ML18065A663
| ML18065A663 | |
| Person / Time | |
|---|---|
| Site: | Palisades  |
| Issue date: | 04/22/1996 |
| From: | Richards S NRC (Affiliation Not Assigned) |
| To: | Vincent R CONSUMERS ENERGY CO. (FORMERLY CONSUMERS POWER CO.) |
| References | |
| RTR-REGGD-01.149, RTR-REGGD-1.149, TASK-*****, TASK-RE NUDOCS 9604250345 | |
| Download: ML18065A663 (4) | |
Text
UNITED STATES NUCLEAR REGULATORY COMMISSION WASHINGTON, D.C. 20555-0001 April 22, 1996 Mr. Robert A. Vincent, Licensing Administrator Palisades Nuclear Plant 27780 Blue Star Memorial Highway Covert, MI 49043
Dear Mr. Vincent:
Thank you for the response to 60 Federal Register 36833 regarding request for comments to Draft Guide-1043 that you provided in your letter dated September 13, 1995.
Consumers Power comments have been considered in full and were very helpful in developing Regulatory Guide 1.149, Revision 2, "Nuclear Power Plant Simulation Facilities for use in Operator License Examinations."
In part, Consumers Power comments reflected those of the industry in general and were discussed in detail with representatives from the Nuclear Energy Institute (NEI}, the Utility Simulator Users Group (USUG}, the ANSI/ANS 3.5 Writing Committee, and other interested parties at a public meeting at NRC Headquarters in Rockville, MD on November 15, 1995.
Those discussions served as the basis for development of this important performance-based regulatory guidance that will serve the goals of both the industry and the Commission.
Other Consumers Power comments were considered to be program-specific or unique to administration of the simulation facility* at the Palisades Nuclear Plant. This letter addresses program-specific Consumers Power comments with respect to the final Regulatory Guide 1.149, Revision 2.
In adopting the 1993 revision of the Standard, consideration should be given to the use of a simulator capability when determining testing requirements.
In general, a simulator capability should be validated at least once, usually as part of initial system or simulator acceptance testing.
The alarm flags on indicators function as remote functions and should be considered to be a function of the software design for the associated system, even though it is recognized that they "affect or alter the normal operation of simulated instrumentation or components in the model."
To the extent that the alarm flag overrides are used in a malfunction capacity to cause, prompt; or elicit operator response or to enable a larger scenario, the capabilities should be considered to be "integral to the facility's training and examination scenarios and exercises" for the purpose of periodic validation and operability testing.
Consumers Power expressed concern that adoption of ANSI/ANS-1993 should not require a separate and redundant submittal of a change in performance test plans with associated NRC Form 474, t~st ab~tracts, test plan, and schedule.
The ~est schedule is -e~pected to be dynamic, even if no significant programmatic changes occur.
The guidance that was provided in NUREG-1262, 240019 r~~~~~~~~~0~4~2~2:----r~~~~l I
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- "Answers to Questions at Public Meetings Regarding Implementation of Title 10, Code of Federal Regulations, Part 55 on Operators' Licenses," still applies.
A similar question, number 229, was raised at that time (1987).
The response stated in part that "... If your schedule for performance testing changes between the time you submit a certification and any subsequent four year report, you should ad~ise us of that change on the Form 474."
Sincerely, Stuart A. Richards, Chief Operator Licensing Branch Division of Reactor Controls and Human Factors Office of Nuclear Reactor Regulatton
DISTRIBUTION:.
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DOCUMENT NAME:. G:\\COLLINS\\REPLY.CPR To receive a copy of this documen_t. lndlcat n the box: "C" = Copy without attachment/enclosure*
OFFI~E' HOLB:DRCH NAME.
FCo ll ins*: r DATE 02/-15/96
. ECORD COPY
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'- "Answers to Questions at Public Meetings Regarding Implementation of Title 10, Code of Federal ijegulations, Part 55 on Operators' Licenses," still applies.
A similar question, number 229, was raised at that time (1987).
The response stated in part that "... If your schedule for performance testing changes between the time you submit a certification and any subsequent four year report,,you should advise us of that change on the Form 474."
DISTRIBUTION:
Central Files HOLB R/F PUBLIC Sincerely, Original signed by:
Stuart A. Richards, Chief Operator Licensing Branch Division of Reactor Controls and Human Factors Office of Nuclear Reactor Reguiation DOCUMENT NAME:
G:\\COLLINS\\REPLY.CPR To receive a copy of thl* document. lndlcat n the box: "C" = Copy without attachment/enclosure "E" = Copy with attachment/enclosure "N" = No copy OFFICE HOLB:DRCH NAME FColl ins:r DATE 02/15/96