ML20085L466
| ML20085L466 | |
| Person / Time | |
|---|---|
| Site: | Oyster Creek |
| Issue date: | 10/28/1991 |
| From: | Fiedler P GENERAL PUBLIC UTILITIES CORP. |
| To: | NRC OFFICE OF INFORMATION RESOURCES MANAGEMENT (IRM) |
| References | |
| C321-91-2293, NUDOCS 9111040177 | |
| Download: ML20085L466 (5) | |
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GPU Nucle ar Corporation U Nuclear raruppany, New Jerwy 07054 4
201 316-?000 TELEX 130 402 j
Writor's 06tect osal Numtw october 28, 1991 i
C321-91-2293 U.S. Nuclear Regulatory Commission Attention: Document Control Desk Washington, D.C.
20555 1
Gentlemen:
Subject:
Oyster Creek Nuclear Generating Station Docket No. 50-219 Status of Plant-Referenced Simulator Ref:
(1)
NRC letter, A. Dromerick to J. Dorton, dated March 27, 1991,
" Exemptions from Certain Requirements of 10 CFR 55.45 (b)(2)(iii) & (iv)".
(2)
GPUN letter, E. Fitzpatrick to NRC Document Control Desk, dated September 5,1990, " Request for Exemption from 10 CFR 55.45(b)(2)(iii) Filing Deadline, and 10 CFR 55.45(b)(2)(iv)".
(3)
GPUN letter C321-91-2024, P. Fiedler to NRC Document Control Desk, dated February 6, 1991, " Additional Information in Support of Simulator Certification Exemption Request".
NRC letter dated March 27, 1991 (Ref. 1) granted CPUN temporary exemptions from certain requirements of 10 CFR 55.45(b)(2)(iii) and (iv). An exemption from the filing requirement of 10 CFR 55.45(b)(2)(lii) was granted to allow for the submittal of Form NRC-474, " Simulation f acility Certification", af ter the March 26, 1991 deadline provided in the rule, but no later than December 31, 1991.
Also, an exemption from the requirement of 10 CFR 55.45(b)(2)(iv) was granted to allow GPUN to continue to administer the simulation facility portion of operator exams on the Nine Mile Point Unit 1 simulator.
The purpose of this letter is to inform you of the current status of our plant referenced simulator project, our efforts to expedite its' completion, projected schedules for completion, and the options we are considering for conducting operator training until the simulator is available. This information is provided as an attachment to this letter.
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i 0321-91-2293 Page 2 As explained in the attachment, we have asked our vendor to pursue (in a parallel effort) the purchase and development of a proven NSSS model to replace the current model if the technical dif ficulties cannot be resolved satisfactorily.
This is intended to be a contingency plan; the first model to work successfully will be used.
Our goal is to provide the most ef fective training possible for our operators both now and in the future.
Accordingly, we have been working aggressively to expedite completion of the plant-referenced simulator while insisting on a quality product that meets our specifications and proves useful for operator training and evaluation.
Until the simulator is ready for training, we will continue to administer our INPO-accredited operator requalification program utilizing the most effective training tools available.
At this time, we anticipate the need for an extension of the above exemptions, it will not be possible to complete all of the acceptance testing necessary to certify the simulator's performance by December 31, 1991. This is due primarily to our vendor's lack of progress in resolving technical dif ficulties associated with modeling Oyster Creek's nuclear steam supply system (NSSS).
As a followup to this letter, we recommend that a meeting be held in the December timeframe to allow us to brief your staf f on our progress, to firm up the course of action to be taken, and to finalize what exemptions or NRC approvals will be required.
If there are any questions regarding this matter, please call Mr. Michael Heller, licensing Engineer, at (609) 971-4680.
Sincerely,
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ledler Vice President and Director Nuclear Assurance cc:
Administrator, NRC Region 1 Senior NRC Resident inspector Oyster Creek NRC Project Manager R. Gallo
C321-91-2293 Attachment Page 1 of 3 Mlafistill
- 1. Simulator Developmeat Statui in our exemption request dated September S, 1990 (Ref. 2), we identified the reason for slippage in the simulator development schedule to be the result of a technical difficulty encountered by our vendor in modeling Oyster Creek's nuclear steam supply system (NSSS).
This is the vendor's first boiling water reactor simulator and modeling the thermal-hydraulic characteristics of Oyster Creek's boiling water reactor has been a significant challenge for the vendor.
Currently, the NSSS model can support normal operations (startup, shutdown) and transient tests such as manual scram, turbine trip, MSIV closure, etc. However, it is still not able to simulate a range of loss of coolant accidents (LOCAs) without eventually becoming unstable, in addition, repeatability problems have hen encountered relative to certain transients which do run on the machine. As a result, it will not be possible to complete all of the acceptance testing necessary to certify the simulator's performance by December 31, 1991.
In September,1991, in reaction to this continued lack of progress, we asked our vendor to (1) hire an outside consultant with real time simulator experience to evaluate the NSSS model and make recommendations for correcting the problems, and (2) in a parallel effort, pursue the purchase and development of a proven NSSS model (a working NSSS model developed by an outside vendor) as a contingency in case the problems with the current model can never be resolved satisfactorily.
Our vendor agreed to this new approach. An outside consultant has been hired and is currently evaluating the NSSS model, and proven NSSS models are being evaluated. The first NSSS model to be completed successfully will be installed 1
on the simulator.
The current simulator development schedule is provided in lable 1.
The target dates identified reflect a very aggressive schedule that allows for no further slippage, however we are working closely with our vendor and making every c
reasonable effort to meet this schedule.
lable 1 Current SLmulator Development Sc_heduls a
Milestone Targe1J11ts Start GPUN factory Acceptance Testing (FAl) 11/4/91 (See Note 1)
Complete GPUN FAT 3/6/92 Pack and Ship Simulator 4/6/92 Submit Simulator Certification 4/6/92 Simulator Ready for Training 5/1/92 Simulator Ready for Operator exam 11/1/92
Attaciiment Page 2 of 3 This schedule reflects our_ intention to. certify the simulator while at the vendor's facility in Monroeville, Pennsylvania, lhis will of course result in certain physical fidelity discrepancies that will be listed as exceptions to certification on NRC Form-474. Additional exceptions _ identified during factory acceptance testing (FAT) may be listed in the interest of complying with 10 CfR U.45(b)(2)(iii) at the earliest possible date, However, we believe that it is in-our best interest to minimize any exceptions prior to certification and prior to accepting delivery of the simulator.
lhis will maximize the quality _of training for our operators.
II. Proles.ted Schedule Table 2 reflects what we believe is a reasonable schedule to consider at this 4
time for the purpose of GMifying what exemptions may be needed. This schedule assumes the current N!.SS model, which is still under development, is used, it also reflects the need to conduct 3 cycles (6 months) of training on the simulator before an exam can be conducted or the simulator.
Table 2 Pro.iected Schedule UsirLq Current NSSSjiodel Milestone Dale Start GPUN FAT 11/4/91 (See Note 1)
Complate GPUN FAT 6/6/92 Submit Simulator Certificatior, 7/6/92 Pack and Ship Simulator
- 7/6/92 Simulator Ready for Training 9/6/92 Simulator Ready for Operator Exam 3/6/93 The schedule in Table 2 would require an exemption from_10 CFR 55.45(b)(2)(iii) to allow until July,1992 for submittal of Form NRC-474, and an exemption fro:n 10 CFR 55.45(b)(2)(iv) to allow use of the Nine Mile Point Unit _1 (NMP-1) simulator-for operator exams in 1992. Rather than using the NNP-1 simulator in 4
1992, another option would be. to request a 6 month exemption from 10 Cf R 55.59(a)(2) to allow the 1992 operating exams to be conducted on the new simulator in April-through June, 1993 in accordance with the national exam schedule.
Table 3 reflects a schedule that assuaies the _use of 0-different vendor's proven NSSS model. _The vendor of a proven NSSS model currently being-evaluated has estimated that it will take 7 and 1/2 n.anths to fully develop and integrate their model into our simulator.
The vendor claims a 75% confidence level in this schedule.
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Attachment Page 3 of 3 Table 3 Erfitc1td Schedule Usina Proven NSSS Model Milestone Qate Start GPUN FAT 11/91 (See Note 1)
Contract with Vendor of Proven NSSS Model 11/91 NSSS Model Developed and Integrated 7/92 Complete GPUN FAT 9/92 Submit Simulator Certification 10/92 Pack t.nd Ship Simulator 10/92 Simulator Ready for Training 12/92 Simulator Ready for 0; arator Exam 6/93 The schedule in Table 3 would require an exemption from 10 CFR 55.45(b)(2)(iii) to allow until October,1992 for submittal of Form NRC-474, and an exemption from 10 CFR 55.45(b)(2)(iv) to allow use of the NMP-1 simulator for operator exams in 1992. Rather than using tb NMP-1 simulator in 1992, another option would be to request an 8 month ex.mption from 10 CFR 55.59(a)(2) to allow the 1992 operating exams to be conduct.d on the new simulator in June through August,1993.
111. Trlinina Imns icat iorts In our letter dated February 6,1991 (Ref. 3), we provided our analy:is of the relative benefits o various alternatives for meeting 10 CFR 55.59 operator requalification regt. rements in lieu of using a certified plant referenced simulator.
At that.ime, we concluded that the NMP-1 simulator was the best alternative available for conducting a meaningful operating test.
This analysis and conclusion remains valid.
The NMP-1 simulator, using Oyster Creek specific software, can accurately reproduce the general operating characteristics of Oyster Creek and is very effective in evaluating a crew's communiciticn skills and team-dependent behavior in a real time environment.
in our letter, we also committed to conduct 6dditional operator evaluations in 1991 using the non-certified plant referenced simulator during f actory acceptance testing.
These evaluations will take place near the end of our factory acceptance testing which will now occur in 1992 os discussed above. We believe this activity will be mutually beneficial te operator training and simulator development, in support of the projected schedules in Table 2 and Table 3, we have scheduled the use of the NMP-1 simulator for operator exams in 1992.
Additionally, in recognition of the fact that a plant referenced simulator is the best tool for conducting casualty training, we have added certain training modules to on-going operator training designed to emphasize the proper use of emergency operating procedures, abnormal operating procedures, and diagnostic procedures.
These modules will be inclu@d in the operator requfification program until the plant referenced simulator is ready for training.
Note 1: Factory Acceptence Testing will be done in parallel with continued model devel opment.
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