ML20067D128
| ML20067D128 | |
| Person / Time | |
|---|---|
| Site: | Oyster Creek |
| Issue date: | 02/06/1991 |
| From: | Fiedler P GENERAL PUBLIC UTILITIES CORP. |
| To: | NRC OFFICE OF INFORMATION RESOURCES MANAGEMENT (IRM) |
| References | |
| C321-91-2024, GL-90-08, NUDOCS 9102120341 | |
| Download: ML20067D128 (7) | |
Text
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GPU Nuclear Corporation
?{ U Egg Pawppany. New Jeri.ey 07054 One Upper Pond Road EM g -
201 316 7000 TE LEX 136-482 Wnte s Deect D.a! Number; r
february 6, 1991 d
C321-91-2024 U.S.
fluelear Regulatory Commisolon Attn Document Control Douk Washington, DC 20555 Dear Sir Subjects Oyster Crook Nuclear conorating Station Docket No. 50-219 Additional Information in Support of Simulator Cort.ification Exemption Roquent koforence:
1.
GPUN lottor irom E. E.
Fitzpatrick to NRC Document Control Dook, September 5, 1990.
2.
GPUN letter from E. E.
Fitzpatrick to T. T.
Martin.
September 20, 1990 Dy lotter dated September 5, 1990 (Ref. 1), GPUli requestod an exon'ption f rom tho i111ng requirement of 10 CFR 55.45(b)(2)(111) to allow for our submittel of NRC Form 4*14, " Simulator Facility Cortification" after the March 26, 1991 deadlino provided in the rulo.
In addition, we further requented an exemption from the requiremont of 10 CPR 55.45(b)(2)(iv) to allow un to continuo to adminiator the Dimulation facility portion of the annual operating toot on the fline Milo Point Unit 1 (!!MP-1 ) olmulator.
Thio roquest wau made under the proviolone of 10 CFR to.12 " Specific Exemptions" following the guidanco in NRC Generic Lotter 90-08
" Simulation Facility Exemptiono", dated August 10, 1990.
CPUN explained that epocial circumetancoe, ao not forth in 10 CFR 50.12(a)(2)(v),
are present justifying the exemption, namely that the exemption would provide only temporary rollof from the applicablo regulation and GPUN han mado good faith offorto to comply. GPUN ctated, baood on the elmulator project development echodulo at the timo, the certification form would be submittod no lator than December 31, 1991.
A mooting was hold with the NRC on January B, 1991 to diocune the otatuo of CPUN'o exemption requent.
At that mooting, GPUN agrood to provido additional information in uupport of the roquent, in particular, our analyole of the rolt.tivo bonofito of various alternativos for mooting 10 CFR 55.59 operator roqualification requiro-monto in lieu of using a cortified plant referenced almulator.
Thio analysis 10 provided in Attachment 1.
Daoed on our analypio of thoco alternativoo, CPUN 10 gr propoping to conduct operator requalification no well an additional operator k,fbr$$p[
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ovaluation and annosoment in 1991 ao identified in Attachment 2.
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{Jng(ig GPU Nucica' Corporobon m a subsdary of Genera' Pubhc Utmt<es Corporabon
o US. Nuclear Regulatory Commincion C321-91-2024 Page 2 As indicated in the attachments, GPUN has concluded that the NMP-1 simulator in the bent alternativo available for conducting a meaningful operating test and for satisfying the associated requirements of 10 CFR 55.59(a)(2),(3), and (4).
The NMP-1 simulator, using Oyster Creek specific software, can reproduce the general oporating characteristica of Oyster Creek and is very offective in ovaluating a crow's communication skills and team-dependent behavior in a real time environmont.
In order to further componsato for the lack of a cortified plant referenced simulator during the exemption period, CPUN is proposing to conduct additional operator ovaluations using the non-certified plant referenced simulator during factory acceptance testing.
This additional evaluation will noL be part of the operating test but will be done to emphasize procedure utilization (including omergency operating procedures), command and control, teamwork and communication and to identify possible generic weakneosos or areas where retraining is nooded.
The exnmption, if granted, would allow GPUN to continue to administer its operator roqualification program for a period of approximately 7 mor.the using the NMP-1 simulator as GPUN has dono for the past 6 years. GPUN has an NRC approved and INPo accredited operator regualificution program that in based on a systems approach to training.
The program was rated as satiofactory by the NRC as a result of a program ovaluation conducted in April-June, 1990.
Furthermore, sinco that program evaluation, CPUN has made significant improvements in the exam administration proceos, exam questions and simulator scenarios as identified in our lotter dated September 20, 1990 (Refereneo 2).
GPUN belloves that, during the exemption period, this program will contit da t o oneure that our operators possess the knowledge, skills and abilition needed to safely operato the plant.
If there are any quontions regarding this matter, pleano ca'.1 Mr. Michael Hellor, Licensing Engineer, at (609) 971-4680.
Vcry truly youro, h
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led er Vice President and Director Nuclear Accurance PBF/MNijc (All w/att) ect Adminiotrator Region 1 Sonior NRC Resident Inspector Oyster Crook NRC Project Manager R. Gallo
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Attachment &
Listed below 'are the pros and cons of various alternatives for meeting 10 CPR 56.59 operator requalification requiremente in lieu of using a certified plant referenced simulator.
1.
Nine Mile P_o[nt_ Malt 1 (NMP-1) Simulator before May 26. 1991 Pros Annual operating test requirement satisfied for 1991.
Cons:
Outage impact.
It is estimated that the cost of the outage will increase by approximately 10 million dollare due to disruption in pihnning and work caused by key managers, engineers, and operatore leaving the plant for extended periods of time when the plant is in abnormal and unusual lineups.
Not an Oyster Creek plant referenced simulator.
2.
2.
NMP-1 Simulator af ter May 26,.1991 Proes Minimal outage impact.
. Annual / biennial training schedule and cycles not perturbed.
Cons:
2 Does not satisfy 10 CFR 65.4B(b)(2)(iv) requirement to use certified plant referenced elmulator.
j.
General Commente Regarding the NMP-1 Simulator
-The simulator has an Oyster Creek specific software platter which helpe make the time and transient response of the NMP-1 simulator closely match that of Oyster Creek.
Over 900 hours0.0104 days <br />0.25 hours <br />0.00149 weeks <br />3.4245e-4 months <br /> of effort has been devoted co development of this software platter.
The NMP-1-simulator has been successfully used for training and evaluation of our operatore since 1985.
.The NMP-1 simulator.is. presently the best tool available for dynamic real time-training and evaluation of our operators - especially in the area of implementation of emergency operating-procedures (EOPe), team responce, and operator command and control.
, simulator can be used to conduct an operating test that requires the erator to demonstrate an understanding of and the ability to perform the actione nocessary to accomplish a comprehenelve sample of items specified in 10 CFR 55.45(a)(2) through (13).
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e C322-91-2024
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3.
Qyster Creek Simulator at Lhe Westinchouse Faellity in Monroeville. PA.
4 Pross j
The panels of this simulator exactly duplicate the Oyster Creek 1
control room (ficelity is greater than that of HMP-1 simulator).
l since the capabilities of the machine will be steadily improving over the year, most effective utilization of this machine for training and a
evaluation will occur late in 1991 concurrent with factory acceptance testing (FAT).
cons:
1 The training and evaluation potential of this machine will np1 t>
effective until later in 1991.
since use of this machine would occur during FAT, exact machine status and response may at times be very unpredictable.
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-Additionally, using the machine for training ard evaluatica during i
FAT will have some impact on the conduct and O. stion of FAT.
Lack of emergency plan communication facilities.
Difficult to write / validate scenarios when machine not operating in a routine mode with ready access by instructors.
Due to space constraints, the arrangement-of come of the major back panels is not identical to the control room, and access to these panels is restricted.
i Due.to the varying condition of the simulator, the exact training value of this one week of support is difficult to quantify.
- However, there clearly is a benefit to the operations personnel and it certainly will lead to improved understanding of plant operations.
Uncertainties associated with the machine preclude its use for pass / fail type of exams (anticipated machine failures, deficiencies, consistency of exam environment, and modeling fixes)..Additionall y, it cannot be assured that each crew would receive the same training / evaluation.
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C321-91-3034 1 (Cont'd) f 4.
Basic Prinelvagg Trainer (BPT)
Pross I
Allows real time exercise of celected EoPs and plant procedures.
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Located on site.
schedule is flexible.
The software of the BPT has been modeled specifically to simulate s
Oyster Creek systems.
Cons:
Not a plant referenced simulator.
Simulation of several systems not possible (e.g. standby gas treatment, primary containment, and most balance of plant systems).
The limited alarm board and indications of the DPT hinder the operators and STA from fully _ analyzing transients / problems on a real-tima basis with all information normally at their disposal.
l This, in addition to physical space constraints, impacts the effectiveness of team oriented training efforts.
Photocraphic control Room Mock-Un Pros Fairly accurate reproduction of Oyster Creek control room.
Located on site.
Schedule is flexible.
4 Cons l-Not dynamic.
Requires extensive verbal cueing to adequately provide information relative to scenacio at hand.
Not viable as a means of evaluating team interaction on a real-time i
basis.
Not viable as a means of accurately evaluating operator control of facility.
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o C331-91-2034 (Cont'd) l 6.
Plant Walk-Throuche
'l Pros Schedule is flexible.
I Training setting fidelity is high.
f Cons:
Not dynamic.
Requires extensive verbal cueing to adequately provide information relative to scenario at hand.
Not viable as a means of evaluating team interaction on a real-time basis.
7.
Ejant Evolutions. Plant Evento, Criticues Pros Allows first hand /real time observation of performance.
Training fidelity issue is moot.
Host valid assessment tool for characterizing operator performance.-
Cons:
Cannot be used for panh/ fail criteria.
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o Erpposed Operator Recualification. Additional Evaluation and Asseesment 1.
Pass / fall exams Written exams in accordance with NUREG 1021.
JPM exams in accordance with NUREG 1021. As previously discussed with NRC Region 1, these JPM's will compensate for the key differences between Oyster Creek and NMP-1 control rooms.
Operating exams using NMP-1 simulator in accordance with NUREG 1021.
2.
hdditional evaluation Six operating crews and STAS will participate in frctory acceptance testing of the plant referenced simulator at the Westinghouse simulator production facility in Monroeville, Pennsylvania.
Procedure utilization, command and control, teamwork and communication will be emphasized by our on-site operations department manager for each operating crew.
A simulator training inotructor will also evaluate and document individual operator and crew performance.
Depending upon operability status of the plant referenced simulator, this evaluation will include dynamic simulator exercises, static walk-throughs of transiunts, or selected control room tasks.
3.
On-coino assessment Utilize the basic principles trainer (BPT) to assess operator skills in the areas of EOP usage, communication, and command and control.
Utilize plant evolutions as an input to characterize and improve operator performance.
Utilize plant experience (LERs, critiques) as en input to enhance operator performance via correction on-the-spot or more globally via training.
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