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MONTHYEARML0526504792005-09-29029 September 2005 Authorization to Use Higher Assigned Protection Factors with the Use of French-designed air-supplied Respirator Equipment Project stage: Other 2005-09-29
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Category:Letter
MONTHYEARCP-202400335, License Amendment Request to Adopt TSTF-51, TSTF-471, and TSTF-571-T to Eliminate Use of the Term Core Alterations and Revise Requirements During Handling of Irradiated Fuel2024-09-12012 September 2024 License Amendment Request to Adopt TSTF-51, TSTF-471, and TSTF-571-T to Eliminate Use of the Term Core Alterations and Revise Requirements During Handling of Irradiated Fuel ML24031A6322024-09-11011 September 2024 Exemption from the Requirements of 10 CFR 50.71(e)(4), Final Safety Analysis Report Update Schedule (EPID L-2023-LLE-0023) - Letter ML24243A0152024-09-0303 September 2024 – Notification of Comprehensive Engineering Team Inspection (05000445/2025012 and 05000446/2025012) and Request for Information ML24194A1332024-08-28028 August 2024 Issuance of Amendment Nos. 190 and 190, Respectively, Revision to Technical Specifications to Adopt TSTF-589, Eliminate Automatic Diesel Generator Start During Shutdown ML24228A2252024-08-22022 August 2024 Relief to Use Later Code Edition for Inservice Inspection Program ML24179A0772024-08-20020 August 2024 Issuance of Amendment Nos. 189 and 189, Respectively, Extension of Allowed Outage Time for an Inoperable Emergency Diesel Generator ML24232A2412024-08-19019 August 2024 Information Request, ISFSI Security IR 2024401 ML24232A2262024-08-19019 August 2024 Information Request, Security IR 2024404 IR 05000445/20240052024-08-15015 August 2024 Updated Inspection Plan for Comanche Peak Nuclear Power Plant, Units 1 and 2 (Report 05000445/2024005 and 05000446/2024005) CP-202400294, (CPNPP) - Response to RAI for Exemption Request from 10 CPR 50.71(e)(4) Final Safety Analysis Update Schedule2024-08-15015 August 2024 (CPNPP) - Response to RAI for Exemption Request from 10 CPR 50.71(e)(4) Final Safety Analysis Update Schedule CP-202400319, (CPNPP) - Revision to CPNPP Letter to the NRC, Multiple Relief Requests for Unit 2 Third Ten-Year Inservice Inspection Interval from 10CFR50.55(a) Inspection Requirements Due to Impracticality2024-08-13013 August 2024 (CPNPP) - Revision to CPNPP Letter to the NRC, Multiple Relief Requests for Unit 2 Third Ten-Year Inservice Inspection Interval from 10CFR50.55(a) Inspection Requirements Due to Impracticality ML24177A2692024-08-0707 August 2024 Issuance of Amendment Nos. 188 and 188, Respectively, Revision to Technical Specifications to Adopt TSTF-591, Revise Risk Informed Completion Time (RICT) Program CP-202400315, (Cpnpp), Multiple Relief Requests for Unit 2 Third Ten-Year Inservice Inspection Interval from 10CFR50.55(a) Inspection Requirements Due to Impracticality2024-08-0505 August 2024 (Cpnpp), Multiple Relief Requests for Unit 2 Third Ten-Year Inservice Inspection Interval from 10CFR50.55(a) Inspection Requirements Due to Impracticality IR 05000445/20240022024-07-31031 July 2024 Units 1 and 2 - Integrated Inspection Report 05000445/2024002 and 05000446/2024002,and Independent Spent Fuel Storage Installation Inspection Report 07200074/2024001 IR 05000445/20244032024-07-16016 July 2024 Security Baseline Inspection Report 05000445/2024403 and 05000446/2024403 (Full Report) ML24187A0372024-07-15015 July 2024 Withdrawal of Requested Licensing Action Exemption from Select Requirements of 10 CFR Part 55, Operators Licenses ML24192A1862024-07-10010 July 2024 Notification of Inspection (NRC Inspection Report 05000445/2024003 and 05000446/2024003) and Request for Information ML24185A1382024-07-0202 July 2024 Inservice Inspection Request for Information IR 05000445/20244012024-06-26026 June 2024 MC&A Program Inspection Report 05000445-2024401 and 05000446-2024401 Public-Final CP-202400253, (Cpnpp), Units 1 & 2 Inservice Testing Plan for Pumps & Valves Third Interval, Revision 52024-06-26026 June 2024 (Cpnpp), Units 1 & 2 Inservice Testing Plan for Pumps & Valves Third Interval, Revision 5 CP-202400235, (Cpnpp), Units 1 & 2, Inservice Testing Plan for Pumps & Valves Fourth Interval, Revision 02024-06-18018 June 2024 (Cpnpp), Units 1 & 2, Inservice Testing Plan for Pumps & Valves Fourth Interval, Revision 0 IR 05000445/20240122024-06-17017 June 2024 Design Basis Assurance Inspection (Programs) Inspection Report 05000445/2024012 and 05000446/2024012 ML24120A3632024-06-10010 June 2024 Issuance of Amendment Nos. 187 and 187, Respectively Adoption of 10 CFR 50.69, Risk-Informed Categorization and Treatment of Structures, Systems and Components for Nuclear Power Plants CP-202400120, (Cpnpp), Unit 1, Condition Prohibited by Technical Specifications Due to Inoperable Remote Shutdown System Functions2024-06-0303 June 2024 (Cpnpp), Unit 1, Condition Prohibited by Technical Specifications Due to Inoperable Remote Shutdown System Functions CP-202400205, (Cpnpp), Units 1and 2, Submittal of the Snubber Inservice Program Plan for the Fourth Ten Year Interval2024-05-30030 May 2024 (Cpnpp), Units 1and 2, Submittal of the Snubber Inservice Program Plan for the Fourth Ten Year Interval CP-202400175, (CPNPP) - Supplement to License Amendment Request to Extend the Allowed Outage Time for an Inoperable Emergency Diesel Generator2024-05-16016 May 2024 (CPNPP) - Supplement to License Amendment Request to Extend the Allowed Outage Time for an Inoperable Emergency Diesel Generator CP-202400100, (Cpnpp), Unit 2, Two Recurring Reactor Scrams Associated with Main Feedwater System Modifications2024-05-13013 May 2024 (Cpnpp), Unit 2, Two Recurring Reactor Scrams Associated with Main Feedwater System Modifications CP-202400097, Re Potential Loss of Safety Function Due to Inoperability of Both Trains of Uninterruptible Power Supply Heating, Ventilation & Air Conditioning2024-05-0606 May 2024 Re Potential Loss of Safety Function Due to Inoperability of Both Trains of Uninterruptible Power Supply Heating, Ventilation & Air Conditioning ML24107B1012024-04-29029 April 2024 Lr Feis Section 106 Consultation Letters, Tribes-Cernek, J, Coushatta Tribe of Louisiana ML24120A2942024-04-29029 April 2024 Lr Feis Section 106 Consultation Letters, Tribes-Gonzalez, B, Caddo Nation ML24120A3012024-04-29029 April 2024 Lr Feis Section 106 Consultation Letters, Tribes-Parton, T, Wichita and Affiliated Tribes ML24120A2912024-04-29029 April 2024 Lr Feis Section 106 Consultation Letters, Tribes-Cooper, D, Apache Tribe of Oklahoma ML24120A2902024-04-29029 April 2024 Lr Feis Section 106 Consultation Letters, Tribes-Bunch, J, United Keetoowah Band of Cherokee Indians ML24120A3022024-04-29029 April 2024 Lr Feis Section 106 Consultation Letters, Tribes-Pierite, M, Tunica-Biloxi Tribe of Louisiana ML24120A3042024-04-29029 April 2024 Lr Feis Section 106 Consultation Letters, Tribes-Sylestine, R, Alabama-Coushatta Tribe of Texas ML24120A2932024-04-29029 April 2024 Lr Feis Section 106 Consultation Letters, Tribes-Garza, Jr, Juan, Kickapoo Traditional Tribe of Texas ML24120A2922024-04-29029 April 2024 Lr Feis Section 106 Consultation Letters, Tribes-Dotson, Delaware Nation ML24120A2952024-04-29029 April 2024 Lr Feis Section 106 Consultation Letters, Tribes-Johnson, L.J., Seminole Nation of Oklahoma ML24120A3032024-04-29029 April 2024 Lr Feis Section 106 Consultation Letters, Tribes-SpottedBird, L, Kiowa Indian Tribe ML24120A3052024-04-29029 April 2024 Lr Feis Section 106 Consultation Letters, Tribes-Woommavovah, M, Comanche Nation ML24120A2982024-04-29029 April 2024 Lr Feis Section 106 Consultation Letters, Tribes-Martinez, E, Mescalero Apache Tribe ML24120A3002024-04-29029 April 2024 Lr Feis Section 106 Consultation Letters, Tribes-Morrow, R K, Thlopthlocco Tribal Town ML24120A2962024-04-29029 April 2024 Lr Feis Section 106 Consultation Letters, Tribes-Kaskaske, D, Kickapoo Tribe of Oklahoma ML24120A3062024-04-29029 April 2024 Lr Feis Section 106 Consultation Letters, Tribes-Yahola, s, Kialegee Tribal Town ML24120A3072024-04-29029 April 2024 Lr Feis Section 106 Consultation Letters, Tribes-Yargee, W, Alabama-Quassarte Tribal Town ML24120A2972024-04-29029 April 2024 Lr Feis Section 106 Consultation Letters, Tribes-Martin, R, Tonkawa Tribe of Oklahoma CP-202400153, (Cpnpp), Registration of Dry Spent Fuel Storage Canisters2024-04-29029 April 2024 (Cpnpp), Registration of Dry Spent Fuel Storage Canisters ML24107B0292024-04-26026 April 2024 Lr Feis Section 106 Consultation Letters SHPO ML24108A1542024-04-26026 April 2024 Lr Feis Section 106 Consultation Letters Achp ML24080A1802024-04-26026 April 2024 Ltr to Ken J. Peters, Sr VP and Chief Nuclear Officer, CPNPP re-NOA Final Plant Specific Supplement 60 2024-09-03
[Table view] Category:Safety Evaluation
MONTHYEARML24179A0772024-08-20020 August 2024 Issuance of Amendment Nos. 189 and 189, Respectively, Extension of Allowed Outage Time for an Inoperable Emergency Diesel Generator ML24177A2692024-08-0707 August 2024 Issuance of Amendment Nos. 188 and 188, Respectively, Revision to Technical Specifications to Adopt TSTF-591, Revise Risk Informed Completion Time (RICT) Program ML24120A3632024-06-10010 June 2024 Issuance of Amendment Nos. 187 and 187, Respectively Adoption of 10 CFR 50.69, Risk-Informed Categorization and Treatment of Structures, Systems and Components for Nuclear Power Plants ML24023A2962024-02-0909 February 2024 Issuance of Amendment Nos. 186 and 186 Regarding General Design Criterion 5 of Appendix a to 10 CFR Part 50 and Regulatory Guide 1.81 ML23319A3872023-12-20020 December 2023 Issuance of Amendment Nos. 185 and 185 Regarding Implementation of Full Spectrum Loss-of-Coolant Accident (Fsloca) Methodology ML23313A0732023-12-0606 December 2023 Issuance of Amendment Nos. 184 and 184 Regarding Revision to Technical Specifications to Implement WCAP-17661-P-A, Rev. 1, Improved Roac and CAOC Fq Surveillance Technical Specifications ML23237B4282023-09-28028 September 2023 Energy Harbor Nuclear Corp. - Vistra Operations Company LLC - Enclosure 2, Draft Conforming License Amendments ML23237B4302023-09-28028 September 2023 Energy Harbor Nuclear Corp. - Vistra Operations Company LLC - Enclosure 4, Safety Evaluation for Transfer of Licenses and Draft Conforming License Amendments (EPID L-2023-LLM-0000) (Public) ML23198A3212023-07-27027 July 2023 Authorization and Safety Evaluation for Proposed Alternative RV-1 ML22192A0072022-08-22022 August 2022 Issuance of Amendment Nos. 183 and 183 Regarding the Adoption of Technical Specifications Task Force Traveler TSTF-505, Revision 2 ML22194A0592022-07-14014 July 2022 Correction to Amendment Nos. 182 and 182 to Revise Technical Specifications to Adopt TSTF-577, Revision 1, Revised Frequencies for Steam Generator Tube Inspections ML22129A0722022-05-16016 May 2022 Review of Quality Assurance Program Changes ML22077A8412022-03-24024 March 2022 Proposed Alternative SNB-3 for the Snubber Inservice Program Third Interval Extension ML21321A3492022-02-24024 February 2022 Issuance of Amendment Nos. 182 and 182 to Revise Technical Specifications to Adopt TSTF-577, Rev. 1, Revised Frequencies for Steam Generator Tube Inspections ML21322A1032021-12-0707 December 2021 Proposed Alternative for the Continued Use of a Risk-Informed Process for the Selection of Class 1 and 2 Piping Welds for Inservice Inspection ML21132A0892021-06-0909 June 2021 Issuance of Amendment Nos. 181 and 181 Regarding the Adoption of Technical Specifications Task Force Traveler TSTF-567, Rev. 1, Add Containment Sump TS to Address GSI - 191 Issues ML21061A2172021-05-19019 May 2021 Issuance of Amendment Nos. 180 and 180 to Authorize Revision of Certain Emergency Action Levels of the Emergency Plan ML21103A0392021-04-23023 April 2021 Issuance of Amendment Nos. 179 and 179 the Adoption of Technical Specifications Task Force Traveler, TSTF-569, Revision 2, Revise Response Time Testing Definition (EPID L-2020-0147) ML21015A2122021-02-12012 February 2021 Issuance of Amendment Nos. 178 and 178 Regarding One-Time Revision to Technical Specifications 3.7.8 Station Service Water System (Ssws) and 3.8.1 AC Sources - Operating ML21022A1622021-02-0808 February 2021 Proposed Alternative to the Requirements of the ASME OM Code to Extend the Inservice Testing Program Interval for Certain Check and Relief Valves (EPID L-2020-LLR-0096 (COVID-19)) ML21021A1002021-02-0101 February 2021 Proposed Alternative to the Requirements of the ASME OM Code to Extend the Inservice Testing Program Interval for Certain Snubbers (EPID L-2020-LLR-0095 (Covid 19)) ML20346A0192021-02-0101 February 2021 Issuance of Amendment Nos. 177 and 177 Regarding Revision to Technical Specifications 3.8.1, AC Sources - Operating ML21013A1282021-01-28028 January 2021 Approval of Proposed Alternative to the Requirements of the ASME Code to Extend the Third Inservice Inspection Interval (EPID L-2020-LLR-0092 (COVID-19)) ML21021A0022021-01-28028 January 2021 Approval of Proposed Alternatives 1A4-1 and 1A4-2 from Certain Requirements of 10 CFR 50.55a for Inservice Inspection of Nuclear Power Plants ML20282A7092020-11-17017 November 2020 Proposed Alternative to the Requirements of the ASME Omcode to Extend the Inservice Testing Program Interval for Certain Snubbers (EPID L-2020-LLR-0060 (COVID-19)) ML20281A4722020-11-0404 November 2020 Use of Later Code Edition to the Requirements of the ASME OM Code ML20255A1002020-10-0707 October 2020 Proposed Alternative to the Requirements of the ASME OM Code to Extend the Inservice Test Program Interval for Certain Check and Relief Valves (EPID L-2020-LLR-0061 and EPID L-2020-LLR-0062 (COVID-19)) ML20223A3492020-08-31031 August 2020 Issuance of Amendment Nos. 175 and 175 Regarding One-Time Revision to Technical Specification 3.7.19, Safety Chilled Water ML20226A0132020-08-17017 August 2020 Use of Later Code Edition to the Requirements of the ASME Code ML20167A3182020-07-0606 July 2020 Issuance of Amendment Nos. 174 and 174 Regarding Revision to Technical Specifications to Adopt TSTF-563, Revision 0 ML20108E8782020-04-17017 April 2020 Issuance of Amendment Nos. 173 and 173 Revision to TS 5.5.9, Unit 1 Model D76 and Unit 2 Model D5 Steam Generator (SG) Program (Exigent Circumstances) ML20054A2762020-02-27027 February 2020 Approval of Change to the Quality Assurance Program as Described in the Comanche Peak Nuclear Power Plant Final Safety Analysis Report ML19267A0182019-11-0404 November 2019 Issuance of Amendment Nos. 172 and 172 to Revise Augmentation Times and Emergency Response Organization Staffing for the Emergency Plan ML18304A4872018-11-30030 November 2018 Issuance of Amendments 171 and 171 Regarding Revision to Technical Specifications for Engineered Safety Feature Actuation System Instrumentation ML18267A3842018-10-25025 October 2018 Issuance of Amendment Nos. 170 and 170 Revision to Technical Specification 3.8.4, DC Sources - Operating, Condition B (Exigent Circumstances) ML18221A6322018-08-15015 August 2018 Eicb Safety Evaluation - Comanche Peak Nuclear Power Plant, Units 1 and 2, License Amendment Request to Revise Technical Specification 3.3.2 Engineered Safety Feature Actuation System Instrumentation Docket/Epid 000976/05000446/L-2018-LLA-0 ML17129A0242017-06-29029 June 2017 Comanche Peak Nuclear Power Plant, Units 1 and 2 - Issuance of Amendment Nos. 169 and 169 Re: Administrative Change to Licensee Name (CAC Nos. MF8933 and MF8934) ML17074A4942017-04-13013 April 2017 Issuance of Amendment Nos. 168 and 168 Adoption of TSTF-545, Revision 3, TS Inservice Testing Program Removal & Clarify SR Usage Rule Application to Section 5.5 Testing ML17095A2512017-04-0707 April 2017 Request for Alternative 2B3-1 Re Examination of Reactor Vessel Closure Head Penetration Nozzles ML16334A1732016-12-14014 December 2016 Comanche Peak Nuclear Power Plant, Units 1 And 2; Safety Evaluation Regarding Implementation Of Mitigating Strategies And Reliable Spent Fuel Pool Instrumentation Related To Orders EA-12-049 And EA-12-051 ML16179A4052016-07-11011 July 2016 Relief Request Nos. B-9, B-3, B-10, and B-11 for Piping Welds, Second 10-year Inservice Inspection Interval ML16137A0562016-06-14014 June 2016 Issuance of Amendment Nos. 166 and 166, Request to Revise Emergency Action Levels Based on Nuclear Energy Institute (NEI) 99-01, Revision 6 ML16096A2642016-05-0606 May 2016 Draft Conforming Amendments, Application for Order Approving Direct and Indirect Transfer of Licenses and Conforming License Amendments ML16096A2662016-05-0606 May 2016 Redacted Letter, Order, Safety Evaluation, and Draft Conforming Amendments, Application for Order Approving Direct and Indirect Transfer of Licenses and Conforming License Amendments ML16074A0012016-03-14014 March 2016 Relief Request 1B3-3, Alternative for Reactor Pressure Vessel Cold Leg Weld Inspection Frequency from Not to Exceed 7 Years to 9 Years for the Third 10-Year Inservice Inspection Interval ML16063A0012016-03-11011 March 2016 Relief Request No. B-15, C-2, and C-4 for Welds in the RPV and Containment Spray and Residual Heat Removal Heat Exchanger Shells, Second 10-year Inservice Inspection Interval ML16011A0732016-01-19019 January 2016 Relief Request T-1; Alternative to the ASME OM Code Frequency Specifications for Inservice Testing for the Third 10-Year IST Interval ML15309A0732015-12-30030 December 2015 Issuance of Amendment Nos. 165 and 165, Revise Technical Specification 5.5.16, Containment Leakage Rate Testing Program, to Increase ILRT Test Interval from 10 to 15 Years and Type C Tests from 60 to 75 Mos ML15259A0042015-10-30030 October 2015 Relief Request 1B3-4, Alternative for Reactor Pressure Vessel Head Penetration Weld Inspection Frequency (from 10 to 15 Years), Third 10-Year Inservice Inspection Interval ML15257A2422015-09-18018 September 2015 Relief Request 2A3-1, from ASME Code Section XI Requirements, Risk-Informed Process for Selection of Class 1 and Class 2 Piping Weld Examinations, Third 10-Year Inservice Inspection Interval 2024-08-07
[Table view] |
Text
September 29, 2005 Mr. M. R. Blevins Senior Vice President &
Chief Nuclear Officer TXU Power Attn: Regulatory Affairs Department P. O. Box 1002 Glen Rose, TX 76043
SUBJECT:
COMANCHE PEAK STEAM ELECTRIC STATION, UNITS 1 AND 2-AUTHORIZATION TO USE HIGHER ASSIGNED PROTECTION FACTORS WITH THE USE OF FRENCH-DESIGNED AIR-SUPPLIED RESPIRATOR EQUIPMENT (TAC NOS. MC8303 AND MC8304)
Dear Mr. Blevins:
By letter dated August 26, 2005, TXU Generating Company LP (the licensee) submitted, pursuant to the provisions of Title 10 of the Code of Federal Regulations (10 CFR) 20.1705, Application for use of higher assigned protection factors, a request for authorization for Comanche Peak Steam Electric Station, Units 1 and 2 to use French-designed air-supplied respiratory equipment with an assigned protection factor (APF). Specifically, the licensee requested authorization to use an APF of 5000 with the Mururoa air-supplied suits, models V4 F1 and V4 MTH2, manufactured by Delta Protection.
The Nuclear Regulatory Commission (NRC) staff has reviewed the licensees request, as documented in the enclosed safety evaluation. The NRC staff concludes that, 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 licensees request to use and take credit for an APF of 5000 with both the Mururoa V4 F1 and Mururoa V4 MTH2 air-supplied suits, is authorized pursuant to 10 CFR Part 20.
Sincerely,
/RA/
Mohan C. Thadani, Senior Project Manager, Section 1 Project Directorate IV Division of Licensing Project Management Office of Nuclear Reactor Regulation Docket Nos. 50-445 and 50-446
Enclosure:
Safety Evaluation cc: See next page
ML052650479 *No significant changes to SE input NRR-106 OFFICE PDIV-1/PM PDIV-1/LA IPSB/TL PDIV-1/SC NAME MThadani DJohnson for DBaxley SKlementowicz DTerao DATE 9/29/05 9/29/05 9/16/05 9/29/05 SAFETY EVALUATION BY THE OFFICE OF NUCLEAR REACTOR REGULATION USE OF FRENCH-DESIGNED AIR-SUPPLIED RESPIRATOR EQUIPMENT COMANCHE PEAK STEAM ELECTRIC STATION, UNITS 1 AND 2 TXU GENERATING COMPANY LP DOCKET NOS. 50-445 AND 50-446
1.0 INTRODUCTION
By letter dated August 26, 2005, TXU Generating Company LP (the licensee) submitted, pursuant to the provisions of Title 10 of the Code of Federal Regulations (10 CFR) 20.1705, Application for use of higher assigned protection factors, a request for authorization for Comanche Peak Steam Electric Station, Units 1 and 2 to use French-designed air-supplied respiratory equipment with an assigned protection factor (APF). Specifically, the licensee requested authorization to use an APF of 5000 with the Mururoa air-supplied suits, models V4 F1 and V4 MTH2, manufactured by Delta Protection.
2.0 REGULATORY EVALUATION
Subpart H, Respiratory Protection and Controls to Restrict Internal Exposure in Restricted Areas, of 10 CFR Part 20, Standards for Protection Against Radiation, 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 the National Institute for Occupational Safety and Health (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, Assigned Protection Factors for Respirators, of 10 CFR Part 20 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 states that a licensee shall obtain NRC authorization before using APFs 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.
Enclosure
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, 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 licensees request. The licensee has requested authorization to use the two suits during normal (non-emergency) operations. The two suits are made by the same manufacturer and are identified as Mururoa V4 F1 (Certificate No.
0073/197/162/12/97/0028) and Mururoa V4 MTH2 (Certificate No. 0073/197/162/01/96/0001).
Both models have been approved as single-use suits (a suit that is disposed of after one use),
and the licensee proposes to use the suits in the approved configurations, relative to the suits form, fit, and function.
The European Standard EN 1073-1 (January 1998), 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 5,000 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, 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 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 MTH2 model also provides two additional vents near the chin for cooling to the face. Both models are fire proof up to 65 oC and can be used in temperatures up to 60 oC. Suits are constructed with reinforced elbow, knee, and crotch areas.
The licensee intends to use the suits in highly contaminated areas, including the steam generator platform work, reactor head work, cavity decontamination, and equipment 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 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 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. The licensee intends to integrate use of the Mururoa suits into its 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, 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 (including the regulated air supply).
- 2. Communication channels will be established and maintained between the licensee, 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). The licensee has committed to report to the manufacturer, any defects experienced with these suits. The licensee will also share operating experience with NRC and other utilities.
- 3. Section 20.1703(c)(4)(vii) requires, among other things, written procedures governing respirator storage and quality assurance. The licensee has committed to implement the provisions in the manufacturer's Instructions For Use with the minor clarification that the suits will be inspected and removed from its 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).
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 licensees request to use, and take credit for an APF of 5,000, with both the Mururoa V4 F1 and Mururoa V4 MTH2 supplied air suits, is acceptable.
Principal Contributor: K. Alm-Lytz Date: September 29, 2005
Comanche Peak Steam Electric Station cc:
Senior Resident Inspector Mr. Brian Almon U.S. Nuclear Regulatory Commission Public Utility Commission P. O. Box 2159 William B. Travis Building Glen Rose, TX 76403-2159 P. O. Box 13326 1701 North Congress Avenue Regional Administrator, Region IV Austin, TX 78701-3326 U.S. Nuclear Regulatory Commission 611 Ryan Plaza Drive, Suite 400 Ms. Susan M. Jablonski Arlington, TX 76011 Office of Permitting, Remediation and Registration Mr. Fred W. Madden, Director Texas Commission on Environmental Regulatory Affairs Quality TXU Generation Company LP MC-122 P. O. Box 1002 P. O. Box 13087 Glen Rose, TX 76043 Austin, TX 78711-3087 George L. Edgar, Esq. Terry Parks, Chief Inspector Morgan Lewis Texas Department of Licensing 1111 Pennsylvania Avenue, NW and Regulation Washington, DC 20004 Boiler Program P. O. Box 12157 County Judge Austin, TX 78711 P. O. Box 851 Glen Rose, TX 76043 Environmental and Natural Resources Policy Director Office of the Governor P. O. Box 12428 Austin, TX 78711-3189 Mr. Richard A. Ratliff, Chief Bureau of Radiation Control Texas Department of Health 1100 West 49th Street Austin, TX 78756-3189