ML20141G070

Ack Receipt of Voice Mail Messages & Fax Re Review of Simulator Regulations & Informs That Info Will Be Placed in Pdr,Per Request

ML20141G070
Person / Time
Issue date:	04/22/1997
From:	Collins F NRC (Affiliation Not Assigned)
To:	Halverson S AFFILIATION NOT ASSIGNED
Shared Package
ML20141G010	List: ML20141G006 ML20141G070
References
NUDOCS 9705220151
Download: ML20141G070 (7)

Text

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e:

" rom: -

Frank Collins -

To:

INTERNET: SOCKETS. NET:HALVERSON Date:

4/22/9710:32am

Subject:

Simulator Regulations Review Scott, I received your voice mail messages and the fax you sent regarding your review of simulator regulations. I agree that further discussion is in order, We are conducting a similar review and will be pleased to' discuss USUG's perspective. I will contact you in the near future, probably in the next few weeks. In the interim, I will place your USUG input of 4/21/97 in the public document room. Thanks, Frank CC:

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j APR 21 '97 01859PM U.E. CfLLc4#1Y PLANT P.1 tmurr muvum vans onour i

1 FAX TO:

Frank Collins Operator Licensing Branch Fax #

301-415-2222 i

Tel#

301-415-3173 FAX FROM:

Scott Halverson i

Utility Simulator Users Group - Chairman Far#

573-676-4481 l

Tel #

573-676-8257 i

Response to telephonc

..r uca concerning your observation that very $rw simulator facilitics have oortined to the new Regulatory Guide and ANSI Standard vs. "some plants will continue to follow the 2

1985 standar<L" l

You also pnwided a copy of the ACRS Bris8ng dated February 9,1996 presented by Mr. James Davis.

Nuclear Enstgy Instinae covering Revision 2 to REO. QUIDE 1.149.

Mr. kmes Davis was contacted and discussed the industry position and the concerns.

Related documents were reviewed to see where and why confbslon is selli present.

Pleses consider the attached review and conclusions l

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! will be happy to discuss and attempt to resolve issues to help simuladon theilities move toward adoption i

cf the now guidelinos and standants.

Raninder.

1 Please also note that next years SCS C&sm"JSUG Annual meeting has been moved to the week of Muary 11 14 toJd plant outaas dates.

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APR 29. '97 92800PM U.E. CALLAWAY PLANT P.2 Apnl2,1997

- ibvisw of Simulator Regulations, NUREG, Reg Guide and Standard

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conducted by Scott Halverson Utility Simulator Users Group - Chairman Engillation '0CFR55.45 4

33.41 Oprating Tssa (b),ficplementation (S) CertMcadon of Simulstion Pacilides (1) Shall povide ggg3l$sglgg on Form NRC-474 (ii) Must submit gaggtevery fbut yeen (performance tests)

Qi) Must submit a ghedglg ewryibur years (performann tests) 011) Must retain gaggbg kr hur years (performance tests)

Oy) Commission determines meeting requiremens (based resula on podermance tests)

(v) Rooorti8 cation including t ssults of completed perfonnance tests) i (vi) Certi8 cation /roosrtiacation report oonent.

i Descripdon of the completed performanet tests Nat ibur year period puformance easts Schedule Abr;py.e H fy25%paforiaanestestsperyear Regulation charly is based on the cunduct of serforgiance tests whatewr they may be......

4 No mention in 10C7R$$,45 is made of an onping con 8 uradon control process in the regulations 3

What is a " PERFORMANCE TEST" as identined in 10CPR$$.437

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Performanen innes are not described or danned within the regulation..

j The Form NRC474 also rehrenose the nedsrasmen tests but does not provide a description of these tests. The fbem links the certi8 cation to 10CFR$5.45, Rag Guide 1.149 and ANSUAN5 3.5.

I By signing the ibra NRC FORM-474 emm8aaradas central is assanad by complying with the ANSI /ANS-3.51935 mansard 8 sedan 5.

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A Airther seamh br the ds8mition of andermance tests atuut be made......

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j APR 21 ?97 02802PM U.E. CALLAWAY PLANT P3 MEG-1262

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Rcdbr to Questions and Answers NUREG 1262 (Page 48) ypdarmanes Tests Q176 Answer: De..s.

. include 2

(1) the malfbactions identitled in section 3.1.2 of the standard to be done at a rate of approximately 2$

porosat per year om en ongoing four9 ear cycle (2) the per% manos tests that are spectSed in Appendix A of the standard, also at a rate of 25 percent per l'er

0) and the opsenhuity tests identified la Appendix B so the standard thss are to be done annually i

(Page 59)Endarmannen Tanis Q211 Answer. We'rt talking about (1) Appendix A of AN51/ANS-3.51985 G) AppendixB ANSI /ANS 1985

0) The list of 25 -ta=viana that are contained in section 3.1.2 of the standard. There is a defined list 2

of =ta=*iaa= that the shemlation thcility needs to perfbrm.

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(page 60) Padhrmance Tests Q215 Answer:

i (1) omtetions and malfhnetions identitled in Scotion 3.1.2 G) postmaanocmetappendix (Appendix A)

(3) operability test appendix (Appendix B)

(page 61) Parformance Testa Q216 Answer, i

(1) Appendix Aperfbrmancetesdag25%peryear (2) speelfic list of malfh=vians that are identified in section 3.1.2 25% par year (3) opctskilitytestingshownin AppendixBtobe-4

' annually i

(pass 63) Padarmance Testa Q 224 Answer.

(1) Perkmanos testing that appears in Appendix A i

(2) Plus a supeat of the malihaction testing, which is described in section 3 of the standard i

(3) operabuitytestidentinedin AppendixB (you don't need to do tests twice)

NURBO.1262 describes the perfbemance test based on the Appendix A and Appendix B of the ANSI /ANS 3.5 1985 standard and the list of malfhnctions nantainmi within the samo standard.

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appenttoinclude and arelimited to:

1. Realtimetests 2.

sesady state tests (Operaldlity Tests)

3. Ncemaloperationstests 4 Transient Tests (Operability Tests) i j

5. MalAm*Ian Tests (generic)

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6. Malfbaction Tess (section 3.1.2. Denton letter %4 e)

Plant modinoations am reviewed annually. Modificadon tests are not clearly identined NO'lY: The 1993 version of tbs Standard has been issued that makes this link much mon difDeult to hilow, if the utility chooses to cardfy to this newer verson of the standard Next compare the 10CFR$5.45 requisement he and the description of nadormance

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333 within NURO 1262 " questions and answers" with the Regulatory Guide nerfbraance testa 2

l APR 21 '97 02:03PPI U.E CALJNAY PLANT P.4 RenulatorY Guide 1.149 i

1.3 Overridas rosy also be considered malibnctions ValidadcaTesdas Periodic Peribraance Testing (=WA esting) t 1

(Apphcable if malfbactions are part of the training and==ia=4n scenano)

NCHE. VaMdat'na matina and M now appear to be addressed.

NorIE: Overrides she singled cut as an instrador interface feature that shoukt be considered to be within j

l the malihnation testing category.

i NOTE. Gensric malfhnetion tests m no longer nah.

NOTE: Malfbaction tests are limited to thoes within the scope of training or examination.

1.4 Veriflestion Validationtesting NOTE: This now term," validation testing," is also discussed in the 1993 standard This new testing term is linked back to modsflations and not to the regulation requirement of"Rpformance tests" or to the questions and answers of NUREG 1262 describing "nerformance testa "

1.5 Stench State and Normal Evolutions (similar to old AppenCx A)

Appendix B Testing (Steady State Test, Stability Test. Transient Performance Tests) 8ection 3.1.4 Malfunction Testisg 25% per year 10CFR Parts S$.45 and 55.59 Other malfbactions 25% per year planned training and examination scenarios 4

Peribraanse tests may be integrated with training programs Malfunatkm Tests may be integrated with training programs Radrence plant snodifications rwlowed annually i

Appendices are part of the Standard NCTIE Testing per.WN A appears to be redefined in the Regulatory guide from the description i

provided in NUREG 1262. (Appendix A no longer lists tests)

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NCTTE: Testing now includes a broader definition of malfunctions, but limits these malfunctions to those j

used within the scope of training or examination.

NCYTE:. >..

are not clearly identiflod as ". 0. -

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4 Perfbemenos tests appear to include sad are limited to:

1.

Sicady Stat: Tests (AppendixB Oa=WWyTests))

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Statdlity Tests (Appendix B Operability Tests) 3.

NormalEmlution tests 4.

Transient'Insts(Oa=Wuty Tests) 5.

Malfbaction Tests (in planned training and examination) 6 Malfhnetion Tests (section 3.1.4. Denton letter requirements)

Modification testing appears to have two associated types of tests:

Venfloation Tests m newly identified.

Validstion Tesis am newly mem-i

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APR 21 '97 02:05PM U.E. CALLAWAY PUNT P.5 e

ANSI /ANS-3-5-1985 Annamen A(PerfbraanceTests)

A3.1 ComputerRaa!ThecTest A3.2 80se# State and Nonnal Operation Tests A3.3 TransientTests(AppendixB)

A3.4 Malfbaction Tests (Bach generic malfbaction also includes section 3.1.2) tests (includedin Ap nis a,es.es.s - pendix A au1A*=*W even it is not called a " malfunction")

Annandla4(Operability Tests)

Includes the sesa# state and transient tests (identitled in.W~8M A)

ANSI /ANS-3-5-1993 Annanst A A"- /. no longer mondons real time toets Seesdy State and Normal Operat6on Tosts are no longer memioned Transient Tests (Appendix B) are not mcotlooed in Appendix A Malfunction Tests (Esch gencric malfhnetion also includes section 3.1.2) are not mentioned Comparing this Appendix A with NUREG 1262 is no longer valid. (tests removed) i Mal 0lREllARE Malfunctions are still listed in section 3.1.4 vs. 3.1.2 Comparing this malfunction list with NUREG 1262 is no longer valid (refbrences 3.1.2)

AnrJd

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nis Appendix is stillin the same ibrmat as Appendix B of the c!d standard l

C-r.rs'.g this Appendix B with NUREO 1262 is still applicable.

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M 21 '97 02:06PM U.C. CALLf44Y PLANT P.6 a

i CONCLUSIONS Due to the revision of both the standard and du regulatory guide many unclear testing tenni and requisesnants are now present. 'Ibe prestat NUREO 1262 is no longer a valid document if the new standard or regnistory guide are used.

A new question and answer asesion should be conducted to clarify and link questions associated widt the certinestion of einmlaHari thoill:los per 10CFR55.45, Reg Guids 1.149 and ANSI /ANS 3.5.

hrternmansa'hsts Perthrmannen tests should be de8ned and exarnplas should be provided.

that are required to be conducted annually should be reviewed and discussed c.n.-

fbr clariflestiva.

Parfanmanca tests that arc required to be conducted at a rate of 25% por year over a four year 3

period should be twiewed and discussed 1br clarl8 cation.

Perfemannes sasts to be included in the ibut year schedule should be identified.

Modificaties Tests Questions duected toward testing of modiscations snede on the simulator should also be discussed YsdGsaling.tadt should be danned and examples should be provided f

I When does a madh ien require a.

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sbould also be discussed.

t Medineatlan tests to be included in the four year ente should be identined.

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