ML18033B433
| ML18033B433 | |
| Person / Time | |
|---|---|
| Site: | Browns Ferry  |
| Issue date: | 07/13/1990 |
| From: | Medford M TENNESSEE VALLEY AUTHORITY |
| To: | NRC OFFICE OF INFORMATION RESOURCES MANAGEMENT (IRM) |
| References | |
| NUDOCS 9007180115 | |
| Download: ML18033B433 (11) | |
Text
ACCELERATED DISTRIBUTION DEMONSTRATION SYSTEM REGULATORY INFORMATION DISTRIBUTION SYSTEM (RIDS)
ACCESSION NBR:9007180115 DOC.DATE: 90/07/13 NOTARIZED: NO DOCKET FACIL:50-259 Browns Ferry Nuclear Power Station, Unit 1, Tennessee 05000259 50-260 Browns Ferry Nuclear Power Station, Unit 2, Tennessee 05000260 50-296 Browns Ferry Nuclear Power Station, Unit 3, Tennessee 05000296 AUTH.NAME AUTHOR AFFILIATION MEDFORD,M.O.
Tennessee Valley Authority.
RECIP.NAME RECIPIENT AFFILIATION Document Control Branch (Document Control Desk)
SUBJECT:
Requests temporary exemption from simulator certification requirements of 10CFR55.45(b)(2)(iii).
DISTRIBUTION CODE:
A005D COPIES RECEIVED:LTR ENCL SIZE:
TITLE: Simulator Facility Certification NOTES:1 Copy each to: B.Wilson,S.
BLACK 1 Copy each to: S.Black,B.WILSON 1 Copy each to:
S.
Black,B.WILSON 05000259 05000260 05000296 RECIPIENT ID CODE/NAME INTER' CENTRAL~LE 0
~HKR/DLPQ/LOLB1 0 EXTERNAL: LPDR NOTES:
COPIES LTTR ENCL 1
1 1
1 1
1 5
5 RECIPIENT ID CODE/NAME IRM MCKNIGHT,J.
NRC PDR COPIES LTTR ENCL 1
0 1
1 NOTE TO ALL"RIDS" RECIPIENTS:
PLEASE HELP US TO REDUCE WASTE! CONTACT THE DOCUMENT CONTROL DESK, ROOM P 1-37 (EXT. 20079) TO ELIMINATEYOUR NAME FROM DISTRIBUTION LISTS FOR DOCUMENTS YOU DON'T NEED!
TOTAL NUMBER OF COPIES REQUIRED:
LTTR 10 ENCL 9
gP'
0 e
t t
TENNESSEE VALLEYAUTHORITY CHATTANOOGA. TENNESSEE 37401 6N 38A Lookout Place JUL 19 1990 U.S. Nuclear Regulatory, Commission ATTN:
Document Control Desk Washington, D.C.
20555 Gentlemen:
In the Matter of Tennessee Valley Authority Docket Nos. 50-259 50-260 50-296 BROWNS FERRY NUCLEAR PLANT (BFN) REQUEST FOR TEMPORARY EXEMPTION FROM 10 CFR 55.45(b)
Pursuant to 10 CFR 55.11, TVA hereby requests a temporary exemption from the simulator certification requirements of 10 CFR 55.45(b)(2)(iii) to defer the submission of NRC Form 474, "Simulation Facility Certification," for the BFN simulator from the March 26, 1991 date provided in the rule to December 31, 1991.
TVA further requests a temporary exemption from the requirements of 555.45(b)(2)(iv) to allow BFN to continue to administer the simulation facility portion of operating tests on the current BFN simulator until that simulator's certification is accomplished.
TVA's intention to submit this request was discussed Jn:.a telephone conference with,.Neil Hunemuller, Dave
- Lange, and 'Thierry 'Ross 'o'f the NRC Headquarters staff on May,,21, 1990..
TVA intends to comply with 10 CFR 55.45(b) for BFN by certifying a plant referenced simulator facility in accordance with 5 55.45(b)(1)(ii).
To meet these requirements, TVA decided to salvage the hardware from the existing BFN simulator (i.e., the panels),
but completely replace the simulator software, instructor's station and computer complex.
Engineering specifications for the upgraded simulator were completed in May 1988; competitive proposals were solicited in accordance with the requirements of the Federal Acquisition Regulations (FARS) in June 1988.
Proposal evaluations were completed in December 1988, final negotiations were concluded in February
- 1989, and a contract was awarded to Singer Link-Miles on March 31, 1989.
The upgraded simulator meeting the requirements of 555.45(b) is presently scheduled to be "ready for training" in November 1991.
Additional supporting information regarding the BFN simulator is contained in Enclosure 1.
Application of the March 26, 1991 certification date to the existing BFN simulator under the circumstances described above does not serve the underlying purpose of 555.45, which is to have a fully certified simulator meeting the requirements of the rule available for use in the administration of operating tests.
Because the effort to upgrade the simulator will not be
- complete, any NRC Form 474, "Simulation Facility Certification," TVA would submit for the existing BFN simulator by March 26, 1991, would contain a number of exceptions to certain aspects of 555.45(b).
- Further, to certify the existing simulator, formal performance
- tests, involving substantial simulator time and personnel resources are necessary.
Formal performance tests will be performed on the upgraded simulator to support its certification; to perform such testpgn the existing simulator would result in a seemingly unnecessary duplication of effort.
9007180ii5 900713 bio PDR ADOCK 05000259'DC An Equal Opportunity Employer
U.S. Nuclear Regulatory Commission JUL 1 8 l980 If granted, these exemptions would provide only temporary relief.
TVA intends to certify the BFN simulator in accordance with 555.45(b)(2)(iii) by December 31, 1991, and to use only the certified simulator for the simulation facility portion of operating tests administered after that date.
As demonstrated by the chronology described
- above, TVA has made a good faith effort to comply with the simulator certification date of March 26, 1991 for BFN, and in fact, intends to certify its Sequoyah and Watts Bar simulators by the March 1991 date.
Approval of these exemption requests will not endanger the public health and safety.
TVA has kept the BFN simulator up-to-date by installing modifications made to BFN Unit 2.
- Thus, the existing simulator continues to be a valuable tool for operator training and is appropriate for use in the operating test portion of operator examinations.
Based on the considerations discussed
- above, and in view of the criteria of 10 CFR 5550.12 and 55.11, TVA requests the following exemptions:
l.
A specific exemption to defer the simulation facility certification requirements of 10 CFR
$55.45(b)(2)(ii) to submit NRC Form 474 for the BFN simulator until December 31, 1991; and 2.
- A specie
- c..exemption to 10 CFR 555.45(b)(2)(iv) to permit TVA to continue to use the existing BFN simulator';to. administer the simulation facility portion of operating tests until the upgraded simulator's certification is accomplished.
The operator license examinations which will be affected by this request are listed in Enclosure 2.
As the NRC itself recognized in the Supplementary Information published along with the final rule, in unique circumstances, deviation from the time requirements established by the rule would be permitted.
Under these circumstances, where TVA has made a good faith effort to comply in a timely manner with regulatory requirements and otherwise intends to fully comply with 10 CFR 55.45(b),
these temporary exemption requests should be granted.
If you have any questions, please telephone F. L. Ginn at 615/751-7667.
Very truly yours, TENNESSEE VALLEY AUTHORITY Mark 0. Medford, Vice President Nuclear Technology and Licensing Enclosures cc:
See page 3
")"/H C4
U.S. Nuclear Regulatory Commission JUL 18 ISSO cc (Enclosures):
Ms.
S.
C. Black, Deputy Director Project Directorate 11-4 U.S. Nuclear Regulatory Commission One White Flint, North 11555 Rockville Pike Rockville, Maryland 20852 Mr. B. A. Wilson, Project Chief U.S. Nuclear Regulatory Commission Region II 101 Marietta Street, NW, Suite 2900 Atlanta, Georgia 30323 NRC Resident Inspector Bro~s Ferry Nuclear Plant Route 12, Box 637
- Athens, Alabama 35611 Charles A. Casto Operator Licensing Section U.S. Nuclear Regulatory Commission Region II, Suite 2900 101 Marietta Street, NW Atlanta, Georgia 30323 Mr. Ken Perkins Chief Operator Licensing Branch, DLPQ U.S. Nuclear Regulatory Commission Washington, D.C.
20555 Thierry M. Ross U.S. Nuclear Regulatory Commission One White Flint, North 11555 Rockville Pike Rockville, Maryland 20852
<<Q9~p
~
h
< ~
ENCLOSURE 1
Supporting Information Numerous design changes have been implemented over the past 13 years to ensure the existing simulator reflects the operating plant.
There are,
- however, significant TVA operator training requirements and requirements of ANSI/ANS 3.5, 10 CFR 55.45 and Regulatory Guide 1.149 which require major simulator software modifications that are not practical to implement with the existing computer software and hardware.
TVA concluded the best and proper approach to comply with these requirements was to completely replace the simulator models and computer complex, and to keep the existing panels which have been kept configured to its referenced unit over the years.
The decision was based upon the results of a study and detailed analysis of the existing simulator which included comparison of simulator data from ANSI/ANS-3.5 transients against RETRAN, a best-estimate engineering analysis code approved for use by NRC.
This identified the following major problems:
1)
Major limiting assumptions in the original model design (e.g.,
thermodynamic equilibrium is assumed during transients, the reactor water level will never go below two-thirds core height, even in a design basis accident; etc.).
2)
Programming that was in fixed point arithmetic with 16-bit variables that caused scaling problems over a wide range'f dynamic responses.
3)
Software documentation was poor.
4)
The scope of electrical systems modeling was not sufficient to accurately model loss or degraded electrical power to the station, loss of diesel generators, or ability to fail vital AC or DC instrument or instrument loop power supplies below the 480VAC distribution level.
5)
Only specific instruments and controls could be failed from the instructor station instead of all instruments and controls available on the simulator to the trainee.
6)
Data collected during performance of the entire training scenario for operator and instructor actions are not available for later review.
ENCLOSURE 2
BFN License Examinations Affected by Exemption Request T
e of. Examination Date Number of Examinations Requalification Requalification Hot License Hot License May 27, 1991 June 10, 1991 June 24, 1991 December 16, 1991 12 12 24 24
~
~
'l)a
(