ML102720830
| ML102720830 | |
| Person / Time | |
|---|---|
| Site: | Palo Verde  |
| Issue date: | 08/10/2010 |
| From: | Potter W Arizona Public Service Co |
| To: | Robert Carpenter Rulemaking, Directives, and Editing Branch |
| References | |
| 75FR29785 00013, DG-1248 | |
| Download: ML102720830 (21) | |
Text
Mendiola, Doris
Subject:
FW: Palo Verde DG-1248 Comments Attachments: Palo Verde Comments to NRC DG1248.pdf Importance: High From: Warren.Potter@aps.com [1] (
Sent: Tuesday, August 10, 2010 4:09 PM To: Carpenter, Robert Cc: Vick, Lawrence 10 5
Subject:
Palo Verde DG-1248 Comments Importance: High Please accept the attached comments on Draft Guide 1248 from Palo Verde Nuclear Generating Station. If you have any questions please don't hesitate to contact me.
Sincerely, Warren Potter Simulator Support Section Leader Palo Verde Nuclear Station Phone: 623 393-6165 Cell: 623 910-1525 Pager.877 467-1189 7 2 Fax: 623 393-6164 i E-mail: wpotter(,apsc.comr C)D CrV 6eo13
-14
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Palo Verde Comments DRAFT REGULATORY GUIDE DG-1248 Item Reference DG-1248 Original Text Comment Proposed Revision to DG-1248 I Page 3, 2 nd 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 and be Testing" applicable to the ANS-3.5-2009 Standard."
2 Page 3, 3rd Additionally, the This comment implies that the Add to the 3 rd 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. 55.3 1(a)(5) shall validatethe 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 manipulations are completed without Page 1 of 20
Palo Verde Comments DRAFT REGULATORY GUIDE DG-1248 Item I Reference DG-1248 Original Text Comment Proposed Revision to DG-1248 procedural exceptions, simulator performance exceptions, or deviation from the approved training scenario sequence.
3 Page 4, 2 nd 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, "Nuclear and endorsement of its implies a "back fit" from the its industry guidance document, NEI-Power Plant- industry guidance proposed revision 4 of 09-09, Revision 1, "Nuclear Power 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, also supports Section of SBT, as described in 4.4.3.2, "Simulator Scenar.io Based Section 4.4.3.2, "Simulator Testing," of ANSIIANS 3.5 1998.
Scenario-Based Testing,"
NEI-09-09, Revision 1, also supports Section 4.4.3.2, "Simulator Scenario-Based Testing," of ANSI/ANS-3.5-1998.
4 Page 5, Section 2.b b. In regard to Section 3.1.4, This paragraph should be b. in regard to Seetion 3. 1A-,
under; NEI 09-09, "Malfunctions," simulation deleted from this section. This "Malfunctions," simulati.n fa.iliv" "NRC Acceptance facility licensees should paragraph is not consistent with licensees should demonstrate that Page 2 of 20
Palo Verde Comments DRAFT REGULATORY GUIDE DG-1248 Item I Reference DG-1248 Original Text Comment Proposed Revision to DG-1248 and Endorsement of demonstrate that the records retention they1 have conducted per-formance ANSI!ANS-3.5- they have conducted requirement in testing of the malfuncetionis listed in 2009" performance testing of the 10CFR55.46(d)(1) which states the standard, as applicable to the malfunctions listed in the that "The results of performance design of the r-efer-encse plant, at least standard, as applicable to tests must be retained for four once in the life of the simulation the years after the completion of facility and that the associated test design of the reference each performance test or until docuentaion 111incld the completed plant, at least once in the superseded by updated test test r-esults. if per-for-mance testing of a life of the simulation facility results."
and that the associated test completed more than once, then the documentation includes the The CFR reference allows licensee need only retain the latest test completed test results. If malfunction tests to be discarded results. The staff r-ecognize performance testing of a after four years. There is no that simul1ator malfuncation test results malfunction has been requirement to maintain may be retained longer-than 4 year-s completed more than once, performance tests records longer after-the completion of eac then the licensee need only than four years. malfunction te&A. Ther-efirec, retain the latest test results.
The staff recognizes sic the mnalfuntioein test has been-that simulator malfunction per-formed, the NRC expet test results may be retained simulation facility licsensees to make longer than 4 years after the the r-esults of these malfunction completion of each performance tests available for-NRC malfunction test. Therefore, review, either-before, or!cencsufent regardless of how long it with, the pr-epar-ation for-ec has been since the operating test or-r-egualification malfunction test has been progra inpection.
performed, the NRC expects simulation facility licensees to make the results of these malfunction Page 3 of 20
Palo Verde Comments DRAFT REGULATORY GUIDE DG-1248 Item I Reference DG-1248 Original Text Comment Proposed Revision to DG-1248 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 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 (su.h as just in time trainin;g for performing applicant SBT for purposes of meeting the and rouitine plant sy....an 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.
Page 4 of 20
Palo Verde Comments DRAFT REGULATORY GUIDE DG-1248 Item Reference DG-1248 Original Text Comment Proposed Revision to DG-1248 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
- .. 3.1, under; NET 09-09, 4.4.3.1, "Simulator It does not clarify or add any "Simu1ato-* Operability Te*ting,"
"NRC Acceptance Operability Testing," additional guidance than that Footnote 6, as referenceed to and Endorsement of Footnote 6, as referenced to already noted in the Standard Appendix A, "Guideline for ANSI/ANS-3.5- Appendix A, "Guideline for and could only add to confusion. Documentation of Simuilatoer Design 2009" Documentation of Simulator and Test Per.formane," simuvalation Design and Test facility lcensees should note that.
Performance," simulation Appendix A provides examples that facility licensees should .. ppliable to Seeti, n 4.4.341.
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. simulation facility licensees should and Endorsement of simulation facility licensees also adhere to the NEI standardized ANSI/ANS-3.5- should also adhere to the approach for the conduct, 2009" NEI standardized approach performance, and documentation of for the conduct, simulator SBT, as described in NEI Page 5 of 20
Palo Verde Comments DRAFT REGULATORY GUIDE DG-1248 Item Reference DG-1248 Original Text 'Comment Proposed Revision to DG-1248 performance, and 09-09, Revision 1. The NRC expects documentation of licensees to perform other-simulator simulator SBT, as described performance testing, .s..eh.astha in NEI 09-09, Revision 1. described in Section 4.4.3.1, The NRC expects licensees "Simulator Operability Testing";
to 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 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 .e.p..t to real tim.e 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 Page 6 of 20
Palo Verde Comments DRAFT REGULATORY GUIDE DG-1248 Item I Reference DG-1248 Original Text I Comment I Proposed Revision to DG-1248 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 1(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 *duringthe time of the NRC to meet NRC applicant by the operations training applicant's initial training program) experience requirements, as programs is very high. the curetrefer-ence plant eor-e load, described in 10 CFR cr if the r-efer-ence plant is in a-55.31 (a)(5), then the most 3. Clarify "and the conduct of refulingoutge, the cor-e load just recent core load (e.g., the core evolutions involved". previous to the outage) in the nuclear current reference plant core This appears to be an power reference plant for which a load, or if the reference incomplete sentence. license is being sought must be plant is in a refueling utilized.
outage, the core load just The third sentence references previous to the outage) in "the most recent core load".
the nuclear power reference License classes may run through plant for which a license is more than one fuel operating being sought must be cycle, so reactivity utilized. 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.
Page 7 of 20
Palo Verde Comments DRAFT REGULATORY GUIDE DG-1248 Item I Reference DG-1248 Original Text Comment Proposed Revision to DG-1248 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 program".
9 Page 6, Sect 2.g Issue/Concern; Reactor Core Recommendation for DRAFT ANSI 3.5,,2009 section Testing in the plant is very REGULATORY GUIDE DG-1248 3.4.3.3 Simulator reactor limited depending on whether core performance testing In regard to 2g, add a statement at the requires that "Simulator initial criticality is attained as expected. Additionally, reactor end that says; reactor core performance utilizes a reactivity testing shall be conducted to engineering If the scope of simulation prevents meter to measure reactivity performance of simulator reactor core confirm that the simulator nuclear and thermal- changes. This requirement in the testing using reference plant hydraulic models replicate ANSI standard reduces the procedures as required by section the reference unit core quality of reactor core testing 4.4.3.3 of ANSI 3.5, 2009, then the response within the scope of currently being implemented by utility should document an exception most facilities. A reactivity to the standard and establish simulator simulation.
meter does not exist in the reactor core testing methodologies Section 4.4.3.3 Simulator simulator modeling which (including acceptance criteria) that reactor core performance means it is not within the scope demonstrate the simulator response testing requires that of simulation (section 3.4.3.3) replicates the response of the "Testing shall be performed and therefore prevents the reference unit.
in accordance with the ability to utilize the reference reference unit procedures plants procedures for core and shall be compared and testing. These two sections seem demonstrated to replicate to contradict each other when Page 8 of 20
Palo Verde Comments DRAFT REGULATORY GUIDE DG-1248 Item I Reference DG-1248 Original Text Comment Proposed Revision to DG-1248 the response of the considering what "within the reference unit." scope of simulation" actually Additionally, this section means.
requires the simulator to meet the reference unit procedures acceptance criteria.
10 Page 6, Section 2.h h. In regard to Section Second sentence: h. In regard to Section 4.4.3.4, "Post-under; NEI 09-09, 4.4.3.4, "Post-Event Event Simulator Testing," simulation "NRC Acceptance Simulator Testing," 1. Delete "As a minimum" to facility licensees should meet the and Endorsement of simulation facility licensees place focus on requirements of the standard with ANSI/ANS-3.5- should demonstrating simulator respect to demonstrating that the 2009" meet the requirements of the performance for items 1 plant-referenced simulator standard with respect to through 4. performance and response compares demonstrating that the favorably to the reference plant's plant-referenced simulator 2. Delete "reference plant performance and response without performance and response events" and "such as" and significant deviation from the compares favorably to the add "relevant unplanned or sequence of events for the reference reference plant's unexpected (off-normal) plant event. As a mi.nimum, a licensee performance and response events-deemed appropriate should demonstrate on the plant-without by the facility licensee"; this referenced simulator those relevant significant deviation from language provides some unplanned or unexpected (off-normal) the sequence of events for degree of flexibility to the events reference plant events deemed the reference plant event. As licensee and is consistent appropriate by the facility licensee, a minimum, a licensee with the intent of Sections such as that--es-tiin (1) the automatic should demonstrate on the 3.4.3.4 and 4.4.3.4 in the initiation of an engineered safety plant-referenced simulator Standard. The items listed system, (2) the manual or automatic those reference plant events in Section 2.h can occur trip of the nuclear reactor, (3) a that result in (1) the during normal plant significant unplanned or unex.peeted automatic initiation of an evolutions and routine reactivity change, and (4) the manual Page 9 of 20
Palo Verde Comments DRAFT REGULATORY GUIDE DG-1248 Item Reference DG-1248 Original Text Comment Proposed Revision to DG-1248 engineered safety system, surveillance testing, the or automatic trip of the main turbine-(2) the manual or automatic scope of testing could be generator while online with the trip of the nuclear very great. Therefore, it electrical grid, and (5) any eth. event.
reactor, (3) a significant should be clarified that the deemed appropriate by the facility unplanned or unexpected unplanned, unexpected, and ... ensec w 60
.ithin.alendar.days reactivity change, (4) the off-normal events should be following the event to ensur.- 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.
11 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 NEI-09-09, Revision method for simulation revision 4 of Regulatory Guide facility licensees to demonstrate their 1" facility licensees to 1.149 to a previous edition of compliance with the requirements of Page 10 of 20
Palo Verde Comments DRAFT REGULATORY GUIDE DG-1248 Item I Reference - DG-1248 Original Text I Comment I Proposed Revision to DG-1248 demonstrate their the ANS-3.5 Standard. Sections 3.4.3.2 and 4.4.3.2 of compliance with the ANSI/ANS-3.5-2009 regarding requirements of Sections Delete third sentence in its simulator SBT. Therefore, the NRC 3.4.3.2 and 4.4.3.2 of entirety. The NEI 09-09 accepts and endorses NEI-09-09 as an ANSI/ANS-3.5-2009 document does not, by itself, acceptable method for an equitable regarding simulator SBT. satisfy the 10CFR55.46 and consistent approach and Therefore, the NRC requirements to: (1) demonstrate methodology for the conduct and accepts and endorses NEI- expected plant response to documentation of SBT, as-described 09-09 as an acceptable operator input and to normal, in ANSI/ANS-3.5-2009 (and method for an equitable and transient, and accident I xxl.JIJIth Ll.1 J..."' txtv, VVhxit~fl +/-LVI VJ, consistent approach and conditions to which the 09, Revision 0, suppored),
methodology for the simulator has been designed to Implementation of NEI 09 09 conduct and documentation respond (10CFR55.46(c)), and Revision 1, ensures that Simuilat1 of SBT, as described in (2) that significant control facility licensees will demonstrate ANSI/ANS-3.5-2009 (and manipulations are completed cxpeetcd plant response to operater ANSI/ANS-3.5-1998, which without procedural exceptions, input and to normal, tr-ansient, and NEI-09-09, Revision 0, simulator performance accident eonditions to whieh the supported). Implementation exceptions, or deviation from simulator-has been designed to of NEI-09-09, Revision 1, the approved training scenario respond, so that significant conto ensures that simulation sequence manipulation aecmlted without facility licensees will (10CFR55.46(c)(2)(ii)). The procedural exceptions, simulatoe demonstrate expected plant simulator's testing program as performance eirceptions, or: deviation response to operator input described in Sections 3.4 and 4.4 fr-om the approved tr-aining cnai and to normal, transient, and of the Standard is designed to seeqenee.
accident conditions to which meet the requirements in the simulator has been 10CFR55.46.
designed to respond, so that significant control manipulations are completed without Page 11 of 20
Palo Verde Comments DRAFT REGULATORY GUIDE DG-1248 Item I Reference - DG-1248 Original Text Comment Proposed Revision to DG-1248 procedural exceptions, simulator performance exceptions,, or deviation from the approved training scenario sequence.
12 Page 6, 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 Facility" (-1998, -1993, and -1985) "testing methodology". It is editions of ANSI/ANS-3.5 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 deumentati 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. Therefore, the NRC staff licensees to transition to facility licensees will anticipates that simulatien.
ANSI/ANS-3.5-2009. voluntarily move to facility licensees will voluntarily Therefore, the NRC staff ANSI/ANS-3.5-2009" mov.e to ANSTVANS 3.5 2009 anticipates that simulation appears to be contradictory. following the
.f date the facility licensees will regulatory voluntarily move to There is a recommendation, guide (e.g., Regulatory Guide 1.1 4 9, ANSI/ANS-3.5-2009 followed by a soft requirement; Rev4'ien 4).
following the date of the there is direction, but no final regulatory direction.
Page 12 of 20
Palo Verde Comments DRAFT REGULATORY GUIDE DG-1248 Item Reference DG-1248 Original Text Comment Proposed Revision to DG-1248 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.
13 Page 6, 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 Commission approval if it plans to addition, a licensee must administer the NRC operating test request using other than a-plant-referenced Commission approval if it simulator or the plant.
plans to administer the NRC operating test using other than a -plant-referenced simulator or the plant.
14 Page 8, Section D, The NRC staff recognizes The WESTRAIN Simulator N/A third paragraph that a commitment to Subcommittee disagrees that under; ANSI/ANS-3.5-2009 is "such a movement will be "Implementation" voluntary on the part of seamless and transparent with simulation facility licensees, minimal burden".
Since its last revision to Regulatory Guide 1.149, the See comments associated with NRC staff has worked Item 4 above.
closely with simulation Page 13 of 20
Palo Verde Comments DRAFT REGULATORY GUIDE DG-1248 Iitem I Reference I DG-1248 Original Text I Comment I Proposed Revision to DG-1248 facility licensees and other Producing malfunction test interested stakeholders documentation to satisfy Section through the NEI LOFG to 2.b will be a significant burden facilitate voluntary and cost if the licensee will be movement to a single required to conduct old industry consensus standard. malfunction tests.
The NRC has determined that Also, additional documentation movement to a single associated with NE10909 is consensus standard is in the considered excessive and an best interest of simulation unnecessary burden.
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 with minimal burden, if any.
As a result, NRC review and inspection of plant-referenced simulators for compliance with the requirements of 10 CFR 55.46 will be more uniform and consistently implemented when the staff carries out the Reactor Oversight Process baseline Inspection Procedure, IP-Page 14 of 20
Palo Verde Comments DRAFT REGULATORY GUIDE DG-1248 Item Reference DG-1248 Original Text Comment Proposed Revision to DG-1248 71111.11, "Licensed Operator Requalification Program."
15 Page 9, 5 th 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 ANSFANS-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 compliance with the facility scope and fidelity Commission's simulation Item 2 does not meet the intent requirements, (2) simulation facility facility scope and fidelity of DG 1248, whereas the other licensees to voluntarily move to a requirements, (2) simulation three items do; delete item 2. &* facility licensees to .on.ensus standard and carry out its voluntarily move to a single -equiremeits-(3) the NRC to consensus standard and communicate its expectations, and carry out its requirements, (4) facilitation of a common approach (3) the NRC to and methodology for conducting and communicate its documenting simulator expectations, and scenario-based performance testing.
(4) facilitation of a common approach and methodology for conducting and documenting simulator scenario-based performance testing.
16 Page 10, 1"t 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 Page 15 of 20
Palo Verde Comments DRAFT REGULATORY GUIDE DG-1248 Item Reference DG-1248 Original Text Comment Proposed Revision to DG-1248 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 maintained in accordance with the applicant experience industry's most recent requirements are maintained consensus standard-whih-will in accordance with the preclude .egativetraining-anA industry's most recent inppro.priate operator-liense.
consensus standard, which evaluations.
will preclude negative Simulation facilities that meet the training and inappropriate minimum scope and fidelity operator license evaluations, requirements of ANSIANS-3.5-2009 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.
17 Page 10, 2 nd 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 Page 16 of 20
Palo Verde Comments DRAFT REGULATORY GUIDE DG-1248 Item I Reference DG-1248 Original Text Comment Proposed Revision to DG-1248 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 NRC staff and facility Where is human resource licensees burdens reduced? Transition would be the benefits from 1998 to 2009 requires associated with enhanced additional burden for SBT efficiency and effectiveness documentation, core in using a common performance testing, and post guidance event simulator testing.
document as the technical basis for demonstrating The WESTRAIN Simulator compliance with the Subcommittee agrees that there Commission's simulation was some burden removed facility during transition from the ANS-scope and fidelity 3.5-1985 Standard to the ANS-requirements, as described 3.5-1998 Standard.
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 Page 17 of 20
Palo Verde Comments DRAFT REGULATORY GUIDE DG-1248 Item I Reference DG-1248 Original Text Comment Proposed Revision to DG-1248 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 performance testing time savings are anticipated as a result of moving to one standard, which the proposed guide is advocating).
18 Page 11 under; N/A Add definitions for: (1) N/A "Glossary" replicate, (2) significant deviation, (3) compare favorably, (4) procedural exception.
19 Appendix B, Item 2 N/A Please clarify; dos "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?
20 Appendix B, Item 10 SBT conducted in a manner Reference to ANS-3.5-2009 is SBT conducted in a manner sufficient sufficient (i.e., meets redundant in this proposed (i.e., ects r-equir-ement. o requirements of revision 4 to Regulatory Guide ANSLNS 3-.5 2009) to ensure that ANSI/ANS-3.5-2009) to 1.149. simulator fidelity has been Page 18 of 20
Palo Verde Comments DRAFT REGULATORY GUIDE DG-1248 Item IReference DG-1248 Original Text Comment Proposed Revision to DG-1248 ensure that simulator demonstrated and met for this fidelity has been Delete reference to ANSI/ANS- scenario. Note: Attach relevant "as-demonstrated and met 3.5-2009. run " marked-up plant proceduresand for this scenario. Note. or procedureportions/pagesutilized Attach relevant "as-run" to support assertion.
marked-up plantprocedures and or procedureportions/pages utilized to support assertion.
21 -Appendix B, Item 11 Modeling and hardware Regarding the sentence; Modeling and hardware discrepancies 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 eateFed-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"... Discrepanciesthat directly affect Note: Discrepanciesthat operatorresponse (or directly affect operator The term "and entered" is action) or expectedplant response response (or redundant to "documented" in must be resolved before the SBT test action) or expectedplant 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.
22 Appendix B, Page The draft regulatoryguide In regards to the italicized note N/A B-1 includes this appendix so at the bottom of Page B-1...
that the public can discern the staff's acceptance and The WESTRAIN Simulator endorsement of the Subcommittee recommends that Page 19 of 20
Palo Verde Comments DRAFT REGULATORY GUIDE DG-1248 Item I Reference DG-1248 Original Text Comment Proposed Revision to DG-1248 Nuclear Energy Institute's this appendix not be included in (NEI) 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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