ML050980119
| ML050980119 | |
| Person / Time | |
|---|---|
| Site: | Saint Lucie, Seabrook, Turkey Point  |
| Issue date: | 04/08/2005 |
| From: | Ellen Brown NRC/NRR/DLPM/LPD2 |
| To: | Stall J Florida Power & Light Co |
| Brown E, NRR/DLPM, 415-2315 | |
| References | |
| TAC MC5816, TAC MC5817, TAC MC5818, TAC MC5819, TAC MC5820 | |
| Download: ML050980119 (9) | |
Text
April 8, 2005 Mr. J. A. Stall Senior Vice President, Nuclear and Chief Nuclear Officer Florida Power and Light Company P.O. Box 14000 Juno Beach, Florida 33408-0420
SUBJECT:
ST. LUCIE UNITS 1 AND 2, TURKEY POINT UNITS 3 AND 4, AND SEABROOK STATION UNIT 1 - USE OF HIGHER ASSIGNED PROTECTION FACTOR WITH THE USE OF FRENCH-DESIGNED AIR SUPPLIED RESPIRATOR EQUIPMENT (TAC NOS. MC5816, MC5817, MC5818, MC5819, MC5820)
Dear Mr. Stall:
By letter dated January 25, 2005, as supplemented by letter dated March 14, 2005, Florida Power & Light Company (FPL) and FPL Energy Seabrook requested U.S. Nuclear Regulatory Commission (NRC) authorization, pursuant to Title 10 Code of Federal Regulations (10 CFR),
Section 20.1705, to (1) use French-designed respiratory protection equipment that has not been tested and certified by the National Institute for Occupational Safety and Health, (2) to not provide standby rescue persons whenever this equipment is used, and (3) to take credit for an assigned protection factor of 5000 for this equipment.
The NRC staff concludes in the enclosed Safety Evaluation that the FPL/FPL Energy Seabrook request is acceptable, and within the provisions of 10 CFR Part 20.
If you or your staff have any questions concerning the resolution of this matter, please contact me at 301-415-2315.
Sincerely,
/RA/
Eva A. Brown, Project Manager, Section 2 Project Directorate II Division of Licensing Project Management Office of Nuclear Reactor Regulation Docket Nos. 50-250, 50-251, 50-335, 50-389, and 50-443
Enclosure:
As stated cc w/enclosures: See next page
Mr. J. A. Stall ST. LUCIE PLANT Florida Power & Light Company TURKEY POINT PLANT SEABROOK STATION, UNIT NO. 1 cc:
Senior Resident Inspector Mr. William A. Passetti, Chief St. Lucie Plant Department of Health U.S. Nuclear Regulatory Commission Bureau of Radiation Control P.O. Box 6090 2020 Capital Circle, SE, Bin # C21 Jensen Beach, Florida 34957 Tallahassee, Florida 32399-1741 Craig Fugate, Director Mr. William Jefferson, Jr.
Division of Emergency Preparedness Site Vice President Department of Community Affairs St. Lucie Nuclear Plant 2740 Centerview Drive 6351 South Ocean Drive Tallahassee, Florida 32399-2100 Jensen Beach, Florida 34957 M. S. Ross, Managing Attorney Attorney General Florida Power & Light Company Department of Legal Affairs P.O. Box 14000 The Capitol Juno Beach, FL 33408-0420 Tallahassee, Florida 32304 Marjan Mashhadi, Senior Attorney Senior Resident Inspector Florida Power & Light Company Turkey Point Nuclear Plant 801 Pennsylvania Avenue, NW., # 220 U.S. Nuclear Regulatory Commission Washington, DC 20004 9762 SW. 344th Street Florida City, Florida 33035 Terry O. Jones, Site Vice President Turkey Point Nuclear Plant Michael O. Pearce Florida Power and Light Company Plant General Manager 9760 SW. 344th Street Turkey Point Nuclear Plant Florida City, FL 33035 Florida Power and Light Company 9760 SW. 344th Street Douglas Anderson Florida City, FL 33035 County Administrator St. Lucie County County Manager 2300 Virginia Avenue Miami-Dade County Ft. Pierce, Florida 34982 111 Northwest 1 Street, 29th Floor Miami, Florida 33128 Mr. G. L. Johnston Plant General Manager Mr. Terry L. Patterson St. Lucie Nuclear Plant Licensing Manager 6351 South Ocean Drive St. Lucie Nuclear Plant Jensen Beach, Florida 34957 6351 South Ocean Drive Jensen Beach, Florida 34957 Walter Parker, Licensing Manager Turkey Point Nuclear Plant 9760 SW. 344th Street Florida City, FL 33035
David Moore, Vice President Ms. Deborah Bell Nuclear Operations Support Federal Emergency Management Agency Florida Power and Light Company Region I P.O. Box 14000 J. W. McCormack P.O. &
Juno Beach, FL 33408-0420 Courthouse Building, Room 401 Boston, MA 02109 Mr. Rajiv S. Kundalkar Vice President - Nuclear Engineering Mr. Tom Crimmins Florida Power & Light Company Polestar Applied Technology P.O. Box 14000 One First Street, Suite 4 Juno Beach, FL 33408-0420 Los Altos, CA 94019 Mr. J. Kammel Mr. Stephen McGrail, Director Radiological Emergency ATTN: James Muckerheide Planning Administrator Massachusetts Emergency Management Department of Public Safety Agency 6000 Southeast Tower Drive 400 Worcester Road Stuart, Florida 34997 Framingham, MA 01702-5399 Mr. Peter Brann Philip T. McLaughlin, Attorney General Assistant Attorney General Steven M. Houran, Deputy Attorney State House, Station #6 General Augusta, ME 04333 33 Capitol Street Concord, NH 03301 Resident Inspector U.S. Nuclear Regulatory Commission Mr. Bruce Cheney, Director Seabrook Nuclear Power Station New Hampshire Office of Emergency P.O. Box 1149 Management Seabrook, NH 03874 State Office Park South 107 Pleasant Street Town of Exeter Concord, NH 03301 10 Front Street Exeter, NH 03823 Mr. Gene F. St. Pierre Station Director Regional Administrator, Region I Seabrook Station U.S. Nuclear Regulatory Commission FPL Energy Seabrook, LLC 475 Allendale Road P.O. Box 300 King of Prussia, PA 19406 Seabrook, NH 03874 Office of the Attorney General James M. Peschel One Ashburton Place, 20th Floor Regulatory Programs Manager Boston, MA 02108 Seabrook Station FPL Energy Seabrook, LLC Board of Selectmen PO Box 300 Town of Amesbury Seabrook, NH 03874 Town Hall Amesbury, MA 01913
ML050980119 NRR-106 OFFICE PDII-2/PE PDII-2/PM PDII-2/PM PDII-2/LA IPSB-B/TL OGC PDII-2/SC NAME JArroyo BMoroney EBrown BClayton SKlementowicz JHull MMarshall DATE 03 / 29 /05 03 / 29 /05 03 / 29 /05 03 / 29 /05 by memo 03/24/05 04 / 07 /05 04 / 08 /05 SAFETY EVALUATION BY THE OFFICE OF NUCLEAR REACTOR REGULATION USE OF A PROTECTION FACTOR OF 5000 WITH FRENCH DESIGNED RESPIRATORY PROTECTION EQUIPMENT FLORIDA POWER & LIGHT COMPANY ST. LUCIE NUCLEAR PLANT, UNITS 1 AND 2 TURKEY POINT NUCLEAR PLANT, UNITS 3 AND 4 FPL ENERGY SEABROOK SEABROOK STATION DOCKET NOS. 50-335, 50-389, 50-250, 50-251, AND 50-443
1.0 INTRODUCTION
By letter dated January 25, 2005, as supplemented by letter dated March 14, 2005, Florida Power & Light Company (FPL) and FPL Energy Seabrook (the licensee) requested U.S.
Nuclear Regulatory Commission (NRC) authorization, pursuant to Title 10 Code of Federal Regulations (10 CFR), Section 20.1705, to (1) use French-designed respiratory protection equipment that has not been tested and certified by the National Institute for 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 5000 for this equipment.
FPL/FPL Energy Seabrook requested to use an APF greater than that listed in Appendix A to 10 CFR Part 20, for persons working in areas of airborne radioactivity with certain respiratory protection equipment that has not been certified by NIOSH. Specifically, FPL/FPL Energy Seabrook requested authorization to use an APF of 5000 with the MURUROA air supplied suits, models V4F4 and V4MTH2, manufactured by Delta Protection.
2.0 REGULATORY EVALUATION
Part 20 to 10 CFR, 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 NRC for authorized use of respiratory protection equipment that has not been tested and certified by NIOSH.
Appendix A to 10 CFR Part 20, 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 testing, are met (i.e., Section 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, FPL/FPL Energy Seabrook 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 reasonably achievable (ALARA).
Testing conducted by the Institute for Nuclear Protection and Security, the European 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 FPL/FPL Energy Seabrook request. FPL/FPL Energy Seabrook have requested authorization to take credit for the protection provided by two suits when used during normal (non-emergency) operations. The two suits are made by the same manufacturer and are identified as MURUROA V4 F1 and MURUROA V4 MTH2 (Certificate Nos. 0073/197/162/12/97/0028 and 0073/197/162/01/96/0001, respectively). Both models have been approved as single-use suits (a suit that is disposed of after one use), and FPL/FPL Energy Seabrook propose to use the suits in the approved configurations, relative to the suits form, fit, and function.
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 suits. 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: 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. Both models passed all required tests, and both 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 5000 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.
In general, when compared with other air-fed respirators, both MURUROA suit models provide 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 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 air flow. The MURUROA V4 MTH model also provides two additional vents near the chin for cooling to the face. Both models are heat resistant to 65 oC and can be used in temperatures up to 60 oC. Suits are constructed with reinforced elbow, knee, and crotch areas.
FPL/FPL Energy Seabrook intend to use the suits in highly contaminated areas, including the steam generator platform work, reactor head work, and cavity decontamination. Both MURUROA suit models 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 practice of using a combination of rain suits and NIOSH-certified air-supplied hoods provides cooling only to the head and force workers to wear the ensemble in a manner that makes self-rescue nearly impossible; thus, a rescue worker is required to be stationed nearby. The MURUROA suits provide improved cooling over the entire body, and the ease-of-removal features provide a means to undress that minimizes the potential for personnel contamination events and an easy-escape design.
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.
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. FPL/FPL Energy Seabrook intend to integrate the use of the MURUROA suits into their existing, ongoing respiratory protection programs that satisfy 10 CFR Part 20 requirements. The NRC staff finds this approach acceptable. The following summary of controls and program elements generally follow the specific 10 CFR Part 20 requirements pertinent to the use of air-supplied suits. Since FPL/FPL Energy Seabrook have a viable, ongoing respiratory protection program, only items 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). FPL/FPL Energy Seabrook have 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 (including the regulated air supply).
- 2. Communication channels will be established and maintained between FPL/FPL Energy Seabrook, the manufacturer and the European certification authority 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 certification agency or the manufacturer may issue a product recall (e.g., a stop-use advisory or user warning issued to all registered users). FPL/FPL Energy Seabrook have committed to report to the manufacturer and other U.S. users any defects experienced with these suits.
- 3. Section 20.1703(c)(4)(vii) requires, among other things, written procedures governing respirator storage and quality assurance. FPL/FPL Energy Seabrook have committed to implement the provisions in the manufacturers Instructions For Use, with the minor clarification that the suits will be inspected and removed from their protective packaging outside of the plants radiological controlled areas, in a way that maintains the integrity of the suit, but does not lead to the unnecessary generation of solid radioactive waste.
- 4. The MURUROA suits are single use only, and are not approved for use in atmospheres that are immediately deleterious to life and health (IDLH). FPL/FPL Energy Seabrook have committed to discarding each suit after one use.
4.0 CONCLUSION
Based on the testing data provided, and when used 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 FPL/FPL Energy Seabrook request to use the MURUROA V4F1 and V4 MTH2 supplied air suits satisfies the 10 CFR Part 20 ALARA requirements, and will provide the suit wearer with an adequate level of protection while working in potentially high airborne radioactivity areas. Therefore, the NRC staff finds that the request is acceptable. The NRC staff also concludes that FPL/FPL Energy Seabrook can take credit for an APF of 5000 for both of these suits, and that the standby rescue personnel, discussed in 10 CFR 20.1703(f), are not required when these suits are used.
Principal Contributor: Roger Pedersen Date: April 8, 2005