ML20086K214
| ML20086K214 | |
| Person / Time | |
|---|---|
| Site: | Oyster Creek |
| Issue date: | 12/06/1991 |
| From: | Fiedler F GENERAL PUBLIC UTILITIES CORP. |
| To: | NRC OFFICE OF INFORMATION RESOURCES MANAGEMENT (IRM) |
| References | |
| C321-91-2322, NUDOCS 9112120302 | |
| Download: ML20086K214 (9) | |
Text
-...
GPU Nuclear Corporation a
Ntsclear tr;'arsee Forked Rwer, New Jersey 08731-0388 009 971-4000 Wnters Direct D al Number.
December (;,1991 C321-91-2322 U.S. Nuclear Regulatory Commission Attn: Document Control Desk Washington, D.C.
20555 Gentlemen:
Subject:
Oyster Creek Nuclear Generating Station Docket No. 50-219 Request for Exemption From 10 CFR 55.45(b)(2)(iii) & (iv)
Ref:
(1)
NRC letter dated March 25, 1991 A.W. Dromerick to J.J.
Barton.
(2)
GPUN letter C321 91-2293, dated October 28, 1991, P.B.
Fiedler to NRC Document Control Desk.
GPUN hereby requests a schedular exemption from 10 CFR 55.45(b)(2)(iii) to allow us until December 31, 1992 to submit Form NRC-474, " Simulation facility Certification'.
In addition, we request an exemption from 10 CFR 55.45 (b)(2)(iv) to allow the continued administration of the simulation facility portion of operator examinations on the Nine Mile Point Unit 1 (NMP-1) simulator until our new simulator's certification is complete.
These exemptions are being requested in accordance with 10 CFR 50.12,
" Specific Exemptions", and the guidance in NRC Generic Letter 90-08,
" Simulation Facility Exemptions". The justification and '"'
" ting information for this request is attached.
Your letter dated March 25,1991 (Ref.1) granted us the above exemptions until December 31, 1991. We are now, in effect, requesting a 12 month extension of the same exemptions previously granted.
The status of our plant referenced simulator project was recently conveyed to you in our letter dated October 28, 1991 (Ref. 2).
In our letter we explained that we would not be able to complete all of the acceptance testing necessary to certify the simulator's performance by December 31, 1991, and this was primarily due to our vendor's lack of progress in resolving technical difficulties associated with modeling Oyster Creek's nuclear steam supply system (NSSS).
)'
914 212cyc 911204 3
FDR ADOCK 0500 l
1 Q{'Pg GPU Nuclear Corporation m a subsdary of General Pubhc Utitres Corporat'on i
l C321-91-2322 Page 2 We also identified a parallel effort that our vendor agreed to pursue, namely, to purchase and develop a proven NSSS model (a working model developed by an outside vendor) as a contingency in case the problems with their current model can never be resolved satisfactorily. At this time, our vendor has decided to focus their efforts on their current model, claiming they have recently isolated the source of their modeling difficulties.
We will be testing their NSSS model the week of December 9, 1991 to confirm this, if the model does not perform to our satisfaction, we will insist that the parallel effort be resumed immediately and without abandon until one of the models performs satisfactorily.
The exemption, if granted, would allow us to continue to administer our operator requalification program for another 12 months using the NMP-1 simulator as we have done for the past 7 years. We have an NRC approved and INPO accredited operator requalification program that is based on a systems approach to training. The effectiveness of our program was evaluated by the NRC in April-June, 1990 and again in April June, 1991.
Both evaluations concluded our program was satisfactory using the criteria in NUREG-1021.
" Operator Licensing Examiner Standards". We are confident that, during the exemption period requested, this program will continue to ensure that our operators possess the knowledge, skills and abilities needed to safely operate the plant.
To compensate for the lack of a plant-referenced simulator during the exemption period, we are proposing to conduct additional operator evaluations using the non-certified plant referenced simulator durinj factory acceptance testing.
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 cperator training designed to errphasize the proper use of emergency operating procedures, abnormal operating procedures, and diagnostic procedures.
These modules will be included in the operator requalification program until the plant referenced simulator is ready for training.
Our goal is to provide the most effective training for our operators both now and in the future. We believe that our actions to date, as detailed in the attachment, reflect our strong commitment to meet this goal. We will continue to assure we are receiving a quality product that meets our specifications and proves effective for operator training and evaluation, while we make every reasonable effort to expedite the completion of the plant referenced simulator.
C321 91-2322 Page 3 We look forward to meeting with you on December 17, 1991 to update you on our progress and to discuss this exemption request.
If there are any questions, please call Mr. Michael Heller, Licensing Engineer, at (609) 971-4680.
S i rc.erely,
Vice President and Director Nuclear Assurance Attachment cc:
NRC Region 1 Administrator NRC Senior Resident inspector A. Dromerick R. Gallo
_..___..m
l Att aehm.eitt SIMULATION FACILITY EXEMPTION RE_ quell Table of Contents Section EiL42 1.
Exemption Request..........................
I II.
Background.................................
I III. Current Status............................
2 IV.
Projected Schedule........................
3 V.
Training Implications.....................
3 VI.
Justification for Exemption...............
4 VII.
Conclusion................................
5 VIII.
Reference.................................
5 I
I
Attachment Page 1 of 5
- 1. Exemotion Reauest 10 CFR 55.45(b)(2)(iii) requires licensees, who intend to administer operating tests utilizing a plant referenced simulator, to submit to the NRC a certification for use of the simulator on Form NRC-474, " Simulation Facility Certification", no later than March 26, 1991.
Further, 10 CFR 55.45(b)(2)(iv) states that the " simulation facility portion of the operating test will not be administered on other thar, a certified or an spproved simulation facility after May 26, 1991." NRC letter dated March 25,1991 (Ref.1) granted GPUN exemptions from the above requirements allowing us until December 31, 1991 to submit Form NRC-474, and allowing us to administer operating tests using the Nine Mile Point Unit 1 (NMP-1) simulator until our new simulator is certified.
We are now requesting an exemption of these same requirements allowing us until December 31, 1992 to submit Form NRC-474 and allowing us to continue to use the NMP 1 simulator until our new simulator is certified.
II. Backaround in February, 1988, GPUN entered into contract with a vendor for construction of a state of the art plant referenced simulator to comply with the new simulation facility requirements of 10 CFR 55.45, " Operating Tests".
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 use of the simulator.
The original development schedule called for the simulator to be ready for training by October 17, 1990, and the contract included monetary )enalties to provide incentive for the vendor to maet the schedule.
This is tie vendor's first boiling water reactor simulator, and modeling the thermal-hydraulic characteristics of Oyster Creek's boiling water reactor became a significant challenge for the vendor.
in May, 1990, the vendor announced significant slippage in the development schedule due to technical difficulties encountered in modeling Oyster Creek's nuclear steam supply system (NSSS).
It became apparent that we would not be able to complete all of the acceptance testing necessary to certify the simulators' performance by the March 26, 1991 deadline. As discussed above, we were subsequently granted an exemption allowing us until December 31, 1991 to certify the simulator.
In September, 1991, as a response to a continued lack of progress in completing the NSSS model, 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 could never be resolved satisfactorily.
Our vendor agreed to this new approach, hired an outside consultant to evaluate their model, and began to evaluate proven NSSS models.
i Attachment Page 2 of 5 On October 28, 1991, we submitted a letter to the NRC (Ref. 2) providing the status of the simulator project, and announced that, despite our efforts, we were anticipating the need for an extension to our current exemptions.
III. Current Status The current simulator development schedule is provided in Table 1.
The target dates identified reflect a very aggressive schedule that allows for no further slippage, however we are working very closely with our vendor and making every reasonable effort to meet this schedule.
Table 1 Current Simulator Development Schedule Milestone Tarcet Date Start GPUN Factory Acceptance Testing (FAT) 11/4/91 (Actual)
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 Our factory acceptance testing of the simulator began on November 4,1991 and will proceed in parallel with continued NSSS model development. We are currently testing some of the large, main models such as the Condensate and Feedwater, Primary Containment, and Main Steam System models, and have been generally encouraged by the results. However, we have noted some significant stability problems in the Main Steam System model, and the Primary Containment model will also require some significant model changes to resolve noted discrepancies.
In addition, repeatability problems have been encountered when running certain transients..V; proximately 628 discrepancies have been documented, and the backlog continues to grow despite our concerted efforts.
The schedule in Table 1 reflects our intention to certify the simulator while at the vendor's facility in Monroeville, Pennsylvania.
This will of course result in certain physical fidelity discrepancies that will be listed as exceptions to certification on Form NRC-474.
Additional exceptions identified during factory acceptance testing may be listed in the interest of complying with 10 CFR 55.45(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 as this will maximize the quality and training value of the final product.
With regard to NSSS model development, our vendor informed us that they are very close to resolving their modeling difficulties and have therefore decided to focus their efforts on their current model. We have concurred in this action. Our vendor has not yet made a final vendor selection for an alternate l
Attachment Page 3 of 5 proven model to be developed and integrated into the simulator. We will be testing their NSSS model the week of December 9, 1991. If the model does not perform to our satisfaction, we will insist that the parallel effort to develop and integrate an alternate proven model be resumed inmediately and without abandon until one of the models performs satisfactorily.
1Y. Pro.iected Schedule Because of the uncertainties with the NSSS model and the new discrepancies being discovered through our factory acceptance testing, we are not highly confident that our vendor will be able to meet the schedule in Table 1.
Our exemption request is based on a projected schedule (Table 2) that includes a reasonable margin for further schedule slippage, and also assumes an alternate proven NSSS model will have to be useu.
Because of the uncertainties involved, we do not believe it is appropriate to base our exemption request on a schedule that is more aggressive than that provided in Table 2.
At this time, we are confident that this projected schedule can be achieved.
T abl e_2 Ergjected Slmulator Development Schedule Milestone QAls Start GPUN Factory Acceptance Testing (FAT) 11/91 (Actual)
Contract with Vendor of Proven Model 1/92 NSSS Model Developed and Integrated 9/92 Complete GPUN FAT 11/92 Pack and Ship Simulator 12/92 Submit Simulator Certification 12/92 Simulator Ready for Training 2/93 Simulator Ready for Operator Exam 8/93 V. Trainina [molicationi in our letter dated February 6,1991 (Ref. 3), we provided our analysis of the relative benefits of various alternatives for meeting 10 CFR 55.59 operator requalification requirements in licu of using a certified plant referenced simulator. We concluded that the NMP-1 simulator is 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 communication skills and team-dependent behavior in a real time environment.
Accordingly, we have scheduled the use of the NMP-1 simulator for operator exams in 1992.
r t
Attachment Page 4 of 5-To further compensate for the lack of a certified plant referenced simulator during the exemption period, we committed to conduct additional aperator evaluations using the non certified plant referenced simulator during factory acceptance testing. These evaluations will take place near the end of our factory acceptance testing which will now occur in 1992 as discussed above.
We believe this activity will be mutually beneficial to operator training and simulator development.
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 l
operating procedures, abnormal o)erating procedures, and diagnostic procedures.
These modules will se included in the operator requalification program until the plant referenced simulator is ready for training.
VI. Justification for Exemptics We believe that srecial circumstances are present as defined in 10 CFR 50.12 to justify the exemption requested. The exemption would provide only temporary relief from the regulation and we have continued to make good faitn efforts to comply.
Further, the Commission has_ recognized that unique circumstances may arise on a-plant specific basis that cause some deviation i
from the time requirements established in the rule according to the supplementary information published with the final rule (52 FR 9453).
Our good faith efforts to comply with 10 CFR 55.45, and to obtain 6 plant referenced simulator at the earliest possible date include the following:
(1)
In February, 1988,-we entered into contract with a vendor for construction of a state of the art plant referenced simulator.
(2)
The contract included monetary penalties to provide incentive for the vendor to meet the development schedulc.
(3)
In March, 1988, we organized a simulator management department in recoonition of the effort required to acquire, modify, operate, maintain and make the most effective use of the simulator.
(4)
When slippage in the development schedule occurred, additional efforts were made to expedite the schedule including the following:
(a)
We asked our vendor to hire an outside consultant to evaluate their NSSS model and make recommendations for correcting the problems.
(b)
We asked our vendor to pursue the purchase and development l
of a proven NSSS model as a contingency.
(
~ -
Attachment Page 5 of 5 (c)
We are conuucting factory acceptance testing of the simulator in parallel with continued NSSS model development.
(d)
Certification testing will be completed at the vendor's facility in Monroeville, Pennsylvania as part of our factory acceptance testing, rather than at Oyster Creek after delivery.
(e)
We have compressed the development schedule by modifying our factory acceptance testing program, including our undertaking a portion of the vendor's test program.
VII. Conclusion GPUN has put forth a good faith effort to meet the plant referenced simulator requirements in 10 CFR-55.45(b)(2)(iii) & (iv). We have continued to make good faith efforts to meet the December 31, 1991 certification deadline established by our exemption previously granted by NRC. Due to the circumstances discussed in this exemption request, it will not be possible to meet the above deadline. We are therefore requesting an exemption allowing us until December 31, 1992 to certify the simulator and allowing use of the NMP-1 simulator for operator exams in the interim.
We believe that special circumstances are present as defined in 10 CFR 50.12 to justify the exemption requested, namely, the exemption would provide only temporary relief from the applicable regulation and GPUN has made good faith efforts-to comply with the regulation. Ue are also confident that our INP0 accr3dited program, using the NMP-1 simulator, will continue through the exemption period to assure that our operators will maintain a high level of training and readiness.
VIII. Refereg g (1)
NRC letter dated March 25, 1991, A.W. Dromerick to J.J. Barton.
(2)
GPUN letter C321-91-2293, dated October 28, 1991, P.B. Fiedler to NRC Document Control Desk.
(3)
GPUN letter C321-91-2024, dated February 6, 1991, P.B. Fiedler to NRC Document Control Desk.
,