NRC-91-0015, Requests Exemption from Simulator Certification Requirements of 10CFR55.45 to Delay Submittal of Certification Until 910930.Existing Simulation Facility Will Be Used for Operator Requalification Until Upgraded Simulator Available

Requests Exemption from Simulator Certification Requirements of 10CFR55.45 to Delay Submittal of Certification Until 910930.Existing Simulation Facility Will Be Used for Operator Requalification Until Upgraded Simulator Available

ML20067B409
Person / Time
Site:	Fermi
Issue date:	01/31/1991
From:	Orser W DETROIT EDISON CO.
To:	NRC OFFICE OF INFORMATION RESOURCES MANAGEMENT (IRM)
References
CON-NRC-91-0015, CON-NRC-91-15 NUDOCS 9102080242
Download: ML20067B409 (5)

Text

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q Detroit Edison !EsDEA wn l

i January 3161991 NRC-91-0013.

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U. S. Nuclear Regulatory Commission

. Attn: Document Control Desk

,j Washington. D.

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References:

1) Fermi 2 NRC Docket No. 50-341 NRC License No. NPF 2) Detroit. Edison letter to NRC.. " Response to z

Diagnostic Evaluation Team Report,";NRC-89-0004 -

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dated January 17, 1989 i

3) Detroit Edison -letter to' NRC, f " Revision Jof Milestone.

- Date for Improvementf of, Simulator Fidelity,"

NRC-89-0079, dated March 23,11989<

.4)- Detroit Edison lett'er to NRC, '? Update of Simulator Upgrade Project Schedule,". NRC-90-0186, ! dated

-December 28, 1990

Subject:

Exemption Request Regarding' Simulator Certification-Schedule Requirements of 10'CFR 55.45 1

- The purpose of this letter is to request an exemption /from.the 2

. requirements-of 10 CFR 55.45, paragraphs (b) (2) (iii);and (b) (2) (iv).

These-paragraphs provide a-schedule for facility licensees to-

. implement the requirements for a plant referenced simulation facility. These requirements were promulgated'in the Code of Federal 3

Regulations in a revision to 10 CFR 55, " Operator' Licenses," which became effective May 26, 1987.

l Paragraph (b)~(2)(iii) requires licensees to submit not. later than 46 3

months after'the offective date_of the rule (March 26, 1991)'e certification for use' of the simulation facility -to the NRC on Form NRC-474, " Simulation Facility-Certification." Detroit Edison'is requesting a one time _ exemption f rom the requirement of. this; regulation.to allow us to submit the. simulation certification to the -

NRC by September 30, 1991.

The one time exception would provide an additional 6 months to complete the simulator upgrade project Detroit Edison undertook to comply with the provisions of the revised 10 CFR 55 rule.

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.e USNRC January _31, 1991 NRC-91-0015 Page 2 i

Paragraph (b)(2)(iv) requires licensees to administer the facility portion of an operating test on a certified simulation facility after -

l May 26._1991.

Currently, the NRC is scheduled.to administer operator a

license examinations: at Fermi in August and December 1991. Because the. simulator will not-be certified.until September-30 =1991 Detroit Edison.cannot comply with:this' provision of the. rule._for the August 1991 operator examination and requests. a _one time exemption from the =

regulation. We intend instead ~to have the August 1991 examination administered on the. existing simulation f acility. - The December 1991 examination would be able to use the certified simulation ' facility ;

4 howeve r.

It should be noted that _ although it will not be certified =

y the existing simulator is. essentially a plant < referenced simulator.

l which has been used for operator training since 1984.

Generic Letter 90-08 " Simulation Facility Exemptions" was reviewed for guidance and to determine specific requirements in preparing this t

exemption request. As noted in the Generic Letter, the provisions the NRC specifies for granting an exemption' are addressed in 10 CFR 50.12

" Specific Exemptions." Paragraph (a)(2)(v) of this tule allows the' NRC to grant an exemption if the exemption would provide only-

.t temporary relief from.the regulation and the_. licensee has made good f aith ef forts to comply with the regulation.. The _first part of this:

provision is met on the basis that the exemptionirequest is:onlyca; temporary relief from the regulation since Detroit Edison intends, to submit the certification Form NRC-474 by September _30,1991.

Additionally, once the certification has been submitted, operator tests would be performed on only the certified simulation facility.

In regard to the second part of this ' provision. Detroit Edison.

believes that it has made - good faith ef forts to comply _ with :the regulation. As noted 'above. Detroit _ Edison undertook a1 major project to upgrade the existing Fermi 2 simulator to meet the -new requirements

'of 10 CFR 55.

The simulator upgrade project consists aof using the existing simulator.

- concrol room panels and adding new computer hardware and sof tware to drive the simulation, and a new instructor's station.- A11"new control / logic models and dynamic process models~for,the-plant systems that are simulated had to be developed as part of the upgrade proj ect. Combustion Engineering (later -purchased by ABB) was awarded the _ contract to provide the computer hardware and sof tware, the -

-i instructor's station, and the dynamic' process models. -The.

l control / logic models were developed-by Detroit Edison..ABB-is also responsible for integrating the dynamic process and control / logic l

models on the simulator computer.

In its January 1989 response.to an NRC Diagnostic Evaluation Team report (Reference 2). Detroit Edison 'took the opportunity to discuss some of the more important elements of the sirulatorxupgrade project and to provide a schedule of the major milestones associated wits the-project.

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i USNRC January 31. 19911 NRC-91-0015 Page 3 q

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The first milestone was to issue the procurement specification for the-U upgrade project. A procurement specification was' written and sent to 1

I perspective bidders in December 1988, and contract award was scheduled-to occur by March 1989.

Seven vendors submitted-. proposals.: Because of the number and diversity of the proposals received, the evaluation -

and selection of a vendor exceeded the time allocated and finali awarding of a contract was not' made until mid-JuneL1989 with CE acceptance of the contract occurring-on June 30 1989. The NRC was informed of this milestone changeL in Reference 3.-- At that time.

Detroit Edison did-not consider the ' delay in selecting 'a: vendor a major setback in achieving certification.' Tho schedule showed the project could be completed on time. -A dedicated group of 15-people

' was established to perform the onsite work, including project..

management, control / logic modeling, and certification documentation '

preparation.-

Af ter the contract was awarded. the-next 'significant milestones :

identified in Reference. 2 occurred in ~ 1990. - These involved < completing the development of-the dynamic process.models and the control / logic '

a models, and hardware and sof tware integration. - The dynamic process 1 and. control / logic model development milestones were completed on time in-September 1990. Hardware and sof tware ' integration :(or model merge) is the process of loading the dynamic process-andfcontrol/ logic'models onto the simulator computer.

The'. process began in October 1990 per'

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the original schedule and was to be completed in December 1990. It was during this time severa1' technical problems emerged that affected the schedule. When the resolution of the technical problems was not.

forthcoming.. an in-depth review of the project was done. The results of this review indicated that the final project milestones.of simulator performance testing =and: certification would not be completed in time to support submittal of_ simulator certification to the NRC by the March 26.-1991; deadline. A letter informing the NRC of this fact was sent in December 1990 (Reference 4). ' A detailed review of remaining work ccope including determination' of a high confidence:

schedule, has since been completed.

The revised project schedule indicates that simulator model merge will be completed by-March 15. 1991~ and_.that simulator certification-testing will be completed by August 22, 1991. ' The-schedule allows about 4 weeks after certification testing to compile and finalize documentation, and to prepare and submit.sinnlator certification. 'The use of the simulator for licensed operator training and;other training

- programs has also been factored into the revised schedule.

I The resolution of the technical problems identified in late 1990 has =

not been completed' but has been factored into the. revised schedule.

One technical problem involves the inability to achieve steady state full power conditions on the simulator. - ABB has been evaluating this problem and believes it may be rooted in the parameters used for the~

dynamic process model calculations for the steam cycle systems. Once

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.j LISNRC January 31. 1991 NRC-91-0015

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this was recognized as the~most:likely cause of the problem, it was l

necessary for ABB to update the dynamic process models for the steam cycle systems. This ef fort is underway.1 Achievement of the fu114 7

power steady state milestone-'is now expected ~ in February. 3 months l

later than originally scheduled.

Another problem involves the respouse time of'some of :the panel' input / output' devices.

For example, when the control: switch for_a pump-'

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is turned on there is.a status light on' the switet that changes; from green to red - to indicate the pump is running. There is:a small but perceptible delay in the change f rom;the green to red ' light on the '

simulator. The deleyi La T.nticeably ' longer than what occurs in the -

plant and needs to be corrected.

The resolution of these and o'ther technical problems is _' delaying completion of the project'beyond~the-March 26.;1991' certification'

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date, resulting in the need for a temporary exemption.

Detroit Edison believes that granting of the exemption request will' i

not present undue risk: to the public; health and safety' and is_-

consistent with the common defense ;and security. : 'As outlined in the regulation, the primary purpose for_ the simulation f acility -is tto provide a plant referenced simulator for administering-the operating -

test to applicants for operator and senior operator licenses.

Only

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the August 1991 examinations will be conducted on-other: than the

. certified simulator. :all: subsequent' examinations will-be_ performed on the certified: simulator.

l The existing simulation f acility has been used for operator training since 1984. NRC Region III inspectors have conducted' operating tests l

on the _ simulator during this same period and are aware of its -

3 capabilities. The operator requalification program, of which the L.

existing' simulator is an integral part, has been-accredited by' INFO since.1985..

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a Detroit Edison intends to continue to use the existing simulation i

l f acility for the operator requalification program unt111 the! upgraded l

simulator is'available for training use. Because the operator requalification program is based 'on a " systems approach to training'E 4

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as discussed in-10 CFR 55.59(c), it is Detroit Edison's understanding L

that use of tho' existing simulator-during this period would continue to meet NRC requirements for :the operator requalification' program.

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-I Detroit Edison requests approval of this exemption request prior'to March 26. 1991. The Nuclear Regulatory Commission recognized in the -

supplementary information published along _with the Final' Rule that unique circumstances may arise _ on_ a plant specific basis that causes some deviation from the certification time' established 1in the rule.

4 Detroit Edison has made good faith efforts to comply with the rule, j

but due to the problems described in this letter cannot meet the i

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USNRC January 31, 1991 NRC-91-0015 Page 5 certification date. Therefore, Detroit ' Edison requests a temp'orary exemption from 10 CFR 55.45, paregraphs (b)(2)(iii). and (b)(2)(iv) until September 30, 1991.

If you have any questions regarding _ this. request or need additional information, please contact Mr. Lewis P. Bregni at (313) 586-4072.

Sincerely, ll !

i cct A. B. Davis R. W. DeFayette W. G. Rogers J. F. Stang i

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