ML061020034
| ML061020034 | |
| Person / Time | |
|---|---|
| Site: | Beaver Valley, Davis Besse, Perry |
| Issue date: | 06/05/2006 |
| From: | Jabbour K Plant Licensing Branch III-2 |
| To: | Leidich G FirstEnergy Nuclear Operating Co |
| K. Jabbour, X1496 | |
| References | |
| TAC MC9150, TAC MC9151, TAC MC9152, TAC MC9153 | |
| Download: ML061020034 (12) | |
Text
June 5, 2006 Mr. Gary R. Leidich President and Chief Nuclear Officer FirstEnergy Nuclear Operating Company 76 South Main Street Akron, OH 44308
SUBJECT:
BEAVER VALLEY POWER STATION, UNITS 1 AND 2; DAVIS-BASSE NUCLEAR POWER STATION, UNIT 1; AND PERRY NUCLEAR POWER PLANT, UNIT 1 - USE OF FRENCH DESIGNED RESPIRATORY PROTECTION EQUIPMENT (TAC NOS. MC9150, MC9151, MC9152, AND MC9153)
Dear Mr. Leidich:
By letter to the Nuclear Regulatory Commission dated December 6, 2005, as supplemented by letter dated March 6, 2006, you submitted a request to use an assigned protection factor (APF) greater than that listed in Appendix A to Title 10 of the Code of Federal Regulations, Part 20, for persons working in areas of airborne radioactivity with certain non-National Institute for Occupational Safety and Health-certified respiratory protection equipment. Specifically, you requested authorization to use at Beaver Valley Power Station, Units 1 and 2; Davis-Besse Nuclear Power Station, Unit 1; and Perry Nuclear Power Plant, Unit 1, an APF of 5,000 with the Mururoa atmosphere-supplying suit, model V4MTH2, manufactured by Delta Protection.
Enclosed is our safety evaluation that concludes that authorization of your request is acceptable. If you have any questions regarding this matter, please contact me at (301) 415-1496 or knj@nrc.gov.
Sincerely,
/RA/
Kahtan N. Jabbour, Sr. Project Manager Plant Licensing Branch III-2 Division of Operating Reactor Licensing Office of Nuclear Reactor Regulation Docket Nos. 50-334, 50-412, 50-346, and 50-440
Enclosure:
Safety Evaluation cc w/encl: See next page
- no legal objections OFFICE LPL3-2/PM LPL3-2/LA IHPB/BC OGC LPL3-2/BC NAME KJabbour:ca DClarke TFrye AHodgdon*NLO DCollins DATE 5/ 25/2006 5 /26/2006 5/ 05/2006 5 /16/2006 6 /05/2006
ENCLOSURE SAFETY EVALUATION BY THE OFFICE OF NUCLEAR REACTOR REGULATION USE OF AN ASSISGNED PROTECTION FACTOR OF 5,000 WITH FRENCH-DESIGNED RESPIRATORY PROTECTION EQUIPMENT FIRST ENERGY NUCLEAR OPERATING COMPANY BEAVER VALLEY POWER STATION, UNITS 1 AND 2 DAVIS-BESSE NUCLEAR POWER STATION, UNIT 1 PERRY NUCLEAR POWER PLANT, UNIT 1 DOCKET NOS. 50-334, 50-412, 50-346 AND 50-440
1.0 INTRODUCTION
By letter to the Nuclear Regulatory Commission (NRC) dated December 6, 2005, as supplemented by letter dated March 6, 2006, FirstEnergy Nuclear Operating Company (FENOC, the licensee) submitted a request to use an assigned protection factor (APF) greater than that listed in Appendix A to Title 10 of the Code of Federal Regulations (10 CFR) Part 20, Standards for Protection Against Radiation, for persons working in areas of airborne radioactivity with certain non-National Institute for Occupational Safety and Health (NIOSH)-certified respiratory protection equipment. Specifically, the licensee requested authorization to use at Beaver Valley Power Station, Units 1 and 2; Davis-Besse Nuclear Power Station, Unit 1; and Perry Nuclear Power Plant, Unit 1, an APF of 5,000 with the Mururoa atmosphere-supplying suit, model V4MTH2, manufactured by Delta Protection, France (hereafter referred to as the Delta suit). Delta Protection, a French company, is part of the Bacou-Dalloz group of companies specializing in the manufacture and supply of personal protective equipment.
2.0 REGULATORY EVALUATION
Subpart H, Respiratory Protection and Controls to Restrict Internal Exposure in Restricted Areas, to 10 CFR Part 20 concerns the use of respiratory protection equipment for protection 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 NIOSH. Section 20.1703(b) states that a licensee shall submit an application to the NRC for authorized use of respiratory protection equipment that has not been tested and certified by NIOSH.
10 CFR Part 20, Appendix A, Assigned Protection Factors for Respirators, does not provide an APF for atmosphere supplying respirator (air-line respirator) suits in a continuous-flow operating mode. Instead, it references footnote (g) which 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 testing, are met (i.e., Section 20.1703).
Section 20.1705, Application for use of higher APFs, states that a licensee shall obtain NRC authorization before using APFs in excess of those specified in Appendix A to CFR Part 20.
Since Appendix A does not provide an APF for atmosphere supplying respirator (air-line respirator) suits in a continuous-flow operating mode, the licensee must obtain NRC approval to take credit for an APF for the French-designed respiratory protection equipment.
Criteria and background information used for the NRC staffs technical evaluation include 10 CFR Part 20, Subpart H; 10 CFR Part 19, Notices, Instruments and Reports to Workers:
Inspection and Investigations; Section 19.12, Instruction to Workers; Regulatory Guide 8.15, Revision 1, Acceptable Programs for Respiratory Protection; NUREG/CR-0041, Revision 1, Manual of Respiratory Protection Against Airborne Radioactive Materials; 42 CFR Part 84, which addresses NIOSH testing and certification regulations; Los Alamos National Laboratory Report LA-101560MS, Acceptance Testing Procedures for Air-Line Supplied Air Suits; and American National Standards Institute (ANSI) Z88.2-1992, American National Standard Practices for Regulatory Protection.
3.0 TECHNICAL EVALUATION
NRC guidance provided in NUREG/CR-0041 encourages the use of supplied-air suits, noting that in certain work environments supplied-air suits may be the best respiratory device when considering respiratory protection, heat stress, trying to minimize skin contamination, and trying to maintain worker doses as low as is reasonably achievable (ALARA).
Testing conducted by the Institute for Nuclear Protection and Security, the European certifying agency (comparable to NIOSH), and over 20 years of successful use in European power plants of similar certified suits form the basis for the licensees request. The licensee has requested authorization to use, and to take credit for, the protection provided by the suit during normal (non-emergency) operations. The suit is made by Delta Protection, and is identified as Mururoa V4 MTH2 (Certificate No. 0073/197/162/01/96/0001). The model has been approved as a single-use suit (a suit that is disposed of after one use), and the licensee proposes to use the suit in the approved configurations, relative to the suits form, fit, and function.
The European Standard EN 1073-1 (January 1998), Protective Clothing Against Radioactive Contamination, Part 1: Requirements and Test Methods for Ventilated Protective Clothing Against Particulate Radioactive Contamination, provided testing and acceptance criteria used for certification of the suits. This standard is generally consistent with the pertinent acceptance criteria provided in Los Alamos National Laboratory Report LA-10156-MS, which is used to test and authorize the use of air-supplied suits at Department of Energy sites.
The certification-testing regime was broadly based and encompassed a range of various functional areas, including: suit material strength, tear and puncture resistance, material flammability, wearer comfort, noise level, wearer visibility, air flow, carbon dioxide concentrations, and degree of contaminate in-leakage during a series of varied simulated work practices and exercises. The Mururoa V4 MTH2 model passed all required tests, and provided a measured average protection level (fit factor) of 50,000. A fit factor, which was developed in a simulated work environment, is the ratio of contaminate concentration outside the suit to the contaminate concentration inside the suit. Given an overall measured fit factor of 50,000 (averaged over all exercise activities), allowing an APF of 5,000 provides a conservative safety factor for estimating the actual protection provided to the user by the suit in the actual working environment. APFs are generally lower than fit factors for all types of respirators, since workplace demands are typically greater on the user of the respirator than are laboratory conditions and simulated work activities due to such workplace factors as higher heat and humidity conditions, longer work durations, and greater worker fatigue.
In general, when compared with other air-fed respirators, the Mururoa V4 MTH2 Delta Suit provides the following advantages to the user: (1) dual zippers (metal zipper inside and plastic zipper outside); (2) a welded sleeve-to-insert communication cable; (3) a removable strip near the mouth that could be used for emergency breathing in case of loss of supplied air; (4) an egress strip stretching from the left arm, over the head, and to the right arm that is used for undressing and for self-rescue in an emergency, such as loss of supplied air; (5) an air intake located at the waist with a built-in regulator that can adjust, but not block, air flow; (6) two exhaust valves that ensure the suit remains airtight should an event block/pinch the air supply line (prevents any aspiration of contaminants if supplied air is lost); (7) a very low noise level at maximum air flow; and (8) air flow to the hands, feet, face, and chest.
Safety features also include light-weight (approximately 2 lbs.), one-piece construction with welded gloves and booties with tie straps. The helmet is made with PVC material that provides distortion-free vision and is large enough for wearing a headset. Noise levels are less than 80 decibels at maximum air flow, and air flow can be adjusted by the user for comfort, but can not be shut off below the required minimum air flow. The Mururoa V4 MTH2 Delta Suit is designed for usage temperatures ranging between + 5 EC to + 55 EC. The suit is constructed with reinforced elbow, knee, and crotch areas.
The licensee currently uses air-supplied hoods (commonly know as bubble hoods) for jobs involving overhead-contaminated water or high potential for skin contamination from discrete radioactive particles. Because the bubble hoods do not cover the hands or feet, workers have to wear additional protective clothing to minimize potential skin contaminations. The Delta suits offer a better alternative (with their unitized construction and ease of removal) and would protect the worker much better against facial/skin contamination and airborne radioactivity than the bubble hoods currently in use. Use of the Delta suits would assist in licensee efforts to control contamination incidents and to prevent intakes during operational activities at all FENOC facilities. The Delta suit is preferable to the currently used bubble hood because the safety features of the Delta suit eliminate the need for using a standby rescue person (per 10 CFR 20.1703(f)), thus helping to minimize occupational radiation exposures. In addition, the ease of removal features provide a way to undress that minimizes the potential for personnel contamination events and an easy escape.
Upon loss of supplied air to the suit, a worker can easily extricate himself or herself from the suit by pulling off the mouth strip and then opening the hood, or by pulling the egress strip from the forearm to the head. Based on these safety features, the NRC staff finds that the suit design provides for easy and effective self-rescue, thus, avoiding asphyxiation if the air supply is interrupted or lost.
Subpart H to 10 CFR Part 20 establishes the requirements for implementing a respiratory protection program. These programmatic requirements ensure that worker doses from airborne radioactive materials are maintained ALARA. The licensee intends to integrate the use of the Delta suits into their existing, ongoing respiratory protection program that satisfies 10 CFR Part 20 requirements. The NRC staff finds this approach acceptable. The following summary of controls and program elements generally follows the specific 10 CFR Part 20 requirements pertinent to the use of air-supplied suits. Since the licensee has a viable, ongoing respiratory protection program, only items pertinent and specific to the use of the Delta suits are discussed below.
1.
Section 20.1703(c) requires, among other things, written procedures governing the training of respirator users (workers). The Delta suits will be integrated into the FENOC radiological respiratory protection programs using the manufacturers recommendations which are found in the following two documents: (1) Mururoa V4 Fully Enclosed Suit - General Description (dated June 9, 2001) and (2) M.T.H. 2 - Instructions for Use (dated December, 2000). New lesson plans will be developed to train workers on the Delta suit features, donning, use and removal and use of mouth strip, and tear off strips for routine and emergency egress. Radiation protection personnel will be provided additional training for selection, approval, issue, equipment set-up operations, and maintenance instructions for the Delta suit.
2.
In the event that there are any defects identified in a Delta suit, the licensee has made a commitment to enter the issue into the FENOC Corrective Action Program and will report it to the manufacturer.
3.
The Delta suits are single use only. The suits will only be used during normal (non-emergency) operations and will not be used in atmospheres that are immediately deleterious to life and health.
4.0 CONCLUSION
On the basis of the testing data provided, and when used in accordance with the applicable manufacturers instructions (as noted in 1. above), licensee commitments, and requirements of Subpart H of 10 CFR Part 20, the NRC staff concludes that the licensees request to use, and take credit for an APF of 5,000, with the Mururoa V4 MTH2 supplied air suits, is acceptable.
Principal Contributor: R. Schmitt Date: June 5, 2006
Beaver Valley Power Station, Unit Nos. 1 and 2 cc:
Gary R. Leidich President and Chief Nuclear Officer FirstEnergy Nuclear Operating Company Mail Stop A-GO-19 76 South Main Street Akron, OH 44308 Joseph J. Hagan Senior Vice President of Operations and Chief Operating Officer FirstEnergy Nuclear Operating Company Mail Stop A-GO-14 76 South Main Street Akron, OH 44308 Danny L. Pace Senior Vice President, Fleet Engineering FirstEnergy Nuclear Operating Company Mail Stop A-GO-14 76 South Main Street Akron, OH 44308 Jeannie M. Rinckel Vice President, Fleet Oversight FirstEnergy Nuclear Operating Company Mail Stop A-GO-14 76 South Main Street Akron, OH 44308 David W. Jenkins, Attorney FirstEnergy Corporation Mail Stop A-GO-18 76 South Main Street Akron, OH 44308 Manager, Fleet Licensing FirstEnergy Nuclear Operating Company Mail Stop A-GHE-107 395 Ghent Road Akron, OH 44333 Vice President FirstEnergy Nuclear Operating Company Beaver Valley Power Station Mail Stop A-BV-SEB1 P.O. Box 4, Route 168 Shippingport, PA 15077 Lew W. Myers Executive Vice President, Special Projects FirstEnergy Nuclear Operating Company Beaver Valley Power Station Mail Stop A-BV-SGRP P.O. Box 4, Route 168 Shippingport, PA 15077 Manager, Site Regulatory Compliance FirstEnergy Nuclear Operating Company Beaver Valley Power Station Mail Stop A-BV-A P.O. Box 4, Route 168 Shippingport, PA 15077 Commissioner James R. Lewis West Virginia Division of Labor 749-B, Building No. 6 Capitol Complex Charleston, WV 25305 Director, Utilities Department Public Utilities Commission 180 East Broad Street Columbus, OH 43266-0573 Director, Pennsylvania Emergency Management Agency 2605 Interstate Dr.
Harrisburg, PA 17110-9364 Ohio EPA-DERR ATTN: Zack A. Clayton P.O. Box 1049 Columbus, OH 43266-0149
Beaver Valley Power Station, Unit Nos. 1 and 2 (continued) cc:
Dr. Judith Johnsrud Environmental Coalition on Nuclear Power Sierra Club 433 Orlando Avenue State College, PA 16803 Director Bureau of Radiation Protection Pennsylvania Department of Environmental Protection Rachel Carson State Office Building P.O. Box 8469 Harrisburg, PA 17105-8469 Mayor of the Borough of Shippingport P.O. Box 3 Shippingport, PA 15077 Regional Administrator, Region I U.S. Nuclear Regulatory Commission 475 Allendale Road King of Prussia, PA 19406 Resident Inspector U.S. Nuclear Regulatory Commission P.O. Box 298 Shippingport, PA 15077
Davis-Besse Nuclear Power Station, Unit 1 cc:
Manager - Regulatory Affairs FirstEnergy Nuclear Operating Company Davis-Besse Nuclear Power Station 5501 North State - Route 2 Oak Harbor, OH 43449-9760 Director, Ohio Department of Commerce Division of Industrial Compliance Bureau of Operations & Maintenance 6606 Tussing Road P.O. Box 4009 Reynoldsburg, OH 43068-9009 Regional Administrator U.S. Nuclear Regulatory Commission 801 Warrenville Road Lisle, IL 60523-4351 Resident Inspector U.S. Nuclear Regulatory Commission 5503 North State Route 2 Oak Harbor, OH 43449-9760 Barry Allen, Plant Manager FirstEnergy Nuclear Operating Company Davis-Besse Nuclear Power Station 5501 North State - Route 2 Oak Harbor, OH 43449-9760 Dennis Clum Radiological Assistance Section Supervisor Bureau of Radiation Protection Ohio Department of Health P.O. Box 118 Columbus, OH 43266-0118 Carol OClaire, Chief, Radiological Branch Ohio Emergency Management Agency 2855 West Dublin Granville Road Columbus, OH 43235-2206 Zack A. Clayton DERR Ohio Environmental Protection Agency P.O. Box 1049 Columbus, OH 43266-0149 State of Ohio Public Utilities Commission 180 East Broad Street Columbus, OH 43266-0573 Attorney General Office of Attorney General 30 East Broad Street Columbus, OH 43216 President, Board of County Commissioners of Ottawa County Port Clinton, OH 43252 President, Board of County Commissioners of Lucas County One Government Center, Suite 800 Toledo, OH 43604-6506 The Honorable Dennis J. Kucinich United States House of Representatives Washington, D.C. 20515 The Honorable Dennis J. Kucinich United States House of Representatives 14400 Detroit Avenue Lakewood, OH 44107 Gary R. Leidich President and Chief Nuclear Officer FirstEnergy Nuclear Operating Company Mail Stop A-GO-19 76 South Main Street Akron, OH 44308 Joseph J. Hagan Senior Vice President of Operations and Chief Operating Officer FirstEnergy Nuclear Operating Company Mail Stop A-GO-14 76 South Main Street Akron, OH 44308 David W. Jenkins, Attorney FirstEnergy Corporation Mail Stop A-GO-18 76 South Main Street Akron, OH 44308
Davis-Besse Nuclear Power Station, Unit 1 cc:
Danny L. Pace Senior Vice President, Fleet Engineering FirstEnergy Nuclear Operating Company Mail Stop A-GO-14 76 South Main Street Akron, OH 44308 Manager, Fleet Licensing FirstEnergy Nuclear Operating Company Mail Stop A-GHE-107 395 Ghent Road Akron, OH 44333 Manager, Site Regulatory Compliance FirstEnergy Nuclear Operating Company Davis-Besse Nuclear Power Station Mail Stop A-DB-3065 5501 North State Route 2 Oak Harbor, OH 43449-9760 Jeannie M. Rinckel Vice President, Fleet Oversight FirstEnergy Nuclear Operating Company Mail Stop A-GO-14 76 South Main Street Akron, OH 44308
Perry Nuclear Power Plant, Unit 1 cc:
David W. Jenkins, Attorney FirstEnergy Corporation Mail Stop A-GO-18 76 South Main Street Akron, OH 44308 Resident Inspector's Office U.S. Nuclear Regulatory Commission P.O. Box 331 Perry, OH 44081-0331 Regional Administrator, Region III U.S. Nuclear Regulatory Commission 2443 Warrenville Road Lisle, IL 60532-4531 Sue Hiatt OCRE Interim Representative 8275 Munson Mentor, OH 44060 Manager - Regulatory Compliance FirstEnergy Nuclear Operating Company Perry Nuclear Power Plant P.O. Box 97, A210 10 Center Road Perry, OH 44081 Mayor, Village of North Perry North Perry Village Hall 4449 Lockwood Road North Perry Village, OH 44081 Donna Owens, Director Ohio Department of Commerce Division of Industrial Compliance Bureau of Operations & Maintenance 6606 Tussing Road P.O. Box 4009 Reynoldsburg, OH 43068-9009 Carol OClaire, Chief, Radiological Branch Ohio Emergency Management Agency 2855 West Dublin Granville Road Columbus, OH 43235-7150 Mayor, Village of Perry P.O. Box 100 Perry, OH 44081-0100 Dennis Clum Radiological Assistance Section Supervisor Bureau of Radiation Protection Ohio Department of Health P.O. Box 118 Columbus, OH 43266-0118 Zack A. Clayton DERR Ohio Environmental Protection Agency ATTN: Mr. Zack A. Clayton P.O. Box 1049 Columbus, OH 43266-0149 Chairman Perry Township Board of Trustees 3750 Center Road, Box 65 Perry, OH 44081 Daniel Z. Fisher Transportation Department Public Utilities Commission 180 East Broad Street Columbus, OH 43215-3793 Joseph J. Hagan Senior Vice President of Operations and Chief Operating Officer First Energy Nuclear Operating Company Mail Stop A-GO-14 76 South Main Street Akron, OH 44308 Director, Regulatory Affairs FirstEnergy Nuclear Operating Company 395 Ghent Road Akron, OH 44333 Gary R. Leidich President and Chief Nuclear Officer FirstEnergy Nuclear Operating Company Mail Stop A-GO-19 76 South Main Street Akron, OH 44308
Perry Nuclear Power Plant, Unit 1 cc:
Danny L. Pace Senior Vice President, Fleet Engineering FirstEnergy Nuclear Operating Company Mail Stop A-GO-14 76 South Main Street Akron, OH 44308 Jeannie M. Rinckel Vice President, Fleet Oversight FirstEnergy Nuclear Operating Company Mail Stop A-GO-14 76 South Main Street Akron, OH 44308 Manager, Fleet Licensing FirstEnergy Nuclear Operating Company Mail Stop A-GHE-107 395 Ghent Road Akron, OH 44333 L. W. Pearce Vice President FirstEnergy Nuclear Operating Company Perry Nuclear Power Plant Mail Stop A-PY-A290 P.O. Box 97, 10 Center Road Perry, OH 44081-0097 Manager, Site Regulatory Compliance FirstEnergy Nuclear Operating Company Perry Nuclear Power Plant Mail Stop A-PY-A200 P.O. Box 97, 10 Center Road Perry, OH 44081-0097