ML19320D560
| ML19320D560 | |
| Person / Time | |
|---|---|
| Issue date: | 06/05/1980 |
| From: | Advisory Committee on Reactor Safeguards |
| To: | Advisory Committee on Reactor Safeguards |
| References | |
| ACRS-1744, NUDOCS 8007210524 | |
| Download: ML19320D560 (23) | |
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DATE ISSUED:
6/5/80 LTD n 3 f11NUTES OF THE M
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E'.iL N APRIL 30,1980 WASHINGTON, DC The ACRS Subcommittee on Regulatory Activities held a meeting on April 30, 1980, at' 1717 H Street, N.W., Washington, D.C. Notice of this meeting was published on Friday, April 18, 1980, in the Federal Register, Volume 45, Number 77; a copy is included as Attachment A. Mr. Sam Duraiswamy was A list of meeting attendees the Designated Federal Employee for the meeting.
is included as Attachment B.
INTROD'JCTORY STATE'4ENT BY THE CHAIRMAN Dr. Siess, the Subcommittee Chairman, convened the meeting at 8:45 a.m.,
reviewed briefly the schedule for the meeting, indicating that the Sub-committee will. hold discussions with the NRC Staff certinent to the fo ing items:
Regulatory Guide 1.144, Revision 1, " Auditing of Quality Assurance 1.
Programs for Nuclear Power Plants".
Proposed Regulatory Guide 1.XXX, " Nuclear Power Plant Simulators 2.
for Use in Operator Training".
He noted that the Subcommittee had received written comments from G Atomic Company, General Electric Company and the Westinghous? Electric The Subet.mmittee did not
' Corporation on Regulatory Guide 1.144, Revision 1.
receive any requests from members of the public for time to make oral statements.
REGULATORY GUIDE 1.144, REVISION 1, " AUDITING OF QUALITY ASSURANCE FOR NUCLEAR POWER PLANTS" Dr. Siess provided a brief preamble to Regulatory Guide 1.144, Revision 1, indicating that it endorses, with certain exceptions, ANSI /ASME N45.2.12-1977, " Requirements for Auditing of Quality Assurance Programs for Nuclear A previous version of this Guide was reviewed by the Regu-Power Plants".
latory Activities Subcommittee at the May 31, 1978 meeting and was issued for public comment in January 1979. The present version of this Guide re-flects consideration of public comments that were received during the public comment period of this Guide.
8007210 9 /
April 30,1980 9eg Act Mtg Indicating that at the May 31, 1978 meeting the Subcommittee asked the NRC Staff to resolve the comments submitted by Westinghouse on the previous version of this Guide, Dr. Siess asked about the action taken by the NRC Staff to resolve Westinghouse's comments.
31, 1978 Mr. Guppy stated that he believes that subsequent to the May meeting, appropriate changes were made to this Guide to resolve some of concerns expressed by' Westinghouse.
!1r. Guppy reviewed briefly sone of the changes made to this Guide as a result of public comments:
1.
Regulatory Position C.3 has been modified to:
eliminate reference to other Regulatory Guides and to provide a.
specific guidance, provide specific exceptions to audit requirements rather than b.
referring to requirements delineated in ANSI N45.2.13-1976, and clarify the point that the specified requirements would be c.
applicable to both prior to and after award of contract procurement phases.
Regulatory Position C.3.b.(2)(a), which required that applicable 2.
elements of a supplier's quality assurance program should be audited by the purchaser at least annually, has been deleted.
Regulatory Position C.5 has been added to include a paragraph of 3.-
This Posi-
'the Discussion Section so as to make it enforceable.
tion states that where more than one purchaser buys from a single supplier, one of the purchasers may perform audit of the suppi er on behalf of the other purchasers in order to reduce the number _ of external audits of the suppliers.
Regulatory Position C.6 has been added to reflect the fact that 4.
audits are not the only method of verifying _ implementation of
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. April 30,1980 9eg Act :1tg N
corrective action; methods other than audits, as specified in 10 CFR Part 50, Appendix B, may also be used for verifying imple-mentation of corrective action.
Mr. Guppy p6inted out that several commentors expressed concern about the annual internal audit requirement delineated in Regulatory Position C.3.
He stated that the annual frequency for internal audit has been included in several documents TANSI N45.2.12-1974, WASH-1283 and 1309 dated May 1974)
To that have been providing guidance on quality assurance requirements.
date, licensees have committed to an annual internal audit and no exceptions to the annual internal audit frequency have been requested in the topical Since the NRC Staff believes that the reports submitted by licensees.
specified annual frequency for internal audit is consistent with the exist-ing MRC practice, they did not make any changes to this requirement.
In response to a question from Mr. Bender as to whether the annual audit requirement will be applied on only certain selected items or on all items, Mr. Morrison' stated that it will be applicable to all elements of the quality assurance program.
In response to another question from Mr. Bender with regard to the extent to which the annual audit requirement would be applied on procurement activities,
' Mr. Morrison stated that he believes that Regulatory Guide 1.123 provides certain guidelines and recommendations with regard to the application of the quality assurance requirements for control of procurement activities.
It is not the intent of Regulatory Guide 1.144 to impose the quality assurance requirements on procurement activities. The purchaser has to make judgment with regard to the extent to which he wants to apply the specified quality assurance requirements for control of procurement activities and services.
Indicating that several of the commentors have expressed concern that Regulatory Guide 1.144, Revision 1 specifies excessive quality assurance audit requirements and implementation of such requirements will result in a substantial increase in the number of both internal and external audits conducted by utilities and
. April 30,1980 Reg Act Mtg other associated organizations, Mr. Sender commented that the NRC Staff did not specify clearly how r<any additional audits will. result from the implementation of the requirements delineated in Regulatory Guide 1.144, Revision 1.
He suggested that additional clarification of this issue would be helpful. He stated further that additional information needs to be developed to provide guidance to the Inspection and Enforcement (I&E) group of the NRC for exercising judgment in the audit process.
Mr. Morrison stated that he believes that the annual internal audit requirement specified in Revision 1 to Regulatory Guide 1.144 is consistent with the exist-ing NRC practice; he does not believe that implementation of this requirement will result in any additional audits.
With regard to the NRC Staff's response to some o'f the public comments, Dr. Siess commented that the NRC Staff's response to certain public comments is inadequate and ambiguous. He believes that the NRC Staff consistently fails to provide explicit clarification to some public comments so as to clear the misinterpretation.
Dr. Siess solicited the opinion of the Subcommittee on the adequacy of the annual internal audit requirement spectiied in Regulatory Position C.3.
Mr. Bender commented that he does not have any objection to this requirement as long as it is applied to major areas without extending its application to
'the procurement activities.
He suggested that the Subcommittee endorse this requirement with the understanding that the NRC Staff does not intend to extend this requirement for control of procurement' activities and services.
Other members of the Subcommittee did not raise any objection to the annual l
internal audit requirement.
With regard to Mr. Bender's comment, Dr. Siess pointed out the statement made by the NRC Staf' in the earlier part of the meeting that the annual internal audit requirement is consistent with the existing NRC practice and the NRC Staff does not intend to. extend the application of this requirement to the procurement activities.
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April 30, 1980 Reg Act Mtg The Subcommittee discussed briefly the written comments submitted by thel l
Westinghouse Electric Corporation, General Electric Company and the Gen l
The Subconnittee sought some response from Atomic Company (Attachment C).
the NRC Staff with regard to the concern expressed by the Westinghouse g
Electric Co'rporation and the General Electric Company that the requiremen delineated in P,egulatory Position C.7 is vague, unnecessary and unjust The NRC Staff indicate'd that Regulatory Position C.7 was added to this to enable I&E to assure that an audit was conducted in ac Since I&E felt that audit checklists would help specified audit programs.
l them decide whether an audit was conducted in accordance with the ap Position requirements, the NRC Staff has included the statement in Regulatory C.7 which states that " Additionally, these records should include documents associated with the conduct of audits which support audit findings (for Westinghouse and the General Electric Company example, audit checklists").
l were concerned that this Position could be misinterpreted to mean that a
- However, documents developed in the course of an audit *should be retained.
it is not the intention of the NRC Staff to require that all documents To avoid such confusion and misinterpretation, the NRC should be retained.
Staff intends to modify Regulatory Position C.7 to say that either audit checklists or procedures should be retained.
' Dr. Siess com:x nted that most of the commentors seem to have problem Regulatory Guides should understanding the main intent of the NRC Staff.
be written to preclude confusion and misinterpretation; they should spe clearly the main intent of the NRC Staff.
Afterfurtherdiscussion,theSubcommitteeindicatedth$titwillrecommend i Guide that the full Committee concur with tN Regulatory Position of th s during the 241st ACRS meeting.
PROPOSED REGULATORY GUIDE 1.XXX, " NUCLEAR POWER PLA OPERATOR TRAINING" He Mr. Wiebe reviewed briefly the need for the development of this Guide.
stated that based on operating experience and the lessons learned fro
e April 30,1980 P,eg Act Mtg TMI-2 accident, the NRC Staff, along witt other technical communities such Special Inquiry Group, who investi-as the President's Commission and the gated the TMI-2 accident, has realized the 7eed for improvement in operator training to improve operator perfor'ance to handle emergency and abnormal situations. ' Realizing that it w.,la be feasible to. perform such improved training on simulators, the NRC Staff has developed this Guide with the intention of initiating improvement in simulator functional require-ments.
Mr. Wiebe stated that this Guide endorses, with certain exceptions, the draft ANS Standard ANSI /ANS 3.5, dated March 18, 1980.
It describes a method for specifying the functional requirements of the simulators and for specifying similarity requirements between the simulator and its reference plant.
Mr. Holman, from the NRC Staff, pointed out that this Guide requires that each simulator should have a reference plant and the simulator should be However, this Guide does kept current with the reference plant changes.
not require that each plant should have a simulator; that is a separate issue and it will be discussed in the proposed revision to 10 CFR Part 55,
" Operators' Licenses".
With regard to using the reference plant data as a basis for simulator
' design, Mr. Bender wondered whether they will be able to obtain all the He commented further necessary data from the reference plant operations.
that the fact that simulators can simulate certain events does not neces-sarily mean that they will be able to provide adequate response to those 93 events that have never happened in real plant operations.
kn Mr. Wiebe reviewed briefly'the requirements delineated in the Regulatory Positions of this Guide (Attachment D, Pages 1 through 6,.
Indicating'that several short-term studies are proposed or ongoing on simulator improvements as a result of the lessons learned from the TMI-2 accident, Dr. Siess asked for the reasons for issuing this Guide at this time without waiting to see the results of these short-term studies.
.y.
April 30, 1980 Reg Act Mtg The NRC Staff stated that the proposed short-term studies are not intende Moreover, they believe mainly to ir,nprove the capabilities of simulators.
'mproving simulator that ANS 3.5 provides some advanced information for The NRC Staff feels that they shoult provide some guidance capabilities.
to the industry on the characteristics of nuclear power plant simulators at this time. They do not see any significant advantages in delaying the issuance of this Guide until some of the short-term studies are completed if the results of the "short-term studies provide any additional information d
on this issue, it will be incorporated into the future revisions of this Gui Mr. Ebersole commented that some of the transients that are required to be He asked simulated by a simulator may lead to two-phase cooling problems.
whether'the simulators will be able to handle two-phase flow problems.
The NRC Staff indicated that they are not sure whether the simulators wi
-be able to handle two-phase flow issues.
After further discussion, the Subcommittee indicated that the NRC Staff could iscue this Guide for public comment.
SUBCOMMITTEE'S REMARK ON THE NRC STAFF'S PRO IDENTIFICATION NUMBERS TO PROPOSED REGULATORY GUIDES _
_In a generic sense, the Subcommittee discussed the appropriateness of NRC Staff's procedure for assigning identification numbers to new Regulat Guides. The previous practice was to assign specific numbers to Regulatory Guides prior to issuing them for public comment, or definitely prior to su According to the new procedure, a mitting them for ACRS concurrence.
Guide until just
. specific number will not be assigned to a new P,egulatory The Subcommittee expressed seri.ous before issuing it for industry use.
concern about this procedure, indicating that this practice will cause I
confusion and create problems in keeping track of the history and develo Moreover, since it does not seem appropriate ment of Regulatory Guides.
-l for the ACRS to concur with a Guide without a specific identification ld 3
number, the Subcommittee recommended strongly that the NRC Staff shou assign numbers to new Regulatory Guides prior to submitting them
'for review.
8-April 30, 1980 Reg Act Mtg
' FUTURE MEETING The NRC Staff indicated that the fol10 wing items will be submitted for the Subcommittee's review at the June 4, 1980 meeting:
Proposed Regulatory Guide 1.23, Revision 1, " Meteorological 1.
Prog' rams in Support of Nuclear Power Plants".
Proposed Revisions to 10 CFR Part 55, " Operators' Licenses" 2.
and 10 CFR Part 50, " Domestic Licensing of Production and Utilization Fa'cilities".
Dr. Siess thanked all the participants and adjourned the meeting at 11:25 a.m.
For additional details, a complete transcrip'. of the meeting is NOTE:
available in the NRC Public Document Room,1717 H St., NW, Washington, DC 20555 or from International Verbatim Reporters, Inc., 499 South
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20002, (202) 484-3550.
Capitol' Street, SW, Suite 107, Washington, DC
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Federal Register / Vol. 45. No. 77 / Friday. April 1s 1980 / Notices _
Persons wishing to submit written Advisory Committee on Reactee statements regarding Regulatory Guide Safeguards Sh...:ii.+ out 1.144. Revision 1 may do ao by providmg Regulatory Activttlea; Meeting a readily reproducible copy to th De ACRS Subchw m Subcommittu at the WW o Regulatory Actmties will!mid an open meeting. However, to insun tliat odequate time is available for full meeting on Apfd 30.1980.in Room 1167
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consideration of these comments at the 1717 H St N.W Washington.DC 20555.
In accordance with the procedures muting. itis desireble to send a readily outlined in the Federal Register on reproducible copy of th: commer.ts as October 1.1979 (64 FR 56408) oral or farin advance of the meeting as written statements may be presented by Practicable to Mr. Sam Dura swamy (ACRS).the Designated Federal members of the public. recordings will be permitted only during thoes partions, Employee for the meeting. in c.an,of, n.
of the meeting when a transc pt isbamg ACRS. Nuclear Regulatory Commissio kept. and questionsmay be asked only Washington. D.C. 20555 or telecopy by members of the Subcommittee,its them to the Designated Federal Employe,(202 634-3319) as far in consultants, and Staff. Persans desiring to make oral statements should nody advance of the meeting as practicable.
the Designated Federal Empicyee ao fur Such comments shall be based upon In advance as practicable so that documents on file and available for appropriate arrangements can be made public inspection at the NRC Public to allow the necessary time during the Document Tsoom.1717 H St., N.W.,
f Washington. DC 20535.
meeti:3 or such statements.
De agenda for subject meeting shall Further information regarding topics be as fo!!aws:
to be discussed. whether the meeting has been cancelled or rescheduled, the we6eshy. April.m w Chean's ruling on tequests for the The steews wdlcemmenw oraca.cr.
opportunity to present oral statements The Subcommittee willhear and the time allotted therefor can be presentations from the NRC StaK and obtained by a prepaid telephone call to will hold discussions with this group the Designated Federal Employee for pertinent to the following-this meeting.Mr. Sam Duraiswamy.
(1) Regulatory Guide 1.144. Revision 1.
(telephone 202/634-3267) between 8:15
" Auditing of Quahty Assurance a.m. and 5.00 p.m. EST.
Programs for Nuclear Power Plants' Demprh.19eo (Post Cormnent) Guide 1.XXX " Nuclear C. %
(2) Regulatory
- 88'Y
- '8""" ""8'"* D ^
Power Plant Simulators for Use in C
Operator Training"(Pre Commeof)
Im 0= *"" N '- ** *** **
Other matters which may be of a was ocoa runaw predecisional nature relevant to reactor
' operation orlicensing activities may be 7
discussed following this session.
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Attachment A
ACRS SUBCOMMITTEE MEETING ON REGULATORY ACTIVITIES WASHINGTON, DC APRIL 30, 1980 ATTENDEES LIST NRC ACRS_
W. M. Morrison, OSD C. P. Sicss, Chairman E. C. Wenziner, OSD H. Etherington, Member G. Guppy, OSD M. Bender, Member J. G. Spraul, QAB J. Ray, Member J. S. Wiebe, OSD J. Ebersole, Member J. J. Holman, OLB S. Duraiswamy, Staff
- KftC,INC.
- Designated Federal Employee R. S. Boyd IVRI M. Winter i
Attachment B 4
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PROPOSED REGULATORY GUIDE 1.144, " AUDITING OF QUALITY ASSURANCE
SUBJECT:
PROGRAMS FOR NUCLEAR POWER PLANTS Letter, G.A. Arlotto (NRC) to L. G. Marquis (GE) dated April 16,
REFERENCE:
1980, and enclosures Enclosures to t'he reference letter included proposed Revision 1 of the subject The following regulatory guide and the Value/ Impact Assessment for the guide.
comments relative to the proposed guide and the Value/ Impact Evaluation are submitted for consideration by the ACRS Regulatory Activities Subcomittee which is scheduled to meet in Washington, D.C. on April 30, 1980.
sNeh 9 ud&2 Regulatory Position.C.7: This position was ot contained in the January 1.
This new position in 1979, "for comments" issue of the regulatory guide. ally, these reccrds should the regulatory guide reads, in part, "Additi w4% support audit findings include documents associated with the conducThis new position consitutes an escala-(for example, audit checklists)."
tion in requirements that is unnecessary and unjustified. As stated, the positi n could be interpreted to mean that any and all documents reviewed rated in the course of an audit which in any way could support audit Such or g findings are to be considered audit records and must be retained.
records would include directive documents reviewed, completed checklists, any pictures taken, notes, etc. Such documents are only necessary to sub-stantiate findings at the time the audit report is issued. Retaining such documents as audit records serves no valid safety-related purpose and imposes an unjustified burden on those organizations which would commit to compli-ance with Regulatory Guide 1.144.
Records that do serve a valid purpose such as the audit system plan, indivi-dual audit plans, audit reports and written replies, and the record of completions of corrective actions are required to be retained by ANSI /ASME It is, therefore, recommended that position C.7 of proposed N45.212-1977.
Regulatory Guide 1.144 be deleted.
'The "Value/ Impact Assessment on Auditing of Value/ Impact Assessment:
Quality Assurance Programs for Nuclear Power Plants" does not address posi-2.
There is no evidence in the tion C.7 in the proposed regulatory guide.
assessment that either the value or the impact of proposed position C.7 was evaluated.
In our judgment, proposed position C.7 has no safety-related value for the reasons identified in comment 1, above. Further, the impact of such a requirement would be significant in terms of the time, energy, From and effort that would be expended in complying with the requirement.
a value/ impact standpoint, it is felt that requirement C.7 is unjustified.
Very truly yours,
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.W. H. D'Ardenne, Manager Safety Evaluation Programs G, enml Elesh;s Ce y, ns cestasa. Au Ja. s,e,
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(.uide 1,144 is cons idering a provision in Regu) story the NRt of the QA progr.im CA underntands that audit ing wher et.y each element s lic e,l et covo r ing ANSI FU..,,2.12 en k'e be)Icvc t bat thite provision flexiteilf t v in the audit schedule Cu3t be audited at Arart ovive a year, in a need t<. previde bcAn/
of activity within the cry.anfratines There be snodified.
and level to safety.
That in, a sc e;.e which recognires thethe importance of the activitics to that are not ie.portant cudited as well am those activitica.
that time period since the-graded approach is needed sobeen acttvcly con < tutted during the Ocfoty or have not 1
be audited every year.
loot audit need not i
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Westinghoute Divisions nnmenrmem me Electric Corporation April 29, 1980 PAS-EJH-80-309 NS-WA-2240 Mr. Sam Duraiswamy Advisory Committee on Reactor Safeguards U.S. Nuclear Regulatory Comission 1717 ll Street, N.W.
Washington, D.C.
20555 Proposed Regulatory Guide 1.144 Revision 1 entitled,
" Auditing of Quality Assurance Programs for Nuclear
Subject:
Power Plants" (Tauk RS-035-2)
Dear air:
f In response to the invitation which appeared in the Federal Regist to take Friday, April 18, Westinghouse Nuclear Energy Systems would like i
to this opportunity to submit written ccmments and suggestions pe Plants."
Regulatory Guide 1.144 " Auditing of QA Programs for Nuclear Po a
liestinghouse has reviewed the Regulatory Guide and has ident to the guida's where revision of the guide is merited.to request modification objectives:
7 graph In addition to the records requirements of ANSI /ASME N45.2.1 i t d with the C.7 of the proposed regulatory guide requires,..." documents ass dit checklists)."
conduct of audits which support audit findings (fo b
t from section I.C of the Value-Impact Statement.
i d) and not requirement as stated is both vague (as only one example is c t t audit merited, as required audit reports contain information tice findings.
Additionally, Westinghouse would like to note the par
- guide, t and their its Value-Impact Statement, and assoc.iated summ (i.e., April 18, 1980)
(60)daycommentperiodshouldbeprovided.
resolutions.
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April 29,1980 Mr. Sam Duraiswamy NS-TMA-2240 Should you desire, Westinghouse would be pleased to further discuss the comments on the attached.'
Very truly yours, T. M. Anderson, Manager Nuclear Safety Ocpartment P.T.McManus/1k Attachment ec:
Mr. $smuel J. Chilk Secretary of the Connission U. S. Nuclear Regulatory Commission 1717 H Street Washington, DC 20555 e
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March 9, 1979 Nr. Samuel J. Chilk Secretary of the Coutission U.S. liuclear Regulatory Comission 171711. Stret?
) Washington, D.C.
20555 Attention:
Docketing and servir.e Drar.ch
Dear Sir:
In respense to the invitation which appeared in the Federal Register, ticstinghnur.e Nuclear Energy Systens v:culd like to take tnis oppo*tunity to submit written coments and su;r, cations pertinent to Regulatory Guide 1.lf.4 "Auditir.0 of QA Programs for lluclea-Fowar Plants."
) W:stingbcuse has carefully reviewed the Regislatory Guide ar.d has identified The attac5cd cor. rent s scvoral areas where revision of the guide is merited.are intended to cl of those areas that do not contribute to its objectives.
In addition,1.'estinghouse did not receive a value impact state:nent on this lie would like the opportunity to resiew and com: ent on the value impact statement, and request that it he forwarded as soon as possible.
Rigulatory Guide.
Should the Connission desire Westin<; house would be pleased to further discuss the corments provided on the attached.
Ver truly yours, T.M.dnderson, Manager
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Huclear Safety Depa'rtment
)M.A.Haley/ keg Attachment c.i
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WESTltiCHOUSE I.D.CTRIC CORPOMTION bC b
Coments on Regulatory Guide 1.144 Auditing of QA proDrams for Nuclear Powcr Plants Pane 1.144-2, Sy,ctinn C.3.a.(2) - Internal Audits Delete the phrase apnlicable elements "...should be Recom,cndation:
audited at 1 cast a inually..." and substitute,
" " " " " " ~ ~
...should be evaluated annually and audited at least on a triennial basis, or at least once within the life of the activity, whichever is shorter."
Add the following sentence after that given above:
"The first of the triennial audits should be conducted luscoarendation:
within the first year v. hen sufficient work is in progress to determine whether the organization is complying with the established quality assurance program. "
An arbitrary annual basis for regularly scheduled internal audits tends to treat all applicable elements Justificatien:
of the quality assurance prog-cm alike, retjardless ofConseq the status and inportance.
may be too frequent for individual activities.
Although an annual basis may simplify schedule review by outside auditors (e.g., fiRC, ASME, utilities, etc ),
it does not necessarily contribute to the safety of the The frequency of audits shcald be established based upon the tyoe of activity, experience, and other public.
ANSI M45.2.12-1977 provides such relevant factors.
latitude in judging the schedule for regular and supple-mental audits.
External Audits
,PfSe_1,1 A4-2. Section_,C.3.b. D.)(,b),_5n,cond Sentence -
"The first of the triennal audits Reword as follows:
should be conducted when sufficient we'rk is in progress Recorr'anda tion:
to detemine whether the organization is complying with
" " ~ " " ~ " "
required quality assurance provisions."
This wording would allow certain pre-award surveys. to Justification:
fulfill the audit obligation.
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III.
REVIEW 0F ANS 3.5
" NUCLEAR POWER PLANT SIMULATORS FOR USE IN OPERATOR TRAINING" A.
SCOPE
- 1. ESTABLISHES MINIMUM FUNCTIONAL CRITERIA FOR NUCLEAR POWER PLANT SIMULATORS USED FOR OPERATOR TRAINING
- 2. SIMULATORS EXCLUDED FROM SCOPE (A)
IEST REACTOR SIMULATORS (B)
MOBILE REACTOR SIMULATORS (C)
RESEARCH REACTOR SIMULATORS (D)
SIMULATORS FOR REACTORS NOT SUBJECT TO NRC LICENSING (E). LIMITED SCOPE SIMULATORS REGULATORY POSITION 1 EXPANDS SCOPE TO INCLUDE SIMULATORS USED FOR TRAINING, ENGINEERING AND MANAGEhiNT PERSONNEL.
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B. GENERAL REQUIREMENTS REGULATORY POSITION 3 __
CLARIFIES THE EXTENT OF SIMULATION BY A SIMULATOR
- 1. SIMULATOR CAPABILITIES (A)
NORMAL PLANT EVOLUTIONS REGULATORY POSITION 4 MAKES EVOLUTIONS TO BE SIMULATED MORE EXPLICIT (B)
PLANT MALFUNCTIONS 8EGULATORY POSITION 5 RECOMMENDS THAT PURCHASER SPECIFIES MALFUNCTIONS THAT ARE TO HAVE VARIABLE RATE AND SEVEF.lTY CAPABILITY.
hlSORECOMMENDSEXPANDING,DESCRIPTIONOF LOSS OF ELECTRICAL POWER MALFUNCTION.
- 2. CONTROL ROOM ENVIRONMENT
-(A)
CONTROL PANELS REGULATORY POSITION 6 RECOMMENDS STRENGTHENING THE EXTENT OF SIMILARITY
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(B)
CONTROL ROOM ENVIRONMENT i
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D?
- 3. SYSTEMS TO BE SIMULATED AND DEGREE 3YSTEMS CONTROLLED FROM THE MAIN CO (A)
REGULATORY POSITION 7 RECOMMENDS THAT SYSTEM INTERACTIONS SYSTEMS BE SIMULATED SYSTEMS OPERATED OR FUNCTIONS CO (B)
OF THE CONTROL ROOM REGULATORY POSITION 8_
RECOMMENDS CLARIFICATION OF INTERAC REMOTE FUNCTIONS
- 4. SIMULATOR IRAINING CAPABILITIES (A)
INITIAL CONDITIONS (B)
MALFUNCTIONS (C)
OTHER CONTROL FEATURES (D)
INSTRUCTOR INTERFACE
- 5. DOCUMENTATION 11
C.
PERFORMANCE CRITERIA 1, STEADY STATE.0PERATION INSTRUMENJ ERROR MASS AND LNERGY BALANCES CRITICAL PARAMETERS
(
NON-CRITICAL PARAMETERS 2.'IRANSIENT OPERATION A) SAME AS STARTUP TEST PROCEDURE ACCEP B) OBSERVABLE CHANGE CORRESPOND ON DIRECTION 4AGNITUDE 10T VIOLATE PHYSICAL LAWS 8LARMSANDTRIPSASINREFERENCEPLANT PALFUNCTIONS AND TRANSIENTS NOT TESTED M6 h
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D.
SIMULATOR UPDATE
- 1. SIMULATOR DATA BASE UPDATING (A) CHANGES TO REFERENCE PLANT EVALUATED FOR APPLICABILITY TO SIMULATOR (B) ACTUAL REFERENCE PLANT PERFORMANCE DATA OPERATED GREATER THAN 18 MONTHS (C) UPDATED TO ACTUAL PLANT PERFORMANCE D IN 18 MONTHS AFTER THE REFERENCE PLANT IS COMMERCIAL OPERATION OR SIMULATOR IS AVAILABLE, WHICHEVER IS LATER f
- 2. SIMULATOR UPDATING A) ANNUAL REVIEW OF HARDWARE B) REVIEW OF MAJOR MODIFICATIONS
- 3. USE OF FEEDBACK FOR UPDATING
- 4. SIMULATOR PERFORMANCE IESTING (A) PERFORMANCE IEST AND REPORT CONDUCTED (1)
FOLLOWING INITI AL CONSTRUCTION AND A f0R TRAININGrlHEN THE SI ULATOR IS UPD (2)
IN SECTION 1 AND 5.2 (3)
UNCE EVERY YEARS MW T
e 4
j) r
E.
PROCEDURE FOR DOCUMENTING SIMULATOR PERFORMANCE 8EGULATORY POSITION 9_
RECOMMENDS INCLUDING THIS PORTION AS PART OF STA RATHER THAN AS A NON-MANDATORY APPENDIX 1.
SIMULATOR INFORMATION ENERAL ONTROL ROOM NSTRUCTOR INTERFACE PERATING PROCEDURES FOR SIMULATED PLANT HANGES SINCE LAST REPORT 2.
SIMULATOR DATA BASE
$TEADY STAIE OPERATING CONDITIONS RATING LONDITIOySlANT UCCURRING
- VENT (lF APPROPRIATE)
IRANSIENT UPb lESIGNANALYSISDATA IGNIFIQANT U
3.
SIMULATOR IESTS l
NORMAL OPgRATION kBNORMALUSERATIONS rLANS FOR JPGRADING
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REGULATORY POSITION 10
)
RECOMMENDS CLARIFYING TERMINOLOGY D-6
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