ML18153B936
| ML18153B936 | |
| Person / Time | |
|---|---|
| Site: | Surry  |
| Issue date: | 10/16/1989 |
| From: | Stewart W VIRGINIA POWER (VIRGINIA ELECTRIC & POWER CO.) |
| To: | NRC OFFICE OF INFORMATION RESOURCES MANAGEMENT (IRM) |
| References | |
| 89-639, NUDOCS 8910230140 | |
| Download: ML18153B936 (13) | |
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VIRGINIA ELECTRIC AND POWER COMPANY RICHMOND, VIRGINIA 23261 October 16, 1989 United States Nuclear Regulatory Commission Attention: Document Control Desk Washington, D. C. 20555 Gentlemen:
VIRGINIA ELECTRIC AND POWER COMPANY SURRY POWER STATION UNITS 1 AND 2 REQUEST FOR ADDITIONAL INFORMATION SIMULATOR CERTIFICATION Serial No.
NO/ETS Docket Nos.
License Nos.89-639 50-280 50-281 DPR-32 DPR-37 On November 23, 1988, Virginia Electric and Power Company submitted the Surry* / "/)
Simulator Certification Package for your review.
In your letter of August 23, 1989,, )
additional information was requested to complete your review. Attachment 1 to this letter provides the requested information.
If you have further questions or require additional information, please call.
Very truly yours, Jl~
W. L. Stewart Senior Vice President - Power Attachment cc:
U. S. Nuclear Regulatory Commission Region II 101 Marietta Street, N. W.
Suite 2900 Atlanta, Georgia 30323 Mr. W. E. Holland NRC Senior Resident Inspector Surry Power Station
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ATTACHMENT 1 SURRY UNITS 1 AND 2 SIMULATOR CERTIFICATION
VIRGINIA ELECTRIC AND POWER COMPANY SURRY UNITS 1 AND 2 SIMULATOR CERTIFICATION RESPONSES TO QUESTIONS IN NRC LETTER OF AUGUST 23, 1989 The following responses are provided to your request for further clarification of data provided in the Surry Simulator Certification Document.
Question 1 All of the fuel exposures indicated in Appendix 3 of, "Initial Conditions" appear to be the same.
ANSI/ANS-3. 5-1985 requires that initial conditions include various times in core life.
Please confirm that the "Core Aging" function is the means by which you satisfy this criteria or provide justification for exception.
Answer 1 The "Core Aging" function is the means by which initial conditions are created for various times in core life.
e Question 2 The "Steady-State Stability" test at 100 percent power described on page 17 of Attachment 3 appears to be the only test performed for steady-state operation.
ANSI/ANS-3. 5-1985, Section 4.1, specifies the performance criteria for steady-state operation and requires that comparisons be made for "interim power levels for" which valid reference plant information is available" and that "During testing, the accuracy of computed values shall be determined for a
minimum of three points over the power range."
Please provide performance test abstracts for the tests required by ANSI/ANS-3.5-1985, Section 4.1, or provide justification for exception to these requirements.
Answer 2 The 100 percent power test described on page 17 of is correct.
However, our interpretation of this requirement is specifically related to the performance of calorimetrics during load increases via normal station operating procedures.
The Surry station operating procedures require several hold points to verify nuclear power distribution and stability.
A calorimetric is only performed at 100% reactor power.
Since our tests are based on accepted station procedures, it was determined unnecessary to specifically state this as an exception.
Because of the various hold points to verify core stability and flux distribution, the intent of Section 4.1 has been met during Plant Startup from Hot Shutdown to Full Power which was reported on page 25 of Attachment 3.
During the performance of the latter test, the calorimetric was performed in accordance with and via station operating procedures.
The abstract on page 17 needs the following added after the last statement.
"The accuracy of computed values over a minimum of three points over the power range was satisfied via the test performed on page 25 of."
Question 3 The tests described in Attachment 3 do not appear to include tests for ANSI/ANS-3. 5-1985, Section 3.1. 1 "Normal Plant Evolutions," items:
"(7) Startup, shutdown and power operations with less than full reactor coolant flow;" and 11 ( 9) Core performance testing such as plant heat balance, determination of shutdown margin, and measurement of reactivity coefficients and control rod worth using permanently installed instrumentation."
Please provide performance test abstracts for these tests or provide justification for exception to performance of these tests.
Answer 3(7)
Tests performed under "Normal Plant Evolutions" were conducted as indicated in the abstracts.
Tests were performed under the same limitations the station operates under.
Power operations with less than full reactor coolant flow is precluded by Surry Technical Specifications, therefore this particular test was considered inappropriate.
Answer 3(9)
Core performance testing with permanently installed instrumentation is limited to heat balance, shutdown margin, and ECP calculations.
A deficiency regarding the core being out of date had been previously identified.
A complete core cycle update and enhancement was completed on 04/28/89.
Permanently installed instrumentation does not support measurements of reactivity coefficients and rod worths.
It should be noted that the ECP and shutdown margin calculations were performed as required by station procedures during the course of integrated operations testing.
Consequently, the need to specifically state their performance was not considered necessary.
The following statement needs to be added after the last statement of paragraph 2 of the abstract on page 25 of Attachment 3, "ECP calculations were performed in accordance with station procedures. 11 A subcri ti cal multiplication ratio plot was performed to verify the ECP."
Add the following statement after the last statement of the abstract on page 25 of Attachment 3, "Heat balance was performed in accordance with station procedures.
Difficulties with the plant computer were reidentified.
The plant computer model upgrade was completed on 07/10/89."
Question 4 The results of the test for "Plant cooldown From Intermediate Shutdown To Cold Shutdown" indicate that the mass balance in the feedwater system may be flawed.
This was also indicated in the examination report from operating tests given on October 25-27, 1988, in item 8 of Enclosure 4,
"Simulation Facility Fidelity Report."
- However, in, "Simulator Upgrade Schedule," the feedwater system is not included.
Please confirm that the feedwater system is adequately. modeled to meet the requirements of Section 4.2, "Transient Operation," of ANSI/ANS-3.5-1985 or provide justification for exception.
Answer 4 The discrepancy #8809221130 identified in the abstract was resolved on 05/09/89.
The Feedwater system upgrade was originally completed in 1987.
Due to the need for operation of the feedwater system for longer periods of time, under different conditions and based upon attempts to solve the "mass balance" problem, it was determined early in 1989 that a complete rewrite of the feedwater system software was required even though the mass balance problem was resolved as indicated.
The Feedwater system software rewrite was completed on 06/29/89.
Consequently, at the time of submittal the Feedwater system upgrade had been completed.
During the resolution of the discrepancy, other problems were discovered such that a complete revision of the feedwater system was undertaken to reflect the new simulator operational criteria.
The feedwater system at this time is adequately modeled to meet the requirements of Section 4. 2, "Transient Operation," of ANSI/ANS-3.5-1985.
Question 5 The results of the test in Attachment 3 for "Plant Startup From Hot Shutdown To Full Power Conditions" and Simulator Modification Reports (SMRs) 8612031600
- and 8702121257 on page 19 of Attachment 8 indicate deficiencies with the core model which were to be corrected by December 1988.
The "Simulation Facility Fidelity Report" from the operating tests given on October 25-27, 1988,
- also described a core modeling problem in Item 10 with respect to rod worth.
Please confirm that the core is adequately modeled to meet the requirements of Section 4. 2, "Transient Operation," of ANSI/ANS-3.5-1985 or provide justification for exception.
Answer 5 Simulator Modification Reports 8612031600 and 8702121257 were closed on 04/28/89 upon completion of the reactor core upgrade to the latest cycle.
The core is adequately modeled to meet the requirements of Section 4.2, "Transient Operation," of ANSI/ANS-3.5-1985.
Question 6 The results of the "Surveillance Tests" on page 87 of state that the plant computer was not able "to support all of the necessary aspects of the tests.",
on page 13, under "Plant Computer P-250 Operator Station" states that "The reference plant computer station is fully simulated with the exceptions of some tasks that are beyond the scope of simulation."
Also item 1 of the aforementioned "Simulation Facility Fidelity Report" s t a t e s
" The P-2 5 0 CRT s c re en w a s not r e 1 i ab 1 e i s consistently providing status information."
Please confirm that, with the upgrade which was scheduled to be complete by February 28, 1989, the plant computer meets the requirements of ANSI/ANS-3.5-1985, Section 3.2.2 or provide justification for exception.
Answer 6 The plant computer interface hardware and other components or displays that would function during normal, abnormal and emergency evolutions are included in the simulator.
The original scope of simulation only modeled those features the operator uses in
- the course of performing assigned tasks, therefore, some engineering tasks were not included.
As the simulator has been modified, additional modifications have been identified to make the plant computer more useful to the operations staff during simulator sessions.
The P-250 CRT screen display problem was resolved by the completion of the Plant computer upgrade on 07/10/89.
The plant computer meets the requirements of ANSI/ANS-3.5-1985, Section 3.2.2.
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Question 7 Attachment 4,
the "Simulator Performance Test Schedule,"
states "The Transient Performance. Tests of ANS-3. 5-1985 Appendix B,
Section B.2.2 will be conducted annually.
ANSI/ANS-3.5-1985, Appendix B, Section B.2.1, "Steady State Performance" tests are also required annually.
Please confirm your intent to perform steady-state tests as well as transient tests or provide justification for exception.
Answer 7 "Steady State Performance" tests will be performed annually.
The "Simulator Test Schedule" in Attachment 4 needs to have the following statement added for each year under the "Integrated Tests" heading: "Steady State Performance test."
Question 8 In Attachment 5 on page 8 regarding "Photo #19" it is noted that a sound-powered phone jack is missing.
In Attachment 6 on page 13 it is noted that some of *the communications systems at the Shift Supervisor's Console are not operational.
SMR 8511050901 on page 9 of Attachment 8 and SMR 84002 on page 12 of Attachment 8 also describe communications systems deficiencies.
ANSI/ANS-3.5-1985, Section 3.2.3, "Control Room Environment" requires that "Communication systems that a control room operator would use to communicate with an auxiliary operator or other support activities shall be operational to the extent that the simulator instructor, when performing these remote activities, shall be able to communicate over the appropriate communication system."
Please confirm that the simulator meets this requirement or provide justification for exception.
Answer 8 Attachments 5, 6, and 8 were intended to document identified discrepancies between the station and simulator control panels/environment for resolution either immediately or after the suitable evaluations have been performed.
In some cases the disc~epancy has been identified to have no action required.
- However, the discrepancies are periodically reviewed to assess implementation due to changing training requirements, changing NRC requirements and economic competition for valuable utility funds" Specifically, the sound powered phone system in question is used solely by Instrument and Control personnel during instrumentation calibration.
Operations personnel rarely use the system, except during refueling, which we are not required to model per ANSI/ANS-3.5-1985 Section 3.1.1 item
( 1 ).
The radio system and the complete AT&T telephone system is not fully operable.
The upgrade of the radio and telephone system is currently under review for upgrade.
When the review has been completed, appropriate action will be taken commensurate with the results of the review.
- However, other normally available communications systems, such as the intercom system is operable.
The *ability to use the current' general telephone system to contact the instructor's booth to simulate communications with various station personnel is available.
Offsi te communications via the NRC ring down system and other offsi te agencies is provided consistent with the system installed in the station.
Therefore, the simulator does meet the requirement to allow adequate communications to perform remote activities.
e Question 9 In Attachment 5, "Physical Fidelity Report," there are 52 pages of physical fidelity discrepancies encompassing over 400 separate items.
Over 90 percent of these items were scheduled to be corrected by December 1988.
SMR 8810031212 and SMR 8810042145 on pages 14 and 15, respectively, of also relate to physical fidelity discrepancies.
Please confirm that the simulator meets the requirements of ANSI/ANS-3.5-1985, Section 3.2.1, "Degree of Panel Simulation" and Section 3.2.2, "Controls on Panels" or provide justification for exception to these requirements.
Answer 9 Attachments 5 and 8 were intended to document identified discrepancies between the station and simulator control panels/environment for resolution either immediately or after the suitable evaluations have been performed.
In some cases the discrepancy has been identified to have no action required.
- However, the discrepancies are periodically reviewed to assess implementation due to changing training requirements, changing NRC requirements and economic competition for valuable utility funds.
The two SMRs, 8810031212 and 8810042145, were included in, because they provide the mechanisms.to perform the task of completing physical fidelity comparison *and resolution and revising simulator panel drawings upon completion of the upgrade project.
While the physical fidelity report is extensive, it is anticipated that both the number and significance of the physical fidelity discrepancies will decrease.
Consequently, the simulator meets the requirements of ANSI/ANS-3.5-1985, Section 3.2.1, "Degree of Panel Simulation" and Section 3.2.2, "Controls on Panels."
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Question 10 In Attachment 8, "Discrepancy Backlog/and Resolution Schedule," of the 160 SMRs, many appear to be more than five years old according to their SMR numbers.
Attachment 9, "Configuration Management Overview Document," does not describe any resolution time for evaluating and incorporating SMRs.
Please confirm that your configuration management program meets the requirements of ANSI/ANS-3.5-1985, Section 5.2, "Simulator Update Design Data" or provide justification for exception to these requirements.
Answer 10 Due to the systematic upgrade currently in progress, it is quite possible for discrepancies more than 5 years old to remain open until a particular upgrade has been completed.
In other cases, the SMR number, i.e., 76002 remains open due to the source document such as a design change remaining open.
Prior to the current SMR numbering system being implemented, the use of a coherent discrepancy numbering system was not uniformly applied.
Consequently, during a previous review process, a design change carrying an issue date df 76-001 for instance may have had an SMR issued using the design change number even though the actual SMR may have been issued in 1985.
Attachment 9
was not intended to provide specific discrepancy management information, but rather a broad based review of Virginia Power's Simulator Configuration Management Program.
Initial classification of priority and scheduled completion is made in accordance with the following criteria:
Priority 1 -
High impact on training.
Conduct simulator training session cannot be performed or be severely limited without corrective action month).
of a will (i 1 Priority 2 -
Moderate impact on training.
Conduct of a simulator training session can be performed, but causes the instructor difficulty in achieving session objectives (i 3 months).
Priority 3 -
Low impact on training.
Conduct of a simulator training session can be performed but corrective action needed to increase session efficiency and effectiveness(~ 3 months).
- However, as instructor situational needs and actual required to resolve a particular discrepancy dictate, will be rescheduled and reprioritized as appropriate.
time SMRs
r Question 11 For Unit 2, NRC Form 474 did not have the box for exceptions checked, however Attachments 1 and 2 describe differences between Unit 2 and the simulator.
Please confirm that, for Unit 2, the Unit 1 simulator meets the guidance contained in ANSI/ANS-3.5-1985, as endorsed by NRC Regulatory Guide 1.149, without exception or provide justification for any exceptions taken.
Answer 11 The box for exceptions on NRC Form 4 7 4 for Unit 2 was inadvertently not checked.
The intent was to certify Unit 2 on NRC Form 4 7 4 with the box for exceptions checked.
The information in Attachments 1 and 2 were intended to prove the identified differences were of a
minor nature.
Therefore, the Unit 1
simulator can be used as the reference plant simulator for Unit 2.