NOC-AE-06002011, Request for Use of Delta Protection Mururoa Blu Single-Use Suits
| ML061590091 | |
| Person / Time | |
|---|---|
| Site: | South Texas  |
| Issue date: | 05/30/2006 |
| From: | Crenshaw J South Texas |
| To: | Document Control Desk, Office of Nuclear Reactor Regulation |
| References | |
| NOC-AE-06002011 | |
| Download: ML061590091 (9) | |
Text
Nuclear Operating Company South Texas P/ecd Ekct'ic Generating Station P.. Bar289 Hodua14 Thas 77483
-1_/_/_
May 30, 2006 NOC-AE-06002011 10CFR20.1703(b) 10CFR20.1705 U. S. Nuclear Regulatory Commission Attention: Document Control Desk One White Flint North 11555 Rockville, MD 20852-2738 South Texas Project Units 1 and 2 Docket Nos. STN 50-498, STN 50-499 Request for Use of Delta Protection Mururoa BLU Single-Use Suits Pursuant to the provision of 10 CFR 20.1703, "Use of Individual Respiratory Protection Equipment," and 10 CFR 20.1705, "Application for Use of Higher Assigned Protection Factors,"
STP Nuclear Operating Company (STPNOC) requests authorization to use the French-designed Delta Protection Mururoa BLU respiratory protection suits with an assigned protection factor (APF).
STPNOC has identified the Delta Protection Mururoa BLU self-fed single use suits as having benefits in contamination control, heat stress reduction, and respiratory protection. Pursuant to 10 CFR 20.1703(b), STPNOC must request authorization for use of equipment that has not been tested or certified by NIOSH, or for which there is no schedule for testing or certification.
Pursuant to 10 CFR 20.1705, STPNOC must obtain authorization from the Nuclear Regulatory Commission before using assigned protection factors in excess of those specified in Appendix A of 10 CFR 20. Because of the assigned protection factor (APF) of 2000 assigned to the suit, STPNOC needs approval for its use. Since these suits have no NIOSH approval for use as a respirator in the United States, STPNOC requests authorization for their use as respiratory protection equipment. Additionally, STPNOC has determined that 10 CFR 20.1703(f), which requires provision of standby rescue persons, is not applicable to the Mururoa BLU respiratory protection suits.
Attachment I provides the justification for this request. As described in the attachment, approval of the request will improve worker safety in areas of airborne radioactivity and high potential for facial/skin contamination from hot particles. In addition, the full body cooling effect will help solve heat stress concerns identified in past outages. This will result in improved worker comfort and productivity, as well as the reduction of personal contamination events.
STI: 32006010
-ADD
NOC-AE-06002011 Page 2 of 3 lists STPNOC's commitments contained in this letter.
Approval of this request will allow STPNOC to proceed with procedure changes and complete training necessary for the use of the Mururoa model BLU suit prior to our next refueling outage.
Therefore, STPNOC is requesting approval by August 1, 2006 in order to support use during the fall 2006 refueling outage.
If you have any questions regarding this submittal, please contact Mr. S. M. Head (361) 972-7136.
John W. Crenshaw General Manager, Oversight TCK Attachments: 1. Approval Request for the Use of Delta Protection Mururoa BLU Singe-use Encapsulating Suits.
- 2. List of Commitments
NOC-AE-06002011 Page 3 of 3 cc:
(paper copy) (electronic copy)
Regional Administrator, Region IV A. H. Gutterman, Esquire U. S. Nuclear Regulatory Commission Morgan, Lewis & Bockius LLP 611 Ryan Plaza Drive, Suite 400 Arlington, Texas 76011-8064 Mohan C. Thadani U. S. Nuclear Regulatory Commission Richard A. Ratliff Steve Winn Bureau of Radiation Control Christine Jacobs Texas Department of State Health Services Eddy Daniels 1100 West 49th Street NRG South Texas LP Austin, TX 78756-31.89 Senior Resident Inspector J. J. Nesrsta U. S. Nuclear Regulatory Commission R. K. Temple P. 0. Box 289, Mail Code: MN116 E. Alarcon Wadsworth, TX 77483 City Public Service C. M. Canady Jon C. Wood City of Austin Cox Smith Matthews Electric Utility Department 721 Barton Springs Road C. Kirksey Austin, TX 78704 City of Austin
Attachment 1 NOC-AE-06002011 Page 1 of 5 APPROVAL REQUEST FOR THE USE OF DELTA PROTECTION MURUROA BLU SINGLE-USE ENCAPSULATING SUIT
1.0 INTRODUCTION
1.1 PURPOSE 1.2 REGULATORY REQUIREMENTS 2.0 TECHNICAL JUSTIFICATION
2.1 BACKGROUND
2.2 IMPLEMENTATION
2.3 CONCLUSION
2.4 REFERENCES
Attachment I NOC-AE-06002011 Page 2 of 5
1.0 INTRODUCTION
1.1 PURPOSE STPNOC proposes the use of the Mururoa "fully enclosed suit" model BLU self-fed single use suit manufactured by Delta Protection, France. The purpose of this letter is to request approval for the use of the suits from Delta Protection and for authorization to use an APF of 2000 with the Mururoa suits. Because of the advanced safety features for emergency breathing and emergency escape built into these models, STPNOC notes that the Mururoa suits can be used without dedicated rescue personnel.
1.2 REGULATORY REQUIREMENTS The following regulatory requirements are relevant to this request.
10 CFR 20.1703(b) allows that if the licensee wishes to use 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.
10 CFR 20.1703(0 requires provision of standby rescue persons, whenever an unaided individual would have difficulty in exiting from an atmosphere-supplying suit.
10 CFR 20.1705, Application for Use of Higher Assigned Protection Factors, requires that the licensee obtain authorization from the Commission before using assigned protection factors in excess of those specified in Appendix A to Part 20.
Appendix A, Assigned Protection Factors lists as item II,Atmosphere supplying respirators (particulate, gases and vapors), Suit in a continuous flow operating mode, 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.,
2.0 TECHNICAL JUSTIFICATION
2.1 BACKGROUND
By letter dated October 27, 2005 (Ref. 6), Delta Protection, a member of the Bacou Dalloz group of personal safety equipment manufacture and supply companies, submitted a topical report (TR) concerning the BLU models of their Mururoa respiratory protection suits for Nuclear Regulatory Commission (NRC) review and approval. The TR covers two suit systems, the Mururoa BLU Ethyfuge, and the Mururoa BLU PVC. These suits differ only in the composition of the material with which the suit enclosures are made. The BLU model suits combine the powered air filtration feature of a powered-air-purifying respirator (PAPR) with the suit enclosure design of the Delta Protection Mururoa V4, supplied air suit systems.
The air purifying feature of the BLU models eliminates the need for a breathable air distribution system (external manifold, regulator, air line hose, etc.) associated with a supplied air suit system.
Attachment I NOC-AE-06002011 Page 3 of 5 Bacou Dalloz is a multi-national group of companies with extensive experience in the production and supply of occupational personal protective equipment. They have over 20 years of successful use with Mururoa style (and similar models) suits in European power plants. Their products must be certified to European Committee (EC) Standards, as established by the Institute for Nuclear Protection and Security (INPS), the European certifying agency comparable to the National Institute for Safety and Health (NIOSH).
The Delta Protection Mururoa BLU suits have a hybrid design for a respiratory protection device. The BLU design combines the powered air filtration of a PAPR with the suit enclosure design of the Delta Protection Mururoa V4 models of atmosphere-supplied suits.
The Mururoa BLU has an advantage over atmosphere-supplied suits since wearers' movements are not restricted by an air line hose. Also, eliminating the need to set up an air distribution system at the work site saves time and overall radiation exposure. However, because the suit supplies filtered ambient air to the wearer, they are only effective against particulate airborne contamination. In addition, the suits are designed to be used only in atmospheres containing specific contaminants in concentrations that are not immediately dangerous to life or health (IDLH) and which have an oxygen content of at least 19.5 percent by volume.
As part of the technical basis to support NRC approval, Delta Protection provided the European safety certifications of both the Mururoa BLU PVC and the Mururoa BLU Ethyfuge model suits. EC Type Examination Certificates were issued by the German certifying body, BIA, for the Mururoa BLU PVC model and the Mururoa BLU Ethyfuge model.
The EC Standards used to certify the Mururoa BLU models are generally consistent with the pertinent acceptance criteria provided in the Los Alamos National Laboratory Report used to test and authorize the use of air-supplied suits at U.S. Department of Energy sites and the proposed revised NIOSH standards for industrial PAPRs. Both models passed all required tests and both provided a measured average protection level (fit factor) of at least 20,000.
Given an overall measured fit factor of 20,000 (averaged over all exercise activities),
allowing an Assigned Protection Factor (APF) of 2,000 provides a conservative safety factor for estimating the actual protection provided to the user by the suit in the actual working environment.
The Mururoa BLU suits are constructed with the following design features common with other Mururoa models:
(1) Dual zippers (metal zipper inside and plastic zipper outside);
(2) 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 left arm, over the head, to the right arm that is used for undressing and for self-rescue in an emergency, such as loss of supplied air; (5) Dual magnetic exhaust valves that provide ventilation, and relief of excess pressure in case the suit is squeezed/pinched unexpectedly; (6) Air flow to hands, feet, face, and chest; (7) Low noise levels (less than 75 dB at maximum rated blower speed);
(8) Reinforced elbows, knees, and crotch areas.
In addition, the Mururoa BLU suits are fitted with a battery-powered Micronel Powered Air Purifying blower unit to provide air flow (optional rated settings of 600 I/min (20 cfm) or 400 I/min (14 cfm)) to the suit. A pocket, intemal to the suit, holds the blower with attached
Attachment I NOC-AE-06002011 Page 4 of 5 battery pack in the small of the wearer's back to minimize interference with suit movement.
This design minimizes contamination of the blowing unit and battery pack. Ambient air is drawn in and filtered through four external high-efficiency filters and distributed throughout the suit during use. The blower has an internal electronic controller to maintain the selected rated flow output. In the event of a defective controller, the blower unit fails safe to its maximum speed. Two warning alarms associated with the blower units signal the wearer to leave the work area and discontinue use of suit. A continuous tone, clearly audible to the wearer, is sounded within the suit on a low battery voltage condition. The unit is designed to alarm when there are 15 minutes of use remaining. An intermittent tone is sounded if the air flow rate drops below the rated setting. In the event of loss of air flow to the suit, the duel magnetic ventilation valves shut, keeping the suit inflated and providing breathable air to the wearer for several minutes. In addition, the wearer can easily extricate himself/herself by pulling off the mouth strip and then opening the hood, or pulling the egress strip from either forearm over the head toward the other forearm.
Based on these safety features the suit provides for easy and effective self-rescue, thus avoiding asphyxiation if the air flow is interrupted or lost. As a result of external radiation levels present in typical job sites, suit users are typically provided with radiological protection (RP) coverage (closed-circuit television or on-scene RP coverage, and continuous audio communication). This communication/coverage adds to the assistance available to the suit wearer, if needed. Due to these design features of the suit, coupled with required training of all suit users on escape methods, and limiting the use of the suits to non-IDLH atmospheres, the requirement for standby rescue personnel in Section 20.1703(f) is not applicable.
2.2 IMPLEMENTATION To implement the requirements identified in the Safety Evaluation STP commits to the following actions:
- 1. The Delta Protection Mururoa model BLU single use suits will be integrated into the STP respiratory program using the information provided by the manufacturer prior to use.
- 2. New lesson plans will be developed to train workers on BLU features, donning, use, removal, cautions and use of mouth strip and tear off strips for routine and emergency egress, as well as the maintenance of the "powered air purifying system" that forms an integral part of the product prior to use.
- 3. Radiation Protection personnel will be provided additional training for selection, approval, issue, equipment set-up, operation and maintenance instructions for the BLU suit prior to use.
- 4. Procedural guidance will be developed to ensure single use only (other than those segregated for training purposes only) and appropriate suit disposal after each use prior to use.
- 5. Procedural guidance will be established to ensure STPNOC-identified defects and usage problems are reported to the suit manufacturer prior to use.
Attachment 1 NOC-AE-06002011 Page 5 of 5
2.3 CONCLUSION
By letter dated April 10, 2006, the NRC issued a Safety Evaluation approving the use of both the Mururoa BLU PVC and the Mururoa BLU Ethyfuge model suits for use in accordance with the requirements of 10 CFR Part 20 (Ref. 7). Based on the Safety Evaluation and the commitments stated on the following page, STPNOC requests authorization to use the Mururoa BLU respiratory suits with an APF of 2000. Also based on the Safety Evaluation, STPNOC requests an exemption from 10 CFR 20.1703(f).
2.4 REFERENCES
- 1. 10 CFR 20.1703 Use of individual respiratory protection equipment.
- 2. 10 CFR 20.1705 Application of use of high assigned protection factors.
- 3. 10 CFR 20 Appendix A Assigned Protection Factors for Respirators
- 4. Regulatory Guide 8.15, Rev 1 Acceptable Programs for Respiratory Protection.
- 5. NUREG-0041 Manual of Respiratory Protection Against Airborne Radioactive Materials.
- 6. MURUBLU05NP, "Topical Report of Delta Protection Mururoa BLU Suit System".
- 7. Safety Evaluation by the Office of Nuclear Reactor Regulation for MURUBLU05NP, "Topical Report of Delta Protection Mururoa BLU Suit System", dated April 10, 2006.
G
Attachment 2 NOC-AE-06002011 Page I of I LIST OF COMMITMENTS The following table identifies the actions in this letter to which the STP Nuclear Operating Company has committed. Statements in this submittal with the exception of those in the table below are provided for information purposes and are not considered commitments. Please direct questions regarding these commitments to Philip Walker at (361) 972-8392.
Commitment Expected CR Action No completion time The Delta Protection Mururoa model BLU single use Prior to placing the CR 06-7098-1 suits will be integrated into the STP respiratory suit in service.
program using the information provided by the manufacturer.
New lesson plans will be developed to train workers Prior to placing the CR 06-7098-2 on BLU features, donning, use, removal, cautions suit in service.
and use of mouth strip and tear off strips for routine and emergency egress, as well as the maintenance of the "powered air purifying system" that forms an integral part of the product.
Radiation Protection personnel will be provided Prior to placing the CR 06-7098-3 additional training for selection, approval, issue, suit in service.
equipment set-up, operation and maintenance instructions for the BLU suit.
Procedural guidance will be developed to ensure Prior to placing the CR 06-7098-4 single use only (other than those segregated for suit in service.
training purposes only) and appropriate suit disposal after each use.
Procedural guidance will be established to ensure Prior to placing the CR 06-7098-5 STPNOC-identified defects and usage problems are suit in service.
reported to the suit manufacturer.