ML18093A677

Requests Exemption from 10CFR20,App A,Footnote d-2 to Allow Credit for Radioiodine Protection Factor in Employing Use of MSA 466220 GMR-I Canister for Respiratory Protection.Fee Paid

ML18093A677
Person / Time
Site:	Salem, Hope Creek, 05000000
Issue date:	02/22/1988
From:	MILTENBERGER S Public Service Enterprise Group
To:	NRC OFFICE OF ADMINISTRATION & RESOURCES MANAGEMENT (ARM)
References
NLR-N88024, NUDOCS 8802290056
Download: ML18093A677 (6)

Text

Public Service Electric and Gas Company Steven E. Miltenberger Vice President

-Public Service Electric and Gas Company P.O. Box 236, Hancocks Bridge, NJ 08038 609 339-4199 Nuclear Operations February 22, 1988 NLR-N88024 United States Nuclear Regulatory Commission Document Control Desk Washington, DC 20555 Gentlemen:

10CFR20 IODINE ABSORBENT CANISTER EXEMPTION REQUEST SALEM GENERATING STATION UNIT NOS. 1 AND 2 HOPE CREEK GENERATING STATION DOCKET NOS. 50-272, 50-311 AND 50-354 Pursuant to 10CFR20.103(e) and 10CFR20.501, Public Service Electric and Gas Company (PSE&G) hereby applies for exemption to 10CFR20, Appendix A, footnote d-2 (c) to allow credit for a radioiodine protection factor in employing the use of MSA 466220 GMR-I canister for respiratory protection.

This exemption is desiiable since it will enable us to reduce our workers' total radiation exposures.

This is consistent with PSE&G's commitment to keep exposures ALARA. 10CFR20, Appendix A, "Protection Factor for Respirators" does not recognize the use of air-purifying respirators for protection against radioiodine and footnote d-2 (c) specifically prohibits this practice.

However, PSE&G is aware of research sponsored by the USNRC -Occupational Radiation Protection Branch, reported in NUREG-CR3403, that has been accomplished to certify air-purifying respirators against radioiodine.

To be consistent with this, NUREG-CR3403 position, PSE&G will implement the following limitations and precautions in its Radiological Program and associated procedures when protection against iodine is implemented:

1. A protection factor equal to 50, as a maximum, will be assigned to the GMR-I canister.

2. The canister allowable service life of eight hours will be calculated from the time of unsealing the canister, including periods of non-exposure.

Document Control Desk 2 02-22-88 3. Canisters will not be used in the presence of organic solvent vapors. Painting or the use of organic substances will be prohibited while the GMR-I canister is in use. 4. Canisters will be used only with a full facepiece respirator proven capable of providing the individual with a protection factor greater than 100 by a quantitative respirator fit test in accordance with the existing procedure.

5. A whole body count will be given to individuals who exceed the level specified by procedure, prior to their next entry into a radioiodine atmosphere.

6. Function and proper usage of the MSA GMR-I canister will be added to respirator protection training courses. 7. Prior to issue, each canister will be inspected in accordance with the appropriate procedure.

The estimated dose savings for a typical task at Hope Creek is given in Attachment

1. The results show a net dose savings of approximately 1000 person-mrem for a reactor vessel head lift when using a full face respirator with GMR-I canisters instead of a SCBA or air line respirator.

PSE&G realizes that the use of the GMR-I canisters are in addition to engineering controls for minimizing iodine exposures.

Engineering controls will continue to be emphasized for exposure reduction.

Presently, the following measures are employed to minimize airborne iodine: 1. Engineering Controls:

Negative pressure ventilation blowers are used when needed to reduce airborne contamination in general work areas where the reactor coolant system (RCS) is breached.

Upon shutdown for an outage, the containment purge system may be operated to reduce general airborne contamination to as low as practical.

At Hope Creek, mechanical vacuum pumps are also used to reduce airborne activity in the condenser bay. Barrier fuel at Hope Creek is the primary defense against radioiodine buildup in reactor coolant. 2. Degasification:

At Salem, normal shutdown procedures require degasification of the RCS by venting the pressurizer vapor space and educting the reactor vessel head. Both processes remove and reduce radioactive gas concentrations including iodine. At Hope Creek the primary system is continuously vented; thus maintaining iodine concentrations at a minimum.

.. Document Control Desk 3 02-22-88 3. Decay Schemes: Maintenance planning for outage items includes consideration of decay times for nuclides of concern, particularily iodine, prior to major breaches of primary systems. If practical, time is allowed for reduction by decay prior to work commencement.

4. System and Area Decontamination:

Prior to commencing outage maintenance, time is allotted to decontaminate affected areas. Surveys are conducted frequently during maintenance activities and cleanup/decontamination is conducted accordingly.

At the end of each outage, time is allotted for decontamination of maintenance areas as well as for overall decontamination of containment surfaces.

In accordance with 10CFR170.12, enclosed is the required application fee of $450.00. If you have any questions regarding this matter, do not hesitate to contact us. Sincerely, Attachment C Mr. G. w. Rivenbark USNRC Licensing Project Manager -Hope Creek Mr. R. w. Borchardt USNRC Senior Resident Inspector

-Hope Creek Mr. D. c. Fischer USNRC Licensing Project Manager -Salem Mr. T. J. Kenny USNRC Senior Resident Inspector

-Salem Document Control Desk 4 C Mr. w. T. Russell, Administrator USNRC Region I Mr. D. M. Scott, Chief Bureau of Nuclear Engineering Department of Environmental Protection 380 Scotch Road Trenton, NJ 08628 02-22-88

.. STATE OF NEW JERSEY COUNTY OF SALEM ) ) ) SS. Steven E. Miltenberger, being duly sworn according to law deposes and says: I am Vice President and Chief Nuclear Officer of Public Service Electric and Gas Company, and as such, I find the matters set forth in our letter dated February 22, 1988 , concerning our response to NRC Compliance Bulletin 87-02, are true to the best of my knowledge, information and belief. Subscribed and Sworn to before me of , 1988 ,_

Notary Public of New Jersey My _Cp!Jl.m-ission expires on EILEEN M. OCHS NOTARY PUBLIC OF NEW JERSEY My Commission Expires July 16, 1992 jJ ' '

• Respirator SCBA/ AIRLINE GMR-I NONE ATTACHMENT l TABLE I -HOPE CREEK VESSEL HEAD LIFT WHOLE BODY DOSE RATE (Cavity) 200 rnR/hr Respiratory Task Time Protection Whole Body Thyroid (Person-hrs)

Factor (person-rnrern) (person-rnrern) 10 2000 2000 0.075 5 50 1000 1.5 3 1 600 45 Total Savings vs. SCBA/AIRLINE (person-rnrern)

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