ML052420161
| ML052420161 | |
| Person / Time | |
|---|---|
| Site: | Susquehanna  |
| Issue date: | 09/22/2005 |
| From: | Richard Guzman NRC/NRR/DLPM/LPD1 |
| To: | Mckinney B Susquehanna |
| Guzman R, NRR/DLPM 415-1030 | |
| References | |
| TAC MC5634, TAC MC5635 | |
| Download: ML052420161 (8) | |
Text
September 22, 2005 Mr. Britt T. McKinney Sr. Vice President and and Chief Nuclear Officer PPL Susquehanna, LLC 769 Salem Blvd., NUCSB3 Berwick, PA 18603-0467
SUBJECT:
SUSQUEHANNA STEAM ELECTRIC STATION, UNITS 1 AND 2 - ISSUANCE OF SAFETY EVALUATION ON AUTHORIZATION TO USE A PF OF 2,000 ON FRENCH MADE SUPPLIED AIR SUITS (TAC NOS. MC5634 AND MC5635)
Dear Mr. McKinney:
By letter dated December 14, 2004, as supplemented by letter dated April 12, 2005, PPL Susquehanna, LLC (PPL, the licensee), submitted a request to use a protection factor greater than that listed in Appendix A to 10 CFR Part 20, for persons working in areas of airborne radioactivity with certain non-NIOSH [National Institute for Occupational Safety and Health]-
certified respiratory protection equipment. Specifically, PPL requested authorization to use an assigned protection factor (APF) of 2,000 with the Mururoa V4 MTH2, a supplied air suit manufactured by Delta Protection.
Based on its review, the Nuclear Regulatory Commission staff has concluded that PPLs request to use and take credit for an APF of 2,000 with the Mururoa V4 MTH2 supplied air suit is acceptable.
The details of the NRC staffs review are contained in the enclosed safety evaluation. If you have any questions, please contact me at 301-415-1030.
Sincerely,
/RA/
Richard V. Guzman, Project Manager, Section 1 Project Directorate I Division of Licensing Project Management Office of Nuclear Reactor Regulation Docket Nos. 50-387 and 50-388
Enclosure:
Safety Evaluation cc w/encl: See next page
September 22, 2005 Mr. Britt T. McKinney Sr. Vice President and and Chief Nuclear Officer PPL Susquehanna, LLC 769 Salem Blvd., NUCSB3 Berwick, PA 18603-0467
SUBJECT:
SUSQUEHANNA STEAM ELECTRIC STATION, UNITS 1 AND 2 - ISSUANCE OF SAFETY EVALUATION ON AUTHORIZATION TO USE A PF OF 2,000 ON FRENCH MADE SUPPLIED AIR SUITS (TAC NOS. MC5634 AND MC5635)
Dear Mr. McKinney:
By letter dated December 14, 2004, as supplemented by letter dated April 12, 2005, PPL Susquehanna, LLC (PPL, the licensee), submitted a request to use a protection factor greater than that listed in Appendix A to 10 CFR Part 20, for persons working in areas of airborne radioactivity with certain non-NIOSH [National Institute for Occupational Safety and Health]-
certified respiratory protection equipment. Specifically, PPL requested authorization to use an assigned protection factor (APF) of 2,000 with the Mururoa V4 MTH2, a supplied air suit manufactured by Delta Protection.
Based on its review, the Nuclear Regulatory Commission staff has concluded that PPLs request to use and take credit for an APF of 2,000 with the Mururoa V4 MTH2 supplied air suit is acceptable.
The details of the NRC staffs review are contained in the enclosed safety evaluation. If you have any questions, please contact me at 301-415-1030.
Sincerely,
/RA/
Richard V. Guzman, Project Manager, Section 1 Project Directorate I Division of Licensing Project Management Office of Nuclear Reactor Regulation Docket Nos. 50-387 and 50-388
Enclosure:
Safety Evaluation cc w/encl: See next page DISTRIBUTION:
PUBLIC PDI-1 RF RLaufer RGuzman MOBrien OGC ACRS SKlementowicz RPedersen MShanbaky DLPM DPR
- Provided SE input by memo. No substantive changes made.
ACCESSION NO.: ML052420161 OFFICE PDI-1/PM PDI-2/LA DIPM/IPSB/SC
- PDI-1/SC NAME RGuzman MOBrien SKlementowicz RLaufer DATE 09/13/05 09/19/05 4/28/05 SE DTD 09/22/05 OFFICIAL RECORD COPY
Susquehanna Steam Electric Station, Units 1 and 2 cc:
Robert A. Saccone Steven M. Cook Vice President - Nuclear Operations Manager - Quality Assurance PPL Susquehanna, LLC PPL Susquehanna, LLC 769 Salem Blvd., NUCSB3 769 Salem Blvd., NUCSB2 Berwick, PA 18603-0467 Berwick, PA 18603-0467 Aloysius J. Wrape, III Luis A. Ramos General Manager - Performance Community Relations Manager, Improvement and Oversight Susquehanna PPL Susquehanna, LLC PPL Susquehanna, LLC Two North Ninth Street, GENPL4 634 Salem Blvd., SSO Allentown, PA 18101-1179 Berwick, PA 18603-0467 Terry L. Harpster Bryan A. Snapp, Esq General Manager - Plant Support Assoc. General Counsel PPL Susquehanna, LLC PPL Services Corporation 769 Salem Blvd., NUCSA4 Two North Ninth Street, GENTW3 Berwick, PA 18603-0467 Allentown, PA 18101-1179 Richard D. Pagodin Supervisor - Document Control Services General Manager - Nuclear Engineering PPL Susquehanna, LLC PPL Susquehanna, LLC Two North Ninth Street, GENPL4 769 Salem Blvd., NUCSB3 Allentown, PA 18101-1179 Berwick, PA 18603-0467 Richard W. Osborne Rocco R. Sgarro Allegheny Electric Cooperative, Inc.
Manager - Nuclear Regulatory Affairs 212 Locust Street PPL Susquehanna, LLC P.O. Box 1266 Two North Ninth Street, GENPL4 Harrisburg, PA 17108-1266 Allentown, PA 18101-1179 Director - Bureau of Radiation Protection Walter E. Morrissey Pennsylvania Department of Supervisor Environmental Protection Nuclear Regulatory Affairs P.O. Box 8469 PPL Susquehanna, LLC Harrisburg, PA 17105-8469 769 Salem Blvd., NUCSA4 Berwick, PA 18603-0467 Senior Resident Inspector U.S. Nuclear Regulatory Commission Michael H. Crowthers P.O. Box 35, NUCSA4 Supervising Engineer Berwick, PA 18603-0035 Nuclear Regulatory Affairs PPL Susquehanna, LLC Regional Administrator, Region 1 Two North Ninth Street, GENPL4 U.S. Nuclear Regulatory Commission Allentown, PA 18101-1179 475 Allendale Road King of Prussia, PA 19406
Susquehanna Steam Electric Station, Units 1 and 2 cc:
Board of Supervisors Salem Township P.O. Box 405 Berwick, PA 18603-0035 Dr. Judith Johnsrud National Energy Committee Sierra Club 443 Orlando Avenue State College, PA 16803
SAFETY EVALUATION BY THE OFFICE OF NUCLEAR REACTOR REGULATION USE OF FRENCH-DESIGNED RESPIRATORY PROTECTION EQUIPMENT PPL SUSQUEHANNA, LLC ALLEGHENY ELECTRIC COOPERATIVE, INC.
SUSQUEHANNA STEAM ELECTRIC STATION, UNITS 1 AND 2 DOCKET NOS. 50-387,AND 50-388
1.0 INTRODUCTION
By letter dated December 14, 2004 (Agencywide Documents Access and Management System (ADAMS) Accession No. ML043630029), as supplemented by letter dated April 12, 2005 (ADAMS Accession No. ML051120025), PPL Susquehanna, LLC (PPL, the licensee) submitted a request to use a protection factor greater than that listed in Appendix A to Title 10 of the Code of Federal Regulations (10 CFR), Part 20, for persons working in areas of airborne radioactivity with certain non-NIOSH [National Institute for Occupational Safety and Health]-certified respiratory protection equipment. Specifically, PPL requested authorization to use an assigned protection factor (APF) of 2,000 with the Mururoa V4 MTH2, a supplied air suit manufactured by Delta Protection.
2.0 REGULATORY EVALUATION
The Nuclear Regulatory Commission (NRC) finds that PPL, in its December 14, 2004, submittal, identified the applicable regulatory requirements. The regulatory requirements and guidance which the NRC staff considered in its review of the application are as follows:
- 1. Part 20 of 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.
- 2. 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.
- 3. 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 Enclosure
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., Section 20.1703).
- 4. 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, PPL must obtain NRC approval to take credit for an APF for the French-designed respiratory protection equipment.
- 5. 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 (ANSI) Standard 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, supplied air 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 PPLs request. PPL has requested authorization to use, and to take credit for, the protection provided by the Mururoa V4 MTH2 (Certificate No.
0073/197/162/01/96/0001) during normal (non-emergency) operations. This model has been approved as a single-use suit (a suit that is disposed of after one use), and PPL proposes to use the suit 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 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 supplied air 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. The Mururoa V4 MTH2 passed all required tests, and 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.
In general, when compared with other air-fed respirators, the Mururoa V4 MTH2 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 that 80 decibels at maximum air flow, and air flow can be adjusted by the user for comfort, but cannot be shut off below the required minimum air flow. The Mururoa V4 MTH model also provides two additional vents near the chin for cooling to the face. It is fire resistant up to 65 degrees celsius (oC) and can be used in temperatures up to 60 oC. Reinforced construction is also provided in the elbow, knee, and crotch areas.
PPL intends to use this suit in highly contaminated areas, including the steam generator platform work, reactor head work, and cavity decontamination. The Mururoa V4 MTH2 offers 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 forces 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 V4 MTH2 provides improved cooling over the entire body, and the ease of removal features provides 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. PPL intends to integrate the use of the Mururoa
suit into its existing, ongoing respiratory protection program that satisfies 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 supplied air suits. Since PPL has a viable, ongoing respiratory protection program, 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). PPL has committed to develop new lesson plans to train workers on the suits features; how to don, use and doff the suits; 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 PPL, 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). PPL has committed to report any defects experience with this suit to the manufacturer and other US users.
- 3. Section 20.1703(c)(4)(vii) requires, among other things, written procedures governing respirator storage and quality assurance. PPL has committed to implement all of the provisions in the manufactures Instructions For Use.
- 4. The Mururoa suits are single use only, and are not approved for use in atmospheres that are immediately deleterious to life and health.
4.0 CONCLUSION
Based on the testing data provided, and when used in accordance with the applicable manufacturers instructions, licensees commitments, and requirements of Subpart H of 10 CFR Part 20, the NRC staff concludes that PPLs request to use, and take credit for an APF of 2,000, with the Mururoa V4 MTH2 supplied air suit, is acceptable.
Principal Contributor: R. Pedersen Date: September 22, 2005