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Request for Use of Delta Protection MURUROA V4F1 R Supplied Air Suits and the MURUROA BLU Suit Systems

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Request for Use of Delta Protection MURUROA V4F1 R Supplied Air Suits and the MURUROA BLU Suit Systems Charles R. Pierce Southern Nuclear Re gul atory Affai rs Director Operating Company, Inc. 40 Inverness Ce nt er Parkway Post Office Box 1295 Birmingham, Alabama 3520 1 Te l 205.992.7872 Fax 205.992 .7 60 1 SOUTHERN'\' COMPANY May 16, 2013 Docket Nos.: 50-321 50-348 50-424 NL-12-1331 50-366 50-364 50-425 U. S. Nuclear Regulatory Commission ATIN: Document Control Desk Washington, D. C. 20555-0001 Edwin I. Hatch Nuclear Plant Joseph M. Farley Nuclear Plant Vogtle Electric Generating Plant Request for Use of Delta Protection MURUROA V4F1 R Supplied Air Suits and the MURUROA BLU Suit Systems Ladies and Gentlemen: Pursuant to 10 CFR 20.1703(b), Southern Nuclear Operating Company (SNC) hereby requests authorization for use of the MURUROA V4F1 R and the MURUROA BLU Suit Systems," which have not been tested or certified by National Institute for Occupational safety and Health (NIOSH). Pursuant to" 10 CFR 20.1705, SNC also requests an Assigned Protection Factor of 5000 associated with the use of the MURUROA V4F1 R since this exceeds those specified in Appendix A of 10 CFR 20. In addition, SNC requests an Assigned Protection Factor of 2000 associated with the use of the MURUROA BLU Suit Systems. These suits have been identified as having benefits from a contamination control, heat stress reduction, and respiratory protection point of view. SNC has previously received approval for use of the MURUROA V4F1 and MTH2 with an assigned protection factor of 5000. Upon approval, these suits will be included as an option in the SNC respiratory protection program for all three SNC plant sites. Enclosure 1 provides documentation supporting this request for the MURUROA V4F1 R. Enclosure 2 provides documentation supporting this request for the MURUROA MURUROA BLU Suit Systems. Enclosure 3 describes activities that SNC has identified for use of these suits. These actions will be completed prior to use. The actions are captured in the SNC Corrective Action Program to assure and track implementation. U. S. Nuclear Regulatory Nl-12-1331 2 letter contains no Regulatory If you have any questions, contact Ken McElroy Respectfully submitted, C. R Pierce Regulatory Affairs Director CRP/GAU Enclosures: 1. Assessment of MURUROA V4F1 R Supplied Air Suits 2. Assessment of MURUROA BlU Suit Systems 3. of Prior To Use cc: Mr. S. E. Kuczynski, & CEO Mr. D. G. Bost, & Chief Nuclear Officer Mr. T. A. lynch, Vice Mr. D. R Madison, Vice Mr. T. E. Tynan, Vice Mr. B. l. Ivey, Vice Mr. B. J. Adams, Vice RType: CFA04.054; Mr. V. M. McCree, Regional Mr. R E. Martin, NRR I-'r('\""",...,. Ms. E. A. Brown, NRR I-'rl'\,'''''/'"'1' 1\1t<:>, .... <:>."''''' .. Mr. E. l. Crowe, Senior Ke:SIOlem Mr. E. D. Morris, Senior Ke:SIUlern Inspec:tor Mr. L M. Cain, Edwin I. Hatch Nuclear Plant Joseph M. Farley Nuclear Plant VogUe Plant Enclosure 1 of MURUROA V4F1 R Supplied Air Assessment of MURUROA V4F1 R Supplied Air Suits Enclosure 1 Table of Contents 1.0 Introduction 1.1 Purpose 1 .2 Background 1.2.1 Regulatory Requirements 1.2.2 Suit Construction 1.2.3 Safety Features of the Delta Protection Supplied-Air Containment Suit 1.2.4 Implementation 2.0 Technical Justification 2.1 Evaluation 3.0 References 4.0 Conclusions 5.0 Enclosure 1 Attachments 1. General Description of the Delta Protection Supplied Air Suit 2. European Standard EN 1073-1; 1998 for Ventilated Protective Clothing 3. Certificate No. 0073/197/162/02/01/0005 for MURUROA V4F1 R 4. Test Results Carried Out On The Full Encapsulated Suit MURUOA V4F1 ref. 8481X1T For The EC Type Examination Certificate No. 0073/197/162/12/97/0028 5. Donning and Removal Instructions for MURUROA V4F1 R E1-1 As~sessment of MURUROA V4F1 R Supplied Air Suits Enclosure 1 1.0 INTRODUCTION 1.1 PURPOSE 10 CFR 20, Appendix A, "Assigned Protection Factors for that an supplied suit may be used in a continuous-flow mode; however, an Protection (APF) not been A footnote this equipment application indicates that the suit can used in a respiratory protection program if the minimum program requirements are (e.g., 10 20.1703, of Individual Respiratory Equipment"). 10 CFR 20.1 states use of non-I'lational Institute for Occupation and Health (NIOSH) equipment is acceptable only if approved for use by the Nuclear Regulatory Commission (NRC). 10 CFR 20, Appendix A specify an for air-supplied 10 CFR 20.1 "Application for Use of Higher Assigned Protection " requires SNC to submit a request to the Nuclear Regulatory Commission (NRC) in to use an protection factor (APF) of 5000. With regard to the MURUROA V4F1 R were accepted by the NRC on August 14, 2006, and October 2006, use by Entergy as a respiratory with an of 5000 Agency-wide Documents Access and Management (ADAMS) Accession No. ML062230266 ML062230281, respectively}. Also, the V4F1 R suit was approved by NRC for use by Turkey Point Units 3 and Lucie Units 1 and 2, Seabrook Duane Arnold Center, and Beach Units 1 and 2 by NRC Safety Evaluation (SER) dated August 31, 2009 (Ref. Accession No. ML092310030). Furthermore, the MURUROA suits have widely used in western European nuclear power plants (the manufacturer indicates that approximately 60,000 MURUROA garments/suits are by these plants each year) as well as plants in North America. 1.2 BACKGROUND 1.2.1 Regulatory Requirements proposes to use model V4F1 R manufactured by Delta Protection. The pu rpose of this is to approval use of this particular suit for authorization to use an of 5000 when using this suit. The following regulatory requirements are relevant to this 10 20.1703(a), "Use of Individual Respiratory Protection Equipment," states that if a licensee or permits the use of protection equipment to limit the intake of radioactive material, "the shall use only respiratory protection equipment that is tested and certified by NIOSH, as otherwise noted in this part." 10 20.1703(b) that if licensee use equipment that has not been tested or certified by NIOSH, or for which there is no for Assessment of MURUROA V4F1 R Supplied Air Suits Enclosure 1 testing or certification, the shall submit an application to the NRC to authorize use of the equipment exceot as provided in part. 10 CFR 20.1703(f) requires use of a standby rescue person whenever one~ piece are which an unaided would have difficulty extricating himself or herself. 10 CFR 20.1 "Application for of Higher Assigned Protection requires that a licensee shall obtain authorization from the NRC before using assigned factors in excess of those specified in 10 CFR 20, Appendix A. 10 CFR 20, A, "Assigned Protection Factors for Respirators," Item II, "Atmosphere Supplying Respirators (particulate, and vapors)," indicates that for a suit in a continuous flow operating mode, no APF is assigned nor is a NIOSH approval schedule currently available for the evaluation of such This equipment may be used in an acceptable respiratory protection program as long as all other minimum program requirements, with the exception of fit testing, are 10 CFR 20.1703). Based on regulatory SNC is to obtain NRC approval for the use aSSigned protection factor for the MURU ROA model R suit. 1.2.2. Suit Construction The Delta Supplied~Air Containment Suit Organization for Standardization 8194, protection - Clothing for protection radioactive contamination - Design, selection, testing use," and the European Standard 1073-1 "Protective Clothing Against Radiation Contamination." The Delta Protection suits have following desirable (Ref. Attachments 1 and 2}: .. One-piece use suit includes integral and booties with tie straps .. Made of flexible PVC with reinforced elbows, knees and crotch areas .. Dual - metal zipper and plastic outside .. Clear Poly Vinyl Chloride (PVC) helmet that provides distortion-free vision and for wearing a headset .. Welded insert communication cable .. A near mouth that could for emergency in case of loss of supplied air .. An egress strip stretching from left arm, over the head, to right arm that is used for undressing and for in an breathing in case of emergency as loss of supplied air. -3 Assessment of MURUROA V4F1 R Supplied Air Suits Enclosure 1 • Air intake located at waist with a built-in regulator that can adjust, but not block, airflow • Two exhaust valves that ensure the suit remains airtight should an event block/pinch the air supply line • Low noise level • Air to arms, face Air of any length can be used, but air shall be supplied to the Delta Protection suits at 2.5 to 7 Bar measured at the inlet. A regulator at the inlet is used to adjust the airflow. To ensure user safety, the regulator cannot shut off the air supply. There are two patented exhaust valves on back of the one the neck and one at the The prevent aspiration of contaminants if supplied The Protection are approved for use with 16 different fittings in fitted with Schrader, or CEJN type fittings used 1 to::IlIf'otu Features of MURUROA Model V4F1 R All MURUROA suit models are lightweight Ibs), made of fire-retardant material and can be used in temperatures up to 140 degrees F per European Standard EN 1073-1. The suits have built-in gloves, booties with binding have reinforced elbows, and crotch. A transparent helmet with 6 inch faceplate Dual ventilation needed ventilation and excess in the event the suit is squeezed/pinched unexpectedly. In case of loss of air, the user can remove the mouth strip and move the opening close to his or enlarge the opening, to breath outside air.
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