ML102720830

Comment (13) of Warren Potter on Behalf of Arizona Public Service Company on Draft Guide 1248

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:

Attachments:

Importance:

FW: Palo Verde DG-1248 Comments Palo Verde Comments to NRC DG1248.pdf 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

-~"

Palo Verde Comments DRAFT REGULATORY GUIDE DG-1248 Item Reference DG-1248 Original Text Comment Proposed Revision to DG-1248 I

Page 3, 2nd N/A The commission should state Add to the 2nd 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 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.

55.3 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, 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, "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,"

of ANSI/ANS-3.5-2009.

NEI-09-09, Revision 1, also supports Section 4.4.3.2, "Simulator Scenario-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 regard to Seetion 3. 1 A-,

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 ANSI!ANS-3.5-2009" demonstrate that they have conducted performance testing of the malfunctions listed in the standard, as applicable to the design of the reference plant, at least once in the life of the simulation facility and that the associated test documentation includes the completed test results. If performance testing of a malfunction has been completed more than once, then the licensee need only retain the latest test results.

The staff recognizes that simulator malfunction test results may be retained longer than 4 years after the completion of each malfunction test. Therefore, regardless of how long it has been since the malfunction test has been performed, the NRC expects simulation facility licensees to make the results of these malfunction the records retention requirement in 10CFR55.46(d)(1) which states that "The results of performance tests must be retained for four years after the completion of each performance test or until superseded by updated test results."

The CFR reference allows malfunction tests to be discarded after four years. There is no requirement to maintain performance tests records longer than four years.

they1 have conducted per-formance testing of the malfuncetionis listed in the standard, as applicable to the design of the r-efer-encse plant, at least once in the life of the simulation facility and that the associated test docuentaion 111incld the completed test r-esults. if per-for-mance testing of a completed more than once, then the licensee need only retain the latest test results. The staff r-ecognize that simul1ator malfuncation test results may be retained longer-than 4 year-s after-the completion of eac malfunction te&A. Ther-efirec, sic the mnalfuntioein test has been-per-formed, the NRC expet simulation facility licsensees to make the r-esults of these malfunction performance tests available for-NRC review, either-before, or! cencsufent with, the pr-epar-ation for-ec operating test or-r-egualification progra inpection.

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 simulator to utilize models relating to nuclear and thermal-hydraulic characteristics that replicate a core load in the nuclear

,power reference plant. If the plant-referenced simulator is used to meet NRC applicant 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.

that would require an eight hour run time (such as a peak xenon test). Simulation facilities appreciate the use of the fast time simulation feature to conduct tests that would require an extensive amount of run time in an age where simulator utilization by the operations training 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.

and thermal-hydraulic characteristics that replicate a core load in the nuclear power reference plant. If the plant-referenced simulator is used to meet NRC applicant experience requirements, as described in 10 CFR 55.3 1(a)(5), then the most recent core load (e.g., the core load(s) that existed

• during the time of the NRC applicant's initial training program) the curet refer-ence plant eor-e load, cr if the r-efer-ence plant is in a-refulingoutge, the cor-e load just previous to the outage) in the nuclear power reference plant for which a license is being sought must be utilized.

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 ANSI 3.5,,2009 section 3.4.3.3 Simulator reactor core performance testing requires that "Simulator reactor core 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 Simulator reactor core performance testing requires that "Testing shall be performed in accordance with the reference unit procedures and shall be compared and demonstrated to replicate Issue/Concern; Reactor Core Testing in the plant is very limited depending on whether initial criticality is attained as expected. Additionally, reactor engineering utilizes a reactivity meter to measure reactivity changes. This requirement in the ANSI standard reduces the quality of reactor core testing currently being implemented by most facilities. A reactivity meter does not exist in the simulator modeling which means it is not within the scope of simulation (section 3.4.3.3) and therefore prevents the ability to utilize the reference plants procedures for core testing. These two sections seem to contradict each other when Recommendation for DRAFT REGULATORY GUIDE DG-1248 In regard to 2g, add a statement at the end that says; 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 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.

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

.ithin 60.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 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 designed to respond, so that significant control manipulations are completed without the ANS-3.5 Standard.

Delete third sentence in its entirety. The NEI 09-09 document does not, by itself, satisfy the 10CFR55.46 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.

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 I xxl.JIJIth Ll.1 J..."'

txtv, VVhxit~fl +/-LVI VJ, 09, Revision 0, suppored),

Implementation of NEI 09 09 Revision 1, ensures that Simuilat1 facility licensees will demonstrate cxpeetcd plant response to operater input and to normal, tr-ansient, and accident eonditions to whieh the simulator-has been designed to respond, so that significant conto manipulation aecmlted without procedural exceptions, simulatoe performance eirceptions, or: deviation fr-om the approved tr-aining cnai seeqenee.

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 date

.f 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 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 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-Producing malfunction test documentation to satisfy Section 2.b will be a significant burden and cost if the licensee will be required to conduct old malfunction tests.

Also, additional documentation associated with NE10909 is considered excessive and an unnecessary burden.

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, 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 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

.egative training-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, 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 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 and providing comments to the NRC during the public comment period. The impact to facility licensees would be the cost of implementing the new standard. The value to the 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 above).

The WESTRAIN Simulator Subcommittee agrees that "significant human resource burdens... are anticipated as a result of moving to one standard."

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 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 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.

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"...

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.

22 Appendix B, Page The draft regulatory guide 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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