ML20059F512

Requests Exemption from Filing Requirement of 10CFR55.45(b)(2)(iii) to Allow Submittal of NRC Form 474, Simulator Facility Certification, After 910326 Deadline & to Allow Administering of Simulator Portion of Test

ML20059F512
Person / Time
Site:	Oyster Creek
Issue date:	09/05/1990
From:	Fitzpatrick E GENERAL PUBLIC UTILITIES CORP.
To:	NRC OFFICE OF INFORMATION RESOURCES MANAGEMENT (IRM)
References
NUDOCS 9009110236
Download: ML20059F512 (3)

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, J.", . GPU Nuclear Corporation -

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609 971 4000-Writer's Direct Dial Number:.

7 September 5, 1990 U.S. Nuclear Regulatory Commission Document Control Desk

- - Washington,'D.C. 20555 Gentlemen a . Subject Oyster Creek Nuclear Generating Station Docket No. 50-219 Request for Exemption from 10CFR55.45(b)(2)(111)

Filing Deadline, and 10CFR55.45(b)(2)(iv)4

' GPUN.hereby requests an exemption from the filing requirement of-10CFR55.45(b)(2)(lii) to allow for our submittal of NRC Form 474, " Simulator Facility Certification" after the March 26, 1991 deadline provided in the-rule.- In addition, we further request an exemption from the requireraent of 10CFR55.45(b)(2)(iv) to allow us to continue to administer the simulation-

..l' facility, portion of the operating tests on the Nine. Mile Point Unit:1-(NMP-1)

- simulator.

-GPUN intends to comply with 10CFR55.45(b) by certifying a plant referenced simulator facility in accordance with 10CFR55.45(b)(1)(ii). In January,'1988,

/ , GPUN entered into contract.with a vendor for' construction'of a state of the art.

, w. . plant referenced simulator. In March, 1988, a-simulator management department was organized in recognition of the increasing effort required to: acquire, modify,? operate, maintain and make the most effective uselof the simulator.

GPUN has. committed significant effort and expense in order to provide our operators with the beat' training avhilable.

m The development schedule-called for the simulator to be ready for training by october 17, 1990, and the contract included a penalty.to provide incentive for-f' the vendor to meet the schedule. Due to a technical difficulty' encountered in modeling Oyster Creek's nuclear' steam supply system, the vendor has now.

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projected that the simulator will not be ready for training.until Junei'1991 and the penalty'was effected. Since this is the vendor's first balling water reactor simulator, modeling the thermal-hydraulic characteristics of Oyster g Creek's boiling water reactor has become a significant challenge for the vendor. Although we have made a good f aith ef fort to comply, bassed upon the current, development schedule, it will not be possible to complete all of the acceptance testing necessary to certify the simulators' performance by the required deadline.

9009110236 900905 PDR ADOCK 05000219 P PDC i

GPU Nuclear Corporation is a subsidiary of General Public UtAt.cs Corporation g/

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US Nuclear Regulatory Commission

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Consequently, GPUN proposes continuing operator training and examination using the NMP-1 simulator, pending agreement with NMP-1 management, up to and including NRC administered examinations scheduled for October 1991.. GPUN will certify the plant referenced simulator no later than December 1991 and will '!

conduct training and examinations on the new simulator.thereafter. GPUN i' believes this'is'a realistic proposal considering the simulator development schedule and the need to conduct operator training with the new simulator for a r period of time before examinations are administered with the new simulator.

- GPUN believes that special circumstances are present as defined in-10CFR50.12

- to justify the exemption requested. The exemption would provide only temporary relief from the regulation and GPUN has made a good faith effort to comply.

Further, the Commission has recognized that unique circumstances may arise on a plant specific basis that cause some deviation.from the time requirements established in the-rule according to the supplementary information published-with the final rule (52 FR 9453).  :

Based on the above discussion and in accordance with the provisions of.

10CFR50.12, GPUN requests the following exemptions:

l '. A specific exemption from 10CFR55.45(b)(0)(iii) allowing submittal-of Form 474 no later than December 31,'1991, and

2. A specific exemption from.10CFR55.45(b)(2)(iv) which will allow use E of the NMP-1 simulator until the new simulator's certification is complete.

'If'there are any questions regarding this matter, please call Mr. Michael Heller, Licensing Engineer, at-(609) 971-4680.

Very.truly yours, I

E. E. Fit atrick Vice President & Director ,

Oyster Creek l

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p p p' cc t ' Mr. Thomas Martin, Administrator ,

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U.S. Nuclear Regulatory Commission

'475 Allendale Road

• King of Prussia, PA 19406

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Mr. Alexander W. Dromerick, Project Manager U.S. Nuclear Regulatory Commission

' Division of-Reactor Projects I/II Washington, DC 20555 Mr. Richard J. Conte, Chief BWR Section, Operations Branch Region-1 U.S. Nuclear Regulatory Commission

475 Allendale Road i King of Prussia,f PA 10406.

NRC Resident Inspector j Oyster Creek Nuclear Generating Station -

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