ML20195J592

Forwards Re Guidance for Development of Simulation Facility to Meet Requirements of 10CFR55.45, Rev 2, to Assure Proper Distribution

ML20195J592
Person / Time
Site:	Fort Saint Vrain
Issue date:	06/15/1988
From:	Heitner K Office of Nuclear Reactor Regulation
To:	Robert Williams PUBLIC SERVICE CO. OF COLORADO
References
TAC-67882, NUDOCS 8806290160
Download: ML20195J592 (4)

Text

June 15, 1988 Docket No.: 50-267 Mr. R. O. Williams, Jr.

Vice President,-Nuclear Operations Public Service Company of Colorado Post Office Box 840 Denver, Colorado 80201-0840

SUBJECT:

USFG SIMULATOR GUIDANCE (TAC NO 67082)

The enclosed letter dated June 1, 1988 was provided by the staff to the Utility Simulation Facility Group (USFG) Chairman. We are providing this copy directly to you to assure proper distribution.

Sincerely,

/s/

Venneth L. Heitner, Project Manager Project Directorate - IV Division of Reactor Projects - III, IV, V and Special Projects

Enclosure:

As stated cc w/ enclosure:

See next page DISTRIBUTION ,

iDocket: File ? J

-NRC & Local PDRs PD4 R/F DCrutchfield LRubenstein PNoonan' KHeitner OGC-Rockville EJordan JPartlow ACRS(10)

Plant File PDIV:L PDIV:PM PNoona KHeitner:jc 06/g/88 06/15 /88 8806290160 800615 PDR ADOCK 05000267 P PDR

June 15,1988

- Docket No.: 50-267 Mr. R. O. Williams, Jr.

Vice President, Nuclear Operations Public Service Company of Colorado Post Office Box 840 Denver, Colorado 80201-0840

SUBJECT:

USFG SIMULATOR GUIDANCE (TAC NO. 67882)

The enclosed letter dated June 1, 1988 was provided by the staff to the Utility Simulation Facility Group (USFG) Chainnan. We are providing this copy directly to you to assure proper distribution.

Sincerely,

/s/

Kenneth L. Heitner, Project Manager Project Directorate - IV Division of Reactor Projects - III, IV, Y and Special Projects

Enclosure:

As stated cc w/ enclosure:

See next page DISTRIBUTION Docket File NRC & Local PDRs PD4 R/F DCrutchfield LRubenstein PNoonan KHeitner OGC-Rockville EJordan JPartlow ACRS (10)

Plant File PDIV:L PDIV:PM PNoona KHeilner:jc 06/c/88 06/l5 /88

1. o g UNITED STATES 8 a NUCLEAR REGULATORY COMMISSION

-s y ;j WASHING TON, D. C. 20655 g ,/ June 15,1988 Docket No.: 50-267 Mr. R. O. Williams, Jr.

Vice President, Nuclear Operations Public Service Company of Colorado Post Office Box 840 Denver, Colorado 80201-0840

SUBJECT:

USFG SIMULATOR GUIDANCE (TAC NO. 67882)

The enclosed letter dated June 1, 1988 was provided by the staff to the Utility Simulation Facility Group (USFG) Chairman. We are providing this copy directly to you to assure proper distribution.

Sincerely,

%j $.. un w Kenneth L. Heitner, Project Manager Project Directcrate - IV Division of Reactor Projects - III, IV, V and Special Projects

Enclosure:

As stated cc w/ enclosure:

See next page l

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s- Mr. R. O. Williams, Jr.

Public Service Company of Colorado Fort St. Vrain cc:

Mr. D. W. Warembourg, Manager Albert J. Hazie, Director Nuclear Engineering Division Padiation Control Division Public Service Corrpany Department of Health of Colorado 4210 East lith Avenue P. O. Box 840 Denver, Colorado 80220 Denver, Colorado 80201-0840 Mr. David Alberstein, 14/15SA Mr. R. O. Williams, Jr. , Acting Manager GA Technologies, Inc. Nuclear Productier Division Post Office Box 85608 Public Service Company of Colorado San Diege, California 92138 16805 Weld County Road 19-1/2 Platteville, Colorado 00651 Mr. H. L. Brey, Manager Nuclear Licensing and Fuel Division Mr. P. F. Tomlinson, Manager Public Service Company of Colorado Cuclity Assurance Division P. O. Box 840 Public Service Company cf Colorado Denver, Colorado 802C1-0840 16805 Weld County Road 19-1/2 Platteville, Colorado 80651 Senior Resident Inspector U.S. Luclear Regulatory Cornission Nr. R. F. Valker P. O. Box 640 Public Service Corpany of Colorado Platteville, Colorade PC651 Post Office Box 840 Denver, Colorado 80201-0840 Kelley, Stansfield 1, O'Donnell Public Service Ceapany BuiMino Comitment Control Progran Recm 500 Coordinator 550 15th Street Public Service Company of Colcrade Danver, Colorado .80202 2420 W. 26th Ave. Suite 100-D Denver, Colorado 80211 ,

Regional Administrator, Region IV l U.S. Nuclear Regulatory Cervission 611 Ryan Plaza Drive, Suite 10C0 Arlingtcn, Texas 76011 Chairman, Board of County Comissioners of Veld County, Colorado Greeley, Colorado 80631 l

Regional Representative l

Padiation Programs Environmental Protection Agency l 1 Denver Place

, 999 18th Street, Suite 1300

! Denver, Colorado 80202-2413 l

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^g UNITED STATES 8 n NUCLEAR REGULATORY COMMISSION h *

$ WASHING TON D. C. 20555 k...../ JUN 011988 Mr. Michael J. Kirby, Chairman Utility Simulation Facility Group Southern California Edison Company P. O. Bcx 800 2244 Walnut Grove Avenue Rosemead, Crlifornia 91770 Gentlemen:

Subject:

Docket Nos. 50-29, 50-155, 50-206 and 50-267 USFG Sinulator Guidance .,

Yankee Nuclear Power Station Big Rock Peirt Plant San Onofre Nuclear Generating Station, Unit 1 Ft. St. Vrain, Unit 1

References:

(A) "Guidance for Development of a Simulation Facility to Meet the Requirements of 10CFR55.45, Revision 2" dated March 1960.

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

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

referencedat(A)above.

Revision 2 satisfactorily addresses the majority of questions and concerns raised by the Staff during our meeting of December 7, 1987, the minutes of which are referenced at (B) above. Therefore, the Staff considers Revision 2 l 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 i 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 I 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 development of its simulation facility.

Sincerely,

• /

l i) 4 W

.' John N. Hannen, Chief Cperator Licensing Branch Division of Licensee Performance and Quality Evaluation Office of Nuclear Reactor Regulatior.

Enclosures:

As stated l

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. ENCLOSURE 1 The following issues, raised by the staff in the December 7,1967 meetirig (Reference B), have not been satisfactorily addressed in Revision 2. Each USFG member sFt11 address each of these issues in its plant-specific application for NRC approval of its simulation 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 (E) above, and in this enclosure.

Issue 1 - PHYSICAL AND FUNCTIONAL FIDELITY.

Er. closure 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 USFG. They continue tc rake statements, such as those on pages 21 and 30, that an operator's ' adequate cualifications,' and ' procedures' can be demonstrated on the actual plant if they cannot be done on an interactive simulation device, ard that the plant itself can serve as a full or partial simulation facility."

C. The hRC's second paragraph requested the USFG to perform research and artlysis to support their position - they have ignored this while runtinuing to support that position. They have neither done, nor agreed te do, such an analysis, Revision 2 addresses the issue of physical and functionti fidelity in several places, specifically on pages 3, 9, 16, 21 and 37. Unfortunately, the dccument has essentially retained the previous USFG position, which resulted in the r.ontentior; described in the minutes of the Dececher 7th meeting.

Further, item (B) above, which requested that an analysis be performed by USFG to support its position, has still nat 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 uce 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 that 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

procedures. No modifications to these procedures are required..." This is

• inconsistent with the staff's position expressed at the December 7th reeting, which continues in force. It is therefore expected that each utility will address this concern in its plant-specific application for approval.

Issue 2 - FIDELITY EVALUATION AND ASSESSMENT OF DEVIATIONS.

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

The USFG will take a new look at this section, the formulas used, and the criterion values established.

While the USFG has indeed reevaluated its methodology and criterion for assessing deviations, the result remains unsatisfactory. The weighting scheme itself is reasonable, but the acceptability criteria are net. Specifically, a case of "high prcbability to error" or "high probelility to confuse" would be masked if either probability occurred alone. For example, if either probtbility 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 will be required to present an acceptable criterion in its plant-specific application.

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

In Enclosure 4 to Reference (B), under the heading GEhERAL ISSUES, the staff asked the USFG to add, in its subsequent revision, definitions for terms such as sh611, should, may, must, will, etc. This has not been done, and it will be required for inclusion in each individual utility's application for approval.

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ENCLOSURE 2 The following represent specific concerns identified by the staf f 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 utilities, but the staff requests that they be addressed if it is decided to issue another revision to the document, or if the iridividual utilities incorporate the document into their plant-specific cpplications for NRC approval. All references below are to Revision 2.

1. Page 70, Section 4.6.2.

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

2. Page 72, Section 5.0, Second Item.

The purpose of an acceptable simulation facility is to evaluate a candidate's plant-specific, not generic, skills and knowledges,.

3. Page 72, Section 5.0, Third Item.

Reference plant walk-throughs are not acceptable as alternatives to the evaluation of specific skills and knowledges on a simulation device.

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4. Page 73, Section 6.0.

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

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