ML030720026

Request for Exemption from 10CFR20. 1703 and 10CFR20 Appendix a, Use of French Designed Respiratory Protection Equipment

ML030720026
Person / Time
Site:	Oconee, Mcguire, Catawba, McGuire
Issue date:	03/04/2003
From:	Mccollum W Duke Energy Corp
To:	Document Control Desk, Office of Nuclear Reactor Regulation
References
Download: ML030720026 (71)

Text

Duke Power SDuke Powier. 526 South Church Street Iftow ower.P.O. Box 1006 A DukeEe Co

• Charlotte, NC 28201-1006 March 4, 2003 U. S. Nuclear Regulatory Commission Washington, DC 20555-0001 ATTENTION: Document Control Desk

Subject:

Duke Energy Corporation Oconee Nuclear Station, Units 1, 2, and 3 Docket Nos. 50-269, 50-270, 50-287 McGuire Nuclear Station, Units 1 and 2 Docket Nos. 50-369, 50-370 Catawba Nuclear Station, Units 1 and 2 Docket Nos. 50-413, 50-414 Request for Exemption from 10CFR20.1703 and 10CFR20 Appendix A Use of French Designed Respiratory Protection Equipment Pursuant to the provision of 10CFR20.2301, "Application for exemptions," Duke Energy Corporation (Duke) is requesting an exemption from certain requirements of 1 OCFR20.1703, "Use of individual respiratory protection equipment" and Appendix A to Part 20, "Assigned Protection Factors for Respirators". The exemption request is provided as an enclosure to this letter.

Specifically, Duke is requesting an exemption from the requirements of 10CFR20.1703(a),

which requires use of respiratory protection equipment that is tested and certified by the National Institute for Occupational Safety and Health (NIOSH). Duke has evaluated the Mururoa V4 F1 and V4 MTH2 respiratory protection suits manufactured in France. These suits have no NIOSH approval for use as a respirator in the United States. Pursuant to 10CFR20.1703(b), Duke must request authorization for use of equipment that has not been tested or certified by NIOSH. Pursuant to 10CFR20.1705, Duke must obtain authorization from the Nuclear Regulatory Commission before using assigned protection factors in excess of those specified in Appendix A of 1 OCFR20. Since these suits have no NIOSH approval for use as a respirator in the United States, Duke is requesting authorization for their use as respiratory protection equipment and assignment of a protection factor. Additionally, Duke is requesting exemption from 10CFR20.1703(f) which requires provision of the standby rescue persons. provides the documentation supporting the exemption request. As described in the enclosure, approval of the requested exemption would improve worker safety in areas of airborne radioactivity and high potential for facial/skin contamination from hot particles. The requested exemption satisfies the requirements of 1 OCFR20.2301 in that it is authorized by law and will not result in undue hazard to life or property. There are no known precedents for this request, however, Duke has discussed with the staff in principle via telephone on October 31, 2002.

U. S. Nuclear Regulatory Commission Document Control Desk March 4, 2003 Page 2 Duke has identified the following as commitments associated with this exemption request.

1. The Mururoa V4 F1 and V4 MTH2 suits will be integrated into Duke's respiratory program using the information provided by the manufacturer.

2. New lesson plans will be developed to train workers on Mururoa's features, donning, use and removal, cautions and use of mouth strip and tear off strips for routine and emergency egress.

3. Radiation Protection personnel will be provided additional training for selection, approval, issue, equipment set-up, operation and maintenance instructions for the Mururoa suit.

Approval of this exemption will allow Duke to proceed with procedure changes and complete training necessary for the use of the Mururoa V4 F4 and V4 MTH2 suits at the Oconee Nuclear Station September, 2003 outage. Therefore, Duke is requesting approval of this exemption by May 15, 2003.

If you have any questions, please contact M. T. Cash at 704 382-5826.

Very truly yours, W. R. McCollum Senior Vice Presid t Nuclear Support xc:

L. A. Reyes, Regional Administrator L. N. Olshan (addressee only)

U. S. Nuclear Regulatory Commission, Region II NRC Senior Project Manager (Oconee)

Atlanta Federal Center U. S. Nuclear Regulatory Commission 61 Forsyth St., SW, Suite 23T85 Mail Stop 0-8 H12 Atlanta, GA 30303-8931 Washington, DC 20555-0001 R. E. Martin (addressee only) S. M. Shaeffer NRC Senior Project Manager (McGuire and Catawba) NRC Senior Resident Inspector U. S. Nuclear Regulatory Commission McGuire Nuclear Station Mail Stop 0-8 H12 Washington, DC 20555-0001 M. C. Shannon E. F. Guthrie NRC Senior Resident Inspector NRC Senior Resident Inspector Oconee Nuclear Station Catawba Nuclear Station

U. S. Nuclear Regulatory Commission Document Control Desk March 4, 2003 Page 3 bxc:

L. E. Nicholson - ON03RC G. D. Gilbert - CN01 RC C. J. Thomas - MG01 RC L. E. Haynes - EC07F T. J. Venkat - EC07F L. B. Jones - EC050 J. W. Foster - CN02RP J. A. Twiggs - ON01 R2 L. E. Loucks - MG01 RP G. T. Hamrick - EC07F NCMPA-1 SREC PMPA NCEMC ONS Master File - ON03DM (File OS 801.01)

MNS Master File - MGO1 DM CNS Master File - CN01 DM ELL

Duke Energy Corporation March 4, 2003 Enclosure 1 Table of Contents EXEMPTION REQUEST 10CFR20.1703 "USE OF INDIVIDUAL RESPIRATORY PROTECTION EQUIPMENT" 10CFR20, APPENDIX A "ASSIGNED PROTECTION FACTORS FOR RESPIRATORS"

1.0 INTRODUCTION

.................................................................................................................. 1 1.1 P URP O S E................................................................................................................... 1 1.2 REGULATORY REQUIREMENTS ......................................................................... 1 1.2.1 Requirements of 10CFR20.1703 and Appendix A .................................... 1 1.2.2 Criteria for Exemption - 10CFR20.2301 Requirements ............................ 2 2.0 TECHNICAL JUSTIFICATION ........................................................................................ 2 2 .1 S C O P E........................................................................................................................ 2

2.2 REFERENCES

.................................................................................................... 3 2.3 DISCUSSION ...................................................................................................... 3 2.3.1 Suit Construction ...................................................................................... 3 2.3.2 Safety Features of V4 F1 and V4 MTH2 Models ...................................... 4 2.3.3 Evaluation of Mururoa V4 F1 .................................................................... 5 2.3.4 Evaluation of Mururoa V4 MTH2 .............................................................. 7 2.3.5 Test Conclusions ....................................................................................... 7 2.3.6 Implementation ......................................................................................... 8

2.4 CONCLUSION

.................................................................................................... 8 2.5 ATTACHMENTS 2.5.1 Technical information on Mururoa V4 model ventilated suits 2.5.2 European Standard CEN/TC 162 N 738 for ventilated protective clothing 2.5.3 Protection Factor determined during fit test exercises for V4 F1 2.5.4 Certificate No. 0073/197/162/12/97/0028 for Mururoa V4 F1 issued by the Institute for Nuclear Protection and Security 2.5.5 Donning and Removal Instructions for Mururoa V4 F1 2.5.6 Certificate No. 0073/197/162/01/96/0001 issued for Mururoa V4 MTH2 by the Institute for Nuclear Protection and Security 2.5.7 Protection Factor determined during fit test exercises for V4 MTH2 2.5.8 Donning and Removal Instructions for Mururoa V4 MTH2

Duke Energy Corporation Exemption Request March 4, 2003 Enclosure 1 Page 1

1.0 INTRODUCTION

1.1 PURPOSE Per Appendix A to 10CFR20, an air-supplied suit may be used in continuous-flow mode at a licensee's facility, but without using an Assigned Protection Factor (APF). Footnote (g) to Appendix A indicates that no National Institute for Occupation Safety and Health (NIOSH) approval schedule is currently available for such atmosphere supplying suits. 10CFR20.1705 requires authorization from the Commission before using APF's in excess of those specified in Appendix A.

In addition, 10CFR20.1703 (f) requires provision of standby rescue persons, whenever an unaided individual would have difficulty in extricating himself or herself from an atmosphere supplying suit.

Duke proposes the use of the Mururoa "fully enclosed suit" models V4 F1 and V4 MTH2 manufactured by Delta Protection, France. The purpose of this letter is to request an exemption from Appendix A of 10CFR20 from the Commission and for authorization to use an APF of at least 1000 with the Mururoa suits. And, because of the advanced safety features for emergency breathing and emergency escape built into these models, Duke requests approval for the use of the Mururoa suits without dedicated rescue personnel.

1.2 REGULATORY REQUIREMENTS 1.2.1 Requirements of 10CFR20.1703 and Appendix A The following regulatory requirements are relevant to this request.

10CFR20.1703, Use of Individual Respiratory Protection Equipment, requires that if a licensee assigns or permits the use of respiratory protection equipment to limit the intake of radioactive material, (a) the licensee shall use only respiratory protection equipment that is tested and certified by NIOSH.

10CFR20.1703(b) allows that if the licensee wishes to use equipment that has not been tested or certified by NIOSH, or for which there is no schedule for testing or certification, the licensee shall submit an application to the NRC for authorized use of this equipment.

10CFR20.1703 (f) requires provision of standby rescue persons, whenever an unaided individual would have difficulty in extricating himself or herself from an atmosphere supplying suit.

10CFR20.1705, Application for Use of Higher Assigned Protection Factors, requires that the licensee shall obtain authorization from the Commission before using assigned protection factors in excess of those specified in Appendix A to Part 20.

Appendix A, Assigned Protection Factors lists as item II, Atmosphere supplying respirators (particulate, gases and vapors), Suit in a continuous flow operating mode, no

Duke Energy Corporation Exemption Request March 4, 2003 Enclosure 1 Page 2 NIOSH approval schedule is currently available for atmosphere supplying suits. This equipment may be used in an acceptable respiratory protection program as long as all the other minimum program requirements, with the exception of fit testing, are met (i.e.,

10CFR20.1703).

Therefore, based on the above requirements, Duke must obtain approval for the use of the respiratory protection suit and assignment of a protection factor for the suit.

1.2.2 Criteria for Exemption - 10CFR20.2301 Requirements The NRC has established certain criteria that permit a licensee to request an exemption from regulatory requirements. These criteria are established in 10CFR20.2301 and are:

"The Commission may, upon application by a licensee or upon its own initiative, grant an exemption from the requirements of the regulations in this part, it is determines the exemption is authorized by law and would not result in undue hazard to life or property."

The NRC has authority under 10CFR20.1703(b) to grant exemptions from the requirements of NRC regulations. Therefore, this requested exemption is "authorized by law", as required by 10CFR20.2301. The technical justification demonstrates that there will be no undue hazard to life or property. In addition, the Mururoa suit has been widely used in western European nuclear power plants for more than 20 years. These are also sold in China, South Africa and South America. The Mururoa V4 MTH2 model was approved for use in 1996 and the Mururoa V4 F1 was approved for use in 1997.

2.0 TECHNICAL JUSTIFICATION 2.1 SCOPE Duke reviewed the following documents from Delta Protection, France:

(a) Technical information on Mururoa V4 model ventilated suits (Attachment 1)

(b) European Standard CEN/TC 162 N 738 for ventilated protective clothing (Attachment 2)

(c) Protection Factor determined during fit test exercises for V4 F1 (Attachment 3)

(d) Certificate No. 0073/197/162/12/97/0028 for Mururoa V4 F1 issued by the Institute for Nuclear Protection and Security (Attachment 4)

(e) Donning and Removal Instructions for Mururoa V4 F1 (Attachment 5)

(f) Certificate No. 0073/197/162/01/96/0001 issued for Mururoa V4 MTH2 by the Institute for Nuclear Protection and Security (Attachment 6)

(g) Protection Factor determined during fit test exercises for V4 MTH2 (Attachment 7)

(h) Donning and Removal Instructions for Mururoa V4 MTH2 (Attachment 8)

The European Standard (Attachment 2) requires that suit material be tested for resistance to abrasion, flex cracking, puncture, blocking, tear and flammability, strength of seams, joins and assemblies, damage resistance of exhaust valves, designed flow rates for pressure range of

Duke Energy Corporation Exemption Request March 4, 2003 Enclosure 1 Page 3 supplied air, noise level and quality of the visor. According to the testing standard, three workers should perform standard exercises, each wearing two different suits inside a chamber filled with a test agent (Sodium Chloride) and measure the leakages during the exercise regimen lasting 20 minutes. Operating parameters are set to manufacturer's instructions.

Standard exercises include walking on a treadmill at 2 mph (3 minutes), moving arms up and down above head while looking upward (3 minutes) and squatting continuously (3 minutes). To ensure worker's comfort, 2 additional practical exercises - walking at 2 mph (5 minutes) and loading a bucket with wood chips from the base of a hopper and emptying it into the opening on top (15 minutes) - should be performed by two workers at specified air flow rates.

Certificate No. 0073/197/162/12/97/0028 (Attachment 4) states that the Mururoa V4 F1 passed in all categories tested and provided a protection factor greater than 50,000. Certificate No.

0073/197/162/01/96/0001 (Attachment 6) states that the Mururoa V4 MTH2 passed in all categories tested and provided a protection factor greater than 50,000. Please note that the term 'protection factor' used in the European Standard is equivalent to the 'fit factor' used in the United States and is not the same as the Assigned Protection Factor used in 10CFR20. Based on a review of the manufacturer's documentation and testing performed at Duke facilities, the Mururoa V4 F1 and V4 MTH2 suits represent a better design than the currently approved "bubble hood" and "rain suit" combination and provide better worker protection with the data supporting an APF of at least 1000.

2.2 REFERENCES

10CFR20.1703 Use of individual respiratory protection equipment 10CFR20.1705 Application for use of high assigned protection factors 10CFR20.2301 Applications for exemption Appendix A to 10CFR20 Assigned Protection Factors for Respirators Regulatory Guide 8.15 Rev 1 Acceptable Programs for Respiratory Protection NUREG-0041 Manual of Respiratory Protection Against Airborne Radioactive Materials European Standard CEN/TC 162 N 738 (July 1996) (Attachment 2)

EC Type Examination Certificate No. 0073/197/162/12/97/0028 for the Mururoa V4 F1 suit dated December 10, 1997 (Attachment 4)

EC Type Examination Certificate No. 0073/197/162/12/96/0001 for the Mururoa V4 MTH2 suit dated January 10, 1996 (Attachment 6) 2.3 DISCUSSION Duke recently had the opportunity to evaluate the Mururoa V4 F1 and V4 MTH2 encapsulated suits manufactured by Delta Protection, 30200 Bagnols su C'eze, France. The results of the test evaluation have been documented in Duke's Problem Investigation Process (PIP) as # G 03-099. PIP allows a structured approach to identify areas for improvement and optimization.

Duke Energy Corporation Exemption Request March 4, 2003 Enclosure 1 Page 4 2.3.1 Suit Construction The Mururoa suit models V4 F1 and V4 MTH2 meet ISO 8194 and the European Standard EN.NF 1073-1 and the manufacturer is ISO 9001 certified. The manufacturer indicates that approximately 60,000 Mururoa garments/suits are used by Electricite de France each year.

The Mururoa suits have the following desirable features that are not available in the "bubblehoods" and "rain suits" manufactured in the United States:

1) One piece suit that includes welded gloves and booties with tie straps

2) Fire proof (up to 65 deg C)

3) Made of PVC or Ethyfuge with reinforced elbows, knees and crotch areas.

4) Dual zippers - metal zipper inside and plastic zipper outside

5) Helmet made of clear PVC material that provides distortion-free vision and large enough for wearing a headset

6) Welded sleeve to insert communication cable

7) A removable strip near the mouth that could be used for emergency breathing in case of loss of supplied air

8) An egress strip stretching from left arm, over the head, to right arm that is used for undressing and for self-rescue in an emergency, such as loss of supplied air

9) Air intake located at the waist with a built-in regulator that can adjust, but not block, air flow.

10) Two exhaust valves that provide ventilation, and also protect from overpressure

11) Very low noise level at maximum air flow

12) Air flow to hands, feet, face and chest.

Air hoses of any length can be used, but air should be supplied to the Mururoa suit (model V4 Fl) at 85 psig measured at the inlet. A regulator at the inlet can adjust the air flow from 41 CFM maximum to 9 CFM at the minimum. The regulator cannot shut off the air supply to ensure user safety. Noise level is kept between 76 dB at maximum air flow to 58 dB at minimum air flow. Air flows through manifolds to the chest, hands and feet. There are two exhaust vents on the back - one behind the neck and one at lower back. The exhaust vents have patented magnetic seals to prevent any aspiration of contaminants if supplied air is lost.

The suit is made of non-flammable PVC, but should not be brought in direct contact with any material colder than 41 deg F or hotter than 140 deg F. Open flames or sparks could melt or perforate the skin. There is a shelf-life of 3 years for this suit and storage between 32 deg F and 140 deg F in original packing is required by manufacturer. The Mururoa is approved for use with 16 different fittings in Europe and can be fitted with Schrader or Foster or CEJN fittings used in Duke's nuclear sites.

The Mururoa suit model V4 MTH2 is made of Ethyfuge material which is fully incinerable. This material is more flexible than the PVC used in V4 Fl. It is constructed the same way as the V4 Fl. Breathing air is required at about the same pressure (87 psig). The regulator can adjust air flow between 17 CFM to 38 CFM. Noise level varies from 66 dB at minimum air flow to 76 dB at maximum air flow. There are two additional air vents near the chin for cooling the face. The

Duke Energy Corporation Exemption Request March 4, 2003 Enclosure 1 Page 5 suit is also fire-retardant and can be used in ambient temperatures up to 140 deg F. Storage requirements are the same as V4 Fl. These suits are also available with multiple fittings.

2.3.2 Safety Features of V4 F1 and V4 MTH2 Models Both Mururoa suit models are light-weight (2.5 Ibs), made of fire-retardant material and can be used in temperatures up to 140 deg F. Contact with open flames or grinding/welding sparks is prohibited. Built-in gloves, booties with binding ties, reinforced elbows, knees and crotch protect against accidental tear, puncture and cracking. A transparent helmet with 6" X 8" clear face plate provides distortion-free view. Dual magnetic ventilation valves provide needed ventilation and relief of excess pressure in case suit is squeezed/pinched unexpectedly. Noise level at maximum air flow is less than 80 dB. Length of air hose supplying Grade D breathing air is not stipulated, but the pressure of air at inlet is required to be 85 psig for V4 F1 and 87 psig for V4 MTH2. Air flow can be adjusted by the user for his/her comfort, but cannot be shut off. In case of loss of air, the user can remove the mouth strip and move the opening close to his face, or enlarge the opening, to breathe outside air. Alternately, the user can pull the escape strip from either forearm, over the head and towards the other forearm, and rip the suit in two halves. This escape strip is normally used for egress from the suit when the work activity has been completed.

The Mururoa suit's design does not permit its use in an immediately dangerous to life and health (IDLH) atmosphere. Duke plans to use this suit for protection against radioactive particulate contamination only. The Mururoa suit is also not designed for use with any personal cooling units such as a Vortex tube, but can be used with a cooling vest supplied by the manufacturer, if desired.

2.3.3 Evaluation of Mururoa V4 F1 Since NIOSH does not have an approval schedule for such air-supplied suits and Duke does not have a suitable test chamber/facility, the Mururoa suit could not be checked for leakage using fit test exercises or estimate its fit factor. The PortaCount equipment used by Duke for fit tests uses concentration of dust particles in ambient air for challenge agent and would be unsuitable for testing the Mururoa suits. Due to these limitations, the Mururoa suits were only evaluated for worker comfort, ease of use, visibility and safe operation within the parameters specified by the manufacturer.

Such an evaluation was performed on August 20, 2002 at the S/G mockup facility at the McGuire site. About 20 Safety, Radiation Protection and Maintenance personnel attended the evaluation. One S/G maintenance worker was dressed out in the Mururoa V4 F1 suit that was connected to a MSA breathing air manifold through a 50' long hose. Supply air pressure was set to 85 psig. The worker wore a communications headset and the communication cable was inserted and sealed in the special sleeve.

Duke Energy Corporation Exemption Request March 4, 2003 Enclosure 1 Page 6 The worker said he felt very comfortable inside the suit. The helmet rested comfortably on his shoulders and provided a clear distortion-free view all around. Worker was able to move his head and headset freely side to side. The pressure regulator was easy to access and manipulate. Sufficient air flowed at all regulator positions without choking or asphyxiation.

Communication was tested and found to be good.

A thermometer was taped to the worker's chest, and an Oxygen monitor was taped in the nasal region. The ambient temperature was measured to be 82 deg F. Worker said he felt cool air coming near his hands and feet. The temperature in the chest area read about 75 deg F. The worker was able to squat, crawl and bend/pick up tools and communicate through headset and said the noise level inside was minimal. The air supply 7,-

was then turned off (after alerting the worker).

After 45 seconds, the Oxygen monitor alarmed indicating that the Oxygen level dropped below 19.5%. Air supply was immediately restored.

The safety strip near the mouth was removed to see if it affected worker's breathing or comfort.

Worker did not report any discomfort or breathing difficulties. The Oxygen monitor did not alarm. Breathing air was then turned off to see if the worker could inhale outside air through the mouth opening. The worker could not do this and the Oxygen monitor alarmed after 35 seconds. However, he could breathe outside air when the mouth opening was pushed near his face. Air supply was immediately restored. The manufacturer states that there is 1 - 3 minutes of air available inside the suit if air supply is lost.

The worker was then moved to outside the building and made to stand in direct sunlight simulating a hot environment. The temperature was 92 deg F in the sun and 86 deg F in the shade. The worker was asked to squat, bend and crawl. He started feeling warm after 5 minutes and beads of sweat appeared on his forehead. The chest thermometer on worker recorded 102 deg F. Worker said his hands and feet were cool, but he did not feel any cool air over his face or chest. Worker was moved to the shade, where he felt better.

The bootie straps were cut and the worker was then asked to undress. When the worker pulled the undressing strip from left arm, over the head, to the right arm, the suit split into two halves easily and worker could roll them down and step out of the suit.

Duke's evaluation revealed that:

Duke Energy Corporation Exemption Request March 4, 2003 Enclosure 1 Page 7

1) In environments hotter than 92 deg F, the Mururoa suit may not provide adequate cooling unless the supplied air is cooled.

2) The cooling to the face/chest region needed improvement.

3) Oxygen-deficient atmosphere develops within 45 seconds of loss of air.

4) In case of loss of air, the worker needs to either:

(a) pull off the mouth strip and then rip open the hood, or (b) pull the egress strip from forearm to head.

5) Users and rescue personnel, if provided, have to be trained in escape methods.

6) Built-in gloves/booties made donning and removal simple and easy with less chances of discrete radioactive particles (DRP) contamination.

7) The Mururoa V4 F1 suit's waist sizes are much smaller than sizes needed for most US workers. The largest waist size available was 32.5".

8) CEJN/Schrader/Foster fittings are required for compatibility with Duke's breathing air systems.

9) The V4 F1 suit is acceptable for use by personnel with smaller waist sizes.

These items were discussed with Mr. Samuel Ozil, Technical Director, Delta Protection, during his visit to Charlotte on October 5, 2002. The vendor agreed to send Duke another model that provides enhanced cooling to the face and with larger sizes and compatible fittings.

2.3.4 Evaluation of Mururoa V4 MTH2 The Mururoa V4 MTH2 suits were received from France on January 2, 2003. The model V4 MTH2 is already approved for use in France and has CEJN fittings, additional air vents near the chin, tear-off mouth-strips and egress strips, and 50" waist sizes. The suits are made of Ethyfuge material, stated by the manufacturer to be fully incinerable. Recommended air supply pressure is 87 psig and the flow rate is adjustable by the user from 17 CFM to 38 CFM with the built-in regulator.

On January 16, 2003, the Mururoa V4 MTH2 was evaluated at the Catawba Nuclear Station's S/G mock-up facility. The ambient temperature was 55 deg F.

Supply air pressure was set to 65 psig, instead of 87 psig recommended by manufacturer, because of a problem with the ,

breathing air compressor in the mockup facility. The worker first put on coveralls, cloth hood, rubber gloves and shoe covers and then donned the Mururoa suit. He felt comfortable with good cooling to his face, chest, hands and legs even with regulator set for minimum air flow. He was able to lift his arms, twist his body, bend down, squat and crawl without any

Duke Energy Corporation Exemption Request March 4, 2003 Enclosure 1 Page 8 discomfort. He entered the SG bowl through the manway without any difficulty, moved around and then descended from the bowl. Air was felt to be flowing freely through the two patented magnetic vents behind the head and at the back. He had clear, undistorted vision all around.

He was able to remove the mouth strip and rip open the suit. The bootie straps were cut and the escape strip was then pulled off from his right forearm, over his head to his left forearm, splitting the suit in two halves and enabling him to step out of the suit.

2.3.5 Test Conclusions Based on the testing performed at Duke facilities and the information received from the manufacturer, Duke has determined that the MURUROA V4 F1 and V4 MTH2 air supplied suits offer a safer and more efficient means to protect workers in areas of high radiological contamination and in areas where there is a potential for airborne contamination. The existing rain suits and bubblehoods provide cooling only to the head and force workers to wear the ensemble in a manner that makes self-rescue nearly impossible, thus requiring a rescue worker to be stationed nearby. Ease of removal of the Mururoa suit provides for more desirable self rescue features, and provides a means to undress that minimizes the potential for personnel contamination events.

2.3.6 Implementation Duke has a respiratory program in full compliance with 10CFR20. The Mururoa V4 F1 and V4 MTH2 suits will be integrated into Duke's respiratory program using the information provided by the manufacturer. New lesson plans will be developed to train workers on Mururoa's features, donning, use and removal, cautions and use of mouth strip and tear off strips for routine and emergency egress. Radiation Protection personnel will be provided additional training for selection, approval, issue, equipment set-up, operation and maintenance instructions for the Mururoa suit. The Mururoa suit's safety features, namely the tear-off mouth strip and the emergency tear-off strip, make it unnecessary for any standby rescue person. Further justification for requesting exemption from the rescue person provision include the fact that workers wearing air-supplied suits are typically under continuous surveillance by Radiation Protection technicians using remote video monitoring or under direct Radiation Protection surveillance at the job location due to radiological conditions. Additionally, in ma'ny cases, workers are in direct contact with Radiation Protection and Steam Generator support personnel via audio headsets. The ability to eliminate the rescue worker is also an ALARA consideration since the work areas where air-supplied suits are used are typically areas with higher radiation and contamination levels. Steam Generator platform work, cavity decon, equipment decon are specifically targeted for the use of the Mururoa suit. Duke will use the Problem Investigation Process (PIP) to document any unexpected problems and track corrective actions taken.

Problems associated with the suits will be communicated to the manufacturer to ensure that operating experience is shared with other users. A relationship with the manufacturer will also be developed that allows operating experience from other users to be incorporated into Duke processes. Duke will be pleased to share this experience with the NRC and other utilities that may be interested in the Mururoa suit.

Duke currently uses the bubblehood for jobs involving high potential for skin contamination from discrete radioactive particles and to prevent intake of airborne contaminates. Because the bubblehood covers only the face and torso, workers have to wear protective clothing, 2 pairs of

Duke Energy Corporation Exemption Request March 4, 2003 Enclosure 1 Page 9 gloves, rubber shoes and cotton booties and tape for sealing. Chances of cross contamination during undressing/exit from contaminated areas are high. The Mururoa suits offer a better alternative (with their unitized construction and ease of removal) and should protect the worker much better against facial/skin contamination and airborne radioactivity. The Reactor Vessel Heads and Steam Generators are due to be replaced between April 2003 and September 2004 at Duke's three Oconee units. The Oconee site has slightly higher alpha activity in the containment due to fuel leaks that occurred during the 80's. Approval of a protection factor of at least 1000 for the Mururoa suits would allow use of the Mururoa suits in Duke's efforts to control contamination incidents and prevent intakes during the replacement activities at Oconee, as well as during applicable operational activities at all of the Duke nuclear stations.

2.4 CONCLUSION

Duke requests an exemption to the requirements of 10CFR20.1703(a), which requires use of respiratory protection equipment that is tested and certified by NIOSH. Based on in-house test conclusions discussed earlier in this enclosure, has determined that the Mururoa suits offer a safer and more efficient means to protect workers in areas of high radiological contamination and in areas where there is a potential for airborne contamination. Pursuant to 10CFR20.1703(b), Duke is hereby requesting authorization to use the recently evaluated Mururoa V4 F1 and V4 MTH2 respiratory protection suits that are manufactured in France.

Pursuant to 10CFR20.1705, Duke is also requesting authorization to use an APF of at least 1000 with the Mururoa suits. The tests conducted at Duke along with a review of the manufacturer's documentation have shown that these suits provide better design and protection that supports the requested APF. Additionally, the Mururoa suits have advanced safety features for emergency breathing and emergency escape. These advanced features allow self rescue during emergencies to be a reasonable expectation. Therefore, Duke is also requesting exemption from 10CFR20.1703(f) in order to use the Mururoa suits without dedicated rescue personnel. All tests results indicate that this request for exemption is reasonable, is authorized by law, and will not result in undue hazard to life or property

Duke Energy Corporation Exemption Request March 4, 2003 ATTACHMENT 2.5.1 TECHNICAL INFORMATION ON MURUROA V4 MODEL VENTILATED SUITS

NO: Do/ USA/ 1 MURUROA INDICE" a V4 FULLY ENCLOSED SUIT DATE D'APPLICATION :06/09/01 DELTA PROTECTIOAI GENERAL DESCRIPTION ) 04 66 89 18 36 PAGE :1/4 MURUROA SUIT The Mururoa suit is a single use garment designed to be used in radioactively contaminated environments. It has been widely used in western European Nuclear Power Plants for more than 20 years, without any major problem (the French state company: Electricit6 de France use 60,000 garments each year).

The Mururoa suit is a fully enclosed PVC plastic, supplied-air and pressurized suit, that offers excellent protection factor ( -100,000) against any solid, liquid, or gas pollutant, minimizing discomfort and heat stress and increasing the worker's efficiency.

The Mururoa suit is C.E. approved and complies with CE standard EN:1073-1 "Protective clothing against Radioactive Contamination"

]-It also fulfils the requirements of the I.S.O. 8194 standard "Radiation Protection-Clothing for protection against Radioactive contamination-Design selection ,testing and use"

N': Do/USA/1 INDICE a V4 MURUROALS INDICE : a V4 FULLY ENCLOSED SUIT DATE D'APPLICATION :06109101 DELTA PROTECTiOES GENERAL DESCRIPTION a, 04 66 89 18 36 PAGE :2/4 VENTILATION I EXHAUST In the supplied-air Mururoa suit, the ventilation system is composed of

- An airflow control valve, preset to a minimum flow of 250 litres/minute (9 CFM) at 3 bar (42 PSIG), located on the right hip and covered with a protection flap. This flow can be adjusted, from 250 to 1150 litres (9 CFM to 41 CFM) per minute. 1150 litres is obtained with the tap fully opened at the feeding pressure of 6 bar (85 PSIG) (refer to graph in annex 11).

- A silencer bag which attenuates the noise level less than 58 dBa at 250 litres/minutes to 76 dBa at 1150 litres/minute.

- A manifold system welded to the suit and distributing the air to the helmet, the legs and the arms.

- An exhaust by two world patented valves placed in the helmet and in the back. These valves ensure a remarkable airtight seal in case of accidental air-feed cut off, or when putting the suit in under pressure through abrupt movements. The valves regulate the overpressure in the garment between 3 mbar (0.042 PSIG) and 10 mbar (0. 142 PSIG) for supply air pressure between 3 bar (42 PSIG) and 6 bar (85 PSIG)

- The benefits of this system are

- High heat removal through superior airflow

- Non irritating diffuse ventilation

- Resistance free breathing

- High level of comfort for long and strenuous jobs in contaminated areas

- Very low noise level

N": Do / USA / 1 INDICE a V4 MURUROA INDICE

• a V4 FULLY ENCLOSED SUIT DATE D'APPLICATION :06109/01 DELTA PROTECTION GENERAL DESCRIPTION T 04 66 89 18 36 PAGE :3/4 DESIGN CHARACTERISTICS One piece PVC, fire proof suit. (Thickness 20/100mm for technical data concerning the material, refer Annex I of this document)

Welded PVC gloves Incorporated overboots with strengthened sole Binding ties on the overboots Reinforced elbows, knees and crotch Dual zipper system: - metal zipper for mechanical strength

- PVC zipper for air and gas tightness (0.30 PVC thickness)

Supple transparent PVC helmet, fitted with a transparent distortion free, PVC face plate 6"x 8" giving almost the same optical quality as glass.

Quick release strip from forearm, overhead to forearm, for easy removal. This i*s used both for undressing or emergency egress. (Emergency egress takes less than 3 seconds).

Quick release strip for access to the mouth.

Welded sleeve for communication cable.

NO: Do/ USA/ I MURUROA INDICE: a V4 FULLY ENCLOSED SUIT DATE D'APPLICATION :06/09101 DELTA PROTECTIOA GENERAL DESCRIPTION o04 66 89 18 36 PAGE :4/4 GENERALCONSIDERATIONS THE MURUROA SUIT IS AVAILABLE IN SIX SIZES Size 0 1,55 m -- 1,62 meter 5 feet I inch -- 5 feet 4 inches Size 1 1,60 - 1,68 meter 5'3" - 56" Size 2 1,68 -- 1,74 meter 5'6" - 58" Size 3 1,74 -- 1,82 meter 5'8" - 6'0" Size 4 1,82 -- 1,92 meter 6'0" -- 6'3" Size 5 1,92 -- 2,05 meter 6'3" -- 6'8" But if any individual selects a suit size different from the recommended size, the operating and safety characteristics will not change.

WEIGHT 1200 grams (2.64 LBS)

FEEDING PRESSURE 6 bar (85 PSIG)

FLOW 450 up to 1150 Lit/minute (16 -41 CFM)

STORAGE

- The suit should be used by the third year from the date of manufacture.

- It must be stored in its original packaging.

- The storage temperature has to stay between 0°C and 600C (32 0F - 140 0F)

- If the storage temperature was below 5 0C (41 0 F),the suit must be stored approximately 3 hours3.472222e-5 days <br />8.333333e-4 hours <br />4.960317e-6 weeks <br />1.1415e-6 months <br /> at a room temperature until the suit become flexible.

- The usage temperature range + 50 C and + 55 0 C (410 - 1310F) depends on air fed temperature

N*: Do / USA / 1 INDICE:

a V4 MURUROALS INDICE

• a V4 FULLY ENCLOSED SUIT DATE D'APPLICATI'N :06/09/01 DELTA PROTECTION GENERAL DESCRIPTION 0104 66 89 18 36 PAGE :5/4 MATERIAL PROPERTIES Technical characteristic of PVC material 20/100 mm using French standards, which would correspond to ANSI standards.

Characteristic Standards Results Units Density NFT 51063 1.38 gm/cm3 Traction Resistance NFT 54102 > 143 N/cm 2 Stretch before tear NFT 54102 > 178  %

Tear resistance NFT 46007 >45 N/cm 2 Weld resistance than material resistance NFT 54122 Peel 50 Tear 65  %

Resistance to cold NFT 51102 -10 °C Vapour permeability NFH 00030 34.1 g/m 2/24h Volatility on activated charcoal NFT 51167 <6  %

Spark perforation NFC 26225 9.2 KV

Duke Energy Corporation Exemption Request March 4, 2003 ATTACHMENT 2.5.2 EUROPEAN STANDARD CEN/TC 162 N 738 FOR VENTILATED PROTECTIVE CLOTHING

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Page 3 prEN 1073-1 : 1996 Foreword This European Standard has been prepared by the Technical Cmmirtee CENITC 162 'Protective clothing including hand and arm protection and lifejackets" the secreta'ia: of which is held by DIN.

This European Standard has been prepared under a mandate given to CEN by the European Commission and the European Free Trade Association and supports essential requirements of EU Directive 891686/EEC.

For relationship with EU Directive[s], see informative Annex ZA. which is an integral par, of this standard.

The annex A is normative and contains the activity sequence for the testing of the protection facor.

Further parts of this standard will deal with requirements for unventilated protective clothing and protection against liquids and gases.

In accordance with the CEN/CENELEC Rules, the following c=unrnes are bound to implement this European Standard:

=C-A iJOICAC92J U011-1410-1 V2P!AD;c1 SW410P ZA.-*ýQ'-Oja

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Page 5 prEN 1073-1 : 1996 body.

3.3 Nominal protection factor (inward leakage, IL)

The ratio of the average concentrations of a test aerosol or gas measured in the ambient atmosphere and inside the hood of the protective clothing at the point where the wearer draws breath. The concentrations taken into account are the average concentrations recorded during a standardized test.

3.4 Radioactive contamination Presence of radioactive substances in or on a matenal or in a place where they are undesirable or could be harmful.

3.5 Seams A permanent fastening between two or more pieces of protective clothing material.

3.6 Assemblages A permanent fastening between two or more different garments, -or, between protective clothing and accessories, obtained, for example by sewing, welcing, vulcanising. gluing.

3.7 Join A non-permanent fastening between two different garments, or between protective clothing and accessories.

3.8 Closure A device, for example, zipper, 'touch and close* fastener, etc., to close openings for donning or removing the protective clothing 4 Design 4.1 Protective clothing against radioactive contamination snail comply with the general requirements specified in EN 340.

4.2 The design of the protective clothing shall be such that the protective clothing is straightforward to pu-,

on and take off, and to minimize the risk of contamination, testing according to 'practical performance test" (see 6.2).

4.3 The clothing can be designed for single or multiple use.

4.4 The protective clothing (see 3.2) may consist cf one or several parts. The clothing may be fitted with a respiratory protective device to enable the wearer to breath in case of failure of tne primary air supply.

5 Requirements 5.1 Materials The materials used for protective clothing against radioactive contamination shall meetthe requirements according to table 1 after the pretreatment in accordance with 6.1.1 and 6.1.2.

Page G prEts 1073.1 t. 1996 Table 1: R~equiremnents for It.* nvatCi4!

Re.jec: Classfic~aun j Te-acrin o T~ oringre~tie esioplcable for

• mginqc use PnteTials A I-ras ten i esz 6 > 20GO Cylele EN S30, Metr-zt 2 r a~e5 > I15ao Cy-5e- 00 a:rasiv pacer ac

-4 > 1000 cy-.ýs cwra-mg 10 PICE1 913.

ý3> 500 Cydc-a 4nd 98kPa 2>100 Cyrcz -downwuard ritn

________________ ¶> 10 0ycras _______________

Flex cr-ecking 6 > 100,000 cyrje4 150 7854 M.etncd E Yes ~

resistance 5 > -Iowa cycles 4 > 15O000Cycjes 3> 5000 Cycle.

2.> 2SO Cycicz.

I1> 1000_Cycles ________ _________

Pu.clr rCz -' 2> 100 N jEN VE~3 ysy I2> SO N I II Rc*ýarxce to J 2 no bleocing ISO E97E e .

rsee note_11 1 ___________ 1 _________ 1____1 Tear tesistance 6 > 150 N I SO E-073-4 V"s yes 4 > ED N I > 20?N RaAsiitci ma-vezI~. vizer an~d *iiI 132rmt shijial net iow.inua to turn rEIN 11.46 tsingfc tue Is. yesye NOITE 1: Unc-6a-.d -materials shalI =t be :es~ed a~a-nst rime.ianeae tobi king, The .tz* repcat shall be rnarked *Noz teztedasint NOTE 2: It reste-ion assirn~tbazandcus chemficils 4 rccriirad :han testing has to be carried. ox, ca-.ding to the r.Iovant c-hemnizal !sndrd!.

5.2 Ventilated protective ciothing 6.2-1 GencraI The dezl~ignof h rtciecch hastrobe tezird fite rca ronrc:ez c1 in 6.2.

5.2.2 Requirementz_ for the nomintal prataese-f facter 11M Venulzied prciecive clozhiris shaR be c~assifiee a.ccrdirq tc Table 2- Tes-in; accarzin; tz e.4 with the ntieeszzy aztrvty sequence acco-0rd1n'g to annex A. af I~r~d~n~r af ticivi ra-.

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Page 9 prEN 1073-1 : 1996 5.2.12 Carbon dioxide content of the inhalation air The carbon dioxide content of the inhalation air, determined at the minimum air flow rate, shall not exceed an average of 1.0 % (by volume), tested according to EN 270. Two suits shall be tested, one of which has to be pretreated as specified in 6.1.1.

5.2.13 Noise associated with the air supply to the suit The noise measured in the suit at the ears shall not exceed 80 dB(A) at the maximum manufacturers' design flow rate. To be tested in accordance with EN 270. Two suits shall be tested, one of whicn has to be pretreated as specified in 6.1.1.

6 Test methods 6.1 Test preparations 6.1.1 Pretreatment When the clothing is intended to be reusable the requirements for the materials or the complete clothing shall be proved after 5 cycles of cleaning and disinfection according to the manufacturer's instructions for use before testing 6.1.2 Conditioning All material samples shall be ccrnditioned by storage at (20 = 2) 0 C and (E5 - r)

% relative humidrty for at least 24 h Start each of the tests as specified in 6.1.3 and 6.1.4, within mrin after removal from the conditioning atmosphere 6.1.3 Visual inspection A visual inspection shall be carried out by the test house prior to the laboratory or the practical performance test. This may entail a certain amcunt of dismantling in accordance with the manufactu rers' information for maintenance.

6.1.4 Preconditioning for the practical performance test If the manufacturer does not state the preconditioning atmosphere for the practical performance test, the complete clothing shall be exposed:

a) for 4 h to a temperature of (-30 +/- 3) *C and allowed to return to ambient conditions, followed by b) for 4 h to an atmosphere of (60 t 3) 'C at 95 % relative humidity. It shall then be allowed to return to ambient temperature.

6.2 Practical performance test 6.2.1 General The tests shall be carried out by two test persons at (20 = 5) 'C and a relative humidity of less 60 %. The test temperature and humidity shall be recorded. The background noise shall not be than greater than 75 dB(A).

The test persons shall be selected who are familiar with using such or similar protective c!othing.

The persons will be drawn from those people certified as fit to do so by the medical officer. The necessity of a medical examination before or supervision during the tests shall be at the testing officers discretion.

Prior to the test there is an examination that the suit is in working-condition and that it can be used without danger. If more than one size of a cothing is manufactured the subjects are asked to select the appropriate size. Ensure that the air supply is within the specified parameters. Two suits shali be tested.

each being tested on one test person.

After fitting the suit each test person is asked 'Does the suit fit?'. If the answer is "Yes', continue the test. If the answer is -No', replace the test person or the suit.

Page 10 prEN 1073-1 : 1996 6.2.2 Procedure During the test the following activities shall be done in simulation of the practical use of the suit:

- the test shall be completed within a total working t.me of 20 mm

- walking on the level with regular rate of 5 km h" for 5 min

- filling a small basket (see figure 1, approximate volume 8 I) with 12 mm chippings (e.g.

limestone chippings) or other suitable material horn a hopper which stands 1.5 m high and has an opening at the bottom to allow the contents to be shovelled out ana a funner ocening az the top where the chippings may be returned. The person stoops or kneels as he wishes and fills the basket with chippings. He then lifts the basket and empties the contents back into the hopper. This is reneated 15 to 20 times in 10 min.

A Figure 1: hopper and basket 6.2.3 Information to be recorded During the practical performance test the clothing shall be subjectively assessed by the wearer and the following shall be recorded:

a) harness comfort (see 6.61; b) security of fastening and couplings; c) accessibility of controls and pressure gauge (if fited);

d) clarity and field of vision from the facepiece and/or visor; el clothing comfort; f) ease of speech transmission:

9) any other comments volunteered by the wearer.

6.3 Measurement of minimum and maximum air flow rate Connect the ends of the distribution system collectively to a surtable measuring device. Record the maximum air flow delivered at the manufacturers' specified air supply. If a control valve is fitted, record the maximum delivered air flow and the minimum delivered air flow.

The value of minimum and maximum air flow rate shall be cetermined under the conditicn of exercise 6 of Annex A (person standing stdll).

6.4 Determination of the protection factor The protec::on factor shall be determined in accordance with prEN 943-1. Sodium chloride test method shall be used. Activity sequences for testing are given in Annex A of this standard.

The determinaticn has to be done at the minimum design air flow rate (see 5.2.7).

On two test subjects four new suits shall be tested. Two suits per test subject.

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Duke Energy Corporation Exemption Request March 4, 2003 ATTACHMENT 2.5.3 PROTECTION FACTOR DETERMINED DURING FIT TEST EXERCISES FOR V4 Fl

DP EA/STESR/CTHEN/97-599 Page 1/2/2 Test Results carried out on the full encapsulated suit MURUROA V4F1 ref. 8481X1T For the EC Type Examination Certificate N00073/197/162/12/97/0028 You will find below the detailed results taken in account for being able to statue on the conformity of this equipment in accordance with the Essential Requirements of the European Standard pr EN 1073-1. Other results those are non pointed out in this report are already written in the EC TYPE Examination certificate (dated December 10k" 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) bMinimum air flow(l/mn) Maximum air flow (Vmn) 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/mn (paragraph 2.3.12. of the EC Examination Type) bTest NoI C02 contents(%) Test N02 C02 contents(%)

1 0,86 0,93 2 0,68 0,68 3 0,75 0,82 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 Tvye) eMaximum air flow(l/mn) Noise level (dB) 1 1050 77,2 2 1070 75,1 3 1050 77,6

Page2/2 4 - Inward leakage average- Fit Factor measured at the minimal air flow of 4501/mn (paragraph 2.3.3. of the CE Examination Type)

Suit no 1 2 3 Exercise Standing still > 120 000 > 120 000 > 120 000 Walking (5 km/h) 76 700 90 900 66 000 Moving arms up and down 113800 > 120 000 113800 above head Continuous squats 30 000 41 700 50 000 Bending forward 110000 103 400 91 700 Person twisting at waist > 120 000 > 120 000 > 120 000 Person crawling 55 000 > 120 000 31 400 5 - Pressure In the suit when measured at the maximum air flow when suit connected under 6 bar feeding pressure (paragraph 2.3.11.of the EC Examination Tvye)

Suit no 1 2 3 Exercise P mln(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 the pr EN 1073-1)

In accordance with the paragraph 4.6; the connexion 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, it appears a deformation of the fabric, near the regulation air flow device. A reinforced area could certainly avoid this deformation.

Duke Energy Corporation Exemption Request March 4, 2003 ATTACHMENT 2.5.4 CERTIFICATE NO. 0073/197116211219710028 FOR MURUROA V4 Fl ISSUED BY THE INSTITUTE FOR NUCLEAR PROTECTION AND SECURITY

ECEC 97 10028 Page 1/12 INSTITUTE FOR NUCLEAR PROTECTION AND SECURITY Technical Center for Nuclear Equipment Certification In accordance with the directive 89/686/EEC dated December 21th 1989 comparing the laws of the States Members Legislations relative to the Personal Protective Equipments, and the decrees n' 92 765, 766 and 768 dated July 2 9 th 1992 transposing the directive into French Laws The organisation herebelow mentioned (IPSN / CTHEN) whose references are as follows

- Address: B.P. n° 6 - 92265 Fontenay-aux-Roses Cedex (France).

- Empowered by Order of the Ministries of Employement and Agriculture dated December 24 1h 1996

, Identified under the n* 0073 (published in the EEC Official Publication dated July 23 th 1994).

Assigns the :

EC TYPE EXAMINATION CERTIFICATE N°,007311971162/1219710028 To the following Personal Protective Equipment model:

- Designation: Ventilated Protective Suit against Radioactive Contamination pressurised for a single use only.

- Commercial reference : MURUROA V4 F1 - ref. 848 IXIT.

- Manufacturer: DELTA PROTECTION / REDI - 69 210 Saint-Germain-Sur-L'Abresle.

- Certificate applicant : DELTA PROTECTION - Z.A. De Berret-30200 Bagnols-Sur-Ceze.

-- 'Essential Requirements Reference : EN 143, pr EN ,1073-1 (July.1997), pr EN 943-1 (October 1997), EN 270, EN 1146 (April 1997).

Date: December 10'h 1997 J. CORBIEREJ Chief of CTHEN Nota : According to article R 223-62 of the "Working Law", the empowered organisation should be informed of any modification made to the material subject of this EEC type examination certificate, as well as of any modification made to the contents of this technical file on which the delivered type certificate was based on (address, manufacturer name, quality insurance certificate extract, ... )

This certificate contains 12 pages n° 1112 to 12/12 French ¥-.on onty zha= be usd whan disute

ECEC 9710028 Page 2/12

1. DESCRIPTION It is a Ventilated Protective Suit against Radioactive Contamination ventilated type - pressurised for a single use only, its name is:

MURUROA V4 F1 - ref. DELTA: 8481X1T The T values are defined according to the size of the suit.

The X values are defined according to the pipe butt (Staubli or CEJN) allowing to connect the suit to the breathable compressed air supply system.

The attached list - annex 2 - gives all the references defined by this ECEC.

The suit includes:

- A air tight suit with an incorporated hood

- A suit fastening system located on the back of the suit.

- A breathable air flow supply system.

- A air exhaust device.

- A safety strip for emergency opening located on the hood.

F-;h vw ortody i*I be un.d wt4w dspte

ECEC 9710028 Page 3/12 1.1. MAIN MATERIALS

- Skin of the suit :

PVC 9013 - Formule 1010, 20/100 mm thickness.

- Hood:

PVC Cristal - 30/100 mm thickness.

- Visor:

PVC (astraglass) 501100 mm thickness.

- Gloves:

PVC Sempersoft type - Size 9-91/2 for all the sizes of the suits.

- Boots :

PVC 9013 - formulation 1010 - 20/100 mm thickness , reinforced PMI.

1.2. COMPONENTS

- Internal Ventilation System:

It includes a total ventilation V4 fitted with a valve with butt.

- Exhaust:

It includes two exhaust valves located on the head and on the back of the suit.

- Fastening device:

It includes a double zip fastener situated vetically on the back of the suit.

- Other components:

The suit includes:

- A safety strip for an emergency opening located on the hood.

- A acoustic link tunnel.

- A loop for breathable air supply pipe.

- Several internal strengthening pieces for elbows, knees and Imegs.

- A transparent window to visualise the dosimeter.

Frenoh vesoim "ohall be used wohendispute

ECEC 971 0028 Page 4112

2. CONFORMITY TO REQUIREMENTS 2.1. REQUIREMENTS FOR THE MATERIALS (except accessories: Gloves, slippers...)

(See paragraph 4.2. of the Norm EN 1073-1) 2.1.1. Abrasion Resistance Test according to the Norm EN 530 - method 2 (abrasive paper 00). The classification is carried out according to the following diagram:

Class Number of cycles 6 > 2 000 cycles 5 > 1500 cycles 4 > 1 000 cycles 3 > 500 cycles 2 > 100 cycles 1 > 10 cycles Results: Class 6 for PVC 9013-formule 1010- 20/100 mm thickness.

Class 6 for Cristal PVC 30/100 mm thickness.

.1.2. Flexcracking Resistance Test according to the Norm ISO 7854 - method B. The clasification is carried out according to the following diagram :

Class Number of cycles 6 > 100 000 cycles 5 > 40 000 cycles 4 > 15 000 cycles 3 > 5 000 cycles 2 > 2 500 cycles I > 1 000 cycles This test is not applicable to suits for one single use only.

French ver only "Ial be used ohemdspte

ECEC 97/ 0028 Page 5/12 2.1.3. Puncture Resistance Test according to the Norm EN 863. The classification is carried out according to the following diagram :

Class Puncture resistance 3 > 100N 2 > 50N 1 > 1ON Results: Class 2 for PVC Cristal - 30/100 mm thickness.

Class 1 for PVC 9013- Formule 1010 -20/100 mm thickness.

2.1.4. Resistance in blocking

-Test according to the Norm EN 25978. The classification is carried out according to the following diagram.

Class Comments 2 non stick I sticky This test is not applicable to non-coated materials.

2.1.5. Tear Resistance Test according to the Norm EN 29073-4. The classification is according to the following diagram:

Class Applied strength 6 > 150N 5 > 80N 4 > 40N 3 > 20N 2 > 1ON 1 >2N Results:. Class 3 for PVC 9013- Formule 1010 - 201100 mm thickness.

Class 4 for Cristal PVC- 301100 mm thickness.

Frech verst1 only shall be used w dispute

ECEC 97 / 0028 Page 6112 2.1.6. Flammability of materials, visors, and ancillary parts Tests are carned out according to the Norms EN 1146 - single burner test (paragraph 7.5.3).

Results: Test requirements entirely fulfilled.

2.2. REQUIREMENTS FOR THE ACCESSORIES 2.2.1. Gloves The gloves set on the MURUROA V4 F1 ref. 8481X1T comply with the specific

,requirements for this type of Individual Protection Equipment, mainly to the Norm EN 421 "Protective Gloves against ionizer radiation and radioactive contamination".

They have Special EC Examination Certificates (ECEC) based on contracted tests.

2.2.2. Boots The boots are part and parcel of the suit and are made of the same constituted material.

Consequently they comply with the requirements.

2.3. REQUIREMENTS FOR THE PROTECTIVE SUIT 2.3.1. Suit Design: Practical Performance Test The Practical Performance Test is carried out according to the Norm 1073-1 (paragraph 5.2.).

The conditioning is according to the manufacturer directions for use.

Parameters Valuations a) Hood comfort Aimless b) Secunty of fastenings &couplings Good c) Accessibility of adjusting devices Good d) Clarity of vision through visor Good e) Suit comfort Good f) Speaking transmission facility Aimless g) Other parameters ,No particular notice 2.3.3. Air flow supply system (project Norm pr EN 1073 paragraph 4.8.)

The manufacturer estimated air flow rates, for a relative air flow supply pressure of 6 bar, with a tolerance of +/- 10%, are:

• Minimal flow rate 30,0 m3.h- 1 (500 L.min" 1)

• Maximum flow rate 58,4 m3 h-1 (973 L.min"1)

F-moh ioý " " be u.ed hM-dispute

ECEC 9710028 Page 7/12 Notice: In order to take into account the manufacturer indicated tolerances, this ECEC tests have been carried out under the following conditions:

Dmin = 27,0 m3 .h-1 (450 I.min 1 Dmax = 64,2 m3 .h 1 (1070 I.min")

The test concerning the air flow rates of the suit has been realised according to the Norm EN 1073-1 (paragraph 5.3), For an air supply pressure of 6 bar, the air flow rate inside the suit must not be : :

Below the minimum value estimated by the manufacturer (Dmin), when the valve is on the

".stop"closed position.

Supernor to the maximum value esitimated by the manufacturer (Dmax), when the valve is on the "on" opened position.

Results : Requirements entirely fulfilled.

2.3.3. Inward leakage average - Fit Factor (paragraph 4.3. of the project Norm pr EN 1073-1)

The ratio of the average inward leakage (or its contrary : Fit Factor) has been measured according to the draft Norm pr EN 943-1 (annex A). According to the Sodium Chloride Method.

Measurements have been performed under the following conditions:

Quantity of tested suits : 3 Air flow rate: Adjusted and maintained on minimum flow rate (D min) as indicated in paragraph 2.3.2.

Trainings sequence: According to the Norm EN 1073-1 Annex A list.

Suit preliminary conditioning: According to the advice of the user manual The ratio of the average inward leakage (or Fit Factor) gives the following classification:

Maximum accepted values, in %, of the ratio of the Ventilated * -average Inward Leakage inside the hood, pressurised calculated on the whole lot of suits FIT FACTOR Suit classification For One activity For all activities 5 0.004 0.002 50 000 4 0.010 0.005 20000 3 0.020 0.010 10000 2 0.040 0.020 5 000 1 0.100 0.050 2 000 Results : The suit is classified 5.

Fmc Mio oriy "iI be used ,khe. dspK e endh

ECEC 97/ 0028 Page 8/12 2.3.4.1. Seams I Welds (paragraph 4.4.1 of the project Norm pr EN 1073-1)

A sample of each type of seam/weld is tested according to the Norm ISO 5082 (annex 2).

The seam performance level is according to the following classification:

Class Seam resistance (N) 5 > 300 4 > 125 3 > 75 2 > 50 1 > 30 The tests have been applied to the folliowing welds:

- Assemblage hood/suit

- Assemblage hood/visor

- Assemblage hood level

- Assemblage belt level

- Assemblage of the strengthening pieces (elbow and knees)

- Assemblage at the level of the arms, back and sides Results : All the welds are classified 4.

2.3.4.2. Joins and Assemblages (paragraph 4.4.2. - project Norm pr EN 1073-1)

This suit has no removable parts. This paragraph is aimless.

2.3.4.3. Visors (paragraph 4.5. - project Norm pr EN 1073-1)

The distorsion of vision is measured, during the Practical Performance Test, by reading letters on an optometrical chart placed at a distance of 5 m; The loss of vision must not exced 2 degrees.

mechanical resistance test of the visor is according to the NormSTheEN 146 (paragraph 6.7.).

Results : Distortion of vision : Up to requirement.

Mechanical resistance : up to requirement.

Fench verJi~oly "hiM be used when dspute

ECEC 97/ 0028 Page 9112 2.3.6. Air supply system (paragraph 4.6. of the project Norm pr EN 1073-1)

The couplings and connections must comply with the requirements of the paragraphs 6.7.1.,

6.7.2., and 6.11.7. of the Norm EN 270. The connection between the compressed air supply system and the suit must resist to a 250 N pull.

Result. requirement entirely fulfilled.

2.3.7. Breathing Hose (paragraph 4.7. of the project Norm pr EN 1073-1)

Tests are performed according to the Norm 270 (paragraph 7.2. and 7.6) The pipes must not block the movements nor cause a rupture of the air supply during the Practical Performance Test.

Result. No constraint.

2.3.8. Air flow rate warning device (paragraph 4.9. of the project Norm pr EN 1073-1)

If a warning is fitted, it must comply to the Norm EN 270 (paragraph 6.13.3). The test must be carried out according to the Norm EN 270 (paragraph 7.12). The sound level must be between 85 dB(A) and 90 dB(A).

Result: Aimless (there is no warning device).

2.3.9. Air supply valve (paragraph 4.10 of the project Norm pr EN 1073-1)

For the air supply pressure specified by the manufacturer, the air supply valve must be able to adjust the air flow between the minimum and maximum values as indicated in the technical manual. It must be impossible to close the valve in order to reduce the air flow supply below the minimum flow rate as specified by the manufacturer.

Result: Requirements entirely fulfilled.

Notice: The MURUROA does not include low air flow indicator.

2.3.10.Exhaust devices (paragraph 4.11. of the project Norm pr EN 1073-1)

The exhaust devices must work correctly after the testing of the pressure in the suit, during the Practical Performance Test and dunng the determination of the Fit Factor. Test in accordance with the Norm 1073-1 (paragraph 5.6.)

Results: Good valves working.

Pull resistance superior to the fixed limit.

French version orgy shall be used when dispute

ECEC 97/ 0028 Page 10/12 2.3.11.Pressure in the suit (Paragraph 4.12. of the project Norm pr EN 1073-1)

During the activity sequence as specified, the overpressure shall not exceed 1000 Pa mean and 2000 Pa peak. A positive pressure shall be maintained.

Test is performed with maximum air flow rate D max, as stipulated in paragraph 2.3.2. on three different suits.

Result : Requirements entirely fulfilled.

2.3.12.Carbon dioxide content of the inhalation air (paragraph 4.13.-project Norm pr EN 1073-1)

The C02 content of the inhalation air, determined at the minimum air flow rate, shall not exceed an average of 1 % (by volume), tested according to the Norm 270 (paragraph 7.15) with the minimum air flow rate D min indicated in paragraph 2.3.2, on three diffeent suits.

Result: Requirement entirely fulfilled.

2.3.13. Noise associated with the air supply to the suit (paragraph 4.14 - project Norm pr EN 1073-1)

Test according to the Norm 270 (paragraph 7.16). The noise measured in the suit at the ears shall not exceed 80 dB(A) at the maximum air flow rate as indicated by the manufacturer.Tested at the maximum air flow rate D max as stipulated in paragraph 2.3.2, on three different suits.

Result: Requirement entirely fulfilled.

3. CHECKINGS 3.1. MARKING (paragraph 6 of the Norm project pr EN 1073-1)

The marking complies with the requirements of the Norms EN 340 and EN 1073-1.'According to the Decree dated February 7 T 1997 "relative to EEC marking of the working equipment and of the Personal Protective Equipment", it includes the distinctive number of the entitled

-organisation for the procedure of controls of the manufactured 'PPE (article 11-of the EEC Directive 891686/EEC).

The symbol "i" is included in the pictogram, in order to show that the manufacturer instructions should be read by the user..

3.2. MANUFACTURER INFORMATION (Paragraph 7 of the project Norm pr 1073-1)

Information comply with the specifications of the project of Norm pr 1073-1. They include the Directions for use, the conditions of use, the specific limits and restraints.

Thes documents will be corrected in order to take into account the tests results as mentionned in this ECEC.

Frech vesion ory "'I be used when dis"*

ECEC 97/ 0028 Page 11/12 3.3. MAINTENANCE MARKING This is aimless, the suit being for one single use only.

4. CONCLUSIONS Upon presentation of the tests results, the Ventilated - pressurised for a single use only, MURUROA V4 F1 - ref. 8481XIT is certified to ensure a protection against radioactive contamination according the following specified limits :

Minimum air flow rate: 27,0 m3.h 1 .

Maximum air flow rate: 64,2 m3.h"1.

The MURUROA V4 F1 is delivered without low air flow rate indicator.

Before using it, the user will have at his disposal the necessary devices to check that the minimum air flow rate, as specified by the manufacturer is reached or over reached before and during the use of the suit.

Fech vIrsicn orgy shall be used whe dispute

ECEC 9710028 Page 12112 ANNEX I Description and references of the equipment certified in the EC Type Examination Certificate The different models of equipment, whose generic appellation is MURUROA V4 Flref. 8481X1T, and which are the subject of this EEC type examination certificate (ECEC), are only-different on the following points.

- The type of pipe buttconnecting the equipment ,to the breathable compressed air'supply system.

- The size.

X indicates the type of pipe butt according to the following values:

Type of butt for connection to References of MURUROA References the compressed air supply V4 F1 associated system X=2 Staubli RBE 06 6150 848121 T X=3 Staubli RBE 06 848131 T "d~trompeur" X=4 CEJN 342 848141 T X=8 Staubli RBE 06 QR 848181 T T indicates the size of the suit according to the following values:

REFERENCE Height ( cm) Waist measurement (cm)

T=0 152-164 56-64 T=1 164-170 64-68 T=2 170-176 68-72 T=3 176-182 72-76 T=4 182-188 76-80 T=5 188-200 80-88 Fren~chverson only shall be used wh/endispite

Duke Energy Corporation Exemption Request March 4, 2003 ATTACHMENT 2.5.5 DONNING AND REMOVAL INSTRUCTIONS FOR MURUROA V4 Fl

NO: Do/ USA/ 2 INDICE: a MURUROA L NDCE_*_a

__ _ INSTRUCTIONS FOR DONNING AND DATE D'APPLICATION :06/09/01 REMOVAL THE MURUROA V4 FULLY DELTA PROTECTION ENCLOSED SUIT ) 04 66 89 18 36 PAGE :1/5 INSTRUCTIONS FOR DONNING AND REMOVAL THE MURUROA V4 FULLY ENCLOSED SUIT

NO: Do/ USA/ 2 INDICE: a MURUROA INSTRUCTIONS FOR DONNING AND DATE D'APPLICATION :06/09/01 REMOVAL THE MURUROA V4 FULLY DELTA PROTECTION ENCLOSED SUIT S 04 66 89 18 36 PAGE :2/5 FOREWORD The Mururoa suit is a fully enclosed supplied-air suit; designed for protecting the wearer against radioactive contamination brought about by contact with liquid or solid substances or by atmospheric pollutants such as solid particles, mist gases or vapors.

Made of non-flammable PVC sheet its mechanical and chemical resistance is good enough for working in most of the nuclear environments, acids, bases or low concentration solvents.

Caution should always be used around sharp edges and tools to avoid tearingof the Mururoa.

Contact-with open flames or grinding spark ray for instance must be avoided to prevent perforation by melting of the PVC skin.

At any time: avoid direct contact with objects less than 5 0C (41 0 F) or more than 60°C (140°F) temperature. It is the responsibility of the supervisor to qualify, by preliminary test, the ability of "the suit to protect the wearer against the harmful atmosphere in each specific environment CAUTIONS

1) Care must always be taken due to the asphyxiation hazard.

2) The buddy system must be in effect with the use of this suit fed with a sufficient breathable air source with either both persons in it or the second person nearby in view with a particulate respirator ready.

3) Suit removal under ordinary circumstances requires an assistant.

4) Thorough knowledge of the safety features of the Mururoa are essential for safety!

a) a safety strip for breathing can be pulled open should air supply be restricted.

-b) a safety strip for suit egress in an emergency is available by using pull tab on each elbow.

c) do not over tighten any tape applied to the suit as it will prevent rapid suit removal.

5) An air supply of 1 to 3 minutes exists inside the suit~should the air supply fail.

During that time, due to the magnetic exhaust valves, the garment will remain overpressurised, avoiding penetration of harmful atmospheres as long as portions of the remaining air have not

' been forced out of-the suit such as if the wearer bendsover and forces air out the discharge valves.

NO: Do / USA / 2 INDICE: a MURUROA INDICE__:_a _ INSTRUCTIONS FOR DONNING AND DATE D'APPLICATION :06/09101 REMOVAL THE MURUROA V4 FULLY DELTA PROTECTION ENCLOSED SUIT 0)04 66 89 18 36 PAGE :3/5 DONNING

1) Review the safety features of the Mururoa with the accompanying assistant and compare with the job scope.

2) The package containing the Mururoa must have been kept 2 hours2.314815e-5 days <br />5.555556e-4 hours <br />3.306878e-6 weeks <br />7.61e-7 months <br /> or more at a temperature around 20'C before being opened and the devices manipulated.

3) Near the job site remove garment from the bag, shake open and inspect for obvious defects.

S-4) Inspect the emergency egress strip to ensure that the strip can be removed easily if desired.

5) Remove the cardboard and the clear plastic faceplate protector. Remove the paper sheet placed in the head position. Discard these.

6) In the donning and removal area, verify that the local breathable air supply is working properly.

7) Connect the garment to the local air supply with a flexible hose. Take care that the hose goes through the throttle valve by using the loop at the back right side of the suit.

-8) Donthe suit from the back with the help of the assistant. Connect the MURUPHONE phonic system if used and check.

9) Bind the shoe joints with the shoe strips and apply tape, if necessary, to the suit gloves.

10) Zip up the mechanical zip.

11) Zip up the external plastic gas sealing zipper when the suit is inflated.

Apply an adhesive tape of sufficient width on the second zip-fastener to be shure no leak occurs.

12) Check the air supply valve and adjust to the desired flow for comfort.

13) Perform several crouching exercises to ensure the exhaust valves work; the air source is sufficient to recharge the suit to its full volume quickly and to check for leaks.

14) Proceed-to the job site and -begin to work. -You can disconnect the hose from the air line, and travel from the donning area to the working area to reconnect your suit at the step off pad; after having insured the air source in the working area is well fed and if the time, disconnected is not more than a few dozen of seconds.

• 15). Comfort in breathing and -in temperature. can be maintained - by adjusting the air inlet regulating valve during work.

CAUTION Should the Mururoa feel hot, deflate, or if fog appears on the faceplate, leave immediately and quietly the working area and contact your assistant for suit removal.

Remember:

1) The air supply of I to 3 minutes exists inside the suit after breaking of air supply feeding.

2) The suit emergency strips are there for your use if needed.

N': Do / USA / 2 INDICE: a MURUROA INSTRUCTIONS FOR DONNING AND DATE D'APPLICATION :06/09/01 REMOVAL THE MURUROA V4 FULLY DELTA PROTECTION ENCLOSED SUIT 0) 04 66 89 18 36 PAGE :4/5 SUIT REMOVAL (with assistance)

When he has to leave the working area, the wearer comes back to the dressing area where an assistant will remove the garment.

1) Remove the clothing while still connected with the air source, remove any restrictive tape (on gloves joint for instance).

2) Pull slowly on the tab of the quick release strip from forearm, overhead to forearm.

3) Carefully remove by-rolling up the two half parts of the suit (front and back, without touching any exterior contaminated surfaces)

4) Continue shedding the suit down.

5) Disconnect the air feeding to the suit.

6) Step out of the suit.

7) Discard suit into appropriate container.

NO: Do / USA / 2 INDIE:

aMURUROA INDICE

• a INSTRUCTIONS FOR DONNING AND DATE D'APPLICATION :06/09/01 REMOVAL THE MURUROA V4 FULLY DELTA PROTECTION ENCLOSED SUIT (7)04 66 89 18 36 PAGE :5/5 EMERGENCY FEATURES EMERGENCY EGRESS

1) Grasp emergency pull-off strip on either elbow with hand.

2) Pull strip firmly upward until the suit separates over the head and to the other elbow.

3) Step out of suit when appropriate.

4) Move to a safe area.

EMERGENCY BREATHING

1) Pull month strip off with either hand

2) Separate plastic of mouth and breath

3) Move to a safe area and get assistance

Duke Energy Corporation Exemption Request March 4, 2003 ATTACHMENT 2.5.6 CERTIFICATE NO. 00731197/16210119610001 ISSUED FOR MURUROA V4 MTH2 BY THE INSTITUTE FOR NUCLEAR PROTECTION AND SECURITY

ECEC 9610001 Page 1/9 INSTITUTE FOR NUCLEAR PROTECTION AND SECURITY Technical Center for Nuclear Equipment Certification In accordance with the directive 89/686/EEC dated December 21 th 1989 comparing the laws of the States Members Legislations relative to the Personal Protective Equipments, and the decrees no 92 765, 766 and 768 dated July 29h 1992 transposing the directive into French Laws.

The organisation here below mentioned (IPSN / CTHEN) whose references are as follows:

- Address : B.P. n° 6 - 92265 Fontenay-aux-Roses Cedex (France).

- Empowered by Order of the Ministries of Employment and Agriculture dated December 24th 1996.

-- Identified under the no 0073 (published in the EEC Official Publication dated July 23 th 1994).

Assigns the :

EC TYPE EXAMINATION CERTIFICATE No 0073 1197 / 162 / 01196 1 0001 To the following Personal Protective Equipment model

- Designation: Ventilated Protective Suit against Radioactive Contamination pressurised for a single use only.

- Commercial reference : MTH 2 - ref. 841 442 T.

- -Manufacturer: DELTA PROTECTION I REDI - 69 210 Saint-Germain-Sur-L'Abresle.

- Certificate applicant: DELTA PROTECTION - Z A. De Berret-30200 Bagnols-Sur-Ceze.

- Essential Requirements

Reference:

EN 143,,pr EN -1073 (nov. 1995), pr EN 943 (august 1995), EN 270, EN 146.

Date : January 10 " 1996 G.BRUHL I Chief of CTHEN Nota : According to article R 223-62 of the "Working Law", the empowered organisation should be informed of any modification made to the material subject of this EEC type examination certificate, as well as of any modification made to the contents of this technical file on which the delivered type certificate was based on (address, manufacturer name, quality insurance certificate extract, ... )

This certificate contains 12 pages no 1/9 to 9/9 Frnh versio only "iI be used whwedispute

ECEC 96 / 0001 Page 2/9

1. DESCRIPTION It is a Ventilated Protective Suit against Radioactive Contamination ventilated type - pressurised for a single use only, its name is:

MTH2 - ref. DELTA: 841 442 T The T values are defined according to the size of the suit.

The suit includes.

- A air tight suit with an incorporated hood

- A suit fastening system located on the back of the suit.

- A breathable air flow supply system.

- A air exhaust device.

- A safety stnp for emergency opening located on the hood.

Front view Profil Ocular Dosimetrc window A  ;% Eibow reinforcement Bootie F re ch e ly s hUb . . se o on d .w en ip ute

ECEC 9610001 Page 319 1.1. MAIN MATERIALS

- Skin of the suit:

White polyethylene: Ethyfuge 2000 Thickness: 24/100 mm

- Hood:

PE Cristal - 30/100 mm thickness.

- Visor:

PVC (astraglass) 50/100 mm thickness.

- Gloves:

PVC Sempersoft type - Size 9-91/2, and Semperstar type - size 10-10 1/2..

- Boots :

Polyethylene - 24/100 mm thickness , reinforced with PE cristal.

1.2. COMPONENTS

- Internal Ventilation System:

It includes a total ventilation V4 fitted with a valve with CEJN (r~f:342) butt.

- Exhaust:

It includes two exhaust valves located on the head and on the back of the suit.

- Fastening device:

It includes a double zip fastener located vertically on the back of the suit

- Other components:

The suit includes:

- A safety strip for an emergency opening located on the hood.

- A acoustic link tunnel.

- A loop for breathable air supply pipe.

- Several internal strengthening pieces for elbows, knees and legs.

- A transparent window to visualise the dosimeter.

2. CONFORMITY TO REQUIREMENTS 2.1. REQUIREMENTS FOR THE MATERIALS (except accessories: Gloves, slippers...)

(See paragraph 5.1. of the prEN 1073)

F-*h yemen only "Idlbe used when dispute

ECEC 9610001 Page 4/9 2.1.1. Abrasion Resistance Test according to the Norm EN 530 - method 2 (abrasive paper 00). The classification is carried out according to the following diagram:

Class Number of cycles 6 > 2 000 cycles 5 > 1500 cycles 4 > 1 000 cycles 3 > 500 cycles 2 > 100 cycles 1 > 10 cycles Results: Class 6 for Ethyfuge 2000 -241100 mm thickness.

Class 6 for PVC.

.1.2. Flex cracking Resistance Test according to the Norm ISO 7854 - method B.The classification is carried out according to the following diagram :

Class Number of cycles 6 > 100 000 cycles 5 > 40 000 cycles 4 > 15 000 cycles 3 > 5000 cycles 2 > 2500 cycles 1 > 1 000 cycles This test is not applicable to suits for one single use only.

2.1.3. Puncture Resistance

-Test according to the Norm EN 863. The classification is carried out according to the following diagram:

Class Puncture resistance 3 > 10ON 2 > 50N 1 > ION Results: Class 1 for Ethyfuge 2000 - 24/100 mm thickness.

Class 2 for PE cristal.

Frdenhversm only "I be ued wlen dispute

ECEC 96 / 0001 Page 5/9 2.1.4. Resistance in blocking Test according to the Norm ISO 5978. The classification is carried out according to the following diagram:

Class Comments 2 non stick I sticky This test is not applicable to non-coated materials.

2.1.5. Tear Resistance Test according to the Norm ISO 9073-4. The classification is according to the following diagram:

Class Applied strength 6 > 150N 5 > 80N 4 > 40N 3 > 20N 2 > 1ON 1 > 2N Results :. Class 4 for Ethyfuge 2000 - 24/100 mm thickness.

Class 3 for PE Cnstal.

2.1.6.Flammability of materials, visors, and ancillary parts Tests are carried out according to the Norms EN 1146 - single burner test (paragraph 7.5.3).

Results: Test requirements entirely fulfilled.

2.2. REQUIREMENTS FOR THE ACCESSORIES 2.2.1 .Gloves The gloves set on the MTH2 ref. 841 442 T comply with the specific, requirements for this type of Individual Protection Equipment, mainly to the Norm EN 421 "Protective Gloves against ionizer radiation and radioactive contamination".

They have Special EC Examination Certificates (ECEC) based on contracted tests.

Freh verdsi orny shal be used veAt dipute

ECEC 96/0001 Page 6/9 2.2.2.Boots The boots are part and parcel of the suit and are made of the same constituted material.

Consequently they comply with the requirements.

2.3. REQUIREMENTS FOR THE PROTECTIVE SUIT 2.3.1. Suit Design: Practical Performance Test The Practical Performance Test is carried out according to the prEN 1073 (paragraph 6.2.)

The conditioning is according to the manufacturer directions for use.

Parameters Valuations a) Harness comfort Aimless b) Security of fastenings &couplings Good c) Accessibility of adjusting devices Good d) Clarity of vision through visor Good e) Suit comfort Good g) Other parameters No particular notice 2.3.2. Fit Factor (paragraph 5.2.2. of the pr EN 1073)

The protection factor is determined according to the PrEN 944 standard (paragraph 8.9) by respecting the sequences indicated in Annex A of the PrEN 1073.

The mean leakage value ( or inversely, the protection factor) enables a clothing classification according to the following table. The preconditioning according to the instructions for use recommendations.

- Maximum accepted values, in %, of the ratio of the Ventilated average Inward Leakage inside the hood, pressunsed calculated on the whole lot of suits FIT FACTOR

- Suit classification For One activity For all activities 5 0.004 0.002 50 000 4 0.010 0.005 20 000 3 0.020 0.010 10000 2 0.040 0.020 5 000 1 0.100 0.050 2000 Results : The suit is classified 5.

Fnmch -Imlo o~y s"aI be used when disptet

ECEC 961 0001 Page 7/9 2.3.3.1. Seams, Joins and Assemblages pull test resistance 2.3.3.1. Seams I Welds (paragraph 5.2.3.1 of the pr EN 1073)

A sample of each type of seam/weld is tested according to the Norm ISO 5082 (annex 2).

The seam performance level is according to the following classification-Class Seam resistance (N) 5 > 300 4 > 125 3 > 75 2 > 50 1 > 30 The tests have been applied to the following welds:

- Elbow and knee reinforcement

- Crotch assembly

- Belt assembly

- Booties assembly Results : All the welds are classified 3.

2.3.3.2. Joins and Assemblages (paragraph 5.2.3.2. - prEN 1073)

This suit has no removable parts. This paragraph is aimless.

2.3.4 Gas tight (paragraph 5.2.4. of prEN 1073.

The test was carried out according to the EN 464 standard . The loss of pressure shall not be greater than 4 mbar in 6 minutes.

Results : Test not undertaken as the clothing is not considered as an gastight suit.

2.3.5. Visors (paragraph 5.2.5. of prEN 1073)

• The distortion of -vision is measured, during -the -Practical 'Performance. The mechanical resistance test of the visor is according to the Norm EN 146 (paragraph 6.6 and 6 7.).

Results : Distortion of vision : Up to requirement.

Mechanical resistance : up to requirement.

Fnmcer.on orly Ma be used wt&ndispue

ECEC 96/0001 Page 8/9 2.3.6. Air supply system (paragraph 5.2.6. of the pr EN 1073)

The couplings and connections must comply with the requirements of the paragraphs 6.7.1.,

6.7.2., and 6.11.7. of the EN 270. The connection between the compressed air supply system and the suit must resist to a 250 N pull.

Result: requirement entirely fulfilled.

2.3.6. Breathing Hose (paragraph 5.2.7. of the pr EN 1073)

Tests are performed according to the EN 270 (paragraph 7.2. and 7.6). The pipes must not block the movements nor cause a rupture of the air supply during the Practical Performance Test.

Result No constraint 2.3.7. Air supply flow rate (paragraph 5.2.8. of the PrEN 1073)

The test is carried out according to the PrEN 1073 standard (paragraph 6.3).

Result Minimal flow rate.30 m3 .h 1 (500 Iainm1) for a 6 Bar supply pressure Maximal flow rate.66 m3 .h 1 (1100 VImin"1) for a 5.5 Bar supply pressure 2.3.8. Air flow rate warning device (paragraph 5.2.9. of the pr EN 1073)

If a warning is fitted, it must comply to the EN 270 (paragraph 6.13.3). The test must be carried out according to the EN 270 (paragraph 7.12) The sound levelmust be higher than 85 dB(A).

Result: Aimless (there is no sonic warning device).

2.3.9. Air supply valve (paragraph 5.2.10 of the pr EN 1073)

Where present, the control valve should enable a variation of flow rate between the minimum and maximum specified values without the possibility of closure.

Result: Requirements entirely fulfilled.

2.3.11.Exhaust devices (paragraph 5.2.11. of the pr EN 1073)

The exhaust devices must work correctly after the testing of the pressure in the suit, during the Practical Performance Test and during the determination of the Fit Factor. Test in accordance with the EN 1073 (paragraph 6.6.).

Results: Good valves working.

Pull resistance superior to the fixed limit.

French vesimonoy shaWlbe used when dispfte

ECEC 9610001 Page 9/9 2.3.12.Pressure in the suit During the activity sequence as specified, the overpressure shall not exceed 1000 Pa mean and 2000 Pa peak. A positive pressure shall be maintained.

Result: Requirements entirely fulfilled.

2.3.13.Carbon dioxide content of the inhalation air The CO 2 content of the inhalation air, determined at the minimum air flow rate, shall not exceed an average of 1 % (by volume),-tested according to the EN 270 (paragraph 7.15).

Result: Requirement entirely fulfilled.

2.3.14. Noise associated with the air supply to the suit (paragraph 5.2.14 - pr EN 1073)

Test according to the EN 270 (paragraph 7.16). The noise measured in the suit at the ears shall not exceed 80 dB(A) at the maximum air flow rate as indicated by the manufacturer.

Result: Requirement entirely fulfilled.

3. CHECKINGS 3.1. MARKING (paragraph 7 of the pr EN 1073)

The marking is satisfies the requirements of article 7 in the EN 340.

3.2. MANUFACTURER INFORMATION (Paragraph 8 of the pr 1073)

"The manufacturers information complies with the specifications in paragraph 8 of the EN 340.

They contain the .instructions for use, the usage conditions and the specific limits and restraints.

3.3. MAINTENANCE MARKING This is aimless, the suit being for one single use only.

4. CONCLUSIONS Upon presentation of the tests results, the Ventilated suit - pressurised for a single use only, MTH 2- ref. 841 '442 T is certified to ensure a protection against radioactive contamination according the following specified limits :

- Minimum air flow rate: 30 m3 .h"1 (500 I.min"1)

- Maximum air flow rate: 66 m3 .h-.(1100 I.min"1)

F-h v -1y sha9 be .ed eh-n disput.

Duke Energy Corporation Exemption Request March 4, 2003 ATTACHMENT 2.5.7 PROTECTION FACTOR DETERMINED DURING FIT TEST EXERCISES FOR V4 MTH2

DPENSTESR/CTHEN/02-642 Page /2 Test Results carried out on the full encapsulated suit MTH2 ref. 841442T For the EC Type Examination Certificate N00073/197/162/01/96/0001 You will find below the detailed results taken in account for being able to statue on the conformity of this equipment in accordance with the Essential Requirements of the European Standard pr EN 1073-1 (revision Nov 1995). Other results those are non pointed out10th in this already written in the EC TYPE Examination certificate (dated December report are 1997) 1 - Air Flow entering the suit when connected to a 6 bar feeding pressure (paragraph

.5.2.8. of the EC Type Examination Certificate)

'--$uit Entrance valve position Air flow feeding pressure air flow (m3/h /

numberK Bar / psig Imnl cfm) 1 Fully open 5,5/ 77 66/1100/38 1 Closed 6,0/87 30/500/17 2 Fully open 5,5/77 65 / 1080/37,8 2 closed 6,0/87 31/516/18 2 - Carbon dioxide content of the Inhalation air when measured at the minimum air flow (paragraph 5.2.13. of the EC Examination Type) ul Feeding pressure Air flow C02 contents(%)

num Bar I psig M3/h I cfm 1 6/87 30/17 0,85 2 6/87 31 / 18 0,80 3 - Noise level associated with the air supply to the suit when tested at the maximum air flow rate (paragraph 5.2.14 of the EC Examination Tvpe) ut Feeding pressure Air flow Noise level (dB) num Bar / psig M3Ih; cfm 1 5,5/77 66/38 76,8 2 5,5/77 65/37,8 78,5

Page2/2 4 - Inward leakage avera-ge- Fit Factor measured at the minimal air flow of 4501/mn (paragraph 2.3.3. of the CE Examination Type)

Suit no 1 2 Exercise Air flow m3/h/ I/mn / cfm 30/500/17 31/516/18 Standing still 130000 130000 Walking (5 km/h) 59 500 50 000 Moving arms up and down 125 000 125 000 above head Continuous squats 65 000 81 250 Bending forward 100 000 92850 Person twisting at waist 115 000 130000 Standing still 130 000 130000 Average 103500 103440 5 - Pressure in the suit when measured at the maximum air flow when suit connected under 5.5 bar (77psig) feeding pressure (paragraph 4.12.of the EC Examination Type)

Suit no 1 2 Exercise P ave/ P min/ Pmax P ave; P min, P Max.

daPa. daPa Standing still 40 - - 38 -

Walking ( 5 km/h) 40 23 74 100 61 128 Moving arms up and down 40 17 62 46 18 72 above head Continuous squats 42 4 86 56 3 110 Bending forward 52 3 104 74 0 162 Person twisting at waist 38 18 58 46 20 110 37 - - 40 -

Person crawling

For Information: Both overboots are breaked at the end of the test 6 Over pressure and fit factor when person crawlinq on the floof as indicated In paragraph 4.12 and 5.2.2 of the pr EN 1073-1dated 1995 Suit number Crawling exercise Average DP Minimum DP Maximum DP Fit Factor daPa daPa daPa 1 52 12 90 110000 2 65 3 102 105000 7 Screen:( paragraph 5.2.5)

- Distortion of the vision: none

- Mechanical resistance : no incidence on the screen.

Duke Energy Corporation Exemption Request March 4, 2003 ATTACHMENT 2.5.8 DONNING AND REMOVAL INSTRUCTIONS FOR MURUROA V4 MTH2

NO/841442T INDICE: e M.T.H.2 DATE: 12/00 PAGE : 1/1 INSTRUCTIONS FOR USE Preliminary remarks : This clothing is to be used under the authority of the person responsible for the intervention who has previously checked that :

- the clothing offers the necessary protection for the risk category to be encountered during the intervention.

- Breathable air

• sockets, with connectors compatible with that of the clothing, are actually available on the intervention site and that they are capable of supplying a sufficient quantity of air :

minimum flow rate 500 liters/mm +i- 10% at 6 Bars; (17 cfm at 87 psig) maximum flow rate 1100 liters/min. +1-10% at 6 Bars ; (38cfm at 87 psig)

DRESSING

- The wearer, with a helper, visually inspects the state of the garment and its components then removes the shipping protection (cardboard on the visor and inside the garment, and removable "cristal" on the visor).

- He slips on the bottom of the garment through the rear opening

- Connects to the breathable air circuit by passing the supply pipe through the loop at the rear of the garment, at the same height as the supply valve.

- Connects , if used, the MURUPHONE system and finishes dressing.

- The helper zips up the dual zipper system and applies a large strip of adhesive tape to the upper extremity of the second zip to ensure air tighness; he ties the over boot laces around the ankles.

- The wearer controls the correct functioning of the air supply; the correct functioning of the supply flow valve and the over pressure valves by crouching rapidly a few times.

- He can go to the work zone.

UNDRESSING

- Removal may be done with the strap envisaged for this usage in the following manner; while the garment is still being supplied with air, the helper pulls on the orange strap, which runs from one wrist to the other over the helmet, and rolls up the front and rear parts in a way that traps the contamination and avoids all contact with the intervening person IMPORTANT

- Leave the work zone immediately if the clothing deflates during the intervention, if the helmet fogs or if the person has a feeling of excessive warmth.

- Remenber that the clothing remains pressunsed for a few moments in the case of an air supply failure STORAGE 0 0 In the original packaging; out of the light, between + 5°C and + 450C.( 41 F and 113 F)

USAGE 0 The air supply should be between + 15°C and + 450C. ( 591F and 1 13 F)

EXPIRY DATE The clothing should be used by the third year from the date of manufacture.

CLEANING Not necessary for this type of equipment which is for a simple usage only.

EMERGENCY MEASURES

- Air outside of the garment can be breathed by removing the strap at the front of the helmet.

- The removal strap, removed by the wearer, enables the wearer to get out of the garment in under 5 seconds.

• Breathable air: see the EN 132 standard.