ML20006D573

Forwards Response to NRC 900112 Request for Addl Info Re 891121 Request for Exemption from Filing Requirements of 10CFR55.45(b)(2)(iii).Qualification Plan for Certification of Existing Simulator Approved in Aug 1987

ML20006D573
Person / Time
Site:	Perry
Issue date:	01/30/1990
From:	Kaplan A CLEVELAND ELECTRIC ILLUMINATING CO.
To:	NRC OFFICE OF INFORMATION RESOURCES MANAGEMENT (IRM)
References
PY-CEI-NRR-1128, NUDOCS 9002140067
Download: ML20006D573 (5)

Text

' ~

.{b N

}il .l]Q 7y .; '

jl"

~

fHE? CLEVELAND ELECTRIC ILLUMINATING COMPANY

, P.O. BOX 97 5 . PERRY OHIO 44001 5 -TELEPHONE (216) 2504737 5- ADDRESS 10 CENTER ROAD ~

g ;' ' FROM CLEVELAND: 479-1260 - E TELEX: 241600 '

ANSWERBACK: CEIPRYO

^ Al Kaplan . Serving The Best location in the Nation

.+ .

PERRY NUCLEAR POWER PLANT

. VICE PRESIDENT '

t rax:LtAR GROUP -

January 30, 1990 PY-CEI/NRR-1128~L f

7 U.S.. Nuclear; Regulatory Commission t' .. Document Control Desk- l

-Washington, D. C. -20555 ,

't Perry Nuclear Power Plant-Docket No. 50-440 Response to NRC Staff RAI Regarding CEI-Request for Exemption from 10CFR55.45(b)(2)(iii)

Filing Deadline 3; Gentlemen:

iThe' Cleveland Electric Illuminating Company _(CEI) is responding by this letter to an NRC Staff request;for additional information (RAI) dated January 12,-

1990 regarding CEI's November 21,fl989 request for exemption from the filing-requirements of:10CFR55.45(b)(2)(iii) submitted via letter PY-CEI/NRR-1072L.

CEI requested exemption from the filing requirements of 10CFR55.45(b)(2)(iii)-

> to allow for the submittal of NRC Form.474,." Simulation Facility;

Certification" after the' March 26, 1991 deadline provided in'the rule.

The information requested by the NRC Staff-and CEI's responses are provided in ,

Attachment 1.  ;

, If you'have any questions, please feel free to call. ,

Very truly yours, 37 f

Al Kaplan Vice President

[ ;. -

Nuclear Group

,* &lI I '

l?.; AK:njc-p Q

iT [4 SO Attachment -

i g/8[

cc: P. H11and 9002140067 900130 PDR

) '

T. Colburn P ADOCK 05000440 \

PDC f' Region III l

3 Attachtint l' '

PY-CEI/NRR-1128 L4 Page:1 of 3 l'

The information requested by the NRC staff and CEI's responses are provided '

below >

NRC Staff Request il Provide'a description of the events and decisions, including approximate-dates, which lead to the decision that your initial plans to upgrade ysur existing simulator were not feasible.

CEI Response Prior to the re-evaluation of alternatives leading to the decision to replace the simulatot, CEI had planned and was working toward certification of the

~

existing simulator.

Subsequent to the May 1987 effective date of 10CFh55.45, a Qualitication. Plan ,

for certification of the existing simulator was approved in August 1987.

Within this plan, it was noted that the majority of identified simulator discrepancies (at that time) were concerned with logic and human factors,  ;

rather than dynamic response. . '

In November of.1987, commercial operation of the plant signified completion of I start-up testing. Assimilation of startup test data for comparison to

simulator performance data began in December 1987. In early 1988, dynamic response differences between plant and simulator performance were becoming apparent. Procedures for certification of the existing simulator were developed and in place by March 1988, and implementation of those procedures vas underway.

.As.1988 progressed the following simulator discrepancies emerged from

' comparison of simulator-performance to plant data. Capability to accurately l simulate required normal plant evolution dynamics was inadequate due to l limitations in reactor kinetic /thermohydraulic and feed flow models I complicated by. numerous deficiencies of lesser magnitude. Substantial corrections to system logic were required, but could not be implemented due to computer capacity limitations. .1

> Capabilities to accurately model malfunctions needed to simulate abnormal and emergency events were limited due to outdated model structures, computer-processing time and capacity limitations, and the shortcomings of the reactor kinetics /thermohydraulic, feed flow response and containment /dryvell models.

s 4

1* ' T* > ' Attcchn:nt 1 3 PY-CEI/NRR-ll28 L Page 2 of 3 j

In mid 1988, after collecting and evaluating the above data, the need for an extensive upgrade of the existing simulator was recognized and a specification

'for-the upgrade was prepared. The scope of the upgrade included replacing the computer complex and-the instructor station,-correction of simulation software .'

deficiencies for key system models and provision of a Configuration Management l' System. A request for proposals'vas issued in October 1988, bids vere i returned in December 1988 and proposal evaluations were completed in February i 1989.-  !

During evaluation of vendor proposals for a simulator upgrade, culminant L factors emerged which contributed to the decision to re-evaluate alternatives i (upgrade-vs-replace) for meeting simulator certification requirements and l

training needs. These factors included:  ;

o certification risks associated with proposed upgrades, I l

l o' training downtime associated with proposed upgrades, j l

l o- outdated input / output devices and limited availability of spare L parts, o the cost of a simulator upgrade relative to the cost of simulator replacement, and 1 o 2 vendors refusing to bid based on the assertion that an. upgrade l could.not be guaranteed to yield certifiable performance.

These events are summarized, chronologically, on Attachment 2. l NRC Staff Request $2

'l Provide a description of your approach to determining your specific needs for l your replacement simulator.

CEI Response:  ;

The scope of simulation for the new simulator was determined by a combination of the requirements of ANS 3.5-1985 and Perry training needs. Regarding Perry training needs,.the following vere considered:

i o scope of equipment exercised by simulator training scenarios for l l normal, abnormal and emergency operations, o Job and Task Analysis for licensed operators. i i  !

(

l o licensed operator input.

l-l l

Attach:2nt l' PY CEI/NRR-1128-L-Page 3 of 3 e

t NRC Staff Request 93 1

Provide a description of the training which license candidates vill receive on j the new simulator prior to its'use for the August 1991 examinations. '

CEI Response:

The August 1991 License Candidates vill have completed their license training l prior to the arrival of the new simulator. This training vill include three veeks of normal simulator operations to be given in October 1990s three veeks j of transient operations to be given in April 1991; and one week of plant l emergency operations to be given in May 1991. We do not anticipate any l changes, from the candidate's view, in the scenarios used on the simulator- ,

during their training period. The new simulator, because'of more I sophisticated modeling, will be able to extend some currently simulated events' i further than is now obtainable with our present simulator, and vill feed back l

- mote information in a shorter response time.

However, the objective of the l training and the scenarios vill not be changed. Current plans are to- i familiarize the candidates with differences between the old and new simulator, i including differences in panel layouts, simulator response times, and use of I the new simulated control room backpanels. The time available from the a completion of installation of this new simulator until the time of the August. l examinations vill dictate the amount of time available for familiarizing the i license candidates with the new machine.

1 l

l l

E..

r

'"* 7,.

Attach::nt 2 e

PY-CEI/NRR-1128 L at Page 1 of 11 ,

EVENTS LEADING TO DECISION TO REPLACE SINULATOR 05/87 - 10CFR55.45 effective 08/87 - Qualification Plan approved for existing simulator "

- Majority of identified discrepancies involved logic or human factors -vs- dynamic response problems

• 10/87 - 3/88 - developed procedures for certification of existing .

-simulator t 11/87 - Perry Plant commercial

- S/U tests complete

'12/87 - assimilation of S/U test data for comparison to simulator :r response underway 1/88 - dynamic response differences becoming apparent .

3/88 - began implementation of proceduros for certifying existing simulator, e.g. identify training requirements, etc. -

10/88 - Request for proposals for simulator upgrade 2/89 - Upgrade proposal evaluations complete 2/89 - INPO Evaluation and Assistance visit +

3/3-14/89 - Re-evaluation of alternatives (upgrade -vs- replace) 3/14/89 - Recommended replacement 3/15/89-4/15/89 - Prepare bid spec. for simulator replacement' 4/17/89-5/19/89 - Out for bid for simulator replacement 5/19/89-5/31/89 - Bid evaluation for simulator replacement L

6/1/89 - Contract award / start vork for simulator replacement L (26 month schedule) l -:

, NJC/ COD 2D/3102 ll 4

)

l lc L

. = = _ _ - . _ _ - - - - - - - __-