ML13331A382
| ML13331A382 | |
| Person / Time | |
|---|---|
| Site: | San Onofre  |
| Issue date: | 03/23/1990 |
| From: | Rosenblum R Southern California Edison Co |
| To: | NRC/IRM |
| Shared Package | |
| ML13331A383 | List: |
| References | |
| NUDOCS 9003290144 | |
| Download: ML13331A382 (3) | |
Text
Southern California Edison Company 23 PARKER STREET IRVINE, CALIFORNIA 92718 R.M.ROSENBLUM TELEPHONE MANAGER OF March 23, 1990 (714) 587-5420 NUCLEAR REGULATORY AFFAIRS U. S. Nuclear Regulatory Commission Attention: Document Control Desk Washington, D.C. 20555 Gentlemen:
Subject:
Docket No. 50-206 Request for Exemption from Schedular Requirements of 10 CFR 55.45, 'Operating Tests' to Allow for Implementation of a Plant Reference Simulator San Onofre Nuclear Generating Station Unit 1
References:
- 1) Letter dated May 26, 1988 from M. 0. Medford,
- SCE, to NRC, "Plan to Meet 10 CFR 55.45 Requirements"
- 2) Letter dated October 2, 1989, from Harold B. Ray, SCE, to NRC, "Full Term Operating License Open Items (TAC No. 11232)"
This letter requests a schedular exemption from 10 CFR 55.45(b)(2)(iv) which requires that operator operating tests be administered on a certified or an approved simulation facility after May 26, 1991.
In response to issuance of 10 CFR 55.45 in May 1987, SCE initially planned to request NRC approval for continued use of the Zion Simulator (see reference 1).
However, in mid 1989, we concluded that it would not be practical to make the modifications to the Zion simulator which would be necessary for it to become an "approved" simulation facility.
The NRC was promptly informed of this decision and we proceeded to expeditiously procure a plant reference simulator.
As indicated previously in our October 2, 1989 letter (Reference 2), we will not be able to meet the May 26, 1991 schedular requirement.
Based on the recent award of the contract for manufacture and delivery of the plant reference simulator, we currently expect that it will be available for operator training no later than February 1993.
Accordingly, a detailed request for a schedular exemption is enclosed.
During the period between May 1991 and February 1993, we propose to continue to conduct operator licensing training and examinations according to our current program using the Zion simulator.
This would include NRC administered examinations scheduled for October 1991, April 1992 and October 1992.
,9003290144 900323 PDR ADOCK 050002 0,6.:
Document Control Deskle
- rch 23, 1990 SCE will submit the certification required by 10 CFR 55.45 (b)(2)(iii) for the plant reference simulator at least 60 days prior to the first exams following the exemption period.
Schedule It is our current expectation that the simulator will be completed and available for-the-cond uct-of onperator-training noil at er th an-ebriayvi-93This-chedal-e will permit operators to be trained on the new simulator before taking their first exam and will also enable substantial Cycle 12 refueling outage Control Room Design Review (CRDR) modifications to be implemented on the simulator prior to the conduct of operator training and testing.
Justification for Exemption SCE believes that this schedular exemption request is justified based on the following:
- 1.
SCE acted in good faith to meet the requirements of the simulator rule by initially participating in an industry group regarding potential use of the existing Zion simulator and submitting a plan to the NRC based on this approach.
- 2.
Upon deciding not to continue with our plans to retain use of the Zion simulator, we proceeded to procure a reference simulator in the shortest practical time.
- 3.
The existing operator training program at San Onofre Unit 1 is an effective program and has received INPO accreditation and re accreditation.
This program will be continued during the exemption period.
- 4.
The Zion simulator has been an effective training tool.
SCE has previously made several improvements to the Zion facility and will continue to use the facility during the exemption period.
- 5.
The additional risk associated with deferring the simulator from May 1991 to February 1993 is minimal.
- 6.
Delivery of the simulator will closely coincide with the start of the Cycle 12 refueling.
CRDR modifications are scheduled to be implemented during the Cycle 12 refueling outage. A February 1993 schedule for the simulator will allow us to incorporate the CRDR modification into the simulator prior to its use for training and examinations.
Further details regarding each of the items listed above are included in the Enclosure.
Document Control Desk
- ch 23, 1990 Request for Exemption Based on the information provided by this submittal, it is respectfully requested that the NRC grant SCE an exemption from the schedular requirements of 10 CFR 55.45(b)(2)(iv) until February 1993 and that operating tests be conducted using the Zion simulator during the exemption period.
Consistent with the above schedule, SCE will also provide the certification required by_10 CFR 55.45(b) j2)(ii)_totheNRCatl east-60 days -prior--toconduct_
of the first operating tests on the new plant reference simulator.
If you have any questions or need more information, please let me know.
Very truly yours, Enclosure cc:
J. B. Martin, Regional Administrator, NRC Region V C. Caldwell, NRC Senior Resident Inspector, San Onofre Units 1, 2 and 3