ML050330405
| ML050330405 | |
| Person / Time | |
|---|---|
| Site: | Grand Gulf, Arkansas Nuclear, River Bend, Waterford  |
| Issue date: | 02/01/2005 |
| From: | Howe A NRC/NRR/DLPM/LPD4 |
| To: | Burford F Entergy Operations |
| Alexion T W, NRR/DLPM, 415-1326 | |
| References | |
| TAC MC5363, TAC MC5364, TAC MC5365, TAC MC5366, TAC MC5367 | |
| Download: ML050330405 (10) | |
Text
February 1, 2005 Mr. F. G. Burford Acting Director Nuclear Safety & Licensing Entergy Operations, Inc.
1340 Echelon Parkway Jackson, MS 39213-8298
SUBJECT:
ARKANSAS NUCLEAR ONE, UNITS 1 AND 2; GRAND GULF NUCLEAR STATION; RIVER BEND STATION; WATERFORD STEAM ELECTRIC STATION, UNIT 3 - USE OF DELTA PROTECTION SUITS (TAC NOS. MC5363, MC5364, MC5365, MC5366, MC5367)
Dear Mr. Burford:
By letter dated December 9, 2004, as supplemented by letter dated December 17, 2004, you submitted a request, under 10 CFR Part 20, for authorization to use and take credit for the Mururoa V4 MTH2 air-supplied suits. These suits provide respiratory protection for persons working in areas of airborne radioactivity.
The NRC staff has reviewed the subject request and finds it acceptable. The NRC staff's related Safety Evaluation is enclosed.
Sincerely,
/RA by M. Webb for A.Howe/
Allen G. Howe, Chief, Section 1 Project Directorate IV Division of Licensing Project Management Office of Nuclear Reactor Regulation Docket Nos. 50-313, 50-368, 50-416, 50-458, 50-382
Enclosure:
As stated cc w/encl: See next page
February 1, 2005 Mr. F. G. Burford Acting Director Nuclear Safety & Licensing Entergy Operations, Inc.
1340 Echelon Parkway Jackson, MS 39213-8298
SUBJECT:
ARKANSAS NUCLEAR ONE, UNITS 1 AND 2; GRAND GULF NUCLEAR STATION; RIVER BEND STATION; WATERFORD STEAM ELECTRIC STATION, UNIT 3 - USE OF DELTA PROTECTION SUITS (TAC NOS. MC5363, MC5364, MC5365, MC5366, MC5367)
Dear Mr. Burford:
By letter dated December 9, 2004, as supplemented by letter dated December 17, 2004, you submitted a request, under 10 CFR Part 20, for authorization to use and take credit for the Mururoa V4 MTH2 air-supplied suits. These suits provide respiratory protection for persons working in areas of airborne radioactivity.
The NRC staff has reviewed the subject request and finds it acceptable. The NRC staff's related Safety Evaluation is enclosed.
Sincerely,
/RA by M. Webb for A.Howe/
Docket Nos. 50-313, 50-368, Allen G. Howe, Chief, Section 1 50-416, 50-458, 50-382 Project Directorate IV
Enclosure:
As stated Division of Licensing Project Management cc w/encl: See next page Office of Nuclear Reactor Regulation DISTRIBUTION:
PUBLIC PDIV-1 Reading RidsNrrDlpmLpdiv (HBerkow)
RidsNrrDlpmLpdiv1 (AHowe)
RidsNrrLADJohnson (4)
Rids NrrPMBVaidya RidsNrrPMTAlexion RidsNrrPMNKalyanam RidsNrrPMDHolland RidsNrrPMMWebb RPedersen RidsOgcRp RidsAcrsAcnwMailCenter RidsRgn4MailCenter (AHowell)
Accession No.: ml050330405 OFFICE PDIV-1/PM PDIV-1 PDIV-1/LA IPSB/SC OGC PDIV-1/SC NAME TAlexion TAlexion for MThorpe-Kavanaugh DJohnson RPedersen for SKlementowicz MLemoncelli nlo w/comments MWebb for AHowe DATE 2/1/05 2/1/05 2/1/05 01/11/05 01/31/05 2/1/05 OFFICIAL RECORD COPY
SAFETY EVALUATION BY THE OFFICE OF NUCLEAR REACTOR REGULATION USE OF RESPIRATORY PROTECTION EQUIPMENT ENTERGY OPERATIONS, INC.
ARKANSAS NUCLEAR ONE, UNITS 1 AND 2 GRAND GULF NUCLEAR STATION RIVER BEND STATION WATERFORD STEAM ELECTRIC STATION, UNIT 3 DOCKET NOS. 50-313, 50-368, 50-416, 50-458, 50-382
1.0 INTRODUCTION
By letter dated December 9, 2004, as supplemented by letter dated December 17, 2004, Entergy Operations Inc. (the licensee) submitted a request to use certain air-supplied suits that provide respiratory protection for persons working in areas of airborne radioactivity.
Specifically, the licensee requested authorization (1) to use French-designed respiratory protection equipment that has not been tested and certified by the National Institute of Occupational Safety and Health (NIOSH), (2) to not provide standby rescue persons whenever this equipment is used, and (3) to take credit for an assigned protection factor (APF) of 2000 for this equipment.
2.0 REGULATORY EVALUATION
Title 10 of the Code of Federal Regulations (10 CFR) Part 20, Standards for Protection Against Radiation, Subpart H, Respiratory Protection and Controls to Restrict Internal Exposure in Restricted Areas, concerns the use of respiratory protection equipment for protection against airborne radioactive materials.
Section 20.1703, Use of individual respiratory protection equipment, paragraph (a), requires that respiratory protection equipment used by a licensee to limit the intake of radioactive material be tested and certified by NIOSH. Section 20.1703(b) states that a licensee can submit an application to the Nuclear Regulatory Commission (NRC) for authorized use of respiratory protection equipment that has not been tested and certified by NIOSH.
Section 20.1703(f) requires that standby rescue personnel be provided whenever respiratory protection equipment from which an unaided individual would have difficulty extricating himself or herself is used.
Appendix A, Assigned Protection Factors for Respirators, does not provide an APF for atmosphere supplying respirator (air-line respirator) suits in a continuous-flow operating mode.
Instead, it references footnote (g) that states, No 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., §20.1703).
Section 20.1705, Application for use of higher assigned protection factors, states that a licensee shall obtain NRC authorization before using assigned protection factors in excess of those specified in Appendix A to Part 20. Thus, the licensee must obtain NRC approval to take credit for an APF for the French-designed respiratory protection equipment.
Criteria and background information used for the NRC staffs technical evaluation include 10 CFR Part 20, Subpart H; 10 CFR Part 19, paragraph 19.12, "Instruction to Workers; Regulatory Guide 8.15, Revision 1, "Acceptable Programs for Respiratory Protection; NUREG/CR-0041, Revision 1, "Manual of Respiratory Protection Against Airborne Radioactive Materials; 42 CFR Part 84, which addresses NIOSH testing and certification regulations; Los Alamos National Laboratory Report LA-101560MS, "Acceptance Testing Procedures for Air-Line Supplied Air Suits; and American National Standards Institute standard ANSI Z88.2-1992, "American National Standard Practices for Regulatory Protection."
3.0 TECHNICAL EVALUATION
NRC guidance provided in NUREG/CR-0041 encourages the use of suits, noting that in certain work environments, air-supplied suits may be the best respiratory device when considering heat stress, trying to minimize skin contamination, and trying to maintain worker doses as low as is reasonably achievable (ALARA).
Testing conducted by the Institute for Nuclear Protection and Security Technical Center for Nuclear Equipment Certification (IPSN/CTHEN), the French certifying agency (comparable to NIOSH), and over 20 years of successful use in European power plants of similar certified suits form the basis for the licensees request. The licensee has requested authorization to use, and to take credit for, the protection provided by the Mururoa V4 MTH2 air-supplied suit from Delta Protection. This respiratory protection equipment has not been certified by NIOSH. However, this model suit has been approved as a single-use suit (a suit that is disposed of after one use) by the IPSN/CTHEN (Certificate No. 0073/197/162/01/96/0001).
The licensee proposes to use the suit in the approved configurations, relative to the suit's form, fit, and function. Specifically, the Mururoa V4 MTH2 will be provided with a reliable source of breathable air capable of supplying a minimum of 17 cubic feet per minute (CFM), and a maximum of 38 CFM, at 85 pounds per square inch, gauge (6 Bars).
The European Standard CEN/TC 162N738 (July 1996), Protective Clothing Against Radioactive Contamination, Part 1: Requirements and Test Methods for Ventilated Protective Clothing Against Particulate Radioactive Contamination, provided testing and acceptance criteria used for certification of the suit. This standard is generally consistent with the pertinent acceptance criteria provided in Los Alamos National Laboratory Report LA-10156-MS, which is used to test and authorize the use of air-supplied suits at Department of Energy sites.
The certification-testing regime was broadly based and encompassed a range of various functional areas, including the following: suit material strength, tear and puncture resistance, material flammability, wearer comfort, noise level, wearer visibility, air flow, carbon dioxide concentrations, and degree of contaminate in-leakage during a series of varied simulated work practices and exercises. The Mururoa V4 MTH2 suit passed all required tests, and it provided a measured average protection level (fit factor) of 50,000. A fit factor, which was developed in a simulated work environment, is the ratio of contaminate concentration outside the suit to the contaminate concentration inside the suit. Given an overall measured fit factor of 50,000 (averaged over all exercise activities), allowing an APF of 2,000 provides a conservative safety factor for estimating the actual protection provided to the user by the suit in the actual working environment. APFs are generally lower than fit factors for all types of respirators, since workplace demands are typically greater on the user of the respirator than are laboratory conditions and simulated work activities due to higher heat and humidity, longer work durations, greater worker fatigue, etc.
When compared with other air-fed respirators, Mururoa V4 MTH2 suit provides the following advantages to the user: (1) dual zippers (metal zipper inside and plastic zipper outside); (2) a welded sleeve-to-insert communication cable; (3) a removable strip near the mouth that could be used for emergency breathing in case of loss of supplied air; (4) an egress strip stretching from the left arm, over the head, and to the right arm that is used for undressing and for self-rescue in an emergency, such as loss of supplied air; (5) an air intake located at the waist with a built-in regulator that can adjust, but not block, air flow; (6) dual magnetic valves that provide ventilation and relief of excess pressure in case the suit is squeezed or pinched unexpectedly; (7) a very low noise level at maximum air flow; and (8) air flow to the hands, feet, face, and chest.
Safety features also include light-weight (2.5 pounds), one-piece construction with welded gloves and booties with tie straps. Helmets are made with Poly Vinyl Chloride (PVC) material that provides distortion-free vision and are large enough for wearing a headset. Noise levels are less than 80 decibels at maximum air flow, and air flow can be adjusted by the user for comfort, but cannot be throttled to below the required minimum. The Mururoa V4 MTH2 suit can be used in temperatures up to 55 oC (131 oF). The suit is constructed with reinforced elbow, knee, and crotch areas.
Upon loss of supplied air to the suit, a worker can easily extricate himself or herself from the suit by pulling off the mouth strip and then opening the hood, or by pulling the egress strip from the forearm to the head. Based on these safety features, the NRC staff finds that the suit design provides for easy and effective self-rescue, thus, avoiding asphyxiation if the air supply is interrupted or lost. When used as proposed, the design features of the suit, coupled with the required training on escape methods that is given to all suit users, are adequate for the staff to conclude that the standby rescue personnel addressed in Section 20.1703(f) are not required.
Subpart H of 10 CFR Part 20 establishes the requirements for implementing a respiratory protection program. These programmatic requirements ensure that worker doses from airborne radioactive materials are maintained ALARA. The licensee intends to integrate the use of the Mururoa suit into the licensees existing, ongoing respiratory protection programs that satisfy Part 20 requirements. The NRC staff finds this approach acceptable. The following summary of controls and program elements generally follow the specific Part 20 requirements pertinent to the use of air-supplied suits. Since the licensee has a viable, ongoing respiratory protection program and has successfully used air-supplied hoods in the past, only items pertinent and specific to the use of suits are discussed below.
1.
Section 20.1703(c) requires, among other things, written procedures governing the training of respirator users (workers). The licensee has committed to develop new lesson plans to train workers on the suits features; how to don, use and doff the suit; and instructions on using the built-in escape strips for routine and emergency egress conditions. This training should include appropriate hands-on and classroom instruction.
Specific training will be provided on actions to be taken by the user in the event of equipment malfunction. The radiation protection personnel will be trained to ensure that they are competent to issue the suits, assist in helping the user don and doff the suits, and set up and operate the unit.
2.
The licensee indicated that communication channels will be established and maintained between the licensee, the manufacturer and the United States nuclear industry to ensure that users are notified in a timely manner of significant problems that may affect suit safety, performance, or function. Depending on the severity of a problem or defect, the manufacturer may issue a product recall (e.g., a stop-use advisory or user warning issued to all registered users). This communication network is analogous to the NIOSH-vendor-user link established in the United States of America.
3.
Section 20.1703(c)(4)(vii) requires, among other things, written procedures governing respirator storage and quality assurance. Since the suits are approved for only single use, there are no maintenance requirements. The vendors manufacturing process is inspected annually by ASQUAL, a European quality assurance organization, to ensure that the required level of process and product quality is maintained. Additionally, on a formalized sample basis, the vendor performs destructive and non-destructive testing of the product line.
4.0 REGULATORY COMMITMENTS The licensee's December 9, 2004, application and December 17, 2004, supplemental letter contain the following regulatory commitments:
COMMITMENT TYPE (Check one)
SCHEDULED COMPLETION DATE (If Required)
ONE-TIME ACTION CONTINUING COMPLIANCE The Mururoa V4 MTH2 single suit will be integrated into the applicable Entergy respiratory programs using the information provided by the manufacturer.
X Before use of Mururoa suit 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.
X Before use of Mururoa suit Radiation Protection personnel will be provided additional training for selection, approval, issue, equipment set-up, operation and maintenance instructions for the Mururoa suit.
X Before use of Mururoa suit An explanation of when standby rescue personnel will be required will be clearly explained in Entergy procedures.
X Before use of Mururoa suit Entergy understands that this is a single use suit and will discard each suit after a single use.
X Before use of Mururoa suit Entergy will report any defects of these suits in a timely manner to the United States nuclear industry through our Operating Experience process and to the manufacturer prior to use of the suits.
X When defects are found Entergy will include all instructions for use and emergency features supplied by the manufacturer in our procedures/training.
X Before use of Mururoa suit The NRC staff finds that reasonable controls for the implementation and for subsequent evaluation of proposed changes pertaining to the above regulatory commitments are best provided by the licensees administrative processes, including its commitment management program. The above regulatory commitments do not warrant the creation of a regulatory requirement (item requiring prior NRC approval of subsequent changes). In addition, the staff finds that the licensee's commitment related to procedures that explain when standby rescue personnel are required, was not considered necessary for the purposes of the staff's review.
5.0 CONCLUSION
Based on the testing data provided, and use in accordance with the applicable manufacturers instructions, licensee commitments, and requirements of Subpart H of 10 CFR Part 20, the NRC staff concludes that the licensees request to use the Mururoa V4 MTH2 is acceptable.
The staff also concludes that the licensee can take credit for an APF of 2,000 and that standby rescue persons, as discussed in Section 20.1703(f), are not required when these suits are used.
Principal Contributor: R. Pedersen Date: February 1, 2005
Entergy Operations, Inc.
cc:
July 2004 Senior Vice President
& Chief Operating Officer Entergy Operations, Inc.
P. O. Box 31995 Jackson, MS 39286-1995 Director, Division of Radiation Control and Emergency Management Arkansas Department of Health 4815 West Markham Street, Slot 30 Little Rock, AR 72205-3867 Winston & Strawn 1400 L Street, N.W.
Washington, DC 20005-3502 Mr. Mike Schoppman Framatone ANP 3815 Old Forest Road Lynchburg, VA 24501 Senior Resident Inspector U.S. Nuclear Regulatory Commission P. O. Box 310 London, AR 72847 Regional Administrator, Region IV U.S. Nuclear Regulatory Commission 611 Ryan Plaza Drive, Suite 400 Arlington, TX 76011-8064 County Judge of Pope County Pope County Courthouse Russellville, AR 72801 Vice President, Operations Support Entergy Operations, Inc.
P. O. Box 31995 Jackson, MS 39286-1995 Wise, Carter, Child & Caraway P. O. Box 651 Jackson, MS 39205 Mr. Jeffrey S. Forbes Vice President Operations Arkansas Nuclear One Entergy Operations, Inc.
1448 S. R. 333 Russellville, AR 72801 Chief Energy and Transportation Branch Environmental Compliance and Enforcement Division Mississippi Department of Environmental Quality P. O. Box 10385 Jackson, MS 39289-0385 President Claiborne County Board of Supervisors P. O. Box 339 Port Gibson, MS 39150 Senior Resident Inspector U. S. Nuclear Regulatory Commission P. O. Box 399 Port Gibson, MS 39150 General Manager, GGNS Entergy Operations, Inc.
P. O. Box 756 Port Gibson, MS 39150 State Health Officer State Board of Health P. O. Box 1700 Jackson, MS 39205 Attorney General Department of Justice P. O. Box 94005 Baton Rouge, LA 70804-9005
Entergy Operations, Inc.
cc:
July 2004 Office of the Governor State of Mississippi Jackson, MS 39201 Attorney General Asst. Attorney General State of Mississippi P. O. Box 22947 Jackson, MS 39225 Director Nuclear Safety Assurance Entergy Operations, Inc.
P.O. Box 756 Port Gibson, MS 39150 Director Nuclear Safety and Licensing 1340 Echelon Parkway Jackson, MS 39213-8298 Mr. George A. Williams Site Vice President Grand Gulf Nuclear Station Entergy Operations, Inc.
P. O. Box 756 Port Gibson, MS 39150 Manager - Licensing Entergy Operations, Inc.
River Bend Station 5458 US Highway 61N St. Francisville, LA 70775 Senior Resident Inspector P. O. Box 1050 St. Francisville, LA 70775 President of West Feliciana Police Jury P. O. Box 1921 St. Francisville, LA 70775 Ms. H. Anne Plettinger 3456 Villa Rose Drive Baton Rouge, LA 70806 Mr. Michael E. Henry, State Liaison Officer Department of Environmental Quality Permits Division P. O. Box 4313 Baton Rouge, LA 708221-4313 General Manager - Plant Operations Entergy Operations, Inc.
River Bend Station 5485 US Highway 61N St. Francisville, LA 70775 Director - Nuclear Safety Entergy Operations, Inc.
River Bend Station 5458 US Highway 61N St. Francisville, LA 70775 Attorney General State of Louisiana P. O. Box 94095 Baton Rouge, LA 70804-9095 Mr. Brian Almon Public Utility Commission William B. Travis Building P. O. Box 13326 1701 North Congress Avenue Austin, TX 78701-3326 Mr. Paul D. Hinnenkamp Vice President - Operations Entergy Operations, Inc.
River Bend Station 5485 US Highway 61N St. Francisville, LA 70775
Entergy Operations, Inc.
cc:
July 2004 Director Nuclear Safety Assurance Entergy Operations, Inc.
17265 River Road Killona, LA 70066-0751 General Manager Plant Operations Waterford 3 SES Entergy Operations, Inc.
17265 River Road Killona, LA 70066-0751 Licensing Manager Entergy Operations, Inc.
17265 River Road Killona, LA 70066-0751 Resident Inspector/Waterford NPS P. O. Box 822 Killona, LA 70066-0751 Parish President Council St. Charles Parish P. O. Box 302 Hahnville, LA 70057 Chairman Louisiana Public Service Commission P. O. Box 91154 Baton Rouge, LA 70825-1697 Mr. Joseph E. Venable Vice President Operations Entergy Operations, Inc.
17265 River Road Killona, LA 70066-0751