ML20244D337
| ML20244D337 | |
| Person / Time | |
|---|---|
| Site: | Big Rock Point File:Consumers Energy icon.png |
| Issue date: | 06/12/1989 |
| From: | Pulsifer R Office of Nuclear Reactor Regulation |
| To: | Office of Nuclear Reactor Regulation |
| References | |
| TAC-68307, NUDOCS 8906190003 | |
| Download: ML20244D337 (14) | |
Text
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^ UNITED STATES 8' j n
$ [3 NUCLEAR REGULATORY COMMISSION
\ vfj,E a WASHWGTON, D. C. 20555 -
- ..+ June 12, 1989 Docket No. 50-155 LICENSEE: Consumers Power Company FACILITY: Big Rock Point
SUBJECT:
SUMMARY
OF MEETING HELD ON MAY 9, 1989 WITH CONSUMERS POWER COMPANY REPRESENTATIVES TO DISCUSS SIMULATOR FACILITY PLANS FOR BIG ROCK POINT On May 9,1989, members of the NRC met with representatives of Consumers Power Company (CPCo), to discuss Simulator Facility Plans for Big Rock Point. The meeting participants are listed in Enclosure 1.
The CPCo representatives presented an agenda for the discussion about their intentions regarding Simulation Facility Plans,10 CFR 55.45(b). (Enclosure 2)
CPCo stated that the NRC comments on the Utility Simulator Facility Group (USFG) submittal and their submittal dated May 26, 1988 lead them to a conclusion that they need to apply for an exemption per 10 CFR Part 50, Section 12(a)(2)(ii).
The prime concern is the resources contemplated in manpower and dollars needed to design, build and maintain a simulator.
CPCo provided a presentation on their confidence in Big Rock Point operators and on the existing license training and reeualification program.
Big Rock Point feels they can meet the rule's purpose under the existing program because 1) Big Rock Point is a small, older, less complex unit, it .has fewer multi-train systems with system interactions making off normal events less likely; 2) High level of experience among licensed operators, low turnover; 3)
Good initial and requalification training program, since 1982 33 of 36 license candidates were successful and the success rate since 1982 has increased; 4)
Perfonnance in the Operations Department has excelled, high SALP ratings.
CPCo estimates that the cost to develop, qualify and maintain a simulator would be 12 to 18 million dollars with about 90 man years of effort. A part task simulator would be 2 to 5 million dollars at about 10 man years of effort. Big Rock Point has only 11 years remaining on their license to recover these costs assuming no request for extension.
The NRC emphasized that the application for exemption must be accompanied with sufficient analysis and details to demonstrate the hardship in meeting this rule l with appropriate investigation of the alternatives. It was important that alternatives be reviewed with the evidence provided before an exemption would be entertained. It was also emphasized that if a plant specific simulator would not be available CPCo was to provide a progran with the submittal on how the NRC would evaluate the license students.
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I The rule specifies November 26, 1990, as the date for submitting an application for use of a simulation facility. As such CPCo was urged to formally submit their program as soon as possible. It was' stressed that the best approach was 1 to provide a program with a comprehensive report explaining how CPCo would meet the intent of this rule. CPCo indicated that a response could be submitted as early as June 30, 1989. ,
Enclosure 3 is a handout provided by CPCo during this meeting.
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+
ulsi r, Project Manager Project Directorate III-1 Division of Reactor Projects - III, IV, V
& Special Projects
Enclosure:
As stated l
1 I
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. Mr. Kenneth W. Berry Big Rock Point Plant and Consumers Power Company Palisades Plant cc Mr. Thomas A. McNish, Secretary Jerry Sarno Consumers Power Company Township Supervisor 212 West Michigan Avenue Covert Township Jackson, Michigan 49201 36197 M-140 Highway Covert, Michigan 49043 Judd L. Bacon, Esquire Consumers Power Company Mr. David P. Hoffman 212 West Michigan Avenue Plant General Manager Jackson', Michigan 49201 Palisades Plant 27780 Blue Star Memorial Hwy.
M. I. Miller, Esquire Covert, Michigan 49043 Sidley & Austin 54th Floor Resident Inspector One First National Plaza c/o USNRC Chicago, Illinois 60603 Palisades Plant 27782 Blue Star Memorial Hwy.
Covert, Michigan 49043 Mr. Thomas W. E1 ward Plant Manager Big Rock Point Plant 10269 U.S. 31 North Charlevoix, Michigan 49720 Mr. Bud Heeres County Commissioner 303 Sheridan -
Charlevoix, Michigan 49720 Office of the Governor Room 1 - Capitol Building Lansing, Michigan 48913
, U.S. Nuclear Regulatory Commission Resident Inspector Office Big Rock Point Plant 10253 U.S. 31 North Charlevoix, Michigan 49720 Regional Administrator, Region III i
U.S. Nuclear Regulatory Commission 799 Roosevelt Road Glen Ellyn, Illinois 60137 Nuclear Facilities and Environmental Monitoring Section Office Division of Radiological Health P. O. Box 30035 Lansing, Michigan 48909
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c 2 .1 l< . AGENDA FOR MAY 9 MSETING ON BRP SIMULATION FACILITY 1
OVERVIEW OF BRP SITUATION DPH CONFIDENCE IN OUR OPERATORS C'RA EXISTING LICENSE TRAINING AND .DGL REQUAL PROGRAM
.n PROPOSED EXEMPTION AND BASIS RJA/KEM SLMfARY DPH or CFJL KRC. STAFF COMMENTS 3
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10 CFR 55.11 Subpart B -
Exemptions The . Commission may, upon application by an interested person, or upon its own initiative, grant such exemptions from the requirements of the regulations of this part as it determines are authorized by law and will not endanger life' or property and are otherwise in the public interest.
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l 10 CFR 50.12 Specific Exemptions (a) The Commission may, upon application by any interested person or upon its own initiative, grant exemptions from the requirements of the regulations of this part, which are .
(1) authorized by law, will not present an undue risk to public health and safety, and are consistent with the common defense and security.
(2) The Commission'will not consider granting an exemption unless special circumstances are present. Special circumstances are present whenever -
9 10 CFR 50.12 Specific Exemptions (cont'd)
(ii) Application of the regulation in the
. particular circumstances would not serve the underlying purpose of the rule or is not necessary to achieve
.the underlying purpose of the rule; or (iii) Compliance would result in undue hard-ship or other costs that a significantly in excess of those contemplated when the regulation was adopted, or that are significantly in _ excess of those incurred by others similarly situated; or
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.. l 10 CFR 55 Exemptions Needed for Big Rock Point
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. 10CFR55.45(b) Implementation-(1) Administration The operating test will .be administered in a
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plant walkthrough and in either -
(i) a simulator facility which the Commission has approved for use after application has been made by the facility licensee, or (ii) a simulation facility consisting solely of a plant-referenced simulator which has been certified to the Commission by the facility licensee.
10CFR55.59(c)(3)(v) g 55.59(c)(4)(iv)
If the simulator or simulation device is used to administer operating tests for -a facility as provided in 10CFR55.45(b)(1) the device approved to meet the requirements of 55.45(b)(1) must be used for credit to be given for meeting the requirements of paragraphs (c)(3)(i) (G through AA) of this section.
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Bases for Exemption L
Application of the regulation in the particular circumstances ... is not necessary _ to achieve the underlying purpose of the rule Purpose Improve the safety of nuclear power plant ;
operation by- improving the operator licensing process, examination content, and
'the basis for administering exams and operating tests to ensure qualified individuals operate or direct the operation of the facilities
L i Exemption Bases (continued)
The. rule's purpose can be achieved under the existing BRP program, with envisioned improvements, because:
- 1. Big Rock Point is a small, older, less complex unit
. non-complex design with fewer (modern) multi-train systems simple control room (~225 alarms total)
. upsets from systeln interaction during off-normal events less likely
. minimal operational shift required
- 2. High level of experience among licensed operators
. Iow turnover since 1960
- 21 shift supervisors (SRO)
- 52 control room operators (RO) (14 were eventual shift supervisors
- 9 R0s left for Palisades staffing
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Exemption 3ases (continued)
- 3. Good initial and requalification training program since 1982,. 33 of 36 license candidates were successful
. reggal program success increase:
198f = 89% 1988 = 100Fs
- 4. -Performance in. the Operations Department has excelled '
. initial SALP rating was above average since the initial rating there have been 1 level "2" and. 6 les'd 7" raungs 1
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c Exemption Bases (continued) 10CFR50.12 (a)(2)(iii)
. Compliance would result in undue hardship or other costs that are significantly in excess of those contemplated when the regulation was adopted, or that are significantly in excess -
of those incurred by others similarly situated
. For Big Rock Point, costs in both manpower and
. monetary resources to develop, qualify and maintain a simulator exceed resources available:
~ 12 to 18 million dollars ~ 90 manyears and for a part-task simulator:
~ 2 to 5 million dollars ~ 10 manyears
. BRP license has only 11 years remaining during which costs could be recovered (if at all)
BRP operating costs per KWh are already among highest in the country
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l The rule specifies November 26, 1990, as the date for submitting an application for use of a simulation facility. As such CPCo was urged to formally submit their program as soon as possible. It was stressed that the best approach was to provide a program with a comprehensive report explaining how CPCo would meet the intent of this rule. CPCo indicated that a response could be submitted as early as June 30, 1989.
Enclosure 3 is a handout provided by CPCo during this meeting.
/3/
Robert M. Pulsifer, Project Manager Project Directorate III-1 Division of Reactor Projects - III, IV, V
& Special Projects
Enclosure:
As stated l
DISTRIBUTION
- DOCKEToFILE NRC & LOCAL PDRs JSNIEZEK PD31 GRAY FILE LYANDELI RPULSIFER OGC EJORDAN BGRIMES i NRC PARTICIPANTS I
ACRS(10)
JCLIFFORD
- SEE PR I CONCURRENCE
- LOLB PM/PD31(DR P NHUNEMULLER RPULSIFER 6/9/89 6//2/89
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