ML20207J567
| ML20207J567 | |
| Person / Time | |
|---|---|
| Site: | Callaway  |
| Issue date: | 12/29/1986 |
| From: | Office of Nuclear Reactor Regulation |
| To: | |
| Shared Package | |
| ML20207J546 | List: |
| References | |
| NUDOCS 8701080518 | |
| Download: ML20207J567 (6) | |
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UNITED STATES g
NUCLEAR REGULATORY COMMISSION n
.h WASHINGTON, D. C. 20555
'+,,.....p SAFETY EVALUATION BY THE OFFICE OF NUCLEAR REACTOR RECULATION RELATED TO THE USE OF RADIGICDIf:E PPOTECTION FACTOR FOR S0RBENT CANISTERS AT UNION ELECTRIC'S CALLAWAY PLANT DOCKET No. 50-482 Introduction By their submittals dated October 22, 1985 and August 26, 1986, Union Electric d-2(c)y (UEC) has requested an exemption to 10 CFR Part 20, Appendix A, footnote Compan The licensee submitted this request in accordf.nce with 10 CFR Part 20.103(e) and provided further justification for the exemption in response to our requests for additional information.
Test data and canister. qualification information have been provided by UEC by reference to Mine Safety Appliances Company (MSA) data submitted in conjunction with similar exemption requests for Farley 1&2 by Alabama Power Company, and for San Onofre 1, 2, and 3 by Southern California Edison Company. UEC has provided a detailed response to all NRC staff concerns relating to the request for exemption to 10 CFR Part 20, Appendix A, footnote d-2(c). The ekemption would al* low the use of a radiciodine protection factor of 50 for MSA GMR-I canisters to be used at the Callaway Unit 1 power reactor facility. Criteria and background information used for the evalct. tion incluce IC CFP Part 20.103, 10 CFR Part 19.12 Regulatory Guide 8.15, " Acceptable Programs for Respiratory Protection,"
Regulatory Guide 8.20, " Applications of Bicassay for I-125 and I-131,"
f.UREG/CR-3403, " Criteria and Test Methods for Certifying Air Purifying Respiratcr Cartridges and Canisters Acainst Radiciodine," and Regulatory Guide 8.8, "Information Relevant to Ensurinc That Occupational Radiation Exposures at Nuclear Power Stations Will Be As low As Is Reasonably Achievable."
Discussion and Evaluation Since a NIOSH/MSHA testing and certification schedule for sorbents for use for protection against radiofodine gases and vapors has not been develooed, the NRC staff has evaluated UEC's request and verified, as required by 10 CFR Part 20.103(e), that the licensee has demonstrated thrcugh reliable test data and adequate quality assurance measures that the material and perfomance characteristics of the MSA GMR-I canister can provide the prooosed degree of protection (i.e., a protection factor of 50) under the anticipated ccnditions of use, for 8 hours9.259259e-5 days <br />0.00222 hours <br />1.322751e-5 weeks <br />3.044e-6 months <br />. Canister efficiency and service life, and the effects of temperature, poisons, relative humidity, challenge concentration and breathing rates on canister efficiency and service life were considered in the staff's technical evaluation. The staff's programatic evaluations considered quality control / quality assurance, administrative controls, and radiation protection /ALARA, ircluding task preparation and planning, on-the-job and post-task evaluations, use of engineering controls, radiological surveillance, and radiological training.
8701080518 861229 PDR ADOCK 05000483 p
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c The licensee has provided reliable test inferration which verifies that the MSA GAR-I canister will provide a protection factor of 50 over a period cf 8 hours9.259259e-5 days <br />0.00222 hours <br />1.322751e-5 weeks <br />3.044e-6 months <br /> of continucus use, provided that the total challenge of radioactive and non-radioactive iodine and other halogenated ccopounds does not exceed 1 ppm, and temperature dces not exceed 110 F, or up to 120'F provided the dewpoint does nct exceed 107 F.
The data provided by MSA showed the breakthrough point to be viell beyond 8 hours9.259259e-5 days <br />0.00222 hours <br />1.322751e-5 weeks <br />3.044e-6 months <br />.
Testing has been concucted under acceptable ccrditinrs of cyclic ' flow, and Lnder t;orst case conditions for these environr.iental factors affecting service life: temperature, relative tciridity, and challenge concentration of CH 1 (methyliodide/r.. ethyl radiciodide), which is the rest penetrating of the#
challenge forros. Data previded from MSA indicate that the l'SA CMR-I canisters perfera adequately under the accepted test conditions. These conditions - the criteria and test trethods - are consistent with those 1
cerived for the canisters by the staff from I;UREG/CR-3403, and are acceptable.
The licensee, thrcugh verification and acceptance cf cverall MSA OA controls for the Callaway Quality Supplier List, and through review and accecterce of the Vansas Gas and Electric (KGSE) quality assurance audit perfomed in conferetion with a similar KG8 E exerpticn request, has provided ccrrniitments that the liSA-GMR-I canisters Lsec kith a protection factor at the Calleway plant will meet standarcs for quality assurance and quality centrol which are recognized by NICSh, i
corrpatible with NRC staff positions ard t=re, therefore, acceptable. This includes a corraitment by 145A to establish a 1% AQL (Acceotable Ouality Lirait) in a 5 to 10 ppm challenge ccccentration of CH I, 90% relative htmicity,110 F, 64 LPM 3
1 cyclic flow, for 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 riore at penetration equal to 1% of the challenge cor.cer.tration. Testing data referenced by the licensee i
deact:strtted that performance (i.e., service life) of canisters at 100%
l relative huuidity is acceptable. UEC cn-site quality control ardits end surveillances will be expanded tc include GhR-1 canister use.
Coupled with the use of a full fecepiece with the capability of providing a protection factor of greater than 100, to be determined by fit test, the protection factor of 50 is conservative under these conditiers. Ctnister efficiercy will be retained for the radioicaine gas or vapors of interest (CH,1,I, HOI) for this time pericd. To preclude aging, service life vill te falcuia,ted from unsealing tirre, inclucing periods of non-use, and the canister will not be useo in the presence of organic solvents or in tcrgeretures in excess of 120 F or 107*F dewpoint. Canisters will be stortd in sealed torddity-barrier packaging in a cool, dry environment, and discarded after the 8-hour use period to prevent reuse.
Through usage restrictions and air sarrplirg, the licensee will preclude exposures to organic vapors and cherricals [such as paint, paint thinner /rerrever (r.ctFylethylketones1, freon cleanir.g agents (trichlorotrifluorcetbare), iscpropyl alcohol, methyl chlorofern?
which could cause aging, sciscring or desorption of the absorbed raoiciodines.
Plant procedures cescriting air sarrpling and administrrtive controls for detecting e.rd rrecluding the presence of organic vaccrs and chemicals will Le Lt1112ed or revised as necessary (f.e., APA-ZZ-00360, HTP-27-Cf CCT'.
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Certain limitations and precautions based on NUREG/CR-3403 guidance are necessary for utilization of the sorbent canisters. We agree with the following such limitations and usage restrictions as proposed by the licensee:
1.
Protecticn factor equal to 50 as a maxicum value.
2.
The maximum permissible continuous use time is eight hours after which the canister will be discarded.
3.
Canisters are not to be used in the presence of organic solvent varors.
4 Canisters are to be stored in sealed, humidity barrier packegire in a cool, dry environtrent.*
5.
The allowable service life for sorbert canisters is to be calcu-lated from the time of unsealing the canister, incluaing pericds of non-exposure.
6.
Canister is to be used with a full facepiece capable of providing rretection factors greater than 100.
7.
Canisters are not to be used in total challenge concentrations of organic iodines and other halogenated corpounds greater than 1 pri",
~ inc1rdirg nenradioactive compounds.
8.
Canisters are not to be used in environments where temperatures are greater than 120 F, or dewpoint exceeds 107 F.
- Sorbent car.isters will be stored in Class "C" or better storage conditions in the Callaway plant warehouse in accordande with prccedure VSP-ZZ-0002, " Storeroom Storege and Control of !!aterial, Corcorents, and Equipment."
Temperatures have averaged 90 F in this facility in tre sumer with relative humidity at 60%, and a maximum tecperature of 100 F.
In addition to the limitations and usage restrictions noted above, administrative ar.d procedural controls will be utilized by the licensee as follows:
1.
Temperatures will be measured prior to and/or coincidently with the use of CfE-I canisters to assure that work temperatures do rot exceed 120*F or tenperatures corresponding to a deupoint of 107'F during sorbent canister use.
2.
In the initial implementaticn cf scrbent canister use, the followirg progran verification measures will be used:
a.
weekly whole body ccunts for ir.dividuals using the scrbent canister for radiciodine protection; b.
for individuals who exceed 10 MPC hours in seven consecutive days, a whole bcdy ccunt will be required prior to their l
next ente / into a radioicdine atmosphere (i.e., effectively a 10 MPC bour stay time);
c.
if an individual measures 70 nCi or greater iodine uptake to the thyroid curing a whole body count, the individctl's entry into radiciodinc etncspheres will be restricted pending health physics cvaluation; and
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a whole body count / survey data base will be compiled to evaluate the results of the program.
3.
Certain air contaminants which could affect GMR-I performance will be controlled under procedures governing performance of plant charcoal and HEPA air filtration systems, as required under Technical Specification 3/4.7.7. These procedures effect controls similar to those needed for CFR-I use.
4.
Specific plant procedures will be modified to incorrerete the limitaticns and usage restrictions, listed as 1 through 8 above, prior to GMR-I canister use (HDP-ZZ-06017, HTP-ZZ-08002).
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5.
Existing respiratory protection program requirements and restric-ticos (e.
A and B) g., physicals, fit tests, Part E0 requirements, Appendices still apply.
The primary bases for UEC's request for exemption are the rotentials for both work effort reduction and dose reduction. The utilization of air curifying respirators in lieu of air-supplied or self-contained apparatuses, where.possible, can result in rersen-rem reductions estimated overall at 30%
for tasks requiring radiciodine prctcction, and up to 50% for some rajor tasks. The light weight, less ctrierscrae air purifying respiratcrs (i.e., sorbent canisters) can provide ircreased comfort and mobility in r.ost cases, and result in intreased worker ef'ffciercy and decreased time on-the-jcb.
The licensee has provided a task analysis which sFcws that the use of sorbent Cdnisters at the Callaway plant can result in significant dese savings and should be an effective ALARA measure.
Other ections taken by UEC to assure that extosures to radiciodine are as low as is reasonably achievable (ALARA) are:
radioiodine air sarcplirg before and during activities involvir.g the use cf sorbent canisters for radioicdine protection; engineering controls such as portable HEFA ventilation ano temporary containraents to ccntrol leakage and reduce airborne levels to ALARA levels; purification and degasification of the primary coolant conducted prior to refueling resulting in reduced radiciodine levels; and area cecontamination to control contamination levels. !! hole body counts will be conducted rcutirely (e.g., weekly and at 10 PPC hours) and racioiodine dzta will be trended to detect problems; an investigation level for radicicdine trtakes has been established (at 70 nCi); training of workers and health physics technicians in the use and restrictions for use of sorbent canisters for radioiodine protectien will be conducted prior to their use; crd procedures iterating the controls, restricticns, and requirements have been developed and will be ircplemented. The licensee's effcrts to kcep exposure i
ALARA are corsisttnt with our positions in Fegulatory Guide 8.8 and are acceptable.
Safety Summary Cur revicw of the licensee's proposal indicctes that the actions propose-d Ly LTC can result in significant cose savings over alternative methods th4c still providing effective protection. This exemption would enable the licerste to use a protection factor for air purifying radiofodine pas ard vapor resoirators in estinating wcrker exposures from radioiodice reces and vapors. The licenste has provided usage restrictions and controls which can
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assure an effective radiciodine protection program. The proposed criteria and test methods for verifying the effectiveness and quality of GMR-I canisters are consistent with our criteria. The licensee's proposed exemption, with the controls and limitations, meets our positions in the SRP, NUREG/CR-3403 and Reg 61atory Guide 8.8, and is acceptable. The actions proposed by the licensee are consistent with the requirements of 10 CFR Part 20.103(e), and form an acceptable basis to authorize the granting of an exemption in accordance with the provisions of 10 CFR Part 20.103(e).
- Principal Contributors:
R. Serbu, PSB P.O. Ccoror, PAD #4 Dated:
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DIS ION:
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Docket Filea U
PAD #4 Rerding MDuncan
-d PO'Connor December 29, 1986 nocnET No.
50-483 Rules and Procedures Branch RAEGIORAISURI FOft:
Division of Rules and Records Office of Administration FROGA:
Office of Nuclear Reactor Regulation susJECT:
Union Electric Company (Callaway Plant)
One signed original of the Federal Register Notice identified below is enclosed for your transmittal to the Office of the Federal Regist er for publication. Additional conformed copies (
) of the Notice are enclosed for your use.
Notice of Receipt of Application for Construction Permit (s)and Operating License (s).
Notice of Receipt of Partial Application for Construction Permit (s) and Facility License (s)-Time for Submission of Views on Antitrust Matters.
Notice of Consideration of issuance of Amendment to Facility Operating License.
Notice of Receipt of Application for Facility License (s); Notice of Availability of Applicant's Environmental Report; and Notice of Consideration of issuance of Facility License (s) and Notice of Opportunity for Hearing.
Notice of Availability of NRC Draf t/ Final Environmental Statement.
Notice of Limited Work Authorization.
Notice of Availability of Safety Evaluation Report.
Notice of issuance of Construction Permit (s).
Notice of issuance of Facility Operating License (s) or Amendment (s).
Order.
Exemption.
Notice of Granting Exemption.
Environmental Assessment.
Notice of Preparation of Environmental Assessment.
Other:
Office of Nuclear Reactor Regulation l
Enclosure:
As stated
Contact:
Phone:
Marilee Duncan 23923
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