ML20246B100
| ML20246B100 | |
| Person / Time | |
|---|---|
| Site: | Rancho Seco |
| Issue date: | 06/28/1989 |
| From: | Virgilio M Office of Nuclear Reactor Regulation |
| To: | SACRAMENTO MUNICIPAL UTILITY DISTRICT |
| Shared Package | |
| ML20246B095 | List: |
| References | |
| NUDOCS 8907070200 | |
| Download: ML20246B100 (9) | |
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UNITED STAIES OF AMERICA l
NUCLEAR REGULATORY COMMISSION
'In the Matter'of SACRAMENTO MUNICIPAL UTILITY DISTRICT
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Docket No. 50-312 (RanchoSecoNuclearGenerating L
Station)
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EXEMPTION I.
The Sacramento Municipal Utility District holds Facility Operating License-No. 0PR-54, which authorizes operation of the Rancho Seco Nuclear Generating Station. ' The license provides among other things, that the facility is subject to all' rules, regulations and Orders of the Nuclear Regulatory Commission (the
. Commission) now or hereafter in effect.
This facility is a pressurized water reactor located in Sacramento County, California.
II.
Appendix A of 10 CFR Part 20 defines protection factors for respirators.
Footnote d-2(c) of this Appendix states that "No allowance is to be made for the use.of sorbents against radioactive gases or vapors."
By submittal dated November 17, 1988, the Sacramento Municipal utility District (the District, or.the licensee) requested an exemption to 10 CFR Part 20, Appendix A, footnote d-2(c). The licensee submitted this request in accordance with 10 CFR Part 20.103(e).
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Test data'and canister _ qualification information obtained from the
- canister vendor, Mine Safety Appliances Company (MSA), nave been provided by the District. This data was also submitted in conjunction with similar exemption requests by Alabama Power Company for the Joseph M. Farley Nuclear Plant, Units 1 and 2 (Docket Nos. 50-348 and 50-364) and Southern California l
Edison Company for San Onofre Units 1, 2 and 3 (Docket Nos. 50-206, 50-361 1
and 50-362)
-The District has provided a detailed submittai responding to all NRC staff concerns relating to the request for exemption to 10 CFR Part 20, Appendix A, footnote d-2(c).. The exemption would allow the use of a radio-iodine protection factor of 50 for MSA GMR-I canisters at Rancho Seco Nuclear Generating Station. Criteria and background information used for our evaluation include 10 CFR Part 20.103; 10 CFR Part 19.12; Regulatory Guide 8.15 " Acceptable Programs for Respiratory Protection"; Regulatory Guide 8.20, d
" Applications of Bioassay for 1-125 and I-131"; NUREG/CR-3403, " Criteria and
. Test Methods for Certifying Air Purifying Respirator Cartridges and Canisters Against Radioiodine", and Regulatory Guide 8.8, "Information Relevant to i
Ensuring That Occupational Radiation Exposures at Nuclear Power Stations Will Be As Low As is Reasonably Achievable." Our discussion and evaluation of the request for exemption follows.
Since a NIOSH/MSHA testing and certification schedule for sorbents for use for protection against radiciodine gases and vapors has not been developed, NRC staff has evaluated the District's request and veritied that the licensee i
has demonstrated by reliable test data and adequate quality assurance rneasures l
that the material and performance characteristics of the MSA GMR-1 canister can provide the proposed degree of protection (i.e., a protection factor of i
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- 50) under the anticipated conditions of use, as required by 10 CFR Part 20.103(e), 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 of temperature, poisons, relative humidity, challenge concentration and breathing rates on canister efficiency and service life.
The programmatic evaluation considered quality control / quality assurance, and radiation protection /ALARA considerations, including task preparation and planning, on-the-job and post-task evaluations, use of engineering controls, radiological surveillance, and radiological training.
The licensee has provided reliable test information which verifies that the MSA GMR-I 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 compounds does not exceed l
1 ppm, and temperature does not exceed 110 F.
The data provided by MSA showed the breakthrough point to be well beyond 8 hours9.259259e-5 days <br />0.00222 hours <br />1.322751e-5 weeks <br />3.044e-6 months <br />.
Testing has been conducted under acceptable conditions of cyclic flow, and under worst case conditions for those environmental factors affecting service life:
temperature, relative humidity, and challenge concentration of
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CH 1 (methyliodide/ methyl radiciodide), which is the most penetrating of the 3
challenge forms. Data provided from MSA indicate that the MSA GMR-I canisters perform adequately under the accepted test conditions.
These conditions - the criteria and test methods - are consistent with those derived for the canisters j
by the staff froc NtJREG/CR-3403, and are acceptable.
The licensee, through acceptance of MSA QA controls, has provided commit-ments that the MSA-GMR-I canisters will meet standards for quality assurance l
and quality control which are recognized by NIOSH, compatible with NRC staft
,m positions, and are therefore acceptable.
This includes a commitment by MSA to establish a 1% AQL (Acceptable Quality Limit) in a 5 to 10 ppm challenge concentration of CH 1, 90% relative humidity,110*F, 64 liters per minute (LPN) 3 pulsed flow, for a maximum service life of 8 hours9.259259e-5 days <br />0.00222 hours <br />1.322751e-5 weeks <br />3.044e-6 months <br /> with no more than 1% of the challenge concentration penetration.
Testing data referenced by the licensee demonstrated that performance (i.e., service lite) of canisters at 90% relative humidity is not expected to be significantly different than performance at 100%
relative humidity and is acceptable.
Coupled with the use of a full tacepiece with the capability of providing a fit factor of greater than 500, to be determined by fit test, the protection factor of 50 is conservative under these conditions.
Canister efficiency will be retained for the radioiodine gas or vapors of interest (CH I' I, H0I) for 3
2 the 8-hour period.
To preclude aging, service life will be calculated from unsealing time, including periods of non-use, and the canister will not be used in the presence of organic solvents or in temperatures in excess of 110 F.
Canisters will be stored in sealed humidity-barrier packaging in.a cool, dry environment, and discarded after the 8-hour use period to prevent reuse.
Through usage restrictions and air sampling, the licensee will preclude exposures to organic vapors and chemicals (such as decontamination components, lubricants, volatilized paint, alcohols, freon) which could cause aging, poisoning or desorption of the absorbed radiciodines.
Certain limitations and precautions based on NUREG/CR-3403 guidance are necessary for utilization of the sorbent canisters. We agree with the
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% following'such 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 which the canister will be discarded.
- 3. 1 Canisters are not to be used in the presence of organic solvent vapors.
4 Canisters. are to be stored in sealed, humidity barrier packaging in a cool, dry environment.*
5.
-The allowable service life for sorbent canisters is to be calculated from the time ot unsealing the canister, including periods of non-exposure.
6.
Canisters are to be used with a full facepiece capable of providing fit factor greater than 500.
7.
Canisters are not to be used in total challenge concentrations of organic iodines and other halogenated compounds greater than 1 ppm, including nonradioactive compounds.
8.
Canisters are not to be used in environments where temperatures are greater than 110 F.
In addition to the limitations and usage restrictions noted above, the following additional controls will be utilized by the licensee:
1.
Temperatures will be measured prior to the beginning of work and coincidently with operations whien heat the work areas to assure that j
1 temperatures do not exceed 110 F during sorbent canister use.
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- 5orbent canisters will be maintained in licensee " Class A" storage as defined in ANSI N45.2.2 (i.e., 70" 10*F; Relative Humidity less than or equal to 40%
Design, less than or equal to 70% Maximum) or an equivalent alternative after receipt on site, except for those maintained for ready issue in the respirator issue area.
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2.
In the initial implementation of sorbent canister use, the following program verification measures will be used:
a.
whule body counts for individuals using the sorbent
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l canister for radioiodine protection will be conducted L
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routinely (e.g. weekly and at 20 MPC-hours).
b.
an investigation level for radioiodine uptakes has been established at 30 nCi.
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Radioiodine data will be trended to detect problems.
3.
painting or the use of organic substances will be prohibited while the GMR-I canister is in use.
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Specific plant procedures will incorporate the limitations and usage restrictions, listed as 1 through 8 above, prior to GMR-I canister use. Additionally, training of workers and radiation protection technicians in the use of GMR-I canisters for radiciodine protection will be conducted prior to canister implementation.
l 5.
Existing respiratory protection program requirements and restrictions (e.g., physicals, fit tests, Part 20 requirements including Appendices A and B) still apply.
The primary bases for the District's request for exemption are the potentials for both work effort reduction and dose reduction. The utilization of air purifying respirators in lieu of air-supplied or self-contained apparatus, where possible, can result in person-rem reductions from 25% to 50% for several major tasks. The light weight, less cumbersome air purifying respirators (i.e., sorbent canisters) can provide increased comfort and
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mobility in most cases.
The resultant increased worker efficiency and decreased time on-the-job will provide significant aose sa i v ngs and be an effective as low as is reasonably achievable ( ALARA) measure Other actions taken by the licensee to assure that exposures t iodine are ALARA are:
o radio-radiciodine air sampling will be conducted before and during activities involving the use of GMR-I canisters f i
or radiciodine protection; engineering controls such as local HEPA ventilatio n and the containment purge system used to reduce airborne levels to as lo levels; purification and degasification of the primary cool w as practical ant conducted prior to refueling resulting in reduced radiciodine levels; us e of area decontami-nation, protective coverings, and strippable paint to help cont rol contamination levels; maintenance planning allowing for radiciodine decay ti mes, where practical, prior to breaching primary systems.
Whole body counts will be conducted routinely (e.g., weekly and at 20 MPC hours) and radiciodi wiil be trended to detect problems; an investigation level for radi i d ne data co ne uptakes has been established (at 30 nCi); training of workers and h ealth physics technicians in the use and restrictions for use of GMR I L 1.
canisters for radioiodine protection will be conducted prior to their use
- and procedures delineating the controls, restrictions, and requirements h and will be implemented.
ave been developed The licensee's efforts to keep exposure ALARA are consistent with the positions in Regulatory Guide 8.8 and are acce t bl pa e.
In summary, the NRC staff's review of the licensee's proposal i di that the actions proposed by the District can result in n cates significant dose savings over alternative methods while still providing effective pr t o ection.
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mobility in most cases. The resultant increased worker efficiency and decreased time on-the-job will provide significant cose savings and be an effective as low as is reasonably achievable ( ALARA) measure.
Other actions taken by the licensee to assure that exposures to radio-iodine are ALARA are:
radiciodine air sampling will be conducted before and during activities involving the use of GMR-I canisters for radioiodine protection; engineering controls such as local HEPA ventilation and the containment purge system used to reduce airborne levels to as low as practical levels; purification and degasification of the primary coolant conducted prior to refueling resulting in reduced radioiodine levels; use of area decontami-nation, protective coverings, and strippable paint to help control contamination levels; maintenance planning allowing for radioiodine decay times, where practical, prior to breaching primary systems.
Whole body counts will be conducted routinely (e.g., weekly and at 20 MPC hours) and radiciodine data wiil be trended to detect problems; an investigation level for radioiodine uptakes has been established (at 30 nCi); training of workers and health physics technicians in the use and restrictions for use of GMR-I canisters for
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radioiodine protection will be conducted prior to their use; and procedures delineating the controls, restrictions, and requirements have been developed and will be implemented. The licensee's efforts to keep exposure ALARA are consistent with the positions in Regulatory Guide 8.8 and are acceptable.
In summary, the NRC staff's review of the licensee's proposal indicates that the actions proposed by the District can result in significant dose savings over alternative methods while still providing effective protection.
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This exemption would enable the licensee to use a protection factor for air purifying radiciodine gas and vapor respirators in estimating worker exposures i
from radioiudine gases and vapors. The licensee has provided usage restrictions and controls which can 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 NRC staff criteria. The licensee's proposed exemption, with the controls and limitations, meets the steff posit 1cns in the SRP, NUREG/CR-3403 and Regulatory Guice 8.8, and is acceptable. The actions proposed by the.icensee are consistent with the requirements of 10 CFR Part 20.103(e), and form an acceptable basis to authorire the granting of an exenption in accordance with the provisions of 10 CFR Part 20.103(e).
III.
I.ccordingly, the Comission has determined that, pursuant to 10 CFR 20.501 an exemption is authorized by law and will not result ir. undue hazard to life or property. The (camission hereby grants an exemption from the requirements of Footnote d-2(c) of Apper. dix A of 10 CFR Part 20.
The Comission has prepared an Environmental Assessment and Finding of No Significant Impact related tc this action which was published in the Federal Register on June 26, 1989 (54 FR 26863). The Environmental Assessment concluded that this actior will not have a significant effect on the quality of the human environment, and therefore the Comission has determined not to prepare 1
1 an environmental impact staterrtnt for this exemption.
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For further details with respect to this action, see the licensee's request dated Noverrber 11, 1988, which is available_for public inspection at the Connission's Public Document Room, 2120 L Street, N.W.. Washington, D.C.
and at the Martin' Luther King Regional Library, 7340 24th Street Bypass,
. Sacramento, California.
FOR THE NUCLEAR REGULATORY COMMISSION tk
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Martir['J.' Virgilio Acting Director Division of Reactor Projects - III, IV, V and Special Projects Office of Nuclear Reacter Regulation Dated at Rockville, Maryland this 28th day of June 1989
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