ML061320253

Brunswick, Units 1 & 2, Crystal River Unit 3, Shearon Harris Unit 1, H. B. Robinson Unit 2; Application for Authorized Use of Delta Protection Mururoa Single Use, Supplied-Air Suits, Models V4 F1 and V4 MTH2

ML061320253
Person / Time
Site:	Harris, Brunswick, Crystal River, Robinson
Issue date:	05/01/2006
From:	Burton C Progress Energy Co
To:	Reyes L A Document Control Desk, Office of Nuclear Reactor Regulation
References
PE&RAS-05-066
Download: ML061320253 (61)

Text

4 10 CFR 20.1703(b) tj Progress Energy 10 CFR 20.1705 PO Box 1551 411 Fayetteville Street Mall Raleigh NC 27602 Serial: PE&RAS-05-066 May 1, 2006 ATTENTION:

Mr. Luis A Reyes, Executive Director for Operations Document Control Desk United States Nuclear Regulatory Commission Washington, DC 20555-0001 BRUNSWICK STEAM ELECTRIC PLANT, UNIT NOS. 1 AND 2 DOCKET NOS. 50-325 AND 50-324 / LICENSE NOS. DPR-71 AND DPR-62 CRYSTAL RIVER UNIT 3 NUCLEAR GENERATING PLANT DOCKET NO. 50-302 / LICENSE NO. DPR-72 SHEARON HARRIS NUCLEAR POWER PLANT, UNIT NO. 1 DOCKET NO. 50-400 / LICENSE NO. NPF-63 H. B. ROBINSON STEAM ELECTRIC PLANT, UNIT NO. 2 DOCKET NO. 50-261 / LICENSE NO. DPR-23 APPLICATION FOR AUTHORIZED USE OF DELTA PROTECTION MURUROA SINGLE-USE, SUPPLIED-AIR SUITS. MODELS V4 F1 and V4 MTH2 Ladies and Gentlemen:

Pursuant to 10 CFR 20.1703(b), Carolina Power & Light Company, now doing business as Progress Energy Carolinas, Inc. (PEC), and Florida Power Corporation, now doing business as Progress Energy Florida, Inc. (PEF), hereby apply for authorized use of Delta Protection Mururoa single-use, supplied-air suits (Models V4 FI and V4 MTH2) to provide respiratory protection for persons working in areas of airborne radioactivity.

Pursuant to 10 CFR 20.1705, Carolina Power & Light Company and Florida Power Corporation also request authorization to use an assigned protection factor of 5000 for this equipment.

Based on the safety features built into this equipment, Carolina Power & Light Company and Florida Power Corporation propose to use this equipment without the standby rescue persons described by 10 CFR 20.1703(f).

Information necessary to support the requested authorization is attached and includes a list of associated Regulatory Commitments.

Approval of this application is requested by July 31, 2006.Please contact me at (919) 546-6901 if you need additional information.

Sincerely, Chris Burton Manager -Performance Evaluation

& Regulatory Affairs HAS Attachment

.-,j ool Enclosure United States Nuclear Regulatory Commission PE&RAS-05-066 Page 2 C: W. D. Travers, Regional Administrator

-Region II USNRC Resident Inspector

-BSEP, Unit Nos. 1 and 2 USNRC Resident Inspector

-CR3 USNRC Resident Inspector

-SHNPP, Unit No. 1 USNRC Resident Inspector

-HBRSEP, Unit No. 2 B. L. Mozafari, NRR Project Manager -BSEP, Unit Nos. 1 and 2; CR3 C. P. Patel, NRR Project Manager -SHNPP, Unit No. 1; HBRSEP, Unit No. 2 J. A. Sanford -North Carolina Utilities Commission R. Vance -North Carolina Utilities Commission S. Watson -North Carolina Utilities Commission B. Hall -North Carolina Department of Environmental and Natural Resources United States Nuclear Regulatory Commission Attachment to PE&RAS-05-066 Page 1 of 22 INFORMATION TO SUPPORT APPLICATION FOR AUTHORIZED USE OF DELTA PROTECTION MURUROA SINGLE-USE, SUPPLIED-AIR SUITS, MODELS V4 F1 AND V4 MTH2 BRUNSWICK STEAM ELECTRIC PLANT, UNIT NOS. 1 AND 2 DOCKET NOS. 50-325 AND 50-324 / LICENSE NOS. DPR-71 AND DPR-62 CRYSTAL RIVER UNIT 3 NUCLEAR GENERATING PLANT DOCKET NO. 50-302 / LICENSE NO. DPR-72 SHEARON HARRIS NUCLEAR POWER PLANT, UNIT NO. 1 DOCKET NO. 50-400 / LICENSE NO. NPF-63 H. B. ROBINSON STEAM ELECTRIC PLANT, UNIT NO. 2 DOCKET NO. 50-261 / LICENSE NO. DPR-23 United States Nuclear Regulatory Commission Attachment to PE&RAS-05-066 Page 2 of 22 Information to Support Application for Authorized Use of Delta Protection Mururoa Single-Use.

Supplied-Air Suits, Models V4 Fl and V4 MTH2

1.0 INTRODUCTION

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3

2.0 REGULATORY EVALUATION

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4 3.0 TECHNICAL JUSTIFICATION

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5 3.1 Explanation Of Why Existing NIOSH-Certified Equipment Does Not Meet Identified Need ............

5 3.2 Material And Performance Characteristics Relative To Anticipated Condition Of Use ....................

..6 3.2.1 Test Information For Certification By The Institute Of Nuclear Protection And Security .......7 3.2.2 Supplemental Test Information On Protection Factor Determined During Fit Test ................

8 3.2.3 Test Information Provided by Duke ..........................................................................

8 3.2.4 Test Information Provided by Entergy .........................................................................

9 3.2.5 Anticipated Conditions of Use ........................

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9 3.3 Safety Features That Obviate The Need For A Standby Rescue Person ................

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9 3.4 Use Of Higher Assigned Protection Factor ........................................................................

10 3.4.1 Need For The Higher Protection Factor ........................................................................

10 3.4.2 Demonstration Of The Higher Protection Factor Under Proposed Conditions Of Use ...........

11 3.5 Implementation And Maintenance Of The Respiratory Protection Program ......................................

12 3.5.1 Written Procedures Regarding Supervision And Training Of Respirator Users ......................

12 3.5.2 Written Procedures Regarding Respirator Selection

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12 3.5.3 Written Procedures Regarding Storage, Issuance, Maintenance, Repair, Testing, And Quality Assurance Of Respiratory Protection Equipment

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13 3.6 Respirator Problem Identification And Communication

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14 3.7 Conclusions

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14

4.0 REFERENCES

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16 Table 1 -List of Regulatory Commitments

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18 Enclosure 1 -Delta Protection, Mururoa V4 Fully Enclosed Suit, "General Description" Enclosure 2 -EC Type Examination Certificate Number 0073 / 197/162/01

/96/ 0001, Delta Protection Mururoa V4 MTH2 Enclosure 3 -EC Type Examination Certificate Number 0073 / 197 /162 / 12 / 97/ 0028, Delta Protection Mururoa V4 FI Enclosure 4 -Delta Protection, Mururoa V4 MTH2, Supplemental Test Results Enclosure 5 -Delta Protection, Mururoa V4 Fl, Supplemental Test Results Enclosure 6 -Delta Protection, Mururoa V4 MTH2 And V4 Fl, "Instructions For Use" United States Nuclear Regulatory Commission Attachment to PE&RAS-05-066 Page 3 of 22 Information to Support Application for Authorized Use of Delta Protection Mururoa Single-Use.

Supplied-Air Suits. Models V4 Fl and V4 MTH2

1.0 INTRODUCTION

Carolina Power & Light Company, now doing business as Progress Energy Carolinas, Inc. (PEC), and Florida Power Corporation, now doing business as Progress Energy Florida, Inc. (PEF), have become aware of the advantages in the respiratory protection afforded by the use of Delta Protection Mururoa single-use, supplied-air suits (Models V4 F1 and V4 MTH2) (subsequently, "this equipment")

to persons working in areas of airborne radioactivity.

From an evaluation of the applicable regulations, Carolina Power & Light Company and Florida Power Corporation conclude that an application to the Nuclear Regulatory Commission (NRC) for authorized use of this equipment is necessary.

The application for authorized use of this equipment requires a request for the authorized use of an assigned protection factor for this equipment.

The scope of the regulatory evaluation includes consideration of the need for a standby rescue person.The NRC has found similar proposals from other licensees to be acceptable, as documented in the following referenced Safety Evaluations:

• Duke Energy Corporation (Duke) (Reference 15),* Florida Power & Light Company and FPL Energy Seabrook (collectively, FPL) (Reference 16),* Union Electric Company (AmerenUE) (Reference 17),* Pacific Gas and Electric Company (PG&E) (Reference 18), and* Constellation Energy Generation Group (Constellation) (Reference 19).In providing the technical justification for this application, Carolina Power & Light Company and Florida Power Corporation cite previously docketed information as applicable for concluding that this equipment should be authorized for use with the requested assigned protection factor but without the need for a standby rescue person.Carolina Power & Light Company and Florida Power Corporation anticipate using this equipment within a viable, ongoing respiratory protection program at the following plants: Brunswick Steam Electric Plant, Unit Nos. 1 and 2 Docket Nos. 50-325 and 50-324 / License Nos. DPR-71 and DPR-62 Crystal River Unit 3 Nuclear Generating Plant Docket No. 50-302 / License No. DPR-72 Shearon Harris Nuclear Power Plant, Unit No. 1 Docket No. 50-400 / License No. NPF-63 H. B. Robinson Steam Electric Plant, Unit No. 2 Docket No. 50-261 / License No. DPR-23 To meet regulatory requirements for use of this equipment, Carolina Power & Light Company and Florida Power Corporation propose to change certain aspects of the respiratory protection program.These proposed actions are captured in associated Regulatory Commitments.

United States Nuclear Regulatory Commission Attachment to PE&RAS-05-066 Page 4 of 22 Information to Support Application for Authorized Use of Delta Protection Mururoa Single-Use.

Supplied-Air Suits, Models V4 FI and V4 MTH2

2.0 REGULATORY EVALUATION

Title 10 of the Code of Federal Regulations (10 CFR) Part 20, "Standards for Protection Against Radiation," Subpart H, "Respiratory Protection and Controls to Restrict Internal Exposure in Restricted Areas," concerns the use of respiratory protection equipment for protections against airborne radioactive materials.

Section 20.1703, "Use of individual respiratory protection equipment," paragraph (a), requires that respiratory protection equipment used by a licensee to limit the intake of radioactive material be tested and certified by the National Institute for Occupational Safety and Health (NIOSH). Section 20.1703(b) states that a licensee can submit an application to the NRC for authorized use of respiratory protection equipment that has not been tested and certified by NIOSH.Appendix A to Part 20, "Assigned Protection Factors for Respirators," does not provide an assigned protection factor (APF) for atmosphere supplying respirator suits in a continuous-flow operating mode.Instead, it references footnote (g) that 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)." Section 20.1705, "Application for use of higher assigned protection factors," states that a licensee shall obtain NRC authorization before using assigned protection factors in excess of those specified in Appendix A to Part 20. The application is required to describe the situation for which a need exists for higher protection factors and to demonstrate that the respiratory protection equipment provides these higher protection factors under the proposed conditions of use.Therefore, based on the above requirements, Carolina Power & Light Company and Florida Power Corporation must obtain approval for the use of this equipment and for the associated use of an assigned protection factor.Section 20.1703(f) requires that standby rescue personnel be provided whenever respiratory protection equipment from which an unaided individual would have difficulty extricating himself or herself is used.Other sources of criteria and background information considered during preparation of the technical justification include: 1. 10 CFR 19.12, "Instruction to workers;" 2. 29 CFR 1910.134 (b), "Respiratory protection," "Definitions;" 3. 42 CFR 84, "Approval of Respiratory Protection Devices;" 4. Regulatory Guide 8.15, Revision 1, "Acceptable Programs for Respiratory Protection;" 5. NUREG/CR-0041, Revision 1, "Manual of Respiratory Protection Against Airborne Radioactive Material;" and 6. Department of Health and Human Services (NIOSH) Publication 87-116, "NIOSH Guide To Industrial Respiratory Protection."

United States Nuclear Regulatory Commission Attachment to PE&RAS-05-066 Page 5 of 22 Information to Support Application for Authorized Use of Delta Protection Mururoa Single-Use.

Supplied-Air Suits. Models V4 Fl and V4 MTH2 3.0 TECHNICAL JUSTIFICATION According to the guidance provided in Section 4.12.1 of Regulatory Guide 8.15, the NRC believes that, in certain nuclear industry applications, supplied-air suits might be the best overall choice, taking into account respiratory protection, contamination control considerations, heat stress, and ALARA. NRC guidance provided in Section 4.10.3 of NUREG/CR-0041 encourages the use of air-supplied suits, noting that in certain nuclear industry applications (e.g., control-rod drive removal at boiling water reactors) these suits may be the best overall choice when taking into account respiratory protection, contamination control considerations, heat stress, and trying to maintain worker doses as low as reasonably achievable (ALARA).3.1 Explanation Of Why Existing NIOSH-Certified Equipment Does Not Meet Identified Need According to the guidance in Section 4.2 of Regulatory Guide 8.15, an application to use a noncertifled device should explain why no existing NIOSH-certifled device meets the licensee 's need.Carolina Power & Light Company and Florida Power Corporation have identified a need for a respiratory protection device that is not NIOSH-certified.

In particular, Carolina Power & Light Company and Florida Power Corporation believe there are advantages in the respiratory protection afforded by the use of Delta Protection Mururoa single-use, supplied-air suits (Models V4 F1 and V4 MTH2) to persons working in areas of airborne radioactivity.

Carolina Power & Light Company and Florida Power Corporation are interested in both models because of supply chain flexibility considerations.

As described below, the advantages of this equipment over existing NIOSH-certified devices have been previously documented in similar requests from other licensees.

In the Duke request (Reference 10), the advantages included improved worker safety in areas of airborne radioactivity and high potential for facial/skin contamination from hot particles.

This equipment was described in Section 2.1 as providing better worker protection than the currently approved bubble hood and rain suit combination.

The elimination of the standby rescue person permitted by the self-rescue capability of this equipment was described in Section 2.3.6 of the Duke request as an ALARA consideration.

The unitized construction and ease of removal was credited in Section 2.3.6 of the Duke request as providing a better alternative with regard to possible cross contamination during undressing/exit from contaminated areas.In the request (Reference

11) from Entergy Operations, Inc. (Entergy), the benefits were cited from a contamination control, heat stress reduction, and respiratory protection point of view. The Entergy request only addressed Model V4 MTH2. Section 1.2.4 of the Entergy request described the possibility of cross contamination using air supplied hoods (i.e., bubble hoods) and credited the unitized construction and ease of removal of the requested equipment as providing a better alternative for protecting the worker from facial/skin contamination and airborne radioactivity.

Section 3.0 of the Entergy request described the cooling provided by existing rain suits and bubble hoods as being limited to the head, whereas Section 1.2.2 described air flow for the requested equipment through manifolds to the chest, hands, and feet with two vents near the chin for cooling the face.

United States Nuclear Regulatory Commission Attachment to PE&RAS-05-066 Page 6 of 22 Information to Support Application for Authorized Use of Delta Protection Mururoa Single-Use.

Supplied-Air Suits. Models V4 F1 and V4 MTH2 In Section 2.1.1 of the FPL request (Reference 12), the high probability of cross contamination during undressing/exit from contaminated area using bubble hoods was described.

FPL credited the unitized construction and ease of removal of this equipment as providing a better alternative for protecting the worker from facial/skin contamination and airborne radioactivity.

The AmerenUE request (Reference

13) also cited improved worker safety in areas of airborne radioactivity and high potential for facial/skin contamination from hot particles.

Ease of removal of the requested equipment was identified in Section 2.3.3 of the AmerenUE request as providing a means of undressing that minimizes the potential for personnel contamination events. AmerenUE also credited the full body cooling effect with helping to eliminate previous concerns regarding heat stress. Section 2.3.3 of the AmerenUE request described the cooling provided by existing rain suits and bubble hoods as limited to the head, whereas Section 2.3.1 described air flow for this equipment through manifolds to the chest, hands, and feet with two additional vents near the chin on Model V4 MTH2 for cooling the face.3.2 Material And Performance Characteristics Relative To Anticipated Condition Of Use Pursuant to 10 CFR 20.1703 (b), the application must include evidence that the material and performance characteristics of the equipment are capable ofproviding the proposed degree of protection under anticipated conditions of use. Section 20.1703 (b) further states that this must be demonstrated either by licensee testing or on the basis of reliable test information.

According to the guidance provided by Section 4.2 of Regulatory Guide 8.15, an application to use a noncertified device should also show that using the device as proposed will not subject the wearer to undue physical or psychological stress or undue hazard. The guidance in Section 4.2 of Regulatory Guide 8.15 further states that, when the NRC has granted authorization to use such a device to one licensee, subsequent applications by additional licensees may make use of test information in that original submittal The material and performance characteristics of this equipment, as described in the enclosed supporting information by either the manufacturer or the European testing and certifying agency, consist of: 1. one piece single-use suit that includes welded gloves and overboots with strengthened soles and binding ties;2. fire proof tested to Norms EN 1146 paragraph 7.5.3;3. made of Polyvinyl Chloride (PVC) or polyethylene (Ethyfuge) with reinforced elbows, knees and crotch areas;4. dual zippers -metal zipper for strength and PVC zipper for air and gas tightness;

5. a supple transparent PVC helmet with a transparent distortion free face plate giving almost the same optical quality as glass;6. a welded sleeve for communication cable;7. a removable strip near the mouth that could be used for emergency breathing in case of loss of supplied air; United States Nuclear Regulatory Commission Attachment to PE&RAS-05-066 Page 7 of 22 Information to Support Application for Authorized Use of Delta Protection Mururoa Single-Use, Supplied-Air Suits, Models V4 F1 and V4 MTH2 8. an quick release egress strip stretching from forearm, overhead to forearm that is used both for undressing and for self-rescue in an emergency, such as loss of supplied air;9. an airflow control valve to adjust, but not block, the air flow;10. two exhaust valves that provide an airtight seal during activities inducing under pressure and that regulate the overpressure;

11. a silencer bag to attenuate the noise level; and 12. a manifold system welded to the suit and distributing the air to the helmet, the legs, and the arms.According to the manufacturer, this equipment has been widely used in western European nuclear power plants for more than 20 years, without any major problem. Reportedly, 60,000 of these garments are used each year in France.Carolina Power & Light Company and Florida Power Corporation anticipate using this equipment within a viable, ongoing respiratory protection program, consistent with the conditions for which it was certified, and in accordance with the manufacturer's "Instructions For Use" (Enclosure 6).3.2.1 Test Information For Certification By The Institute Of Nuclear Protection And Security The material and performance of this equipment have been tested and certified by the Institute of Nuclear Protection and Security.

The essential requirements reference was European Standard CEN/TC 162 N 738, "Protective Clothing Against Radioactive Contamination," (November 1995 and July 1997 for Model V4 MTH2 and Model V4 Fl, respectively).

The resultant EC Type Examination Certificates are: No. 0073/197/162/01/96/0001, issued for Mururoa Model V4 MTH2 on January 10, 1996, and No. 0073/197/162/12/97/0028, issued for Mururoa Model V4 FI on December 10, 1997.These certificates are enclosed as Enclosure 2 and Enclosure 3 for Model V4 MTH2 and Model V4 F1, respectively.

Specific results were presented for: abrasion resistance, puncture resistance, tear resistance, flammability, inward leakage average-Fit Factor, seam resistance, vision distortion, pressure in suit, carbon dioxide content in inhalation air, and noise level. The conclusions were: MURUROA V4 MTH2: Upon presentation of the test results, the ventilated suit-pressurized for a single use only, MTH2 -ref. 841 442 T is certified to ensure a protection against radioactive contamination according to the following specified limits:-Minimum air flow rate: 30 m 3/h (500 1/min)-Maximum air flow rate: 66 m 3/h (1100 I/min)MURUROA V4 Fl: Upon presentation of the test results, the ventilated suit-pressurized for a single use only, MURUROA V4 F1 -ref. 8481XiT is certified to ensure a protection against radioactive contamination according to the following specified limits:-Minimum air flow rate: 27 m 3/h-Maximum air flow rate: 64.2 m 3/h United States Nuclear Regulatory Commission Attachment to PE&RAS-05-066 Page 8 of 22 Information to Support Application for Authorized Use of Delta Protection Mururoa Single-Use.

Supplied-Air Suits, Models V4 Fl and V4 MTH2 The MURUROA V4 FI is delivered without low air flow rate indicator.

Before using it, the user will have at his disposal the necessary devices to check that the minimum air flow rate, as specified by the manufacturer is reached or over reached before and during the use of the suit.As a clarification, neither model is delivered with a low air flow rate indicator.

Further, Carolina Power & Light Company and Florida Power Corporation do not intend to provide the user with a device to check for the minimum air flow rate, contrary to the statement in the Conclusion section of the Certificate for the Mururoa Model V4 Fl. Instead, Carolina Power & Light Company and Florida Power Corporation propose to regulate the air supplied from the distribution manifold such that the air supplied to the suit inlet is consistent with the conditions for which this equipment was certified.

As proposed, the regulation of the air supply for this equipment would to be operationally similar to the existing practice for NIOSH-certified equipment.

3.2.2 Supplemental

Test Information On Protection Factor Determined During Fit Test The manufacturer supplemented the test information documented in the EC Type Examination Certificates with more detailed test results on the protection factor determined during the fit test.That information comprised:

1. The minimum and maximum air flow entering the suit, corresponding to valve closed/full open, 2. Carbon dioxide content of inhalation air measured at minimum air flow, 3. Noise level with air supply at maximum flow, 4. Inward leakage average -Fit factor measured at minimum air flow for various exercises, and 5. Maximum and minimum pressure in suit at maximum air flow for various exercises.

Test information was provided for two Mururoa Model V4 MTH2 suits and three Mururoa Model V4 F1 suits. For Mururoa Model V4 MTH2, information was also provided for a test on overpressure and fit factor of a person crawling and for a distortion and mechanical resistance test of the screen. For Mururoa Model V4 Fl, information was also provided from a pull test on the connection with the air supply.The supplemental test results are enclosed, Enclosure 4 and Enclosure 5, for Mururoa Model V4 MTH2 and for Mururoa Model V4 FI, respectively.

3.2.3 Test Information Provided by Duke Sections 2.3.3 and 2.3.4 of the Duke request (Reference

10) described in-house tests conducted to evaluate worker comfort, ease of use, visibility and safe operation for Mururoa Model V4 F1 and Mururoa Model V4 MTH2, respectively.

These tests also included a practical demonstration of the ability of the worker to remove the safety strip near the mouth and, in one test, to rip open the suit to breathe without difficulty or discomfort.

No physical or psychological stress or hazard was identified.

Duke supplemented the information provided in the initial request with a letter (Reference 14)containing additional test information on the determination of overall fit factors, calculated per ANSI Z88.2-1980, over a range of flow rates and for various exercises.

United States Nuclear Regulatory Commission Attachment to PE&RAS-05-066 Page 9 of 22 Information to Support Application for Authorized Use of Delta Protection Mururoa Single-Use.

Supplied-Air Suits. Models V4 F1 and V4 MTH2 3.2.4 Test Information Provided by Entergy Section 2.1 of the Entergy request (Reference

11) reported that in-house inspection and demonstration of the suits were conducted.

This inspection/demonstration indicated that Mururoa suits are an improvement due to the associated ease in donning and doffing.3.2.5 Anticipated Conditions of Use Single-Use Only This equipment is intended for single-use only (i.e., disposed of after one use).Radiological Contamination/Airborne Radioactivity This equipment is intended for use in areas of high radiological contamination and/or areas with high airborne radioactivity.

Work in these areas may include, but is not limited to: steam generator platform work, reactor head work, cavity decontamination, and control rod drive work.Not in Environments Immediately Dangerous To Life and Health (IDLHW This equipment is not intended for use in environments that are immediately dangerous to life and health (IDLH), as defined in 29 CFR 1910.134 (b) and as clarified in the guidance in Section 6.8 of Regulatory Guide 8.15 for the resolution of minor difference between NRC and OSHA respiratory protection requirements.

As defined in 29 CFR 1910.134 (b): Immediately dangerous to life or health (IDLH) means an atmosphere that poses an immediate threat to life, would cause irreversible adverse health effects, or would impair an individual's ability to escape from a dangerous atmosphere.

According to the guidance provided in Section 6.8 of Regulatory Guide 8.15, the term IDLH does not realistically apply to airborne radioactivity but could apply to certain nonradiological hazards at an NRC-licensed facility, in which case OSHA rules apply. Such nonradiological hazards include oxygen-deficient environments (e.g., inerted structures and vessels), chemical hazards (e.g., chlorine, hydrazine), and fire fighting.3.3 Safety Features That Obviate The Need For A Standby Rescue Person Pursuant to 10 CFR 20.1703 (f), 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 usedfrom which an unaided individual would have difficulty extricating himself or herself Based on the safety features built into this equipment, Carolina Power & Light Company and Florida Power Corporation propose to use this equipment without the standby rescue persons described by 10 CFR 20.1703(f).

The NRC has found similar proposals from other licensees to be acceptable, as documented in Safety Evaluations (References 15, 16, 17, 18, and 19 for Duke, FPL, AmerenUE, PG&E, and Constellation, respectively).

United States Nuclear Regulatory Commission Attachment to PE&RAS-05-066 Page 10 of 22 Information to Support Application for Authorized Use of Delta Protection Mururoa Single-Use.

Supplied-Air Suits. Models V4 Fl and V4 MTH2 The relevant safety features which obviate the need for a standby rescue person include: 1. An egress strip stretching from left arm, over the head, to right arm that is normally used for undressing and can be used for self-rescue during an emergency, such as loss of supplied air;2. A removable strip covering an opening near the mouth that could be used for emergency breathing in case of loss of supplied air;3. Two exhaust valves that provide ventilation, and also protect from overpressure; and 4. Air intake located at the waist with a built-in control valve that can adjust, but not block, air flow.The "General Description" (Enclosure

1) and the "Instructions For Use" (Enclosure

6) provided by the manufacturer indicate that emergency egress takes less than 3 to 5 seconds while, in case of an air supply failure, this equipment remains pressurized for a few minutes.3.4 Use Of Higher Assigned Protection Factor Pursuant to 10 CFR 20.1705, a licensee is required to obtain authorization from the Commission before using assigned protection factors (APF) 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.According to the guidance provided in Section 4.12.2 of Regulatory Guide 8.15, if a licensee needs to apply for an APF to a supplied-air suit, the conditions of use to be described in the written 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 APFfor supplied-air suits.Carolina Power & Light Company and Florida Power Corporation request authorization to use an APF of 5000 for this equipment.

The NRC has found similar proposals from other licensees to be acceptable, as documented in Safety Evaluations (References 16, 17, 18, and 19 for FPL, AmerenUE, PG&E, and Constellation, respectively).

The certification process for this equipment did not include consideration for the length of air supply hose and breathing air supply pressure.

Section 3.4.2 describes an alternative to ensure that the air supplied to the suit inlet is consistent with the conditions for which this equipment was certified.

3.4.1 Need For The Higher Protection Factor Authorization to use a higher protection factor is requested because this type of equipment is listed under 11. 1 (i.e., atmosphere supplying respirators-air line respirator-suit) in Appendix A to 10 CFR Part 20 with no assigned protection factor.

United States Nuclear Regulatory Commission Attachment to PE&RAS-05-066 Page 11 of 22 Information to Support Application for Authorized Use of Delta Protection Mururoa Single-Use.

Supplied-Air Suits. Models V4 Fl and V4 MTH2 3.4.2 Demonstration Of The Higher Protection Factor Under Proposed Conditions Of Use As documented in Enclosures 2 and 3, this equipment was tested and certified for a fit factor of 50,000 based on European Standard CEN/TC 162 N 738. The manufacturer estimates the actual protection factor at approximately 100,000. Consequently, use of an assigned protection factor of 5000 is conservative.

However, the approach taken to establish the conditions for testing and certification under European Standard CEN/TC 162 N 738 is different from that taken by NIOSH. As described in Section 3.2.1, this equipment was certified for a range of air flow being supplied to the inlet of this equipment at about 85 psig. For the MURUROA V4 Fl, the certificate specifically concluded that the user will have a device to check for achieving the minimum air flow rate. In contrast, the NIOSH approach, as expressed in Section 4.18.2 of NUREG/CR-0041 for supplied-air respirators, is: "NIOSH approvals for [supplied-air respirators]

require that a minimum airflow be delivered to the respiratory inlet covering .... The certifications are written, however, so that the end user of the respiratory device is not required to measure the actual flow rate of air delivered to the device. Rather, an acceptable pressure range at the distribution manifold is specifiedfor a given length of hose, number of hose sections, or for a specified number of quick-connect fittings.

... Licensees are never required to measure the flow rate of air supplied to afacepiece or hood " As stated in Section 3.2.1, Carolina Power & Light Company and Florida Power Corporation do not intend to provide the user with a device to check for the minimum air flow rate, contrary to the statement in the Conclusion section of the Certificate for the Mururoa Model V4 Fl. Instead, Carolina Power & Light Company and Florida Power Corporation propose to regulate the air supplied from the distribution manifold such that the air supplied to the suit inlet is consistent with the conditions for which this equipment was certified.

As proposed, the regulation of the air supply for this equipment would be operationally similar to the existing practice for NIOSH-certified equipment currently in use.From practical standpoint, the maximum and minimum hose lengths and maximum and minimum air supply pressures for this equipment may be limited by the need to interface with existing respiratory protection equipment which is NIOSH-certified.

In Table 8, "Air Supply Line Requirements and Tests (42 CFR Part 84, Subpart J)," the maximum and minimum lengths of hose are listed as 300 feet and 25 feet, respectively, for NIOSH certification of Type "C" supplied-air respirators.

The maximum pressure would be limited to 125 psig at the inlet of the hose connection by 42 CFR 84.148 (b) for Type "C" supplied-air respirator, continuous flow class.To establish the conditions at the distribution manifold actually necessary to ensure that the air supplied to the suit inlet is consistent with the conditions for which this equipment was certified, Carolina Power & Light Company and Florida Power Corporation propose to conduct and document pressure drop tests of the various combinations of hose lengths and number and types of connections that are representative of those anticipated to be used. Carolina Power & Light Company and Florida Power Corporation propose to use the test results at a Carolina Power &Light Company or Florida Power Corporation plant at which the test was not conducted following a satisfactory review of the test and test results for applicability.

Carolina Power & Light Company United States Nuclear Regulatory Commission Attachment to PE&RAS-05-066 Page 12 of 22 Information to Support Application for Authorized Use of Delta Protection Mururoa Single-Use, Supplied-Air Suits. Models V4 Fl and V4 MTH2 and Florida Power Corporation further propose to incorporate, into the respiratory protection program, specific instructions for use of this equipment based on the test results. This proposal to test and document is identified as a Regulatory Commitment in Table 1.3.5 Implementation And Maintenance Of The Respiratory Protection Program According to Note g to Appendix A of 10 CFR 20, atmosphere supplying respirators-air line respirator-suits may be used in an acceptable respiratory protection program as long as all the other minimum program requirements, with the exception offit testing, are met (i. e., § 20.1703).Carolina Power & Light Company and Florida Power Corporation implement and maintain a viable, ongoing respiratory protection program pursuant to the requirements of 10 CFR 20.1703.Currently, the program only permits the use of respiratory protection equipment that has been tested and certified by NIOSH, pursuant to the requirements of 10 CFR 20.1703(a).

Subsequent to NRC authorization under 10 CFR 20.1703(b) to use this equipment and prior to actual first use, Carolina Power & Light Company and Florida Power Corporation propose to modify, consistent with the "Instructions For Use" (Enclosure

6) provided by the manufacturer for this equipment, the respiratory protection program as necessary to meet the minimum program requirements of 10 CFR 20.1703, with the exception of fit testing. This proposal is identified as a Regulatory Commitment in Table 1.Many elements of the respiratory protection program are generically applicable and will not require change. The following discussion addresses those elements of the respiratory protection program that will require change: 3.5.1 Written Procedures Regarding Supervision And Training Of Respirator Users Pursuant to 10 CFR 20.1703(c)(4)(ii) and the guidance provided in Section 4.12 of Regulatory Guide 8.15, Carolina Power & Light Company and Florida Power Corporation propose to revise or develop written lesson plans to train workers on the features of this equipment; how to don, use, and doff this equipment; and instructions on using the built-in escape strips for routine and emergency egress conditions.

The proposed training will include appropriate hands-on and classroom instruction.

Carolina Power & Light Company and Florida Power Corporation propose to conduct specific training on actions to be taken by the user in the event of equipment malfunction.

Carolina Power & Light Company and Florida Power Corporation further propose to provide appropriate training to personnel responsible for implementation of the respiratory protection program to assist in selection, issuance, set-up, and operation of this equipment.

3.5.2 Written

Procedures Regarding Respirator Selection Pursuant to 10 CFR 20.1703(c)(4)(iv) and the guidance provided in Section 4.12 of Regulatory Guide 8.15, Carolina Power & Light Company and Florida Power Corporation propose to revise or develop written procedures within the Plant Operating Manual to provide guidance on respirator selection.

In particular, written guidance is proposed to include: 1. The equipment is designated for a single-use (to be discarded after one use).

United States Nuclear Regulatory Commission Attachment to PE&RAS-05-066 Page 13 of 22 Information to Support Application for Authorized Use of Delta Protection Mururoa Single-Use, Supplied-Air Suits, Models V4 Fl and V4 MTH2 2. This equipment is not intended for use in environments that are immediately dangerous to life and health (IDLH), such as oxygen-deficient environments (e.g., inerted structures and vessels), chemical hazards (e.g., chlorine, hydrazine), and fire fighting.

Contact with open flames or grinding/welding sparks is prohibited.

3. The assigned protection factor for use with this equipment is 5000.4. To provide the 6 Bars (about 85 psig) air supply pressure to the inlet of this equipment, as specified by the manufacturer in "Instructions For Use" (Enclosure 6), the setup of the pressure at the distribution manifold needs to be appropriate for the pressure drop in the combination of hose length and number and type of connections that is actually used.5. This equipment may be used without a standby rescue person.3.5.3 Written Procedures Regarding Storage, Issuance, Maintenance, Repair, Testing, And Quality Assurance Of Respiratory Protection Equipment Pursuant to 10 CFR 20.1703(c)(4)(vii) and the guidance provided in Section 4.12 of Regulatory Guide 8.15, Carolina Power & Light Company and Florida Power Corporation propose to revise or develop written procedures consistent with the conditions for which this equipment was certified and in accordance with manufacturer's recommendations in the "Instructions For Use" (Enclosure 6). In particular, written guidance is proposed to include: 1. This equipment has a shelf-life of 3 years from date of manufacture when stored in the original packaging, out of the light, with the temperature between 0 degC and 60 degC (32 degF and 140 degF).2. Because this equipment is designated as single-use, there is no maintenance or repair.3. Consistent with the guidance in Table 4-21 of NUREG/CR-0041, this equipment need not be routinely inspected when stored in the packaging as received from the manufacturer.

Testing is limited to an inspection at or near the time of issue and an operational check by the user after donning and before exposure to airborne contaminants.

Consistent with the guidance in Section 4.13.2 of NUREG/CR-0041, the inspection will check for tears and defects in fabrication material, presence of zippers as required, and integrity of heat-sealed seams and air distribution and exhaust systems. An operational check for the correct functioning of the supply flow valve and the over pressure valves can be accomplished by crouching down rapidly a few times.Carolina Power & Light Company and Florida Power Corporation note that the NRC authorized for FPL (Reference

16) a minor clarification in the process for removal of the protective packaging and inspection of this equipment to avoid the unnecessary generation of solid radioactive waste.Carolina Power & Light Company and Florida Power Corporation may implement a similar clarification to the manufacturer's "Instructions For Use" (Enclosure

6) if necessary to avoid similar concerns.

United States Nuclear Regulatory Commission Attachment to PE&RAS-05-066 Page 14 of 22 Information to Support Application for Authorized Use of Delta Protection Mururoa Single-Use.

Supplied-Air Suits. Models V4 Fl and V4 MTH2 3.6 Respirator Problem Identification And Communication As described in Section 4.9.2 of NUREG/CR-0041, the NIOSH approval process includes a problem-investigation program, in which reports ofproblems receivedfrom regulatory agencies, labor organizations, respirator users, and respirator manufacturers, are investigated and resolved Items of major interest or significance are widely distributed as "Respirator User Notices" or"Respirator User Warnings. " That program is described in Chapter 6, Section F. of Department of Health and Human Services (NIOSH) Publication 87-116, "NIOSH Guide To Industrial Respiratory Protection.

" Since this equipment is not certified by NIOSH, the NIOSH program described in NUREG/CR-0041 for problem-investigation would not be applicable to this equipment.

Instead, subsequent to NRC authorization under 10 CFR 20.1703(b) to use this equipment and prior to actual first use, Carolina Power & Light Company and Florida Power Corporation propose to revise the respiratory protection program to use the existing Corrective Action Program and the Operating Experience Program to provide appropriate guidance for communicating identified problems with this equipment to the vendor and the rest of the nuclear industry.

The Corrective Action Program is credited with meeting the requirements of 10 CFR 50, Appendix B, Criterion XVI, but is also normally used to identify and resolve a wider range of problems and enhancements.

That process already interfaces with the Operating Experience Program under which such information is evaluated, used, and shared with the rest of the nuclear industry.

This proposal is identified as a Regulatory Commitment in Table 1.3.7 Conclusions Pursuant to 10 CFR 20.1703(b), Carolina Power & Light Company and Florida Power Corporation are applying for NRC authorization to use respiratory protection equipment that has not been tested and certified by NIOSH, specifically Delta Protection Mururoa single-use, supplied-air suits (Model V4 MTH2 and Model V4 F1). Pursuant to 10 CFR 20.1705, Carolina Power & Light Company and Florida Power Corporation are also applying for NRC authorization to use an assigned protection factor of 5000 for this equipment.

As documented in Safety Evaluations (References 15, 16, 17, 18, and 19 for Duke, FPL, AmerenUE, PG&E, and Constellation, respectively), the NRC has found applications from other licensees with similar requests to be acceptable.

Based on the safety features of this equipment, Carolina Power & Light Company and Florida Power Corporation are proposing to use this equipment without the standby rescue persons described by 10 CFR 20.1703(f).

Carolina Power & Light Company and Florida Power Corporation have explained why existing NIOSH-certified respiratory protection equipment does not meet an identified need. The explanation is consistent with information in relevant NRC guidance documents and in similar applications from other licensees.

Carolina Power & Light Company and Florida Power Corporation have enclosed information provided by the manufacturer relative to the material and performance characteristics of this equipment.

Previously docketed test information from the manufacturer, from the European testing and certifying agency, and from other licensees has been enclosed or referenced as reliable evidence that the material and performance characteristics of this equipment are capable of providing the proposed degree of protection under the anticipated conditions of use. The United States Nuclear Regulatory Commission Attachment to PE&RAS-05-066 Page 15 of 22 Information to Support Application for Authorized Use of Delta Protection Mururoa Single-Use, Supplied-Air Suits. Models V4 FI and V4 MTH2 information shows that use of this equipment will not subject the wearer to undue physical or psychological stress or undue hazard.Noting that no assigned protection factor is listed in Appendix A to 10 CFR Part 20 for this type of equipment, Carolina Power & Light Company and Florida Power Corporation have described a situation for which a need exists for a higher assigned protection factor. Previously docketed test information from the manufacturer and from the European testing and certifying agency has been enclosed to demonstrate that the respiratory protection equipment conservatively provides the higher protection factor under the anticipated conditions of use. To ensure that the air pressure supplied to the suit inlet is consistent with the conditions for which this equipment was certified, Carolina Power& Light Company and Florida Power Corporation have established Regulatory Commitments, as listed in Table 1, to conduct and document pressure drop tests of the various combinations of hose lengths and number and types of connections that are representative of those anticipated to be used.Carolina Power & Light Company and Florida Power Corporation implement and maintain a viable, ongoing respiratory protection program at each plant. To use this equipment appropriately within the existing respiratory protection program, Carolina Power & Light Company and Florida Power Corporation have established Regulatory Commitments, as listed in Table 1, to make changes to address training, storage, setup, discard after single use, prohibition from use in an environment that is immediately dangerous to life and health, inspection, testing, and respirator problem identification and communication.

United States Nuclear Regulatory Commission Attachment to PE&RAS-05-066 Page 16 of 22 Information to Support Application for Authorized Use of Delta Protection Mururoa Single-Use.

Supplied-Air Suits. Models V4 Fl and V4 MTH2

4.0 REFERENCES

1. 10 CFR 19.12, "Instruction to workers." 2. 10 CFR 20.1703, "Use of individual respiratory protection equipment." 3. 10 CFR 20.1705, "Application for use of high assigned protection factors." 4. Appendix A to 10 CFR 20, "Assigned Protection Factors for Respirators." 5. 29 CFR 1910.134 (b), "Respiratory protection," "Definitions." 6. 42 CFR 84, "Approval of Respiratory Protection Devices." 7. Regulatory Guide 8.15, Revision 1, "Acceptable Programs for Respiratory Protection." 8. NUREG/CR-0041, Revision 1, "Manual of Respiratory Protection Against Airborne Radioactive Material." 9. Department of Health and Human Services (NIOSH) Publication 87-116, "NIOSH Guide To Industrial Respiratory Protection." 10. Duke Energy Corporation, "Request for Exemption from 10CFR20.1703 and 1OCFR1720 Appendix A Use of French Designed Respiratory Protection Equipment," March 4, 2003.(ML030720026)

11. Entergy Operations, Inc., "Request for Use of Delta Protection, Supplied Air Suits," December 9, 2004. (ML050110423)

12. Florida Power and Light Company/FPL Energy Seabrook, "Request for Use of Higher Assigned Protection Factors Pursuant to 10 CFR 20.1705 with Use of French Designed Air Supplied Respirator Equipment," January 25, 2005. (ML050310410)

13. Union Electric Company, "Request For Authorization For Use Of Delta Protection Respiratory Protection Equipment," June 1, 2005. (ML052280297)

14. Duke Energy Corporation, "Response to Request for Additional Information Concerning Request for Exemption from 10CFR20.1703 and IOCFR20 Appendix A Use of French Designed Respiratory Protection Equipment," May 1, 2003. (MLO31320020)

15. NRC Office of Nuclear Reactor Regulation, "Use of French Designed Respiratory Protection Equipment, Re: Oconee Nuclear Station, Units 1, 2, and 3; McGuire Nuclear Station, Units 1 and 2; and Catawba Nuclear Station, Units 1 and 2 (TAC Nos. MB7952, MB7953, MB7954, MB7955, MB7956, MB7957, and MB7958)," June 30, 2003. (ML031810133)

United States Nuclear Regulatory Commission Attachment to PE&RAS-05-066 Page 17 of 22 Information to Support Application for Authorized Use of Delta Protection Mururoa Single-Use.

Supplied-Air Suits. Models V4 Fl and V4 MTH2 16. NRC Office of Nuclear Reactor Regulation, "St. Lucie Units 1 and 2, Turkey Point Units 3 and 4, and Seabrook Station Unit 1 -Use of Higher Assigned Protection Factor With the Use of French-Designed Air Supplied Respirator Equipment (TAC Nos. MC5816, MC5817, MC5818, MC5819, MC5820)," April 8, 2005. (ML050980119)

17. NRC Office of Nuclear Reactor Regulation, "Callaway Plant, Unit 1 -Use of Delta Protection Respiratory Protection Equipment (TAC No. MC7242)," September 14, 2005. (ML052570106)

18. NRC Office of Nuclear Reactor Regulation, "Diablo Canyon Power Plant, Unit Nos. 1 and 2 -Use of Assigned Protection Factor With the Use of French-Designed Air Supplied Respirator Equipment (TAC Nos. MC9005 and MC9006)," December 21, 2005. (ML053340498)

19. NRC Office of Nuclear Reactor Regulation, "Calvert Cliffs Nuclear Plant, Unit Nos. 1 and 2, R.E. Ginna Nuclear Power Plant, and Nine Mile Point Nuclear Power Station, Unit Nos. 1 and 2-Authorization for Use of Delta Protection Mururoa Single Use Supplied Air Suits, Model V4 MTH2, With an Assigned Protection Factor of 5000 (TAC Nos. MC8680, MC8681, MC8682, MC8683, and MC8684)," January 19, 2006. (ML053570243)

United States Nuclear Regulatory Commission Attachment to PE&RAS-05-066 Page 18 of 22 Information to Support Application for Authorized Use of Delta Protection Mururoa Single-Use.

Supplied-Air Suits. Models V4 Fl and V4 MTH2 TABLE 1 List of Regulatory Commitments The following table identifies those actions in this document committed to by Carolina Power &Light Company, now doing business as Progress Energy Carolinas, Inc. (PEC), and Florida Power Corporation, now doing business as Progress Energy Florida, Inc. (PEF). Any other statements in this document are provided for informational purposes and are not considered to be Regulatory Commitments.

Please direct questions regarding these Regulatory Commitments to Chris Burton, Manager -Performance Evaluation

& Regulatory Affairs at (919) 546-6901.REGULATORY COMMITMENT DUE DATE Based on satisfactory tests results from applicable pressure drop tests of the Prior to first use of various combinations of hose lengths and number and types of connections this equipment at that are representative of those anticipated to be used, Carolina Power & Light Brunswick Steam Company will incorporate specific instructions into the respiratory protection Electric Plant.program to ensure that the air is supplied to the suit inlet consistent with the conditions for which this equipment was certified.

Based on satisfactory tests results from applicable pressure drop tests of the Prior to first use of various combinations of hose lengths and number and types of connections this equipment at that are representative of those anticipated to be used, Carolina Power & Light Shearon Harris Company will incorporate specific instructions into the respiratory protection Nuclear Power program to ensure that the air is supplied to the suit inlet consistent with the Plant.conditions for which this equipment was certified.

Based on satisfactory tests results from applicable pressure drop tests of the Prior to first use of various combinations of hose lengths and number and types of connections this equipment at that are representative of those anticipated to be used, Carolina Power & Light H. B. Robinson Company will incorporate specific instructions into the respiratory protection Steam Electric program to ensure that the air is supplied to the suit inlet consistent with the Plant.conditions for which this equipment was certified.

Based on satisfactory tests results from applicable pressure drop tests of the Prior to first use of various combinations of hose lengths and number and types of connections this equipment at that are representative of those anticipated to be used, Florida Power Crystal River Unit Corporation will incorporate specific instructions into the respiratory 3 Nuclear protection program to ensure that the air is supplied to the suit inlet consistent Generating Plant.with the conditions for which this equipment was certified.

United States Nuclear Regulatory Commission Attachment to PE&RAS-05-066 Page 19 of 22 Information to Support Application for Authorized Use of Delta Protection Mururoa Single-Use.

Supplied-Air Suits. Models V4 F1 and V4 MTH2 TABLE 1 (continued)

List of Regulatory Commitments REGULATORY COMMITMENT DUE DATE Carolina Power & Light Company will modify the respiratory protection program to provide training and additional written instructions, as follows: 1) Training: a) Revise or develop written lesson plans and train workers on: i) The features of this equipment; ii) How to don, use, and doff this equipment; and iii) Using the built-in escape strips for routine and emergency egress conditions.

The training will include appropriate hands-on and classroom instruction and will include actions to be taken by the user in the event of equipment malfunction.

b) Provide appropriate training to personnel responsible for implementation of the respiratory protection program to assist in selection, issuance, set-up, and operation of this equipment.

2) Provide written instructions for storage, repair, selection, inspection, and use of this equipment:

a) Discard this equipment after a single use, b) Do not use in an environment immediately dangerous to life and health, c) Prohibit contact with open flames or grinding/welding sparks, d) Use with an assigned protection factor of 5000, e) Comply with manufacturer's recommendations for shelf-life and storage conditions for this equipment, f) Perform no maintenance or repair, g) Inspect this equipment at or near time of issue for tears, defects in material, presence of required zippers, and integrity of seams and air distribution and exhaust systems, and h) Wearer to perform an operational check after donning and before exposure to airborne contaminants.

3) Provide written instructions for respirator problem identification and communication:

a) Identify problems in the Corrective Action Program, b) Communicate with the vendor to investigate and resolve identified problems, and c) Communicate identified problems to other licensees through the Operating Experience Program.Prior to first use of this equipment at Brunswick Steam Electric Plant.

United States Nuclear Regulatory Commission Attachment to PE&RAS-05-066 Page 20 of 22 Information to Support Application for Authorized Use of Delta Protection Mururoa Single-Use.

Supplied-Air Suits, Models V4 Fl and V4 MTH2 TABLE 1 (continued)

List of Regulatory Commitments REGULATORY COMMITMENT I DUE DATE Carolina Power & Light Company will modify the respiratory protection Prior to first use of program to provide training and additional written instructions, as follows: this equipment at 1) Training:

Shearon Harris a) Revise or develop written lesson plans and train workers on: Nuclear Power i) The features of this equipment; Plant.ii) How to don, use, and doff this equipment; and iii) Using the built-in escape strips for routine and emergency egress conditions.

The training will include appropriate hands-on and classroom instruction and will include actions to be taken by the user in the event of equipment malfunction.

b) Provide appropriate training to personnel responsible for implementation of the respiratory protection program to assist in selection, issuance, set-up, and operation of this equipment.

2) Provide written instructions for storage, repair, selection, inspection, and use of this equipment:

a) Discard this equipment after a single use, b) Do not use in an environment immediately dangerous to life and health, c) Prohibit contact with open flames or grinding/welding sparks, d) Use with an assigned protection factor of 5000, e) Comply with manufacturer's recommendations for shelf-life and storage conditions for this equipment, f) Perform no maintenance or repair, g) Inspect this equipment at or near time of issue for tears, defects in material, presence of required zippers, and integrity of seams and air distribution and exhaust systems, and h) Wearer to perform an operational check after donning and before exposure to airborne contaminants.

3) Provide written instructions for respirator problem identification and communication:

a) Identify problems in the Corrective Action Program, b) Communicate with the vendor to investigate and resolve identified problems, and c) Communicate identified problems to other licensees through the Operating Experience Program.

United States Nuclear Regulatory Commission Attachment to PE&RAS-05-066 Page 21 of 22 Information to Support Application for Authorized Use of Delta Protection Mururoa Single-Use.

Supplied-Air Suits. Models V4 Fl and V4 MTH2 TABLE 1 (continued)

List of Regulatory Commitments REGULATORY COMMITMENT DUE DATE I Carolina Power & Light Company will modify the respiratory protection program to provide training and additional written instructions, as follows: 1) Training: a) Revise or develop written lesson plans and train workers on: i) The features of this equipment; ii) How to don, use, and doff this equipment; and iii) Using the built-in escape strips for routine and emergency egress conditions.

The training will include appropriate hands-on and classroom instruction and will include actions to be taken by the user in the event of equipment malfunction.

b) Provide appropriate training to personnel responsible for implementation of the respiratory protection program to assist in selection, issuance, set-up, and operation of this equipment.

2) Provide written instructions for storage, repair, selection, inspection, and use of this equipment:

a) Discard this equipment after a single use, b) Do not use in an environment immediately dangerous to life and health, c) Prohibit contact with open flames or grinding/welding sparks, d) Use with an assigned protection factor of 5000, e) Comply with manufacturer's recommendations for shelf-life and storage conditions for this equipment, f) Perform no maintenance or repair, g) Inspect this equipment at or near time of issue for tears, defects in material, presence of required zippers, and integrity of seams and air distribution and exhaust systems, and h) Wearer to perform an operational check after donning and before exposure to airborne contaminants.

3) Provide written instructions for respirator problem identification and communication:

a) Identify problems in the Corrective Action Program, b) Communicate with the vendor to investigate and resolve identified problems, and c) Communicate identified problems to other licensees through the Operating Experience Program.Prior to first use of this equipment at H. B. Robinson Steam Electric Plant.

United States Nuclear Regulatory Commission Attachment to PE&RAS-05-066 Page 22 of 22 Information to Support Application for Authorized Use of Delta Protection Mururoa Single-Use.

Supplied-Air Suits. Models V4 FI and V4 MTH2 TABLE 1 (continued)

List of Regulatory Commitments REGULATORY COMMITMENT DUE DATE Florida Power Corporation will modify the respiratory protection program to Prior to first use of provide training and additional written instructions, as follows: this equipment at 1) Training:

Crystal River Unit a) Revise or develop written lesson plans and train workers on: 3 Nuclear i) The features of this equipment; Generating Plant.ii) How to don, use, and doff this equipment; and iii) Using the built-in escape strips for routine and emergency egress conditions.

The training will include appropriate hands-on and classroom instruction and will include actions to be taken by the user in the event of equipment malfunction.

b) Provide appropriate training to personnel responsible for implementation of the respiratory protection program to assist in selection, issuance, set-up, and operation of this equipment.

2) Provide written instructions for storage, repair, selection, inspection, and use of this equipment:

a) Discard this equipment after a single use, b) Do not use in an environment immediately dangerous to life and health, c) Prohibit contact with open flames or grinding/welding sparks, d) Use with an assigned protection factor of 5000, e) Comply with manufacturer's recommendations for shelf-life and storage conditions for this equipment, f) Perform no maintenance or repair, g) Inspect this equipment at or near time of issue for tears, defects in material, presence of required zippers, and integrity of seams and air distribution and exhaust systems, and h) Wearer to perform an operational check after donning and before exposure to airborne contaminants.

3) Provide written instructions for respirator problem identification and communication:

a) Identify problems in the Corrective Action Program, b) Communicate with the vendor to investigate and resolve identified problems, and c) Communicate identified problems to other licensees through the Operating Experience Program.

United States Nuclear Regulatory Commission Enclosure 1 to Attachment to PE&RAS-05-066 6 Pages (including this cover sheet)Delta Protection MURUROA V4 FULLY ENCLOSED SUIT GENERAL DESCRIPTION N 0: Do/ USA/ 1 MURUROA /k INDICE: a V4 FULLY ENCLOSED SUIT DATE D-APPLICATION 06901DELTA PROTECTIQA

06/09/0 GENERAL DESCRIPTION CE 04 66 89 18 36 PAGE :1/4 5 MURUROA SUIT The Mururoa suit is a single use garment designed to be used in radioactively contaminated environments.

It has been widely used in western European Nuclear Power Plants for more than 20 years, without any major problem (the French state company: Electricit6 de France use 60,000 garments each year).The Mururoa suit is a fully enclosed PVC plastic, supplied-air and pressurized suit, that offers excellent protection factor ( -100,000) against any solid, liquid, or gas pollutant, minimizing discomfort and heat stress and increasing the worker's efficiency.

The Mururoa suit is C.E. approved and complies with CE standard EN:1073-1 "Protective clothing against Radioactive Contamination" It also fulfils the requirements of the I.S.O. 8194 standard 'Radiation Protection-Clothing for protection against Radioactive contamination-Design selection ,testing and use" N 0: Do / USA / 1 INDIE : V4 MURUROA INDICE: a V4 FULLY ENCLOSED SUIT DATE D'APPLICATION 06901 DELTA PRO TECTIOA:06/09/0 GENERAL DESCRIPTION (I 04 66 89 18 36 PAGE :2/4 5 VENTILATION

/ EXHAUST In the supplied-air Mururoa suit, the ventilation system is composed of-An airflow control valve, preset to a minimum flow of 250 litres/minute (9 CFM) at 3 bar (42 PSIG), located on the right hip and covered with a protection flap. This flow can be adjusted, from 250 to 1150 litres (9 CFM to 41 CFM) per minute. 1150 litres is obtained with the tap fully opened at the feeding pressure of 6 bar (85 PSIG) (refer to graph in annex 11).-A silencer bag which attenuates the noise level less than 58 dBa at 250 litres/minutes to 76 dBa at 1150 litres/minute.

-A manifold system welded to the suit and distributing the air to the helmet, the legs and the arms.-An exhaust by two world patented valves placed in the helmet and in the back. These valves ensure a remarkable airtight seal in case of accidental air-feed cut off, or when putting the suit in under pressure through abrupt movements.

The valves regulate the overpressure in the garment between 3 mbar (0.042 PSIG) and 10 mbar (0. 142 PSIG)for supply air pressure between 3 bar (42 PSIG) and 6 bar (85 PSIG)-The benefits of this system are-High heat removal through superior airflow-Non irritating diffuse ventilation

-Resistance free breathing-High level of comfort for long and strenuous jobs in contaminated areas-Very low noise level N 0: Do/USA/1 MURUROA of INDICE: a V4 FULLY ENCLOSED SUIT DATE D'APPLICATION 06901DELTA PROTECTIO!h

06/09/0 GENERAL DESCRIPTION ) 04 66 89 18 36 PAGE :3/4 5 DESIGN CHARACTERISTICS

-One piece PVC, fire proof suit. (Thickness 20/1 00mm for technical data concerning the material, refer Annex I of this document)-Welded PVC gloves-Incorporated overboots with strengthened sole-Binding ties on the overboots-Reinforced elbows, knees and crotch-Dual zipper system: -metal zipper for mechanical strength-PVC zipper for air and gas tightness (0.30 PVC thickness)

-Supple transparent PVC helmet, fitted with a transparent distortion free, PVC face plate 6"x 8" giving almost the same optical quality as glass.-Quick release strip from forearm, overhead to forearm, for easy removal. This is used both for undressing or emergency egress. (Emergency egress takes less than 3 seconds).-Quick release strip for access to the mouth.-Welded sleeve for communication cable.

NO: Do/USA/1 MURUROA A INDICE: a V4 FULLY ENCLOSED SUIT I DATE D'APPLICATION 06901DELTA PRO TECTIOA~DN:06/09/0 GENERAL DESCRIPTION ) 04 66 89 18 36 PAGE :4/4 5 GENERALCONSIDERATIONS THE MURUROA SUIT IS AVAILABLE IN SIX SIZES Size 0 1,55 m -4 1,62 meter 5 feet I inch Size 1 1,60 -1,68 meter 5'3" Size 2 1,68 -4 1,74 meter 5'6" Size 3 1,74 -4 1,82 meter 5'8" Size 4 1,82 -4 1,92 meter 6'0" Size 5 1,92 -4 2,05 meter 6'3" But if any individual selects a suit size different from the safety characteristics will not change.-* 5 feet 4 inches-o 5'6"-5'8"-4 6'0"-o 6'3"-6'8" recommended size, the operating and WEIGHT 1200 grams (2.64 LBS)FEEDING PRESSURE 6 bar (85 PSIG)FLOW 450 up to 1150 Lit/minute (16 -41 CFM)STORAGE-The suit should be used by the third year from the date of manufacture.

-It must be stored in its original packaging.

-The storage temperature has to stay between 0C and 60'C (32 0 F -140'F)-If the storage temperature was below 5 0 C (41 0 F) the suit must be stored approximately 3 hours3.472222e-5 days <br />8.333333e-4 hours <br />4.960317e-6 weeks <br />1.1415e-6 months <br /> at a room temperature until the suit become flexible.-The usage temperature range + 50 C and + 55 0 C (410 -131'F) depends on air fed temperature NO: Do/ USA/ 1 MURUROA INDICE: a V4 FULLY ENCLOSED SUIT DATE D'APPLICATION

06/09/01 DELTA PROTECTION

06/09/0 GENERAL DESCRIPTION ) 04 66 89 18 36 PAGE :5/4 5 MATERIAL PROPERTIES Technical characteristic of PVC material 20/100 mm using French standards, which would correspond to ANSI standards.

Characteristic Standards Results Units Density NFT 51063 1.38 gm/cm3 Traction Resistance NFT 54102 2 143 N/cm 2 Stretch before tear NFT 54102 2 178 %Tear resistance NFT 46007 2 45 N/cm 2 Weld resistance than material resistance NFT 54122 Peel 50 I Tear 65 %Resistance to cold NFT 51102 -10 0C Vapour permeability NFH 00030 34.1 g/m 2/24h Volatility on activated charcoal NFT 51167 < 6 %Spark perforation NFC 26225 9.2 KV United States Nuclear Regulatory Commission Enclosure 2 to Attachment to PE&RAS-05-066 10 Pages (including this cover sheet)EC TYPE EXAMINATION CERTIFICATE Number 0073 / 197/162 / 01 /96 /0001 Delta Protection MURUROA V4 MTH2 ECEC 96/0001 Page 1/9 T 1 INSTITUTE FOR NUCLEAR PROTECTION AND SECURITY Technical Center for Nuclear Equipment Certification In accordance with the directive 89/686/EEC dated December 21 th 1989 comparing the laws of the States Members Legislations relative to the Personal Protective Equipments, and the decrees n 0 92-765, 766 and 768 dated July 29th 1992 transposing the directive into French Laws.The organisation here below mentioned (IPSN / CTHEN) whose references are as follows:-Address: B.P. no 6 -92265 Fontenay-aux-Roses Cedex (France).-Empowered by Order of the Ministries of Employment and Agriculture dated December 24h 1996.-Identified under the no 0073 (published in the EEC Official Publication dated July 23 th 1994).Assigns the: EC TYPE EXAMINATION CERTIFICATE N 0 0073/197/162/01

/96/0001 To the following Personal Protective Equipment model:-Designation:

Ventilated Protective Suit against Radioactive Contamination pressurised for a single use only.-Commercial reference

MTH 2- ref. 841 442 T.-Manufacturer:

DELTA PROTECTION

/ REDI -69 210 Saint-Germain-Sur-L'Abresle.

-Certificate applicant:

DELTA PROTECTION

-Z.A. De Berret-30200 Bagnols-Sur-Ceze.

-Essential Requirements

Reference:

EN 143, pr EN 1073 (nov. 1995), pr EN 943 (august 1995), EN 270, EN 146.Date : January 10' 1996 G.BRUHL / Chief of CTHEN Nota : According to article R 223-62 of the "Working Law", the empowered organisation should be informed of any modification made to the material subject of this EEC type examination certificate, as well as of any modification made to the contents of this technical file on which the delivered type certificate was based on (address, manufacturer name, quality insurance certificate extract, ...)This certificate contains 12 pages no 1/9 to 9/9 Fre-dh vision only sh"I be ad when dspunt ECEC 96/0001 Page 2/9 1. DESCRIPTION It is a Ventilated Protective Suit against Radioactive Contamination ventilated type -pressurised for a single use only, its name is: MTH2 -ref. DELTA: 841 442 T The T values are defined according to the size of the suit.The suit includes:-A air tight suit with an incorporated hood-A suit fastening system located on the back of the suit.-A breathable air flow supply system.-A air exhaust device.-A safety strip for emergency opening located on the hood.Frora view Profit Hood Ocuar 7osimetric window Ir 4 4 Elbow reinforcement Bootie Frnch version only shali be .usd when disp.te ECEC 96/0001 Page 3/9 1.1. MAIN MATERIALS-Skin of the suit: White polyethylene:

Ethyfuge 2000 Thickness:

24/100 mm-Hood: PE Cristal -30/1 00 mm thickness.

-Visor: PVC (astraglass) 50/100 mm thickness.

-Gloves: PVC Sempersoft type -Size 9-91/2, and Semperstar type -size 10-10 %..-Boots: Polyethylene

-24/100 mm thickness, reinforced with PE cristal.1.2. COMPONENTS

-Internal Ventilation System: It includes a total ventilation V4 fitted with a valve with CEJN (ref:342) butt.-Exhaust: It includes two exhaust valves located on the head and on the back of the suit.-Fastening device: It includes a double zip fastener located vertically on the back of the suit.-Other components:

The suit includes:-A safety strip for an emergency opening located on the hood.-A acoustic link tunnel.-A loop for breathable air supply pipe.-Several internal strengthening pieces for elbows, knees and legs.-A transparent window to visualise the dosimeter.

2. CONFORMITY TO REQUIREMENTS

2.1. REQUIREMENTS

FOR THE MATERIALS (except accessories:

Gloves, slippers...)(See paragraph 5.1. of the prEN 1073)French vmnion only shIl be used when dispute ECEC 96/0001 Page 4/9 2.1.1. Abrasion Resistance Test according to the Norm EN 530 -method 2 (abrasive paper 00). The classification is carried out according to the following diagram: Class Number of cycles 6 > 2 000 cycles 5 > 1500 cycles 4 > 1 000 cycles 3 > 500 cycles 2 > 100 cycles 1 > 10 cycles Results: Class 6 for Ethyfuge 2000 -24/100 mm thickness.

Class 6 for PVC..1.2. Flex cracking Resistance Test according to the Norm ISO 7854 -method B. The classification is carried out according to the following diagram: Class Number of cycles 6 > 1 00 000 cycles 5 > 40 000 cycles 4 > 15 000 cycles 3 > 5 000 cycles 2 > 2 500 cycles 1 > 1 000 cycles This test is not applicable to suits for one single use only.2.1.3. Puncture Resistance Test according to the Norm EN 863. The classification is carried out according to the following diagram: Class Puncture resistance 3 > 100N 2 > 50N I > 1ON Results: Class 1 for Ethyfuge 2000 -24/100 mm thickness.

Class 2 for PE cristal.French veson only shall be Ued ehen dispte ECEC 96/0001 Page 5/9 2.1.4. Resistance in blocking Test according to the Norm ISO 5978. The classification is carried following diagram: out according to the Class Comments 2 non stick 1 sticky This test is not applicable to non-coated materials.

2.1.5. Tear Resistance Test according to the Norm ISO 9073-4. The classification is according to the following diagram: Class Applied strength 6 > 150 N 5 > 80N 4 > 40N 3 > 20N 2 > 1ON 1 > 2N Results:.

Class 4 for Ethyfuge 2000 -24/1 00 mm thickness.

Class 3 for PE Cristal.2.1.6.Flammability of materials, visors, and ancillary parts Tests are carried out according to the Norms EN 1146 -single burner test (paragraph 7.5.3).Results: Test requirements entirely fulfilled.

2.2. REQUIREMENTS

FOR THE ACCESSORIES

2.2.1 Gloves

The gloves set on the MTH2 ref. 841 442 T comply with the specific requirements for this type of Individual Protection Equipment, mainly to the Norm EN 421 "Protective Gloves against ionizer radiation and radioactive contamination".

They have Special EC Examination Certificates (ECEC) based on contracted tests.French -oNy ".II be ueed eben di.p"A ECEC 96/0001 Page 6/9 2.2.2. Boots The boots are part and parcel of the suit and are made of the same constituted material.Consequently they comply with the requirements.

2.3. REQUIREMENTS

FOR THE PROTECTIVE SUIT 2.3.1. Suit Design: Practical Performance Test The Practical Performance Test is carried out according to the prEN 1073 (paragraph 6.2.).The conditioning is according to the manufacturer directions for use.Parameters Valuations a) Harness comfort b) Security of fastenings

& couplings c) Accessibility of adjusting devices d) Clarity of vision through visor e) Suit comfort g) Other parameters Aimless Good Good Good Good No particular notice 2.3.2. Fit Factor (paragraph 5.2.2. of the pr EN 1073)The protection factor is determined according to the PrEN 944 standard (paragraph 8.9) by respecting the sequences indicated in Annex A of the PrEN 1073.The mean leakage value ( or inversely, the protection factor) enables a clothing classification according to the following table. The preconditioning according to the instructions for use recommendations.

Maximum accepted values, in %, of the ratio of the Ventilated average Inward Leakage inside the hood, pressurised calculated on the whole lot of suits FIT FACTOR Suit classification For One activity For all activities 5 0.004 0.002 50 000 4 0.010 0.005 20 000 3 0.020 0.010 10 000 2 0.040 0.020 5 000 I 0.100 0.050 2 000 Results: The suit is classified 5.French verio only shall be used vt- disput.

ECEC 96 / 0001 Page 7/9 2.3.3.1. Seams, Joins and Assemblages pull test resistance 2.3.3.1. Seams / Welds (paragraph 5.2.3.1 of the pr EN 1073)A sample of each type of seam/weld is tested according to the Norm ISO 5082 (annex 2).The seam performance level is according to the following classification:

Class Seam resistance (N)5 > 300 4 > 125 3 > 75 2 > 50 1 > 30 The tests have been applied to the following welds:-Elbow and knee reinforcement

-Crotch assembly-Belt assembly-Booties assembly Results: All the welds are classified 3.2.3.3.2. Joins and Assemblages (paragraph 5.2.3.2. -prEN 1073)This suit has no removable parts. This paragraph is aimless.2.3.4 Gas tight (paragraph 5.2.4. of prEN 1073.The test was carried out according to the EN 464 standard .The loss of pressure shall not be greater than 4 mbar in 6 minutes.Results : Test not undertaken as the clothing is not considered as an gastight suit.2.3.5. Visors (paragraph 5.2.5. of prEN 1073)The distortion of vision is measured, during the Practical Performance.

The mechanical resistance test of the visor is according to the Norm EN 146 (paragraph 6.6 and 6.7.).Results: Distortion of vision: Up to requirement.

Mechanical resistance:

up to requirement.

French i only sh.a be ued when dupA.

ECEC 96/0001 Page 8/9 2.3.6. Air supply system (paragraph 5.2.6. of the pr EN 1073)The couplings and connections must comply with the requirements of the paragraphs 6.7.1., 6.7.2., and 6.11.7. of the EN 270. The connection between the compressed air supply system and the suit must resist to a 250 N pull.Result: requirement entirely fulfilled.

2.3.6. Breathing

Hose (paragraph 5.2.7. of the pr EN 1073)Tests are performed according to the EN 270 (paragraph 7.2. and 7.6). The pipes must not block the movements nor cause a rupture of the air supply during the Practical Performance Test.Result: No constraint.

2.3.7. Air supply flow rate (paragraph 5.2.8. of the PrEN 1073)The test is carried out according to the PrEN 1073 standard (paragraph 6.3).Result: Minimal flow rate:30 m 3.h 1 (500 I/min 1) for a 6 Bar supply pressure Maximal flow rate:66 m 3.h 1 (1100 I/minr 1) for a 5.5 Bar supply pressure 2.3.8. Air flow rate warning device (paragraph 5.2.9. of the pr EN 1073)If a warning is fitted, it must comply to the EN 270 (paragraph 6.13.3). The test must be carried out according to the EN 270 (paragraph 7.12). The sound level must be higher than 85 dB(A).Result: Aimless (there is no sonic warning device).2.3.9. Air supply valve (paragraph 5.2.10 of the pr EN 1073)Where present, the control valve should enable a variation of flow rate between the minimum and maximum specified values without the possibility of closure.Result: Requirements entirely fulfilled.

2.3.11.Exhaust devices (paragraph 5.2.11. of the pr EN 1073)The exhaust devices must work correctly after the testing of the pressure in the suit, during the Practical Performance Test and during the determination of the Fit Factor. Test in accordance with the EN 1073 (paragraph 6.6.).Results: Good valves working.Pull resistance superior to the fixed limit.Fr.n-h vmsion onJy s"1lI be used vAn disput.

ECEC 96 / 0001 Page 9/9 2.3.12.Pressure in the suit During the activity sequence as specified, the overpressure shall not exceed 1000 Pa mean and 2000 Pa peak. A positive pressure shall be maintained.

Result: Requirements entirely fulfilled.

2.3.13.Carbon dioxide content of the inhalation air The C02 content of the inhalation air, determined at the minimum air flow rate, shall not exceed an average of 1 % (by volume), tested according to the EN 270 (paragraph 7.15).Result: Requirement entirely fulfilled.

2.3.14. Noise associated with the air supply to the suit (paragraph 5.2.14 -pr EN 1073)Test according to the EN 270 (paragraph 7.16). The noise measured in the suit at the ears shall not exceed 80 dB(A) at the maximum air flow rate as indicated by the manufacturer.

Result: Requirement entirely fulfilled.

3. CHECKINGS 3.1. MARKING (paragraph 7 of the pr EN 1073)The marking is satisfies the requirements of article 7 in the EN 340.3.2. MANUFACTURER INFORMATION (Paragraph 8 of the pr 1073)The manufacturers information complies with the specifications in paragraph 8 of the EN 340.They contain the instructions for use, the usage conditions and the specific limits and restraints.

3.3. MAINTENANCE

MARKING This is aimless, the suit being for one single use only.4. CONCLUSIONS Upon presentation of the tests results, the Ventilated suit -pressurised for a single use only, MTH 2 -ref. 841 442 T is certified to ensure a protection against radioactive contamination according the following specified limits:-Minimum air flow rate: 30 m 3.h" (500 I.min-)-Maximum air flow rate: 66 m 3.h-1.(1100 I.mina')F-noh V-inon only shWI b. U.d f~n dispute United States Nuclear Regulatory Commission Enclosure 3 to Attachment to PE&RAS-05-066 13 Pages (including this cover sheet)EC TYPE EXAMINATION CERTIFICATE Number 0073 /197/162/12/97/0028 Delta Protection MURUROA V4 F1 ECEC 97/0028 Page 1/12 INSTITUTE FOR NUCLEAR PROTECTION AND SECURITY Technical Center for Nuclear Equipment Certification In accordance with the directive 89/686/EEC dated December 21th 1989 comparing the laws of the States Members Legislations relative to the Personal Protective Equipments, and the decrees no 92-765, 766 and 768 dated July 29th 1992 transposing the directive into French Laws.The organisation herebelow mentioned (IPSN / CTHEN) whose references are as follows:-Address: B.P. n 0 6-92265 Fontenay-aux-Roses Cedex (France).-Empowered by Order of the Ministries of Employement and Agriculture dated December 24 " 1996.-Identified under the no 0073 (published in the EEC Official Publication dated July 23 th 1994).Assigns the: EC TYPE EXAMINATION CERTIFICATE No00731197/16211219710028 To the following Personal Protective Equipment model:-Designation:

Ventilated Protective Suit against Radioactive Contamination pressurised for a single use only.-Commercial reference:

MURUROA V4 F1 -ref. 848 1XIT.-Manufacturer:

DELTA PROTECTION

/ REDI -69 210 Saint-Germain-Sur-L'Abresle.

-Certificate applicant:

DELTA PROTECTION

-Z.A. De Berret-30200 Bagnols-Sur-Ceze.

-Essential Requirements

Reference:

EN 143, pr EN 1073-1 (July 1997), pr EN 943-1 (October 1997), EN 270, EN 1146 (April 1997).Date: December 10h 1997 J. CORBIERE/

Chief of CTHEN Nota : According to article R 223-62 of the "Working Law", the empowered organisation should be informed of any modification made to the material subject of this EEC type examination certificate, as well as of any modification made to the contents of this technical file on which the delivered type certificate was based on (address, manufacturer name, quality insurance certificate extract, ...)This certificate contains 12 pages n" 1/12 to 12/12 F.noh v-nion orgy "h.I be used vtn dispute ECEC 97/ 0028 Page 3/12 1.1. MAIN MATERIALS-Skin of the suit: PVC 9013 -Formule 1010, 20/100 mm thickness.

-Hood: PVC Cristal -30/100 mm thickness.

-Visor: PVC (astraglass) 50/100 mm thickness.

-Gloves: PVC Sempersoft type -Size 9-91/2 for all the sizes of the suits.-Boots: PVC 9013 -formulation 1010 -20/100 mm thickness, reinforced PMI.1.2. COMPONENTS

-Internal Ventilation System: It includes a total ventilation V4 fitted with a valve with butt.-Exhaust: It includes two exhaust valves located on the head and on the back of the suit.-Fastening device: It includes a double zip fastener situated vetically on the back of the suit.-Other components:

The suit includes:-A safety strip for an emergency opening located on the hood.-A acoustic link tunnel.-A loop for breathable air supply pipe.-Several internal strengthening pieces for elbows, knees and Imegs.-A transparent window to visualise the dosimeter.

F-enh -v.nof ordy shaI be U-ed wy- di"~,t ECEC 97 / 0028 Page 4/12 2. CONFORMITY TO REQUIREMENTS

2.1. REQUIREMENTS

FOR THE MATERIALS (except accessories:

Gloves, slippers...)(See paragraph 4.2. of the Norm EN 1073-1)2.1.1. Abrasion Resistance Test according to the Norm EN 530 -method 2 (abrasive paper 00). The classification is carried out according to the following diagram: Class Number of cycles 6 > 2 000 cycles 5 > 1500 cycles 4 > 1 000 cycles 3 > 500 cycles 2 > 100 cycles> 10 cycles Results: Class 6 for PVC 9013- formule 110- 20/100 mm thickness.

Class 6 for Cristal PVC 30/1 00 mm thickness.

.1.2. Flexcracking Resistance Test according to the Norm ISO 7854 -method B. The clasification is carried out according to the following diagram: Class Number of cycles 6 > 100 000 cycles 5 > 40 000 cycles 4 > 15 000 cycles 3 > 5 000 cycles 2 > 2 500 cycles I > 1 000 cycles This test is not applicable to suits for one single use only.Frmnch -o ody slIl b. .d when disput ECEC 97 /0028 Page 5/12 2.1.3. Puncture Resistance Test according to the Norm EN 863. The classification is carried out according to the following diagram: Class Puncture resistance 3 > 100N 2 > 50N 1 > 1ON Results: Class 2 for PVC Cristal -30/100 mm thickness.

Class 1 for PVC 9013 -Formule 1010 -20/1 00 mm thickness.

2.1.4. Resistance

in blocking Test according to the Norm EN 25978. The classification is carried out according to the following diagram: This test is not applicable to non-coated materials.

2.1.5. Tear Resistance Test according to the Norm EN 29073-4. The classification is according to the following diagram: Class Applied strength 6 > 150 N 5 > 80N 4 > 40N 3 > 20N 2 > 1ON 1 > 2N Results :. Class 3 for PVC 9013 -Formule 1010 -20/100 mm thickness.

Class 4 for Cristal PVC -30/100 mm thickness.

F-noh V-rnon only shuII be used t-n dispute ECEC 97/0028 Page 6/12 2.1.6. Flammability of materials, visors, and ancillary parts Tests are carried out according to the Norms EN 1146 -single burner test (paragraph 7.5.3).Results: Test requirements entirely fulfilled.

2.2. REQUIREMENTS

FOR THE ACCESSORIES

2.2.1. Gloves

The gloves set on the MURUROA V4 F1 ref. 8481X1T comply with the specific requirements for this type of Individual Protection Equipment, mainly to the Norm EN 421 "Protective Gloves against ionizer radiation and radioactive contamination".

They have Special EC Examination Certificates (ECEC) based on contracted tests.2.2.2. Boots The boots are part and parcel of the suit and are made of the same constituted material.Consequently they comply with the requirements.

2.3. REQUIREMENTS

FOR THE PROTECTIVE SUIT 2.3.1. Suit Design: Practical Performance Test The Practical Performance Test is carried out according to the Norm 1073-1 (paragraph 5.2.).The conditioning is according to the manufacturer directions for use.Parameters Valuations a) Hood comfort Aimless b) Security of fastenings

& couplings Good c) Accessibility of adjusting devices Good d) Clarity of vision through visor Good e) Suit comfort Good f) Speaking transmission facility Aimless g) Other parameters No particular notice 2.3.3. Air flow supply system (project Norm pr EN 1073-1 -paragraph 4.8.)The manufacturer estimated air flow rates, for a relative air flow supply pressure of 6 bar, with a tolerance of +/- 10%, are:* Minimal flow rate : 30,0 m 3.h 1-(500 L.min-)* Maximum flow rate : 58,4 m 3 h-1 (973 I.min-')Finch vision only halI b. used wt-ln di.pt.

ECEC 97/ 0028 Page 7/12 Notice: In order to take into account the manufacturer indicated tolerances, this ECEC tests have been carried out under the following conditions:

Dmin = 27,0 m 3.h 1 (450 I.min '1)Dmax = 64,2 m 3.h 1 (1070 L.min-')The test concerning the air flow rates of the suit has been realised according to the Norm EN 1073-1 (paragraph 5.3); For an air supply pressure of 6 bar, the air flow rate inside the suit must not be::-Below the minimum value estimated by the manufacturer (Dmin), when the valve is on the"stop" closed position.-Superior to the maximum value esitimated by the manufacturer (Dmax), when the valve is on the 'on" opened position.Results: Requirements entirely fulfilled.

2.3.3. Inward

leakage average -Fit Factor (paragraph 4.3. of the project Norm pr EN 1073-1)The ratio of the average inward leakage (or its contrary : Fit Factor) has been measured according to the draft Norm pr EN 943-1 (annex A). According to the Sodium Chloride Method.Measurements have been performed under the following conditions:

-Quantity of tested suits : 3-Air flow rate: Adjusted and maintained on minimum flow rate (D min) as indicated in paragraph 2.3.2.-Trainings sequence:

According to the Norm EN 1073-1 Annex A list.-Suit preliminary conditioning:

According to the advice of the user manual The ratio of the average inward leakage (or Fit Factor) gives the following classification:

Maximum accepted values, in %, of the ratio of the Ventilated average Inward Leakage inside the hood, pressurised calculated on the whole lot of suits FIT FACTOR Suit classification For One activity For all activities 5 0.004 0.002 50 000 4 0.010 0.005 20 000 3 0.020 0.010 10 000 2 0.040 0.020 5 000 1 0.100 0.050 2 000 Results: The suit is classified 5.Frendh vems on ody shaI b. ld Mmen dis"pu ECEC 97 / 0028 Page 8/12 2.3.4.1. Seams / Welds (paragraph 4.4.1 of the project Norm pr EN 1073-1)A sample of each type of seam/weld is tested according to the Norm ISO 5082 (annex 2).The seam performance level is according to the following classification:

Class Seam resistance (N)5 > 300 4 > 125 3 > 75 2 > 50 1 >30 The tests have been applied to the following welds:-Assemblage hood/suit-Assemblage hood/visor

-Assemblage hood level-Assemblage belt level-Assemblage of the strengthening pieces (elbow and knees)-Assemblage at the level of the arms, back and sides Results: All the welds are classified 4.2.3.4.2. Joins and Assemblages (paragraph 4.4.2. -project Norm pr EN 1073-1)This suit has no removable parts. This paragraph is aimless.2.3.4.3. Visors (paragraph 4.5. -project Norm pr EN 1073-1)The distorsion of vision is measured, during the Practical Performance Test, by reading letters on an optometrical chart placed at a distance of 5 m; The loss of vision must not exced 2 degrees.The mechanical resistance test of the visor is according to the Norm EN 146 (paragraph 6.7.).Results: Distortion of vision: Up to requirement.

Mechanical resistance:

up to requirement.

Frnrzh version ory s"Irl be used oen dispute ECEC 97/ 0028 Page 9/12 2.3.6. Air supply system (paragraph 4.6. of the project Norm pr EN 1073-1)The couplings and connections must comply with the requirements of the paragraphs 6.7.1., 6.7.2., and 6.11.7. of the Norm EN 270. The connection between the compressed air supply system and the suit must resist to a 250 N pull.Result: requirement entirely fulfilled.

2.3.7. Breathing

Hose (paragraph 4.7. of the project Norm pr EN 1073-1)Tests are performed according to the Norm 270 (paragraph 7.2. and 7.6). The pipes must not block the movements nor cause a rupture of the air supply during the Practical Performance Test.Result: No constraint.

2.3.8. Air flow rate warning device (paragraph 4.9. of the project Norm pr EN 1073-1)If a warning is fitted, it must comply to the Norm EN 270 (paragraph 6.13.3). The test must be carried out according to the Norm EN 270 (paragraph 7.12). The sound level must be between 85 dB(A) and 90 dB(A).Result: Aimless (there is no warning device).2.3.9. Air supply valve (paragraph 4.10 of the project Norm pr EN 1073-1)For the air supply pressure specified by the manufacturer, the air supply valve must be able to adjust the air flow between the minimum and maximum values as indicated in the technical manual. It must be impossible to close the valve in order to reduce the air flow supply below the minimum flow rate as specified by the manufacturer.

Result: Requirements entirely fulfilled.

Notice: The MURUROA does not include low air flow indicator.

2.3.10.Exhaust devices (paragraph 4.11. of the project Norm pr EN 1073-1)The exhaust devices must work correctly after the testing of the pressure in the suit, during the Practical Performance Test and during the determination of the Fit Factor. Test in accordance with the Norm 1073-1 (paragraph 5.6.).Results: Good valves working.Pull resistance superior to the fixed limit.Frnh version only shull be se.d when dispute ECEC 97/ 0028 Page 10/12 2.3.11.Pressure in the suit (Paragraph 4.12. of the project Norm pr EN 1073-1)During the activity sequence as specified, the overpressure shall not exceed 1000 Pa mean and 2000 Pa peak. A positive pressure shall be maintained.

Test is performed with maximum air flow rate D max, as stipulated in paragraph 2.3.2. on three different suits.Result: Requirements entirely fulfilled.

2.3.12.Carbon dioxide content of the inhalation air (paragraph 4.13.-project Norm pr EN 1073-1)The C02 content of the inhalation air, determined at the minimum air flow rate, shall not exceed an average of 1 % (by volume), tested according to the Norm 270 (paragraph 7.15)with the minimum air flow rate D min indicated in paragraph 2.3.2, on three diffeent suits.Result: Requirement entirely fulfilled.

2.3.13. Noise associated with the air supply to the suit (paragraph 4.14 -project Norm pr EN 1073-1)Test according to the Norm 270 (paragraph 7.16). The noise measured in the suit at the ears shall not exceed 80 dB(A) at the maximum air flow rate as indicated by the manufacturer.Tested at the maximum air flow rate D max as stipulated in paragraph 2.3.2, on three different suits.Result: Requirement entirely fulfilled.

3. CHECKINGS 3.1. MARKING (paragraph 6 of the Norm project pr EN 1073-1)The marking complies with the requirements of the Norms EN 340 and EN 1073-1. According to the Decree dated February 7 T 1997 "relative to EEC marking of the working equipment and of the Personal Protective Equipment", it includes the distinctive number of the entitled organisation for the procedure of controls of the manufactured PPE (article 11 of the EEC Directive 89/686/EEC).

The symbol '"i is included in the pictogram, in order to show that the manufacturer instructions should be read by the user..3.2. MANUFACTURER INFORMATION (Paragraph 7 of the project Norm pr 1073-1)Information comply with the specifications of the project of Norm pr 1073-1. They include the Directions for use, the conditions of use, the specific limits and restraints.

Thes documents will be corrected in order to take into account the tests results as mentionned in this ECEC.Fr-ndh vomion ody hlu11 bh used Mhn diputo ECEC 97/0028 Page 11/12 3.3. MAINTENANCE MARKING This is aimless, the suit being for one single use only.4. CONCLUSIONS Upon presentation of the tests results, the Ventilated

-pressurised for a single use only, MURUROAV4 F1 -ref. 8481X1T is certified to ensure a protection against radioactive contamination according the following specified limits: Minimum air flow rate: Maximum air flow rate: 27,0 m 3.h '.64,2 m 3.h-'.The MURUROA V4 F1 is delivered without low air flow rate indicator.

Before using it, the user will have at his disposal the necessary devices to check that the minimum air flow rate, as specified by the manufacturer is reached or over reached before and during the use of the suit.Fnch verson only shall be sed Wmen dispute ECEC 97/ 0028 Page 12/12 ANNEX 1 Description and references of the equipment certified in the EC Type Examination Certificate The different models of equipment, whose generic appellation is MURUROA V4 F1 ref. 8481XIIT, and which are the subject of this EEC type examination certificate (ECEC), are only different on the following points:-The type of pipe butt connecting the equipment to the breathable compressed air supply system.-The size.X indicates the type of pipe butt according to the following values: Type of butt for connection to References of MURUROA References the compressed air supply V4 F1 associated system X=2 Staubli RBE 06 6150 848121 T X=3 Staubli RBE 06 848131 T"detrompeur" X=4 CEJN 342 848141 T X=8 Staubli RBE 06 QR 848181 T T indicates the size of the suit according to the following values: REFERENCE Height ( cm) Waist measurement (cm)T=0 152-164 56-64 T=1 164-170 64-68 T=2 170-176 68-72 T=3 176-182 72-76 T=4 182-188 76-80 T=5 188-200 80-88 French velmon only shId be Ed when dispte United States Nuclear Regulatory Commission Enclosure 4 to Attachment to PE&RAS-05-066 Page 1 of 4 Delta Protection MURUROA V4 MTH2 SUPPLEMENTAL TEST RESULTS United States Nuclear Regulatory Commission Enclosure 4 to Attachment to PE&RAS-05-066 Page 2 of 4 DPEA/STESR/CTHEN/02-642 Page 1/2 Test Results carried out on the full encapsulated suit MTH2 ref. 841442T For the EC Type Examination Certificate N 0 0073/197/1 62/01/96/0001 You will find below the detailed results for this equipment in accordance with the Essential Requirements of the European Standard pr EN 1073-1 (revision Nov 1995). Other results that are not pointed out in this report are already written in the EC TYPE Examination certificate (dated December 10t 1997)I -Air Flow entering the suit when connected to a 6 bar feeding pressure (paragraph

.5.2.8. of the EC Type Examination Certificate) uit Entrance valve position Air flow feeding pressure air flow (m3Ih I num Bar I psig llmn/ cfm)I Fully open 5,5 / 77 66/1100/ 38 I Closed 6,0 /87 30/500 / 17 2 Fully open 5,5 / 77 65 / 1080 /37,8 2 closed 6,0 / 87 31 /516 / 18 2 -Carbon dioxide content of the inhalation air when measured at the minimum air flow (paragraph 5.2.13. of the EC Examination Tvpe)it Feeding pressure Air flow C02 contents(%)

numbs Bar I psig M3lh I cfm 1 6/87 30/ 17 0,85 2 6/87 31 / 18 0,80 3 -Noise level associated with the air supply to the suit when tested at the maximum air flow rate (paragraph 5.2.14 of the EC Examination TyPe)Feeding pressure Air flow Noise level (dB)numBar psig M3/h; cfm 1 5,5 / 77 66/38 76,8 2 5,5 / 77 65 / 37,8 78,5 United States Nuclear Regulatory Commission Enclosure 4 to Attachment to PE&RAS-05-066 Page 3 of 4 Page2/2 4 -Inward leakage average- Fit Factor measured at the minimal air flow of 4501/mn (paragraph 2.3.3. of the CE Examination Tvpe)Suit n'1 2 Exercise Air flow m3lh/ llmn I cfm 30 / 500 / 17 31 /516 / 18 Standing still 130 000 130 000 Walking ( 5 km/h) 59 500 50 000 Moving arms up and down 125 000 125 000 above head Continuous squats 65 000 81 250 Bending forward 100 000 92 850 Person twisting at waist 115 000 130 000 Standing still 130 000 130 000 Average 103 500 103 440 5 -Pressure in the suit when measured at the maximum air flow when suit connected under 5,5 bar (77psin) feeding pressure (paragraph 4.12.of the EC Examination Tvpe)Suit n 1 2 Exercise P ave/ P min/ Pmax P ave; P min, P Max.daPa. daPa Standing still 40 --38 --Walking ( 5 km/h) 40 23 74 100 61 128 Moving arms up and down 40 17 62 46 18 72 above head Continuous squats 42 4 86 56 3 110 Bending forward 52 3 104 74 0 162 Person twisting at waist 38 18 58 46 20 110 Person crawling 37 --40 --For Information:

Both overboots are breaked at the end of the test United States Nuclear Regulatory Commission Enclosure 4 to Attachment to PE&RAS-05-066 Page 4 of 4 6 Over pressure and fit factor when person crawling on the floof as indicated in paragraph 4.12 and 5.2.2 of the pr EN 1073-1dated 1995 7 Screen:( paragraph 5.2.5 )-Distortion of the vision: none-Mechanical resistance:

no incidence on the screen.

United States Nuclear Regulatory Commission Enclosure 5 to Attachment to PE&RAS-05-066 Page 1 of3 Delta Protection MURUROA V4 Fl SUPPLEMENTAL TEST RESULTS United States Nuclear Regulatory Commission Enclosure 5 to Attachment to PE&RAS-05-066 Page 2 of 3 DPEAISTESR/CTHEN/97-599 Page '2 Test Results carried out on the full encapsulated suit MURUROAV4FI ref. 8481X1T For the EC Type Examination Certificate N 0 0073/197/162/12/97/0028 You will find below the detailed results taken in account for being able to statue on the conformity of this equipment in accordance with the Essential Requirements of the European Standard pr EN 1073-1 .Other results those are non pointed out in this report are already written in the EC TYPE Examination certificate (dated December 1Oth 1997)I -Air Flow entering the suit when connected to a 6 bar feeding pressure (Paragraph 2.3.2. of the EC Type Examination Certificate) b Minimum air flow(lUmn)

Maximum air flow (I/mn)1 508 1050 2 516 1070 3 508 1050 2 -Carbon dioxide content of the inhalation air when measured at the minimum air flow of 450 I/mn (Paragraph 2.3.12. of the EC Examination Type)Test NO1 C02 contents(%)

Test N 0 2 C02 contents(%)

1 0,86 0,93 2 0,68 0,68 3 0,75 0,82 3 -Noise level associated with the air supply to the suit when tested at the maximum air flow rate at 6 bar (paragraph 2.3.13 of the EC Examination Tvpe),nber Maximum air flow(Umn)

Noise level (dB)1 1050 77,2 2 1070 75,1 3 1050 77,6 United States Nuclear Regulatory Commission Enclosure 5 to Attachment to PE&RAS-05-066 Page 3 of 3 F 4 -Inward leakaae averaae- Fit Factor measured at the minimal air flow of 45011mn'age2/2 (paragraph 2.3.3. of the CE Examination Type)Suit n 0 1 2 3 Exercise Standing still > 120 000 > 120 000 > 120 000 Walking (5 km/h) 76 700 90 900 66 000 Moving arms up and down 113 800 > 120 000 113 800 above head Continuous squats 30 000 41 700 50 000 Bending forward 110 000 103 400 91 700 Person twisting at waist > 120 000 > 120 000 > 120 000 Person crawling 55 000 > 120 000 31 400 5 -Pressure in the suit when measured at the maximum air flow when suit connected under 6 bar feeding pressure (paragraph 2.3.11 .of the EC Examination Type)Suitn' 1 2 3 Exercise P min(Pa) P Max. P min(Pa) P Max. P min(Pa) P Max.Standing still 275 280 295 305 275 280 Walking (5 km/h) 200 800 300 900 600 900 Moving arms up and down 150 400 160 420 250 800 above head Continuous squats 30 900 30 1050 70 1700 Bending forward 80 1550 60 1900 100 1900 Person twisting at waist 140 500 160 420 160 650 Person crawling 160 900 150 850 250 1050 6 Air supply system (paragraph 4- 6 of the Pr EN 1073-1)In accordance with the paragraph 4.6; the connexion between the compressed air supply system and the suit has been tested for a steady pull of 250 N. The three suits have been tested successfully.

However, it appears a deformation of the fabric, near the regulation air flow device. A reinforced area could certainly avoid this deformation.

United States Nuclear Regulatory Commission Enclosure 6 to Attachment to PE&RAS-05-066 Page 1 of 2 Delta Protection MURUROA V4 MTH2 And F1 INSTRUCTIONS FOR USE United States Nuclear Regulatory Commission Enclosure 6 to Attachment to PE&RAS-05-066 Page 2 of 2 NO/841442T INDICE: e MURUROAV4 lDATE: 12/00 MTH2 And F1 DELTA PROTEC PAGE:1/1 04 66 89 18 36 INSTRUCTIONS FOR USE Preliminary remarks: This clothing is to be used under the authority of the person responsible for issuing the equipment for its dedicated use:-the clothing offers the necessary protection for it's intended use.-Breathable air *network, hoses with connectors compatible with that of the clothing, are actually available on site and that they are capable of supplying a sufficient quantity of air: minimum flow rate 500 liters/min.

+/- 10% at 6 Bars; (17 cfm at 85 psig)maximum flow rate 1100 liters/min.

+/- 10% at 6 Bars; (38cfm at 85 psig)DRESSING-The wearer, with a helper, visually inspects the condition of the garment and its components, then removes the shipping protection (cardboard on the visor and inside the garment, and removable"plastic protection" from the visor).-He enters through the rear opening of the garment and insures that his legs are in the garment.-Connects to the breathable air network by passing the supply line through the loop at the rear of the garment, at the same height as the supply valve.-Connects, if used, the MURUPHONE system, or other communication device through the safety loop and communication loop and finishes dressing.-The helper zips up the dual zipper system and applies a large strip of adhesive tape to the upper extremity of the second zipper at the top to ensure air tightness.

He then, ties the over boot laces around the ankles.-The wearer can control the air supply by turning the adjustment knob. The correct functioning of the supply flow valve and the over pressure valves can be verified by crouching down rapidly a few times.-He then is free to enter the work zone.UNDRESSING

-Undressing may be done in the following manner. While the garment is still being supplied with air, the helper pulls on the orange undressing strip, which runs from one wrist to the other over the hood. Once the undressing strip is removed, the helper can split the suit shell by pulling on the hooded area and separating the suit into two identical pieces. The helper rolls up the front and rear parts in a way that traps the contamination and avoids all contact with the wearer of the garment. (Please consult our video for detailed undressing techniques).

IMPORTANT-Leave the work zone immediately if the clothing deflates during the work phase evolution .If the helmet fogs, or if the person has a feeling of excessive warmth.-Remember that the clothing remains pressurised for a few minutes in case of an air supply failure STORAGE In the original packaging; out of the light; between + 5oC and + 45 0 C.( 41 0 F and 113'F)USAGE The air supply should be between + 1 5 0 C and + 45 0 C. (59 0 F and 11 3 0 F)EXPIRY DATE The clothing should be used by the third year from the date of manufacture.

CLEANING Not necessary for this type of equipment which is for a single use only.EMERGENCY FEATURES-Air outside of the garment can be breathed by removing the safety strip at the front of the helmet/hood.

-The undressing strip, removed by the wearer, enables the wearer to self escape t in less than 5 seconds.A Breathable air: see the EN 132 standard.