ML110420133

Regulatory Analysis, Revision 4 of Regulatory Guide 1.149, Nuclear Power Plant Simulation Facilities for Use in Operator Training, License Examinations, and Applicant Experience Requirements

ML110420133
Person / Time
Issue date:	04/30/2011
From:	Office of Nuclear Reactor Regulation
To:
Carpenter R, RES/DE,301-251-7483
Shared Package
ML110420056	List: ML110420133
References
DG-1248 RG-1.149, Rev 4
Download: ML110420133 (3)

Text

REGULATORY ANALYSIS REVISION 4 OF REGULATORY GUIDE 1.149, NUCLEAR POWER PLANT SIMULATION FACILITIES FOR USE IN OPERATOR TRAINING, LICENSE EXAMINATIONS, AND APPLICANT EXPERIENCE REQUIREMENTS.

Statement of the Problem On September 4, 2009, ANSI approved ANSI/ANS-3.5-2009 as the new industry consensus American National Standard. Initially approved in 1979, the 2009 version marks the sixth issuance of the standard. The ANS-3.5 Working Group of the Standards Committee of the ANS developed and prepared the new standard.

Facility licensees that maintain a simulation facility consisting solely of a plant-referenced simulator currently adhere to and use one of three historical versions of ANSI/ANS-3.5:

(1) ANSI/ANS-3.5-1985, (2) ANSI/ANS-3.5-1993, or (3) ANSI/ANS-3.5-1998. Based on recent industry feedback and work with industry representatives through the NEI LOFG, the NRC believes that the use of a single updated standard will greatly enhance facility licensees approach to and standardization of simulator performance testing requirements, as well as the NRCs ability to uniformly inspect for and determine compliance with its plant-referenced simulator fidelity regulations. The staff believes that simulation facility licensees can transition to ANSI/ANS-3.5-2009 with little or no impact to their simulator performance testing programs.

The NRC has revised Regulatory Guide 1.149, originally issued April 1981, three times (April 1987, April 1996, and October 2001) to endorse successive revisions of ANSI/ANS-3.5. The staff specified exceptions to previous standards in the area of performance testing in the initial issuance through Revision 3 to ensure that application of previous standards would support the requirements of the regulations and be responsive to the NRCs concern that simulator fidelity be demonstrated and met, maintained, and assured on a continuing basis.

As a result of regulatory experience gained from oversight and inspection of simulation facilities, as well as feedback from industry stakeholders, the NRC is revising Regulatory Guide 1.149 to update and clarify its position regarding methods acceptable to the staff for complying with those portions of the NRCs regulations associated with approval or acceptance of a simulation facility for use in operator and senior operator training (initial and requalification), for use in NRC license examinations (operating tests), and for use in meeting applicant experience requirements (for performing control manipulations that affect reactivity) to establish eligibility for an operators license.

Revision of Regulatory Guide 1.149 is necessary for (1) the NRC to endorse the use of ANSI/ANS-3.5-2009 as a technical standard to ensure compliance with the Commissions simulation facility scope and fidelity requirements, (2) simulation facility licensees to voluntarily move to a single consensus standard and carry out its requirements, (3) the NRC to communicate its expectations, and (4) facilitation of a common approach and methodology for conducting and documenting simulator scenario-based performance testing.

Objective The objective of this regulatory action is to update and clarify a number of regulatory issues important to the NRC staff and simulation facility licensees as stakeholders for which the current revision (i.e., Revision 3) of Regulatory Guide 1.149 does not provide sufficient guidance.

Alternative Approaches The NRC staff considered the following alternative approaches:

Do not revise Regulatory Guide 1.149.

Revise and update Regulatory Guide 1.149.

Alternative 1: Do Not Revise Regulatory Guide 1.149 Under this alternative, the NRC would not revise this guidance, and the current guidance would be retained. If NRC does not take action, there would not be any changes in costs or benefit to the public, licensees, or the NRC. However, the no-action alternative would not address identified concerns with the current version of the guide. The NRC would continue to review each simulation facility on a case-by-case basis. This alternative provides a baseline condition from which any other alternatives will be assessed.

Alternative 2: Revise and Update Regulatory Guide 1.149 Under this alternative, the NRC would revise Regulatory Guide 1.149, taking into consideration the extensive regulatory experience gained since last revision of Regulatory Guide 1.149 in October 2001.

The benefit of updating and revising Regulatory Guide 1.149 is that it would provide guidance to ensure that nuclear power plant simulation facilities used for operator training, license examinations, and applicant experience requirements are maintained in accordance with the industrys most recent consensus standard, which will preclude negative training and inappropriate operator license evaluations.

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

The impact to the NRC would be the costs associated with preparing and issuing the revised regulatory guide. The impact to the public would be the voluntary costs 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 Commissions 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 performance testing time savings are anticipated as a result of moving to one standard, which the proposed guide is advocating).

Conclusion Based on this regulatory analysis, the staff recommends revision of Regulatory Guide 1.149. The staff concludes that the proposed action will reduce unnecessary burden on both the NRC and its licensees and will result in an improved and more uniform process for simulation facility licensees to demonstrate Page 2

compliance with the Commissions plant-referenced simulator regulations. Moreover, the staff sees no adverse effects associated with issuing this regulatory guide.

Page 3