NRC-2010-0187, Comment (14) of Gary Degraw on NRC-2010-0187-0001, Draft Regulatory Guide: Issuance, Availability
| ML102720829 | |
| Person / Time | |
|---|---|
| Site: | River Bend  |
| Issue date: | 08/25/2010 |
| From: | Degraw G Entergy Corp |
| To: | Rulemaking, Directives, and Editing Branch |
| References | |
| 75FR29785 00014, DG-1248, NRC-2010-0187-0001 | |
| Download: ML102720829 (22) | |
Text
Mendiola, Doris
Subject:
FW: DG-1248 Comments Attachments: DG1248 Comments.pdf j75-fAJ c~ ~% ~2 &
From: DEGRAW, GARY D [1]
Sent: Wednesday, August 25, 2010 6:02 PM To: Carpenter, Robert Cc: Vick, Lawrence
Subject:
DG-1248 Comments Mr. Carpenter,
-71 Attached are River Bend Station comments on the NRC Draft Guide DG-1248. C-ý (T-I Thank You, C/D Gary Degraw Supt., Simulator and Training Support River Bend Station (225)378-3527
.qde raw(@enterqy.com
<<DG1248 Comments.pdf>>
sav S-E- 1ýe YJ elý Az' -2~ 2' 1 6I~-~- ~ y~7L2~< (r)
River Bend Station Comments DRAFT REGULATORY GUIDE DG-1248 Page 3, 2 nd N/A The commission should state Add to the 2 nd paragraph: "The paragraph under; that it recognizes exceptions commission recognizes exceptions "Plant-Referenced taken on initial certification of taken on initial certification of Simulator simulation facilities. simulation facilities; these exceptions Performance may be carried forward as applicable Testing" to the ANS-3.5-2009 Standard."
2 Page 3, 3rd Additionally, the This comment implies that the Add to the 3 rd paragraph: "Facility paragraph under; Commission's regulations only testing acceptance criteria licensees that.propose to use a plant-
"Plant-Referenced in 10 CFR 55.46(c)(2) for experience requirement referenced simulator to meet the Simulator /require that facility criteria are items (1) and (2) of experience requirements in 10 CFR Performance licensees that propose to use this paragraph. 55.3 1(a)(5) shall validate the Testing" a plant-referenced simulator performance of the simulator via to meet the experience The regulator should reference simulator reactor core performance requirements in 10 CFR scenario-based testing testing and scenario-based testing 55.3 1(a)(5) ensure that (1) acceptance criteria in Section utilizing acceptance criteria in the plant-referenced 4.4.3.2 or clearly state any sections 4.4.3.2 and 4.4.3.3 of the simulator utilizes models additional acceptance criteria in Standard, respectively."
relating to nuclear and the regulatory guide. This thermal-hydraulic comment also applies to DG characteristics that replicate 1248 Appendix B, Item 5 for the the most recent core load in experience requirement.
the nuclear power reference plant for which a license is being sought, and (2) simulator fidelity has been demonstrated so that significant control Page 1 of 21
River Bend Station Comments DRAFT REGULATORY GUIDE DG-1248 Item' Reference I DG-e248 - . ProposedRevision.
_ _ _i OriginalText Po eDGRevisio manipulations are completed without procedural exceptions, simulator performance exceptions, or deviation from the approved training scenario sequence.
i -I. +
3 Page 4, 2 nd On December 8, 2009, NEI The last sentence should be On December 8, 2009, NEI provided paragraph under; provided for NRC review deleted from this paragraph. It for NRC review and endorsement of NEI 09-09, and endorsement of its implies a "back fit" from the its industry guidance document, NEI-
"Nuclear Power industry guidance proposed revision 4 of 09-09, Revision 1, "Nuclear Power Plant-Referenced document, NEI-09-09, Regulatory Guide 1.149 to a Plant-Referenced Simulator Scenario Simulator Scenario Revision 1, "Nuclear Power previous edition of the ANS-3.5 Based Testing Methodology" (Ref.
Based Testing Plant-Referenced Simulator Standard. 10), which provides an equitable and Methodology" Scenario Based Testing consistent approach and methodology Methodology" (Ref, 10), for the conduct and documentation of which provides an equitable SBT, as described in Section 4.4.3.2, and consistent approach and "Simulator Scenario-Based Testing,"
methodology for the of ANSI/ANS-3.5-2009. NEIT 0 09, conduct and documentation Revision A1,2also supports Seetien
'1 "Sm.ihtr L..'nri.
"H'e. i of SBT, as described in Section 4.4.3.2, "Simulator " - XTC'T/ AXTC ' I C 1 AflO
- ... 51 - ý -- .1- - XI -
Scenario-Based Testing,"
NEI-09-09, Revision 1, also supports Section 4.4.3.2, "Simulator Scenario-Page 2 of 21
River Bend Station Comments DRAFT REGULATORY GUIDE DG-1248 Based Testing," of ANSI/ANS-3.5-1998.
4 Page 5, Section 2.b b. In regard to Section 3.1.4, This paragraph should be I-. T . . . , . .. *- -1 1 AI under; NEI 09-09, "Malfunctions," simulation deleted from this section. This "Malfunctiens," simulation facility "NRC Acceptance facility licensees should paragraph is not consistent with licensees should demionstr.ate that IJ. 0111*] 1 JI ICh11%J Lt[.PSJL
,&l/,J~*1. LAfl
. C LT,*I 1 and Endorsement of demonstrate that the records retention they have eondueted per-formance ANSI/ANS-3.5- they have conducted requirement in testing of the malfunctiens listed in 2009" performance testing of the 10CFR55.46(d)(1) which states the stanmdar-d, as applicable. ten the malfunctions listed in the that "The results of performance design of the r.efer.ence pla tet standard, as applicable to tests must be retained for four onee in the life of the simulation the years after the completion of facility and that the associated test design of the reference each performance test or until plant, at least once in the superseded by updated test testFesilts. impfui ae tetn of'~
tL life of the simulation facility results." mnalfunction has beent and that the associated test copee mnore than once, then the documentation includes the The CFR reference allows licensee need only retain the latest ts completed test results. If malfunction tests to be discarded r-esults. The staff rcceognizs performance testing of a after four years. There is no that sim.ulator ... fun .tion test results malfunction has been requirement to maintain may be r-etainied longer than 4 years.
completed more than once, performance tests records longer after the completion of each,-
then the licensee need only than four years. malfunction test. Therefore, retain the latest test results. regardless of how long it has been The staff recognizes Additionally, the NRC has since the malfunction test has been that simulator malfunction previously inspected the results performed, the NRC expect-s test results may be retained of the ANS-3.5-1985 Standard simi~ulation facility licensees to make longer than 4 years after the malfunction testing and the results of these nalfunetion completion of each approved initial certification of performance tests available for NRC Page 3 of 21
River Bend Station Comments DRAFT REGULATORY GUIDE DG-1248 Item RfrneD-28Comment - Proposed Revision item! -Reference . DG-1248 Original Text- .. -to DG-1248 malfunction test. Therefore, the simulators which included review, either-before, or-concurrent regardless of how long it the malfunction tests. with, the preparation for each.
has been since the operating test or-r*e*ualification malfunction test has been p-ca spee.tin.
performed, the NRC expects simulation facility licensees to make the results of these malfunction performance tests available for NRC review, either before, or concurrent with, the preparation for each operating test or requalification program inspection.
5 Page 6, Section 2.d d. In regard to Section Delete "(such as just-in time d. In regard to Section 3.4.3.2, under; NEI 09-09, 3.4.3.2, "Simulator training and routine plant system "Simulator Scenario-Based Testing,"
"NRC Acceptance Scenario-Based Testing," and equipment startup and simulation facility licensees and Endorsement of simulation facility licensees shutdown training)", should meet the requirements of the ANSI/ANS-3.5- should meet the standard with respect to the following 2009" requirements of the standard The perceived intent of this type of SBTs for inclusion as with respect to the sentence was to provide simulator performance tests: (1) NRC following type of SBTs for examples when operator and initial license examination (operating inclusion as senior operator training test) scenarios, (2) licensed simulator performance tests: simulator scenarios are excluded operator requalification annual (1) NRC initial license from SBT for purposes of examination (operating test) simulator examination (operating test) meeting the standard's SBT scenarios, and (3) scenarios used Page 4 of 21
River Bend Station Comments DRAFT REGULATORY GUIDE DG-1248
[Item
. R__~Rlfer'c~ [7) -02proped RC Isi7 6-Xg,46J.4 scenarios, (2) licensed requirements; however, the for performing applicant control operator requalification examples provided within the manipulations that affect reactivity to annual examination parentheses is not all inclusive establish eligibility for an (operating test) simulator when operator and senior operator's license. All other operator scenarios, and (3) scenarios operator training simulator and senior operator training simulator used scenarios may excluded from scenarios *k4 (such as just in time training
,,x- .. oj.L
- u ~lX*txau ul for performing applicant SBT for purposes of meeting the al-t. 14 Funl.-.. i .y -... 'h alt control manipulations that standard's SBT requirements. It equipmelnt f*,iL Lta (it.
a*dap O wfliin.4.VV affect reactivity to establish could be perceived by licensees t-'aiiing) are excluded from SBT for eligibility for an and inspectors that these are the purposes of meeting the standard's operator's license. All other only occasions when operator SBT requirements.
operator and senior operator and senior operator training training simulator scenarios simulator scenarios are excluded (such as just-in time training from SBT for purposes of and routine plant system meeting the standard's SBT and equipment startup and requirements, despite the fact shutdown training) are that the three requirements are excluded from SBT for listed in this section.
purposes of meeting the standard's SBT requirements.
6 Page 6, Section 2.e e. In regard to Section Delete this section in its entirety. e. in regard to Seition 4.434-,
under; NEI 09-09, 4.4.3.1, "Simulator It does not clarify or add any ,Simu1ate*-*Opefabi.ity Tes*ing,"
"NRC Acceptance Operability Testing," additional guidance than that Footnote 6, as refer.enced to and Endorsement of Footnote 6, as referenced to already noted in the Standard Appendix A, "Guideline foe ANSIANS-3.5- Appendix A, "Guideline for and could only add to confusion. Decumentatien of Simnulater Design 2009" Documentation of Simulator and -Tes"Peformance," . simulati Page 5 of 21
River Bend Station Comments DRAFT REGULATORY GUIDE DG-1248 Item Reference-, DG-1248 -.,Comment Proposed Revision,
_____ .__.... Original Text ____-.to DG-__248_......
Design and Test fa-ility li.ensees should note that Performance," simulation Appendix A provides examples that facility licensees should are applicable to Section .4.3. 1.
note that Appendix A provides examples that are applicable to Section 4.4.3.1.
7 Page 6, Section 2.f f. In regard to Section Editorial; delete words "other" f. In regard to Section 4.4.3.2, under; NEI 09-09, 4.4.3.2, "Simulator and "such as that" from the last "Simulator Scenario-Based Testing,"
"NRC Acceptance Scenario-Based Testing," sentence to provide clarity in simulation facility licensees should and Endorsement of simulation facility licensees regards to the regulator's also adhere to the NEI standardized ANSI/ANS-3.5- should also adhere to the expectations. approach for the conduct, 2009" NEI standardized approach performance, and documentation of for the conduct, simulator SBT, as described in NEI performance, and 09-09, Revision 1. The NRC expects documentation of simulator licensees to perform othef-simulator SBT, as described in NEI performance testing, sueh as that 09-09, Revision 1. The described in Section 4.4.3.1, NRC expects licensees to "Simulator Operability Testing";
perform other Section 4.4.3.3, "Simulator Reactor simulator performance Core Performance Testing", and testing, such as that Section 4.4.3.4, "Post-Event described in Section 4.4.3.1, Simulator Testing," separately and "Simulator Operability independently from the testing Testing"; described in Section 4.4.3.2.
Section 4.4.3.3, "Simulator Reactor Core Performance Page 6 of 21
River Bend Station Comments DRAFT REGULATORY GUIDE DG-1248 Itemi Reference DG-1248 '" Comment Proposed Revision
____.... original Text .to DG-1248 Testing", and Section 4.4.3.4, "Post-Event Simulator Testing,"
separately and independently from the testing described in Section 4.4.3.2.
8 Page 6, Section 2.g g. In regard to Section First sentence: g. In regard to Section 4.4.3.3, under; NEI 09-09, 4.4.3.3, "Simulator Reactor "Simulator Reactor Core Performance "NRC Acceptance Core Performance Testing," 1. Add "within the scope of Testing," simulation facility licensees and Endorsement of simulation facility simulation" to be consistent should meet the requirements of the ANSI/ANS-3.5- licensees should meet the with Section 3.4.3.3 of standard within the scope of 2009" requirements of the standard Standard. simulation with r.espe.t to real time with respect to real time and and the conduct of core evolutions the conduct of core 2. Delete "with respect to real involved. The NRC expects a facility evolutions involved. The time"; there are some licensee's plant-referenced simulator NRC expects a facility simulator performance tests to utilize models relating to nuclear licensee's plant-referenced that would require an eight and thermal-hydraulic characteristics simulator to utilize models hour run time (such as a that replicate a core load in the relating to nuclear and peak xenon test). Simulation nuclear power reference plant. If the thermal-hydraulic facilities appreciate the use plant-referenced simulator is used to characteristics that replicate of the fast time simulation meet NRC applicant experience a core load in the nuclear feature to conduct tests that requirements, as described in 10 CFR power would require an extensive 55.3 1(a)(5), then the most recent core reference plant. If the plant- amount of run time in an age load (e.g., the core load(s) that existed referenced simulator is used where simulator utilization during the time of the NRC to meet NRC applicant by the operations training applicant's initial training program; Page 7 of 21
River Bend Station Comments DRAFT REGULATORY GUIDE DG-1248 experience requirements, as programs is very high. reactivity manipulations may be described in 10 CFR conducted on core loads that precede 55.3 1(a)(5), then the most 3. Clarify "and the conduct of and follow a refueling outage, recent core load (e.g., the core evolutions involved". therefore, reactivity manipulations current reference plant core This appears to be an may be- performed in more than one load, or if the reference incomplete sentence. fuel cycle) the cur-ent referenc. plant plant is in a refueling eor-e lead, Or- if the r-efer-nee plant i~
outage, the core load just The third sentence references in a refueling outage, the eor-e lead previous to the outage) in "the most recent core load". just pr-evious to the eutage) in the the nuclear power reference License classes may run through nuclear power reference plant for plant for which a license is more than one fuel operating which a license is being sought must being sought must be cycle, so reactivity be utilized.
utilized. manipulations may be conducted on core loads that precede and follow a refueling outage, therefore, reactivity manipulations may not be performed in the same fuel cycle.
Additional clarification is required in the third sentence taking into account the preceding comment. Consider defining the "most recent core load" as "the core load(s) that existed during the time of the NRC applicant's initial training I
Page 8 of 21
River Bend Station Comments DRAFT REGULATORY GUIDE DG-1248 Item Re'ference G-1248 Comment. . Proposed Revision, Orgina1 Text .ptorDG-1248 9
_____ I Page 6, Section 2.h
_____________program~'
- h. In regard to Section Second sentence: h. In regard to Section 4.4.3.4, "Post-under; NEI 09-09, 4.4.3.4, "Post-Event Event Simulator Testing," simulation "NRC Acceptance Simulator Testing," 1. Delete "As a minimum" to facility licensees should meet the and Endorsement of simulation facility licensees place focus on requirements of the standard with ANSI/ANS-3.5- should demonstrating simulator respect to demonstrating that the 2009" meet the requirements of the performance for items 1 plant-referenced simulator standard with respect to through 4. performance and response compares demonstrating that the favorably to the reference plant's plant-referenced simulator 2. Delete "reference plant performance and response without performance and response events" and "such as" and significant deviation from the compares favorably to the add "relevant unplanned or sequence of events for the reference reference plant's unexpected (off-normal) plant event. As a minimum, a licensee performance and response events-deemed appropriate should demonstrate on the plant-without by the facility licensee"; this referenced simulator those relevant significant deviation from language provides some unplanned or unexpected (off-normal) the sequence of events for degree of flexibility to the events r.efer.en.e pla events deemed the reference plant event. As licensee and is consistent appropriate by the facility licensee, a minimum, a licensee with the intent of Sections such as that fesult in (1) the automatic should demonstrate on the 3.4.3.4 and 4.4.3.4 in the initiation of an engineered safety plant-referenced simulator Standard. The items listed system, (2) the manual or automatic those reference plant events in Section 2.h can occur trip of the nuclear reactor, (3) a that result in (1) the during normal plant significant unplanned or .. . c,*,x ,.-
automatic initiation of an evolutions and routine reactivity change, and (4) the manual engineered safety system, surveillance testing, the or automatic trip of the main turbine-(2) the manual or automatic scope of testing could be generator while online with the trip of the nuclear very great. Therefore, it electrical grid, and (5) any other-event Page 9 of 21
.River Bend Station Comments DRAFT REGULATORY GUIDE DG-1248 tem. Reference W_1~i248;1 CPtmntt Com e .
ýJzý1248P
ýv ii.. . .. - -. . . . . . . . -. .. . ..--. .. ..- . . .. . ... . . . . . . . . i . . . . . . . .. ... .. . . .-.. . . . .- . . . .. .. . . .. . -. ... . . . . . .. . .. . .. . . . . ..-
reactor, (3) a significant should be clarified that the deemed appr-epr-iate by. thc faeility unplanned or unexpected unplanned, unexpected, and licensee within 60 calendarpay-s reactivity change, (4) the off-normal events should be following the event to ensuire that manual or automatic trip of the focus of post event fidelity is being met and maintained-.
the main turbine-generator simulator testing. The comparison should be performed while online with the and any significant deviations electrical grid, and (5) any 3. Delete item 5 from the list identified within 60 days of the event.
other event deemed and add the following appropriate by the facility clarification: "The licensee within 60 calendar comparison should be days following the event to performed and any ensure that fidelity is significant deviations being met and maintained. identified within 60 days of the event." This is to clarify that resolutions to noted deviations are not required to be resolved within 60 days; depending on scope of deviation, efforts to resolve could take longer than 60 days (and may require vendor support or model replacements).
10 Page 6, Section 3 The NRC staff has reviewed The reference to ANS-3.5-1998 The NRC staff has reviewed NEI under; "NRC NEI-09-09, Revision 1, and should be deleted from the 09, Revision 1, and finds the Acceptance and finds the implementation second sentence. It implies a implementation guidance an Endorsement of guidance an acceptable "back fit" from the proposed acceptable method for simulation Page 10 of 21
River Bend Station Comments DRAFT REGULATORY GUIDE DG-1248 Iti ~Rf~ie P-1248 -CJ 6111~h~
MIR 112._ " o1*I-14.
NEI-09-09, method for simulation revision 4 of Regulatory Guide facility licensees to demonstrate their Revision 1" facility licensees to 1.149 to a previous edition of compliance with the requirements of demonstrate their the ANS-3.5 Standard. Sections 3.4.3.2 and 4.4.3.2 of compliance with the ANSI/ANS-3.5-2009 regarding requirements of Sections Delete third sentence in its simulator SBT. Therefore, the NRC 3.4.3.2 and 4.4.3.2 of entirety. The NEI 09-09 accepts and endorses NEI-09-09 as an ANSI/ANS-3.5-2009 document does not, by itself, acceptable method for an equitable regarding simulator SBT. satisfy the 10CFR55.46 and consistent approach and Therefore, the NRC requirements to: (1) demonstrate methodology for the conduct and accepts and endorses NEI- expected plant response to documentation of SBT, as described 09-09 as an acceptable operator input and to normal, in ANSI/ANS-3.5-2009 (a-d method for an equitable and transient, and accident ANSI/ANS 3.5 1998, which NEI 09 consistent approach and conditions to which the 09, Revision 0, supp.rted . -
methodology for the simulator has been designed to implementation of NEI 09 09, conduct and documentation respond (10CFR55.46(c)), and Revision 1, ensures that simulation of SBT, as described in (2) that significant control facility licensees will demonstrate ANSI/ANS-3.5-2009 (and manipulations are completed ,xpe*.,dplant response to operater ANSIIANS-3.5-1998, which without procedural exceptions, input and to normal, transientt, and NEI-09-09, Revision 0, simulator performance accident conditionis to which the supported). Implementation exceptions, or deviation from simulator-has been designed to of NEI-09-09, Revision 1, the approved training scenario respond, so that significant control ensures that simulation sequence maniplations are completed withu*tt facility licensees will (10CFR55.46(c)(2)(ii)). The proceedur-al exceeptions, simutlator demonstrate expected plant simulator's testing program as per-formanceecetos or deviation response to operator input described in Sections 3.4 and 4.4 frmn the approved trainingseai and to -normal, transient, and of the Standard is designed to sequenee7-accident conditions to which meet the requirements in the simulator has been 10CFR55.46.
Page 11 of 21
River Bend Station Comments DRAFT REGULATORY GUIDE DG-1248
.Item
...... Reference DG-1248o.
Original Text Comment Proposed Revision itoDG-1248 designed to respond, so that significant control manipulations are completed without procedural exceptions, simulator performance exceptions, or deviation from the approved training scenario sequence.
11 Page 7, Section 4 Licensees who maintain First sentence: 4. Acceptability of Licensee's under; simulation facilities Simulation Facility "Acceptability of certified under previous 1. Substitute "testing Licensees who maintain simulation Licensee's editions of ANSI/ANS-3.5 documentation" with facilities certified under previous Simulation (-1998, -1993, and -1985) "testing methodology". It is editions of ANSI/ANS-3.5 Facility" endorsed by the NRC are not perceived that previous (-1998, -1993, and -1985) endorsed encouraged to, but are not simulator documentation by the NRC are encouraged to, but are required to, revise the would be revised to not required to, revise the software and testing transition to ANS-3.5-2009. software and testing deeumentati documentation to maintain methodology to maintain the the simulation facility in 2. The idea that "the NRC simulation facility in accordance with accordance with encourages simulation ANSI/ANS-3.5-2009. The NRC staff ANSI/ANS-3.5-2009. The facilities to, but do not recognizes that it will take some time NRC staff recognizes that it require simulation facilities for these simulation facility will take some time for to..." and "the NRC staff licensees to transition to ANSI/ANS-these simulation facility anticipates that simulation 3.5-2009. Therefore, the NRC staf licensees to transition to facility licensees will anicieiates that simulation rot6, tb elt ! . el ANSI/ANS-3.5-2009. voluntarily move to &nsiIitv 1 o ntnri Iv xviii IIwenw Page 12 of 21
River Bend Station Comments DRAFT REGULATORY GUIDE DG-1248 Item R r e DG-1248 Comment Proposed Revson
_ __ . Original Text to DG-1248.
Therefore, the NRC staff ANSIIANS-3.5-2009" move to A"SI/AT NS 3.5 2009 anticipates that simulation appears to be contradictory. following the date of the fina.
facility licensees will -egulatefy voluntarily move to There is a recommendation, guide (e.g., Regulatry Guide 1. 149, ANSI/ANS-3.5-2009 followed by a soft requirement; Revision4).
following the date of the there is direction, but no final regulatory direction.
guide (e.g., Regulatory Guide 1.149, Revision 4). Recommend either: (1) deletion of last sentence, or (2) absolute direction to the industry regarding transition to one Standard.
12 Page 7, Section 5, The NRC will only This statement should be The NRC will only administer second paragraph administer operating tests applicable to single/multiple unit operating tests on a single/multiple under; "Use of on a plant-referenced plants. plant-referenced simulator that meets Simulation Facility simulator that meets the the Commission's requirements, as for Multiple Plants" Commission's Correct typo "plant-referenced". described in 10 CFR 55.46. In requirements, as described addition, a licensee must request in 10 CFR 55.46. In May need to address use of Commission approval if it plans to addition, a licensee must single unit plant-referenced administer the NRC operating test request simulator in separate section using other than a-plant-referenced Commission approval if it since Section 5 is specific to simulator or the plant.
plans to administer the NRC multiple plants.
operating test using other than a -plant-referenced simulator or the plant.
Page 13 of 21
River Bend Station Comments DRAFT REGULATORY GUIDE DG-1248 item
- r. Reference DG-1248 -Comment, Proposed Revision
... .Original Text C to DG-1248 13 Page 8, Section D, The NRC staff recognizes The WESTRAIN Simulator N/A third paragraph that a commitment to Subcommittee disagrees that under; ANSI/ANS-3.5-2009 is "such a movement will be "Implementation" voluntary on the part of seamless and transparent with simulation facility licensees. minimal burden".
Since its last revision to Regulatory Guide 1.149, the See comments associated with NRC staff has worked Item 4 above.
closely with simulation facility licensees and other Producing malfunction test interested stakeholders documentation to satisfy Section through the NEI LOFG to 2.b will be a significant burden facilitate voluntary and costly if the licensee will be movement to a single required to conduct old industry consensus standard. malfunction tests. This is The NRC has determined particularly true for those that facilities that eliminated records movement to a single over 4 years old as allowed by consensus standard is in the 10CFR 55.46.
best interest of simulation facility licensees, as well as Also, additional documentation NRC inspectors and associated with NE10909 is examiners and the general considered excessive and an public. The NRC is unnecessary burden. Marking confident that such a up and retaining all procedures movement will used during the scenario-based be seamless and transparent test is of no advantage to the Page 14 of 21
River Bend Station Comments DRAFT REGULATORY GUIDE DG-1248 Item Reference DG-1248 Comment j Proposed Revision Original Text .. topDG124&d.eis with minimal burden, if any. facility except to demonstrate As a result, NRC review compliance in the NRC and inspection of inspection process. The plant-referenced simulators affirmation of the acceptance for compliance with the criteria by the lead instructor is requirements of 10 CFR sufficient. The WESTRAIN 55..46 will be more uniform Simulator Subcommittee agrees and consistently that capturing alarms and trends implemented when the staff can provide some value to the carries out the Reactor lead instructor during the SBT; Oversight Process baseline however, this requirement is in Inspection Procedure, IP- fact additional burden.
71111.11, "Licensed Operator Requalification Program."
14 Page 9, 5t" Revision of Regulatory Is this revision of Regulatory Revision of Regulatory Guide 1.149 paragraph under; Guide 1.149 is necessary for Guide 1.149 necessary for is necessary for (1) the NRC to "Regulatory (1) the NRC to endorse the simulation facility licensees to endorse the use of ANSI/ANS-3.5-Analysis" use of voluntarily move to a single 2009 as a technical standard to ensure ANSI/ANS-3.5-2009 as a consensus standard and carry compliance with the Commission's technical standard to ensure out its requirements? simulation facility scope and fidelity compliance with the requirements, (2) si.muation facilit Commission's simulation Item 2 does not meet the intent li..ns.es to v.luntar-ily move to a facility scope and fidelity of DG 1248, whereas the other gin&e requirements, (2) simulation three items do; delete item 2. consensus standard and earry out its facility licensees to . ieniý -(2) the NRC to voluntarily move to a single communicate its expectations, and Page 15 of 21
River Bend Station Comments DRAFT REGULATORY GUIDE DG-1248 Item Reference, DG-1248,.
original
-O_ Text .- Comment 1. Proposed Revision to DG-1248-..
consensus standard and (3) facilitation of a common approach carry out its requirements, and methodology for conducting and (3) the NRC to documenting simulator communicate its scenario-based performance testing.
expectations, and (4) facilitation of a common approach and methodology for conducting and documenting simulator scenario-based performance testing.
15 Page 10, 1st The benefit of updating and Revising Regulatory Guide The benefit of updating and revising paragraph under; revising Regulatory Guide 1.149 will not preclude negative Regulatory Guide 1.149 is that it "Alternative 1.149 is that it would training and inappropriate would provide guidance to Approaches" provide guidance to operator license evaluations, ensure that nuclear power plant ensure that nuclear power simulation facilities used for operator plant simulation facilities Strike this phrase from this training, license examinations, and used for operator training, paragraph; it appears nafve. applicant experience requirements are license examinations, and Implementation of the maintained in accordance with the applicant experience Regulatory Guide 1.149 industry's most recent requirements are maintained Revision 4 and the ANS-3.5- consensus standard-w,'hic-wil4 in accordance with the 2009 Standard will not by itself pr.elude negative training and-industry's most recent preclude negative training inappropriate oper-at, r lien..
consensus standard, which ("...preclude negative evaluations.
will preclude negative training..." is an absolute Simulation facilities that meet the training and inappropriate statement). minimum scope and fidelity
__ operator license evaluations. requirements of ANSI/ANS-3.5-2009 Page 16 of 21
River Bend Station Comments DRAFT REGULATORY GUIDE DG-1248 Item Reference DG-1248--. Comment. - Proposed Revision
'Original Text- to DG-1248 Simulation facilities that must meet the minimum scope be able to demonstrate, on a and fidelity requirements of continuing basis, compliance with the ANSI/ANS-3.5-2009 must Commission' s simulation facility be able to demonstrate, on a regulations, as described in 10 CFR continuing basis, 55.46.
compliance with the Commission's simulation facility regulations, as described in 10 CFR 55.46.
16 Page 10, 2nd The impact to the NRC The WESTRAIN Simulator N/A paragraph under; would be the costs Subcommittee believes that it is "Alternative associated with preparing inappropriate for the NRC staff Approaches" and issuing the revised to "believes that simulation regulatory guide. The facility licensees would incur impact to the public would little or no cost" (See comments be the voluntary costs associated with items 4 and 13 associated with reviewing above).
and providing comments to the The WESTRAIN Simulator NRC during the public Subcommittee agrees that comment period. The "significant human resource impact to facility licensees burdens ... are anticipated as a would be the cost of result of moving to one implementing the new standard."
standard. The value to the Page 17 of 21
River Bend Station Comments DRAFT REGULATORY GUIDE DG-1248 Item Reference DG-1248 COmment - Proposed Revision
-1 O riginal Text to DG-1248 ..-
NRC staff and facility Where is human resource licensees burdens reduced? Transition would be the benefits from 1998 to 2009 requires associated with enhanced additional burden for SBT efficiency and effectiveness documentation, core in using a common performance testing, and post guidance event simulator testing.
document as the technical basis for demonstrating The WESTRAIN Simulator compliance with the Subcommittee agrees that there Commission's simulation was some burden removed facility during transition from the ANS-scope and fidelity 3.5-1985 Standard to the ANS-requirements, as described 3.5-1998 Standard.
in 10 CFR 55.46, and during other interactions between the NRC and facility licensees.
The staff believes that simulation facility licensees would incur little or no cost (for licensees who have not already moved to ANSIIANS-3.5-2009, the cost is expected to be minimal, if any, since significant human resource burdens and simulator Page 18 of 21
River Bend Station Comments DRAFT REGULATORY GUIDE DG-1248 item eee e ReferenceDG14.,omn Ie!L.Fltem,[a TeDxt je rigina'l Tex ,!:Cmet*.* [..*i***.*...-.. Revision.
Proposed
- .::*Popsdn, e1s24&,.:..*i,.
-DG :*i....
performance testing time savings are anticipated as a result of moving to one standard, which the proposed guide is advocating).
17 Page 11 under; N/A Add definitions for: (1) N/A "Glossary" replicate, (2) significant deviation, (3) compare favorably, (4) procedural exception.
18 Appendix B, Item 2 N/A Please clarify; do "Simulator N/A initial conditions (IC) agreed with reference plant with respect to reactor status, plant configuration, and system operation" only apply to scenarios associated with reactivity manipulations?
19 Appendix B, Item SBT conducted in a manner Reference to ANS-3.5-2009 is SBT conducted in a manner sufficient 10 sufficient (i.e., meets redundant in this proposed (i.e., meets r.equir.ements
.t requirements of revision 4 to Regulatory Guide ANS/ANS 3.5 2009) to ensure that ANSI/ANS-3.5-2009) to 1.149. simulator fidelity has been ensure that simulator demonstrated and met for this fidelity has been Delete reference to ANSI/ANS- scenario. Note: Attach relevant "as-Page 19 of 21
River Bend Station Comments DRAFT REGULATORY GUIDE DG-1248 Item Reference DG-1248 'Comment Proposed Revision.
_Original Text . toDG-1248 demonstrated and met 3.5-2009. run marked-upplant procedures and for this scenario. Note: or procedureportions/pagesutilized Attach relevant "as-run" to support assertion.
marked-up plantprocedures and or procedureportions/pages utilized to support assertion.
20 Appendix B, Item Modeling and hardware Regarding the sentence; Modeling and hardware discrepancies 11 discrepancies identified "Modeling and hardware identified during the conduct of SBT during the conduct of SBT discrepancies identified during are are the conduct of SBT are documented aAd-entered-in documented and entered in documented and entered in accordance with the site simulator accordance with the site accordance with the site configuration simulator configuration simulator configuration management procedures. Note.
management procedures. management procedures"... Discrepanciesthat directly affect Note: Discrepanciesthat operatorresponse (or directly affect operator The term "and entered" is action) or expected plant response response (or redundant to "documented" in must be resolved before the SBT test action) or expected plant the configuration management results can be response must be resolved process. Strike the phrase "and judged as satisfactory.
before the SBT test results entered".
can be judged as satisfactory.
21 Appendix B, Page The draft regulatoryguide In regards to the italicized note N/A B-1 includes this appendix so at the bottom of Page B-1...
that the public can discern Page 20 of 21
River Bend Station Comments DRAFT REGULATORY GUIDE DG-1248 Itemrn Reference* DG-1248 Comment Proposed Revision L IOriginal Text toDG-1248 the staff's acceptance and The WESTRAIN Simulator endorsement of the Subcommittee recommends that Nuclear Energy Institute 's this appendix not be included in (NEI) industry technical final regulatory guide; remove guidance document, NEI- any references to it in the body 09-09, Revision 1. Thefinal of the proposed revision to the guide may or may not regulatory guide.
include this appendix.
Page 21 of 21