ML20236A973
| ML20236A973 | |
| Person / Time | |
|---|---|
| Site: | San Onofre, Yankee Rowe, Big Rock Point, 05000000, Fort Saint Vrain |
| Issue date: | 10/13/1987 |
| From: | Hannon J Office of Nuclear Reactor Regulation |
| To: | Bailey I NRC |
| References | |
| NUDOCS 8710230274 | |
| Download: ML20236A973 (25) | |
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UNITED STATES o#
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NUCLEAR REGULATORY COMMISSION j
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WASHINGTON, D. C. 20555 e
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OCT 131987 I
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MEMORANDUM FOR:
Inez K. Bailey, Chief Records Services Branch FROM:
John N. Hannon, Chief
' Operator Licensing Branch, DLPQ
SUBJECT:
MINUTES OF MEETING BETWEEN NRC AND UTILITIES PROPOSING NON-ANS 3.5 SIMULATORS - SEPTEMBER'15 - 16, 1987 Please place the enclosed minutes-in the Public Document Room (PDR).
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John N. Hannon, Chief i
Operator Licensing Branch, DLPQ
Enclosure:
As stated i
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CONTACT:
i Jerry Wachtel, NRR X28508
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ADDCM 05000155 l
MINUTES OF MEETING 0F NRC WITH FOUR FACILITY LICENSEES PROPOSING TO APPLY FOR NRC APPROVAL FOR SIMULATION FACILITIES September 15 - 16, 1987
'A public meeting u s held between the NRC staff and utility representatives to' discuss the approach proposed jointly by four facility licensees to comply with NRC's requirement for simulation facilities under 10 CFR 55.45(b). The-meeting was held from 9:00 am to 5:00 pm on September 15, 1987, and from 8:30 am to 11:30 am on September 16, 1987, in Room 2242, Air Rights Building, 4550 Montgomery Avenue, Bethesda, Maryland. The meeting was conducted by the staff of. the Operator Licensing Branch (OLB)' Division'of Licensee Performance and Quality Evaluation (DLPQE) for the Commission, and by R.
Michael Kirby of Southern California Edison Company for the Utility Simulation Facility. Group (USFG). Representatives from the utilities involved, cognizant project managers, and two members of the public attended.-
An attendance list is provided as Enclosure 1.
Opening remarks by Jack Roe, Director, DLPQE, clarified the NRC position that each utility's simulation facility, regardless of its design or configuration, would be expected to fully comply with the regulation. He stated that the Commission finds that simulators are very important to safety, and that the staff's goal is to work closely with each of the four utilities to ensure that their simulation facilities meet, to the greatest extent possible, the requirements of ANSI /ANS 3.5, 1985.
John Hannon, Chief, OLB, expressed his intent that each of the four utilities 1
should be able to leave the meeting with sufficient information, on a plant-specific basis, to know what was expected of them by the staff. John also requested a briefing at the conclusion of the meeting, to include an t
identification of all open issues and a description of the actions that would be taken to resolve them.
The USFG then presented its approach to complying with the Commission's regulations.- This approach, titled " Guidance for Development of a Simulation Facility to Meet the Requirements of 10 CFR 55.45" is provided, in summary form, as Enclosure 2.
I After NRC presented its goals for non-ANS 3.5 simulators (see Enclosure 3),
the participants spent the remainder of the day working through the USFG proposal in detail. The Staff expressed a number of specific concerns to the USFG about specific aspects of the proposal (see Enclosure 4), and the USFG responded to each concern in turn.
.At the conclusion of the meeting, the Staff presented a summary of 14 key items that had been the subject of discussion, and the resolution proposed for each. This summary is provided at Enclosure 5.
Essential agreement was L
achieved in all areas but one, " Physical and Functional Fidelity." The USFG
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will perform additional research and/or analysis in order to support or l
refute its position, and will present the findings to NRC in early November, at which time it will also provide a revision to its guidance document. The staff emphasized that physical and functional fidelity would be an important consideration in an operator's acceptance of a simulation facility as an adequate training device.
E__ _ _
ENCLOSURE 1 HEETING ATTENDEES:
M.-J'. Kirby, Southern California Edison D. G. Lacroix, Consumers Power Co.
J. G. Ibarra, Southern California Edison T. L. Lorens, Southern Califorian Edison T. Henderson, Yankee Atomic Electric J. 0. Bradfude, USNRC K. Heitner, USNRC S. Willford, Public Service Company of Colorado
-K. P. Owens, Public Service Companyn of Colorado R. R. Frisch, Consumers Power Co.
R. Hall, USNRC D.-Rocssner, Iowa Electric J. W. Roe, USNRC L. Wiens, USNRC J, Wachtel, USNRC i
R. Laughery, Micro Analysis and Design l
C. Plott, Micro Analysis and Design
.J. Scholand, We:,tinghous-Training D. A. Maidrand, Yankee Atomic Electric Co.
J. N. Hannon, USNRC C. Plott, Micro Analysis and Design
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ENCLOSURE 2 j
l AGEXDA NUCLEAR REGUIATORY COMMISSION MEETING-UTILITY SIMULATION FACILITY GROUP SEPTEMBER 15-16, 1987
- 1. PRESENTATION OF USGF GOALS
- 2. OVERVIEW OF USFG DOCUMENT
- 3. REVIEY OF NRC.G0ALS AXD OBJECTIVES
- 4. OPEX ISCUSSIOX 03 COMMEXTS
- 5. XTERE ACTIONS ?EX3D UTILITIES
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NRC
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UTILITY SIMULATION FACILITY GROUP.
o FORMED TO DEVELOP GENERIC bUIDANCE TO met-1 10 CFR; 55.45 (B),(1) (I) o PLANT REFERENCE SIMULATION FACILITY GUIDANCE DOES.NOT APPLY TO USFG
' MEMBER PLANTS 0 PLANTS THAT DO NOT HAVE PLANT ~ REFERENCE SIMULATION DEVICES o METHODOLOGY TO DEVELOP OR EVALUATE NON-PLANT REFERENCE SIMULATION DEVICES
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USFG MEMBERSHIP
, 01 CONSUMERS POWER COMPANY (BIG ROCK POINT) 1 y
b oiPUBLIC SERVICE COMPANY OF COLORADO (FT. lST.
VRAIN) 1 y
o SOUTHERN CALIFORNIA EDISON COMPANY l
(SAN ONOFRE 1) o' YANKEE ATOMIC ELECTRIC COMPANY (YANKEE NUCLEAR POWER STATION)
,i o WESTINGHOUSE ELECTRIC CORP.
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i USFG CONCLUSIONS / OBSERVATIONS i
s Lo': CONSISTENT. APPROACH TO MEET 10 CFR 55.'46 i
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o _FACIC.ITYSYSTEMATI,CJDEVELOPMENT OD' SIMULATION
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- o.ENHANC$ MENT TO OPERATOR TRAINING q,,
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-o; MEETS INTENT OF, REGULATION
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. IMPLEMENTATION SCHEDULE j
- L SUBMIT' PLAN - MAY 26 1988 I
SUBMIT APPLICATION - NOVEMBER, 1990 4
MEtIS THE PLAN 4
- DESCRIPTION OF THE COMPONENTS DESCRIPTION OF PERFORMANCE TESTS o
L AFTER MAY 26, 1991 OPERATOR TESTS WILL BE CONDUCTED ONLY ON APPROVED SIMULATION FACILITIES L
,g-i OVERVIEW OF GENERIC PLAN l
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e CRITERIA l
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SIMULATION DEVICES l
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DEVELOPMENT OF SIMULATION FACILITY l
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1 CRITERIA i
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PROCEDURES 1
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STEADY STATE AND TRANSIENT MODELS e
PERFORMANCE TESTING e
OPERATING TEST METHODOLOGY
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NON PLANT REFERENCED SIMULATOR e
CONTROL ROOM MOCK-UP 1
MINIMUM SCOPE SIMULATOR e
PART TASK SIl4ULATOR I
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CRT SIMULATOR H
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.e REFERENCE PLANT l
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DEVELOPMENT OF SIMULATION FACILITY SYSTEM FUNCTION TASK ANALYSIS 1
i f SIMULATION DEVICE 1.
NPRS l
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CRM 3.
MSS FIDELITY EVALUATION 4.
PTS 5.
CRT SIM.
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REF.
PLANT l
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10 CFR 55.45-OPERATINGLTESTS DEMONSTRATE PERFORMANCE OF.THE FOLLOWING:
1)
PRE-STARTUP PROCEDURES q
2)
OPERATION BETWEEN SHUTDOWN & FULL LPOWER L3)
RESPOND TO ANNUNCIATORS
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4)
SIGNIFICANCE OF FACILITY INSTRUMENT READINGS 5)-
OBSERVE AND CONTROL OPERATING BEHAVIOR CHARACTERISTICS 6)-
CONTROL MANIPULATIONS DURING NORMAL, ABNORMAL AND EMERGENCY SITUATIONS 7)
FACILITY'S. HEAT REMOVAL SYSTEM 8)'
FACILITY'S RADIATION MONITORING SYSTEM 9)
FACILITY'S RADIATION HAZARDS AND MITIGATING ACTIONS 10)'
SIGNIFICANT RADIATION HAZARDS AND i
MITIGATING ACTIONS 11)
. KNOWLEDGE OF THE EMERGENCY PLAN, L
RESPONSIBILITIES AND DECISIONS 12)
KNOWLEDGE AND ABILITY TO ASSIGNED POSITION 13)
ABILITY TO FUNCTION WITHIN THE 1
CONTROL ROOM TEAM
l USFG CONCLUSIONS o
OPERATING TEST CAN BE PERFORMED IN ACCORDANCE WITH REGULATIONS o
. SYSTEMATIC DEVELOPMENT OF SIMULATION g
FACILITY o
USE EXISTING TRAINING DEVICES o-PROMOTE ACTIVE MAN / MACHINE INTERFACE J
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REQUESTED NRC ACTIONS i
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e' SUPPORT USFG METHODOLOGY i;
-IN PROGRESS AUDIT OF SIMULATION h
FACILITY IMPLEMENTATION NRC REGIONAL INVOLVEMENT e
REPEATED USE OF NRC EXAMINERS
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- ENCLOSURE 3L
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DVERVIEW OF NRC. GOALS FOR:NON ANS 3.5 SIMULATORS.
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THE 'NRC SOAL IS THAT ALL FACILITY LICE 0 SEES MEET THE.
REQUIREMENTS OF ANSI /ANS 3.5,11985, AS ENDORSED BY REGULATORY GUIDE I.149,LTO THE EXTENT POSSIBLE. THIS
.MEANS THAT WE ARE NOT GOING TO HOLD-YOU TO A LESSER STANDARD: BUT RATHER A DIFFERENT APPLICATION OF.THE SAME STANDARD.
2.
.THE SIMULATION FACILITY MUST CREATE AN ENVIRONMENT IN WHICH LICENSE EXAMINERS CAN EVALUATE. INDIVIDUAL s-CANDIDATE PERFORMANCE AS WELL AS TEAM INTERACTION AND COMMUNICATION UNDER DYNAMIC, REAL-TIME OPERATING d
CONDITIONS.
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OPERATORS.MUST.BE ABLE TO UTILIZE CONTROLLED.CDPIES OF m-THE REFERENCE PLANT PROCEDURES IN THE SIMULATION T ~
FACILITY.
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THE ANALYSES PERFORMED AND THE RATIONALE USED FOR THE DEVELOPMENT AND CONTINUING SUPPORT OF THE SIMULATION FACILITY HUST BE DOCUMENTED AND AVAILABLE FOR S
is INSPECTION.
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THERE MUST BE A WELL-DEFINED CONFIGURATION MANAGEMENT
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FACILITY IS KEPT CURRENT WITH REFERENCE PLANT CHANSES 7l DVER TIME.
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FOR OPERATING PLANTS,-THE EVALUATION OF-THE SIMULATION
?{ j FACILITY'S FIDELITY MUST BE BASED ON AVAILABLE PLANT OPERATING HISTORY, AND NOT MERELY BEST ESTIMATE 3; y
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ANALYSES.
7.
ANY PLANT PROCEDURE THAT MAY BE USED IN AN OPERATING TEST MUST BE CAPABLE OF BEING EXERCISED DN A SINGLE SIMULATION DEVICE.
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g, NRC CONCERNS AND QUESTIONS ABOUT USFG PROPOSAL j
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USE OF PLANT PROCEDURES, AND DEMONSTRATION OF THE
" ABILITY TO PERFORH" THE SIMULATION FACILITY SHALL USE CONTROLLED COPIES OF PLANT PROCEDURES, WITH CHANGES TAKEN ONLY AS AN EXCEPTION. YOUR DEFINITION OF PROCEDURES MAKES NO REFERENCE TO REFERENCE j
4 PLAhT PROCEDURES, NO LESS CONTROLLED COPIES, AND YOUR PRESENTATION EMPHASIZES PEN AND INK CHANGES TO PROCEDURES.
HOW DO YOU FEEL THAT THIS SUPPORTS CONDUCT OF AN OPERATING f
-]EST, ESPECIALLY SINCE YOUR DEFINITION DESCRIBES PROCEDURES p
AS THOSE THAT 'AN DPERATOR OR CANDIDATE WOULD BE REQUIRED TO p
IMPLEMENT?"
WE DISAGREE WITH YOUR APPROACH TO PROCEDURE SCOPE AND USE.
YOU SAY THAT THE CHOICE OF PROCEDURE TO BE USED ON A b e--
SIMULATOR SHOULD BE BASED ON THE SIMULATOR'S CAPABILITY. WE BELIEVE THAT THE REVERSE IS TRUE. SIMULATOR CAPABILITIES SHOULD NOT DRIVE PROCEDURE CONTENT; PROCEDURE CONTENT SHOULD DRIVE THE SIMULATOR CAPABILITIES. IF A SIMULATION FACILITY CAN'T RUN ALL PROCEDURES FOR AN OPERATING TEST, THEN IT IS NOT SATISFACTORY AND MUST BE SUPPLEMENTED. THIS IS ADDRESSED, BUT NOT STRONGLY ENDUBH, UNDER " PROCEDURE
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Fi' WHY DO YOU RECOMMEND ONLY THAT CQNSJDERATJQN OF AN f
ALTERNATIVE DEVICE UNDER THESE CIRCUMSTANCES?
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y WE DISAGREE WITH YOUR STATEMENT IN 3.6.5 THAT OPERATING TESTS, WHEN USING THE REFERENCE PLANT AS A SINULATION i
h' DEVICE, CAN ONLY CONSIST OF WALKTHROUGHS, AND THAT TASK PERFORMANCE CAN ONLY BE DISCUSSED.
WHY CAN'T CERTAIN NORMAL EVOLUTIONS, SURVEILLANCE TESTS, AND l
START-UPS AND SHUT-DOWNS BE PERFORMED ON THE PLANT?
l IN 4.2, YOU STATE THAT " PROCEDURES NOT CAPABLE OF BEING IMPLEMENTED ON ANY OTHER SIMULATION DEVICE CAN BE EXAMINED ON THE REFERENCE PLANT. THIS BEGS THE QUESTION. YOU HAVE PREVIOUSLY STATED THAT THE REFERENCE PLANT PERMITS ONLY WALKTHROUGHS. THUS THIS DISCUSSION EFFECTIVELY ELIMINATES CERTAIN OPERATING TESTS FROM BEING ACHIEVED.
IF THE OPERATOR'S " ABILITY TD PERFORM' CANNOT BE DEMONSTRATED ON THE SIMULATION FACILITY IN A REAL-TIME, INTERACTIVE 3ETTING, WHY SHOULDN'T THE PLANT BE USED FOR THESE DEMONSTRATIONS?
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2.
PHYSICAL'AND FUN;TIONALLFIDELITY_
WE DISA6RFE WITH YOUR' STATEMENT IN'2.1 THAT "THE ONLY.
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W' ACHIEVABLE FIDELITY COMPONENT WOULD BE DUPLICATION IN 1
J:tNCTION. "
THERE ARE DEGREES OF. FIDELITY - IT IS NOT ALL DR?g..
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PHYSICAL FIDELITY ON PAGE 9.' ATTEMPTS TO ACHIEVE-A MEASURE-l
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THIS IS INDICATED BY YOUR OWN DISCUSSION OF
,4 DF PHYSICAL FIDELITY SHOULD NOT BE DISMISSED. WE FEEL THAT j
CRITERIA ARE NEEDED FOR THE. TERM "SHOULD APPROXIMATE" ON 4
I PAGE 9.
PLEASE DESCRIBE YOUR RATIONALE.FOR ACCEPTING " REDUCED SCALE REPRODUCTIONS"'IN A SIMULATION DEVICE OF THE SAME SIZE AS THE REFERENCE PLANT.
j UNDER THE HEADING OF FIDELITY OF STEADY STATE AND TRANSIENT
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t-MODELS (3.1.3), WHO DEFINES WHEN A SOFTWARE MODELING CHANGE "CANNOT BE REASONABLY PURSUED," AND WHAT CRITERIA WILL BE
'g USED IN THIS DECISION (PAGE 19)?
WHY D0 YOU FEEL THAT THE 2% AND 10% CRITERIA FROM ANS 3.5 (AND USED BY YOU ELSEWHERE IN THIS DOCUMENT) DO NOT APPLY TO l
NON PLANT REFERENCED SIMULATORS (NPRS)?
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EXIST!ND VS NEW SIMULATION DEVICES YOUR INTENT AS EXPRESSED, SEEMS TO ASSUME THE USE OF ONLY EXISTING SIMULATION FACILITIES, RATHER THAN CONSIDERING THE w
POSSIBILITY OF DEVELOPING NEW ONES TO MEET THE NEED L 3l ESTABLISHED BY THE OPERATING TEST (PAGE IV).
FOR EXAMPLE, IN 4.3, WE ARE CONCERNED THAT THE TONE REPRESENTS A LIMITATION IN THE DOCUMENT AS A WHOLE. THAT IS, l
THE STATED PURFOSE OF THE FIDELITY EVALUATION IS TO f,
" IDENTIFY AND JUST!FY THE DEVIAT!DNS OF THE SIMULATION
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DEVICE FROM THE REFERENCED PLANT."
' l WHY, BEFORE ANY SUCH DEVIATIONS CAN BE JUSTIFIED, ISN'T SERIOUS CONSIDERATION 61VEN TO SEEKING ADDITIONAL DEVICES SD AS TO MINIMIZE THE EXTENT OF SUCH DEVIATIONS (PAGE 49)?
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-HARDWARE ALTERNATIVES AND INTEGRATION i
y ALTHOUGH YOU HAVE EVALUATED 6 MAJOR CATEGORIES OF SIMULATION [,,
FACILITY COMPONENTS, THERE ARE OTHER POSSIBILITIES THAT 1
COULD HAVE BEEN EXPLORED AND DISCUSSED. E.G. ENGINEERING t
f SIMULA' TORS, BASIC-PRINCIPLES TRAINERS, INTERACTIVE VIDE 0 DISK =
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SYSTEMS, ETC.
HAVE YOU EXPLORED ANY OF THESE ALTERNATIVES?
YOUR TREATMENT OF THE 6 CATEGORIES OF SIMULATION FACILITY COMPONENTS IS UNEVEN, WITH SOME RECEIVING MORE WEIGHT THAN DTHERS. THESE DIFFERENCES IN EMPHASIS SHOULD BE ADDRESSED.
i IN 4.0, WHILE ME AGREE THAT THERE IS A DISTINCTION BETWEEN DEVICES WITH ACTIVE M/M INTERFACES AND THOSE WITHOUT, WE L-DISABREE WITH YOUR CHARACTERIZATION OF REFERENCE PLANT AS E.
PASSIVE, OR THAT A CRT MUST ALWAYS BE PASSIVE. SINCE ALL OF I
THE DEVICES DISCUSSED HAVE CERTAIN LIMITATIONS THAT MUST BE
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FAY NOT BE NECESSARY.
THE DEFINITION OF NPRS IS TOO IMPRECISE, AND NEEDS CLARIFICATION (PAGE 17).
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IN 3.4.5, WHY DD YOU NOT CONSIDER A PART TASK SIMULATCR (PTS) APPLICABLE TO PERFORMANCE OF OPERATOR TASKS FOR
.: CERTAIN ABNORMAL AND EMERGENCY EVENTS 7 w
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IN 3.5.5, WE BELIEVE THAT YOUR STATEMENT ABCUT THE USE OF A Fl CRT IN CONJUNCTION WITH OTHER SIMULATION' FACILITY COMPONENTS IS ALSO AFPLICABLE TO EACH OF THESE OTHER COMPONENTS, AND THAT A SECTION ADDRESSING OVERALL INTEGRATION IS NEEDED.
IN 4.5, WE AGREE THAT "IT IS IMPORTANT THAT THE SIMULATION j
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FACILITY PROVIDE THE OPPORTUNITY TO EXAMINE ALL OF THE j
OPERATOR RESPONSES TO THE CUES LISTED IN THE OPERATIONAL CUE l
I ANALYSIS," BUT WE BELIEVE THAT THIS MUST BE ACHIEVED IN AN INTERACTIVE MODE - ONE WHICH PERMITS THE OPERATOR OR CANDIDATE TO DEMONSTRATE THE " ABILITY TO PERFORM" AS REQUIRED IN 10CFR55.45(A). FURTHER, WE DO NOT ACCEPT YOUR PREMISE THAT CONSIDERATION SHOULD BE 61VEN ONLY TO
" SIMULATION DEVICES CURRENTLY AVAILABLE OR EASILY MADE AVAILABLE."
WHY DD YOU REJECT THE THOUGHT THAT NEW DEVICES MAY BE NEEDED.
IN ORDER TO COMPLY WITH THE REGULATION?
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- 5. BEL. fSf! MATE. ANALYSIS AND BASELINE DATA RELI ANCE Oh "BEST: ESTIMATE ANALYSIS" FOR SIMULATOR ~
?nY OUTPUT IS ACCEPTABLE ONLY FOR A REFERENCE PLANT WITHOUT-1 1
'AN OPERATING HISTORY. FOR AN OPERATING PLANT, ACTUAL PLANT?'
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I DATA MUST BE USED AS BASELINE'ASAINST WHICH TO COMPARE Y
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SIMULATOR CUTPUT-(PAGE 12).
FURTHER, IF WE UNDERSTAND YOUR DISCUSSION OF METHODOLOGY, IT SEEMS THAT SINULATOR PERFORMANCE TESTING RESULTS WILL SERVE AS BASELINE DATA FOR SUBSEQUENT PERFORMANCE TESTING.'
j ANSI 3.5 REQUIRES THAT PLANT DATA (ACTUAL OR PREDICTED AS APPROPRIATE) SERVE'AS THE BASELINE FOR PERFORMANCE TESTING (PAGE 20).
CAN YOU DISCUSS THESE TWO CONCERNS?
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REAL TIME SIMULATION WE BELIEVE THAT YOUR~ ACCEPTANCE OF " APPROXIMATE REAL TIME" p e--
MAY NOT BE SATISFACTORY FOR PARTS OF THE OPERATING TEST, ESPECIALLY THOSE EXAMINING TEAM DEPENDENT AND TIME CRITICAL BEHAVIORS. DEVIATIONS FROM TRUE REAL TIME PERFORMANCE MUST BE SHOWN AS EXCEPTIONS AND JUSTIFIED.
CAN YOU' PROVIDE SUCH A JUSTIFICATION?
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HOW DD YOU PLAN TO ADDRESS THE CUES IDENTIFIED IN ThE CUE g Q.
ANALYSIS WHICH ARE TIME-DEPENDENT, WITFOUT HAVING REAL TIME
- D SIMULATION CAPABILITY?
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SKILLS AND KNOWLEDGES (of,'
HAVE YOU DEFINED THE LINK BETWEEN THE PLANT SPECIFIC SKILLS AND KNOWLEDGES AND THE RULE?
YOUR OPERATING TESTS ADDRESS THE EVALUATION OF AN OPERATORS' i
" GENERIC SKILLS." CAN YOU DESCRIBE HOW AND WHERE THE PLANT SPECIFIC SKILLS ARE EVALUATED (PAGE IV)?
I 8.
USE OF CONTROLLERS YOU PLACE GREAT EMPHASIS ON THE ROLE OF " CONTROLLERS." YET THEIR SKILLS, TRAINING, EMPLOYMENT AFFILIATION, SUPERVISION, ETC. ARE NOT DESCRIBED. PLEASE SUPPLY MORE INFORMATION ABOUT THIS CONCEPT, AND DEFEND ITS VIABLILITY, l
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9.< HUMAN; FACTORS ISSUES
?'[l WHAT CRITERIA DO YOU PLAN TO USE IN MAKING THE HUMAN FACTORS
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.y EVALUATIONS?.
- IN 3.1.'1,.WHAT'00 YOU' INTEND'TO'00 ABOUT DEVIATIONS I
r DISCOVERED'DURING THE HUMAN FACTORS REVIEW 7 DOES LISHTING (UNDER AMBIENT OPERATING ENVIRONMENT) INCLUDE
. NDRMAL AND EMERGENCY. LIGHTING (PAGE 10)?
IN 3.2.1, PLEASE COMMENT DN WHY A STATIC CONTROL ROOM MOCKUP (CRM), IF BUILT, SHOULD NOT BE AN EXACT PHYSICAL REPLICA 0F THE CONTROL ROOM.
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OPERAT10NAL CUE ANALYSIS.
WE'ARE CONFUSED BY THE SECOND PARAGRAPH ON PAGE 13. THE' t.
"0PERATIONAL CUE ANALYSIS" IS AN ANALYSIS OF BOTH THE CUES W'
AVAILABLE CN THE SIMULATOR AND THOSE REQUIRED BY REFERENCE 3.-
PLANT PROCEDURES. THIS ANALYSIS YIELDS " DIFFERENCES" WHICH MUST BE RESOLVED'BY ENHANCMENT OF THE SIMULATION OR BY.
ADDlHG'AN ADDITIONAL DEVICE TO THE SIMULATION FACILITY. BUCH
- A TOP-DOWN APPROACH - AN OVERALL INTEGRATION OF THE VARIOUS INDIVIDUAL DEVICES THAT MIGHT MAKE UP A SIMULATION FACILITY, SEEMS TO BE LACKINS IN YOUR DISCUSSION ON PAGE 13.
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WILL YOU DEFINE THE.REALTIOhSHIP.BETWEEN THE CUE ANALYSIS I
AND THE SKILLS AND KNOWLEDGES REQUIRED FOR THE OPERATORS?
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- 11. - MULTI-DISCIPLINARY. TEAM YOU INDICATE,.UNDER " ACCEPTANCE' CRITERIA" ON PAGE 20, t
THAT A MULTI-DISCIPLINARY TEAM WILL DETERMINE THE ACCEPTABILITY.OF PERFORMANCE TEST RESULTS.
WHAT CRITERIA ARE TO BE USED IN THESE ASSESSMENTS 7 WHAT ARE THE QUALIFICATIONS, TRAINING, EMPLOYMENT AFFILIATION,
~ SUPERVISION, ETC. OF THE MULTI-DISCIPLINARY TEAM 7 WHAT AUTHORITY / POWERS WILL THIS TEAM HAVE7 a
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CONFIGURATION MANAGEMENT.
I IN 4.6, YOU SEEN TO BE REFERRING TO A CONFIGURATION MANAGEMENT FROGRAM TO KEEP.THE SIMULATION FACILITY CURRENT QA WITH PLANT CHANGES. WE BELIEVE THAT YOUR COMMITTMENT MADE TO g
THESE UPGRADES IS INSUFFICIENT TO ENSURE CONTINUING
'y FIDELITY. E.G. YOU STATE THAT MODIFICATIONS TO THE SIMULATION FACILITY WILL BE MADE IN ACCORDANCE WITH EXISTING ADMINISTRATIVE CONTROLS PROCEDURES, YET SUCH PROCEDURES MAY NOT BE IN PLACE FOR SIMULATION FACILTIES. WE FEEL THAT A FORMAL, DOCUMENTED PROGRAM FOR EVALUATION AND UPGRADES, SUBJECT TO AUDIT, IS NEEDED FOR CONFIGURATION MANAGEMENT.
HAVE YOU EXFLORED A FORMAL CONFIGURATION MANAGEMENT AFFROACH?
i-13.
MISCELLANEOUS WE DO NOT UNDERSTAND YOUR INTENT IN THE DISCUSSION OF p
QUALITY ASSURANCE ON PAGE 15. SCENARIOS USED IN THE CONDUCT
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' 0F OPERATING TESTS ARE DEVELOPED BY NRC EX AMINERS.
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CAN YOU EXPLAIN THE MEANING OF THIS SECTION7 YOUR SUGGEST!0N OF USING THE SAME EXAMINERS FOR NON PLANT REFERENCED SIMULATOR EXAMS REFEATEDLY IS NOTED, BUT NOT LIKELY TO BE FEASIBLE (PAGE 15).
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..USE OF PLANT: PROCEDURES,'AND DEMONSTRATION:0F THE if m y j
" ABILITY TO PERFORM"~
Agreement'was reached on the use of controlled copies of the reference plant procedures. Pen and inkimark-ups.of the procedures will be considered deviations from the
-requirements ~a'nd shal be only made as a last-resort.'Such changes will be made'only,after-the following steps have l
been taken:
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Determination'h'as been made that the procedure l
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cannot be perf ormed on existing simulation devices.
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Upgrades to ~ eristing simulation devices, or the i
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development of. new simulation devices f or the c'
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. procedure (st or part of'the procedure (s) which cannot j
i be conducted require an excessive effort or burden in l
11 relation to the-benefit' gained.
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The use of: controllers or-similar mechanisms would
'renult in a degradation to the examination process.-
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It was agreed that it is'necessary, in order to; comply with
- 10CFR55.45 f or the simulation f acility.to provide the!
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capability,to' allow license candidates to demonstrate their Id~
" ability to perf orm"-:-the operations' required by the J
'-O procedures. This capability may include,=if so' determined by j
the facility licensee, the use of the reference plant for the performance of normal plant operations.
4 44
(;, 4 O-2.7. PHYSICAL AND FUNCTIONAL FIDELITY It was agreed that both physical and functional fidelity should be included in the simulation f acility. There was however, a distinct difference between the approaches for meeting this goal proposed by the USFG and the NRC staff. It was,the USFG's position that this goal could be met by using separate simulation devices to provide physical and functional fidelity. It was the staff's position that both should be included in a single device for a given procedure or event.
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Given this point of contention, the NRC staff requests that
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the;USFG perform the research and/or analysis to support or w
refute its position, and prisent these findings to the NRC.
The staff expects that this analysis, if performed
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j adequately, would demor. strate a requirement for some degree
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of simultaneous physical and functional fidelity.
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3.
EXISTING VS'NEW S!MUL'ATION DEVICES r
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The USFG will: include, in thelr; plan, the considerationJof obtaining or developing new simulation devices.as a higher;
,3I*f priority than the use of controllers or procedure changes.
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- 4. - HARDWARE ALTERNAT'!VEC AND INTE6 RAT 10N The USF6 will include a. general. discussion of the overall integration of the simulation facilityles in the current plan. Epocific discussions for each facilty licensee will be included in that f acility licensee's plant-specific plan to
.be submitted no later than May 26, 1988.-
5.
BEST ESTIMATE ANALYSIS AND BASELINE DATA e
Reference plant operating history data will be applied to
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simulation devices as appropriate.
Reference plant operating history data will not be applied to non-plant referenced simulators (NPRS) because they,'by definition, are not referenced to the facility' licensee's 6
i reference plant. Instead, best esticate data will be utilized to initially validate the NPRS models.
S is 6.
REAL-TIME SIMULATION
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Criteria'and evaluation procedures for determining real time
~l fidelity in both the pragmatic sense and the " computer r
,1 simulation" sense will'be developed and applied to l
F simulation devices, as appropriate, by the USFG.
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7.-
SKILLS AND KNOWLED6ES l
h' The use of the skills and knowledges as a basis for the development of the simulation facility will be more clearly defined and described in the USFB plan. Methods for showing the relationships between the skills and knowledges, the analyses to be conducted, and the regulation, will also be explored.
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Y 8.
USE)0F CONTROLLERS'
~The role, functions,'and limitations of the controllers will,..g c,,
be more clearly delineated by the USFG. Mechanisms for J
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ensuring the integrity of examinations when using l9ih controllers wil1 also be explored. Controllerqualifications'3J
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will be determined'by.the specific utilities and included,in ca 't r
their. plant-specific plans.
9.
HUMAN FACTORS ISSUES The USFG-will more clearly delineate the criteria and evaluation procedures for the human factors issues.
- 10. OPERATIONAL CUE ANALYSIS The USFB will provide more detail on the information 'and
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reference plant characteristics to be included in the fe' operational cue analysis.
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J11. MULTI-DISCIPLINARY TEAM.
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The USFG will provide inf ormation about the guidance and criteria to be used by this team, and its overall role in the development of the simulation facility. Team make-up will be addressed by the individual utilities and included in their plant-specific plans.
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- 12. CONFIGURATION MANAGEMENT i
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The USFG will provide more information on plans for
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configuration management. This will include consideration of
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such changes made'to NPRS as a result of changes made to the t
NPRS's reference plant.
- 13. MISCELLANEOUS The USFB plan will be changed to delete referencas to the utility review and approval of NRC examinations on the simulation facility, and to the repeated use of examiners.
1 14.
WORKING REALTIONSHIP It was agreed that the USF6 and the staff would maintain close working relationships during the development of the simulation facilities.
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