ML102420039

Comment (7) of Scott Cupp, on Behalf of Entergy Operations, Inc., on Draft Regulatory Guide DG-1248

ML102420039
Person / Time
Site:	Arkansas Nuclear
Issue date:	08/26/2010
From:	Cupp S Entergy Operations
To:	Rulemaking, Directives, and Editing Branch
References
75FR29785 00007, DG-1248
Download: ML102420039 (22)

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Mendiola, Doris From:

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CUPP, SCOTT G [SCUPP@entergy.com]

Thursday, August 26, 2010 3:26 PM Rulemaking Comments Alejandro, Raymond V; WALKER, DENVER R; RUSSELL, DAVID R; ADAMS, LARRY W; JONES, ROGER D ANO Comments DG-1248 Westrain Comments DG1248 FINAL.pdf The attached document is a summary of comments from the Westrain Simulator Support Subcommittee with respect to NRC DG-1248. Arkansas Nuclear One is a member of this organization which represents approximately 20 nuclear power plant sites.

In addition to the Westrain submittal, ANO provides the following comment external to the Westrain response:

ANSI/ANS-3.5-2009 Section 3.4.3.3 states that "simulator reactor corb performance testing shall be conducted to confirm that the simulator nuclear and thermal-hydraulic models replicate the reference unit core response within the scope of simulation." Section 4.4.3.3 states that "testing shall be performed in accordance with the reference unit procedures and shall be compared and demonstrated to replicate the response of the reference unit." The section later requires the simulator to meet the reference unit procedures' acceptance criteria.

Concern:

At many stations, including ANO, reactor engineering utilizes a reactivity meter to measure reactivity changes. Since this meter is not a fixed component of the reference unit control room and has no impact to operator training, it was not included in the original scope of simulation therefore preventing the ability to utilize reference plant procedures for core testing and comparison. The effort required to implement a reactivity meter does not seem cost effective since it results in no net improvement to the operator training program. In addition, simulator reactor core testing currently conducted specifically targets parameters visible during normal operator training conditions at selected times-in-core-life, whereas the additional low power physics testing mandated by reference plant procedures occur at a burnup not normally used by the operator training programs and provide little confidence that the reactivity parameters seen at other times-in-core-life are correct.

For our station, the new core testing requirement is seen as a barrier to implementation of ANSI/ANS-3.5-2009 due to the (1) additional time required to establish/maintain a zero burnup condition set, (2) additional time to conduct reactor core testing in accordance with reference unit procedures (in addition to the simulator core testing already done), and (3) the additional time/cost associated with implementation of a reactivity meter.

Recommendation:

With regard to DG-1248 Section C2(g), add a statement at the end of the paragraph stating:

If the scope of simulation prevents performance of simulator reactor core testing using reference plant procedures as required by Section 4.4.3.3 of ANSI/ANS-3.5-2009, then the utility should document an exception to the standard and establish simulator reactor core testing methodologies (including acceptance criteria) that demonstrate the simulator response replicates the response of the reference unit.

Thank you for the opportunity to provide comments, Scott Cupp Supt, Simulator and Training Support Arkansas Nuclear One Phone: (479) 858-6858 Fax:

(479) 858-6820 Pager: (479) 498-1266 E-mail: scupp@entergy.com

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WESTRAIN Simulator Subcommittee Comments DRAFT REGULATORY GUIDE DG-1248 Item 1 Reference DG-1248 Comment Proposed Revision L._Original Text I

to DG-1248 Page 3, 2n-N/A The commission should state Add to the 2 nd paragraph: "The paragraph under; that it recognizes exceptions commission recognizes exceptions "Plant-Referenced taken on initial certification of taken on initial certification of Simulator simulation facilities.

simulation facilities; these exceptions Performance may be carried forward as applicable Testing" to the ANS-3.5-2009 Standard."

2 Page 3, 3 rd Additionally, the This comment implies that the Add to the 3rd paragraph: "Facility paragraph under; Commission's regulations only testing acceptance criteria licensees that propose to use a plant-

"Plant-Referenced in 10 CFR 55.46(c)(2) for experience requirement referenced simulator to meet the Simulator require that facility criteria are items (1) and (2) of experience requirements in 10 CFR Performance licensees that propose to use this paragraph.

55.31 (a)(5) shall validate the Testing" a plant-referenced simulator performance of the simulator via to meet the experience The regulator should reference simulator reactor core performance requirements in 10 CFR scenario-based testing testing and scenario-based testing 55.31 (a)(5) ensure that (1) acceptance criteria in Section utilizing acceptance criteria in the plant-referenced 4.4.3.2 or clearly state any sections 4.4.3.2 and 4.4.3.3 of the simulator utilizes models additional acceptance criteria in Standard, respectively."

relating to nuclear and the regulatory guide. This thermal-hydraulic comment also applies to DG characteristics that replicate 1248 Appendix B, Item 5 for the the most recent core load in experience requirement.

the nuclear power reference plant for which a license is being sought, and (2) simulator fidelity has been demonstrated so that significant control Page 1 of 21

WESTRAIN Simulator Subcommittee Comments DRAFT REGULATORY GUIDE DG-1248 Item Reference DG-1248 Comment Proposed Revision I Original Text Ito DG-1248 manipulations are completed without procedural exceptions, simulator performance exceptions, or deviation from the approved training scenario sequence.

3 Page 4, 2nd On December 8, 2009, NEI The last sentence should be On December 8, 2009, NEI provided paragraph under; provided for NRC review deleted from this paragraph. It for NRC review and endorsement of NEI 09-09, and endorsement of its implies a "back fit" from the its industry guidance document, NEI-

"Nuclear Power industry guidance proposed revision 4 of 09-09, Revision 1, "Nuclear Power Plant-Referenced document, NEI-09-09, Regulatory Guide 1.149 to a Plant-Referenced Simulator Scenario Simulator Scenario Revision 1, "Nuclear Power previous edition of the ANS-3.5 Based Testing Methodology" (Ref Based Testing Plant-Referenced Simulator Standard.

10), which provides an equitable and Methodology" Scenario Based Testing consistent approach and methodology Methodology" (Ref. 10),

for the conduct and documentation of which provides an equitable SBT, as described in Section 4.4.3.2, and consistent approach and "Simulator Scenario-Based Testing,"

methodology for the of ANSI/ANS-3.5-2009. NEI 09 09, conduct and documentation Revision 1, alse supports Seetoni of SBT, as described in 4.4.3.2, "Simulator-Scenar-io Based Section 4.4.3.2, "Simulator Testing," of ANS"/ANS 3.5 1998.

Scenario-Based Testing,"

of ANSI/ANS-3.5-2009.

NEI-09-09, Revision 1, also supports Section 4.4.3.2, "Simulator Scenario-Page 2 of 21

WESTRAIN Simulator Subcommittee Comments DRAFT REGULATORY GUIDE DG-1248 Item Reference DG-1248 Comment Proposed Revision Based Testing," of ANSI/ANS-3.5-1998.

4Property "ANSI code" (as page type) with input value "ANSI/ANS-3.5-1998.</br></br>4" contains invalid characters or is incomplete and therefore can cause unexpected results during a query or annotation process. Page 5, Section 2.b

b. In regard to Section 3.1.4, This paragraph should be

b. in rega.d to Scetion 3.1.,*

under; NEI 09-09, "Malfunctions," simulation deleted from this section. This "Malfn.*.etiens,. Sim.,ulatin fa.ility "NRC Acceptance facility licensees should paragraph is not consistent with licensees should demonstrate that and Endorsement of demonstrate that the records retention they have on...t. d pf*.f.-man..

ANSI/ANS-3.5-they have conducted requirement in testing of the malfun.tions listed in 2009" performance testing of the 10CFR55.46(d)(1) which states the standard, as appli-able to the malfunctions listed in the that "The results of performance design of the r.eference plant, at least standard, as applicable to tests must be retained for four once in the life of1the skulatien the years after the completion of facility and that the associated test design of the reference each performance test or until documentation includes the completed plant, at least once in the superseded by updated test test results. if perfom.ane. testing of a life of the simulation facility results."

malfunction has been and that the associated test completed mo*, than oene, then the documentation includes the The CFR reference allows

...nsee n.eed only retain the latest test completed test results. If malfunction tests to be discarded results. The staff r-ecognize-s, performance testing of a after four years. There is no that simulater malfunctien test results malfunction has been requirement to maintain may be retained lner. than 4 years completed more than once, performance tests records longer after-the completion ef eac then the licensee need only than four years.

malfuntion test. Therefoe, retain the latest test results.

fegar.less ef how

,log it has beefi The staff recognizes Additionally, the NRC has sin.e the malfun.tien test has been that simulator malfunction previously inspected the results per*f*med, the NRC expe

-t s

test results may be retained of the ANS-3.5-1985 Standard sifumlWtin facility i*ensees to

.ma]

longer than 4 years after the malfunction testing and the results ef these malfunetien completion of each approved initial certification of I

Pe tests avila.l fo" r,-

Page 3 of 21

WESTRAIN Simulator Subcommittee Comments DRAFT REGULATORY GUIDE DG-1248 Item Reference DG-1248 Conmment Proposed Revision Original Text Ito DG-1248 malfunction test. Therefore, the simulators which included review, either before, or c.ncu.. ent.

regardless of how long it the malfunction tests.

with, the pr.epar.ation for-eac. h has been since the operating test or-r.e.ualifica*

t malfunction test has been pro-gr*am. inspc.ti.n.

performed, the NRC expects simulation facility licensees to make the results of these malfunction performance tests available for NRC review, either before, or concurrent with, the preparation for each operating test or requalification program inspection.

5 Page 6, Section 2.d

d. In regard to Section Delete "(such as just-in time

d. In regard to Section 3.4.3.2, under; NEI 09-09, 3.4.3.2, "Simulator training and routine plant system "Simulator Scenario-Based Testing,"

"NRC Acceptance Scenario-Based Testing,"

and equipment startup and simulation facility licensees and Endorsement of simulation facility licensees shutdown training)".

should meet the requirements of the ANSI/ANS-3.5-should meet the standard with respect to the following 2009" requirements of the standard The perceived intent of this type of SBTs for inclusion as with respect to the sentence was to provide simulator performance tests: (1) NRC following type of SBTs for examples when operator and initial license examination (operating inclusion as senior operator training test) scenarios, (2) licensed simulator performance tests:

simulator scenarios are excluded operator requalification annual (1) NRC initial license from SBT for purposes of examination (operating test) simulator examination (operating test) meeting the standard's SBT scenarios, and (3) scenarios used Page 4 of 21

WESTRAIN Simulator Subcommittee Comments DRAFT REGULATORY GUIDE DG-1248 Item Reference DG-1248 Comment Proposed Revision I

I Original Text IJto DG-1248 scenarios, (2) licensed requirements; however, the for performing applicant control operator requalification examples provided within the manipulations that affect reactivity to annual examination parentheses is not all inclusive establish eligibility for an (operating test) simulator when operator and senior operator's license. All other operator scenarios, and (3) scenarios operator training simulator and senior operator training simulator used scenarios may excluded from scenarios (such as just in tim-a trainiMg for performing applicant SBT for purposes of meeting the and r..utin plant system and control manipulations that standard's SBT requirements. It equipment startup and shutdown affect reactivity to establish could be perceived by licensees training) are excluded from SBT for eligibility for an and inspectors that these are the purposes of meeting the standard's operator's license. All other only occasions when operator SBT requirements.

operator and senior operator and senior operator training training simulator scenarios simulator scenarios are excluded (such as just-in time training from SBT for purposes of and routine plant system meeting the standard's SBT and equipment startup and requirements, despite the fact shutdown training) are that the three requirements are excluded from SBT for listed in this section.

purposes of meeting the standard's SBT requirements.

6 Page 6, Section 2.e

e. In regard to Section Delete this section in its entirety. e. In regard to Section 1.143-,

under; NEI 09-09, 4.4.3.1, "Simulator It does not clarify or add any

,Sif*..ter

,Opefability Testin","

"NRC Acceptance Operability Testing,"

additional guidance than that Footnote 6, as referenced to and Endorsement of Footnote 6, as referenced to already noted in the Standard App en dix A, "Gu'ide;lde Iinef ANS!ANS-3.5-Appendix A, "Guideline for and could only add to confusion.

Dou*m.entation f Simfu*laor Design 2009" Documentation of Simulator I

rand Test Perform.an.e," simulation Page 5 of 21

WESTRAIN Simulator Subcommittee Comments DRAFT REGULATORY GUIDE DG-1248 Item Reference DG-1248 Comment Proposed Revision I OrigialTet to DG-1248 Design and Test f-eility lcensees sh.. uld note that Performance," simulation Appendix A provides ex.amples tha facility licensees should are appliable to Seetin 4.4.3. 1.

note that Appendix A provides examples that are applicable to Section 4.4.3.1.

7 Page 6, Section 2.f

f. In regard to Section Editorial; delete words "other"

f. In regard to Section 4.4.3.2, under; NEI 09-09, 4.4.3.2, "Simulator and "such as that" from the last "Simulator Scenario-Based Testing,"

"NRC Acceptance Scenario-Based Testing,"

sentence to provide clarity in simulation facility licensees should and Endorsement of simulation facility licensees regards to the regulator's also adhere to the NEI standardized ANSI/ANS-3.5-should also adhere to the expectations, approach for the conduct, 2009" NEI standardized approach performance, and documentation of for the conduct, simulator SBT, as described in NEI performance, and 09-09, Revision 1. The NRC expects documentation of simulator licensees to perform other--simulator SBT, as described in NEI performance testing,,sueh as.tha 09-09, Revision 1. The described in Section 4.4.3.1, NRC expects licensees to "Simulator Operability Testing";

perform other Section 4.4.3.3, "Simulator Reactor simulator performance Core Performance Testing", and testing, such as that Section 4.4.3.4, "Post-Event described in Section 4.4.3.1, Simulator Testing," separately and "Simulator Operability independently from the testing Testing";

described in Section 4.4.3.2.

Section 4.4.3.3, "Simulator Reactor Core Performance Page 6 of 21

WESTRAIN Simulator Subcommittee Comments DRAFT REGULATORY GUIDE DG-1248 Item Reference DG-1248 Comment Proposed Revision Original Text to DG-1248 Testing", and Section 4.4.3.4, "Post-Event Simulator Testing,"

separately and independently from the testing described in Section 4.4.3.2.

8 Page 6, Section 2.g

g. In regard to Section First sentence:

g. In regard to Section 4.4.3.3, under; NEI 09-09, 4.4.3.3, "Simulator Reactor "Simulator Reactor Core Performance "NRC Acceptance Core Performance Testing,"

1. Add "within the scope of Testing," simulation facility licensees and Endorsement of simulation facility simulation" to be consistent should meet the requirements of the ANSI/ANS-3.5-licensees should meet the with Section 3.4.3.3 of standard within the scope of 2009" requirements of the standard Standard.

simulation with rcspet to real

ifn, with respect to real time and and the conduct of core evolutions the conduct of core

2. Delete "with respect to real involved. The NRC expects a facility evolutions involved. The time"; there are some licensee's plant-referenced simulator NRC expects a facility simulator performance tests to utilize models relating to nuclear licensee's plant-referenced that would require an eight and thermal-hydraulic characteristics simulator to utilize models hour run time (such as a that replicate a core load in the relating to nuclear and peak xenon test). Simulation nuclear power reference plant. If the thermal-hydraulic facilities appreciate the use plant-referenced simulator is used to characteristics that replicate of the fast time simulation meet NRC applicant experience a core load in the nuclear feature to conduct tests that requirements, as described in 10 CFR power would require an extensive 55.3 l(a)(5), then the most recent core reference plant. If the plant-amount of run time in an age load (e.g., the core load(s) that existed referenced simulator is used where simulator utilization during the time of the NRC to meet NRC applicant by the operations training applicant's initial training program; Page 7 of 21

WESTRAIN Simulator Subcommittee Comments DRAFT REGULATORY GUIDE DG-1248 Item Reference DG-1248 Comment Proposed Revision Original Text to DG-1248I experience requirements, as described in 10 CFR 55.31 (a)(5), then the most recent core load (e.g., the current reference plant core load, or if the reference plant is in a refueling outage, the core load just previous to the outage) in the nuclear power reference plant for which a license is being sought must be utilized.

programs is very high.

3.

Clarify "and the conduct of core evolutions involved".

This appears to be an incomplete sentence.

The third sentence references "the most recent core load".

License classes may run through more than one fuel operating cycle, so reactivity manipulations may be conducted on core loads that precede and follow a refueling outage, therefore, reactivity manipulations may not be performed in the same fuel cycle.

Additional clarification is required in the third sentence taking into account the preceding comment. Consider defining the "most recent core load" as "the core load(s) that existed during the time of the NRC applicant's initial training reactivity manipulations may be conducted on core loads that precede and follow a refueling outage, therefore, reactivity manipulations may be performed in more than one fuel cycle) the cu.en.t reference plan eor-e leoa, or-if the r-efer-enco plant is in a refueling outage, the core lea' just previous to the outage) in the nuclear power reference plant for which a license is being sought must be utilized.

Page 8 of 21

WESTRAIN Simulator Subcommittee Comments DRAFT REGULATORY GUIDE DG-1248 Item Reference DG-1248 Comment 1

Proposed Revision Or*igialTe.06 toDG14 program".

9 Page 6, Section 2.h under; NEI 09-09, "NRC Acceptance and Endorsement of ANSI/ANS-3.5-2009"

h. In regard to Section 4.4.3.4, "Post-Event Simulator Testing,"

simulation facility licensees should meet the requirements of the standard with respect to demonstrating that the plant-referenced simulator performance and response compares favorably to the reference plant's performance and response without significant deviation from the sequence of events for the reference plant event. As a minimum, a licensee should demonstrate on the plant-referenced simulator those reference plant events that result in (1) the automatic initiation of an engineered safety system, (2) the manual or automatic trip of the nuclear Second sentence:

1. Delete "As a minimum" to place focus on demonstrating simulator performance for items 1 through 4.

2. Delete "reference plant events" and "such as" and add "relevant unplanned or unexpected (off-normal) events-deemed appropriate by the facility licensee"; this language provides some degree of flexibility to the licensee and is consistent with the intent of Sections 3.4.3.4 and 4.4.3.4 in the Standard. The items listed in Section 2.h can occur during normal plant evolutions and routine surveillance testing, the scope of testing could be very great. Therefore, it

h. In regard to Section 4.4.3.4, "Post-Event Simulator Testing," simulation facility licensees should meet the requirements of the standard with respect to demonstrating that the plant-referenced simulator performance and response compares favorably to the reference plant's performance and response without significant deviation from the sequence of events for the reference plant event. As a m.inif.mum, a licensee should demonstrate on the plant-referenced simulator those relevant unplanned or unexpected (off-normal) events e"fcrcnee plant events deemed appropriate by the facility licensee, such as that result in (1) the automatic initiation of an engineered safety system, (2) the manual or automatic trip of the nuclear reactor, (3) a significant unpla... d r t..xpe.t. d reactivity change, and (4) the manual or automatic trip of the main turbine-generator while online with the electrical grid, and (5) any oer.... vnt A

Page 9 of 21

WESTRAIN Simulator Subcommittee Comments DRAFT REGULATORY GUIDE DG-1248 Item Reference DG-1248 Comment Proposed Revision reactor, (3) a significant should be clarified that the deemed apprpr*iate by the facility unplanned or unexpected unplanned, unexpected, and licensee within 60 calendar days reactivity change, (4) the off-normal events should be felwing the event to en...e that manual or automatic trip of the focus of post event fidelity is being met and maintained.

the main turbine-generator simulator testing.

The comparison should be performed while online with the and any significant deviations electrical grid, and (5) any

3. Delete item 5 from the list identified within 60 days of the event.

other event deemed and add the following appropriate by the facility clarification: "The licensee within 60 calendar comparison should be days following the event to performed and any ensure that fidelity is significant deviations being met and maintained, identified within 60 days of the event." This is to clarify that resolutions to noted deviations are not required to be resolved within 60 days; depending on scope of deviation, efforts to resolve could take longer than 60 days (and may require vendor support or model replacements).

10 Page 6, Section 3 The NRC staff has reviewed The reference to ANS-3.5-1998 The NRC staff has reviewed NEI under; "NRC NEI-09-09, Revision 1, and should be deleted from the 09, Revision 1, and finds the Acceptance and finds the implementation second sentence. It implies a implementation guidance an Endorsement of guidance an acceptable "back fit" from the proposed acceptable method for simulation Page 10 of 21

WESTRAIN Simulator Subcommittee Comments DRAFT REGULATORY GUIDE DG-1248 Item Reference DG-1248 Comment Proposed Revision I_______Original____________________________Text_______________to__________DG__________1248__.Orgn l e tI oDGI4 I

I'

.Y.

NEI-09-09, Revision 1" method for simulation facility licensees to demonstrate their compliance with the requirements of Sections 3.4.3.2 and 4.4.3.2 of ANSI/ANS-3.5-2009 regarding simulator SBT.

Therefore, the NRC accepts and endorses NEI-09-09 as an acceptable method for an equitable and consistent approach and methodology for the conduct and documentation of SBT, as described in ANSI/ANS-3.5-2009 (and ANSI/ANS-3.5-1998, which NEI-09-09, Revision 0, supported). Implementation of NEI-09-09, Revision 1, ensures that simulation facility licensees will demonstrate expected plant response to operator input and to normal, transient, and accident conditions to which the simulator has been revision 4 of Regulatory Guide 1.149 to a previous edition of the ANS-3.5 Standard.

Delete third sentence in its entirety. The NEI 09-09 document does not, by itself, satisfy the 10CFR5 5.46 requirements to: (1) demonstrate expected plant response to operator input and to normal, transient, and accident conditions to which the simulator has been designed to respond (10CFR55.46(c)), and (2) that significant control manipulations are completed without procedural exceptions, simulator performance exceptions, or deviation from the approved training scenario sequence (10CFR55.46(c)(2)(ii)). The simulator's testing program as described in Sections 3.4 and 4.4 of the Standard is designed to meet the requirements in 10CFR55.46.

facility licensees to demonstrate their compliance with the requirements of Sections 3.4.3.2 and 4.4.3.2 of ANSI/ANS-3.5-2009 regarding simulator SBT. Therefore, the NRC accepts and endorses NEI-09-09 as an acceptable method for an equitable and consistent approach and methodology for the conduct and documentation of SBT, as described in ANSI/ANS-3.5-2009 (and AVTQT/A *TQ I

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11*1 J1 Revision 1, ensures that simulation facility hlccnsees will demonstrate cxpccted plant rc-sp.nsc to oper*at*

input and to normnal, transient, and accrident cond-ition-s to-4which the simulator has been de *-ned t respond, so that signifieant control maniplations are completed without proceedural exceptions, simulator per-formance exceeptions, or-deviation from the approved tfaining cnai sequenee.

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L Page 11 of 21

WESTRAIN Simulator Subcommittee Comments DRAFT REGULATORY GUIDE DG-1248 Item Reference DG-1248 IComment Proposed Revision Original Text Ito DG-1248 designed to respond, so that significant control manipulations are completed without procedural exceptions, simulator performance exceptions, or deviation from the approved training scenario sequence.

11 Page 7, Section 4 Licensees who maintain First sentence:

4. Acceptability of Licensee's under; simulation facilities Simulation Facility "Acceptability of certified under previous

1. Substitute "testing Licensees who maintain simulation Licensee's editions of ANSI/ANS-3.5 documentation" with facilities certified under previous Simulation

(-1998, -1993, and -1985)

"testing methodology". It is editions of ANSI/ANS-3.5 Facility" endorsed by the NRC are not perceived that previous

(-1998, -1993, and -1985) endorsed encouraged to, but are not simulator documentation by the NRC are encouraged to, but are required to, revise the would be revised to not required to, revise the software and testing transition to ANS-3.5-2009.

software and testing deouffientati documentation to maintain methodology to maintain the the simulation facility in

2. The idea that "the NRC simulation facility in accordance with accordance with encourages simulation ANSI/ANS-3.5-2009. The NRC staff ANSI/ANS-3.5-2009. The facilities to, but do not recognizes that it will take some time NRC staff recognizes that it require simulation facilities for these simulation facility will take some time for to..." and "the NRC staff licensees to transition to ANSI/ANS-these simulation facility anticipates that simulation 3.5-2009. Therefere, the NRC staff licensees to transition to facility licensees will anticipeAts that simulatin ANSI!ANS-3.5-2009.

voluntarily move to facili*ty4 lensees will,oluntril Page 12 of 21

WESTRAIN Simulator Subcommittee Comments DRAFT REGULATORY GUIDE DG-1248 Item Reference DG-1248 Comment Proposed Revision Therefore, the NRC staff ANSIANS-3.5-2009" m.v. te ANSI/ANS 3.5 2009 anticipates that simulation appears to be contradictory.

following the date of the fial facility licensees will regulate voluntarily move to There is a recommendation, guide- (e*g. Regulaery -Guide, 1 149-,

ANSI/ANS-3.5-2009 followed by a soft requirement; Revision-4).

following the date of the there is direction, but no final regulatory direction.

guide (e.g., Regulatory Guide 1.149, Revision 4).

Recommend either: (1) deletion of last sentence, or (2) absolute direction to the industry regarding transition to one Standard.

12 Page 7, Section 5, The NRC will only This statement should be The NRC will only administer second paragraph administer operating tests applicable to single/multiple unit operating tests on a single/multiple under; "Use of on a plant-referenced plants.

plant-referenced simulator that meets Simulation Facility simulator that meets the the Commission's requirements, as for Multiple Plants" Commission's Correct typo "plant-referenced".

described in 10 CFR 55.46. In requirements, as described addition, a licensee must request in 10 CFR 55.46. In May need to address use of Commission approval if it plans to addition, a licensee must single unit plant-referenced administer the NRC operating test request simulator in separate section using other than a-plant-referenced Commission approval if it since Section 5 is specific to simulator or the plant.

plans to administer the NRC multiple plants.

operating test using other than a -plant-referenced simulator or the plant.

Page 13 of 21

WESTRAIN Simulator Subcommittee Comments DRAFT REGULATORY GUIDE DG-1248 Item Reference DG-1248 Comment Proposed Revision Original Text to DG-1248 13 Page 8, Section D, third paragraph under; "Implementation" The NRC staff recognizes that a commitment to ANSIIANS-3.5-2009 is voluntary on the part of simulation facility licensees.

Since its last revision to Regulatory Guide 1.149, the NRC staff has worked closely with simulation facility licensees and other interested stakeholders through the NEI LOFG to facilitate voluntary movement to a single industry consensus standard.

The NRC has determined that movement to a single consensus standard is in the best interest of simulation facility licensees, as well as NRC inspectors and examiners and the general public. The NRC is confident that such a movement will be seamless and transparent The WESTRAIN Simulator Subcommittee disagrees that "such a movement will be seamless and transparent with minimal burden".

See comments associated with Item 4 above.

Producing malfunction test documentation to satisfy Section 2.b will be a significant burden and costly if the licensee will be required to conduct old malfunction tests. This is particularly true for those facilities that eliminated records over 4 years old as allowed by 10CFR 55.46.

Also, additional documentation associated with NE10909 is considered excessive and an unnecessary burden. Marking up and retaining all procedures used during the scenario-based test is of no advantage to the N/A Page 14 of 21

WESTRAIN Simulator Subcommittee Comments DRAFT REGULATORY GUIDE DG-1248 Item Reference DG-1248 Comment Proposed Revision Original Text to DG-1248 with minimal burden, if any. facility except to demonstrate As a result, NRC review compliance in the NRC and inspection of inspection process. The plant-referenced simulators affirmation of the acceptance for compliance with the criteria by the lead instructor is requirements of 10 CFR sufficient. The WESTRAIN 55.46 will be more uniform Simulator Subcommittee agrees and consistently that capturing alarms and trends implemented when the staff can provide some value to the carries out the Reactor lead instructor during the SBT; Oversight Process baseline however, this requirement is in Inspection Procedure, IP-fact additional burden.

71111.11, "Licensed Operator Requalification Program."

14 Page 9, 5th Revision of Regulatory Is this revision of Regulatory Revision of Regulatory Guide 1.149 paragraph under; Guide 1.149 is necessary for Guide 1.149 necessary for is necessary for (1) the NRC to "Regulatory (1) the NRC to endorse the simulation facility licensees to endorse the use of ANSI/ANS-3.5-Analysis" use of voluntarily move to a single 2009 as a technical standard to ensure ANSI/ANS-3.5-2009 as a consensus standard and carry compliance with the Commission's technical standard to ensure out its requirements?

simulation facility scope and fidelity compliance with the requirements, (2) simulation facility Commission's simulation Item 2 does not meet the intent li..nse.s to v.hlntarily m. ve tc a facility scope and fidelity of DG 1248, whereas the other single requirements, (2) simulation three items do; delete item 2.

consensus standard and earry out its facility licensees to ts-(2) the NRC to voluntarily move to a single communicate its expectations, and Page 15 of 21

WESTRAIN Simulator Subcommittee Comments DRAFT REGULATORY GUIDE DG-1248 Item Reference DG-1248 Comment Proposed Revision' consensus standard and (3) facilitation of a common approach carry out its requirements, and methodology for conducting and (3) the NRC to documenting simulator communicate its scenario-based performance testing.

expectations, and (4) facilitation of a common approach and methodology for conducting and documenting simulator scenario-based performance testing.

15 Page 10, 1st The benefit of updating and Revising Regulatory Guide The benefit of updating and revising paragraph under; revising Regulatory Guide 1.149 will not preclude negative Regulatory Guide 1.149 is that it "Alternative 1.149 is that it would training and inappropriate would provide guidance to Approaches" provide guidance to operator license evaluations, ensure that nuclear power plant ensure that nuclear power simulation facilities used for operator plant simulation facilities Strike this phrase from this training, license examinations, and used for operator training, paragraph; it appears naive.

applicant experience requirements are license examinations, and Implementation of the maintained in accordance with the applicant experience Regulatory Guide 1.149 industry's most recent requirements are maintained Revision 4 and the ANS-3.5-consensus standardwhieh -will in accordance with the 2009 Standard will not by itself pr.e.lude negative training and industry's most recent preclude negative training inappropriate ope.ater. leense consensus standard, which

("...preclude negative e

a tiei will preclude negative training..." is an absolute Simulation facilities that meet the training and inappropriate statement).

minimum scope and fidelity operator license evaluations.,_I requirements of ANSI/ANS-3.5-2009 Page 16 of 21

WESTRAIN Simulator Subcommittee Comments DRAFT REGULATORY GUIDE DG-1248 Item Reference DG-1248&

Comment T

Proposed Revision

_ _Original Text

{

to DG-1248 Simulation facilities that must meet the minimum scope be able to demonstrate, on a and fidelity requirements of continuing basis, compliance with the ANSI/ANS-3.5-2009 must Commission's simulation facility be able to demonstrate, on a regulations, as described in 10 CFR continuing basis, 55.46.

compliance with the Commission's simulation facility regulations, as described in 10 CFR 55.46.

16 Page 10, 2nd The impact to the NRC The WESTRAIN Simulator N/A paragraph under; would be the costs Subcommittee believes that it is "Alternative associated with preparing inappropriate for the NRC staff Approaches" and issuing the revised to "believes that simulation regulatory guide. The facility licensees would incur impact to the public would little or no cost" (See comments be the voluntary costs associated with items 4 and 13 associated with reviewing above).

and providing comments to the The WESTRAIN Simulator NRC during the public Subcommittee agrees that comment period. The "significant human resource impact to facility licensees burdens... are anticipated as a would be the cost of result of moving to one implementing the new standard."

standard. The value to the Page 17 of 21

WESTRAIN Simulator Subcommittee Comments DRAFT REGULATORY GUIDE DG-1248 Item Reference*

DG-1248 Comment ProposedRevision Original Text toDG-1248 NRC staff and facility licensees would be the benefits associated with enhanced efficiency and effectiveness in using a common guidance document as the technical basis for demonstrating compliance with the Commission's simulation facility scope and fidelity requirements, as described in 10 CFR 55.46, and during other interactions between the NRC and facility licensees.

The staff believes that simulation facility licensees would incur little or no cost (for licensees who have not already moved to ANSI/ANS-3.5-2009, the cost is expected to be minimal, if any, since significant human resource burdens and simulator Where is human resource burdens reduced? Transition from 1998 to 2009 requires additional burden for SBT documentation, core performance testing, and post event simulator testing.

The WESTRAIN Simulator Subcommittee agrees that there was some burden removed during transition from the ANS-3.5-1985 Standard to the ANS-3.5-1998 Standard.

Page 18 of 21

WESTRAIN Simulator Subcommittee Comments DRAFT REGULATORY GUIDE DG-1248 EItem Reference I

DG-1248 IComment 1Proposed Revision I Origial Text to DG-1248 performance testing time savings are anticipated as a result of moving to one standard, which the proposed guide is advocating).

17 Page 11 under; N/A Add definitions for: (1)

N/A "Glossary" replicate, (2) significant deviation, (3) compare favorably, (4) procedural exception.

18 Appendix B, Item 2 N/A Please clarify; do "Simulator N/A initial conditions (IC) agreed with reference plant with respect to reactor status, plant configuration, and system operation" only apply to scenarios associated with reactivity manipulations?

19 Appendix B, Item SBT conducted in a manner Reference to ANS-3.5-2009 is SBT conducted in a manner sufficient 10 sufficient (i.e., meets redundant in this proposed (i.e., meets r-equir-ements of requirements of revision 4 to Regulatory Guide ANS

,ANS 3,.5,2009) to ensure that ANSI/ANS-3.5-2009) to 1.149.

simulator fidelity has been ensure that simulator demonstrated and met for this fidelity has been Delete reference to ANSI/ANS-scenario. Note: Attach relevant "as-Page 19 of 21

WESTRAIN Simulator Subcommittee Comments DRAFT REGULATORY GUIDE DG-1248

[Item Reference DG-1248 Comment Proposed Revision demonstrated and met 3.5-2009.

run" marked-up plant procedures and for this scenario. Note:

or procedure portions/pages utilized Attach relevant "as-run" to support assertion.

marked-up plant procedures and or procedure portions/pages utilized to support assertion.

20 Appendix B, Item Modeling and hardware Regarding the sentence; Modeling and hardware discrepancies 11 discrepancies identified "Modeling and hardware identified during the conduct of SBT during the conduct of SBT discrepancies identified during are are the conduct of SBT are documented and-entefed in documented and entered in documented and entered in accordance with the site simulator accordance with the site accordance with the site configuration simulator configuration simulator configuration management procedures. Note:

management procedures.

management procedures"...

Discrepancies that directly affect Note: Discrepancies that operator response (or directly affect operator The term "and entered" is action) or expected plant response response (or redundant to "documented" in must be resolved before the SBT test action) or expected plant the configuration management results can be response must be resolved process. Strike the phrase "and judged as satisfactory.

before the SBT test results entered".

can be judged as satisfactory.

21 Appendix B, Page The draft regulatory guide In regards to the italicized note N/A B-I includes this appendix so at the bottom of Page B-1...

that the public can discern 1_1 Page 20 of 21

WESTRAIN Simulator Subcommittee Comments DRAFT REGULATORY GUIDE DG-1248

((tem[

Reference DG-1248 Comment TProposed Revision Original Text j

to DG-1248 the staff's acceptance and The WESTRAIN Simulator endorsement of the Subcommittee recommends that Nuclear Energy Institute's this appendix not be included in (ANI) industry technical final regulatory guide; remove guidance document, NEI-any references to it in the body 09-09, Revision 1. Thefinal of the proposed revision to the guide may or may not regulatory guide.

include this appendix.

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