LR-N08-0249, Units I and 2, Response to RAI - Request for Authorization to Use Delta Protection French Designed Respiratory Protection Equipment

Units I and 2, Response to RAI - Request for Authorization to Use Delta Protection French Designed Respiratory Protection Equipment

ML083370298
Person / Time
Site:	Salem, Hope Creek
Issue date:	11/21/2008
From:	Neely C Public Service Enterprise Group
To:	Document Control Desk, Office of Nuclear Reactor Regulation
References
LR-N08-0249
Download: ML083370298 (6)

Text

PSEG Nuclear LLC P.O. Box 236,, Hancocks Bridge, NJ 08038-0236 0 PSEG Nuclear L.L. C.

NOV 21 2008 uer.C N10CFR20.1703(b)

LR-N08-0249 United States Nuclear Regulatory Commission Document Control Desk Washington, DC 20555 Hope Creek Generating Station Facility Operating License No. NPF-57 NRC Docket No. 50-354 Salem Generating Station, Units I and 2 Facility Operating License Nos. DPR 70 and DPR-75 NRC Docket Nos. 50-272 and 50-311

Subject:

Response to RAI - Request for Authorization to Use Delta Protection French Designed Respiratory Protection Equipment Reference (1) Letter from PSEG to NRC: "Request for Authorization to Use Delta Protection French Designed Respiratory Protection Equipment, Hope Creek Generating Station, Salem Nuclear Generating Station, Units 1 and 2," dated July 3, 2008 In Reference 1, PSEG Nuclear LLC (PSEG) submitted an authorization request, in accordance with the provisions of 10CFR20.1703(b), 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) take credit for an assigned protection factor of 2,000 for this equipment and (3) not provide standby rescue persons whenever this equipment is used.

The NRC provided PSEG a Request for Additional Information (RAI) on the authorization request. The response to the RAI is provided in Attachment 1 to this submittal. Regulatory commitments as a result of this submittal are identified in Attachment 2.

If you have any questions or require additional information, please do not hesitate to contact Mr.

Jeff Keenan at (856) 339-5429.

Sincerely, Christine T. Neely Director-Regulatory Affairs A4co(

Document Control Desk NOV 21 2008 LR-N08-0249 Attachments: (2)

C Mr. S. Collins, Administrator - Region I U. S. Nuclear Regulatory Commission 475 Allendale Road King of Prussia, PA 19406 Mr. R. Ennis, Project Manager - Salem Unit 1 and Unit 2 U. S. Nuclear Regulatory Commission Mail Stop 08B1 Washington, DC 20555-0001 USNRC Senior Resident Inspector-Hope Creek USNRC Senior Resident Inspector-Salem Unit 1 and Unit 2 Mr. P. Mulligan Bureau of Nuclear Engineering PO Box 415 Trenton, New Jersey 08625 Commitment Coordinator-Salem.

Commitment Coordinator - Hope Creek PSEG Commitment Coordinator - Corporate:

Attachment I LR-N08-0249 REQUEST FOR ADDITIONAL INFORMATION REGARDING REQUEST FOR AUTHORIZATION TO USE DELTA PROTECTION RESPIRATORY PROTECTION QUIPMENT FOR HOPE CREEK GENERATING STATION AND SALEM NUCLEAR GENERATING STATION, UNIT NOS. 1 AND 2 DOCKET NOS. 50-354, 50-272 AND 50-311 By letter dated July 3, 2008 (Agencywide Documents Access and Management System (ADAMS) Accession No. ML081980090), PSEG Nuclear LLC (PSEG or the licensee) requested authorization, pursuant to Title 10 of the Code of Federal Regulations (10 CFR), Part 20, Section 20.1703(b), for Hope Creek Generating Station and Salem Nuclear Generating Station, Unit Nos. 1 and 2, 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) take credit for an assigned protection factor of 2,000 for this equipment; and, (3) not provide standby rescue persons whenever this equipment is used.

The Nuclear Regulatory Commission (NRC) staff has reviewed your request and would like to discuss the following to clarify the submittal.

1)

Page 2 of the cover letter states that PSEG will implement the following controls for use of the Mururoa V4 F1 and V4 MTH2 single use respiratory protection suits:

1.

The Mururoa V4 F1 and V4 MTH2 single use suit will be integrated into the PSEG respiratory protection programs using the information provided by the manufacturer.

2.

New lesson plans will be developed 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.

Radiation Protection personnel will be provided additional training for selection, approval, issue, equipment set-up, operation and maintenance instructions for the Mururoa suit.

Although Enclosure 1 to your submittal addressed some of the following issues, the cover letter did not specifically include the following controls in the above list of controls.

Please address whether the following controls will also be implemented and, if not, provide justification:

1 of 3

Attachment I LR-N08-0249

1.

The manufacturer's instructions for use and storage of the Delta Protection Mururoa V4F1 and V4 MTH2 suits will be integrated into the respiratory protection programs.

2.

The 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).

3.

Any defects discovered will be entered into the Corrective Action Program and reported to the manufacturer, as necessary. Industry notifications, when required, will be made through the Operating Experience Program.

RESPONSE

The latter list of three controls will be implemented. The controls listed in the July 3, 2008 cover letter were not all-inclusive; the complete discussion of controls related to implementation of the use of the Delta Protection Mururoa V4F1 and V4 MTH2 suits is provided in Enclosure 1, Sections 2.3.2 and 2.3.4, of the July 3, 2008 submittal. These controls are listed below, and are provided in Attachment 2 of this submittal as commitments PSEG is making related to use of the Delta Protection Mururoa V4F1 and V4 MTH2 suits.

1. The manufacturer's instructions for use and storage of the Delta Protection Mururoa V4F1 and V4 MTH2 suits will be adhered to and integrated into the respiratory protection programs, with the exception of "instructions for donning and removal", Attachment 2.5.5, Caution Step 2 (stand-by rescue person not required).

2. New lesson plans will be developed 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. Radiation Protection personnel will be provided additional training for selection, approval, issue, equipment set-up, operation and maintenance instructions for the Mururoa suit.

4. The 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 with the Mururoa suit will be entered into the Corrective Action Program and reported to the manufacturer, as necessary. Industry notifications, when required, will be made through the Operating Experience Program.

2)

As required by 10 CFR 50.34(b)(3), the Updated Final Safety Analysis Report (UFSAR) shall include information describing the means for controlling and limiting radiation exposures within the limits set forth in 10 CFR Part 20. Please provide a regulatory commitment to include the controls discussed in question 1 in the Hope Creek and Salem UFSARs upon implementation of the requested authorization.

2 of 3 LR-NO8-0249

RESPONSE

As discussed in the response to Question 1, PSEG is committing to establish appropriate controls related to implementation of the requested authorization. These controls will be included in the Hope Creek and Salem UFSARs, and be captured as commitments in the Commitment Management Program (see Attachment 2 of this submittal) to be integrated into appropriate procedures and programs.

3 of 3 LR-NO8-0249 List of Regulatory Commitments PSEG implement the following controls at the Salem and Hope Creek Generating Stations:

COMMITTMENT TYPE ONE-TIME PROGRAMMATIC COMMITTMENT COMMITTED DATE ACTION (YesRMMNo)

ACTION (Yes / No)

(Yes I No)

The manufacturer's instructions for use and storage of the Delta Protection Mururoa V4F1 and V4 MTH2 suits will be March 31, 2009, adhered to and integrated into the upon NRC respiratory protection programs, with the approval and No Yes exception of "instructions for donning and subsequent removal", Attachment 2.5.5, Caution Step implementation 2 (stand-by rescue person not required).

New lesson plans will be developed to train workers on Mururoa's features, March 31, 2009, donning, use and removal, cautions and upon NRC approval No Yes use of mouth strip and tear off strips for and subsequent routine and emergency egress.

implementation Radiation Protection personnel will be provided additional training for selection, March 31, 2009, approval, issue, equipment set-up, upon NRC approval No Yes operation and maintenance instructions and subsequent for the Mururoa suit.

implementation The Mururoa V4F1 and V4 MTH2 suits will be discarded after a single use and March 31, 2009, will not be used in atmospheres that are upon NRC approval No Yes immediately dangerous to life and health and subsequent (IDLH).

implementation Any defects discovered with the Mururoa suit will be entered into the Corrective Action Program and reported to the March 31, 2009, manufacturer, as necessary. Industry upon NRC approval No Yes notifications, when required, will be made and subsequent through the Operating Experience implementation Program.

The above five (5) controls will be March 31, 2009, included in the Hope Creek and Salem upon NRC approval Yes No UFSARs.

and subsequent implementation 1 of 1