ML20029C416
| ML20029C416 | |
| Person / Time | |
|---|---|
| Site: | Perry  |
| Issue date: | 03/19/1991 |
| From: | Boger B Office of Nuclear Reactor Regulation |
| To: | CLEVELAND ELECTRIC ILLUMINATING CO. |
| Shared Package | |
| ML20029C411 | List: |
| References | |
| NUDOCS 9103280035 | |
| Download: ML20029C416 (6) | |
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VillTED STATES Of ANERICA NUCLEAR REGULAT0f.Y C0tilllSSION In the Matter of THE CLEVELAND ELECTRIC -ILLUMINATING Docket no. 50-440 COMPANY, ET AL.
(Perry Nuclear Power Plant, Unit 1)
EXEMPTION 1.
The Cleveland Electric 111uminating Company, Centerior Service Company, Duquesne Light gany, Ohio Edison Company, Pennsylvhnia Pcwcr Col.;peny and Tole /o Edison Con.pany (the licensees) are the holdert, of Fucility Cperating License No. NPF-58, which nuthorizes operation of the-Perry Nuclear Power Plant, Unit No.1 (the-facilitM) at steady) state' reactor pcwer levcit nct in excess-of 2E79 raegawatts thermal. The license provides, among other things, that the piant is subject to all. rules, regulations and orders of the Nuclear---
Regulatory Cconission (the Commission) now or hereaf ter. in effect. The i
facility is a boiling water _ reactor lectted at-the-licer.see's site.in Lake Cout.ty, Ohio.
The revision to 10 CFR Part 55, " Operators' Licenses," which became-effective on May 26, 1987, established requirements for the ada.inistration of_
operating tcsts on nuclear phcr plant simulators. These regelationt,, in conjunction with 10 UR 50.54(1-1), require facility licensees to use-simulation facilities when ac'n.inistering operatitis tr.sts for initial licensing at.d rcqus11fication. These ru,uintions further regire tht.t a certificd or 9103280035 910319 DR ADOCK 0500 0
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2 ERC-approved situlation facility must be used to administer operatin9 tests af ter May 26, 1991.
By letter dated Noven,ber 21, 1989, as supplemen*ed by letters dated January 30, 1990, and February 12, 1991, the licensees requested an exeniption concerning the schedular requirements for certification of a p' ant-referenced simulator, 11.
Sectich EE.4E(b)(2)(iii) of 10 CFR Part 55 requires that facility licensees submit a certification for use of a simuletion facility consisting sclely of a plant-referenced simulator no later than 4C months after the effective date of this rule, that is, by March 26, 1991, by filing Form NRC-474, " Simulation Facility Certification." On November 21, 1989, as supple-rer,ted ty letters dated January 30, 1990, and February 12, 1991, the licensees requested an exemption from the filing rcouirements of 10 CFR 55.45(b)(2)(iii) to allow for the. subtiittal of Form NRC-474 after March 2c, 1991.
The licensees intend to cor.: ply with 10 CFR 55.45(b) by certifying a plant-referenccd simulator.
The licensees propose to subr.it Fon. hRC-474 nc later then June CE,1991, followirg completion of vendor and licensee acceptance testing but prior to shipment of the simulatcr from the vendor f a cility.
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The licensecs initially planned to upgrade the existing Perry simulator 1
i to rect the certification requirements. However, efter determining the reouired scope of the upgrade and evaluating vendor proposals, it was detern:ined that these initial plans were not feasible.
Based upon-the certification requircments and Perry's training netds, the licensees decided l
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to replace the existir.g sitalator and to delay certification until the ncw sirmlator is operational. The exemption wts requcsted because the replacenent simulator will not be ready for certification by March 26, 1991.
In August 1987, 3 months after the effective date of 10 CFR 55.45, a qualification plan for certification of the existing simulator was approved by the licensees. Withir that plan, it was noted that the ecjority of the simulatcr discrepancies identified et that time were concerned with logic and ltr,a t f actors, rather than dynamic response.
The pcrry plar.t ccepleted start-up testing and began cent.ercial operaticn in November of 1987.
- n Deter..ber 1987, the licensees besar the analysis of start-up tcst data.for con.parison to situlctor performance and it sect, became apparent that thcre wcre significant dyr.cn.ic respcr.se ciifererces between plant and sin.ulator, procedures for certification of the existing simulator were developcd and in place by l' arch 1988, and inplerentation of those procedures was underway.
/.s 1988 progressed, the fcilowing simulator discrepancies euerged ferr, cutparisch vi sis *latur pcrformance to plant data:
(1) Capability to accurately simulate required ncrmal pitnt evolution dynemics was inadequate due to limitations in reactcr kinetic /thermohydraulic and fetd-ficw tcodels ar.d numerous deficiencies cf lesser magnitude; (2) Substantial corrections to systen logic were-required but cculd not be implerented due to computer cepacity limitations and; (3) The ability to accurately r.edel ralfunctions needed to simulate abnormal and emergency events was limited due to outdated tcdel structures, cou.puter processing tire and capacity limitations, and the shot tcomings of the reactcr kinttics/thermohydraulic, fecd fick rcsperse and 1
contairment/drywell cicdels.
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i By mid-1988, 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 statir.n, correcting the simulation sof t' are deficiencies for the key system models and providing a Configuraticr. t;anagetient Syster.. A request for pccpcsels wcs issued in October 1988, bids were rcturned in Decenter 1988, and proposci cvuluations wue cor4 (ted in February 19f.9.
1 During evaluation of vendor prt.posals for a sir.ulatcr upgrade, factors emerged which prcmpted the licensees to re-evaluate the alternatives (upgrade vs replace) for rcetting sinulator certification requirements and trainir.g needs and ultin,ately resulted in the decision te replatt the situ'ator. These facters included:
certification risks associated with proposed upgradcs, trair.ing dwntime associated with proposcd upgrades, outdated input / output devices and limited availability of spare parts, the cost of a simulator upgrade relative to the cost of sinviator replaterr.er.t, and two vendors refusing to teid based on the asserticr. that an upgrade could not be guaranteed to yield certifiable -
perforriance.
III.
The Ccmission has detenr.ined that pursuant to 10 CFR 55.11, this-exemption is tuthorized by law and will not endanger life or property and is l
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-C-otherwise in the public interest. Furthermore, the Commission has determined, pursuant to 10 CFR 50.12(a), that special circumstances-of 10 CFR 50.12(a)(2)(v) are applicable it that the eteinption would provide only tcmporary relief from the applicable regulation and the licensee has r.;ade good faith efforts to cortply with the regulaticr.. This exer.iption grants a temporary relief period of approximately 3 inonths from the i< arch 1991-date for_ subtittal of the Perry simulation f acility certification. Good faith efforts to coriply with the regulation were tradc as follows:
(1)
Prior tc the re-evaluation of aiternatives leading to the decisjon to replace the sinulator, the licer. sect had planned and were working tout.rd cortification of the existil.g sirulator.
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In lurch 1989, replaceuent was recermei ced based on the~
re-evaluation of alternatives.
(3)
In April 1989, simulator replacement prcposals were requested.
(4)
Bid evaluations were completed in fiay 1989.
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On June 1,1989, a contract was awarded and work on the replacer.ient sirculator was-started with a schedule for completion in '26 months.
(6)
The replacement simulator will be available for use in the first operating tests schedulcd af ter May 26 -1991. These-tests are i
scLtduled for February 1992. Therefore, no enr..ption is required from Section 55.45(b)(2)(iv), which states that "The simulation facility portion of.the operating test will not be administered on other than a certified or an apprcved simulation facility after May 26,1991.
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l 6-The Commission hereby grants an exemption from the schedular requirements
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of 10 CFR 55.45(b)(2)(iii) for submittal of Form NRC-474, " Simulation Facility _
j Certification." This exemption is effective until June 28.-1991.-
Pursuant to 10 CFR 51.32 the Commission has determined that the f
issuance of this exemption will have no significant impact on the environment I
(56 FR 10579) March 13, 1991.
The licensee's initial exemption request dated November 21, 1989, the Commission's request for additional information dated January 12, 1990, the licensee's response to the request for additional information dated January 30, i
1990, and the licensees' revised request dated February 12, 1991, are-available.
t for public. inspection at the Commission's Public Document Room, 2120 L Street, i
N.W., Washington, D.C. and at the local public document room located at the-
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Perry Public Library, 3752 Main Street, Perry. 0hio 44081..
This exemption is effective upon issuance.
FOR THE NUCLEAR REGULATORY COMMISSION'
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i Bruce A. Boger,' Director Division-of Reactor Projects III/IV/V Off. ice of--Nuclear Reactor _ Regulation-L Dated at Rockville, Maryland
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this 19th day of March
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