ML17332A921

Comment Supporting Draft Rg DG-1043, Nuclear Power Plant Simulation Facilities for Use in Operator License Exam.

ML17332A921
Person / Time
Site:	Cook
Issue date:	08/14/1995
From:	Fitzpatrick E INDIANA MICHIGAN POWER CO. (FORMERLY INDIANA & MICHIG
To:	NRC OFFICE OF ADMINISTRATION (ADM)
References
FRN-60FR36833, RTR-REGGD-01.149, RTR-REGGD-1.149, TASK-*****, TASK-RE 60FR36833-00003, 60FR36833-3, AEP:NRC:0508AN, AEP:NRC:508AN, NUDOCS 9509190062
Download: ML17332A921 (4)

Text

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ACCESSION NBR:9509190062 DOC.DATE: 95/08/14 NOTARIZED: NO DOCKET N-FACI6:50-315 Donald C. Cook Nuclear Power Plant, Unit 1, Indiana M 05000315 50-316 Donald C. Cook Nuclear Power Plant, Unit 2, Indiana M 05000316 AUTH. NAME AUTHOR AFFILIATION FITZPATRICK,E. Indiana Michigan Power Co. (formerly Indiana 6 Michigan Ele RECIP.NAME RECIPIENT AFFILIATION Division oG Freedom of information & Publications Services

SUBJECT:

Comment supporting draft RG DG-1043, "Nuclear Power Plant Simulation Facilities for Use in Operator License Exam."

DISTRIBUTION CODE: DS09D COPIES RECEIVED:LTR I ENCL 0 SIZE:

TITLE: SECY/DSB Dist: Public Comment on Proposed Rule (PR)-Misc Notice;Reg G NOTES:

RECIPIENT COPIES RECIPIENT COPIES ID CODE/NAME LTTR ENCL ID CODE/NAME LTTR ENCL INTERNAL: NMSS/IMOB T8F5 OGC/DR 15-B-18 RES DIR RES/DRA/DEPY RES/DSIR EXTERNAL: NRC PDR YOTE TO ALL"RIDS" RECIPIEi"4TS:

PLEASE HELP US TO REDUCE iVASTE! COYTACTTHE DOCL'Ii fEYTCOYTROL DESK, ROOM Pl.37 (EXT. 504-20S3 ) TO ELIMIYATEYOUR YAibfE FROif DIS I'RIBL"I'IOY.LISTS FOR DOCU!ifEYTS YOU DO'8 "I'EED!

TOTAL NUMBER OF COPIES REQUIRED: LTTR 7 ENCL

Indiana MicMgan Power Company

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USNRC August 14, 1995 AEP'NRC'0508AN Docket Nos.: 50-315 50-316 Rules Review and Directives Branch, DFIPS Office of Administration U.S. Nuclear Regulatory Commission Washington, DC 20555 Gentlemen:

Donald C. Cook Nuclear Plant Units 1 and 2 COMMENTS ON DRAFT REGULATORY GUIDE DG-1043 NUCLEAR POWER PLANT SIMULATION FACILITIES FOR USE IN OPERATOR LICENSE EXAMINATIONS We appreciate the opportunity to comment on the subject draft regulatory guide DG-1043. We believe paragraphs 1.4 and 1.6 of the Re ulato Position could be clarified. Following are excerpts from 1.4 and 1.6 with our comments.

Paragraph 1.4

'..Overrides, as defined, should be considered to be features that affect input/output (I/O) devices at the man-machine interface, such as panel instrumentation and controls. Other simulator f ea tures that might be referred to as overrides in their documentation and instructor station presentation, but which affect or al ter the normal operation of simulated instrumentation or components wi thin the model, should be considered to be malfuncti ons for the purposes of validation and periodic performance testing....'he Donald C. Cook Nuclear Plant simulator has in excess of 600

" remote functions'o support performing local actions external to the control room in accordance with paragraph 3.3.4 " Instructor Interface'f the ANSI standard. These remote functions are used as delineated in the referenced ANSI paragraph as well as for initial condition setup (condenser tube plugging, steam generator tube plugging, control air leakage, aux steam leakage, etc.). These remote functions are not manipulated except as directed by t'e, control room operator or in initial condition setup.

9509190062 950814 PDR RECQD l Oi. i49 C PDR ~i-

U. S. Nuclear Regulatory Commission AEP:NRC:0508AN Page 2 It is our position that although these remote functions '..affect or al ter the normal operation of simulated instrumentation or components in the model...'he use of these remote functions is not as malfunctions and therefore these functions are not considered to be malfunctions for the purposes of validation and periodic performance testing.

We request that paragraph 1.4 be changed to clarify this position.

Paragraph 1.6

'...The simulator' performance of other malfunctions, component failures, and component overrides, if applicable to the facility by incorporation in the planned training and examination scenarios and exercises, should also be tested at least once every four years, approximately 258 per year....'he Donald C. Cook Nuclear Plant simulator has component failures termed 'lobal Malfunctions.'hese failures apply to every air operated valve, motor operated valve, 600 VAC breaker, and 4KV breaker that can be manipulated from the control room. These failures meet the criteria set in paragraph 1.4 to be classified as malfunctions. These failures also, provide the same indications as some local operator actions and are used in that capacity. An example is that a failure of a 600 VAC motor operated valve thermal overload provides the same indications and response as if the auxiliary operator opened the supply breaker to that component.

It is our position that if, in the training environment, a 'Global Malfunction's used only for local operator action, then it does not fall under the testing criteria of paragraph 1.6. Additionally it is our position that Malfunctions'rior if a process is in place that tests these

'Global to use in training via validation du'ring pre-runs, then the '..at least once every four years, approximately 258 per year... does not apply. This process meets the intent to verify performance prior to observation by the operator.

We request that paragraph 1.6 be changed to clarify this position.

Sincerely, E. E. Fitzpatric Vice President pit

U. S. Nuclear Regulatory Commission AEP:NRC:0508AN Page 3 CC: A. A. Blind G. Charnoff H. J. Miller NFEM Section Chief NRC Resident Inspector - Bridgman J. R. Padgett