ML20210E210
| ML20210E210 | |
| Person / Time | |
|---|---|
| Site: | San Onofre  |
| Issue date: | 06/16/1992 |
| From: | Rosenthal R SOUTHERN CALIFORNIA EDISON CO. |
| To: | NRC OFFICE OF INFORMATION RESOURCES MANAGEMENT (IRM) |
| References | |
| NUDOCS 9206180410 | |
| Download: ML20210E210 (7) | |
Text
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Southem Califomia Ecfinon Company 23 8' AfW F H ST RE E T June 16, 1992
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r U. S. Nuclear Regulatory Commission Attention:
Document Control Desk Washington. 0.C.
20555 Gentlemen:
Subject:
Docket No. 50-206 Withdrawal of Request for Exemption from Requalification I
Simulator Requirements San Onofre Nuclear Generating Station, Unit 1 (SONGS 1)
References:
1)
Letter from R. Ornelas, SCE, to USNRC, dated March 27, 1992.
2)
Letter from H. B. Ray, SCE to T. E. Hurley, dated January 15, 1992.
This letter withdraws our previous request for an exemption from recuirements to use a simulator in licensed operator requalification training anc testing.
This letter also presents our overall plan for operator qualification during the transition to a defueled status, describes our 1992 requalification mc training and testing program, describes our plans for operator staffing, and explains why NRC administered requalification examinations will no longer be necessary.
The plans described in this letter are based on the anticipated pennanent shutdown and defueling of SONGS 1 at the end of the current fuel cycle (Fuel Cycle 11).
If plant operation is extended beyond Fuel Cycle 11, we will notify the NRC and describe the associated changes in our plans and programs.
-a BACKGROUND i
We previously requested, in Reference 1, an exemption from 10CFR55 rcuirements to use a simulator for licensed operator requalification training anc testing. Our request was based on the ability of the augmented non-simulator portions of our requalification program to maintain the necessary level of operator expertise for the relatively_ short period of operations remaining until the plant is permanently shutdown and defueled.
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Document Control Desk,
We have since decided to provide a modified requalification simulator training and testing program lastir.g one week for each crew.
In a meeting with the NRC on May 13, 1992, we presented a description of our planned requalification program and related topics.
The issues presented at that meeting are discussed below.
OVERALL PLAN Our overall plan for operator qualification during the transition to a permanently defueled status provides assurance of adequate operator expertise during the remaining limited period of plant operation. Our plan also minimizes the performance of unnecessary training, meets the requirements of 10CFR55, and provides for implementation of appropriate operator cualification requirements following defueling. Our overall plan is illustratec by the time line contained in the enclosure to this letter.
The milestones on the enclosure represent our current projections and may undergo minor changes due to unexpected plant outages or other unforeseen events.
We previously informed the NRC (reference 2) of our agreement with the staf f of the California Public Utilities Commission to discontinue operation of SONGS 1.
We plan to permanently shut down the plant at the end of Fuel Cycle 11, which is expected in November 1992, and complete defueling in January 1993.
We plan to replace our 10CFR55 licensed operator program with an NRC approved fuel Handler Certification (FHC) program which will be more appropriate to the plant's defueled condition.
We intend to commence our normal 1993 requalification classrcom training program in January 1993 to satisfy the 10CFR55 requirement for a continuous requalification program.
To minimize unnecessary training, the 1993 program should be replaced with the FHC program no later than March 1993.
Our plans are to refer to the FHC program in our Permanently Defueled Technical Specifications (PDTS) operator qualification requirements. We believe it will take approximately six months to obtain NRC approval of the FHC program and PDTS. Therefore, we intend to submit our proposed FHC program and PDTS no later than September 1992 so that we may anticipate NRC approval by March, 1993.
In the interim, we intend to complete our 1992 10CFR55 requalification program as described below.
1992 REQUALIFICATION PROGRAM Our planned 1992 requalification program will satisfy the requirements of 10CFR55. We intend to conduct our normal training and evaluation programs except for the modifications described in the following discussions.
The modified elements of the program will be developed using a Systems Approach to Training as was done in our normal program.
A Document Control Desk.
Operator Trainina The 1992 requalification training program will last <64 hours, which exceeds the minimum of 240 hours0.00278 days <br />0.0667 hours <br />3.968254e-4 weeks <br />9.132e-5 months <br /> recommended by Institute of Nuclear Power Operations (INP0) National Academy of Nuclear Training.
The program includes both classroom and simulator training as required by 10CFR55. Our classroom training program, which has been in progress since January 1992, will last 176 hours0.00204 days <br />0.0489 hours <br />2.910053e-4 weeks <br />6.6968e-5 months <br /> and remains unchanged from prior programs except for the additional 40 hours4.62963e-4 days <br />0.0111 hours <br />6.613757e-5 weeks <br />1.522e-5 months <br /> described below.
Our simulator training program, which commenced on May 24 and is planned to continue until July 4, 1992, will provide one week (48 hours5.555556e-4 days <br />0.0133 hours <br />7.936508e-5 weeks <br />1.8264e-5 months <br />) of simulator training for each operating crew.
The 48 hours5.555556e-4 days <br />0.0133 hours <br />7.936508e-5 weeks <br />1.8264e-5 months <br /> will be comprised of 36 hours4.166667e-4 days <br />0.01 hours <br />5.952381e-5 weeks <br />1.3698e-5 months <br /> on the simulator panel, and 12 hours1.388889e-4 days <br />0.00333 hours <br />1.984127e-5 weeks <br />4.566e-6 months <br /> of supporting lectures and discussions related to the evolutions performed on the panels. Although the 36 hours4.166667e-4 days <br />0.01 hours <br />5.952381e-5 weeks <br />1.3698e-5 months <br /> of simulator training is less than the 60 hours6.944444e-4 days <br />0.0167 hours <br />9.920635e-5 weeks <br />2.283e-5 months <br /> normally recommended by the INPO National Academy of Nuclear Training, we believe our program will assure adequate operator expertise for the following reasons:
The one week simulator program will concentrate on Emergency Operating Instructions (E01s) and associated plant restoration measures, since the E01s require the most expedient actions and the most precise coordination of operations.
A significant number of operators have already had experience on the plant referenced simulator.
A total of 87% of the licensed operators currently assigned to control room duty (100'4 of the SR0s and 73'4 of the R0s) have spent one to two weeks on the simulator as part of the testing process for that facility. During this testing, operators manipulated controls and observed indications during simulated normal operations, transients, and plant malfunctions. Although the testing was conducted primarily to validate simulator behavior, the process familiarized the operators with the new facility, provided additional experience in applying procedural controls during startups, shutdowns, and power changes, and provided an opportunity for the operators to observe the plant response during various transients and malfunctions.
Additional simulator time will be allocated to operators or crews exhibiting the need for remediation.
Individual and crew performance will be monitored during the training sessions and evaluated at the end of the training period. Additional simulator training and evaluation will be conducted if considered necessary by our Nuclear Training and Operations Departments.
The classroom portion of our program will contain 40 hours4.62963e-4 days <br />0.0111 hours <br />6.613757e-5 weeks <br />1.522e-5 months <br /> of training beyond that normally included in our requalification program.
The additional training will cover topics that were originally scheduled for the 1993 requalification program.
These topics include several Abnormal Operation Instructions and General Operating Instructions, and crew team building.
1
4 Document Control Desk There is only a short period of power operations remaining until the plant is permanently shut down in November 1992.
Following completion of the simulator )rogram, there will be less than five months of operation until tie planned shut down in November, 1992.
These factors, combined with our normal classroom training and the below described operator evaluations, will assure adequate o>erator expertise without the additional 24 hours2.777778e-4 days <br />0.00667 hours <br />3.968254e-5 weeks <br />9.132e-6 months <br /> of simulator time whic1 would be needed to satisfy the INPO National Academy of Nuclear Training recommendation.
Operator Evaluation As required by 10CFR55.59(c)(4), our requalification program will include comprehensive written examinations and annual operating tests. These will be the same type of examinations and tests administered in our normal program, except where noted otherwise below.
Examinations using the simulator began May 30 and are planned to continue through July 3, 1992. All other examinations are planned for October 19 to November 20, 1992.
As in our normal requalification program, a dynamic examination on the simulator will be conducted at the end of the simulator training period.
This examination will satisfy requirements for the simulator portion of the annual operating test.
The plant walk-through portion of the annual operating test will be conducted using Job Performance Measures (JPMs) as in our normal program. However, the operators will walk through all JPMs in the plant rather than on the simulator.
This is the same method used when the NRC examined licensed operators in October, 1990.
As in our normal program, the written examination will include a section on plant and control systems, and a section on administrative controls and procedural limits.
The section on plant and control systems will be covered in a classroom environment and through JPM oral questioning rather than on a static or frozen simulator as is normally done.
STAFFING REQUIREMENTS AND AVAILABILITY The NRC has indicated an interest in our plans to assure an adequate number of qualified operations personnel remain available.
We have compared operator staffing requirements with the anticipated availability of licensed personnel, and determined that sufficient personnel will be available to support our plans for the transition to a permanently defueled status. The following table shows the anticipated staffing needs and personnel availability for Senior Reactor Operator (SRO), Reactor Operator (RO), Plant Equipment Operator (PEO), Certified Fuel Handler (CFH), and Control Room Operator (CRO) positions iuring the three phases of our overall operator transition plan.
The expected decreases in the number of available
Document Control Desk personnel result from reassignments within the site organization and anticipated departure of individuals to other employment.
l from Complet' on of.
From Present Until Defuelina Unt< 1 PDTS After PDTS and Defuelina Complete and FHC Program Approved FHC Approve;l Needed Needed Needed 12 SR0s 8 SR0s 8 CFHs 12 R0s 8 R0s 8 CR0s 24 PEOs 8 PE0s 4 PE0s Available Available Available 16 SR0s 14 SR0s 10 CFHs 25 R0s 16 R0s 8 CR0s 24 PEOs 14 PEOs 4 PE0s To assure these personnel availability projections remain valid, we have taken measures to retain the SONGS 1 operators by assuring them of continued employment following plant shutdown, with no decrease in compensation.
The initial operator response to these measures has been positive. We believe these measures will allow us to retain the recuired pool of operators and utilize them as needed to support the expectec shift mcnning requirements.
NRC ADMINISTERED EXAMINATIONS NRL administered examinations are not necessary since none of our operator's licenses will expire until after the 10CFR55 program has been replaced by an l
FHC program.
1 The license renewal conditions of 10CFR55 require each operator to pass an NRC i
administered written examination and operating test at least once during the six year term of the operator's license. As required by the regulation, our requalification program includes SCE administered written examinations and annual operating tests.
The regulation also states that the NRC may administer these examinations and tests, or may accept certification that the operator has passed the SCE administered examinations and tests.
No SONGS 1 operator license will reach the end of the six-year term until August 1993. As previously stated, we plan to replace our 10CFR55 operator qualification program with an NRC approved FHC program, and request termination of the operator's 10CFR55 licenses in March, 1993. Since no operator licenses will be renewed, NRC administration of written examinations and operating tests will not be necessary.
Document Control Desk 4 WITHDRAWAL OF EXEMPTION REQUEST Since we will be conducting requalification programs which comply with the requirements of 10CFR55 until the FHC program is implemented in 1993, our previous exemption request, submitted in the referenced letter, is hereby I
withdrawn.
If you have any questions or coments, please do not hesitate to contact me.
Very truly yours, f LH fW&
v Enclosure cc:
J. B. Martin, Regional Administrator, NRC Region V George Kalman, NRC Senior Project Manager, San Onofre Unit 1 J. O. Bradfute, NRC Project Manager, San Onofre Unit 1 C. W. Caldwell, NRC Senior Resident Inspector, San Onofre Units 1, 2&3 l
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