ML20153C305

Requests Exemption from 10CFR20.501,App A,Footnote d-2(c) to Allow Use of Air Purifying Respirators in Lieu of Supplied Air or self-contained Breathing Apparatuses.Fee Paid

ML20153C305
Person / Time
Site:	Vogtle
Issue date:	08/26/1988
From:	Hairston W GEORGIA POWER CO.
To:	NRC OFFICE OF ADMINISTRATION & RESOURCES MANAGEMENT (ARM)
Shared Package
ML20153C307	List: ML20153C305 ML20153C497
References
TAC-71145, TAC-71146, VL-41, NUDOCS 8809010083
Download: ML20153C305 (6)

Text

1 Ge:wg'a Fbwer Company

,b ~ *g 333 P.edmont Avenue A*tarta. Georg:a 30304 Vernone 404 5264506 s <e 545 A:!anta, Gevg a 30302

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twer creat,ons YL-41 0018e X7G.117-V000 August 26, 1988 U. S. Nuclear Regulatory Commission ATTN: Document Control Desk Washington, D. C. 20555 PLANT YOGTLE - UNIT 1 NRC DOCKET 50-424 OPERATING LICENSE NPF-68 EXEMPTION REQUEST - WORKER RESPIRATORY PROTECTION APPARATUS Gentlemen:

In accordance with the provisions of 10CFR 20.103(e) and 10CFR20.501, '

Georgia Fower Company (GPC) hereby requests an exemption from 10CFR20, Appendix A, footnote d-2(c) which states, with respect to establishing pSrsonnel protection factors, "No allowance is to be made for the use of solvent canisters against radioactive gases and vapors." GPC proposes to use a protection factor equal to 50 for solvent iodine canisters in an atmosphere cor'aining radiof ocine. A safety analysis is provided as Attachment 1 which demonstrates the exemption will not result in an undue hazard to life or property.

The requested exemption would allow utilization of air purifying ,

respirators in lieu of supplied air or self-contained breathing apparatuses.

The air purifying respirators, MSA GMR-I canisters, which GPC proposes to use L would be manufactured by Mine Safety Appliance Company. A copy of the MSA  !

test report is included as Attachment 2 to this letter.  !

@@ Previously. Alabama Power Company, Southern California Edison Company, c)o Kansas Gas and Electric Company, Union Electric Company, Pacific Gas and g:e Electric, and the Grand Gulf Nuclear Station have been issued exemptions that o8 allow the use of the MSA GMR-! canister. Additionally, the Washington Public l g

o Power Supply System has also requested an exemptir a allowing the use of these can'sters.

j O$ 10CFR20.103(e) allows the Comission to authorize the use of equipment 3" which has not been certified by NIOSH/MSHA but which has been tested reliable >

under proposed conditions of use. The MSA GMR-I canister has been adequately l tested, as evidenced by the MSA tests and previously granted exemptions. GPC A '

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GeorgiaPoner A ,

U. S. Nuclear Regulatory Connission August 15, 1988 Page Two asks that this request for an exemption ce acted on by the NRC by September 15, 1988 to allow the use of these canisters in Plant Yogtle's initial refueling outage which is scheduled to begin October 7,1988.  ;

jl i Pursuant to the requirement of 10CFR170, a check for $150 is enclosed.  ;

t Sincerely .

W Y

I. W, G. Hairston, III

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Enclosures:

1. Safety Analysis '

2. MSA Test Report j 3. GPC Check ($150)

c: Georgia Power Cogany  :

Mr. P. D. Rice ,

Mr. G. Bockhold, Jr.  !

Mr. M. Sheibant '

Mr. J. P. Kane

! GO-NORMS I  !

NORMS l U. S. Nuclear Regulatory Connission Dr. J. N. Grace, Regional Administrator Mr. J. B. Hopkins, Licensing Project Manager, NRR (2 copies)

! Mr. J. F. Rogge Senior Resident Inspector - Operations, Yogtle 1

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ENCLOSWE 1 TO VL-41 t

PROPOSAL FOR EXEMPTION FROM 10 CFR 20, Appendix A. footnote d-2(c)

! Allowing Use of the GMR-I Canister Against Radioiodine 1 L i

ABSTRACT: i This proposal is a request for exemption from 10 CFR 20,  :

Appendix A, footnote d-2(c) in accordance with 10 CFR 20.103 (e) and i will cover Georgia Power's facility Vogtle Electric Generating Plant l Units 1 & 2. The desired conclusion is the use of the MSA GMR-1 '

canister and a full facepeice,-that has the capability of providing. ,

a protection factor of 50 or greater, to achieve a protection factor '

of 50 against radioactive iodine and.particulates.

, J US TI FICf. TIC N :

, The benafite associated ic using the GMR-I over Air-Lines or (

, SCBA's a re an increase in worker safety and a reduction in worker l 4

exposure o radiation.

WORKER SAFETY is greatly improved by (1) reducing the respiratory  !

j protection equipment weight causing a decrease in probability for '

i back injury or falling / tripping injury, (2) eliminating accidents i j caused by a loss of air situation, (3) reducing worker fatigue by  ;

i deleting entangled air lines, uncomfortable harnesses and eye <

irritation caused by the air flow. (4) reroving the false feeling of j coolness caused by the air flow across the face that can leadoto (

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heat s tro k s and eventually fainting, and (5) reducies' workers time (

in the respiratory protection equipment by 22-50% Jue to the  :

, increased work efficiency. 1 Exposure Reduction is achieved by the decrease in work time to the I corrasponding measures of 25-50t in cases that normally require the  !

use of Air-lines or SCBA applications.

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l OPER.'. TING CONDITIONS:

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With guidance frqa NUREG/CR-3403, the following precautions and l

! limitations are proposed:  !

i (1) The maximum permissible continuous use time for a GMR-I esnister is eight (8) hours after which the canister is discarded. This j time will be calculated from the moment the canister ir j unsealed, and will include periods of non-exposure.

1 (2) The GMR-I canister will not be stored or used in the pre:ence of l organic solvent vapors. Procedure vill deny ?.he use or storage

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of these canisters in areas that painting or use of erganic j vapors / chemicals is in progress or has recently oeen complettd.

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.3 d (3) The storing of the GMR-I canisters will be in a ClaeJ A or better environment, as defined in ANSI N45.2.2, by the manufacture, any third party distributors and the licenses. All orders placed for GMR-I canisters, that will be used for radioactive iodine protection, will state this condition.

(4) The GMR-I canister will be used with a full facepeice capable of providing a protection factor equal to or greater than 50.

(5) The GMR-I canister will not be used in temperatures greater than 110 degrees Fahrenheit or up to 120 degrees Fahrenheit if the dewpoint is equal to or less than 107 degrees Fahrenheit.

Temperatures will be measured prior to a.4/or during the use of the GMR-I canister to assure the working temperatures are within limits.

(6) Air samples will be taken prior to and during any activities that invcive the use of the GMR-I canister for protectica age. inst radioactive iodine.

(7) The organic vapors and chemicals of concern relative to GMR-I canister use at Vogtle Electric Generating Plant Xylene 111 Trichloroethane Naphthalene Methyl Ethyl Ketone Methylnamyl Ketone Toluene Cychohexanone Acetone 4

Trichlorofloroethane Butanone These vapors and chemicals are not of concern in areas where GMR-I canisters will be routinely stored. The canisters are purchased in a hermetically sealed condition and are not opened until placed in service.

Vogtle Technical Specification 4.7.7 defines the availability and surveillance requirements related to the Auxiliary Building Radiation Area Filter Exhaunt and Continuous Exhadst 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 1.52 for design, testing and mainterance of filtration systems. Tt.e s e requirements are utilized to demonstrate system operability with [

respect to HEPA and charcoal filters. Since GMR-1 canister will be in the same areas served by these systems, assurance of continuing t operability of these systems will provide assurance of a proper  !

environment (i.e., no organic vapors or chemicals) for GMR-I canister use.

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A. m (8) A GMR-I canister found to have exceeded 3 years from date of manufacture will not be used for protection against radioactive iodine.

PROGRAM IMPLEMENTATION:

In the initial implementation of the GMR-I program, the following verification measures will be in effects

a. Weekly whole body counts for individuals using the GMR-I canisters for radioiodine protection.

b. A whole body count for individuals that exceed 10 MPC in a week and used the GMR-I canister for respiratory protection in that period.

c. Anyone that measures 70 aci or greater iodine uptake to the thyroid during a whole body count will be restricted from entering a radioiodine atmosphere pending Health Physics evaluation.

d. The radiological survey and whole body count informatior will be compiled to evaluate the effectiveness of the program.

These precautions will be relaxed as the data proves the effectiveness of the program.

RADIATION WASTE REDUCTIONS:

Due to the greater volume of the GMR-I c anister over a standard particulate filter, the particulate filter will normally be used in situations permitted to reduce the generation of radioactive vaste. -

PROCEDURES AND TRAINING:

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Upon approval, procedures will be created or revised to define I the proper storage, issuing and use of the GMR-I canister prior to ,

program implementation. These revisions will include the I restrictions and limitations of the GMR-I canister that has been formulated in the proposal. The procedures that wil.1 be modified i are Departmental VEGP 47001-C and Administrative VEGP 00970-c. l Training of the workers on the proper use and the limitations of the i GMR-I canister will be performed prior to issuing and shall be l incorporated into the GET respirator training program. The Health Physics staff will be qualified on the procedures and shall receive training on the characteristics of the GMR-I canister.

Additionally, onsite Quality Assurance audits and surveillance of the Tespiratory Protection Program will be expanded to include GMR-I canister use and associated procedures and controls. ,

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. ENGINEERING CONTROLS:

This proposal does not lessen the responsibilities of the licensee in the use of engineering controls to relieve the needs for repiratory protection as required in 10 CFR 20.103 (b) (1). These measures include but are not limited to, degasification of the reactor coolant system, crud burst clean up, process to confine or eliminate airborne radioactivity, delay breacher of primary systems to allow decay of radioisotopes and area decontamination to decrease possibilities of generating airborne radioactive material.

QUALITY ASSURANCE:

The Qualit y Aa r,u rance program established and maintained by the Mine Safety Appliances Company is sufficient in supplying the GMR-I canister in proper operating condition. Only canisters covered by the MSA GMR-I Quality Assurance program will be used for tne protection against radioactive iodine. To ensure that the MSA GMR-I canisters meet standards for quality control, procedure number 47001-C or a Departmental Instruction will require personnel verify that for each canister used with the protection facter that the seal is intact, the canister shelf life has not expired asd the following MSA label is attached to the GMR-I canister:

"This canister meets the NRC Quality Assurance Specification required for Radioiodine Protection Factor Credit, in addition to the NIOSMiMSHA Requirements. Credit may only be taken by licensees whc have been granted a NRC Exemption."

TEST DATA:

This proposal is based on studies performed by the Mine Safety Appliances Company, Attachment i 1, and NUREG/CR 3403, Attachment i 2 and structured after NRC approved programs at Alabama Power Company and Union Electric Company. The parameters of the studies specifically air temperature and humidity, con r the conditions that exist at Vogtle Electric Generating plant.

CLOSING STATEMENT:

This proposal is based on data and contains the controls deemed acceptable by the NRC as 4 proper GMR-I canister program. This exemption will allow Georgia Power Company to increase worker aarety, h/ a decrease in work stress and radiation exposure, without offecting the safety of the general public. This proposal also acts as notitication of GMR-I canister use 30 days precedias exemption approval 4

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