ML053420014
| ML053420014 | |
| Person / Time | |
|---|---|
| Site: | Monticello, Palisades, Point Beach, Prairie Island, Duane Arnold  |
| Issue date: | 12/28/2005 |
| From: | Padovan L Plant Licensing Branch III-2 |
| To: | Weinkam E Nuclear Management Co |
| Padovan L, NRR/DLPM, 415-1423 | |
| References | |
| TAC MC8744, TAC MC8745, TAC MC8746, TAC MC8747, TAC MC8748, TAC MC8749, TAC MC8750 | |
| Download: ML053420014 (13) | |
Text
December 28, 2005 Mr. Edward J. Weinkam, Director Nuclear Licensing & Regulatory Services Nuclear Management Company, LLC.
700 First Street Hudson, WI 54016
SUBJECT:
DUANE ARNOLD ENERGY CENTER, MONTICELLO NUCLEAR GENERATING PLANT, PALISADES NUCLEAR PLANT, POINT BEACH NUCLEAR PLANT, UNITS 1 AND 2, PRAIRIE ISLAND NUCLEAR GENERATING PLANT, UNITS 1 AND 2 USE OF DELTA PROTECTION RESPIRATORY PROTECTION EQUIPMENT (TAC NOS. MC8744, MC8745, MC8746, MC8747, MC8748, MC8749, AND MC8750)
Dear Mr. Weinkam:
Your letter of October 20, 2005, requested our approval to use Delta Protection Mururoa Single-Use Supplied-Air Suits, Models V4 F1 and V4 MTH2, at Nuclear Management Company, LLCs (NMCs) nuclear facilities identified above. You also requested our authorization to use an Assigned Protection Factor (APF) of 2,000 when using the suits.
Based on our review, the Nuclear Regulatory Commission staff authorizes NMC to use the Mururoa V4 F1 and V4 MTH2 supplied-air suits at its nuclear plants specified above, and take credit for an APF of 2,000. The details of our review are contained in the enclosed safety evaluation. If you have any questions, please contact me at 301-415-1423.
Sincerely,
/RA/
L. Mark Padovan, Project Manager Plant Licensing Branch III-1 Division of Operating Reactor Licensing Office of Nuclear Reactor Regulation Docket Nos. 50-331, 50-263, 50-255, 50-266, 50-301, 50-282 and 50-306
Enclosure:
Safety Evaluation cc w/encl: See next pages
ML053420014 OFFICE NRR/LPL3-1/PM NRR/LPL3-1/LA NRR/IHPB/BC NRR/LPL3-1/BC NAME LPadovan THarris SKlementowicz LRaghavan DATE 12/28/05 12/28/05 12/27/05 12/28/05
Duane Arnold Energy Center cc:
Michael B. Sellman President and Chief Executive Officer Nuclear Management Company, LLC 700 First Street Hudson, WI 54016 John Bjorseth Plant Manager Duane Arnold Energy Center 3277 DAEC Road Palo, IA 52324 Steven R. Catron Manager, Regulatory Affairs Duane Arnold Energy Center 3277 DAEC Road Palo, IA 52324 U. S. Nuclear Regulatory Commission Resident Inspectors Office Rural Route #1 Palo, IA 52324 Regional Administrator, Region III U.S. Nuclear Regulatory Commission Suite 210 2443 Warrenville Road Lisle, IL 60532-4351 Jonathan Rogoff Vice President, Counsel & Secretary Nuclear Management Company, LLC 700 First Street Hudson, WI 54016 Bruce Lacy Nuclear Asset Manager Alliant Energy/Interstate Power and Light Company 3277 DAEC Road Palo, IA 52324 Daniel McGhee Utilities Division Iowa Department of Commerce Lucas Office Buildings, 5th floor Des Moines, IA 50319 Chairman, Linn County Board of Supervisors 930 1st Street SW Cedar Rapids, IA 52404 Craig G. Anderson Senior Vice President, Group Operations 700 First Street Hudson, WI 54016 Gary Van Middlesworth Site Vice President Duane Arnold Energy Center Nuclear Management Company, LLC 3277 DAEC Road Palo, IA 52324-0351
November 2005
Monticello Nuclear Generating Plant cc:
U.S. Nuclear Regulatory Commission Resident Inspector's Office 2807 W. County Road 75 Monticello, MN 55362 Manager, Regulatory Affairs Monticello Nuclear Generating Plant Nuclear Management Company, LLC 2807 West County Road 75 Monticello, MN 55362-9637 Robert Nelson, President Minnesota Environmental Control Citizens Association (MECCA) 1051 South McKnight Road St. Paul, MN 55119 Commissioner Minnesota Pollution Control Agency 520 Lafayette Road St. Paul, MN 55155-4194 Commissioner Minnesota Department of Health 717 Delaware Street, S. E.
Minneapolis, MN 55440 Douglas M. Gruber, Auditor/Treasurer Wright County Government Center 10 NW Second Street Buffalo, MN 55313 Commissioner Minnesota Department of Commerce 85 7th Place East, Suite 500 St. Paul, MN 55101-2198 Manager - Environmental Protection Division Minnesota Attorney Generals Office 445 Minnesota St., Suite 900 St. Paul, MN 55101-2127 Nuclear Asset Manager Xcel Energy, Inc.
414 Nicollet Mall, R.S. 8 Minneapolis, MN 55401 Mr. John T. Conway Site Vice President Monticello Nuclear Generating Plant Nuclear Management Company, LLC 2807 West County Road 75 Monticello, MN 55362-9637
November 2005
Palisades Plant cc:
Robert A. Fenech, Senior Vice President Nuclear, Fossil, and Hydro Operations Consumers Energy Company 1945 Parnall Rd.
Jackson, MI 49201 Arunas T. Udrys, Esquire Consumers Energy Company 1 Energy Plaza Jackson, MI 49201 Supervisor Covert Township P. O. Box 35 Covert, MI 49043 Office of the Governor P. O. Box 30013 Lansing, MI 48909 U.S. Nuclear Regulatory Commission Resident Inspector's Office Palisades Plant 27782 Blue Star Memorial Highway Covert, MI 49043 Michigan Department of Environmental Quality Waste and Hazardous Materials Division Hazardous Waste and Radiological Protection Section Nuclear Facilities Unit Constitution Hall, Lower-Level North 525 West Allegan Street P.O. Box 30241 Lansing, MI 48909-7741 Michigan Department of Attorney General Special Litigation Division 525 West Ottawa St.
Sixth Floor, G. Mennen Williams Building Lansing, MI 48913 Douglas E. Cooper Senior Vice President - Group Operations Palisades Nuclear Plant Nuclear Management Company, LLC 27780 Blue Star Memorial Highway Covert, MI 49043 Stephen T. Wawro, Director of Nuclear Assets Consumers Energy Company Palisades Nuclear Plant 27780 Blue Star Memorial Highway Covert, MI 49043 Laurie A. Lahti, Manager Regulatory Affairs Nuclear Management Company, LLC Palisades Nuclear Plant 27780 Blue Star Memorial Highway Covert, MI 49043 Paul A. Harden Site Vice President Palisades Nuclear Plant Nuclear Management Company, LLC 27780 Blue Star Memorial Highway Covert, MI 49043 November 2005
Point Beach Nuclear Plant, Units 1 and 2 cc:
Mr. F. D. Kuester President & Chief Executive Officer WE Generation 231 West Michigan Street Milwaukee, WI 53201 Regulatory Affairs Manager Point Beach Nuclear Plant Nuclear Management Company, LLC 6610 Nuclear Road Two Rivers, WI 54241 Mr. Ken Duveneck Town Chairman Town of Two Creeks 13017 State Highway 42 Mishicot, WI 54228 Chairman Public Service Commission of Wisconsin P.O. Box 7854 Madison, WI 53707-7854 Resident Inspector's Office U.S. Nuclear Regulatory Commission 6612 Nuclear Road Two Rivers, WI 54241 Mr. Jeffery Kitsembel Electric Division Public Service Commission of Wisconsin P.O. Box 7854 Madison, WI 53707-7854 Nuclear Asset Manager Wisconsin Electric Power Company 231 West Michigan Street Milwaukee, WI 53201 Site Director of Operations Nuclear Management Company, LLC 6610 Nuclear Road Two Rivers, WI 54241 Dennis L. Koehl Site Vice-President Point Beach Nuclear Plant Nuclear Management Company, LLC 6610 Nuclear Road Two Rivers, WI 54241 November 2005
Prairie Island Nuclear Generating Plant, Units 1 and 2 cc:
Manager, Regulatory Affairs Prairie Island Nuclear Generating Plant Nuclear Management Company, LLC 1717 Wakonade Drive East Welch, MN 55089 Manager - Environmental Protection Division Minnesota Attorney Generals Office 445 Minnesota St., Suite 900 St. Paul, MN 55101-2127 U.S. Nuclear Regulatory Commission Resident Inspector's Office 1719 Wakonade Drive East Welch, MN 55089-9642 Administrator Goodhue County Courthouse Box 408 Red Wing, MN 55066-0408 Tribal Council Prairie Island Indian Community ATTN: Environmental Department 5636 Sturgeon Lake Road Welch, MN 55089 Nuclear Asset Manager Xcel Energy, Inc.
414 Nicollet Mall, R.S. 8 Minneapolis, MN 55401 Mr. Thomas J. Palmisano Site Vice President Prairie Island Nuclear Generating Plant Nuclear Management Company, LLC 1717 Wakonade Drive East Welch, MN 55089 November 2005
ENCLOSURE SAFETY EVALUATION BY THE OFFICE OF NUCLEAR REACTOR REGULATION USE OF DELTA PROTECTION RESPIRATORY PROTECTION EQUIPMENT NUCLEAR MANAGEMENT COMPANY, LLC DUANE ARNOLD ENERGY CENTER MONTICELLO NUCLEAR GENERATING PLANT PALISADES NUCLEAR PLANT POINT BEACH NUCLEAR PLANT, UNITS 1 AND 2 PRAIRIE ISLAND NUCLEAR GENERATING PLANT, UNITS 1 AND 2 DOCKET NOS. 50-331, 50-263, 50-255, 50-266, 50-301, 50-282 and 50-306
1.0 INTRODUCTION
Nuclear Management Company, LLCs (NMCs) letter of October 20, 2005, requested Nuclear Regulatory Commission (NRC) approval to use Mururoa Single-Use Supplied Air Suits, Models V4 F1 and V4 MTH2, manufactured by Delta Protection, France, at the following nuclear facilities:
Duane Arnold Energy Center Monticello Nuclear Generating Plant Palisades Nuclear Plant Point Beach Nuclear Plant, Units 1 and 2 Prairie Island Nuclear Generating Plant, Units 1 and 2 NMC also requested NRC authorization to use an assigned protection factors (APF) of 2,000 when using the suits. These suits are not certified by the National Institute for Occupational Safety and Health (NIOSH) in the United States, and Title 10 of the Code of Federal Regulations (CFR), Part 20, Standards for Protection Against Radiation, Appendix A does not specify an APF for these suits.
NMCs letter contained the following commitments:
- 1. The Mururoa V4 F1 and V4 MTH2 suits will be integrated into NMCs respiratory protection program using the information provided by the manufacturer and (a) the program will assure that the suits are discarded after one use and (b) the program will assure that the suits will not be used in environments that are immediately deleterious to life and health.
- 2. Lesson plans will be revised 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.
- 3. Provisions of the manufacturers Instructions for Use will be incorporated into procedures in the respiratory protection programs.
- 4. Radiation Protection personnel will be provided additional training for selection, approval, issue, equipment set-up, operation and maintenance instructions for the Mururoa suits.
- 5. NMC will use its Corrective Action Program (CAP) to document any problems and track corrective actions taken. Problems associated with the suits will be communicated to the manufacturer to ensure that operating experience is shared with other users.
Additionally, due to the advanced safety features for emergency breathing and emergency escape built into these suit models, NMC indicated that it may choose to use the Mururoa suits without dedicated rescue personnel being assigned.
2.0 REGULATORY EVALUATION
Paragraph 20.1703(b) of 10 CFR Part 20 requires prior authorization from the NRC to use equipment that has not been tested or certified by NIOSH. Section 20.1705, Application for use of higher assigned protection factors, requires prior NRC authorization to use assigned protection factors in excess of those specified in 10 CFR Part 20, Appendix A, Assigned Protection Factors [APFs] for Respirators. Appendix A, 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 contains 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).
Additional NRC regulatory requirements and guidance that the NRC staff considered in its review are as follows:
NUREG/CR-0041, Revision 1, "Manual of Respiratory Protection Against Airborne Radioactive Materials.
Subpart H, Respiratory Protection and Controls to Restrict Internal Exposure in Restricted Areas, of 10 CFR 20 applies to the use of respiratory protection equipment for protection against airborne radioactive materials.
Title 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.
3.0 TECHNICAL EVALUATION
NMC requested the NRC to authorize the use of the subject suits as respiratory protection equipment for operations activities at NMCs nuclear plants specified above, and to assign an APF of 2000 for the suits. NMC said it currently uses bubblehoods for jobs that have high potential for skin contamination from discrete radioactive particles, and to prevent intake of airborne contaminants. Workers have to wear protective clothing, two pairs of gloves, rubber shoes, cotton booties and tape for sealing because the bubblehood covers only the face and torso. Chances of cross contamination exist during undressing and exit from contaminated areas. NMC indicated the Mururoa suits offer an alternative (with their unitized construction and ease of removal) that better protects the worker against face and skin contamination and airborne radioactivity. In particular, NMC said these suits would provide enhanced protection for the under-vessel control rod work at boiling-water reactors.
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).
Suit construction and safety features form the basis for NMCs request. NMC said Mururoa suit models V4 F1 and V4 MTH2 meet International Organization for Standardization 8194, Radiation protection - Clothing for protection against radioactive contamination - Design, selection, testing and use, and European Standard CEN/TC 162 N 738, Protective clothing against radioactive contamination, final draft of July 1996. NMC indicated that the Mururoa suits have been widely used in Western European nuclear power plants, and that the manufacturer indicated about 60,000 Mururoa garments/suits are used by these plants each year. The Institute for Nuclear Protection and Security, the European certifying agency (comparable to NIOSH), certified the suits for use in 1996. It issued Certificate No.
0073/197/162/12/97/0028 for the Mururoa V4 F1 suit, and Certificate No.
0073/197/162/01/96/0001 for the Mururoa V4 MTH2 suit.
European Standard CEN/TC 162 N 738, 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 the following:
suit material strength tear and puncture resistance material flammability wearer comfort noise level wearer visibility air flow carbon dioxide concentrations degree of contaminate in-leakage during a series of varied simulated work practices and exercises The Mururoa suits 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 overall exercise activities),
allowing an APF of 2,000 provides a conservative safety factor for estimating the actual protection provided to the user by a suit in the actual working environment. APFs are generally lower than fit factors for all types of respirators. This is due to workplace demands (e.g., higher heat and humidity, longer work durations, greater worker fatigue, etc.) being typically greater on the user of the respirator than are laboratory conditions with simulated work activities.
Desirable features of the Mururoa V4 F1 and V4 MTH2 suits include the following:
One piece single use suit that includes welded gloves and booties with tie straps.
Made of polyvinyl chloride (PVC) or Ethyfuge with reinforced elbows, knees and crotch areas.
Dual zippers - metal zipper inside and plastic zipper outside.
Helmet made of clear PVC material that provides distortion-free vision and large enough for wearing a headset.
Welded sleeve to insert communication cable.
Removable strip near the mouth that could be used for emergency breathing in case of loss of supplied air.
An egress strip stretching from left arm, over the head, to right arm that is used for undressing and for self-rescue in an emergency, such as loss of supplied air.
Air intake located at the waist with a built-in regulator that can adjust, but not block, air flow.
Two exhaust valves that provide ventilation, and also protect from overpressure.
Very low noise level at maximum air flow.
Air flow to hands, feet, face and chest.
Safety features include both Mururoa suit models being light-weight, made of fire-retardant material and useable in temperatures up to 140 degrees F. Built-in gloves, booties with binding ties, reinforced elbows, knees and crotch protect against accidental tear, puncture and cracking. A transparent helmet with 6" X 8" clear face plate provides distortion-free view.
Airflow can be adjusted by the user for comfort, but cannot be shut off. In case of loss of air, the user can remove the mouth strip and move the opening close to the face, or enlarge the opening, to breathe outside air. Alternately, the user can pull the escape strip from either forearm, over the head and towards the other forearm, and rip the suit in two halves. This escape strip is also used for normal egress from the suit when the work activity has been completed.
NMC determined that the Mururoa V4 F1 and V4 MTH2 air-supplied suits offer a safe and efficient means to protect workers in areas of high radiological contamination, and in areas where there is a potential for airborne contamination. Easy removal of the Mururoa suit provides for more desirable self-rescue features, and gives a means to remove the suit that minimizes the potential for personnel contamination events. 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. NMC committed in its letter of October 20, 2005, to integrate the Mururoa V4 F1 and V4 MTH2 suits into NMCs respiratory protection program using the information provided by the manufacturer. The NRC staff finds this approach acceptable.
The summary of controls and program elements below generally follows the specific Part 20 requirements pertinent to the use of supplied air suits. Since NMC has a viable, ongoing respiratory protection program, only items pertinent and specific to the use of suits are discussed, as follows:
Section 20.1703(c) requires, among other things, written procedures governing the training of respirator users (workers). NMC committed to revise lesson plans 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. Radiation Protection personnel will be provided additional training for selection, approval, issue, equipment set-up, operation and maintenance instructions for the Mururoa suits. Training should include appropriate hands-on and classroom instruction.
NMC committed to use its CAP to document any problems and track corrective actions taken. NMC will also communicate problems associated with the suits to the manufacturer to ensure that operating experience is shared with other users.
Section 20.1703(c)(4)(vii) requires, among other things, written procedures governing respirator storage and quality assurance. NMC has committed to incorporate provisions of the manufacturers Instructions for Use into procedures in its respiratory protection programs.
The Mururoa suits are single use only, and are not approved for use in atmospheres that are immediately deleterious to life and health. NMC committed that its program will assure that the suits are discarded after one use, and that the suits will not be used in environments that are immediately deleterious to life and health.
Additionally, the requirement in 10 CFR 20.1703(f), Use of individual respiratory protection equipment, to provide standby rescue persons whenever one-piece atmosphere-supplying suits are used from which an unaided individual would have difficulty extricating himself or herself does not apply when the Mururoa suits are used in accordance with the manufacturers instructions.
4.0 CONCLUSION
Based on the testing data provided, and when used in accordance with NMCs commitments and the requirements of Subpart H of 10 CFR Part 20, the NRC staff authorizes NMC to use the Mururoa V4 F1 and V4 MTH2 supplied-air suits at its nuclear plants specified above, and take credit for an APF of 2,000.
Principal Contributor: L. Padovan Date: December 28, 2005