CNRO-2006-00034, Supplement to Request for Use of Delta Protection Mururoa V4F1 R Supplied Air Suits; Arkansas Nuclear One, Indian Point, Grand Gulf, Waterford, FitzPatrick, River Bend, Pilgrim, Vermont Yankee
| ML061980030 | |
| Person / Time | |
|---|---|
| Site: | Indian Point, Grand Gulf, Pilgrim, Arkansas Nuclear, River Bend, Vermont Yankee, Waterford, FitzPatrick  |
| Issue date: | 07/13/2006 |
| From: | Burford F Entergy Operations |
| To: | Document Control Desk, NRC/FSME |
| References | |
| CNRO-2006-00034 | |
| Download: ML061980030 (12) | |
Text
AEntergy Entergy Operations, Inc.
1340 Echelon Parkway Jackson, Mississippi 39213-8298 Tel 601-368-5758 F. G. Burford Acting Director Nuclear Safety & Licensing CNRO-2006-00034 July 13, 2006 U. S. Nuclear Regulatory Commission Attn.: Document Control Desk Washington, DC 20555-0001
SUBJECT:
Supplement to Request for Use of Delta Protection Mururoa V4F1 R Supplied Air Suits Arkansas Nuclear One Units 1 & 2 Docket Nos. 50-313 & 50-368 License Nos. DPR-51 and NPF-6 Grand Gulf Nuclear Station, Unit 1 Docket No. 50-416 License No. NPF-29 James A. FitzPatrick Nuclear Power Plant Docket No. 50-333 License No. DPR-59 Pilgrim Nuclear Power Station Docket No. 50-293 License No. DPR-35 Indian Point Nuclear Generating Units Nos. 1, 2 and 3 Docket Nos.50-003, 50-247, and 50-286 License Nos. DPR-5, DPR-26, and DPR-64 Waterford Steam Electric Station, Unit 3 Docket No. 50-382 License No. NPF-38 River Bend Station Docket No. 50-458 License No. NPF-47 Vermont Yankee Nuclear Power Docket No. 50-271 License No. DPR-28
Reference:
Request for Use of Delta Protection Mururoa V4F1 R Supplied Air Suits (CNRO 2006-00021) dated May 16, 2006
Dear Sir or Madam:
Entergy Operations Inc. and Entergy Nuclear Operations Inc. (Entergy), in the reference above, requested authorization for use of equipment that has not been tested or certified by the National Institute for Occupational Safety and Health (NIOSH). The request was to use Delta Protection's Mururoa V4F1 R Supplied Air Suits. The request was made pursuant to 10 CFR 20.1703(b).
I/W(
CNRO-2006-00034 Page 2 of 3 The NRC staff provided several questions in the form of a draft Request for Additional Information (RAI). On June 16, 2006, Entergy and members of your staff held a phone call to discuss the questions. As a result of that call, Entergy provided answers to the questions and agreed to make several new commitments. The answers to the questions are provided in. Test results to support requested fit factor are provided in Attachment 2. The new commitments provided in Attachment 3 are in addition to the previous commitments made in the original submittal (i.e., the referenced letter). There was one previous commitment that was worded incorrectly. Corrections to that commitment are discussed in the response to Question 6.
Should you have any questions regarding this submittal, please contact Bill Brice at (601) 368-5076.
Very truly yours, FGB/WBB/bal Attachments:
- 1. Response to Request for Additional Information
- 2. Test Results for the MURUROA V4F1
- 3. List of Regulatory Commitments cc: (see next page)
CNRO-2006-00034 Page 3 of 3 cc:
Mr. M. A. Balduzzi (PILG)
Mr. W.R. Campbell (ECH)
Mr. F. R. Dacimo (IPEC)
Mr. J. P. DeRoy (ECH)
Mr. P. T. Dietrich (JAF)
Mr. W. A. Eaton (ECH)
Mr. R. K. Edington (CNS)
Mr. J. S. Forbes (ANO)
Ms. C. L. Gaujacq (ECH)
Mr. J. T. Herron (WPO)
Mr. P. D. Hinnenkamp (RBS)
Mr. M. R. Kansler (WPO)
Mr. 0. Limpias (WPO)
Mr. J. McGaha (ECH)
Mr. C. J. Schwarz (WPO)
Mr. T. A. Sullivan (VY)
Mr. G. J. Taylor (ECH)
Mr. J. E. Venable (W-3)
Mr. G. A. Williams (GGNS)
Mr. J. P. Boska, Project Manager, IP2, IP3, JAF Mr. S. J. Collins, Regional Administrator, Region I Mr. M. B. Fields, Project Manager, WF3 Mr. D. G. Holland, Project Manager, ANO-1&2 Dr. B. S. Mallett, NRC Regional Administrator, Region IV Mr. J. J. Shea, Project Manager, PNPS, VY Mr. B. K. Vaidya, Project Manager, GGNS & RBS Mr. M. K. Webb, Project Manager, IP1 NRC Resident Inspectors (ANO, GGNS, IP2, IP3, JAF, RBS, PNPS, WF3, VY)
American Nuclear Insurers (Attn: Library)
Mr. Bernard R. Bevill (Arkansas Dept. of Health (DRC & EM)
Mr. Paul Eddy (NYS Dept. of Public Service)
LA Dept. of Environmental Quality (OECSD)
Mr. D. E. Levanway (Wise Carter)
Mr. David O'Brien (Vermont DPS)
Mr. J. Smith (Wise Carter)
Mr. Peter R. Smith (NYSERDA)
Mr. H. L. Thomas (SMEPA)
ATTACHMENT 1 CNRO-2006-00034 Response to Request for Additional Information CNRO-2006-00034 Page 1 of 2 Response to Request for Additional Information Question 1 Verify that Entergy commits to notifying the manufacturer (as well as the U. S. Nuclear Industry) of any defects experienced during the use of the MURUROA V4F1 R devices.
Response for Question I Entergy commits to notifying the manufacturer (as well as the U. S. Nuclear Industry) of any defects experienced during the use of the MURUROA V4F1 R devices. This commitment is included in Attachment 3.
Question 2 The last sentence of page 3 of Attachment 1 indicated that Entergy intends to use the V4F1 R suit in a configuration other than that for which it was certified. Specifically that Entergy intends to fit the suits with air hose fittings (Schrader and Foster type) not tested in the referenced certification. Verify that Entergy will use the suit as allowed in the certification (with CEJN or STAUBLI fittings) or provide the results of independent testing by a certifying body that demonstrates that the V4F1 R meets the EN 1073-1 standard.
Response for Question 2 Entergy will use the suit as allowed in the certification (with CEJN or STAUBLI fittings).
Question 3 Provide the testing data that demonstrates that the V4F1 R suit provides a fit factor of greater than 50,000.
Response for Question 3 The test data demonstrating that the suit provides an average protection level (fit factor) of 50,000 is provided in Attachment 2.
Question 4 Page 8 of the EC Type Examination Certificate discusses how the minimum air flow rate was verified through the entire range of air supply pressures (2.5 to 7 bars) allowed for the V4F1 R suit. Is there any limitation on the rate of change of the inlet pressure in terms of the dynamic response of the regulator? If so describe it and discuss how Entergy will ensure that the air supply at each facility meets this limitation.
CNRO-2006-00034 Page 2 of 2 Response for Question 4 There is no limitation regarding the rate of change of the inlet pressure in terms of dynamic response of the regulator. Tests have been carried out by the manufacturer with the regulator seeing incremental step changes in pressure of approximately 14 psi/step. This was done in both increasing and decreasing increments. In addition, instantaneous pressure availability such as going from 0 to 40 PSI, then shutting off the supply and re-establishing it again was conducted, all with success and stability. A test was also conducted at an instantaneous pressure of 140 PSI and then stepping down to the certified pressure range with no negative effects.
Question 5 Section 3.2 of the EC Type Examination Certification (page 12 of 16) indicates under "(t)he limits of use of the MURUROA V4F1 R suit" that "the user will have to provide himself with the necessary devices to check if the minimum air flow rate, as indicated by the manufacture, is reached or exceeded before and during wearing the suit." Describe the instrumentation and procedures that Entergy will implement to meet this limitation of use.
Response for Question 5 Entergy will perform an initial test of their breathable air network system to insure that it has sufficient capacity (minimum pressure and flow) through an established maximum length of hose, prior to the initial use of the Mururoa V4F1 R suit system. This test will establish the conditions at the distribution manifold actually necessary to ensure that the air supplied to the suit inlet is consistent with the conditions for which the equipment was certified. Entergy plants will follow the manufacturer's recommended "Instructions for Use" of the suits, specifically insuring that the minimum operating air pressure 2.5 bar (35 PSI) and airflow 450 I/min (16 CFM) is being supplied to the suits prior to working in them. Pressure will be monitored during use.
Question 6 Item number 4 in the list of commitments in Attachment 2 of the original submittal states that "All suits and cartridges will be treated as "Single Use" only." What cartridges are associated with the MURUROA V4F1 R supplied air suit?
Response for Question 6 There are no cartridges used with the MURUROA V4F1 R supplied air suits. This was an error in the original submittal. The commitment should read, "All suits will be treated as 'Single Use' only." The revised commitment is included in Attachment 3.
ATTACHMENT 2 CNRO-2006-00034 Test Results for the MURUROA V4F1 CNRO-2006-00034 Page 1 of 3 DPEANSTESRICTHEN/97-599 Test Results Carried Out on the Full Encapsulated Suit MURUROAV4F1 ref. 8481X1T For the EC Type Examination Certificate No. 0073/197/162/12/97/0028 Below are the detailed results that demonstrate the conformity of this equipment to the Essential Requirements of the European Standard EN 1073-1. Other results that are not pointed out in this report are already written in the EC TYPE Examination Certificate (dated December 10th, 1997).
- 1. Air Flow entering the suit when connected to a 6 bar feeding pressure (paragraph 2.3.2. of the EC Type Examination Certificate)
Suit number Minimum air flow(l/min)
Maximum air flow (I/min) 1 508 1050 2
516 1070 3
508 1050
- 2.
Carbon dioxide content of the inhalation air when measured at the minimum air flow of 450 I/min (paragraph 2.3.12. of the EC Examination Type)
Suit number Test No. 1 C02 contents(%) Test No. 2 C02 contents(%)
1 0.86 0.93 2
0.68 0.68 3
0.75 0.82 CNRO-2006-00034 Page 2 of 3
- 3. Noise level associated with the air supply to the suit when tested at the maximum air flow rate at 6 bar (paragraph 2.3.13 of the EC Examination Type)
Suit number Maximum air flow(l/min)
Noise level (dB) 1 1050 77.2 2
1070 75.1 3
1050 77.6
- 4.
Inward leakage average-Fit Factor measured at the minimal air flow of 4501/min (paragraph 2.3.3. of the CE Examination Type)
Suit nmber 1
2 3
Exercise Standing still
> 120,000
> 120,000
> 120,000 Walking (5 kmlh) 76,700 90,900 66,000 Moving arms up and down 113,800
> 120,000 113,800 above head Continuous squats 30,000 41,700 50,000 Bending forward 110,000 103,400 91,700 Person twisting at waist
> 120,000
> 120,000
> 120,000 Person crawling 55,000
> 120,000 31,400 CNRO-2006-00034 Page 3 of 3
- 5. Pressure in the suit when measured at the maximum air flow when suit connected under 6 bar feeding pressure (paragraph 2.3.1 1.of the EC Examination Type)
Suit number 1
2 3
Exercise P min(Pa) P Max.
P min(Pa) P Max.
P min(Pa) P Max.
Standing still 275 280 295 305 275 280 Walking (5 km/h) 200 800 300 900 600 900 Moving arms up and down 150 400 160 420 250 800 above head Continuous squats 30 900 30 1050 70 1700 Bending forward 80 1550 60 1900 100 1900 Person twisting at waist 140 500 160 420 160 650 Person crawling 160 900 150 850 250 1050
- 6. Air supply system (paragraph 4 - 6 of EN 1073-1)
In accordance with the paragraph 4.6; the connection between the compressed air supply system and the suit has been tested for a steady pull of 250 N. The three suits have been tested successfully. However, there was some deformation of the fabric near the regulation air flow device. A reinforced area could certainly avoid this deformation.
ATTACHMENT 3 CNRO-2006-00034 List of Regulatory Commitments
List of Regulatory Commitments The following table identifies those actions committed to by Entergy in this document. Any other statements in this submittal are provided for information purposes and are not considered to be regulatory commitments.
TYPE (Check one)
SCHEDULED ONE-CONTINUING COMPLETION COMMITMENT TIME COMPLIANCE DATE (If ACTION Required)
Entergy commits to notifying the manufacturer (as Following well as the U. S. Nuclear Industry) of any defects x
identification experienced during the use of the MURUROA of defects V4F1 R devices.
of defects Entergy will use the suit as allowed in the Before use of certification (with CEJN or STAUBLI fittings).
X suit Procedures for use of the suit systems are integrated into the respiratory programs required by Subpart H of 10 CFR Part 20. Fit testing of user is Before use of not applicable to fully encapsulating suits. Prior to X
suit use, wearers are trained on these conditions of use as well as the emergency escape features of the suits.
Entergy will perform an initial test of their breathable air network systems to insure that it has sufficient capacity (min. pressure and flow) through an established maximum length of hose, prior to the Before use of initial use of the Mururoa V4F1 R suit system. This X
suit test will establish the conditions at the distribution manifold actually necessary to ensure that the air supplied to the suit inlet is consistent with the conditions for which the equipment was certified.
Entergy plants will follow the manufacturers recommended "Instructions for Use" of the suits, specifically insuring that the minimum operating air Before use of pressure 2.5 bar (35 PSI) and airflow 450 I/min X
suit (16 CFM) is being supplied to the suits prior to working in them. Pressure will be monitored during use.
All suits will be treated as "Single Use" only (this Before use of commitment supersedes that of items 4 of X
suit CNRO-2006-00021).
I I