Regulatory Guide 1.149: Difference between revisions

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{{Adams
{{Adams
| number = ML110420119
| number = ML12305A245
| issue date = 04/30/2011
| issue date = 04/30/1981
| title = Nuclear Power Plant Simulation Facilities for Use in Operator Training, License Examinations, and Applicant Experience Requirements
| title = Nuclear Power Plant Simulators for Use in Operator Training
| author name = Vick L
| author name =  
| author affiliation = NRC/NRR/DIRS
| author affiliation = NRC/RES, NRC/RGN-I
| addressee name =  
| addressee name =  
| addressee affiliation =  
| addressee affiliation =  
| docket =  
| docket =  
| license number =  
| license number =  
| contact person = Carpenter  R, RES/DE,301-251-7483
| contact person =  
| case reference number = DG-1248
| case reference number = Task RS 110-5
| document report number = RG-1.149, Rev 4
| document report number = RG 1.149
| package number = ML110420056
| document type = Regulatory Guide
| document type = Regulatory Guide
| page count = 10
| page count = 4
}}
}}
{{#Wiki_filter:U.S. NUCLEAR REGULATORY COMMISSION
{{#Wiki_filter:4"      U.S. NUCLEAR REGULATORY COMMISSION                                                                             April 1981
April 2011 Revision 4 REGULATORY GUIDE
                  ~REGULATORY                                                                                     GUIDE
  OFFICE OF NUCLEAR REGULATORY RESEARCH
                  0'      OFFICE OF NUCLEAR REGULATORY RESEARCH
    The NRC issues regulatory guides to describe and make available to the public methods that the NRC staff considers acceptable for use in implementing specific parts of the agency's regulations, techniques that the staff uses in evaluating specific problems or postulated accidents, and data that the staff needs in reviewing applications for permits and licenses.  Regulatory guides are not substitutes for regulations, and compliance with them is not required.  Methods and solutions that differ from those set forth in regulatory guides will be deemed acceptable if they provide a basis for the findings required for the issuance or continuance of a permit or license by the Commission.
                                                            REGULATORY GUIDE 1.149 (Task RS 110.5)
 
                  NUCLEAR POWER PLANT SIMULATORS FOR USE IN OPERATOR TRAINING
This guide was issued after consideration of comments received from the public.
 
Regulatory guides are issued in 10 broad divisions C1, Power Reactors; 2, Research and Test Reactors; 3, Fuels and Materials Facilities; 4, Environmental and Siting; 5, Materials and Plant Protection; 6, Products; 7, Transportation; 8, Occupational Hea lth; 9, Antitrust and Financial Review; and 10, General.
 
Electronic copies of this guide and other recently issued guides are available through the NRC's public Web site under the Regulatory Guides document collection of the NRC's Electronic Reading Room at http://www.nrc.gov/reading-rm/doc-collections/ and through the NRC's Agencywide Documents Access and Management System (ADAMS) at http://www.nrc.gov/reading-rm/adams.html, under Accession No. ML110420119.  The regulatory analysis may be found in ADAMS under Accession No. ML110420133. REGULATORY GUIDE 1.149 (Draft was issued as DG-1248, dated May 2010)  
NUCLEAR POWER PLANT SIMULATION FACILITIES FOR USE IN OPERATOR TRAINING, LICENSE EXAMINATIONS, AND APPLICANT EXPERIENCE REQUIREMENTS


==A. INTRODUCTION==
==A. INTRODUCTION==
This guide describes methods acceptable to the staff of the U.S. Nuclear Regulatory Commission (NRC) for complying with those portions of the Commission's regulations associated with approval or acceptance of a nuclear power plant simulation facility for use in operator and senior operator training and license examination operating tests and for meeting applicant experience requirements.
exist between a simulator and the facility that the operators are being trained to operate, is addressed in 10 CFR Part 55, Appendix A, "Requalification Programs for Licensed Oper-                    "Operators' Licenses." This issue, the similarity that must ators of Production and Utilization Facilities," to 10 CFR                      exist between a simulator and the facility that the operators Part 55, "Operators' Licenses," permits use of simulators for                   are being trained to operate, is not addressed in the guide and operator training.                                                              should not be confused with the guidance provided that speci- fies the similarity that should exist between a simulator and This regulatory guide describes a method acceptable to                      its reference plant.


Title 10, of the Code of Federal Regulations, Part 55, "Operators' Licenses" (10 CFR Part 55) (Ref. 1), defines the term "simulation facility" in 10 CFR 55.4, "Definitions," as meaning one or more of the following components, alone or in combination, used for either the partial conduct of operating tests for operators, senior operators, and license applicants, or to establish on-the-job training and experience prerequisites for operator license eligibility:  (1) a plant-referenced simulator, (2) a Commission-approved simulator under 10 CFR 55.46(b), or (3) another simulation device, including part-task and limited scope simulation devices, approved under 10 CFR 55.46(b).  In particular, 10 CFR 55.46, "Simulation Facilities," addresses the use of a simulation facility for the administration of the operating test and plant-referenced simulators to meet experience requirements for applicants for operator and senior operator licenses.  In addition, 10 CFR 55.59, "Requalification," addresses, in part, the use of a simulation facility to perform required control manipulations and plant evolutions not performed at the plant for on-the-job training of licensed operator and senior operators.
the NRC staff for specifying the functional requirements of a nuclear power plant simulator to be used for operator                                          


This regulatory guide contains information collection requirements covered by 10 CFR Part 55 that the Office of Management and Budget (OMB) approved under OMB control number 3150-0018.
==C. REGULATORY POSITION==
training.


Rev. 4 of RG 1.149, Page 2  The NRC may neither conduct nor sponsor, and a person is not required to respond to, an information collection request or requirement unless the requesting document displays a currently valid OMB control number.  The NRC has determined that this regulatory guide is not a major rule as designated by the Congressional Review Act and has verified this determination with OMB.
The requirements established by ANSI/ANS 3.5-1981, The Advisory Committee on Reactor Safeguards has                            "Nuclear Power Plant Simulators for Use in Operator Train- been consulted concerning this guide and has concurred in                        ing," for specifying the functional capability of a simulator the regulatory position.                                                        and for comparing a simulator to its reference plant are acceptable to the NRC staff, subject to the following:


==B. DISCUSSION==
==B. DISCUSSION==
Background In March 1987, the Commission amended its regulations requiring all utilization facility licensees to have a simulation facility (either a "plant-referenced simulator" or an "other-than-a-plant-referenced simulator") by May 26, 1991, for use in administering NRC operating tests and licensed operator requalification training (Volume 52, page 9460, of the Federal Register (52 FR 9460; March 25, 1987)) (Ref. 2).  
1. The standard identifies at the point of reference The need for improvements in operator training in the areas                (Section 1.1, "Background Data") other documents to be of response to abnormal and emergency situations was high-                       included as part of the standard. The applicability of these lighted as a result of the operator errors noted in NUREG-0585,                  documents should be determined by referring to the latest
 
  "TMI-2 Lessons Learned Task Force Final Report."' Use of                        revision of the following regulatory guides and the version the actual plant for training operators to respond to accidents                of the standard the guide endorses:
In October 2001, the NRC amended its regulations to permit facility licensee applicants for operator's licenses to fulfill a portion of the required experience prerequisites by manipulating a plant-referenced simulator as an alternative to manipulating the controls of the actual nuclear power plant (66 FR 52667; October 17, 2001) (Ref. 3). The final rule became effective November 16, 2001.
would result in additional challenges to the plant's protective
 
                                                                                                          2 features and is therefore undesirable. Thus, the additional                            ANS Standard                  Regulatory Guide training required to improve operator performance should be performed on simulators. In order to maximize the effective-                                   3.1                          1.8 ness of this training, the simulator must be kept current with                                3.2                          1.33 changes in the reference plant and lessons learned from operating experience. Recommendations of instructors and                            2. Section 3.1.2, "Plant Malfunctions," lists the abnormal operator trainees for improving a simulator should be encour-                    and emergency conditions that must be performed by the aged. ANSI/ANS 3.5-1981, "Nuclear Power Plant Simulators                         simulator if applicable to the reference plant. A simulator for. Use in Operator Training," 2 in conjunction with this                      should also be able to perform diesel generator failure.
Also in October 2001, the staff issued Revision 3 of Regulatory Guide 1.149, "Nuclear Power Plant Simulation Facilities for Use in Operator Training and License Examinations" (Ref. 4). This guide endorsed the industry's previously adopted consensus standard, American National Standards Institute/American Nuclear Society (ANSI/ANS)-3.5-1998, "Nuclear Power Plant Simulators for Use in Operator Training and Examination," dated April 15, 1998 (Ref. 5), as well as two historical editions, ANSI/ANS-3.5-1993, dated March 29, 1993 (Ref. 6), and ANSI/ANS-3.5-1985, dated October 25, 1985 (Ref. 7), as methods acceptable to the NRC staff for implementing specific parts of the Commission's regulations and techniques used by the staff in evaluating compliance.


As a result of the regulatory experience gained since Revision 3 of Regulatory Guide 1.149, this new revision of the guide updates and clarifies the scope of the guideline to better serve simulation facility licensees and the regulatory community.  The guide helps to ensure that simulation facilities used to meet the requirements of 10 CFR Part 55 are sufficient in both scope and fidelity for the regulatory purposes for which they are being used with respect to (1) operating tests, as described in 10 CFR 55.45(a), (2) licensed operator requalification training requirements, as described in 10 CFR 55.59, and (3) performance of control manipulations that affect reactivity to establish eligibility for an operator's license, as described in 10 CFR 55.31(a)(5). 
regulatory guide, provides guidance in these areas.
Role of Nuclear Power Plant Simulation Facilities in Operator Licensing Facility licensees are responsible for ensuring that individuals who receive operator or senior operator licenses have the knowledge, skills, and abilities necessary to operate the nuclear facility safely and competently.  Since 1991, the NRC and facility licensees have been using nuclear power plant simulation facilities to determine whether an applicant for an operator's license has learned to operate a facility competently and safely, and, in the case of a senior operator, whether an applicant has learned to direct the licensed activities of licensed operators competently and safely.  Currently, 72 full-scope plant-referenced simulators are in service for use in meeting the regulatory needs of approximately 4,500 licensed operators manning 104 commercial nuclear power plants operating in the United States.  When applicants are tested and evaluated on a plant-referenced simulator, major facility differences are Rev. 4 of RG 1.149, Page 3  minimized between the testing and operating environments.  As a result, NRC examiners are able to make pass-fail judgments with confidence.
 
Currently, no facility licensees have proposed to use a simulation facility other than a plant-referenced simulator in the administration of an operating test.  Facility licensees are required to request approval from the Commission should they propose to use other than a plant-referenced simulator in the operating test.  Absent the use of plant-referenced simulators, operator licensing regulatory requirements would be much more difficult to meet since Commission-approved simulation facilities and Commission approval of the use of the actual plant would require the Commission to find that the simulation facility and its proposed use, or the proposed use of the plant, are suitable for the conduct of operating tests.
 
The staff anticipates that additional nuclear power plant simulation facilities will be placed into service to meet future operator licensing needs with the advent of new nuclear power plants.  This guide also applies to the use of new full-scope nuclear power plant simulation facilities when used to meet 10 CFR Part 55 operator licensing requirements.
 
Plant-Referenced Simulator Performance Testing The guidance in this topical area ensures a more uniform and consistent approach to performance testing of a plant-referenced simulator.  The Commission's regulations in 10 CFR 55.4 define the following three terms, which are very important to understanding the staff's perspective on simulator performance testing:
1. "Performance testing" means testing conducted to verify a simulation facility's performance as compared to actual or predicted reference plant performance.
 
2. "Plant-referenced simulator" means a simulator modeling the systems of the reference plant with which the operator interfaces in the control room, including operating consoles, and which permits use of the reference plant's procedures.
 
3. "Reference plant" means the specific nuclear power plant from which a simulation facility's control room configuration, system control arrangement, and design data are derived.
 
The simulator must meet specific regulatory requirements, as described in 10 CFR 55.46(c) and 10 CFR 55.46(d), for the Commission to accept a simulation facility consisting solely of a plant-referenced simulator for conducting operating tests, as described in 10 CFR 55.45(a) and 10 CFR 55.59(a)(2); for requalification training, as described in 10 CFR 55.59(c)(3); or for performing control manipulations that affect reactivity to establish eligibility for an operator's license, as described in 10 CFR 55.31(a)(5).  Specifically, 10 CFR 55.46(c) prescribes the minimum scope and fidelity requirements for a plant-referenced simulator, while 10 CFR 55.46(d) prescribes the performance testing requirements necessary for continued assurance of simulator fidelity.
 
The underlying purpose of the performance testing requirement is to ensure that plant-referenced simulators (when used to meet operator licensing requirements) demonstrate on a continuing basis (1) expected plant response to operator input and to normal, transient, and accident conditions to which the simulator has been designed to respond, and (2) sufficiency in scope and fidelity to allow conduct of the evolutions associated with operating test content and licensed operator requalification program on-the-job training, applicable to the design of the reference plant.  Additionally, the Commission's regulations in 10 CFR 55.46(c)(2) require that facility licensees that propose to use a plant-referenced simulator to meet the experience requirements in 10 CFR 55.31(a)(5) ensure that (1) the plant-referenced Rev. 4 of RG 1.149, Page 4  simulator utilizes models relating to nuclear and thermal-hydraulic characteristics that replicate the most recent core load in the nuclear power reference plant for which a license is being sought, and (2) simulator fidelity has been demonstrated so that significant control manipulations are completed without procedural exceptions, simulator performance exceptions, or deviation from the approved training scenario sequence.
 
ANSI/ANS-3.5-2009, "Nuclear Power Plant Simulators for Use in Operator Training and Examination" On September 4, 2009, ANSI approved ANSI/ANS-3.5-2009, "Nuclear Power Plant Simulators for Use in Operator Training and Examination" (Ref. 8), as an American National Standard.  The ANS Standards Committee Working Group ANS-3.5 developed and approved this industry consensus standard.  The 2009 version is the sixth issuance of the standard since its initial approval in 1979.  The revised standard received substantial support from a diverse and dedicated group of professionals, representing many utilities and interested parties, experienced in the use of full-scope nuclear power plant simulators.  The ANS-3.5 Working Group comprised a wide range of utility, independent and industry oversight organizations (including official representatives from the Institute of Nuclear Power Operations and the NRC) during the development of the revised standard.
 
The revised standard continues to establish the functional requirements for full-scope nuclear power plant control room simulators for use in operator training and examination, as well as criteria for the scope of simulation, performance, and functional capabilities of simulators.  In addition to enhanced readability, users of the revised standard will find improvements and clarifications in simulator scenario-based performance testing, new sections addressing simulator core performance testing and postevent simulator testing, and other important guidance required to ensure accurate simulation for use in operator training and examination.
 
NEI 09-09, "Nuclear Power Plant-Referenced Simulator Scenario Based Testing Methodology" On December 11, 2007 (Ref. 9), the NRC and the Nuclear Energy Institute (NEI) Licensed Operator Focus Group agreed, in principle, on a methodology for performing, evaluating, and documenting simulator scenario-based testing (SBT) that facilitates implementation of a standardized approach to SBT mutually acceptable to both parties.
 
On December 8, 2009, NEI provided for NRC review and endorsement its industry guidance document, NEI-09-09, Revision 1, "Nuclear Power Plant-Referenced Simulator Scenario Based Testing Methodology" (Ref. 10), which provides an equitable and consistent approach and methodology for the conduct and documentation of SBT, as described in Section 4.4.3.2, "Simulator Scenario-Based Testing,"
of ANSI/ANS-3.5-2009.
 
==C. REGULATORY POSITION==
1. Use of Voluntary Consensus Standards The National Technology Transfer and Advancement Act of 1995 (Pub. L. 104-113)
(Ref. 11) requires that Federal agencies use technical standards developed or adopted by voluntary consensus standard bodies unless the use of such a standard is inconsistent with applicable law or otherwise impractical.  NRC representatives participated in the development of ANSI/ANS-3.5-2009 in support of Rev. 4 of RG 1.149, Page 5  its mission and to encourage industry to develop a standard that the NRC can endorse and industry (e.g., simulation facility licensees) can voluntarily carry out.


2. NRC Acceptance and Endorsement of ANSI/ANS-3.5-2009 In general, the NRC accepts and endorses industry consensus standards through incorporation by reference in regulations and through reference in such documents as regulatory guides, NUREG reports, standard review plans, and technical specifications.  The NRC recognizes that the designation of ANSI/ANS-3.5-2009 as an American National Standard attests that the principles of openness and due process have been followed in its approval and that a consensus of those directly and materially affected by the standard has been achieved.  Therefore, the agency's sponsoring office, the Office of Nuclear Reactor Regulation (NRR), through reference in this regulatory guide, accepts and endorses ANSI/ANS-3.5-2009 as described below.
3. Appendix A, "Procedure for Documenting Simulator The use of simulators for operator training, including                      Performance," to the standard should be considered an the requirements which specify the similarity that must                        *integral part of the standard.


The clarifications outlined in the following paragraphs apply to the Commission's endorsement of ANSI/ANS-3.5-2009.
ICopies are available for public inspection or copying for a fee at the        4. The simulator performance test discussed in Sec- NRC Public Document Room, 1717 H Street NW., Washington, D.C.,                  tion 5.4, "Simulator Performance Testing," of the standard or copies may be purchased for $2.50 directly from NRC by sending check or money order payable to the Superintendent of Documents to the Director, Division of Technical Information and Document Con-                   2Copies may be obtained from the American Nuclear Society, trol, U.S. Nuclear Regulatory Commission, Washington, D.C. 20555.              555 North Kensington Avenue, LaGrange Park, Illinois 60525.


a. ANSI/ANS-3.5-2009 sets forth provisions acceptable to the NRC staff for (1) addressing minimum design, testing, performance, and configuration criteria for a full-scope plant-referenced simulator, (2) comparing a simulator to its reference plant, (3) upgrading a simulator to reflect changes to reference plant response or control room configuration, and (4) improving simulator fidelity.  As such, ANSI/ANS-3.5-2009 provides methods acceptable to the NRC staff for a facility licensee to demonstrate that, through meeting the criteria of the standard, a plant-referenced simulator will be sufficiently complete and accurate to meet the requirements of 10 CFR 55.46.  Although the scope statement of ANSI/ANS-3.5-2009 is limited to the use of full-scope nuclear power plant simulators in operator training and examination, the staff has concluded that simulators meeting this standard should also be satisfactory for meeting the applicant experience requirements described in 10 CFR 55.31(a)(5). b. In regard to Section 3.1.4, "Malfunctions," 10 CFR 55.46(d)(1) allows simulation facility licensees to discard malfunction performance tests and test results after 4 years or until superseded by updated test results. Additionally, previous certification of completed simulator malfunction performance tests and results through Form NRC-474, "Simulation Facility Certification," submittals is sufficient evidence that the required malfunction testing has been conducted at least once within the life of the simulator as referenced in NEI-09-09, Revision 1, Section 2, Recommendation Number 4. Through its endorsement of NEI-09-09, Revision 1, without exceptions, the staff concludes that the SBT methodology should provide sufficient assurance that ANS-3.5 required malfunctions remain suitable should they be used for the conduct of licensed operator requalification or initial operating test evolutions.  c. In regard to Section 3.4.1, "Simulator Verification Testing," and Section 3.4.2, "Simulator Validation Testing," the NRC neither expects nor requires the standard's quality assurance methodology (during software model development in a controlled configuration environment) to be included in the facility licensee's quality assurance program, as described in Appendix B, "Quality Assurance Criteria for Nuclear Power Plants and Fuel Reprocessing Plants," to 10 CFR Part 50, "Domestic Licensing of Production and Utilization Facilities" (Ref. 12).  Appendix B does not apply to simulation facilities as defined in and used for meeting 10 CFR Part 55 requirements. d. In regard to Section 3.4.3.2, "Simulator Scenario-Based Testing," simulation facility licensees should meet the requirements of the standard with respect to the following type of SBTs for inclusion as simulator performance tests: (1) NRC initial license examination (operating test) scenarios, (2) licensed operator requalification annual examination (operating test) simulator scenarios, and (3) scenarios used for performing applicant control manipulations that affect reactivity to establish eligibility for an Rev. 4 of RG 1.149, Page 6  operator's license.  All other operator and senior operator training simulator scenarios (such as just-in-time training and routine plant system and equipment startup and shutdown training) are excluded from SBT for purposes of meeting the standard's SBT requirements.  e. In regard to Section 4.4.3.2, "Simulator Scenario-Based Testing," simulation facility licensees should also adhere to the NEI standardized approach for the conduct, performance, and documentation of simulator SBT, as described in NEI 09-09, Revision 1.  The NRC expects licensees to perform simulator performance testing described in Section 4.4.3.1 ("Simulator Operability Testing"), Section 4.4.3.3 ("Simulator Reactor Core Performance Testing"), and Section 4.4.3.4 ("Post-Event Simulator Testing") separately and independently from the testing described in Section 4.4.3.2.
USNRC REGULATORY GUIDES                                      Comments should be sent to the Secretary of the Commission, U.S. Nuclear Regulatory Commission, Washington, D.C. 20555, Regulatory Guides are issued to describe and make available to the             Attention: Docketing and Service Branch.


f. In regard to Section 4.4.3.3, "Simulator Reactor Core Performance Testing," simulation facility licensees should meet the requirements of the standard with respect to real time during the conduct of core evolutions performed in accordance with reference unit proceduresThe NRC expects a facility licensee's plant-referenced simulator to use models relating to nuclear and thermal-hydraulic characteristics that replicate a core load in the nuclear power reference plantIf the plant-referenced simulator is used to meet NRC applicant experience requirements, as described in 10 CFR 55.31(a)(5), then the most recent core load (e.g., the current reference plant core load, or if the reference plant is in a refueling outage, the core load just previous to the outage) in the nuclear power reference plant for which a license is being sought must be utilized.  g. In regard to Section 4.4.3.4, "Post-Event Simulator Testing," simulation facility licensees should meet the requirements of the standard with respect to demonstrating that the plant-referenced simulator's performance and response compares favorably to the reference plant's performance and response without significant deviation from the sequence of events for the reference plant eventSimulation facility licensees are encouraged, but not required, to conduct post-event simulator testing within 120 days of the actual reference plant event.
public methods acceptable to the NRC staff of implementing specific parts of the Commission's regulations, to delineate tech-              The guides are issued in the following ten broad divisions:
nidues used by the staff in evaluating specific problems or postu- lated accidents or to provide guidance to applicants. Regulatory                1.  Power Reactors                  6.  Products Guides are not substitutes for regulations, and compliance with                 2Research and Test Reactors      7Transportation them is not required. Methods and solutions different from those set            3. Fuels and Materials Facilities  8. Occupational Health out in the guides will be acceptable if they provide a basis for the           4. Environmental and Siting        9. Antitrust and Financial Review findings requisite to the issuance or continuance of a permit or                5Materials and Plant Protection  10. General license by the Commission.


3. NRC Acceptance and Endorsement of NEI-09-09, Revision 1
Copies of issued guides may be purchased at the current Government This guide was issued after consideration of comments received from            Printing Office price. A subscription service for future guides in spe- the public. Comments and suggestions for improvements in these                  cific divisions is available through the Government Printing Office.


The NRC staff has reviewed NEI-09-09, Revision 1, and finds the implementation guidance an acceptable method for simulation facility licensees to demonstrate their compliance with the requirements of Sections 3.4.3.2 and 4.4.3.2 of ANSI/ANS-3.5-2009 regarding simulator SBT.  Therefore, the NRC accepts and endorses NEI-09-09 as an acceptable method for an equitable and consistent approach and methodology for the conduct and documentation of SBT, as described in ANSI/ANS-3.5-2009.
guides are encouraged at all times, and guides will be revised, as              Information on the subscription service and cur*rent GPO prices may
.appropriate, to accommodate comments and to reflect new informa-                be obtained by writing the U.S. Nuclear Regulatory Commission, tion or experience.                                                             Washington, D.C. 20555, Attention: Publications Sales Manager.


4. Acceptability of Licensee's Simulation Facility Licensees that maintain simulation facilities certified under previous editions of ANSI/ANS-3.5 (1998, 1993, and 1985) endorsed by the NRC are encouraged to, but are not required to, revise the software and testing documentation to maintain the simulation facility in accordance with ANSI/ANS-3.5-2009.  The NRC expects that a simulation facility will be maintained in accordance with a single version of the standard, preferably ANSI/ANS-3.5-2009.
should include as a minimum all the provisions of Appen-            described in this guide will be used in the evaluation of all dix.A to the standard.                                               simulators placed in operation after August 1, 1984, that are used for training nuclear powerjplant 6operators and others
      5. Sections 2.1, 2.2. and 2.3 of Appendix A to. the              whose. duties require an- operator's or senior operat6r's- standard require documentation of equipment lineup as              Aicense. In addition, all simulators currently in use or placed part of the simulator data base for steady state operating          in use prior to August 1, 1984, for training nuclear power conditions, transient operating conditions, and significant        ,plant operators and others whose duties require an operator's plant-occurring events. Equipment lineup documentation              or senior operator's license will be evaluated in accordance need only include equipment that may have an observabl'e            with the following schedule:
'effect on the expected plant response being considered.


5. Use of Simulation Facility for Multiple Plants a. If a simulation facility licensee desires to use its plant-referenced simulator to train and or examine operators and senior operators for more than one nuclear power plant (other than the reference plant), the licensee must be able to demonstrate to the NRC staff that the differences between the nuclear power plants are not so significant that they will result in negative training. This demonstration should Rev. 4 of RG 1.149, Page 7  include an analysis and summary of the differences between each nuclear power plant, including the following:
I. The requirements of Section 1, "Simulator Informa-
(1) facility design and systems relevant to control room personnel, (2) technical specifications, (3) procedures, primarily abnormal and emergency operating procedures, (4) control room design and instrument control location, and
      6. Item 2 of Section 3.2, "Abnormal Operations," of              tion," of Appendix A to the standard should be complete Appendix A to the standard should be taken to mean that             by August 1, 1982, or by the time the simulator is placed in although Section 3.1.2 of the stafidard requires that a              operation for training, whichever is later.
(5) operational characteristics.


b. The NRC will administer operating tests only on a plant-referenced simulator that meets the Commission's requirements, as described in 10 CFR 55.46.  In addition, a licensee must request Commission approval if the licensee plans to administer the NRC operating test using other than a plant-referenced simulator or the actual plant.
minimum of 75 malfunctions be simulated, each simulator will most likely be capable of simulating more than the                  2. The requirements of Section 2, "Simulator Data Base,"
  minimum; therefore, every malfunction that can be intro&            of Appendix A to the standard should be complete by duced into the simulator by the instructor should be tested.        August 1, 1982, or by the time the simulator is placed in operation for training, whichever is later.


6. Use of Other Simulation Devices  If a simulation facility licensee desires to use other simulation devices, including part-task and limited scope simulation devices, approved under 10 CFR 55.46(b) to train and or examine operators and senior operators, the licensee must be able to demonstrate to the NRC staff that use of such devices will not result in negative training. The NRC staff recognizes that other simulation devices not approved under 10 CFR 55.46(b) are being used extensively to supplement operator and senior operator training in classroom settings or on personal computers or both.  The NRC acknowledges the use of other simulation devices when simulation models have been derived directly from the facility licensee's plant-referenced simulator.
7. The terms "transients,"    "abnormal conditions,"
  "abnormal operations," and "abnormal evolutions" used in                3. The tests discussed in Section 3, "Simulator Tests,"
  the standard should be considered equivalent to "anticipated        of Appendix A to the standard shouldbe conducted and the operational occurrences."                                            initial documentation should be complete by August 1, 1983, or by the time the simulator is placed in operation for training, whichever is later.


==D. IMPLEMENTATION==
==D. IMPLEMENTATION==
The purpose of this section is to provide information on how applicants and licensees
4. Deviation from the data base should be corrected and The purpose of this section is to provide information           the simulator should be in full compliance with the require- to applicants regarding the NRC staff's plans for using this         ments of ANSI/ANS 3.5-1981 as modified by this guide by regulatory guide. Except in those cases in which an applicant        August 1, 1984, or by the time the simulator is placed in proposes an acceptable alternative method, the method                operation for training, whichever is later.
1 may use this guide and information regarding the NRC's plans for using this Regulatory Guide. In addition, it describes how the NRC staff has complied with the Backfit Rule, 10 CFR 50.109 and any applicable finality provisions in 10 CFR Part 52.


Applicant and Licensees' Use Applicants and licensees may (i.e., voluntarily) use the information in this regulatory guide to develop applications for initial licenses, amendments to licenses, or other requests for NRC regulatory approval (e.g., exemptions).  Licensees may use the information in this regulatory guide for actions which do not require prior NRC review and approval (e.g., changes to a facility design under 10 CFR 50.59 which do not require prior NRC review and approval).  Licensees may use the information in this Regulatory Guide or applicable parts to resolve regulatory or inspection issues (e.g., by committing to comply with provisions in the regulatory guide).
.1.149-2
Current licensees may continue to use the guidance that was found acceptable for complying with specific portions of the regulations as part of their license approval process, which may be a previous version of this Regulatory Guide.


1 In this section, "licensees" refers to licensees of nuclear power plants under 10 CFR Parts 50 and 52; and the term "applicants," refers to applicants for licenses and permits for (or relating to) nuclear power plants under 10 CFR Parts 50 and 52, and applicants for standard design approvals and standard design certifications under 10 CFR Part 52.
VALUE/IMPACT STATEMENT
  1. ACTION                                                                Plant Personnel" uses the adjectives "suitable" (Paragraph
                                                                            5.2.1) or "appropriate" (Paragraphs 5.2.4 and 5.5.1.2.2)
  1.1 Description                                                          when describing reactor simulators used for training person- nel. The value of this action to the NRC is the availability Prior to issuing an operator's license to an applicant, the          of guidance on what is a "suitable" or "appropriate"
Commission regulations require that evidence be shown that                reactor simulator against which to review licensee training the applicant has learned to operate the controls in a compe-            programs for adequacy. The impact of this action on the tent and safe manner. In accordance with ANSI/ANS 3.1-1978,              NRC will be that of the time spent in developing the
"Qualification and Training of Personnel for Nuclear Power                guidance, reviewing the licensees' proposals to comply with Plants," and Regulatory Guide 1.8, "Personnel Selection and               the guide, and verifying implementation of the proposals.


Rev. 4 of RG 1.149, Page 8  A licensee who believes that the NRC staff is inappropriately imposing this Regulatory Guide as part of a request for a license amendment or request for a change to a previously issued NRC regulatory approval may file a backfitting appeal with the NRC in accordance with applicable procedures.
Training,"* reactor simulators may be used to partially fulfill this requirement. In addition, Appendix A to 10 CFR                  1.3.2 Other Government Agencies Part 55 describes the use of simulators for requalification programs, and NUREG-0094, "NRC Operator Licensing                            This action should not impact other government agencies,.
Guide,"*
* describes the use of simulators for initial licensing.        unless the government agency is an applicant, such as TVA.


NRC Staff Use The NRC staff does not intend or approve any imposition or backfitting of the guidance in this Regulatory Guide.  The staff does not expect any existing licensee to use or commit to using the guidance in this Regulatory Guide in the absence of a licensee-initiated change to its licensing basis.  The NRC staff does not expect or plan to request licensees to voluntarily adopt this Regulatory Guide to resolve a generic regulatory issue.  The NRC staff does not expect or plan to initiate NRC regulatory action which would require the use of this regulatory guide (e.g. issuance of an order requiring the use of the Regulatory Guide, requests for information under 10 CFR 50.54(f) as to whether a licensee intends to commit to use of this regulatory guide, generic communication, or promulgation of a rule requiring the use of this Regulatory Guide) without further back-fit consideration.
This action provides guidance on the acceptable character- istics of reactor simulators used for operator training as                    1.3.3 Industry, described in the above references.


During inspections of specific facilities, the staff may suggest or recommend that licensees consider various actions consistent with staff positions in this regulatory guide, as one acceptable means of meeting the underlying NRC regulatory requirement.  Such suggestions and recommendations would not ordinarily be considered backfitting even if prior versions of this Regulatory Guide are part of the licensing basis of the facility with respect to the subject matter of the inspection.  However, unless this regulatory guide is part of the licensing basis for a plant, the staff may not represent to the licensee that the licensee's failure to comply with the positions in this Regulatory Guide constitutes a violation.
The result of this action is expected to be the addition
  1.2 Need for Action                                                      of required functions to simulators that may now be in use for specific nuclear, power plants. The impact on industry
    *The need for improvements in operator training in the areas          will, likely be that of increased cost as more complex of response to abnormal and emergency situations was high-                simulators are. required. An alternative to simulators is the lighted as a result of the operator errors noted in NUREG&0585,           use of the actual power plant for trainin


If an existing licensee seeks a license amendment or change in an already approved area of NRC regulatory concern, the NRC staff's consideration of the request involves a regulatory issue directly relevant to this revised regulatory guide, and the specific subject matter of the new or revised guidance is an essential consideration in the NRC staff's determination of the acceptability of the licensee's request, then the staff may (in the absence of a licensee proposal complying with the underlying NRC regulatory requirement) require the licensee to use this Regulatory Guide as a prerequisite for NRC approval. This is not considered backfitting as defined in 10 CFR 50.109(a)(1) or a violation of any of the issue finality provisions in 10 CFR Part 52.
====g. This use results====
"TMI-2 Lessons Learned Task Force Final Report." Use of                  in lost revenue because the power plant is not available to the actual plant for training operators to respond to accidents          produce electrical power and also results in additional would result in additional challenges to the plant's protective          challenges to the plant protection systems. The value of the features and is therefore undesirable. Thus, additional train-            action to industry should be (1) more efficient operation of ing required to impr6ve, operator performance should be                  the power plant by better trained operators that would performed on simulators. A recommendation to require                      result in a cost savings when the power plant is put on line simulator training for initial and requalification training was          in an expeditious manner and (2) a reduction in operator made to the Commission and accepted. The simulators used                  errors that might cause plant downtime or equipment for current training and proposed future training should                  damage. The value is based on using simulators that more have characteristics that allow the objective of training the             accurately reflect the power plant they represent and that operator to operate the controls in a competent and safe                  simulate additional accidents, transients, and evolutions in a manner to be met. The action discussed in this value/impact              more complete manner than can safely be performed on an statement is e.xpected to ensure that the objective stated                actual plant.


Conclusion This regulatory guide is not being imposed upon current licensees and may be voluntarily used by existing licensees.  In addition, this Regulatory Guide is issued in conformance with all applicable internal NRC policies and procedures governing backfitting.  Accordingly, the NRC's staff issuance of this regulatory guide is not considered backfitting, as defined in 10 CFR 50.109(a)(1), nor is it deemed to be in conflict with any of the issue finality provisions in 10 CFR Part 52.
above will be met.


Rev. 4 of RG 1.149, Page 9 REFERENCES
1.3.4 Public
1. 10 CFR Part 55, "Operators' Licenses," U.S. Nuclear Regulatory Commission, Washington, DC.
1.3 Value/Impact of Action The value to the public will be that better trained
    1.3,1 NRC                                                            operators should reduce the possibility of improper operation of nuclear power plant equipment or systems that could Section 5 of ANSI/ANS 3.1-1978 (endorsed by Regula-                  endanger public health and safety. The impact will be that tory Guide 1.8) "Selection and Training of Nuclear Power                  of slightly higher electrical rates caused by higher costs as explained in Item 1.3.3.


2. 52 FR 9460, "Operator's Licenses and Conforming Amendments," Final Rule, Federal Register , Volume 52, Number 57, p. 9460, Washington, DC, March 25, 1987.
1.4 Decision on Action Second proposed Revision 2 to Regulatory Guide 1.8 entitled              This guide is being issued to .provide recommendations
"Personnel Qualification and Training" was issued for comment              acceptable to the NRC staff on acceptable characteristics of in September 1980.


3. 66 FR 52667, "Operator License Eligibility and Use of Simulation Facilities in Operator Licensing," Final Rule, Federal Register, Volume 66, Number 201, p. 52667, Washington, DC, October 17, 2001.
nuclear power plant simulators for use in operator training.


4. Regulatory Guide 1.149, "Nuclear Power Plant Simulation Facilities for Use in Operator Training and License Examinations," Revision 3, U.S. Nuclear Regulatory Commission, Washington, DC, October 2001.
Copies are available for public inspection or copying for a fee at the NRC Public Document Room, 1717 H Street NW., Washington,          


5. ANSI/ANS-3.5-1998, "Nuclear Power Plant Simulators for Use in Operator Training and Examination," American Nuclear Society, La Grange Park, IL, April 15, 1998.
===2. TECHNICAL APPROACH===
D.C., or copies may be purchased for $4.00 directly from NRC by sending check or money order payable to the Superintendent of Documents to the Director, Division of Technical Information and               The decision to use simulators for training of operators Document Control, U.S. Nuclear Regulatory Commission, Washing- ton, D.C. 20555.                                                          has been made by the Commission.


6. ANSI/ANS-3.5-1993, "Nuclear Power Plant Simulators for Use in Operator Training and Examination," American Nuclear Society, La Grange Park, IL, March 29, 1993.
1.149-3


7. ANSI/ANS-3.5-1985, "Nuclear Power Plant Simulators for Use in Operator Training," American Nuclear Society, La Grange Park, IL, October 25, 1985.
3. PROCEDURAL APPROACH                                              4. STATUTORY CONSIDERATIONS
3.1 Procedural Alternatives                                        4.1 NRC Authority
    1. Regulation                                                      Authority for this guide is derived from the safety


8. ANSI/ANS-3.5-2009, "Nuclear Power Plant Simulators for Use in Operator Training and Examination," American Nuclear Society, La Grange Park, IL, September 4, 2009.
===2. Regulatory guide===
    3. National standard,     endorsed by a regulatory guide requirements of the Atomic Energy Act of 1954, as amended, and the Energy Reorganization Act of 1974 through the
                                                                                                                                    (
                                                                    Commission's regulations; in particular, 10 CFR Part 55
3.2 Value/Impact of Procedural Alternatives                        applies.


3  9. Memo from Nancy L. Salgado, Chief, Operator Licensing and Human Performance Branch, Division of Inspection and Regional Support (DIRS), Office of Nuclear Reactor Regulation (NRR), to Frederick D. Brown, Director, DIRS, NRR, re:  Summary of December 11, 2007, Meeting with Industry Focus Group on Operator Licensing Issues, January 3, 2008. (Agencywide Documents Access and Management System (ADAMS) Accession No. ML073511714) 
The value of alternative 1, a regulation, is that it would have the full force and authority of a law. The impact of           4.2 Need for NEPA Assessment alternative 1 is that it would lack flexibility in implementa- tion. The value of alternative 2, a regulatory guide, is that it        An environmental impact statement is not required since would achieve the desired result with suitable flexibility for      this guide is not a major action that may significantly affect innovation by licensees. The impact of alternative 2is that          the quality of the human environment.
10. Letter to the NRC from John C. Butler, Director, Operations Support, Nuclear Generation Division, NEI, to John McHale, Chief, Operator Licensing and Training Branch, DIRS, NRR, re:  NEI 09-09, "Nuclear Power Plant-Referenced Simulator Scenario Based Testing Methodology," Revision 1, December 8, 2009.  (ADAMS Accession Nos. ML093521654 (cover letter) and ML093521659 (associated attachment))
11. The National Technology Transfer and Advancement Act of 1995, Pub. L. 104-11


===3.      ===
it may not take full advantage of the work performed by industry in the area the guide addresses, which may result in a longer development period prior to issuing the guide.          5. RELATIONSHIP TO OTHER EXISTING OR PROPOSED
2  All publicly available NRC documents are available electronically through the Electronic Reading Room on the NRC's public Web site at http://www.nrc.gov/reading rm/doc collections/cfr/. The documents can also be viewed on-line for free or printed for a fee in the NRC's Public Document Room (PDR) at 11555 Rockville Pike, Rockville, MD; the mailing address is USNRC PDR, Washington, DC 20555; telephone (301) 415-4737 or (800) 397-4209; fax (301) 415 3548; and e mail pdr.resource@nrc.gov. 3  Copies of American Nuclear Society (ANS) standards may be purchased from the ANS Web site (http://www.new.ans.org/store/); or by writing to: American Nuclear Society, 555 North Kensington Avenue, La Grange Park, Illinois 60526, U.S.A., Telephone 800-323-3044.
The value of alternative 3, a standard endorsed by a regu-              REGULATIONS OR POLICIES
latory guide, is that it would achieve the desired result while taking advantage of the work performed by industry                Regulatory Guide 1.8 and Appendix A to 10 CFR Part 55 in its development of ANSI/ANS 3.5-1981, "Nuclear Power              make reference to simulators used in the training program Plant Simulators for Use in Operator Training." The impact          for operators. In these documents, only general.statements of alternative 3 is that effort would have to be expended by        are made concerning the characteristics of acceptable simu- the NRC in preparing, reviewing, and issuing the regulatory          lators. This guide is consistent with existing and proposed guide. It is estimated, however, that the effort spent on the        requirements and guidelines for simulators.


Rev. 4 of RG 1.149, Page 10  12. 10 CFR Part 50, "Domestic Licensing of Production and Utilization Facilities," U.S. Nuclear Regulatory Commission, Washington, DC.
action would be greater if alternatives 1 or 2 were chosen.


13. 10 CFR Part 52, "Licenses, Certifications, and Approvals for Nuclear Power Plants," U.S. Nuclear Regulatory Commission, Washington, DC.}}
3.3 Decision on Procedural Approach                                  6. SUMMARY AND CONCLUSION
    The action has been accomplished by publishing a                    Regulatory Guide 1.149, "Nuclear Power Plant Simulators regulatory guide endorsing ANSI/ANS 3.5-1981, "Nuclear              for Use in Operator Training," has been prepared. It endorses, Power Plant Simulators for Use in Operator Training."                with certain exceptions, ANSI/ANS 3.5-1981.                    (
            UNITED STATES
NUCLEAR REGULATORY COMMISSION
        WASHINGTON, D. C. 20555
                                    1194060020CL                  I QPISIR
                                    LS NRC REGION I
                                    CFFICE Of INSPECILON & ENFORCE
                                    R J BORES
                                    631 PARK AVENUE
                                    REGION I
                                    KING OF PRUSSIA                      PA      1940C
                                                            1.149-4}}


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Latest revision as of 21:46, 11 November 2019

Nuclear Power Plant Simulators for Use in Operator Training
ML12305A245
Person / Time
Issue date: 04/30/1981
From:
Office of Nuclear Regulatory Research, NRC Region 1
To:
References
Task RS 110-5 RG 1.149
Download: ML12305A245 (4)


4" U.S. NUCLEAR REGULATORY COMMISSION April 1981

~REGULATORY GUIDE

0' OFFICE OF NUCLEAR REGULATORY RESEARCH

REGULATORY GUIDE 1.149 (Task RS 110.5)

NUCLEAR POWER PLANT SIMULATORS FOR USE IN OPERATOR TRAINING

A. INTRODUCTION

exist between a simulator and the facility that the operators are being trained to operate, is addressed in 10 CFR Part 55, Appendix A, "Requalification Programs for Licensed Oper- "Operators' Licenses." This issue, the similarity that must ators of Production and Utilization Facilities," to 10 CFR exist between a simulator and the facility that the operators Part 55, "Operators' Licenses," permits use of simulators for are being trained to operate, is not addressed in the guide and operator training. should not be confused with the guidance provided that speci- fies the similarity that should exist between a simulator and This regulatory guide describes a method acceptable to its reference plant.

the NRC staff for specifying the functional requirements of a nuclear power plant simulator to be used for operator

C. REGULATORY POSITION

training.

The requirements established by ANSI/ANS 3.5-1981, The Advisory Committee on Reactor Safeguards has "Nuclear Power Plant Simulators for Use in Operator Train- been consulted concerning this guide and has concurred in ing," for specifying the functional capability of a simulator the regulatory position. and for comparing a simulator to its reference plant are acceptable to the NRC staff, subject to the following:

B. DISCUSSION

1. The standard identifies at the point of reference The need for improvements in operator training in the areas (Section 1.1, "Background Data") other documents to be of response to abnormal and emergency situations was high- included as part of the standard. The applicability of these lighted as a result of the operator errors noted in NUREG-0585, documents should be determined by referring to the latest

"TMI-2 Lessons Learned Task Force Final Report."' Use of revision of the following regulatory guides and the version the actual plant for training operators to respond to accidents of the standard the guide endorses:

would result in additional challenges to the plant's protective

2 features and is therefore undesirable. Thus, the additional ANS Standard Regulatory Guide training required to improve operator performance should be performed on simulators. In order to maximize the effective- 3.1 1.8 ness of this training, the simulator must be kept current with 3.2 1.33 changes in the reference plant and lessons learned from operating experience. Recommendations of instructors and 2. Section 3.1.2, "Plant Malfunctions," lists the abnormal operator trainees for improving a simulator should be encour- and emergency conditions that must be performed by the aged. ANSI/ANS 3.5-1981, "Nuclear Power Plant Simulators simulator if applicable to the reference plant. A simulator for. Use in Operator Training," 2 in conjunction with this should also be able to perform diesel generator failure.

regulatory guide, provides guidance in these areas.

3. Appendix A, "Procedure for Documenting Simulator The use of simulators for operator training, including Performance," to the standard should be considered an the requirements which specify the similarity that must *integral part of the standard.

ICopies are available for public inspection or copying for a fee at the 4. The simulator performance test discussed in Sec- NRC Public Document Room, 1717 H Street NW., Washington, D.C., tion 5.4, "Simulator Performance Testing," of the standard or copies may be purchased for $2.50 directly from NRC by sending check or money order payable to the Superintendent of Documents to the Director, Division of Technical Information and Document Con- 2Copies may be obtained from the American Nuclear Society, trol, U.S. Nuclear Regulatory Commission, Washington, D.C. 20555. 555 North Kensington Avenue, LaGrange Park, Illinois 60525.

USNRC REGULATORY GUIDES Comments should be sent to the Secretary of the Commission, U.S. Nuclear Regulatory Commission, Washington, D.C. 20555, Regulatory Guides are issued to describe and make available to the Attention: Docketing and Service Branch.

public methods acceptable to the NRC staff of implementing specific parts of the Commission's regulations, to delineate tech- The guides are issued in the following ten broad divisions:

nidues used by the staff in evaluating specific problems or postu- lated accidents or to provide guidance to applicants. Regulatory 1. Power Reactors 6. Products Guides are not substitutes for regulations, and compliance with 2. Research and Test Reactors 7. Transportation them is not required. Methods and solutions different from those set 3. Fuels and Materials Facilities 8. Occupational Health out in the guides will be acceptable if they provide a basis for the 4. Environmental and Siting 9. Antitrust and Financial Review findings requisite to the issuance or continuance of a permit or 5. Materials and Plant Protection 10. General license by the Commission.

Copies of issued guides may be purchased at the current Government This guide was issued after consideration of comments received from Printing Office price. A subscription service for future guides in spe- the public. Comments and suggestions for improvements in these cific divisions is available through the Government Printing Office.

guides are encouraged at all times, and guides will be revised, as Information on the subscription service and cur*rent GPO prices may

.appropriate, to accommodate comments and to reflect new informa- be obtained by writing the U.S. Nuclear Regulatory Commission, tion or experience. Washington, D.C. 20555, Attention: Publications Sales Manager.

should include as a minimum all the provisions of Appen- described in this guide will be used in the evaluation of all dix.A to the standard. simulators placed in operation after August 1, 1984, that are used for training nuclear powerjplant 6operators and others

5. Sections 2.1, 2.2. and 2.3 of Appendix A to. the whose. duties require an- operator's or senior operat6r's- standard require documentation of equipment lineup as Aicense. In addition, all simulators currently in use or placed part of the simulator data base for steady state operating in use prior to August 1, 1984, for training nuclear power conditions, transient operating conditions, and significant ,plant operators and others whose duties require an operator's plant-occurring events. Equipment lineup documentation or senior operator's license will be evaluated in accordance need only include equipment that may have an observabl'e with the following schedule:

'effect on the expected plant response being considered.

I. The requirements of Section 1, "Simulator Informa-

6. Item 2 of Section 3.2, "Abnormal Operations," of tion," of Appendix A to the standard should be complete Appendix A to the standard should be taken to mean that by August 1, 1982, or by the time the simulator is placed in although Section 3.1.2 of the stafidard requires that a operation for training, whichever is later.

minimum of 75 malfunctions be simulated, each simulator will most likely be capable of simulating more than the 2. The requirements of Section 2, "Simulator Data Base,"

minimum; therefore, every malfunction that can be intro& of Appendix A to the standard should be complete by duced into the simulator by the instructor should be tested. August 1, 1982, or by the time the simulator is placed in operation for training, whichever is later.

7. The terms "transients," "abnormal conditions,"

"abnormal operations," and "abnormal evolutions" used in 3. The tests discussed in Section 3, "Simulator Tests,"

the standard should be considered equivalent to "anticipated of Appendix A to the standard shouldbe conducted and the operational occurrences." initial documentation should be complete by August 1, 1983, or by the time the simulator is placed in operation for training, whichever is later.

D. IMPLEMENTATION

4. Deviation from the data base should be corrected and The purpose of this section is to provide information the simulator should be in full compliance with the require- to applicants regarding the NRC staff's plans for using this ments of ANSI/ANS 3.5-1981 as modified by this guide by regulatory guide. Except in those cases in which an applicant August 1, 1984, or by the time the simulator is placed in proposes an acceptable alternative method, the method operation for training, whichever is later.

.1.149-2

VALUE/IMPACT STATEMENT

1. ACTION Plant Personnel" uses the adjectives "suitable" (Paragraph

5.2.1) or "appropriate" (Paragraphs 5.2.4 and 5.5.1.2.2)

1.1 Description when describing reactor simulators used for training person- nel. The value of this action to the NRC is the availability Prior to issuing an operator's license to an applicant, the of guidance on what is a "suitable" or "appropriate"

Commission regulations require that evidence be shown that reactor simulator against which to review licensee training the applicant has learned to operate the controls in a compe- programs for adequacy. The impact of this action on the tent and safe manner. In accordance with ANSI/ANS 3.1-1978, NRC will be that of the time spent in developing the

"Qualification and Training of Personnel for Nuclear Power guidance, reviewing the licensees' proposals to comply with Plants," and Regulatory Guide 1.8, "Personnel Selection and the guide, and verifying implementation of the proposals.

Training,"* reactor simulators may be used to partially fulfill this requirement. In addition, Appendix A to 10 CFR 1.3.2 Other Government Agencies Part 55 describes the use of simulators for requalification programs, and NUREG-0094, "NRC Operator Licensing This action should not impact other government agencies,.

Guide,"*

  • describes the use of simulators for initial licensing. unless the government agency is an applicant, such as TVA.

This action provides guidance on the acceptable character- istics of reactor simulators used for operator training as 1.3.3 Industry, described in the above references.

The result of this action is expected to be the addition

1.2 Need for Action of required functions to simulators that may now be in use for specific nuclear, power plants. The impact on industry

  • The need for improvements in operator training in the areas will, likely be that of increased cost as more complex of response to abnormal and emergency situations was high- simulators are. required. An alternative to simulators is the lighted as a result of the operator errors noted in NUREG&0585, use of the actual power plant for trainin

g. This use results

"TMI-2 Lessons Learned Task Force Final Report." Use of in lost revenue because the power plant is not available to the actual plant for training operators to respond to accidents produce electrical power and also results in additional would result in additional challenges to the plant's protective challenges to the plant protection systems. The value of the features and is therefore undesirable. Thus, additional train- action to industry should be (1) more efficient operation of ing required to impr6ve, operator performance should be the power plant by better trained operators that would performed on simulators. A recommendation to require result in a cost savings when the power plant is put on line simulator training for initial and requalification training was in an expeditious manner and (2) a reduction in operator made to the Commission and accepted. The simulators used errors that might cause plant downtime or equipment for current training and proposed future training should damage. The value is based on using simulators that more have characteristics that allow the objective of training the accurately reflect the power plant they represent and that operator to operate the controls in a competent and safe simulate additional accidents, transients, and evolutions in a manner to be met. The action discussed in this value/impact more complete manner than can safely be performed on an statement is e.xpected to ensure that the objective stated actual plant.

above will be met.

1.3.4 Public

1.3 Value/Impact of Action The value to the public will be that better trained

1.3,1 NRC operators should reduce the possibility of improper operation of nuclear power plant equipment or systems that could Section 5 of ANSI/ANS 3.1-1978 (endorsed by Regula- endanger public health and safety. The impact will be that tory Guide 1.8) "Selection and Training of Nuclear Power of slightly higher electrical rates caused by higher costs as explained in Item 1.3.3.

1.4 Decision on Action Second proposed Revision 2 to Regulatory Guide 1.8 entitled This guide is being issued to .provide recommendations

"Personnel Qualification and Training" was issued for comment acceptable to the NRC staff on acceptable characteristics of in September 1980.

nuclear power plant simulators for use in operator training.

Copies are available for public inspection or copying for a fee at the NRC Public Document Room, 1717 H Street NW., Washington,

2. TECHNICAL APPROACH

D.C., or copies may be purchased for $4.00 directly from NRC by sending check or money order payable to the Superintendent of Documents to the Director, Division of Technical Information and The decision to use simulators for training of operators Document Control, U.S. Nuclear Regulatory Commission, Washing- ton, D.C. 20555. has been made by the Commission.

1.149-3

3. PROCEDURAL APPROACH 4. STATUTORY CONSIDERATIONS

3.1 Procedural Alternatives 4.1 NRC Authority

1. Regulation Authority for this guide is derived from the safety

2. Regulatory guide

3. National standard, endorsed by a regulatory guide requirements of the Atomic Energy Act of 1954, as amended, and the Energy Reorganization Act of 1974 through the

(

Commission's regulations; in particular, 10 CFR Part 55

3.2 Value/Impact of Procedural Alternatives applies.

The value of alternative 1, a regulation, is that it would have the full force and authority of a law. The impact of 4.2 Need for NEPA Assessment alternative 1 is that it would lack flexibility in implementa- tion. The value of alternative 2, a regulatory guide, is that it An environmental impact statement is not required since would achieve the desired result with suitable flexibility for this guide is not a major action that may significantly affect innovation by licensees. The impact of alternative 2is that the quality of the human environment.

it may not take full advantage of the work performed by industry in the area the guide addresses, which may result in a longer development period prior to issuing the guide. 5. RELATIONSHIP TO OTHER EXISTING OR PROPOSED

The value of alternative 3, a standard endorsed by a regu- REGULATIONS OR POLICIES

latory guide, is that it would achieve the desired result while taking advantage of the work performed by industry Regulatory Guide 1.8 and Appendix A to 10 CFR Part 55 in its development of ANSI/ANS 3.5-1981, "Nuclear Power make reference to simulators used in the training program Plant Simulators for Use in Operator Training." The impact for operators. In these documents, only general.statements of alternative 3 is that effort would have to be expended by are made concerning the characteristics of acceptable simu- the NRC in preparing, reviewing, and issuing the regulatory lators. This guide is consistent with existing and proposed guide. It is estimated, however, that the effort spent on the requirements and guidelines for simulators.

action would be greater if alternatives 1 or 2 were chosen.

3.3 Decision on Procedural Approach 6. SUMMARY AND CONCLUSION

The action has been accomplished by publishing a Regulatory Guide 1.149, "Nuclear Power Plant Simulators regulatory guide endorsing ANSI/ANS 3.5-1981, "Nuclear for Use in Operator Training," has been prepared. It endorses, Power Plant Simulators for Use in Operator Training." with certain exceptions, ANSI/ANS 3.5-1981. (

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