ML20247D620

Informs That 881025 Submittal Re Simulator Certification Does Not Provide Basis to Support 10CFR55.45(b) Compliance. Timely Nature of Initial Simulation Facility Certification Should Allow Time for Completion Prior to Mar 1991

ML20247D620
Person / Time
Site:	Vogtle
Issue date:	05/16/1989
From:	Hopkins J Office of Nuclear Reactor Regulation
To:	Hairston W GEORGIA POWER CO.
References
TAC-72976, TAC-72977, NUDOCS 8905250510
Download: ML20247D620 (7)

Text

Fy.,

preg g[%,

UNITED STATES

[C

.y g

NUCLEAR REGULATORY COMMISSION i

7.

j W ASHINGTON, D. C. 20655 k**,*/

May 16, 1989 Docket Nos.:

50-424 and 50-425 Mr. W. G. Hairston, III Senior Vice President -

Nuclear Operations Georgia Power Company P.O. Box 1295 Birmingham, Alabama 35201

SUBJECT:

V0GTLE UNITS 1/2 - SIMULATOR CERTIFICATION (TACS 72976/72977)

The staff has conpleted its review of your initial Simulator Certification submittal for Vogtle Units 1 and 2 dated October 25, 1988. We appreciate your early submittal, long before the required date of March 1991.

However, the review has found that there is not currently an adequate basis to support compliance with 10 CFR 55.45(b). The enclosure provides the details which lead to this finding as well as guidance as to what additional information should be provided.- Also, your letter dated April 28, 1989, requesting an extension for the annual simulator test is moot and will not be acted on by the NRC staff.

The Vogtle certification will be considered incomplete until the planned modifications to the core, reactor coolant system, steam generator, and containment models are complete and additional performance test abstracts are submitted which document that the simulator demonstrates expected plant response. We currently intend to continue administering exams as we have been.

If the examiners determine, however, that it is extremely difficult or not possible to conduct valid operating tests, then an on-site inspection will be conducted. The on-site inspection may lead to terminating the further conduct of operating tests for either initial or requalification examinations until the simulator models are upgr.eded.

As your certification is considered incomplete, your license applications will continue to require full documentation of the applicant's qualifications and training in accordance with 10 CFR i

8905250510 890516 DR ADOCK 0500 4

l l

Mr. W. G. Hairston, III May 16, 1989 55.31(a)(4). Fortunately, the timely nature of your initial sinulation facility certification should allow more than adequate time for completion prior to March 1991.

Contact me if you have any questions.

Sincerely, t

M Jon B. Hopkins, Projeci. Manager Project Directorate 11-3 Division of Reactor Projects - I/II Office of Nuclear Reactor Regulation

Enclosure:

As stated cc w/ enc 1: See next page

1.

Mr. W. G. Hairston, III

-2'

'May 16,'1989 55.31(a)(4).

Fortunately, the timely nature of your initial simlation facility -

certification should allow more than adequate time' for completion prior to -

March 1991.

Ccntact me ~if you have any questions.

Sincerely,

/s/

Jon B. Hopkins, Project Manager Project Directorate II-3 Division of Reactor Projects - 1/II Office of Nuclear Reactor.Rt.gulation

Enclosure:

As stated

. DISTRIBUTION:

DocketJ1]e; S. Varge 14-H-3 J. Hopkins NRC PDR G. Lainas 14-H-3 OGC 15-B-18 D. Matthews 14-H-25 E. Jordan MNBB-3302 Local POR tNf/Jkied:

14-H-25 B. Grimes 9-A-2 PDII-3 Reading

- N. K.. Hunemuller 10-D-18 K. ' Perkins 10-0-18 ACRS(10.)

P 315

• P 3

• PDII-3

• 0GC 3

M JHopkins:1s CBarth MDMatthews 04/28/89 04/28/89 05/03/89 0 05//p /89

• See Previous conci!rrence

Mr. W C. Hairston, III Georgia Power Company Vogtle Electric Generating Plant cc:

Mr. J. A. Bailey Resident Inspector V

Manager - Licensing Nuclear Regulatory Commission I

Georgia Power Company P.O. Box 572 P.O. Sox 1295 Waynesboro, Georgia 30830 Birmin9bm, Alabama 35201 James E. Joiner, Esq.

Bruce W. Churchill, Esq.

Troutmen, Sanders, Lockerman, Shaw, Pittman, Potts and Trowbridge

& Ashmore 2300 N Street, N.W.

1400 Candler Building Washington, D.C. 20037 127 Peachtree Street, N.E.

Atlanta, Georgia 30303 Mr. G. Bockhold, Jr.

General Manager, Nuclear Operations Mr. R. P. Mcdonald Georgia Power Company Executive Vice President P.O. Box 1600 Nuclear Operations Waynesboro, Georgia 30830 Georgia Power Company P.O. Box 1295 Regional Administrator, Region II Birmingham, Alabama 35201 U.S. Nuclear Regulatory Comission 101 Marietta Street, N.W., Suite 2900 Mr. J. Leonard Ledbetter, Director Atlant, Georgia 30323 Environmental Protection Division Department of Natural Resources Office of the County Commissioner 205 Butler Street, S.E., Suite 1252 Burke County Commission Waynesboro, Georgia 30830 Attorney General Law Department Office of Planning and Budget 132 Judicial Building Room 615B Atlanta, Georgia 30334 270 Washington Street, S.W.

Atlanta, Georgia 30334 Mr. Alan R. Herdt, Chief Project Branch #3 Mr. C. K. McCoy U.S. Nuclear Regulatory Comission Vice President - Nuclear 101 Marietta Street, NW, Suite 2900 Georgia Power Company Atlanta, Georgia 30323 P.O. Box 1295 Birmingham, Alabama 35201

l

~

d ENCLOSURE 1.

10 CFR 55.45(b)(5) requires a certified simulator to meet the definition of a " plant referenced simulator" given in 10 CFR 55.4 which states:

"" Plant-referenced simulator" means a simulator modeling the systems of tha reference plant with which the operator interfaces in the control i

room, including operating consoles, and which permits use of the reference plant's procedures. A plant-referenced simulator demonstrates expected plant response to operator input, and to normal, transient, and accident conditions to which the simulator has been designed to respond."

The Discrepancy Resolution Worksheets (DRWs) included in Attachment 2 to the Unit 1 Form 474 indicate that the Vogtle simulator does not demonstrate expected plant response and will not do so until the Core, Reactor Coolant System, Steam Generator, and Containment models are replaced.

This point is illustrated by the following excerpts from 20 of the DRWs, all of which should be corrected by the model upgrades:

a) Test: 05-01 (LOCA Significant SG Leaks)

1) DRW 1 "Significant impact - simulator is very unrepresentative of expected plant response."

2) DRW 2 "Significant impact - level responds too quickly, leading trainee to take inappropriate action."

3) DRW 3 "Significant impact - may lead trainee to misdiagnose transient."

b) Test: 05-02 (LOCA:

InsideContainment)

1) DRW 4 "Significant impact

)

a)majorlossofcreditability b) will not allow proper implementation of E0P's."

2) DRW 59 "Significant impact - Unrealistic model which decreases simulator credibility."

c)

Test: 05-18 (Loss of all Feedwater)

1) DRW 38 "Significant impact - RX trips may occur in the plant due to students not practicing control of SG 1evels with shrink / swell."

2) DRW 42 "Significant impact - loss of FW transient on simulator would confuse students for one in the plant."

3) DRW 43 "Significant imp (RCS) heat up/repressurization and act - Allows to much operator tim?

prior to plant feed / bled method of cooling."

(-

. d)

Test: 05-24 (Failure in Reactor Coolant Pressure and Volume Control System)

1) FRW 37 "Significant impact - will teach students that a fast refill of the pressurizer will have little effect on pressure and could result in causing overpressure protection to actuate."

(e) Te:t: 05-25B (MS Bypass Valve Header Rupture)

1) DRW 20 "Significant impact - improper training on steam generator dynamics."

2) DRW 21 "Significant impact - possible misdiagnosis as LOCA."

3) DRW 22 "Significant im act - may lead to misdiagnosis (i.e.,

it is a SV leak."

(f) Test: 05-26 (FW line 2 Rupture Inside Containment)

1) ORW 31 "Following feedline isolation #2 SG WR level began increasing and eventually passed the level in the unaffected SG.

(Should have decreased to zero)."

(g) Test: 05-29A(LoopPressTransmitterPT438FailsHigh)

1) DRW 28 "With loss of shutdown cooling, temperature goes down (shouldincrease)." "Significant impact - does not properly portray RCS dynamics."

(h) Test: 05-30B (Train A Cont Spray Auto Actuation Failure)

1) DRW 34 "SG #1 pressure decreased to O psig following Rx trip and SI. This test was initiated by inserting a cold leg rupture on Loop 3.

(Should have followed SG pressure forunaffectedSG's)." "Significant impact - could lead operators to misdiagnose a 1.oca."

i)

Test: 06-01(PlantStartuptoHotStandby)

1) DRW 49 "SG pressure oscillates significantly more than it should when compared to SG temperature and RCS temperature."

"Significant impact - Very hard to teach plant control at low power levels when SG's are so unstable. A majority of plant trips occur due to SG 1evel problems and simulator should prepare students to effectively handle the SG's."

j)

Test: 07-01 (Manual Rx Trip)

1) DRW 39 "Significant impact - may cause incorrect response by I

operators to an uncomplicated reactor trip."

(

, ~

k)

Test: 07-02 (Simultaneous Trip of All Feedwater Pumps)

1) ORW 44 "Significant impact - may cause inadequate operator response to pressurizer level transient in plant."

b 1)

Test: 07-06 (Turbine Trip w/s Rx Trip 9 30%)

1) DRW 50 "Significant impact - improper training of operators on pressurizer response to insurges and outsurges."

m)

Test: 07-09 (Unisolable Main Steam Line Rupture IC)

1) DRW 52 "Significant impact - Student cannot properly identify the affected SG."

Upon completion of the model upgrades simulator performance testing should be conducted in accordance with ANSI /ANS-3.5-1985 Section 5.4.1 (2) as these are simulator design changes resulting "in significant simulator configuration or performance variations." Performance test abstracts from this testing should be sub"*tted documenting that the simulator demonstrates expected plani. response.

2.

ANSI /ANS-3.5-1985, Section 5.4.1, " Simulator Performance Testing,"

requires testing within the requirements of Section 4 (Performance Criteria)." One of the criteria in Section 4 is that " administrative controls of other means shall be provided to alert the instructor when certain parameters approach values indicative of events beyond the implemented model or known plant behavior."

It appears that no testing was performed to ensure that this criteria was met.

Performance test abstracts for such testing, or justification for exception to this requirement, should be provided.

3.

A description of the baseline data used to determine fidelity to the reference plant was not provided.

It appears that the baseline data used consisted largely of the judgement of a panel of experts; however, there is very little documentation of their review. Additional documentation of their review should be provided. This documentation may include such items as the makeup and qualifications of the panel and any differing professional opinions as to the outcome of tha tests.

4.

It is not clear that the four test procedures identified in the abstract f

" Surveillance Testing on Safety Equipment or Systems (06-08)" are j

inclusive of all " Operator conducted surveillance testing on safety-related equipment or systems" as required by ANSI /ANS - 3.5 -1985, Section3.1.1, item (10). Confirmation that the simulator is capable of meeting this requirement, or justification for exception, should be l

provided.

I l

- - - -