ULNRC-05334, Request for Authorization for Use of Delta Protection Mururoa Blu Single-Use Suits

Request for Authorization for Use of Delta Protection Mururoa Blu Single-Use Suits

ML062910238
Person / Time
Site:	Callaway
Issue date:	10/10/2006
From:	Keith Young AmerenUE, Union Electric Co
To:	Document Control Desk, Office of Nuclear Reactor Regulation
References
TAC MC8994, ULNRC-05334
Download: ML062910238 (6)

Text

V.

Union Electric P0 Box 620 CallawayPlant Fulton, M0 65251 October 10, 2006 U.S. Nuclear Regulatory Commission Attn: Document Control Desk Mail Stop PI-137 Washington, DC 20555-0001 Ladies and Gentlemen: ULNRC-05334 wAme/ren DOCKET NUMBER 50-483 UF CALLAWAY PLANT UNIT 1 UNION ELECTRIC CO.

FACILITY OPERATING LICENSE NPF-30 REQUEST FOR AUTHORIZATION 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," Union Electric Company (AmerenUE) requests authorization to use the French-designed Delta Protection Mururoa BLU respiratory protection suits described in "Topical Report of Delta Protection Mururoa BLU Suit System" (TR MURUBLU05NP).

AmerenUE commits to use the Delta Protection Mururoa BLU self-fed single-use suits consistent with "Topical Report of Delta Protection Mururoa BLU Suit System" (TR MURUBLU05NP) and to use the suits within the approved device configuration, limitations and conditions of use specified in Section 4.0 of the NRC Safety Evaluation dated April 10, 2006 for TR MURUBLU05NP (TAC NO. MC8994).

Approval of the request would 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 us eliminate concerns that have come up in the past outages regarding heat stress. This will result in reduced outage time, as well as the reduction of personal contamination events.

Enclosure I list AmerenUE's commitments supporting this request.

Ako a subsidiaryof Ameren Corporation

ULNRC-05334 October 10, 2006 Page 2 Authorization to use these suits will allow AmerenUE to proceed with procedure changes and complete training necessary for the use of the Mururoa BLU suits prior to our next refueling outage. Therefore, AmerenUE is requesting NRC approval by February 1, 2007 in order to support use during the spring 2007 refueling outage.

If you have any questions regarding this submittal, please contact Mr. Dave Shafer, Superintendent - Licensing at (314) 554-3104.

Sincerely,

., Keith D. Young Manager - Regulatory Affairs BFH/jdg

Enclosure:

1. List of Commitments

ULNRC-05334 October 10, 2006 Page 3 Mr. Bruce S. Mallett Regional Administrator U.S. Nuclear Regulatory Commission Region IV 611 Ryan Plaza Drive, Suite 400 Arlington, TX 76011-4005 Senior Resident Inspector Callaway Resident Office U.S. Nuclear Regulatory Commission 8201 NRC Road Steedman, MO 65077 Mr. Jack N. Donohew (2 copies)

Licensing Project Manager, Callaway Plant Office of Nuclear Reactor Regulation U. S. Nuclear Regulatory Commission Mail Stop O-7D 1 Washington, DC 20555-2738 Missouri Public Service Commission Governor Office Building 200 Madison Street PO Box 360 Jefferson City, MO 65102-0360 Mr. Ron Reynolds Director Missouri State Emergency Management Agency P.O. Box 116 Jefferson City, MO 65102

.4 ULNRC-5334 Enclosure 1 Page 1 of 2 LIST OF COMMITMENTS The following table identifies the actions necessary to fulfill the commitment made in this letter to use the Delta Protection Mururoa BLU self-fed single use suits consistent with "Topical Report of Delta Protection Mururoa BLU Suit System" (TR MURUBLU05NP) and to use the suits within the device configuration, limitations and conditions of use stated in the Safety Evaluation, dated April 10, 2006 (TAC No.

MC8994). Any other statements in this document are provided for information purposes and are not considered commitments. Please direct questions regarding these commitments to Mr. David E. Shafer at (314) 554-3104.

COMMITMENT Due Date/Evcnt The BLU suits will be used in a configuration consisting of: Prior to placing Mururoa BLU one-piece encapsulating suit (of either PVC or the suit in service.

Ethyfuge construction), fitted with a Micronel C500X-0I2EK-AB60 blower with a C501A-012AK-A battery (consistent with the parts list in Section 7 of Attachment 6.6.6 to the Topical Report TR MURUBLU05NP (ADAMS Accession No. ML053060280) four Scott PF 10 P3, or four Delta Protection P3, high efficiency particulate filter cartridges. All four filter cartridges must be matching and replaced as a set.

Procedures for use of the suit systems are integrated into the Prior to placing respiratory programs required by Subpart H of 10 CFR Part 20. the suit in service.

Fit testing of user is not applicable to fully encapsulating suits.

Prior to use, wearers are trained on these conditions of use as well as the emergency escape features of the suits.

Suits are used in accordance with recommendations in Prior to placing Attachments 6.6.4, 6.6.5, and 6.6.6 of the Topical Report TR the suit in service.

MURUBLU05NP (ADAMS Accession No. ML053060280)

Suit enclosures are single use only, (other than those segregated Prior to placing for training purposes only) and are discarded after use. Unused the suit in service.

suit enclosures are stored in their original manufacturer's packing (in an environment not colder than 32 deg. F, nor hotter than 140 deg. F), with a maximum storage shelf-life of 3 years. Suits are not to come in contact with anything colder than 41 deg. F, nor hotter than 140 deg. F, during use.

-SI ;%

ULNRC-05334 Enclosure 1 Page 2 of 2 Suits are donned with a fully charged battery pack installed on the Prior to placing blower. The maximum period of use (timed from a fully charged the suit in service.

battery), is 4 hours4.62963e-5 days <br />0.00111 hours <br />6.613757e-6 weeks <br />1.522e-6 months <br /> with the blower set at 600 I/min; and 7 hours8.101852e-5 days <br />0.00194 hours <br />1.157407e-5 weeks <br />2.6635e-6 months <br /> with the blower at the 400 I/min setting.

Suits are used only in atmospheres containing specific Prior to placing contaminants in concentrations that are not immediately the suit in service.

dangerous to life or health (IDLH), as given in NIOSH "Concept for Industrial Power, Air-purifying Respiratory Standard", Draft for Comment, May 30, 2005 (http://vwwv.cdc.gov/niosh/npptl/standardsdev.html), and have an oxygen content of at least 19.5 percent by volume.

Communication channels are established with Delta Protection to Prior to placing report any defects experienced with the device, and ensure that the suit in service.

any manufacturer's notifications concerning the suit systems are received in a timely manner.

The following elements and controls found in Section 6.4 of Prior to placing Topical Report TR MURUBLU05NP will be incorporated into the suit in service Callaway's respiratory protection program:

1. The Mururoa BLU self fed suits will be integrated into the respiratory protection program, using the information provided by the manufacturer.

2. New lesson plans will be developed to train workers on Mururoa BLU's features, donning, use and removal, cautions and use of mouth strips and tear off strips for routine and emergency egress.

3. Provide training to Radiation Protection personnel on selection, approval, issue, equipment set-up, operation and maintenance instructions for Mururoa BLU suits.

• 'a COMMITMENT REVISION, INITIATION, DELETION REQUEST (CRIDR)

~ ..ORIGINATOR.

1. Check the appropriate request: El Revision 0 Initiation [] Deletion

2. Name (print) Brian Holderness 3. Date 09/26/2006

4. Commitment No. .. (RRA will enter this in case of initiation)

5. Source document, section, and date ULNRC-05334

6. Reference documents, sections, and dates (use attachments if necessary)

7. Justification for revision, initiation, or deletion: (attach additional pages as required)

This letter identifies commitment to the NRC on actions AmerenUE will completed prior to use of the Delta suits once they are approved for use at Callaway.

CRITERIA FOR A COMMITMENT

8. Place an 'x' by any of the following items that apply to the commitment text (initiation and revision only):

a) Z It is a written promise by AmerenUE - Callaway Plant to the NRC to perform an action by a given date.

b) F1 It is a written promise by AmerenUE - Callaway Plant to another regulatory agency to perform an action by a given date.

c) n It is a written promise by AmerenUE - Callaway Plant to another entity to perform an action by a given date.

If none of the items can be marked, this text may not represent a commitment. In this case, contact RRA for further directions.

9. Action Documents various 10. Recommended Responsible Person(s) Johann Geyer

11. Approving Manager * /O/Z 0,/e.

Forward CRIDR package'to RRA

12. Commitment coordinator 13. Date Entered CTS Instructions 1.-3. Self explanatory

4. Enter the number of the commitment being revised or deleted.

5. Enter the title of the source document, the section of the source document that contains the commitment text, and the date the document was issued. The source document is the document in which AmerenUE commits an action to outside organizations.

6. Enter the title of the source documents, the sections containing the reference text, and the date the documents were issued. Reference documents are any documents that contain redundant, similar, or supporting information with respect to the source text.

7. Enter the reason for revising, initiating, or deleting this commitment.

8. Select the applicable choice. If none apply, this may not be a commitment, but an obligation.

9. Enter document(s) which satisfy the commitment (if known).

10. Enter responsible person(s) (if known).

11. Signature of the Approving manager Rturn CIUDR to RRA Z170.0050 Page I of I CA1571 08/04/03 APA-ZZ-00540