% for J
several major tasks.
The light weight, less cumbersome air purifying respi.
rators (i.e.
sorbent canisters) can provide increased comfort and mobility in i
most cases, and result in increased worker efficiency and decreased time on-the.
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Other actions taken by the licensee to assure that exposures to radioiodine are i
as lew as is reasonably achievable (ALARA) are:
radiciodine air sampling before and during activities involving the use of snrbent canisters for radioiodine a
l protection; engineering controls such as degasification of the primary coolant; j
area decontaminat.pn to control contamination levels; maintenance planning allowing for radiciodine decay tires, where practical, prior to breaching i
primary systems. Whole body counts will be conducted routinely, radiological data will be evaluated, an evaluation level for radiciodine uptakes has been 4
I established (at 70 nC1); training of workers and health physics technicians in I
the use and restrictions for the use of sorbent canisters for radiciodine
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protection will be conducted prior to their use; and procedures iterating the
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controls, restrictions, and requirements will be developed and implemented.
The licensee's efforts to keep exposure ALARA are consistent with staff positions in Regulatory Guide 8.8 and are acceptable.
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SAFETY SilMMARY The NRC staff review of the licensee's proposal indicates that the actions proposed by the licensee can result in significant dose savings over alternative methods while still providing effective protection. This exemption would enable l
the licensee to use a protection factor for air purifying radiciodine gas and F
vapor respirators in estimating worker exposures from radiciodice gases and vapors. The licensee has provided usage restrictions and controls which can assure an effective radioiodine protection program. The proposed criteria and test methods for verifying th6 effectiveness and quality of GMR-1 canisters are
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consistent with our criteria.
The licensee's proposed exception. with the controls and limitations, meets the NRC staff's positions in the Standard I
Review Plan (NUREG-0800). NUREG/CR-3403 and Regulatory Guide 8.8, and is i
acceptable. The actions proposed by the licensee are consistent with the I
requirements of 10 CFR Part 20.103(c), and form an acceptable basis to authorire the use of equipment (MSA GMR-1 caniaters) in accordance with 10 CFR 20.103(e) and to authorize the grantino of an exemption in accordance with the provisions f
Principal Contributor: Jon B. Hopkins. PDII-3/NRR Dated: October 27, 1988 I
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DISTRIBUTION 1
boches file NRC PDR Local PDR PD!l-3 Reading T. Murley/J. $nierek 12-G-18 D. Crutclifield 12-G-18 i
E. Rossi 12-G-18
- 5. Varga 14-E-4 G. Lainas 14-H-3 D. Matthews 14-H-25 I
H. Rood 14-H-25 J. Hopkins 14-H-25 OGC 15-B-18 E. Jordan MNBB-3302 B. Grires 9-A-2 L. Cunningham 11-D-23 C. Hinson 11-0-23 T. Barnhart (4 cys for each Docket No.) P1-137 ACRS (10)
P 315 GPA/PA 17-F-2 ARM /LFHB AR-2015 YOGTLE PLANT FILE 1
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