ML20141M091
| ML20141M091 | |
| Person / Time | |
|---|---|
| Site: | San Onofre  |
| Issue date: | 03/27/1992 |
| From: | Ornelas R SOUTHERN CALIFORNIA EDISON CO. |
| To: | NRC OFFICE OF INFORMATION RESOURCES MANAGEMENT (IRM) |
| References | |
| NUDOCS 9204010015 | |
| Download: ML20141M091 (5) | |
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Southem Califomia Edison Company 23 P Ank E H STRE F.T IRVINE, C ALIFORNIA 92718 U$E w-.O Z.,,m, March 27, 1992 V. S. Nuclear Regulatory Commission Attention: Document Control Desk Washington, D. C. 20555 Gentlemen:
Subject:
Docket No. 50-206 Request for Exemption from Operator Requalification Simulator Requirements San Onofre Nuclear Generating Station, Unit 1, (SONGS 1)
References:
1)
Letter from H. B. Ray, SCE, to T. E. Murley, NRC, dated January 15, 1992.
2)
Letter from J. E. Dyer, NRC, to H. B. Ray, SCE, dated March 22, 1991.
3)
Letter from P. F. Collins, NRC, to J. B. Moore, SCE, dated June 6, 1974.
4)
Letter from M. O. Medford, SCE, to D. G. Eisenhut, NRC, dated January 22, 1985.
5)
Letter from K. E. Perkins, NRC, to H, E. Morgan, SCE, dated November 21, 1990.
This letter requests an exemption from 10CFR55 requirements to utilize a simulator in licensed operator requalification training and in licensed operator requalification testing.
The exemption request is based on our current plans to shut down and permanently defuel SONGS 1 at the end of the l
present fuel cycle (Cycle 11), scheduled for the end of 1992.
If plant operation is extended by means of a fuel shuffle (Cycle llB) this request will be revised.
We consider the other portions of our requalification program adequate to l
maintain the necessary operator expertise during the period of operation
~
remaining until the planned defueling.
Following defueling, the operational l
events modeled by the simulator are no longer credible, and the operator expertise maintained through requalification simulator training and requalification simulator testing is not necessary.
l BACKGROUND We previously informed the NRC (Reference 1) of our tentative agreement with the California Public Utilities Commission to discontinue operation of SONGS 1.
We plan to permanently shut down and defuel the reactor at the end of fuel Cycle 11.
Fuel Cycle 11 full power operations are expected to end in I
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November 1992.
Based on current plant performance, the possibility of a coast down period, existing surveillance recuirements, and the projected time for fuel movement, we expect to complete cefueling during the period from December,1992 through January,1993.
Licensed operators are required by 10CFR55(a)(1) to complete a requalification program.
This requalification program is required by 10CFR55.59(c) to be approved by the NRC and to include training on a simulator.
The SONGS 1 requalification program was initially approved by the NRC in Reference 3, and was more recently described in Reference 4 and evaluat?d as satisfactory in Reference 5.
Licensed operators are required-by 10CFR55.59(a)(2) to' pass an annual operating test.
This operating test -is required by 10CFR55.45(b)(1) to include evaluation =on a simulator.
The next SONGS l'requalification operating test is required by Reference 2 to be completed by the end of October 1992.
To meet this requirement we had planned to conduct requalification training and testing on the SONGS 1 simulator from May through October, 1 #2.
The NRC is allowed by 10CFR55.11 to grant exemptions to Part 55 if the NRC determines the exemptions are authorized by law, will not endanger life or property, and are otherwise in the public interest.
REQUEST FOR EXEMPTION We request, pursuant to 10CFR55.11, exemption from the 10CFR55.59(c) requirement to include simulator training in our SONGS 1 requalification program, and exemption from the 100FR55.45(b)(1) requirement to include j
evaluation on a simulator in the SONGS 1 requalification operating test.
This request is based on the planned pemanent shutdown and defueling of the reactor following Fuel Cycle 11.
Therefore, if requalification simulator training and requalification simulator testing is eliminated pursuant: to this exemption, plant operation following Fuel _ Cycle 11 will be prohibited without NRC approval of the operators' qualification status, in support of this exemption request, the following assessment is provided of the need for requalification simulator training and requalification simulator testing during the anticipated remaining period of fueled plant conditions, and during the period following defueling.
Remaining Period of Fueled Plant Conditions The purpose of the requalification program is to provide ongoing training such-that operators will maintain the level of expertise required to conduct the' normal, abnomal, and emergency operations associated with a fueled reactor for the duration of their licenses.
e Document Control Desk The assessment provided in this section examines the ability of the non-simulator portions of our requalification program to maintain this level of expertise for the anticipated remaining period of fueled plant conditions, without reliance on simulator training and simulator testing.
Non-simulator Trainina Conducted Per 10CRF55 The classroom portion of our requalification program includes instruction on the same topics as our simulator training curriculum.
These topics include selected theories of operation, operator weaknesses identified in previous requalification cycles, industry and site operating experiences, important, difficult, or infrequently performed tasks, selected items from the NRC Knowledge and Abilities catalog, Operations Departmene feedback, changes to plant ecuipment and procedures, NRC Bulletins, Information Notices, an; Generic Letters, and Normal, Abnormal, and Emergency Operating Instructions. Written and oral examinations are administered on these topics.
The classroom portion of our requalification program is conducted using a Systems Approach to Training, as defined in 10CFR55.4.
This is a task oriented approach, with the tasks defined as the normal, abnormal, and emergency manipulations necessary for the safe operation the plant.
Thus the requalification program provides task oriented training, in a classroom setting, on the same topics covered on the simulator.
The on-shift training portion of our requalification program requires operators to read and acknowledge information pertinent to plant safety and operation.
This program provides, through the following types of documents, significant and pertinent material for review by operators that directly impacts their duties and responsibilities: system operating bulletins, design modifications, emergency plan implementing procedures, Normal, Abnormal, and Emergency Operating Instructions, administrative procedures, Ucensee Event Reports, Station Incident Reports, Significant Operating Experience Reports, o)erations procedure change summary reports, facility license changes.
T1ese documents inform the operators of changes in hardware and requirements which may affect Control Room actions, and advise the operators of lessons learned through actual operating events.
Auanentation of 10CFR55 Reauired Trainina Although not required by 10CFR55, our requalification program includes Professional Operator Development Program seminars which provide training on the command, control, communication, and team work skills which are also obtained through simulator training.
Deletion of simula+.or training will not eliminate training on these skills.
Additionally, our requalification program is augmented by the use of Job Performance Measures to evaluate operator proficiency at performing operating tasks, Control Room evaluations of operator performance during plant evolutions, and emergency plan mini-drills utilizing computer
Do'cument Control Desk assisted dynamic events in a static Control Room mock-up.
These mechanisms for evaluating Control Room performance )rovide an observation and feedback process similar to that ac11eved on the simulator.
In addition to the training provided by the non-simulator portions of the requalification program, credit can be taken for operator retention of skills which were acquired through previous simulator training, and on-the-job experience. Also, almost 80% of our licensed operators have or will spend at least one week performing plant evolutions on our new plant-referenced simulator as part of the testing process for that facility.
Therefore, we consider that operator participation in the non-simulator portions of our requalification program, as currently augmented, provides adequate assurance of safe operation during the anticipated remaining period of fueled plant conditions.
Period following Defueling The requirements of 10CFR55 were formulated on the assumption that the operators would be controlling an operating facility subject to the transients and malfunctions which can occur during start up, power operation, and shut down. With the reactor defueled, these events are no longer credible and operators need not maintain expertise in the normal, abnormal, and emergency Control Room operations associated with fueled reactors. Since maintenance of this type of expertise is the primary function of requalification simulator training and requalification simulator testing, the need for such training and testing is eliminated when the plant is permanently shut down and defueled.
With the plant in a defueled condition, the required operator expertise is limited to that needed for monitoring the storage facility, and res)onding to the accidents which are credible in a defueled condition suc1 as loss of spent fuel pool cooling, loss of spent fuel pool water inventory, and fuel handling accidents. Monitoring the storage facility and responding to the credible accidents requires far fewer manipulations in the Control Room than are necessary for an operational nuclear power plant. As a result requalification simulator training and simulator testing is largely irrelevant when the plant is shut down and permanently defueled.
The above assessments indicate that the non-simulator portions of our requalification program, as 'arrently augmented, are adequate to ensure safe operation during the anticipcited remaining period of fueled plant conditions, and that requalification simulator training and requalification simulator testing is not necessary with the reactor defueled.
These results support our requested exemption from the requalification simulator training and requalification simulator testing requirements contained in 10CRF55.
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b Do'cument Control Desk.
CURRENT AND FUTURE LICEllSED OPERATOR PROGRAMS Upon approval of this exemption, our current requalification program will be modified accordingly.
We anticipate submitting a future request for additional exemptions to 10CFR55 which together with this request, will form the basis for comprehensive operator licensing and requalification programs specifically tailored to the defueled condition of the plant.
The initial qualification testing which is currently scheduled for April 1992 is thus the last anticipated need for the SONGS 1 plant-referenced simulator.
We request NRC approval of the exemption stated in this letter as soon as possible. Since preparations for requalification simulator training are scheduled to begin May 5, 1992, NRC approval prior to that date would provide us with the most benefit.
If you have any questions or comments, please do not hesitate to contact me.
Very truly yours, cc:
J. B. Martin, Regional Administrator, NRC Region V George Kalman, NRC Senior Project Manager, San Onofre Units 1, 2&3 J. O. Bradfute, NRC Project Manager, San Onofre Unit 1 C. W. Caldwell, NRC Senior Resident Inspector, San Onofre Units 1, 2&3 l