ML080730064
| ML080730064 | |
| Person / Time | |
|---|---|
| Site: | Summer  |
| Issue date: | 03/18/2008 |
| From: | Steven Garry NRC/NRR/ADRO/DIRS/IHPB |
| To: | Martin R NRC/NRR/ADRO/DORL/LPLII-1 |
| Pedersen R NRR/DIRS/IHPB 301-415-3162 | |
| References | |
| TAC MD8126 | |
| Download: ML080730064 (6) | |
Text
March 18, 2008 MEMORANDUM TO: Robert Martin, Project Manager Plant Licensing Branch II-Division of Operating Reactor Licensing Office of Nuclear Reactor Regulation FROM:
Steven Garry, Leader/RA/
Health Physics Team Reactor Inspection Branch Division of Inspection and Regional Support Office of Nuclear Reactor Regulation
SUBJECT:
VIRGIL C. SUMMER NUCLEAR STATION - ISSUANCE OF SAFETY EVALUATION REPORT ON AUTHORIZATION AND EXEMPTION REQUESTS TO USE CERTAIN RESPIRATORS FOR WORKER PROTECTION FROM AIRBORNE RADIOACTIVE MATERIALS (TAC NO. MD8126)
The Health Physics Team has completed its review of the joint application from South Carolina Electric and Gas Company, dated February 19, 2008. This application requested authorization under and exemption to certain 10 CFR Part 20 requirements in order to use and take credit for certain air-supplied suits for worker respiratory protection while working in airborne radioactivity areas at the Virgil C. Summer Nuclear Station.
On the basis of its review, the staff finds the license request acceptable. The enclosed safety evaluation documents the staff findings. This completes the staffs review under the subject TAC No.
Docket Nos. 50-395
Enclosure:
Safety Evaluation CONTACT: Roger Pedersen, IPSB/NRR 301-415-3162
MEMORANDUM TO: Robert Martin, Project Manager Plant Licensing Branch II-Division of Operating Reactor Licensing Office of Nuclear Reactor Regulation FROM:
Steven Garry, Leader Health Physics Team Reactor Inspection Branch Division of Inspection and Regional Support Office of Nuclear Reactor Regulation
SUBJECT:
VIRGIL C. SUMMER NUCLEAR STATION - ISSUANCE OF SAFETY EVALUATION REPORT ON AUTHORIZATION AND EXEMPTION REQUESTS TO USE CERTAIN RESPIRATORS FOR WORKER PROTECTION FROM AIRBORNE RADIOACTIVE MATERIALS (TAC NO. MD8126)
The Health Physics Team has completed its review of the joint application from South Carolina Electric and Gas Company, dated February 19, 2008. This application requested authorization under and exemption to certain 10 CFR Part 20 requirements in order to use and take credit for certain air-supplied suits for worker respiratory protection while working in airborne radioactivity areas at the Virgil C. Summer Nuclear Station.
On the basis of its review, the staff finds the license request acceptable. The enclosed safety evaluation documents the staff findings. This completes the staffs review under the subject TAC No.
Docket Nos. 50-395
Enclosure:
Safety Evaluation CONTACT: Roger Pedersen, IPSB/NRR 301-415-3162 DISTRIBUTION:
B. Bonser R. Martin R. Pedersen ADAMS Accession Number: ML080730064 OFFICE DIRS/NRR (A)TL:DIRS/NRR NAME RPEDERSEN SGARRY DATE 03/14/2008 03/18/2008 OFFICIAL RECORD COPY
SAFETY EVALUATION BY THE OFFICE OF NUCLEAR REACTOR REGULATION USE OF FRENCH DESIGNED RESPIRATORY PROTECTION EQUIPMENT WITH A PROTECTION FACTOR OF 5000 VIRGIL C. SUMMER NUCLEAR STATION DOCKET NUMBER 50-395.
1.0 INTRODUCTION
By letter dated February 19, 2008, South Carolina Electric and Gas Company (the licensee) submitted a request to use an assigned protection factor (APF) greater than that listed in Appendix A to 10 CFR 20, for persons working in areas of airborne radioactivity with certain non-NIOSH-certified respiratory protection equipment. Specifically, the licensee requested authorization to use an APF of 5000 with the Mururoa atmosphere-supplying suit, models V4F1, and V4MTH2, manufactured by Delta Protection, France (hereafter referred to as the Delta Suits).
2.0 REGULATORY EVALUATION
Title 10 of the Code of Federal Regulations (10 CFR) Part 20, 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. Paragraph (b) of Section 20.1703 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. Paragraph (f) of section 20.1703 requires standby rescue personnel be provided when using an atmosphere supplying suit from which an unaided wearer would have difficulty extracting himself or herself.
10 CFR 20, 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 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 Nuclear Regulatory Commission (NRC) authorization before using assigned protection factors in excess of those specified in Appendix A to Part 20. Since Appendix A does not provide an APF for atmosphere supplying respirator (air-line respirator) suits in a continuous-flow operating mode, the licensee 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
The Delta Suits are atmosphere supplying suits that fully enclose the wearer. Breathing and cooling air is supplied from the plants air system through an air hose and a regulator that is integral to the suit. Currently, NIOSH does not certify suit type respiratory protective devices.
Footnote (g) in Appendix A to 10 CFR 20, authorizes the use of non-NIOSH certified supplied air suits when used in a respiratory protection program that meets the requirements of 20.1701(c), with the exception of fit testing. Therefore, requesting authorization under 20,1701(b) is not required. However, since no APF is provided in 10 CFR 20 Appendix A for air supplied suits, authorization to use an APF of 5000 is required under 20.1705.
NRC guidance provided in NUREG/CR-0041 encourages the use of supplied-air suits, noting that in certain work environments, supplied-air suits may be the best respiratory device when considering respiratory protection, heat stress, trying to minimize skin contamination, and trying to maintain worker doses as low as is 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, and to take credit for, the protection provided by two suits during normal (non-emergency) operations. The suits are made by Delta Protection, France and are identified as Mururoa V4 F1 (Certificate No. 0073/197/162/12/97/0028) and V4 MTH2 (Certificate No.
0073/197/162/01/96/0001). Both models have been approved as a single-use suits (i.e.,
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 such workplace factors as higher heat and humidity conditions, longer work durations, and greater worker fatigue.
In general, when compared with other air-fed respirators, both Delta Suits 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.
The removable emergency breathing strip, and the over the head egress strip, provided on both models of the Delta Suits, allows an unaided wearer to escape from the suit in case of loss of breathing air supply or other emergency. 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. Therefore, when used in a manner that does not impede the use of these safety features, the requirement for providing a standby rescue person in 20.1703(f) is not applicable to the Delta Suits.
Other features of the Delta Suits include light-weight (2.5 pounds), and a one-piece construction with welded gloves and booties with tie straps. The helmet is made with PVC material that provides distortion-free vision and is 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 shut off below the required minimum air flow. The Delta Suits provide 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. The suits are constructed with reinforced elbow, knee, and crotch areas.
The licensee intends to use the suits to minimize personnel exposure/contamination in radiation areas with high contamination or potential for high airborne radioactivity. Examples of these areas include the steam generator primary manways, underneath the reactor head, and in the reactor cavity. The Delta Suits 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 Delta Suits are preferable to the currently used bubblehoods because the ease of removal features provide a means to undress that minimizes the potential for personnel
contamination events. In addition, eliminating the need for using standby rescue personnel, helps to minimize occupational radiation exposures.
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 the use of the Delta Suits into their existing, ongoing respiratory protection program, that satisfies Part 20 requirements, using the manufacturers recommendations described in the Mururoa V4 Fully enclosed Suit - General Description (No. Do/USA/1), the Instructions for Donning and Removal of the Mururoa V4 Fully Enclosed Suit (No. Do/USA/2), and the Mururoa V4F1 and MTH2-V4 Instructions For Use (NO/841442T). The NRC staff finds this approach acceptable.
4.0 REGULATORY COMMITMENTS The licensee has made the following regulatory commitments concerning the use of these suits.
- 1. The manufacturers instructions for use and storage of the Delta Protection Mururoa V4F1 and V4 MTH2 suits will be integrated into VCSNS respiratory program with the minor clarification that the suits will be inspected and removed from their protective packaging outside of the plants radiological controlled area in a way that maintains the integrity of the suit, but does not lead to the unnecessary generation of solid radioactive waste.
- 2. Lesson plans will be developed and used to train workers and radiation protection technicians on the Delta Protection Mururoa V4F1 and V4 MTH2 suits features, donning, use and removal, and use of mouth strip and tear off strips for routine and emergency egress.
- 3. VCSNS radiation protection personnel will be provided additional training for selection, approval, issue, equipment set-up, operation and maintenance instructions for the Delta Protection Mururoa V4F1 and V4 MTH2 suits.
- 4. The Protection Mururoa V4F1 and V4 MTH2 suits will be discarded after a single use and will not be used in atmospheres that are immediately dangerous to life and health (IDLH).
- 5. Any defects discovered will be entered into the VCSNS Corrective Action Program and reported to the manufacturer, as necessary. Industry notifications, when required, will be made through the Operating Experience Program.
5.0 CONCLUSION
On the basis of 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: R. Pedersen