ML18153A121
| ML18153A121 | |
| Person / Time | |
|---|---|
| Site: | Surry, North Anna  |
| Issue date: | 03/27/1997 |
| From: | Ohanlon J VIRGINIA POWER (VIRGINIA ELECTRIC & POWER CO.) |
| To: | NRC OFFICE OF INFORMATION RESOURCES MANAGEMENT (IRM) |
| Shared Package | |
| ML18152A072 | List: |
| References | |
| NUDOCS 9704070313 | |
| Download: ML18153A121 (11) | |
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VIRGINIA ELECTRIC AND POWER COMPANY RICHMOND, VIRGINIA 23261 March 27, 1997 United States Nuclear Regulatory Commission
- Attention: Document Control Desk *
- Washington, D.C. 20555
Dear Gentlemen:
VIRGINIA ELECTRIC AND POWER COMPANY SURRY POWER STATION UNITS 1 AND 2 NORTH ANNA POWER STATION UNITS 1 AND 2 10 CFR 20.1703(a)(2) EQUIPMENT AUTHORIZATION Serial No.
NL&OS/DAS Docket Nos.
License Nos.97-092 R1.
50-280 50-281 50-338 50-339 DPR-32 DPR-37 NPF-4 NPF-7 10 CFR 20.1703(a)(1) specifies that respiratory protection equipment used to limit intakes be tested and certified or have certification extended by the National Institute for Occupational Safety and Health/Mine Safety and Health Administration (NIOSH/MSHA) to make allowance for protection factors. 10 CFR 20.1703(a)(2) permits a licensee to request specific authorization from the Commission for equipment which has not been tested. and certified by NIOSH/MSHA. A prerequisite for such an authorization is demonstration by testing or reliable test information that the material and performance characteristics of the equipment are capable of providing the proposed degree of protection under anticipated conditions of use. In addition, 10 CFR 20.1703(c) specifies that only equipment that had been specifically certified or had certification extended for emergency use by NIOSH/MSHA shall be used as emergency devices.
Surry and North Anna Power Stations have subatmospheric containments. Personnel entries require Self-Contained Breathing Apparatus (SCBA) charged with 35% oxygen I 65% nitrogen breathing gas mixture to compensate for the reduced oxygen partial pressure. Mine Safety Appliances Company (MSA) Models 401, Ultralite and Custom 4500 Dual Purpose Pressure Demand SCBA are NIOSH/MSHA certified for use with Ii compressed air. However, these SCBA were not formally tested by NIOSH/MSHA for
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enriched oxygen application. Virginia Electric and Power Company contracted with the National Aeronautics and Space Administration (NASA) and Lawrence Livermore J/7),7 11 National Laboratory (LLNL) to have these NIOSH/MSHA approved SCBAs tested to Vf confirm the compatibility of their materials and design with enriched oxygen application and thereby demonstrate the equipment is capable of providing the proposed degree of protection under the anticipated conditions of use. The test results were acceptable.
Therefore, in accordance with 10 CFR 20.1703(a)(2), Virginia Electric and Power 9704070313 970327 PDR ADOCK 05000280 P
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requests specific authorization to use MSA Models 401 (constructed of either brass or aluminum components), Ultralite and Custom 4500 Dual-Purpose Pressure-Demand SCBA supplied with a 35% oxygen/65% nitrogen breathing gas mixture and make allowance for the protection factors as specified for Pressure-Demand SCBA in 1 O CFR 20, Appendix A (i.e., 10,000 or greater) during normal and emergency use.
- Attachment 1 -to this letter provides the basis for this authorization request and a summary of the test protocol and results. In addition, a copy of the final test reports are included as Attachments 2 and 3 to this letter.
Should you have any questions regarding the authorization request, please do not hesitate to contact us.
Very truly yours,
~f.o-:11~
James P. O'Hanlon Senior Vice President - Nuclear Attachments
- 1. 10 CFR 20.1703(a)(2)Authorization Request
- 2. NASA White Sands Test Facility Test Report
- 3. Lawrence Livermore National Laboratory Test Report Commitments made by this letter:
None cc:
U.S. Nuclear Regulatory Commission Region II 101 Marietta Street, N. W.
Suite 2900 Atlanta, Georgia 30323 Mr. R. A. Musser NRC Senior Resident Inspector Surry Power Station NRC Senior Resident Inspector North Anna Power Station
10CFR20. 1703(a) (2) RESPIRATORY PROI'OCTION
~IPMENT ATJIBORIZATION REC'D W/LTR D'ID 03/27/97 **** 970'4070313
- NOTICE -
THE ATTACHED FILES ARE OFFICIAL RECORDS OF THE INFORMATION &
RECORDS MANAGEMENT BRANCH.
THEY HAVE BEEN CHARGED TO YOU FOR A LIMITED TIME PERIOD AND MUSTBERETURNEDTOTHE RECORDS & ARCHIVES SERVICES SECTION, TS C3. PLEASE DO NOT SEND DOCUMENTS CHARGED OUT THROUGH THE MAIL. REMOVAL OF ANY PAGE(S) FROM DOCUMENT FOR REPRODUCTION MUST BE REFERRED TO FILE PERSONNEL.
- NOTICE -
10 CFR 20.1703(a)(2) Authorization Request Virginia Electric and Power Company Surry and North Anna Power Stations
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10 CFR 20.1703(a)(2) Authorization Request
Purpose:
.. 1 O CFR 20. 1703(a)(1) specifies that respiratory protection-equipment be tested and certified or have certification extended by the National Institute for Occupational Safety and Health/Mine Safety and Health Administration (NIOSH/MSHA) to make allowance for protection factors.
10 CFR 20. 1703(a)(2) permits a licensee to request specific authorization from the Commission for equipment which has not been tested and certified by NIOSH/MSHA. A prerequisite for such an authorization is demonstration by testing or reliable test information that the material and performance characteristics of the equipment are capable of providing the proposed degree of protection under anticipated conditions of use.
In addition, 10 CFR 20.1703(c) specifies that only equipment that has been specifically certified or had certification extended for emergency use by NIOSH/MSHA shall be used as emergency devices. This document provides the basis of our request for specific authorization to make allowance for protection factors and emergency use of Mine Safety Appliances Company (MSA)
Models 401 (constructed of either brass or aluminum components), Ultralite and Custom 4500 Dual-Purpose Self-Contained Breathing Apparatus (SCBA) supplied with a 35% oxygen I 65% nitrogen breathing gas mixture.
Background:
The containments at both North Anna and Surry Power Stations are designed to be maintained at subatmospheric pressure during power operations. Actual containment environment varies depending on unit load and time of year, however, pressure ranges between 9.0 and 11.0 pounds per square inch absolute (psia). Additionally, localized air temperatures may exceed 120° Fahrenheit and relative humidity can be 90%.
It is necessary for station personnel to periodically enter containment while the units are operating in order to perform inspections or maintenance. The impact of the above mentioned containment environment on personnel safety was assessed in the mid 1970s due to minor physiological symptoms observed in some personnel working in containment (e.g., dizziness, cramps, shortness of breath). Heat stress management techniques (e.g., stay times, fluids, cooling garments), already developed for general industry, were adapted to mitigate these symptoms and are still in use today. The other containment stress, oxygen deficiency due to reduced pressure, requires a unique solution (i.e., use of SCBA with enriched oxygen breathing gas).
Page 1 of 6
Oxygen Deficiency:
Oxygen deficiency can be caused by a reduction of the percent by volume of oxygen or by reduction of atmospheric pressure. The effect of oxygen deficiency on the body is the same in either case. It is the quantity or partial pressure of oxygen available that is important, not the percent by volume or atmospheric pressure.
Specifically, the percentage. of. oxygen in the air,. normally 20.9%, does. not change with decreasihg absolute pressure (or increasing altitude); however, the oxygen partial pressure does decrease because the total pressure decreases.
People are able to live and work at oxygen partial pressures similar to those found in our containments with little or no physiological problems. This is due to acclimatization.
Changes in the body's respiratory, cardiovascular, and hematopoietic systems compensate for reduced oxygen partial pressure.
Unfortunately, acclimatization requires too much time to be of any practical use in our situation of limited and infrequent entries into containment.
Solution:
Methods to compensate for the physiological effects of reduced pressure were explored and it was determined that oxygen enriched breathing gas was necessary. Using the guidance contained in ANSI 288.2-1980, Practices for Respiratory Protection, an oxygen *enrichment of 35% (with the balance comprised of nitrogen) was established as proper. ANSI 288.2-1992 bases its reduced atmospheric pressure conditions guidance on different methodology than that used in the 1980 version. However, a 35% oxygen enrichment is still valid.
Per ANSI 288.2-1980, Practices for Respiratory Protection, there are two possible respirators acceptable for use in our subatmospheric containments.
They include:
positive pressure, closed-circuit SCBA and positive pressure, open-circuit SCBA.
Closed-circuit SCBA were evaluated during the mid 1970s.
Their disadvantages (contaminant recirculation, increased complexity, 100% oxygen hazard, heat stress component due to exothermic reaction associated with carbon dioxide scrubbing) outweighed their advantages (light weight, longer service life).
Open-circuit SCBA supply air which does not add to the user's heat stress load is "user friendly," is highly reliable, and does not produce high oxygen concentration levels, which could make the device a fire hazard. Additionally, for our specific application, use of the same respiratory equipment type inside and outside of containment simplifies employee training and equipment maintenance.
Page 2 of 6
To provide protection for personnel entering containment under subatmospheric conditions, Virginia Electric and Power Company initially purchased MSA Model 401 open-circuit, dual-purpose pressure-demand SCBA constructed of brass components.
Procedures were established to utilize these devices with a 35% oxygen / 65% nitrogen breathing gas mixture. This respirator has been in use at North Anna and Surry Power Stations since 1976 with.. no incidence of oxygen induced failure or other adverse performance indicators noted.
SCBA Maintenance:
The MSA Model 401 SCBA purchased by Virginia Electric and Power Company are supplied for use with compressed air.
Following the recommendations of the Compressed Gas Association's Pamphlet C-10, Recommended Procedures for Changes of Gas Service for Compressed Gas Cylinders, Model 401 cylinders designated for use with 35% oxygen / 65% nitrogen have been qualified for Class 1 Oxidizing Gas Service.
SCBA are maintained by station personnel certified by MSA under their Air Mask Service Center Certification Program and in accordance with MSA's preventive maintenance and repair procedures.
Equipment is designated for containment use with the 35% oxygen I 65% nitrogen mixture and is segregated and controlled to ensure no inadvertent exchange with compressed air units.
Breathing Gas Mixture:
The 35% oxygen / 65% nitrogen mixture used at the stations is purchased from an outside vendor. Strict controls are employed by the vendor during manufacture of the mixture which involves reconstitution of medical grade liquid oxygen and liquid nitrogen.
The vendor is required by purchase order to certify that the oxygen used to produce the breathing gas mixture meets the specifications defined in the latest revision of The United States Pharmacopeia (USP)-The National Formulary (NF). The nitrogen used must meet the specifications defined in the National Formulary.
Additionally, the oxygen and nitrogen constituents must be within two percent of the specified volume percentages.
Vendor supplied bulk 35% oxygen / 65% nitrogen mixtures are transferred to dedicated SCBA cylinders using cascade systems or transfer pumps dedicated to 35% oxygen /
65% nitrogen breathing gas mixtures. The cylinder charging systems are specifically designed for transferring respirable gases and are operated by trained personnel in accordance with approved station procedures.
Page 3 of 6
Training:
Personnel who use SCBA equipment (35% oxygen / 65% nitrogen or compressed air) are provided specific training on their proper operation.
SCBA user training is a separate course of instruction administered to potential users following basic Respiratory Protection Training. This instruction includes review of appropriate actions in the event of an emergency or an equipment malfunction. (Station procedures also address subatmospheric containment work including emergency actions.) Appropriate testing is employed, including practical demonstrations, to ensure training effectiveness.
Periodic retraining is required to maintain SCBA user qualification.
Equipment Testing for Enriched Oxygen Application:
Although the MSA SCBA referenced have received NIOSH/MSHA certification, they have not specifically been tested for 35% enriched oxygen applications.
Specific authorization per 10 CFR 20.1703(a)(2) requires a demonstration by testing or reliable test information that the material and performance characteristics of the equipment are capable of providing the proposed degree of protection under anticipated conditions of use. These devices have been NIOSH/MSHA tested for compressed air application.
To specifically address material compatibility in enriched oxygen applications and thereby demonstrate equipment capability under anticipated conditions of use, Virginia Electric and Power Company contracted with both NASA's White Sands Test Facility (WSTF) and Lawrence Livermore National Laboratory (LLNL) to conduct applicable oxygen compatibility testing. The respective final reports are enclosed as Attachments 2 and 3.
WSTF evaluated the compatibility of the MSA Custom 4500 SCBA with an oxygen enriched breathing gas mixture. (Testing of the MSA Custom 4500 envelopes the lower pressure applications of the MSA Ultralite and Model 401 SCBA).
To do this, the flammability of the Custom 4500 was assessed using three types of tests:
- 1. Promoted ignition tests determined that the aluminum alloy 6061 used in the regulator body of the Custom 4500 would not sustain combustion in an atmosphere up to 52% oxygen at 4500 psig. (Brass, used in the regulator of Virginia Electric and Power Company's Model 401 SCBA, is less reactive than aluminum alloy 6061 and hence is conservatively enveloped by this testing.)
- 2. Regulator combustion tests determined that the combustion of gross hydrocarbon contamination within the test article would not ignite the aluminum alloy 6061 in the regulator body. (Brass, used in the regulator of Virginia Electric and Power Company's Model 401 SCBA, is less reactive than aluminum alloy 6061 and hence is conservatively enveloped by this testing.)
- 3. Compressive heating tests determined that compressive heating of uncontaminated units does not promote ignition of the high-pressure flex hose or the regulator assembly softgoods at the use conditions.
Page 4 of 6
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NASA concluded that the MSA Custom 4500 (and therefore the Ultralite and 401 Models) is compatible based on flammability hazards testing for use with a breathing gas mixture of 35% oxygen / 65% nitrogen provided the following stipulations are met:
- 1. All hydrocarbon contamination is removed. (MSA repair guidance stipulates that no hydrocarbon based compounds are to be used within the pressure boundary during maintenance.)
- 2. The SCBA are maintained so as to preclude the introduction of hydrocarbon contamination. (Virginia Electric and Power Company SCBA are required to be stored and repaired in clean, dry locations free of chemical contamination.)
- 3. The temperature of the system does not exceed 135° Fahrenheit when the regulator is first activated. (Containment average air temperature is required by Technical Specifications to be less than or equal to 125 ° Fahrenheit at Surry and 120° at North Anna.)
NASA cautioned that their test data did not prove that the MSA SCBA tested was safe to use with an oxygen enriched breathing gas under all circumstances.
They recommended that tests be conducted to determine the effects of the user exhaling the oxygen enriched mixture into a "fire-charged" environment. Subsequent discussions with NASA and MSA personnel resulted in Virginia Electric and Power Company contracting with Lawrence Livermore National Laboratory (LLNL) to evaluate our equipment under the National Fire Protection Association's (NFPA) SCBA Flame and Heat Test.
The LLNL SCBA Flame and Heat Test evaluates a SCBA's performance in a typical fire fighting thermal and flashover environment while being operated at moderate to high breathing rates. The facepiece design used with the Custom 4500, Ultralite and 401 Model SCBA is interchangeable. Therefore, testing of a common facepiece design addressed all three SCBA models.
LLNL concluded that a MSA Custom 4500, equipped with the interchangeable silicone facepiece, meets the NFPA Flame and Heat Test requirements whether operated with 35% oxygen / 65% nitrogen breathing gas mixture or with compressed air.
(Virginia Electric and Power Company procedural guidance presently requires that SCBA using the 35% oxygen / 65% nitrogen breathing gas mixture be equipped with silicone facepieces.)
Use History:
In addition to the formal testing outlined above, Virginia Electric and Power Company has accumulated over twenty years of actual safe operating experience using SCBAs with 35% oxygen / 65% nitrogen. Over this time period, no incidents of oxygen induced failure or equipment maintenance problems associated with enriched oxygen operation have been recorded.
We believe that this safe operational experience provides additional "reliable test information" as to the acceptability of the use of enriched oxygen with MSA SCBA.
Page 5 of 6
Summary of Request for Specific Authorization:
Specific authorization per 10 CFR 20.1703(a)(2) requires a demonstration by testing or reliable test information that the material and performance characteristics of the equipment are capable of providing the proposed degree of protection under anticipated conditions of use.
We believe that the combination of formal testing conducted for Virginia Electric and Power Company by NASA and LLNL, our extensive sate use history and the existing NIOSH/MSHA certification for the SCBAs meets this regulatory requirement.
Therefore, in accordance with 10 CFR 20.1703(a)(2), we request specific authorization to use MSA Models 401 (constructed of either brass or aluminum components), Ultralite, and Custom 4500 Dual-Purpose Pressure-Demand SCBA supplied with 35% oxygen I 65% nitrogen breathing gas mixture and to make allowance for protection factors as specified for pressure-demand SCBAs in 1 O CFR 20, Appendix A during normal and emergency use.
Page 6 of 6
NASA White Sands Test Facility Test Report Virginia Electric and Power Company Surry and North Anna Power Stations