ML20058F395

Forwards Request for Exemption from Simulator Certification & Operation Requalification Schedule Requirements

ML20058F395
Person / Time
Site:	San Onofre
Issue date:	11/02/1990
From:	Rosenblum R SOUTHERN CALIFORNIA EDISON CO.
To:	NRC OFFICE OF INFORMATION RESOURCES MANAGEMENT (IRM)
References
NUDOCS 9011080254
Download: ML20058F395 (11)

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Southern California Edison Company 23 PARKER STREET IRVINE. C ALIF ORNIA 92718 November 2, 1990

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, m a a a E.* L a n a n U. S. Nuclear Regulatory Commission Attention: Document Control Desk Washington, D.C.

20555 Gentlemen:

Subject:

Docket No. 50-206 Exemption Request for Simulator Certification and Operator Requalification Exam S.hedule San Onofre Nuclear Generating Station Unit 1

Reference:

Letter, R. M. Rosenblum, SCE, to NRC, " Request for Exemption from Schedular Requirements of 10 CFR 55.45 to Allow for Implementation of a Plant Reference Simulator," dated March 23, 1990, in response to NRC concerns expressed during recent meetings, we have developed a new plan for implementing a plant reference simulator (PRS) for SONGS 1.

The new plan allows initial operator exams on the PRS in April,1992 at the vendor's facility and requalification exams in October,1992 at SONGS.

Thisschedulesatisfiestherequirementof10CFR55.45(b)(2)(iv)toconduct operator exams performed after May 26, 1991, on a PRS. With this plan, we no longer require an exemption from that requirement and retract our previous request (seereference). However, a new exemption is needed since our plan i) schedules submittal of PRS certification by February 5,1992, which does not meet the March 26, 1991 deadline specified by 10 CFR 55.49(b)(2)(iii), and ii) requires a one time,18 month interval between operator requalification exams scheduled for April,.1991 and October,1992 rather than the annual interval required by 10 CFR 55.59(a)(2).

BACKGROUND The NRC revised 10 CFR 55 in 1987 to improve the operator licensing process.

The revised sections of 10 CFR 55.45 (simulator rule) require that operators complete practical examinations on either a certified PRS or on a simulation facility otherwise approved by the NRC. We initially planned to satisfy this-requirement by modifying the Zion simulator. To support this approach, we formed the Utility Simulator Facility Group to develop guidance for use of non-PRS simulation facilities to comply'with the simulator rule.

Our plan for use of the Zion simulator was submitted to the NRC in May, 1988.

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Document Control Desk November 2, 1990 However, the NRC expressed significant concern in their letter dated January 3, 1989, about the physical and functional fidelity differences between SONGS 1 and the Zion facility. After further evaluation, we concluded in mid-1989 that it was not practical to satisfy the simulator rule by modifying the Zion facility.

As a result, we notified the NRC in October, 1989 of our plan to install a PRS. Our schedule for conducting operator exams on the PRS was indicated in a March 23, 1990 letter to the NRC. We committed in that letter to ip4 1 ate operator training at SONGS by February,1993.

The proposed schedule 6equired an exem) tion since operator exams were to be continued on the Zion facility after t1e May 26, 1991 deadline until the PRS was completed.

We met with the NRC on September 17, 1990, to discuss our plans for implementing the. SONGS 1 PRS and our associated exemption request.

Based upon NRC concerns expressed at that meeting and subsequent meetings on October 4 and October 19, 1990, we have developed a new plan for conducting operator exams on a PRS.

RETRACTION OF PREVIOUS EXEMPTION RE0 VEST Our new plan satisfies the requirement of 10 CFR 55.45(b)(2)(iv) to conduct all operator exams )erformed after May 26, 1991, on a PRS. We will comply with that deadline )y initially conducting operator exams after that date on the PRS at the vendor's site in Montreal, Canada. Therefore, with this letter we retract our previous exem) tion request regarding cperator examinations on a PRS. However, as discussed )elow, a schedular exemption from the certification requirements of 10 CFR 55.45(b)(2)(iii) and from the requirement of 10 CFR 55.59(a)(2) for annual operator requalification exams is required.

REVISED SCHEDULE FOR SIMULATOR IMPLEMENTATION AND OPERATOR EXAMINATIONS As a result of our recent meetings with the NRC, two new options have been developed to comply with the simulator rule so that operator exams performed after May 26, 1991, are conducted on a PRS. These o)tions are identified as Options A and B in Figure 2-1 of the enclosure.

Eac1 option satisfies 10 CFR 55.45(b)(2)(iv) by initially completing operator training and examinations on the PRS at the vendor's facility.

For comparison purposes, the major milestones for our previous PRS implementation schedule and our new Options A and B are presented below.

Document Control Desk November 2, 1990 Operator Trainina Milestones Previous Milestone Schedule Option A Option B 1.

Conduct operator requalification 10/91 4/91 4/91 examinations.

Zion Zion Zion 10/92 10/92 10/92 Zion SONGS Montreal 2.

Conduct initial operator 4/92 4/92 10/92 examinations.

Zion Montreal Montreal 3.

Submit certification request to 12/92 2/92 8/92 the NRC for use of SONGS 1 PRS.

4.

Complete installation of Control 2/93 2/93 2/93 Room Design Review modifications and other Cycle 12 changes on the PRS and initiate operator training at SONGS.

We have revised our plans from that of the referenced letter and are now aggressively pursuing Option A.

Option B is a backup plan that will be relied upon only if dictated by PRS delays.

Our new plan includes some changes to the locations and timing for operator exams to be completed in 1991 and 1992. Specifically, both options require rescheduling the upcoming operator requalification exams from October, 1991 to April,1991, in order to complete the exams at Zion before the simulator rule

date, in addition, Option A entails conducting initial operator exams on the PRS in April, 1992 at the vendor's facility, ship)ing the PRS to SONGS, and performing requalification exams at SONGS in Octo)er,1992.

The locations and timing for the October,1992 operator requalification exams were selected, in part, to aid NRC manpower planning as requested during the meeting on October 19, 1990. A one time exemption from the requirement of 10 CFR 55.59(a)(2) for conducting annual-requalification exams is necessary to support this proposed schedule.

The exemption is needed since the April,1991 and October,1992 exams are scheduled on an 18 month interval rather than annually as required by that regulation.

As discussed during our meetings, Option A is an aggressive schedule.

Should PRS delays dictate reliance on backup Option B, the A operator exams will be rescheduled to October,1992 (pril,1992 initial at our vendor's site in Montreal, Canada). Our )lans for completing operator examin:tions consistent with Option A will be su)mitted in our upcoming response to Generic Letter 90-07, " Operator Licensing National Examination Schedule."

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Document Control Desk November 2, 1990 It is our understanding from the discussions during the recent meetings that the proposed approach is agreeable to the NRC and that the NRC will support operator examination schedules for either Option A or B.

It was also indicated that the NRC will schedule exams in Montreal, Canada and/or at SONGS as needs dictate.

If there are delays which dictate reliance on backup l

Option B, we will promptly notify the NRC and submit a revised exemption 8

request.

EXEMPTION FROM SIMULATOR AND OPERATOR RE0VAllFICAT10N SCHEDULE RE0VIREMENTS We are pursuing Option A for implementing the SONGS 1 PRS. As discussed in the enclosed exemption request, that implementation p(lan requires an exemption c

from the schedule requirements of 10 CFR 55.45(b)(2) iii) and 10 CFR 55.59(a)(2). Therefore, we respectfully request that the NRC grant a schedule exemption to allow: i) submittal of the request for certification of the r

SONGS 1 PRS by February 5, 19f,2, and 11) a one time, 18 month interval between requalification exams in Apri':, 1991 and October, 1992.

If you have any questions on this inatter, please contact me.

Very truly yours, kM Enclosure cc:

J. S. Martin, Regional Administrator, NRC Region V C. Caldwell, NRC Senior _ Resident inspector, San Onofre Units 1, 2 and 3 3

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REQUEST FOR EXEMPTION FROM SIMULATOR CERTIFICATION AND OPERATION REQUALIFICATION h

~ SCHEDULE REQUIREMENTS i

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TABLE OF CONTENTS Section Eagg 1.0 Exemption Request.......................

1 2.0 Background..........................

1 3.0 Justification for Exemption..................

4 4.0 Conclusions..........................'. 5 p.

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y REQUEST FOR EXEMPTION FROM SIMULATOR CERTIFICATION AND OPERATOR REQUALIFICATION SCNEDULE REQUIREMENTS SAN ON0FRE NUCLEAR GENERA 11NG STATION UNIT 1 1.0 EXEMPTION REQUEST 4

'We-have initiated the.necessary steps to procure a plant reference i

simulator (PRS) for San Onofre Unit 1 (SONGS 1).

Examinations required by 10'CFR 55.45(a) will be conducted on a PRS within the schedule limits specified by 10 CFR 55.45(b).

However, for the reasons discussed in this exemption request,.

certification of the-SONGS 1 PRS cannot be accomplished within the time frame required by 10 CFR 55.45(b)(2)(iii)..That> regulation recuires certification forcuse of the simulator facility (to be submittecwithin 46 months after.the effective date of the rule i.e.. by March 26, 1991). Our' schedule is.to have a PRS available for initial operator-exams'at our vendor's ' site in April,1992. We propose submitting the i

certification two months before these first operator exams on the. PRS.

t We,have also scheduled the 1992 operator requalification_ exams on an 18 month, rather than annual, interval. This schedule was selected,.in-j part,;to accommodate NRC. manpower planning. A'one time exemption from the annual requalification exam requirement of 10 CFR 55.59(a)(2) is.

needed to support'this-proposed schedule.

4 We. request that' the NRC grant an exemption from the requirements of 10 CFR 55.45(b)(2)(iii) and 10 CFR 55.59(a)(2) to allow:

Submittal of the SONGS 1 PRS certification by February 5, 1992

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- *L Scheduling operator requalification exams in April,1991 and

= 0ctober 1992, an 18 month interval.

This' exemption is being requested'under the provision of 10 CFR 50.12,

" Specific Exemptions," which allows the' Commission to grant such exemptions.

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2.0 -BACKGROUND' i

Issuance'of R~le and Formation of ' Utility Group ~

The.NRC. revised 10 CFR 55 in 1987 to improve the operator licensing

.grocess..Therevisedsectionsof10CFR55.45,.referredtohereasthe-simulator rule," require that operators perform, as part of the

- licensing process, a' practical examination on.either a: certified PRS or.

on a= simulation _ facility otherwise approved by the Commission.-

Following issuance of these revisions,.we formedJan industry group to I_

develop' uidance for using non-plant reference: simulation facilities to comply w th the. simulator rule. The industry group, the Utility 3

Simulator Facility Group.(USFG), worked closely with NRC Staff personnel

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to develop acceptable guidance for members to use in complying with the

< simulator rule. Since we have had good success at the Zion simulator j

-and have u) graded the fidelity of that facility, we initially planned to comply wit 1 the regulations by continued use of the Zion facility.

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Eyaluation of NRC Concerns with Physical Fidelity l

We submitted a simulation facility development plan to the NRC on L

May 26, 1988.

The plan was based upon implementation of the USFG guidance to qualify the Zion simulator for use as.a SONGS 1 simulation y

facility.

In responding to that plan, the NRC indicated in a January 3,1989 letter + hat significant concern. remained 'with respect to the physical and functional fidelity differences between SONGS 1 and the Zion k

simulator. This NRC' assessment meant that a major effort would be E

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. We concluded in mid-1989 that it was not prac'ical to make the modifications necessary to meet the requirements of the regulation.

Commitment to Install Plant Reference Simulator As discussed in our letter dated October 2,1989, we decided to install l

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a PRS rather:than rely on a modified version of the Zion facility. Our h

original schedule for conducting operator exams on the. SONGS 1 PRS was ~

' described in our March 23, 1990 letter.

That letter committed to having the PRS available for operator training' at SONGS by February,1993.

The letter also requested an exemption from the. schedule requirements of

'10 CFR 55.45(b)(2)(iv). The request was necessary.since, with our I;

earlier PRS ' implementation plan, we would have been unable to conduct L

all; operator exams performed after May 26, 1991, on a PRS.

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. Revised ~ Implementation Plan for Plant Reference Simulator

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Meetings we'e held with the NRC staff on October 4 and.0ctober 19,.1990, y

to discuss our plans'for the' SONGS 1 PRS. Those meetings resulted'in 1

two new schedule options (Options A and B in Figure 2-1). We'are-1 actively;p(b)(2)(iv)ption A to satisfy the schedule requirements of 10 ursuing O '

CFR 55.45

. -That plan schedules the first operator exams performed after May 26, 1991, to be conducted'on the PRS in April,1992 at our vendor's site in Piontreal,; Canada.. Backup Option B'will only be Ladopted if. our vendor is unable to maintain the aggressive schedule -

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Option A entails disassembling the PRS after the initial l operator exams, 3

T shipping,it to. SONGS, and )erforming operator. requalification exams at SONGS in October, 1992.

T1e timing and locations for the October, 1992.

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c operator requalification exams were selected, in part, to aid NRC manpower planning as' requested by the NRC during our meeting on October 19, 1990. The schedule for operator requalification exams embodied by either Option A or B requires a one time exemption from the requirement of 10 CFR 55.59(a)(2) for conducting annual requalification exams.

This exem) tion is needed since requalification exams are scheduled 18 montis apart in April,1991 and October,1992.

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j Option A also requires an exemption from the certification schedule requirement of 10 CFR 55.49-(b)(2)(iii) to allow submittal of PRS certification by February 5, 1992.

As discussed with the NRC staff during the recent meetings, the certification request will identify additional exceptions to ANSI 3.5 (1985) guidelines that are associated with the physical environment at the vendor's facilities.

3.0 JUSTIFICATION FOR EXEMPTION We are requesting an exemption from the schedule requirements of 10 CFR f

55.45(b)(2)(iii) and 10 CFR 55.59(a)(2) to allow:

i) submittal of the 1

PRS certification by February 5,1992 and 11) an 18 month interval l

c' between operator requalification exams scheduled for April,1991 and-October, 1992. The requested exemption is justified based upon the following considerations:

1 We will meet the intent of the simulator rule by conducting a

all operator exams'that are scheduled after May 26, 1991, on the SONGS l' PRS. This will initially be achieved by L

performing exams in A)ril,1992, at the vendor's site in Montreal, Canada. Su) sequent exams will be completed at SONGS.

i We propose submitting the. SONGS 1 certification two months a

I before the first operator exams'in April',.1992.

This timing

-for PRS certification is consistent with the intent of 10 CFR.55.45(b)(3)(iii), which requires simulator certificatjon i

two' months before conducting operator exams.

Our initial-approach for complying with the simulator rule was.to rely on the use of,a modified version of the Zion simulator facility. However, based upon discussion with the NRC, we recognized'it may not be practical to complete the modifications of.the Zion facility.that would be needed to

- i obtain.NRC approval. -Therefore, we decided in mid-1989 to procure a SONGS 1 PRS. By that time, a.significant )ortion.

of the period allowed-for licensees' to comply with tie simulator rule had elapsed.

Despite1the delayed start in-procuring the PRS, we plan to meet the intent of the rule by conducting all' operator examinations p.erformed after May 26, 1991, on a PRS.'

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't Once the decision was made, we pursued obtaining the PRS and awarded a contract in March, 1990, that is based on a 24 month completion schedule.

In addition, we are arranging i

to schedule operator exams on the PRS at the vendor's factory before its shipment.to SONGS.

t Our request'for. delayed PRS certification will have no impact on our ability to satisfy the rule's schedule requirements for operator examinations.

Each option schedules operator requalification exams in April, 1991 and 0ctober, 1992. This timing was selected, in part, to assist NRC manpower planning.

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CONCLUSIONS' We will comply with the simulatsr rule by implementing a PRS.

The

. requirement for conducting all operator exams performed after May.26, as 1991, on a PRS will be satisf,ed by i) expediting the PRS schedule and

11) scheduling operator exam' at the vendor's site.

However, our PRS procurement schedule does net allow submittal of the request.for PRS certification within the 46 month period (March 26,1991) specified by the. simulator rule.

InLad(ition.we have scheduled operator requalification exams in 0 tober,1992 even though that timing i

represents an 18 month, rather than annual, exam interval. This 18 month interval.for-requalification examination was selected, in part, to assist NRC manpower planning.

-We request'the NRC grant.an extension until February 28. 1992, for submittal of the SONGS'1 PRS certification and allow operator requalification exams to be conducted in April,1991 and October,1992.

.We will.promptly notify the NRC and submit a revised exemption request consistent with Option B if.necessary.

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