ML20155B732

Comments on Review of Mar 1988 Rev 2 to Guidance for Development of Simulation Facility to Meet Requirements of 10CFR55.45. Rev Satisfactorily Addresses Majority of Questions & Concerns Raised During 871207 Meeting.W/Encl

ML20155B732
Person / Time
Site:	San Onofre, Yankee Rowe, Big Rock Point, 05000000, Fort Saint Vrain
Issue date:	06/01/1988
From:	Hannon J Office of Nuclear Reactor Regulation
To:	Kirby M SOUTHERN CALIFORNIA EDISON CO., UTILITY SIMULATION FACILITY GROUP
Shared Package
ML20155B735	List: ML20155B732 ML20155G932
References
NUDOCS 8806130317
Download: ML20155B732 (6)

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ta asc oq jeg UNITED STATES NUCLEAR REGULATORY COMMISSION

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JUN 011968 l

Mr. Michael J. Kirby, Chairman Utility Simulation Facility Group Southern California Edison Company P. O. Bcx 800 2244 Walnut Grove Avenue Rosemead, California 91770 Gentlemen:

Subject:

Docket Nos. 50-29, 50-155, 50-206 and 50-267 USFG Sinulator Guidance tankee Nuclear Power Station -

Big Rock Point Plant San Onofre Nuclear Generating Station, Unit 1 ft. St. Vrain, Unit 1

' Reierences: (A) "Guidance for Development of a Simulation Facility to Meet the Requirements of 10CFR55.45, Revision 2" dated March 1988.

(B) "Minutes of Followup Meeting Between NRC and Utilities Proposing Non-ANS 3.5 Simulators Held December 7, 1987."

We have completed our review of the document (henceforth called "Revision 2")

referenced at (A) above.

Revision 2 satisfactorily addresses the majority of questiers and concerns raised by the Staff durin our meeting of December 7, 1987, the minutes of whic.harereferencedat(g)above.B Therefore, the Staff considers Revision 2 to be an acceptable baseline from which each member utility of the Utility Simulation Facility Group (USFG) can proceed with the development of its own plant-specific plan and subsequent application for approval for a simulation facility in accordance with 10 CFR 55.45(b)(2)(ii).

There remain, however, three specific areas in which the staff does not find Revision 2 to be acceptable. These issues are discussed in Enclosure 1 to this letter. Each USFG member utility must address each of these concerns in its plant-specific application for NRC approval of its simulation facility.

Such applications for approval are due, under the provisions of 10CFR55.45(b)(2)(ii)nolaterthanNovember 26, 1990. NRC approval will not be granted to an individual utility if its application fails to address each of these concerns in a manner satisfactory to the Staff, as documented in Enclosure 4 to the meeting minutes referenced at (B) above.

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Michael J. Kirby Enclosure 2 to this letter itemizes several specific concerns raised by the Staff as a result of its review of Revision 2. There is no requirement for a further revision to this document. However, if the USFG does revise the document, the Staff requests that these concerns be addressed.

We apprecicte the positive approach and leadership shown by the members of the USFG in responding to the requirements of 10 CFR 55. We look forward to a cooperative working relationship with each individual member utility as each moves forward with the developtrent of its simulation facility.

Sincerely,

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6' John N. Hannon, Chief

/ Operator Licensing Branch Division of Licensee Performance and Quality Evaluation

, Office of Nuclear Reactor Regulation

Enclosures:

As stated

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• ENCLOSURE 1 r

C The following issues, raised by the staff in the December 7, 1987 meeting (Reference B), have not been satisfactorily addressed in Revision 2. Each USFG member shtl1 address each of these issues in its plant-specific application for NRC approval of its silaulation facility in accordance with 10CFR55.45(b)(2)(ii). NRC approval will not be granted unless each of these issues is addressed in a manner satisfactory to the staff as documented in Enclosure 4 to the meeting minutes referenced at (B) above, and in this enclosure.

Issue 1 - PHYSICAL AND FUNCTIONAL FIDELITY.

Enclosure 4 to Reference (B), "NRC Concerns with Revised USFG Proposal and Agreements Reached At December 7, 1987 Meeting," states, at item (2):

A. This remains the major point of contention between NRC and VSFG. They continue to make statements, such as those on pages 21 and 30, that an operator's ' adequate qualifications,' and ' procedures' can be demonstrated on the actual plant if they cannot be done on an interactive

, simulation device, and that the plant itself can serve as a full or partial simulation facility."

B. The NRC's second paragraph requested the USFG to perform research and analysis to support their position - they have ignored this while continuing to support that position. They have neither done, nor agreed to do, such an analysis.

Revision 2 addresses the issue of physical and functional fidelity in several places, specifically on pages 3, 9, 16, 21 and 37. Unfortunately, the document has essentially retained the previous USFG position, which resulted in the contention described in the minutes of the December 7th meeting.

Further, item (B) above, which requested that an analysis be performed by USFG to support its position, has still not been addressed.

Accordingly, each individual utility member of the USFG must address this issue, including performance of the analysis to support its conclusion, in its plant specific application for NRC approval.

Closely related to this issue is that of the use of the reference plant.

Enclosure 4 to Reference (B), under the heading "General Issues," states:

The staff reminded the USFG that it considers the use of the reference plant, when serving as a simulation facility, to mean actual performance, not simply a walk-through; and that this position has implications for the inability to conduct operating examinations when the plant is shut down.

The discussion on page 70 of Revision 2 indicates thi.t the USFG continues to consider the use of the reference plant as essentially a device for verbal discussion and a walk-through. This is clear from statements such as: "Use of the Reference Plant as a simulation device allows usage of all of the

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procedures. No modifications to these procedures are required..."' This is inconsit,hr.t kith the staff's position expressed at the December 7th reeting, which addressco'itinues this concern in force. . Itisthereforeexpectedthateachutilitywill/

in'its plant-specific application for approval. ,

f Issue 2 - FIDELITY EVAL 11ATION AND ASSESSMENT OF DEVIATIONS.

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Enclosure 4'to Reference (B) states, under tht category titled NEW ISSUE:

The USFG will take a new look at this section[the formulas used, and the criterion valres estflyshea. i i

While the USN bis 'indeed reevaludIdd its me.9 odoTeoy and criterion for assessing deviations, the result remains unst tisfactory. The weighting scheme f

itselfisreasonable,buttheacceptabyityc'iteriaarenet. Specifically, a case of "nigh prcbability to error" of 'high probetility to confuse" would be masked if either probability occurred'alone. For example, if either probability was 10, and the other. values were each 0, then the weighted rating of 2.5 would be considered acceptable under the ,USFG scheme because it was below the chosen criterion ~of 4.0. The staff finds this to be /

unacceptable, and each utility w'ill be required to pre @;t an acceptable criterion in its plant-specific application. .

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Issue 3 - USE OF SHALL, SHOULD, MAY, ETC.\ ,

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In Encfosure 4 to Reference (B), under the hdading GENERAL ISSUES, the staff asked the USFG f.u ado, in its subsequent revision, definitions for terms si.ch as sh611, shoeid, nay, must, will, etc. This has not been done, and it wi'.1 be required f ar inclusion '

in each individual utility's application for approval. l '

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EtCLOSURE 2 The following represent specific cencerns identified by the staff as a result of its review of Revision 2. There is no requirement that these concerns be addressed by the USFG or by the individual member culities, but the staff requests that they be addressed if it is decided to issue another revision to the document, or if the individual utilitics incerunte the document into thein plant-specific applications for NRC approval. All references below are

,,to Ra2!sion 2.

1. Page 70, Section 4.6.2.

The reference plant does not allow usage of all of the procedures (see item 3 below).

2. Page 72, Section 5.0, Second item.

[/ The purpose of an acceptable simulation facility is to evaluate a candiftte'7, plant-specific, not generic, skills and knowledges.

3. Page 72, Section 5.0, Thir'd item.

Referenceplan\; walk-throughsarenotacceptableasalternativestothe evaluation of specific skills and knowledges on a simulation device.

'4. Page 73, Section 6.0.

Reference should be made to the final, published version of NUREG-1258, dated Gerember 1987.

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