View source for NUREG-1262, Discusses Review of Plant Simulation Facility Development Plan,Submitted on 880526.Overall Approach of Plan Acceptable Due to Reliance on Util Simulation Facility Group Baseline Document.Issues Requiring Resolution Stated

{{Adams
| number = ML20244A662
| issue date = 04/10/1989
| title = Discusses Review of Plant Simulation Facility Development Plan,Submitted on 880526.Overall Approach of Plan Acceptable Due to Reliance on Util Simulation Facility Group Baseline Document.Issues Requiring Resolution Stated
| author name = Pulsifer R
| author affiliation = NRC OFFICE OF NUCLEAR REACTOR REGULATION (NRR)
| addressee name = Berry K
| addressee affiliation = CONSUMERS ENERGY CO. (FORMERLY CONSUMERS POWER CO.),
| docket = 05000155
| license number = 
| contact person = 
| case reference number = RTR-NUREG-1262
| document report number = TAC-68307, NUDOCS 8904180123
| document type = CORRESPONDENCE-LETTERS, NRC TO UTILITY, OUTGOING CORRESPONDENCE
| page count = 4
| project = TAC:68307
| stage = Approval
}}

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            ../                                                         kg                            UNITED STATES                                  ,
      ,(*)                                                               ;j NUCLEAR REGULATORY COMMISSION WASHINGTON, D. C. 20555
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                           %                                            /                           April 10,1989 Docket No. 50-155 Mr. Kenneth W. Berry Director Nuclear Licensing Consumers Power Company 1945 West Parnall Road Jackson, Michigan 49201

==Dear Mr. Berry:==

==SUBJECT:==
BIG ROCK POINT PLANT RESPONSE ON SIMULATION FACILITY                                    ,
PLAN (TAC 68307)                                                       i The Commission has reviewed the subject simulation facility development plan which was submitted, in accordance with the requirements in 10 CFR 55.45(b)(2)(1), on May 26, 1988.
As you know, the regulation does net provide for NRC review of this plan.
Rather, it stipulates at Section 55.45(b)(i), that NRC review will be made of your application for approval of a simulation facility which is to be submitted in accordance with this plan no later than November 1990. However, in accordance with the guidance given by the staff at a series of public meetings held to discuss implementation of 10 CFR 55 and arsociated regulatory guides at the                      '
time of their issuance, documented in NUREG-1262, the staff agreed to review such plans and to inform facility licensees of the results of its review. You should review NUREG-1262, in particular, questions 176, 177 and 178, for guidance with respect to acceptance criteria for approval of simulation facilities.
Our review of your plan indicates that your overall approach is acceptable in                    i that it relies on the baseline document developed by the Utility Simulation Facility Group (USFG). However, the following specific issues were not adequately addressed in the USFG document, nor in your plan, and must be
            .                                     resolved prior to approval of your application.
: 1. The issue of the relationship between physical and functional         !
fidelity, and the ability of the simulation facility to support the use of controlled copies of reference plant procedures during an examination in which team dependent and time critical behaviors can be demonstrated, has not been satisfactorily addressed. In addition, you have not indicated that you have perfonned or will perform the research and analysis required to support your position on this matter. The major physical fidelity deviation expected to exist between the Big Rock Point control root and the Dresden l                                                                           simulator are not likely to be sustained for use by such an analysis.
We are concerned that the use of the Dresden simulator may not meet the intent of section 2.1 of the USFG guidance document.
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P      D k o %10                                                         .

  .                                                                                                                                  2. You have not included definitions for terms such as shall, should, may, etc.
The issues expressed below continue to be of concern to the staff. It is recommended that you carefully consider these issues during the continued         ,
development of your simulation facility, and that you address them specifically    !
in you application for approval.
: 1. We fail to see any serious consideration being given to the possible use of other simulation devices. Based upon your proposed schedule, any such consideration is likely to occur too late in the process to be practical and realistic.
: 2. There appears to be no one representing professional human factors expertise on your review team. Such representation should be included. l
: 3. There appears to be no one representing Dresden simulator expertise on your team. Such expertise would appear to be necessary.
: 4. You are again reminded that we consider the use of the reference plant, when serving as a simulation facility to mean actual performance, not simply a walk-through as implied in section 4.6.5 of your plan.
The staff again expresses its willingness to work with you as you progress toward the development of your simulation facility and the application for its approval for use in the cor. duct of operating tests. You had requested on         l March 3, a meeting with the NRC to present your plans. Please provide some         .
acceptable dates for this presentation and I will arrange the meeting. Some       !
dates acceptable to us are the week of April 17 or after May 1,1989. You may also address the above items at this meeting.
Sincerely,
                                                                               /s/
Robert M. Pulsifer, Project Manager Project Directorate III-1 Division of Reactor Projects - III, IV, V
                                                                                  & Special Projects DISTRIBUTION
                                  - DOCKET' FILE
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OGC l                                         NRC & LOCAL PDRs            EJORDAN PD31 GRAY FILE              BGRIMES GHOLAHAN                    ACRS(10)
MVIRGILIO                   KPERKINS PSHUTTLEWORTH RPULSIFER PM/PD31:DRSP          (I)/PD31:DRSP O
NRR/LOLB LA/PD31:DP.SPgg[f P HUTTLEWORTII       RPULSIFEPg            T}   Y(v            KPERKINS J/89             f/(,/89              f/7/89              4 /10 / 8 9 l

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: 2. You have not included definitions for tems such as shall, should, i
may, etc.
The issues expressed below continue to be of concern to the staff. It is recommended that you carefully consider these issues during the continued                            3 development of your simulation facility, and that you address them specifically                       l in you application for approval.                                                                     !
: 1. We fail to see any serious consideration being given to the possible use of other simulation devices. Based upon your proposed schedule, any such consideration is likely to occur too late in the process to be practical and realistic.                                                                 j
: 2. There appears to be no one representing professional human factors                         I expertise on your review- team. . Such representation should be included.
: 3. There appears to be no one representing Dresden simulator expertise on your team. Such expertise would appear to be necessary.
: 4. You are again reminded that we consider the use of the reference plant, when serving as a simulation facility to mean actual perfomance, not simply a walk-through as implied in section 4.6.5 of your plan.
The staff again expresses its willingness to work with you as you progress toward the development of your simulation facility and the application for its approval for use in the conduct of operating tests. You had requested on March 3, a meeting with the NRC to present your plans. Please provide some acceptable dates for this presentation and I will arrange the meeting. Some dates acceptable to us are the week of April 17 or after May 1,1989. You may also address the above items at this meeting.
Sincerely, e
o er    . Pulsif , Project Manager Project Directorate III-1 Division of Reactor Projects - III, IV, V                        ;
                                                   & Special Projects                                             '
cc:   See next page l

                  ''?
Nr. Kenneth W. Berry
* Consumers Power Company.            Big Rock Point Plant 7p cc:
                       - Mr. -Thomas ' A. McNish, Secretary Consumers Power Company 212 West Michigan Avenue Jackson, Michigan 49201
                      -Judd L. Bacon, Esquire Consumers Power Company 212 West Michigan Avenue Jackson, Michigan 49201 Mr. Thomas W. Elward-Plant Manager-                                           1  '
Big Rock Point Plant-10269 U.S. 31 North Charlevoix, Michigan 49720.
Mr. Bud Heeres-County Commissioner 303 Sheridan Charlevoix, Michigan 49720 Office of the Governor Room 1 - Capitol Building Lansing, Michigan 48913 Regional Administrator, Region III~
U.S. Nuclear Regulatory. Commission 799 Roosevelt Road
                      . Glen Ellyn, Illinois 60137 Nuclear Facilities and Environmental Monitoring Section Office Division of Radiological Health P. O. Box 30035 Lansing, Michigan 48909 U.S. Nuclear Regulatory Commission                         !
Resident Inspector Office Big Rock Point Plant                                       i 10253 U.S. 31 North                                        1 Charlevoix, Michigan 49720-l l
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