ML20134G205

Advises That,By 850805,revised Facial Hair Policy Will Be Implemented to Require Nuclear Plant Fire Brigade Members & Radiation Protection Personnel Responding to Fires to Remain Clean Shaven in Area of Respirator Facepiece Seal

ML20134G205
Person / Time
Site:	Big Rock Point File:Consumers Energy icon.png
Issue date:	07/29/1985
From:	Vandewalle D CONSUMERS ENERGY CO. (FORMERLY CONSUMERS POWER CO.)
To:	James Keppler NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION III)
Shared Package
ML20134G202	List: ML20134G200 ML20134G205 ML20134G211
References
NUDOCS 8508230167
Download: ML20134G205 (2)

Text

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General offices: 1945 West Parnall Road, Jackson, MI 49201 * (517) 788-0550

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- FIL D July 29, 1985 James G Keppler, Administrator Region III US Nuclear Regulatory Commission 799 Roosevelt Road Glen Ellyn, IL 60137 DOCKET 50-155 - LICENSE DPR BIG ROCK POINT PLANT -

FACIAL HAIR POLICY IMPLEMENTATION Consumers Power Company has reviewed the information you provided in the "IA-85-650, Requests Review of Unmonitored Liquid Release of Co-60, Mn-54,Cs-134 & Cs-137 to Onsite Soil at Facility to Determine Whether Licensee Request,Per [[CFR" contains a listed "[" character as part of the property label and has therefore been classified as invalid.,required|March 14, 1985 letter]] from C J Paperiello and the October 31, 1984 memorandum from L R Greger to S Guthrie, Sr, copies of which are attached.

The October 31, 1984 memorandum was a response to a request for legal interpretation from officials of the union representing a number of plant employees.

It included a clarification of OSHA regulations concerning respirator usage and facial hair which stated "any hair growth in the face sealing area is unacceptable." It continued, "It is obvious that, if workers' duties involve emergency response activities, where respirator usage may be required, they must remain clean shaven if they are to respond quickly to emergencies." This is important not only for-the safety of the employees

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involved, but also for the safety of their fello workers and the general public.

Based on review and evaluation of the "IA-85-650, Requests Review of Unmonitored Liquid Release of Co-60, Mn-54,Cs-134 & Cs-137 to Onsite Soil at Facility to Determine Whether Licensee Request,Per [[CFR" contains a listed "[" character as part of the property label and has therefore been classified as invalid.,required|March 14, 1985 letter]] and the October 31, 1984 memorandum and their attachments, the Company has concluded that fire brigade members and radiation protection personnel assigned to respond to a fire are required to respond quickly to emergencies where respirator usage may be required. Hence, they must remain clean shaven in the area of the facepiece seal at all times.

Therefore, by August 5, 1985, Consumers Power Company will implement a revised facial hair policy requiring nuclear plant fire brigade members and radiation protection personnel responding to a fire to be and remain clean shaven in the area of the respirator facepiece seal at all times.

8508230167 850816 PDR ADOCK 05000155 F

PDR JUL 31685 0C0785-0253-NLO4

l James G Keppler, Administrator 2

Big Rock Point Plant Facial Hair Policy July 29, 1985 In addition, the Company will continue to require all other individuals to be clean shaven in the area of the respirator facepiece seal each time they are required to wear a respirator.

It is anticipated that this policy will be contested by the employees or their union. The Company requests that you be prepared to provide a witness to testify as to the necessity for this policy. Please notify me as to the name, address and telephone number of the witness you will provide.

d.Ldeuh1L David andeWalle Director, Nuclear Licensing CC. Director, Office of Nuclear Reactor Regulation Director, Office of Inspection and Enforcement NRC Resident Inspector - Big Rock Point Attachment OC0785-0253-NLO4

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NUCLEAR REGULATORY COMMISSION 2

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NUCLEAR UCENSING GLEN ELLYN, ILLINOIS 60137 5,,

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Docket No. 50-155 Consumers Power Company ATTN: Mr. R. B. DeWitt Vice President Nuclear Operations 212 West Michigan Avenue Jackson, MI 49201 Gentlemen:

In a letter to the Region III office dated October 12, 1984, you informed Region III of your intent to delay implementation of Consumers Pcwer Company's revised facial hair policy pending clarification of the requirements.

Attached is a November 2, 1984 memorandum from R. L. Baer, Chief, EGCB, IE, to all five regions concerning regulatory prohibitions against the use of tight-fitting respirators if facial hair intrudes into the facepiece seal against the skin.

Based on this information and your November 2,1984 letter, please inform us of your plans for implementation of your revised facial hair policy.

Sincerely, A$

C. J. P periello, Chief Emergency Preparedness and Radiological Protection Branch

Attachment:

As stated cc w/ attach:

D. J. VandeWalle, Director Nuclear Licensing D. P. Hoffman, Plant Superintendent DMB/ Document Control Desk (RIDS)

Resident Inspector, RIII Ronald Callen. Michigan Public Service Comission Nuclear Facilities and Environmental Monitoring Section 1

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NOV 2 1984-1 MEMORANDUM FOR:

Ronald R. Bellamy, Chief, RPB, DETP, RI Douglas M. Collins, Chief. EPRPB *DRSS, RII Carl J.- Paperiello, Chief. EPRPB, DRSS, RIII Ramon E. Hall, Chief, TPB, DVTP, RIV.

Frank A. Wenslawski. Chief, RSB, DRSSP, RV LeRoy R. Norderhaug, Chief. SEPB, DRSSP, RV FROM:

Robert L. Baer, Chief. EGCB, DEPER, IE

SUBJECT:

OSHA INTERPRETATION: BEARDS AND TIGHT-FITTING RESPIRATORS In response to a Region III April 1983 request for technical assistance.

DIE issued a memorandum (Cunningham to Greger, September 8,1983) providing a broad technical basis to support the position for prohibiting bearded-users from wearing SCBA's. However, at that time, a strict legal reading of NRC regulations led us to conclude that as long as a no respirator protection l

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factor was assumed we could not prohibit a bearded-individual from wearing a l.

respirator.

The controversy over bearded fire brigade members at a Region III facility has continued and a recent OSHA written interpretation on the subject has surfaced.

The enclosed OSHA reading is clear and direct--OSHA's 29 CFR 1910.134(e)(5)(1) prohibits facial hair _in the seal area. We recommend that if recalcitrant licensees continue to allow bearded Emergency Response / fire brigade individual to wear tight-fitting respirators after being informed of this OSHA inter-pretation, the region should refer this nonradiological respiratory problem to the appropriate regional OSHA authorities, in accordance with Chapter 1007 of the IE manual (Interfacing Activities Between Regional Offices and OSHA) of the j

IE manual.

f By separate correspondence to RES we plan to recomend RES change the tegfhts,Jaffo l

to expressly forbid facial hair in the seal area of tight fitting respire If you have any further questions tigertjing this matter, please ch!h:!

l Jim Wigginton.

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• th&t eI JiYttlobe1 Chigf 9

Ifnerg@Dfy 44 f+406fff fe m!bl(ations Branch Divisi0ft6( 'trergency h eparedness l

._qI g y, g c and Engineering Responits It t

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Multiple Addressees. NOV 2 884

Enclosures:

As stated cc:

J. M. Taylor, IE E. L. Jordan, IE S. A. Schwartz, IE E. L. Blackwood, IE R. L. Baer, IE D. P. Allison, IE J. E. Wigginton, IE L. J. Cunningham, IE L_.Jendricks. 'IE W. Greger, RIII

0. Lynch, NRR P. Loysen, NMSS L. 1. Cobb, IE R. Alexander, RES Office of General Industry Compliance Assistance, OSHA e

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.7 -',IJ.di. Department of Labor occupational sarery ana weertn Aar

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Reply to the Attenton of-J DEC 13 883 Ms. Melodye Turek Manager Occupation 11 Safety and Health Edison Electric Institute

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1111 19th Street, N.W.

Washington, D.C.

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Dear Ms. Turek:

N ^}NThis'is in response to your letter of November 22, 1983, concerning bea-:'s and respirator facepiece fit.

Our regulation concerning the ;rchibition cf ~ te grwa. cf facial hair e.

the respirator seal surface 1: :2 nr and mant ; cry, 29 CFR 1910.134(e)(5)(1). The answe

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the employ e is in v M t1 of the idad if empicyees are allowed to we: raspirater ser fact Mi. at the sealing sur: ace of the ree;1 rater.

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Yes', qualitative fit tests are highly 5.njective. Furthu ::re, the errors associated with this typs ting are gene ^dly high.

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isfact: c fit any tign; 1; ting res;1ran-r is worn. L:::

fitting n e i !T; :crs, su:-

s powered cir-purifying r i sirators e:: su;a.ied air respro : cts, are acce table to wer' ar conditient stich are not immediatr:r dangu our life c-heal h, since the inle.

covering a these r4e ators L direct contact with c

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.tained L ning apparatus is also

ceptable for emergent -itape fc:

bearded person.

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14. 3,lr to it. Ass. #.inue t,t JR 131983

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Harry C., Busse!!, Col. USAF, BSC Command Bioenvironmental Engineer Office of the Surgeon w-

.<Departnst of the Air Force Headquarters Air Force 1.ogistics Command Wright-Patterson Air Force Base, Ohio 45433

. bear Colonel Russell We are providing answers to the questions on beards and respirator wear which you asked in your letter of June 20,1983, a.

Yes, any f acial hair growth between the f acepiece sealing surf ace and the skin that prevents a good sealing surface is a violation of 29 CFR 1910.134(e)(3)(i).

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The OSHA stand' ard is a minimum standard. Any employer can set more stringent requirements than OSHA's. If the bearded employee is exposed 9(.

to a toxic material in excess of the Air Force standard but within the OSHA standard, the respirator should not be worn until the interferring hair is removed because the Air Fcrce standard would have been violated even if the OSHA standard were not.

c.

Yes, the situation described in your section C is still a violation of 1910.134(eX5)(i). The question is not whether the bearded person can pass the fit test on a given day, but whether he can pass the test everyday.

Since the c;ensity and texture of the beard is not uniform around the face, and because the density and bulk of beard is not the same over time, consistent fit test results cannot be obtair.ed. Quantitative fit testing (QNFT)is the only available method which can accurately measure the fit testing result of a respirator. It is a time consuming process. The equipment is rather expensive and needs trained personnel to operate it.

For these reasons, the QNFT is generally conducted only annually, it is unreasonable to require the employer to concuct QNFT everyday to determine whether a satisfactory fit caa be obtained from a bearded individual. Qualitative fit testing woultyield less reliable results.

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OSHA's position is that any hair growth'in the face sealing area is unacceptable. Depending on the grow.h, density and texture of beard, noine bearded individuals cannot achieve a satisfactory seat even at the end of the shif t.

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The language on beards and respirator wearing is adequate in

!#10.134(eX5)(i). The third sentence in this paragraph only provides a partial list of the conditions that prevent a good face seal. The second sentence clearly prohibits respirator useDhen any such condition is pregnt. Since the Air Force can adopt a standard which is more stringent 3

than ours, you may consider adopting the current American National

~ 5tandud Practices for RespiratoryYrotection, /.N51288.2,1980

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(enclosed).

We are also enclosing two research papers on facial hair and a publication from the Fire Fighters Union which includes two U.S. Supreme Court decisions on the facial hair Issue for your reference.

Sincerely,

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ifhtiL' ard 3. Baier Director Technical Support, Enclosure.s

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