ML13331A384
| ML13331A384 | |
| Person / Time | |
|---|---|
| Site: | San Onofre  |
| Issue date: | 03/23/1990 |
| From: | Southern California Edison Co |
| To: | |
| Shared Package | |
| ML13331A383 | List: |
| References | |
| NUDOCS 9003290146 | |
| Download: ML13331A384 (9) | |
Text
ENCLOSURE REQUEST FOR EXEMPTION FROM 10 CFR 55.45 IMPLEMENTATION SCHEDULE AND REVISED PLAN TO COMPLY WITH SIMULATOR RULE SAN ONOFRE NUCLEAR GENERATING STATION UNIT 1 Southern California Edison Company 9003290146 900323 FR ADOCK 05000206 F'
TABLE OF CONTENTS Section Page 1.0 Exemption Request
.. 1 2.0 Background........................
.. 2 3.0 Status.......................
.. 3 4.0 Justification for Exemption.
.... 5 4.1 Good Faith Efforts to Meet Requirements of Simulator Rule
. 5 4.2 Effectiveness and Accreditation of Existing Operator Training Program..................
... 5 4.3 Efforts to Procure Simulator with Shortest Practical Lead Time......
.... 5 4.4 Continued Use of Zion Simulator.........
...... 6 4.5 Low Risk Associated with Deferral.
.... 6 4.6 Incorporation of CRDR Modifications.
... 7 5.0 Conclusions..
..... 7 6.0 Reference......................
... 7
REQUEST FOR SCHEDULAR EXEMPTION FROM 10 CFR 55.45 AND REVISED PLAN TO COMPLY WITH SIMULATOR RULE SAN ONOFRE NUCLEAR GENERATING STATION UNIT 1 1.0 EXEMPTION REQUEST SCE is requesting a schedular exemption from the requirements of 10 CFR 55.45 regarding operator licensing examinations on a certified or approved simulation facility. SCE has initiated the necessary steps to procure a plant reference simulator for San Onofre Unit 1 (SONGS 1).
However, for the reasons discussed in this exemption request, the simulator will not be available for the conduct of operating tests until after the May 26, 1991 implementation date stipulated in 10 CFR 55.45.
Specifically, 10 CFR 55.45(b)(2)(iv) states that the "simulation facility portion of the operating test will not be administered on other than a certified or an approved simulation facility after May 26, 1991."
SCE is unable to satisfy this requirement and therefore requests an exemption from this requirement under the provision of 10 CFR 55.11, "Specific Exemptions," which allows the Commission to grant such exemptions. SCE will continue to implement its existing operator training and licensing program using the Zion simulator in the interim.
As part of this exemption request, it is also necessary to defer submittal of the certification documentation for the plant reference simulator as required by 10 CFR 55.45(b)(2)(iii).
That regulation requires submittal of a certification for use of the simulation facility on Form NRC-474 forty six months after the effective date of the rule (March 26, 1991 or two months prior to the May 26, 1991 date indicated above).
SCE's schedule is to have a plant reference simulator available for the conduct of operating tests no later than February 1993. The submittal of certification using Form NRC-474 will be no later than two months prior to the first operating tests following the exemption period.
SCE further requests that the NRC continue to conduct NRC administered operating tests on the Zion simulator during the exemption period.
Included with this exemption request is the background for this issue and SCE's basis and justification for this request. The information provided herein demonstrates that the deferral requested by this exemption will not endanger life or property and is otherwise in the public interest.
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2.0 BACKGROUND
Issuance of Rule and Formation of Utility Group In 1987 the NRC revised 10 CFR 55.45 to improve the operator licensing process. The primary purpose of the rule change is to require practical examinations modeling plant operation such that NRC examiners can evaluate an operator's ability to assess plant conditions and perform specific tasks. The revised sections of 10 CFR 55.45, hereafter referred to as the "simulator rule", require that operators perform as part of the licensing process, a practical examination on either a plant reference simulator certified to the NRC or on a simulation facility otherwise approved by the Commission. Following issuance of these revisions, SCE formed an industry group to develop guidance for using non-plant reference simulation facilities to comply with the simulator rule. The industry group, the Utility Simulator Facility Group (USFG),
worked closely with NRC Staff personnel to develop acceptable guidance for members to use to comply with the simulator rule. Since SCE had good success at the Zion simulator and has spent some effort to upgrade the fidelity of that facility, it was initially believed that we could comply with the regulations by continued use of the facility.
SCE Evaluation of NRC Concerns with Physical Fidelity On May 26, 1988, in accordance with 10 CFR 55.45(b)(2)(i), SCE submitted a simulation facility development plan to the NRC. The plan was based upon SCE's implementation of the USFG guidance to qualify the Zion simulator for use as a SONGS 1 simulation facility.
In responding to SCE's plan, the NRC indicated in a January 3, 1989 letter that significant concern remained with respect to the physical and functional fidelity differences between SONGS 1 and the Zion simulator. This NRC assessment clearly meant that a major effort would be necessary to justify the differences and obtain NRC approval of the Zion simulator. In addition, due to the age of the Zion simulator, there is a high potential for inadequate documentation to support the basis for the existing modeling. SCE concluded in mid-1989 that it would not be practical to make the modifications which it had become clear would be necessary to meet the requirements of the regulation.
Commitment to Install Plant Reference Simulator As discussed in our letter dated October 2, 1989, SCE's evaluation of all options available to comply with the simulator rule given the above events resulted in the decision to install a plant reference simulator.
-3 3.0 STATUS Delivery and Startup Testing The schedule for implementation of a plant reference simulator is based on the following. Following the decision in mid-1989 to provide a plant reference simulator, a specification was developed, bids were solicited and evaluated, and a contract awarded in March 1990. The most reasonable delivery schedule is 30 months. This was used to determine the exemption period. As illustrated in figure 2-1, this will put delivery of the simulator in September 1992, coincident with the scheduled start of the Cycle 12 refueling outage. With turnover of the simulator to SCE in September 1992, there would not be sufficient time to allow operator training on the new facility prior to the currently scheduled October 1992 exams.
Impact of Control Room Design Review Modifications The modifications to the control room resulting from the CRDR are scheduled to be implemented during the Cycle 12 refueling outage. These modifications will significantly alter the configuration and appearance of the control room. These modifications will also be required to be reflected in the simulator in accordance with Regulatory Guide 1.149, "Nuclear Power Plant Simulation Facilities for Use in Operating License Examinations."
Because these modifications are extensive, we have elected to implement the CRDR modifications in the simulator in parallel with or before the control room modifications. This will significantly add to the simulator's initial training value. Completion of the CRDR modifications will result in the simulator being released for training in February 1993.
However, should delivery be earlier than currently expected, or if the Cycle 12 refueling outage schedule slips significantly, the simulator would be placed in service without the benefit of incorporating the CRDR modifications. In no case will the simulator be placed in service after February 1993.
The first requalification exams on the new simulator are currently scheduled for October 1993 as indicated in our September 12, 1989 response to Generic Letter 89-12, "Operator Licensing Examinations."
1990 199 1
199 2 19 AISOI J tFI-M I-AIM 1-1-A
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[D J F-1M I MIj JA I-sI O1NiDHFMAjMIJ AISIOIN D A
M 0J SIMULATOR SCHEDULE CYCLE 12 REFUELI',JG AWARD CONiRACT FOR SIMULATOR A MAR.
FABRICATE AND DELIVER SIMULATOR MAR.
A SEP CRDR MODIFICATIONS SEP FEB.
SIMULATOR AVAILABLE FOR OPERATOR TRAINING FEB.
SUBMITTAL OF CERTIFICATION FORM NRC-474 FIRST NRC ADMINISTERED EXAM ON NEW SIMULATOR ACT.
NRC ADMINISTERED OPERATOR EXAM SCHEDULE EFFECTIVE DATE OF SIMULATOR RULE MAY 26 INITIAL OUALIFICATION EXAMS C.A APR.
ACCT.
OCT REQUALIFICATION EXAMS AOCT.
A APR.
A OCT.
A OcT.
AOCT.
EXAMS ON EXAMS ON ZION SIMULATOR REFERENCE SIMULATOR Plant Certification will occur at least 60 days prior to the first examinations on the new Simulator.
FIGURE 2-1: ESTIMATED SIMULATOR CONSTRUCTION SCHEDULE
-5 4.0 JUSTIFICATION FOR EXEMPTION This request for exemption became necessary as a result of SCE's decision in mid 1989 to procure a plant reference simulator. The length of the exemption request is based on a realistic projection of the lead time required for procurement and installation of a plant reference simulator, the desirability of incorporating CRDR modifications before using the simulator for training and examinations and the amount of time required for operators to become familiar with the functional aspects of the new simulator prior to conducting any operating tests.
The deferral is considered justified on the following basis:
4.1 Good Faith Effort to Meet Requirements of Simulator Rule As indicated in the Background section above, SCE has acted in good faith to meet the requirements of this rule. Based on our past success with the Zion simulator, we initially proceeded to take the necessary actions to obtain NRC approval for continued use of the Zion simulator.
However, once it became apparent that SCE could not fully meet the requirements of the rule following this path, a decision was made to obtain a plant reference simulator.
4.2 Efforts to Procure Simulator with Shortest Practical Lead Time Once the decision was made to procure a plant reference simulator, SCE expeditiously proceeded to obtain bids from various qualified vendors.
SCE selected the best qualified vendor with the most reasonable implementation schedule. This was done to assure ourselves that the simulator will be delivered and ready for operator training within 30 months after the award.
4.3 Effectiveness and Accreditation of Existing Operator Training Program A significant basis upon which SCE justifies this exemption request is the adequacy of the existing program for operator training. SCE will continue this program during the interim period prior to implementation of the plant reference simulator. Based on its accreditation by INPO in 1985 and re-accreditation in November 1989, this program is considered fully capable of ensuring that operator skills and knowledge are maintained at a high level.
All the necessary elements are available in the program to perform constructive evaluations of operator performance.
-6 4.4 Continued Use of Zion Simulator SCE's current training program incorporates the use of the Zion simulator for training and evaluation of operators' performance of__
esstilloDtaKS.
Ine Lion simulator has been used with good success by SCE for over six years for operator training. Plant specific procedures modified to reflect differences between the Zion simulator and SONGS 1 design are used in training. In addition, SCE has made changes to the simulator including using SONGS setpoints and values for all major parameters such as Power, Tave, Pressure, Trip Setpoints, etc.
SCE pump curves and protection philosophies have been incorporated into the software models. SCE specific labels and annunciator windows are used throughout. SCE instructors are used to develop and present all training and to conduct all evaluations. SCE will continue to use this facility during the exemption period. To ensure continued availability of the Zion simulator, SCE intends to establish a contract with Westinghouse for the use of Zion until delivery of our own plant reference simulator.
Until the Unit 1 plant reference simulator is available, SCE also intends that the NRC continue to conduct requalification examinations on the Zion simulator. These examinations will be conducted in a manner similar to the currently scheduled October 1990 examinations and in accordance with NUREG 1021 Rev 5, "Operator Licensing Examiner Standards." This plan is necessary to ensure that SONGS Unit 1 licensed operator renewals meet the requirements of 10 CFR 55.57, "Renewal of Licenses."'
We believe that this approach provides assurance that SONGS 1 operators will continue to maintain a high level of training and readiness.
4.5 Low Risk Associated With Deferral SCE has evaluated the risks associated with deferring the implementation of a plant reference simulator and determined that a deferral of less than two years will not significantly impact plant safety. This determination was the result of utilizing the existing partial Level 1 Probabilistic Risk Assessment (PRA) for SONGS 1, and assuming a 20%
reduction in operator error rates once the plant reference simulator becomes available.
While our PRA does not yet meet all standards of a full Level 1 PRA, considerable effort has been expended to ensure that accurate plant models exist for those initiators that have been shown to be dominant contributors in PWR PRA's (i.e., loss of off-site power/station
'Specifically, 10 CFR 55.57(b)(2)(iv) requires that each licensee "has passed a comprehensive requalification written examination and operating test administered by the Commission during the term of a six-year license."
-7 blackout, small LOCA, small-small LOCA, large LOCA, and loss of main feedwater). The results of our PRA evaluation indicate that the risk of core damage is decreased in the range of E-6 per year assuming use of a plant reference simulator. This value is relatively small and confirms th-'truiuY-dferral from May-19F9T to ebruaryS1993 will not have a significant impact on the health and safety of the public and will not endanger life or property.
4.6 Incorporation of CRDR Modifications As indicated above under "Status," delivery of the simulator is expected to closely coincide with commencement of the Cycle 12 refueling outage.
For reasons stated in that section, it is prudent for SCE to plan implementation of the CRDR modifications prior to placing the simulator in service.
5.0 CONCLUSION
S SCE has determined that implementation of a plant reference simulator is necessary to comply with the simulator rule, but this cannot be done until after the May 26, 1991 simulator implementation date required by the regulations.
SCE has put forth a good faith effort to meet the requirements of the simulator rule but due to the events described above will not be able to meet the implementation deadline. The current INPO accredited program utilizing the Zion simulator, will continue through the exemption period and provide assurance that the operators will maintain a high level of training and readiness. In addition, we have shown that the risks associated with the deferral are minimal.
For these reasons it is requested that a schedular exemption be granted to defer implementation of a SONGS 1 plant reference simulator until February 1993 and that examinations of the operators using the Zion simulator continue in the interim.
6.0 REFERENCE
- 1.
Regulatory Analysis of Proposed Changes to 10 CFR 55 (March 27, 1986).