ML20211B745
| ML20211B745 | |
| Person / Time | |
|---|---|
| Issue date: | 09/08/1983 |
| From: | Liza Cunningham NRC OFFICE OF INSPECTION & ENFORCEMENT (IE) |
| To: | Greger L NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION III) |
| References | |
| NUDOCS 8610210102 | |
| Download: ML20211B745 (7) | |
Text
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F UNITED STATES
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k NUCLEAR REGULATORY COMMISSION
- p wAsHWGTON, D. C. 20555
%,.....J SEP 8 1983 ir MEMORANDUM FOR: L. ~ R. Greger, Chief Facilities Radiation Protection Section Emergency Preparedness and Radiological Safety Division of Radiological and Materials Safety Program, Region III FROM:
LeMoine J. Cunningham, Chief, Section B Engineering and Generic Consnunications Branch Division of-Emergency Preparedness and Engineering Response Office of Inspection and Enforcement
^
SUBJECT:
GUIDANCE CONCERNING 10 CFR 20.103 AND USE OF PRESSURE DEMAND SCBA's l
This is in response to your April 19, 1983 memorandum requesting guidance on the above subject.
The Region III licensee's proposed respiratory protection plan to allow bearded personnel to use pressure demand-SCBA's (provided that service time is not reduced to less than 20 minutes) has been discussed with RES (Lynette Hendricks), and I;IOSH has been consulted.
In your memorandum you stated your objection to the licensee's proposal but could find no clear regu-latory basis for your objection. We support your objection and feel there is a strong technical basis for that objection.
We found several technical flaws in the licensee's proposal to deviate from the normal industry practice of requiring clean-shaven faces in the seal area of tightfitting respirators (see enclosed proposal). One serious problem is the potential for a user to "overbreath"; a person working under heavy physical and mental stress (such as firefighting efforts) can exceed the SCBA's air supply capability. When a beard-caused leak in the seal area exists, the additional
" makeup" air is drawn from the outside atmosp'here through the leak area.
The proposal is silent on this problem.
Another problem is beard interference with the operation of the facepiece's ex-haust(exhalation) valve.
A beard can hold this valve open, and on a deep breath could allow outside, contaminated air to enter the facepiece. Also, on a nonnal volume inhalation an open exhaust valve could allow loss of air, thereby reducing the users's air service time. The licensee does not address this problem.
Technical Contacts:
Jim Wigginton, IE 49-24967 Lynette Hendricks, RES 443-7970 8610210102 830900 PDR 18<E PDR GENERAL
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L. R. Greger SEP 8 1983 A major problem with the licensee's proposal centers on the high probability for increased outward leakage caused by beard interference with the seal. The Industrial Hygiene testing of bearded, Support Group at Lawrence Livemore Lab (LLL) has noted during personnel that the SCBA advertised 30-minutes air supply (which normally' lasts approximately 20 minutes) ran out in 10-12 minutes at a 4
moderate work load. As reported in.the enclosed article, " Facial Hair & Breath-ing Protection", "It must be emphasized again that facial hair characteristics change daily, so any test of facepiece fit or how long the breathing air cylinder will last on one day will be different on succeeding days." We and NIOSH believe i
that a daily quantitive fit test would probably be required to ensure adequate air supply service time for bearded users who have facial hair in the seal area.
The administrative costs and problems with such a program seem to be tremendous.
Since the licensee has formally asked for Regional approval, we recommend you deny approval based on the above technical grounds. The proposed program does not provide sufficient assurance for preventing significant SCBA service-time reduction and is silent on the serious personal safety concerns involving over-breathing and exhausion valve interference for bearded users. Additionally, it is obvious that an impaired firefigher could reduce overall firefighting capa-bilities, with attendant potential for loss of accident mitigation capabilitics.
As to the regulatory basis for denying program approval, while the regulations I
do not specially prohibit facial hair in the seal area, sufficient regulatory guidance already exists which defines acceptable practices in this area. We wish to make the point that beards and facial hair are addressed specifically in this response only because they are the subject of your memorandum and the licensee's proposal. The basic issue is assurance that a leak-tight seal is obtained.
Inadequate seals can be caused not only by beards and facial hair,
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but also facial bone structure, scar tissue, skin blemishes, etc.
Personnel having any condition that prevents a leak-tight seal and proper operation of the respirator should not be qualified respirator wearers nor should they be assign-ed duties which necessitate the wearing of respirators.
And now to address your specific question of whether 10 CFR 20.103 (a) (3) pemits the use of post-exposure whole body counts to determine compliance with Part 20
' intake limits. As you know, the regulations allow licensees who choose not to I
fully implement the respiratory protection program requirements in 20.103 (c) (2) to use respirators, but does not allow them to take any credit for protection ~
i factors. We feel this is a reasonable position from the perspective of providing workers protection during routine, planned operations in airborne radioactivity areas.
For these operations, the degree of hazard can be pre-determined by air sampling, and licensees can then assume no protection factors and limit the stay time such that administrative intake "overexposures" should not occur. However.
l the case for firefighters differs drastically.
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L. R. Greger SEP 8 1983 Prompt emergency response does not lend itself to the pre-work assessment of airborne hazards (toxic smoke, gases, and radioactive material).
In emergency situations, it is clearly illogical to take the "no-protection" assumption for entry into IDLH areas of unknown hazards.
In the case of firefighting hazards, exposure to-radioactive materials is generally of secondary importance, and toxic fumes / gases are the principal personal safety threat. However, a strict, legal reading of the regulations leads us to conclude that nothing specifically prohibits the licensee from using post-work whole body counts for demonstrating compliance with Part 20 intake limits for emergency entries i
into areas of unknown hazards.
From a routine radiological perspective we are not uncomfortable with this reading; however, in the case of unqualified respirator wearers performing emergency response actions in high risk areas with the attendant unknown level of protection, we strongly believe the regu-l lations should clearly require licensees to provide high quality respiratory I
protection.
We have worked closely with RES's Occupational Protection Branch on this matter and they have agreed to consider recommending interim changes to the regulations to clarify and strengthen the respiratory requirements in the emergency-use area.
Additionally, they have budgeted research funds for the 1985 fiscal year to have Los Alamos examine the effect of facial hair on the operation of SCBA's.
It is interesting to note that in the firefighter Ouinn VS. Muscare case (copy enclos-ed) the Supreme Court did not overturn a lower court ruling in favor of the Chicago fire department's policy of not allowing facial hair in the seal area.
ELD has no legal objections to this guidance.
If you have any questions concerning this guidance, please call me or Jim Wigginton.
hM&*l LeMo'ine J. Cunningham, Chief Section B Engineering and Generic i
Connunications Branch l
Division of Emergency Preparedness and Engineering Response, IE
Enclosures:
- 1. Licensee Proposal
- 2. LLL Article
- 3. Supreme Court Ruling cc: see page 4 9
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1 SEP 8 1983 L. R. Greger 4
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R. Alexander, RES W. Fisher, IE E. Flack, IE
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M Jemas G Kippler, Administrator
/NF 4
Big Rock Point Plant IEIR 82-13 Response January 31, 1983 ective Action To Be Taken To Avoid Further Nonsellpliance:
The propo olicy regarding use of resp ory protection equipment (see response Item No. 3a.2) will aplemented upon approval by i
the NRC, and all e brigade me s will be so qualified.
Our plant requirements vi changed to require biennial testing in accordance*with Jedera gula ' ns.
The Date When F Complilance Will be ieved:
The dat full compliance is dependant on the ults of the NRC rev of the proposed policy but will be no later 30 days lowing said approv'al. All required respiratory fit t will be completed by March 1, 1983.
3a.2 "During this routine inspection, the inspectors observed a total of three (3) fire brigade members with full facial beards partic'ipation in the annual fire brigade practice session conducted on Wednesday, August 18, 1982. These persons cannot be considered qualified fire brigade members because their facial hair invalidates their qualification for the use of respiratory protection equipment".
Response to Item No. 3a.2 i
Corrective Action Taken and Results Achieved:
We have reviewed the applicable regulations regarding the use of respiratory protection devices, and there appears to be no specific requirement that would invalidate the respiratory protection qualifica-tion of fire brigade members wearing beards.
In particular we noted the following:
10 CFR 20 - it is stated in Appendix A, footnote B, that "Only for shaven faces and where nothing interferes with the seal of tight fitting face pieces against the skin." This is interpreted to permit the use of published Protection Factors when the listed devices are used on individuals who are clean shaven in the area of the seal.
However,10 CFR 20 does not appear, to state that individuals must be.
clean shaven to wear the respirator. Also,10 CFR 20.103a.3 permits the use of post exposure whole body counts for the purpose of determining compliance with 10 CFR 20.103.
29 CFR - in this regulation which addresses,non-radiological hazards it is stated in Section 1910.134e.5.1 that, " Respirators shall not be worn f
when conditions prevent a good face seal.
Such conditions may be a I
growth of beards, sideburns, a skull cap that projects under the face Piece or temple pieces on glasses." Thus, if a good face seal exists oc1282-0113a142-123 l
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' James G Ksppler, Administrator 5
Big Rock Point Plant IEIR 82-13 Response j'
Janua ry 31, 1983 (defined as the lack of inward leakage), facial hair in the area of the seal may be worn.
Therefore, we are proposing the following policy regarding use of respiratory protection equipment.
In addition to the regulations dis-cussed above, this policy was developed based on the following two con-siderations:
1.
The results of an experiment we performed with a Survive Air rer ?irator which indicate that these 30 minute respirators, operating in the positive pressure mode, provide 22 minutes of protection for.a person with a coarse full beard. This experiment was performed in a quantitative fit-test booth and the observed protection factor did not vary from those normally seen 1'or clean shaven persons.
2.
According to our Fire Plan, we may be required to call upon the local volunteer fire department for assistance. Some of these individuals, ever whom we have no control, have beards.
F The proposed policy is as follows:
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Persons who say be required to wear respiratory protection devices with tight fitting face pieces shall be certified in their~use. To maintain certification, each individual to be certified shall shave in the area of,the seal and receive a quantitative fit test once every two years and/or if a signif-icant change in the individual's facial features is noted, b.
Persons required to wear respiratory protection devices with tight fitting face pieces shall also be clean shaven in the area i
of the seal when such devices are required to be worn, except as described in c below.
c.
Persons with facial hair in the area of the seal may initially don, (1) in emergency (radiological or fire) situations and, (2) in drills, positive pressure open circuit SCBAs provided that the service time is not reduced to 'ess than 20 minutes. For persons with such facial hair, a length of service time test under simulated work conditions shall be performed with their beards intact at least every two years.
d.
Individuals initially responding to emergencies, who have facial hair in the area of the seal, shall be replaced as soon as practical with individuals that are clean shaven in the area of the seal.
e.
Determination of individual intakes of radioactivity may be based on air sample and bioassay techniques.
oc1282-0113a142-123
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' Jams G Keppler, Administrator 6
Big Rock Point Plant IEIR 82-13 Response January 31, 1983 f.
Appropriate respirator eyeglasses should be maintained available.
Also, contact lenses shall not be worn in any Respiratory Protection Device.
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Corrective Action To Be Taken To Avoid Further Noncompliance:
3 The proposed policy regarding use of respiratory protection equipment will,be implemented upon approval by the NRC.
The Date When Full Compliance Will Be Achieved:
i The date of full compliance is dependant on the.results of the NRC a
review of the proposed policy but will be no later than 30 days following said approval.
3.3
" Appendix A, cards 5 and 6, " Fire Emergency Actions and Respons
- i-ties," of the fire protection implementing procedures do not quire the fire brigade leader. or other fire brigade members to re ond to ractice ' drill or actual fire scenes wearing protective nout coats l
o OSHA hard hats."
i Response to I m No. 3a.3
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Correctiv etion Taken and Results Achieved:
Section 5.6 of e Fire Protection Imple ting Procedures states i
"Selfcontained b thing units shall b orn for protection against i
airborne activity, gen deficient a as, toxic gases or when j
specified by the Prop ty Protectic Supervisor or brigade leader."
Appendix A, Card 5 (Fir Brigade ader) states "His isusediate actions
)l are to don a self-contain br
.hing apparatus and bring the caddy to the scene of the fire."
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We concur that protectiv cloth and respiratory equipment are important and should b worn when hting fires. However, the NRC's concern is that all igade members sponding to a fire alarm should be required to fi put on protective othing and respiratory equipment.
4 We believe at response to a fire alarm shou be immediate without i
undue del The detectors in use at Big Rock at are very sensitive and if ere is a fire, it could still be small en h that a fire extin isher could put it out.
If time is taken to to a fire depot to a protective clothing and respirator, fire brigad embers might i
a ive five or ten minutes later to the fire and the fire re I
avolved.
Presently, the brigade leader dons protective clothing and a re rator and reports to the scene. Normally, an Auxiliary Operator would l
oc1282-0113a142-123 i
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