L-2005-058, Response to Request for Additional Information Related to Fpl/Fpl Energy Seabrook Request for Use of Higher Assigned Protection Factors Pursuant to 10 CFR 20.1705 with Use of French Designed Air Supplied Respirator Equipment

Response to Request for Additional Information Related to Fpl/Fpl Energy Seabrook Request for Use of Higher Assigned Protection Factors Pursuant to 10 CFR 20.1705 with Use of French Designed Air Supplied Respirator Equipment

ML050760313
Person / Time
Site:	Saint Lucie, Seabrook, Turkey Point
Issue date:	03/14/2005
From:	Stall J Florida Power & Light Co
To:	Document Control Desk, Office of Nuclear Reactor Regulation
References
L-2005-058
Download: ML050760313 (3)

Text

P.O.Box 14000,Juno Beach, FL 33408-0420 FPL MAR 1 4 2005 L-2005-058 U. S. Nuclear Regulatory Commission 10 CFR 20.1703(b)

Attn: Document Control Desk 10 CFR 20.1705 Washington, DC 20555 RE: Florida Power and Light Company St. Lucie Units 1 and 2 Docket Nos. 50-335 and 50-389 Turkey Point Units 3 and 4 Docket Nos. 50-250 and 50-251 FPL Energy Seabrook, LLC Seabrook Station Docket No. 50-443 Response to Request for Additional Information Related to FPUFPL Energy Seabrook Request for Use of Higher Assigned Protection Factors Pursuant to 10 CFR 20.1705 with Use of French Designed Air Supplied Respirator Equipment By letter dated January 25, 2005, Florida Power and Light Company (FPL), the licensee for the St. Lucie Nuclear Plant, Units 1 and 2, and the Turkey Point Nuclear Plant, Units 3 and 4, and FPL Energy Seabrook, LLC (FPL Energy Seabrook), the licensee for Seabrook Station, requested authorization (1) to use French-designed respiratory protection equipment that has not been tested and certified by the National Institute for Occupational Safety and Health (NIOSH), and (2) to take credit for an assigned protection factor (APF) of 5000 for this equipment.

On February 14, 2005, FPL received a draft Request for Additional Information (RAI) concerning the use of this equipment. On March 8, 2005, FPL personnel and Nuclear Regulatory Commission (NRC) staff held a telephone call to discuss the draft RAI. As a result of the call, FPL agreed to provide a formal response to the RAI. The FPUFPL Energy response is contained in Attachment 1.

Should you have any questions regarding this submittal, please contact Joe Danek at (561) 694-4213.

Sincerely yours J. A. Stall Senior Vice President, Nuclear and Chief Nuclear Officer A cIA Attachments (1) an FPL Group company

St. Lucie Units 1 and 2, Docket No. 50-335 and 50-389 Turkey Point Units 3 and 4, Docket No. 50-250 and 50-251 Seabrook Station, Docket No. 50-443 L-2005-058, Page 2 cc: Regional Administrator, Region I Regional Administrator, Region 11 USNRC Project Manager, Turkey Point Senior Resident Inspector, USNRC, Turkey Point USNRC Project Manager, St. Lucie Senior Resident Inspector, USNRC, St. Lucie USNRC Project Manager, Seabrook Station Senior Resident Inspector, USNRC, Seabrook Station

St. Lucie Units 1 and 2, Docket No. 50-335 and 50-389 Turkey Point Units 3 and 4, Docket No. 50-250 and 50-251 Seabrook Station, Docket No. 50-443 L-2005-058, Attachment 1, Page 1 ATTACHMENT 1 Response to Request for Additional Information Related to FPUFPL Energy Seabrook Request for Use of Higher Assigned Protection Factors Pursuant to 10 CFR 20.1705 with Use of French Designed Air Supplied Respirator Equipment Question 1:

Based on a review of the attachments provided in the licensee's submittal, the manufacturer states (and the European Certification Authority assumes) that both models of the suits are authorized for single-use only. Please confirm that the suit will be discarded after one use.

Response 1:

Florida Power and Light Company (FPL) and FPL Energy Seabrook will discard the suit(s) after one time use. Appropriate procedural controls will be in place to administer the Mururoa V4 F1 and V4 MTH2 as single use suits.

Question 2:

The licensee plans to develop implementing procedures (and training lesson plans) for using the suits. Please identify any of the manufacturer's "instructions for donning and removal",

"instructions for use" and "emergency features" technical information and directions provided, that will not be required by procedures, or that will deviate from the manufacturer's procedures.

For each instruction identified, explain the rationale for not including it in the program's procedures/training, or explain any deviation from the manufacturer's procedures (and any other compensating actions taken).

Response 2:

FPL/FPL Energy will include the "M.T.H.2 Instructions for Use", supplied by the manufacturer (see Attachment 8 to our January 25, 2005, L-2004-232 submittal), in our procedures/training.

These instructions include emergency features. The manufacturer's representative (Mr. Gary Zimmermann) was recently contacted and has indicated that the "Instructions for Donning and Removal of The Mururoa V4 Fully Enclosed Suit" (Attachment 5 to our January 25, 2005 submittal) are now outdated and are no longer supplied. The manufacturer's representative further indicated that the "M.T.H.2 Instructions for Use" (Attachment 8 to our January 25, 2005 submittal) are adequate for the Mururoa V4 MTH2 and V4 F1 suits.

One deviation from the manufacturer's "M.T.H.2 Instructions for Use" (Attachment 8 to our January 25, 2005 submittal) is also requested. Under the "Dressing" section of the instruction, the manufacturer describes performing a visual inspection before removing the shipping protection (cardboard on the visor and inside the garment, and removable "plastic protection" from the visor)". FPUFPL Energy proposes to perform a visual inspection of the garment and its components after the shipping protection material (cardboard and plastic protection) have been removed. This will allow removing the shipping protection material outside of a contaminated area and thus reduce potential radioactive waste. According to the manufacturer's representative, both the cardboard and the plastic are used to maintain the integrity of the visor and nothing more, particularly during transit and storage. This is done so that during the shipping process the visor does not become damaged, scratched or disfigured.

The cardboard adds rigidity, and the plastic offers protection to the visor. Both must be removed prior to use of the suit.