Text

Constellation Energy Generation, Llc_Fleet - Request to Authorize Use Honeywell Mururoa V4F1 R Supplied Air Suits
	ML22293B805
Person / Time
Site:	Calvert Cliffs, Dresden, Peach Bottom, Nine Mile Point, Byron, Braidwood, Limerick, Ginna, Clinton, Quad Cities, LaSalle
Issue date:	11/30/2022
From:	Nancy Salgado; NRC/NRR/DORL/LPL3
To:	Rhoades D; Constellation Energy Generation
	Purnell B, NRR/DORL/LPL3
References
	EPID L-2022-LLL-0011
	Download: ML22293B805 (1)
	v • d • e

November 30, 2022 Mr. David P. Rhoades Senior Vice President Constellation Energy Generation, LLC President and Chief Nuclear Officer Constellation Nuclear 4300 Winfield Road Warrenville, IL 60555

SUBJECT:

BRAIDWOOD STATION, UNITS 1 AND 2; BYRON STATION, UNIT NOS. 1 AND 2; CALVERT CLIFFS NUCLEAR POWER PLANT, UNITS 1 AND 2; CLINTON POWER STATION, UNIT NO. 1; DRESDEN NUCLEAR POWER STATION, UNITS 2 AND 3; LASALLE COUNTY STATION, UNITS 1 AND 2; LIMERICK GENERATING STATION, UNITS 1 AND 2; NINE MILE POINT NUCLEAR STATION, UNITS 1 AND 2; PEACH BOTTOM ATOMIC POWER STATION, UNITS 2 AND 3; QUAD CITIES NUCLEAR POWER STATION, UNITS 1 AND 2; AND R. E. GINNA NUCLEAR POWER PLANT - REQUEST TO AUTHORIZE USE OF HONEYWELL MURUROA V4F1 R SUPPLIED AIR SUITS (EPID L-2022-LLL-0011)

Dear Mr. Rhoades:

By application dated June 30, 2022 (Agencywide Documents Access and Management System (ADAMS) Accession No. ML22181A094), Constellation Energy Generation, LLC (the licensee) requested U.S. Nuclear Regulatory Commission (NRC) authorization to allow the use of Honeywell Mururoa V4F1 R supplied air suits with an assigned protection factor (APF) of 5,000 at Braidwood Station, Units 1 and 2; Byron Station, Unit Nos. 1 and 2; Calvert Cliffs Nuclear Power Plant, Units 1 and 2; Clinton Power Station, Unit No. 1; Dresden Nuclear Power Station, Units 2 and 3; LaSalle County Station, Units 1 and 2; Limerick Generating Station, Units 1 and 2; Nine Mile Point Nuclear Station, Units 1 and 2; Peach Bottom Atomic Power Station, Units 2 and 3; Quad Cities Nuclear Power Station, Units 1 and 2; and R. E. Ginna Nuclear Power Plant (collectively, the facilities). The application was submitted in accordance with sections 20.1703(b) and 20.1705 of Title 10 of the Code of Federal Regulations (10 CFR).

Specifically, in accordance with 10 CFR 20.1703(b), the licensee requests NRC authorization to use respiratory protection equipment to limit the intake of radioactive material that has not been tested or certified by the National Institute for Occupational Safety and Health. Additionally, pursuant to 10 CFR 20.1705, the licensee requests NRC authorization to use an APF in excess of those specified in appendix A to 10 CFR Part 20.

The NRC staff has reviewed the application and concludes, as set forth in the enclosed safety evaluation, that the licensee has adequately addressed the regulatory requirements set forth in 10 CFR 20.1703(b) and 20.1705. Therefore, the NRC staff authorizes the use of the Honeywell Mururoa V4F1 R suits with an APF of 5,000 at the licensees facilities, as described in the application.

If you have any questions, please contact Scott Wall at 301-415-2855 or via email at Scott.Wall@nrc.gov.

Sincerely, Nancy L. Salgado, Chief Plant Licensing Branch III Division of Operating Reactor Licensing Office of Nuclear Reactor Regulation Docket Nos. STN 50-456, STN 50-457, STN 50-454, STN 50-455, 50-317, 50-318, 50-461, 50-237, 50-249, 50-373, 50-374, 50-352, 50-353, 50-220, 50-410, 50-277, 50-278, 50-254, 50-265, and 50-244

Enclosure:

Safety Evaluation cc: Listserv Nancy L.

Salgado Digitally signed by Nancy L. Salgado Date: 2022.11.30 10:40:14 -05'00'

Enclosure SAFETY EVALUATION BY THE OFFICE OF NUCLEAR REACTOR REGULATION REQUEST TO USE HONEYWELL MURUROA V4F1 R SUPPLIED AIR SUITS EXELON GENERATION COMPANY, LLC BRAIDWOOD STATION, UNITS 1 AND 2 BYRON STATION, UNIT NOS. 1 AND 2 CALVERT CLIFFS NUCLEAR POWER PLANT, UNITS 1 AND 2 CLINTON POWER STATION, UNIT NO. 1 DRESDEN NUCLEAR POWER STATION, UNITS 2 AND 3 LASALLE COUNTY STATION, UNITS 1 AND 2 LIMERICK GENERATING STATION, UNITS 1 AND 2 NINE MILE POINT NUCLEAR STATION, UNITS 1 AND 2 PEACH BOTTOM ATOMIC POWER STATION, UNITS 2 AND 3 QUAD CITIES NUCLEAR POWER STATION, UNITS 1 AND 2 R. E. GINNA NUCLEAR POWER PLANT DOCKET NOS. STN 50-456, STN 50-457, STN 50-454, STN 50-455, 50-317, 50-318, 50-461, 50-237, 50-249, 50-333, 50-373, 50-374, 50-352, 50-353, 50-220, 50-410, 50-277, 50-278, 50-254, 50-265, AND 50-244

1.0 INTRODUCTION

By application dated June 30, 2022 (Agencywide Documents Access and Management System (ADAMS) Accession No. ML22181A094), Constellation Energy Generation, LLC (CEG, the licensee) requested U.S. Nuclear Regulatory Commission (NRC, or Commission) authorization to allow the use of Honeywell Mururoa V4F1 R supplied air suits (Mururoa V4F1 R suits) with an assigned protection factor (APF) of 5000 at Braidwood Station, Units 1 and 2; Byron Station, Unit Nos. 1 and 2; Calvert Cliffs Nuclear Power Plant, Units 1 and 2; Clinton Power Station, Unit No. 1; Dresden Nuclear Power Station, Units 2 and 3; LaSalle County Station, Units 1 and 2; Limerick Generating Station, Units 1 and 2; Nine Mile Point Nuclear Station, Units 1 and 2; Peach Bottom Atomic Power Station, Units 2 and 3; Quad Cities Nuclear Power Station, Units 1 and 2; and R. E. Ginna Nuclear Power Plant (collectively, the facilities).

The application was submitted in accordance with sections 20.1703(b) and 20.1705 of Title 10 of the Code of Federal Regulations (10 CFR).

Specifically, in accordance with 10 CFR 20.1703(b), the licensee requests NRC authorization to use respiratory protection equipment to limit the intake of radioactive material that has not been tested or certified by the National Institute for Occupational Safety and Health (NIOSH).

Additionally, pursuant to 10 CFR 20.1705, the licensee requests NRC authorization to use an APF in excess of those specified in appendix A to 10 CFR part 20. The CEG facilities have respiratory protection programs administered by the licensee to be compliant with 10 CFR part 20.

2.0 REGULATORY EVALUATION

2.1 Regulatory Requirements The regulations in 10 CFR 20.1703, Use of individual respiratory protection equipment, specify the requirements for the use of respiratory protection equipment to limit the intake of radioactive material. The regulation in 10 CFR 20.1703(b) states:

If the licensee wishes to use [respiratory protection] equipment that has not been tested or certified by NIOSH, or for which there is no schedule for testing or certification, the licensee shall submit an application to the NRC for authorized use of this equipment except as provided in this part. The application must include evidence that the material and performance characteristics of the equipment are capable of providing the proposed degree of protection under anticipated conditions of use. This must be demonstrated either by licensee testing or on the basis of reliable test information.

APF is defined in 10 CFR 20.1003 as the expected workplace level of respiratory protection that would be provided by a properly functioning respirator or a class of respirators to properly fitted and trained users. Operationally, the inhaled concentration can be estimated by dividing the ambient airborne concentration by the APF. The APFs for respirators are specified in appendix A to 10 CFR Part 20, but this appendix does not provide an APF for atmosphere supplying continuous flow suits. Footnote g of the appendix 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).

The regulation in 10 CFR 20.1703(f) states, in part, that: Standby rescue persons are required whenever one-piece atmosphere-supplying suits, or any combination of supplied air respiratory protection device and personnel protective equipment are used from which an unaided individual would have difficulty extricating himself or herself.

The regulation in 10 CFR 20.1705, Application for use of higher assigned protection factors, states:

The licensee shall obtain authorization from the Commission before using assigned protection factors in excess of those specified in Appendix A to Part 20.

The Commission may authorize a licensee to use higher assigned protection factors on receipt of an application that:

(a) Describes the situation for which a need exists for higher protection factors; and (b) Demonstrates that the respiratory protection equipment provides these higher protection factors under the proposed conditions of use.

2.2 Guidance NRC Regulatory Guide (RG) 8.15, Revision 1, Acceptable Programs for Respiratory Protection (ML003739528), includes guidance for applications submitted under 10 CFR 20.1703(b) and 20.1705. Section 4.2 of the RG states, in part, that when the NRC staff has authorized one licensee to use of a respiratory protection device that has not been certified by NIOSH, subsequent applications by additional licensees may make use of test information in the original submittal. For requests to use a supplied air suit with an APF, section 4.12.2 of the RG states, in part, that: Conditions of use to be described in the application would include the anticipated length of air supply hose (minimum and maximum) and breathing air supply pressure (minimum and maximum). The NIOSH approval criteria for supplied-air hoods (42 CFR part 84) may be useful to licensees who anticipate applying for use of an APF for supplied-air suits.

European Standard EN 1073-1, Protective Clothing Against Radioactive Contamination, dated January 1998 was provided in attachment 1, enclosure 5.2, of the application. The NRC staff has previously found that this standard is consistent with NIOSH testing criteria and testing criteria used to authorize the use of air-supplied suits at U.S. Department of Energy (DOE) facilities. Historically, in the absence of NIOSH testing and certification, the DOEs Office of Environment, Health Safety and Security has funded a testing program for supplied air suits and the NRC has used the results of this testing program to inform approvals of equipment not certified by NIOSH.

NUREG/CR-0041, Revision 1, Manual of Respiratory Protection Against Airborne Radioactive Material, dated January 2001 (ML010310331), provides information to assist respirator users and program staff in establishing a respiratory protection program that complies with NRC regulations.

2.3 Precedent By letter dated August 14, 2006 (ML062230266), the NRC staff authorized the use of Mururoa V4F1 R suits with an APF of 5,000 at Arkansas Nuclear One, Unit 2 (ANO-2), and James A.

Fitzpatrick Nuclear Power Plant (JAF).

3.0 TECHNICAL EVALUATION

The NRC staff evaluated the licensees application to use the Mururoa V4F1 R suits with an APF of 5,000 under the requirements listed in Section 2.1 of this safety evaluation. The NRC staff considered the guidance described in Section 2.2 and the precedent described in Section 2.3 of this safety evaluation in its review.

The following enclosures were provided in attachment 1 to the application:

5.1 General Description of the Honeywell Mururoa V4F1 R Supplied Air Suit 5.2 European Standard EN 1073-1:1998 for Ventilated Protective Clothing 5.3 Certificate No. 0073/197/162/02/01/0005 for Mururoa V4F1 R 5.4 Donning and Removal Instructions for Honeywell Mururoa V4F1 R 5.5 Honeywell Safety and Productivity Solutions Product Recall Policy 3.1 Material and Performance Characteristics Pursuant to 10 CFR 20.1703(b), the licensee requests NRC authorization to use respiratory protection equipment to limit the intake of radioactive material that has not been tested or certified by the NIOSH. This regulation requires the application to include evidence that the material and performance characteristics of the equipment are capable of providing the proposed degree of protection under anticipated conditions of use. This must be demonstrated either by licensee testing or on the basis of reliable test information.

Section 1.2.3 of the application includes the following information regarding the material and physical characteristics of the Mururoa V4F1 R suit:

The Honeywell Mururoa V4F1 R supplied air suit is lightweight (< 1.8 kg

[kilograms] or 4 lbs. [pounds]), made of fire-retardant material (M1 classification) and can be used in temperatures up to 140 degrees Fahrenheit, as per European Standard EN 1073-1. The suits have built-in gloves, booties with binding ties, and have reinforced elbows, feet, and knees. A transparent helmet with 6-inch x 8-inch clear faceplate provides distortion-free view. Dual magnetic ventilation valves provide needed ventilation and relief of excess pressure in the event the suit is squeezed/pinched unexpectedly. Should a loss of air occur, the user can remove the mouth strip, adjust the opening closer to their face, or enlarge the opening to access and breathe outside air. Alternatively, the user can pull the escape strip from either forearm, over the head and towards the other forearm, and rip the suit in two (2) halves. This escape strip is normally used for egress from the suit when the work activity has been completed.

Section 1.2.4 of the application states, in part, that the Mururoa V4F1 R supplied air suit may be used for Steam Generator platform work, reactor cavity decontamination, control rod drive (CRD) exchange and equipment decontamination. The staff finds that that the proposed work conditions are consistent with the uses of these types of suits at NRC licensed commercial reactor facilities. Section 1.2.3 of the application also states that the Mururoa V4F1 R suit is not designed for use in immediately dangerous to life and health (IDLH) environments. As described in section 3.4 of this safety evaluation (SE), the licensee stated that the Mururoa V4F1 R suits will not be used in an IDLH environment. Therefore, the use of these suits in an IDLH environment was not considered in the NRC staffs evaluation of the application.

Section 1.2.2 of the application includes the following information regarding the air supply and hose length:

Air hoses of any length may be used; however, air supplied to the Mururoa V4F1 R suits shall be between 35-100 psig [pounds per square inch gauge]

(2.5 Bar to 7 Bar) resulting in airflow between 450 and 750 liters per minute (lpm) as measured at the inlet. A regulator at the inlet automatically adjusts the airflow without user intervention to meet the desired operating range. To ensure user safety, the regulator cannot shut off the air supply. There are two (2) exhaust vents on the back, one (1) behind the neck and one (1) at the lower back. The exhaust vents have patented magnetic seals to prevent any intrusion of contaminants if supplied air is lost.

The Honeywell Mururoa suit is approved for use with different fittings in Europe and can be fitted with Schrader or Foster or CEJN-type fittings used at CEG facilities.

Regarding hose length, section 4.12.2 of the RG states, in part, that: Conditions of use to be described in the application would include the anticipated length of air supply hose (minimum and maximum) The NRC staff notes that the certificate for the Mururoa V4F1 suit does not prescribe a minimum or maximum hose length, but the licensee will determine a maximum hose length during its initial testing of the suit (see, table 1 below). Section 1.2 of the certificate for the Mururoa V4F1 R suit, specifies that the suit be connected to the breathable pressurized air supply system through a flow control valve with a STAUBLI or CEJN type fitting. As described in section 3.4 of this SE (see Table 1 below), the licensee stated that it would use the Mururoa V4F1 R suits with STAUBLI or CEJN fittings in accordance with the certificate. Therefore, the use of these suits with fittings other than STAUBLI or CEJN was not considered in the NRC staffs evaluation of the application.

The NRC staff noted that the licensee did not propose to use the Mururoa V4F1 R suits under conditions that would exceed the suits specifications. In particular, the licensee has not proposed to use the suits in IDLH environments or with uncertified fittings. Therefore, the NRC staff has reasonable assurance that the anticipated conditions for use of the Mururoa V4F1 R suits would be consistent with the suits specifications.

With respect to the testing of the Mururoa V4F1 R suit, section 2.1 of the application states that the licensee reviewed the documents included as enclosures to attachment 1 of the application:

A key element of this review was the application of the European Standard and the Certificate issued by IRSN (Institute for Nuclear Protection and Security) for the Mururoa suits. The European Standard (Enclosure 5.2) requires that the suit material be tested for resistance to abrasion, flex cracking, puncture, blocking, tear and flammability, strength of seams, joints and assemblies, damage resistance of exhaust valves, designed flow rates for pressure range of supplied air, noise level, and quality of the visor. According to the testing standard, three (3) workers were monitored performing standard exercises, each wearing two (2) different suits inside a chamber filled with a test agent (sodium chloride) and leakage was measured during the exercise regimen which lasted 20 minutes.

Operating parameters were set to manufacturers instructions. Standard exercises included walking on a treadmill at 2 mph [miles per hour] (3 minutes),

moving arms up and down above head while looking upward (3 minutes), and squatting continuously (3 minutes). To ensure workers comfort, two (2) additional practical exercises - walking at 2 mph (5 minutes) and loading a bucket with wood chips from the base of a hopper and emptying it into the opening on top (15 minutes) - were performed by two (2) workers at specified air flow rates.

By letter dated August 14, 2006, the NRC staff authorized the use of Mururoa V4F1 R suits with and APF of 5000 at ANO-2 and JAF. In the associated SE, the NRC staff accepted the testing and qualification conducted under European Standard EN 1073-1 as a basis for authorizing the use of the Mururoa V4F1 R suits. The NRC staff continues to find that such testing provides an adequate basis for characterizing the performance of the equipment and the proposed degree of protection under the anticipated conditions of use.

Based on the above, the NRC staff has determined that, in accordance with 10 CFR 20.1703(b),

the material and performance characteristics of the Mururoa V4F1 R suits are capable of providing the proposed degree of protection under the anticipated conditions of use.

3.2 Assigned Protection Factor Pursuant to 10 CFR 20.1705, the licensee requests NRC authorization to use an APF in excess of those specified in appendix A to 10 CFR part 20. This regulation requires the application to (a) describe the situation for which a need exists for higher protection factors; and (b) demonstrate that the respiratory protection equipment provides these higher protection factors under the proposed conditions of use.

Section 1.2.4 of the application, states, in part, that:

CEG currently uses other style Mururoa suits that have been approved for use by the NRC for work involving overhead contaminated water or high potential for skin contamination from discrete radioactive particles, and to prevent intake of airborne contaminants. Because the other style Mururoa suits used operate at a higher-pressure range with an adjustable valve, the V4F1 R supplied air suit offers the opportunity to use these suits with the same level of safety; however, with breathable network variability. The single suit construction and ease of removal provides protection against facial/skin contamination as well as airborne radioactivity. The tearable strips offer an effective method of suit removal and, therefore, minimize chances of cross-contamination during undressing/exit from contaminated areas. Approval of an APF of 5,000 for the Honeywell Mururoa V4F1 R supplied air suits would allow use of the suits to further enhance CEGs efforts to control contamination incidents and prevent intakes during operational activities at the other CEG facilities.

Additionally, section 1.2.4 of the application states: Similar to the other Mururoa suits in use, the Mururoa V4F1 R supplied air suit may be used for Steam Generator platform work, reactor cavity decontamination, control rod drive (CRD) exchange and equipment decontamination.

Therefore, the NRC staff finds that the application describes the situation for which a need exists for higher protection factors.

As a demonstration that the suit can provide the proposed APF of 5,000, the licensee stated in section 2.1 of its application that Certificate No. 0073/197/162/02/01/0005 (Enclosure 5.3) states that the Mururoa V4F1 R suit passed in all categories tested and provided a protection factor greater than 50,000.

As stated above, by letter dated August 14, 2006, the NRC staff authorized the use of Mururoa V4F1 R suits with an APF of 5,000 at ANO-2 and JAF. In the associated safety evaluation, the NRC staff accepted the testing and qualification conducted under European Standard EN 1073-1 as a basis for authorizing the use of the Mururoa V4F1 R suits. The NRC staff continues to find that such testing provides an adequate basis for characterizing the performance of the equipment and the proposed degree of protection under the anticipated conditions of use. Further, 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. Therefore, the NRC staff finds that the licensee has adequately demonstrated that the Mururoa V4F1 R suits will provide an APF of 5,000 under the proposed conditions of use.

Based on the above, the NRC staff finds an APF of 5,000 to be acceptable for the use of Mururoa V4F1 R suits at the CEG facilities 3.3 Respiratory Protection Program The regulations in 10 CFR 20.1703 specify the requirements for the use of respiratory protection equipment to limit the intake of radioactive material. As discussed in section 2.1 of this SE, the regulations in 10 CFR part 20, appendix A, state that atmosphere supplying suits 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.

The NRC staff reviewed the application to verify that there was reasonable assurance that the Mururoa V4F1 R suits could be used in the licensees respiratory protection programs in accordance with the applicable requirements of 10 CFR 20.1703. The NRC staffs review does not include a review or approval of the licensees respiratory protection programs. The NRCs Reactor Oversight Process provides for biennial NRC inspection of the licensees use of respiratory protection to limit the intake of radioactive materials.

Section 1.2.4 of the application states, in part, that the facilities have respiratory protection programs in full compliance with 10 CFR Part 20. The licensee also states that existing training and procedures would be revised to incorporate the changes needed to implement the use of the Mururoa V4F1 R suits at the licensees facilities. In addition, the licensee stated that workers using these suits would be in direct contact with radiation protection personnel or support personnel via audio headsets, remote monitoring, and camera observation.

As stated above, the regulation in 10 CFR 20.1703(f) requires, in part, that: Standby rescue persons are required whenever one-piece atmosphere-supplying suits, or any combination of supplied air respiratory protection device and personnel protective equipment are used from which an unaided individual would have difficulty extricating himself or herself. Section 1.2.1 of the application states, in part, that due to the advanced safety features for emergency breathing and emergency escape built into these suit models, CEG may choose to use the Mururoa V4F1 R supplied air suits without dedicated rescue personnel being assigned. The staff agrees that the suit design provides features such that it reasonable to conclude that it would not be difficult for an unaided individual to extricate himself or herself from the suit. In view of these statements, the NRC staff finds that the suit design, as described in section 3.1 of this SE, provides for easy and effective extrication, allowing for self-rescue to prevent asphyxiation if the air supply is interrupted or lost. Provided that an individual has adequate emergency escape training as described in section 3.4 of this SE, the NRC staff has reasonable assurance that standby rescue persons would not be required by 10 CFR 20.1703(f) when the Mururoa V4F1 R suit is used as described in the application.

Based on its review of the application, as summarized above, the NRC staff has reasonable assurance that the licensees respiratory protection programs would continue to meet the applicable requirements of 10 CFR 20.1703 when using the Mururoa V4F1 R suits as described in the application.

3.4 Table of Actions to Be Competed Prior To Use In Enclosure 2 of the application dated June 30, 2022, the licensee provided regulatory commitments that identify actions that CEG stated it will perform. The NRC staff considers these actions as conditions for approval to use the Mururoa V4F1 R air-supplied suit at the CEG facilities. Table 1 below provides a summary of the actions that shall be conducted in order to use the Mururoa V4F1 R suits.

Table 1: Summary of Required Actions REQUIRED ACTION DUE DATE The Mururoa V4F1 R suit will be integrated into CEG respiratory program using the information provided by the manufacturer.