ML20059J314
| ML20059J314 | |
| Person / Time | |
|---|---|
| Site: | Big Rock Point File:Consumers Energy icon.png |
| Issue date: | 09/10/1990 |
| From: | Crutchfield D Office of Nuclear Reactor Regulation |
| To: | CONSUMERS ENERGY CO. (FORMERLY CONSUMERS POWER CO.) |
| Shared Package | |
| ML20059J312 | List: |
| References | |
| NUDOCS 9009190260 | |
| Download: ML20059J314 (8) | |
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.g 7590-01 UNITED STATES OF AMERICA
,-l NUCLEAR REGULATORY COMMISS10N'
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In The Matter of C0llSUl!ERS POWER COMPANY l
Docket No. 50-155 L
(BigRockPointPlant)
EXEMPTION 4
I.
ConsumersPowerCompany(CPCo,thelicensee)isthe_holderofFacility Operating License No. DPR-6 which authorizes the operation of the Big Rock l
Point Plarit (the facility). at steady-state reactor power levcis not in excess l
l of 240 n.eSawatts therrnal (rated power).
The facility cclisists of one boiling water reactor located at the licensee's site in Charlevoix County, Michigan.
The license provides, arrong other things, that it is subject to all rules, regulations, and Orders of the Nuclear Regulatory Connission (Connission) now or hereafter in effect.
II.
l Section 55.45(b)(2)(ii) of 10 CFR Part 55 requires that an application for use of a sin.ulation facility be subnitted not later than 42 n.onths after the effective date of the Part 55 rule; that is, by November 26, 1990.
Further requirenients of-10 CFR 55.45(b)(2)(ii) state that the application be subniitted in ectordance with paragraph (b)(4)(1) of the sarne Section which requires the application to include "(C) A description of the perforrrance tests as part of' the application, and the results of such tests."
9009190260 900910 DR ADOCK 050001!55 PDC
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Ey letter dated April 4, 1990, the licensee requested a schedular l
exerption to de16y submittal of the performance' test requirements until May 26, 1991.
Consumers Power Company has submitted a Si9 Rock Point simulation facility application (excepting the perforrnance tests) in a letter dated June 29, 1990.
The application reflects a siinulation facility consisting of five parts:=(1) a full scale static mock-up;. (2) ~ partial task enhancements; (3) use of actual-plant;.(4)aLplantwalk-through;and(5)the:continueduseoftheDresdenfull scope sinulator. Some of the partial task enhancements will be accomplished I
by installation of a PC-based work statier, that models the Big Rock Point reactor core and primary system thermohydraulics. The work station will iriclude the capability for son'e input /outy:its (I/0) to be-dynamically simulated, thereby providir E a limited scope simulator (LSS) as part of the simulation fccility for Big Rock Point.
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Contractual agreements between the;1icensee and its supplier reflect delivery of the work station during November 1990. - The' performance testing specifiedby10CFR55.45(b)(4)((i)(C)cannotbeaccomplisheduntilafter receipt, it.sta11ation, and acceptance testing of.the work station. Acceptance testing is currently sc.teduled for completion during January 1991, and will include verification of the software outputs up to the termination units.-
Installation of the control room panel instrun'ents'and wiring from the panels to the terniination units may occur concurrent with installation of the work statfori; however, final ties at the. terminators will not occur before acceptance-testing has been conipleted. The acceptance tests results will become part of the 10 CFR 55.45 performance test program.
The test program must also include
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i verification of response at the par.e1 instruments.
In addition, the perforn.ance test program will ir.clude confirmation of other partial task enhancenients that will be installed in the LSS and will involve dynamic simulation with feedback, but will not directly tie-in as one of the I/Os to the work station.-
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-Thc Big Rock Point LSS will initially ince, orate the dynamics specified l
.by a control manipulation analysis and critica: system functions'specified by the Control Room Design Review Program. The LSS will be expanded via incorporation in the Intergrated Assessment Living Schedule to include other dyr.anics identified by training that will permit. effective demonstration of performance for various routine, cff-normal, and en.ergency procedures. Since the c'esign of the LSS provides for expansion of the facility to acconodate edditioral panel instrunients and controls, ar. appropriate freeze time must be esteb11shed for subrcittal of the perforn.ance testing progran and test results.
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Subsequent irsproven.cnts then, will be submitted vie a configuration nanagen.ent Frcsren.
A May 26, 1991, freeze date is selected as an appropriate extension for this exen,ption request.
"A description of the. performance tests as part of the l'
application, and the results of such t. :s" will be submitted by May 26, 1991.
That date rtflects the stage of LSS developnent at that time.
A schedular exemption until May 26,.1991, is appropriate for the Big Rock Point Sin.ulation Facility because:
(1)
It provides an adequate time, following acceptence testing'of.the work station for wiring.of par.el instrunients to the work station and subsequent petfornance testing,
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(2)
It provides for the long-term expansion of-the LSS via the Integrated Assessnent Living Schedule, and establishes a freeze date at which to:
.(en.plete instellaticn and perforrence testing of as seny of the additional pa:.tl-instrun+nts.5 possible to permit a more function 61 and complete sin.ulation facility.
(3)- It takes into consideration paragraph (b)(3)(ii) for facility licensee applicants, to allow 180 days before the date for conducting the
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operating test.
No operating test will be pronosed for Big Rock Point during the 180-day period followi~' y-l 1 '..
(4) The May 26, 1991, date is specified by regulation in that peregraph (b)(2)(iv) requires, "the simulation facility portion of the. operating test will r.ct be administened on other then a-certified er an approved siniulatior, f acility after May 26, 1991."
Eased on the above, the steff has determined that.the schedule proposed by the lictosee for subn.ittal of the perforn.ar.ce tests requirenents of its applic6 tion is acceptable.
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The Corrmission has determined that pursuant to 10.CFR 555.11; the exemption 4
is authorized by law and will not endar.gt.r life or property and is otherwise iii tbt public interest.
Furthermore, the Conenission heis determined pursuant to '
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10CFR50.12(a)thatspecialcircumstancesof10CFR50.12(a)(2)(v)are appliteble in that the exemption wculd provide only temporary rolief from the erplicable-regulation and the licensee has inade good faith efforts to comply.
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with the regulation. This exemption grants a temporary relief period of six mer,ths front the Novenber 1990, date for submittel of part of the Big Rock L
Point application for use of the siniulation facility. Good faith efforts to comply with the regulation were itade'as follows:
(1) Inmediately following publication of the new Part 55 rule, Big Rock L
Point joined with three other facilities to form the Utility.
Simulation Fecility Group (UFSG).
(2) During the development of the plan, the UFSG interacted with'NRC in n.eetings on September 15 and 16,1987, and Decernber 7,1987, to obtain.
comments and ur.derstandings.
l (3) A final USrG document was issued on April 5,.1988, that provided
" Guidance for the Development of a Siniulation Facility to Meet the l
Requirements of 10 CFR 55.45."
(4) Consumers Power Company submitted a Big Rock Point Plant specific l_
Simulation Facility Plan that incorporated and reflected the USFG guidance document plans by letter' dated May.-26, 1988.
(5) KPC letter dated April 10, 1989, provided consents to the licensee's May 26, 1988, Simulation Facility Plan. The NRC comments indicated that the licensee would probably not be successful in justifying j
continued use of the Dresden simulator, even if they performed "the research and analysis required to support" their position. The-letter stated, "the major physical' fidelity deviation expectedi to exist between the Big Rock Point control room and the Dresden sirrulator are not likely to be sustained for use by such an analysis."
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t (6) Consumers Power Company met with NRC on May 9,1989, to discuss NRC i
concents regarding their proposal, and the need to apply for exemption; since resolution of-NRC comments seemed to require a plant-specific simulator.
(7) NRC letter dated June 12, 1989 documented the May 9, 1989, n.eeting and.
sunmarized the conclusion as follows:
"It was also erphasized that if a plant-cpecific simulator would not be available Consumers Power
.j Corpany was to provide a-program with the submittal on how the NRC would evaluate the license students."
(8) On September 7,1989, Consumers Power Company met with NRC-to present'-
i a plan ~that specified how the-NRC would evaluate Big Rock Point-j operators, using Dresden controls with Big Rock Point specific labels, panel overleys, and other enhancen,ents. This erproach was to be combined with use of the actual plant' and' a conalitnwnt 'to develop a j
full-scale site mock-up of the Big Rock Point control room. The licensee expressed concern that an analysis to' identify deviations-and justify the differences between the Dresden simulator and Big Rock-
- j Point control room could be cost prohibitive.
(9) HRC letter dated October 2, 1989, documented the-Septemb a 7, 1989, j
meeting and sunciarized the NRC staff position as follows:- '~"The staff indicated that the fidelity' issue can be addressed by other techniques with an analysis of any exceptions of deviations. These other techniques would model Big Rock Point processes to compensate for-the Cresden simulator differences. The plan should be packaged as close as possible to the rule."
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'h (10) Working n.eetings and telephone conference calls held with NRC and l
Region staff members which_ included a meeting on October 12, 1989; a conference call on October 25.-1989, and a meeting on November 13, 1989, identified alternative courses of action in lieu of spending an estimated additional 1.million dollars on an analysis that offered little-in return except. justification for doing what was already proposed'in the docketed simuletion facility plan.
(11)' On December 19, 1989, a-letter of intent with a simulator vendor'was signed to purchase a work station that provides a real-time thermohydraulic code of the Big Rock Point reactor core and.prinary system.
(12) Durin9 December 1989, and January 1990, rethodology was developed 1
for a control manipulation analysis that would evaluate: operator s
actions to identify which part task sin.ulation devices were appiopriate to be included in a Big Rock Point plantispecific limited scope simulator.
(13) In December 1989, Jar.uary and February 1990, construction of the Big I
Rock Point plant-specific mock-up and limited scope simulator began. Software development for the work station was'also initiated.
(14) On February 27, 1990, Censumers' Power Company met with HRC to present' our revised approach for the Big Rock Point Plant Simulation l
L F6cility.
In that ineeting, NRC-expressed concern that it was l
important for Consumers Power Company to submit an exemption request.
as soon as possible if we identified that we could not r.eet the timingrequirementsspecifiedby10CFR55.45(2)(11).
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-B-(15) The licensee submitted on exemption request on April 4, 1990, i
(16) The licensee submitted an application'(excepting the performance:
tests)onJune 29, 1990..
The Comission hereby grants an exemption from the schedular requirements of10CFR655.45(b)(2)(ii)forsubmittalofa'descriptionoftheperformance test and the results of the performance tests aslpart of the submittal of-an-1 application for use of a simulation facility.
This exemption is effective j
until Mey 26, 1991, i
Pursuant to 10 CFR 551.32, the Comissien has determined that the-i issuance of the exernpticn will have no significant impact on the environment L
(55FR35382, August 29,1990).
The licensee's request dated April 4, 1990, is available for public inspection at the Comission's Public Docurnent Room 2320 L. Street,-NW.,
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' Washington, s.C. and at the North Central Michigan College, 1515 Howard Street, Petuskey, Michigan, i
This exenption is effective upon issuance.
FOR THE NUCLEAR REGULATORY: COMMISSION 1
. V f k.
De:
rutchfield,'Dir tor-Division'of Reactor Pr ects III, IV,'V 8-Special Projects Office of Nuclear Reactor Regulation-Dated at' Rockville, Maryland this 10th day of Septembbr 1990.
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