ML20247M741

Forwards Response to 890526 Requests for Addl Info Re Certification of Simulation Facility. Braidwood Procedure Generation Package & Production Training Dept,Braidwood, Malfunctions & Initial Conditions Encl

ML20247M741
Person / Time
Site:	Byron, Braidwood, 05000000
Issue date:	07/27/1989
From:	Trzyna G COMMONWEALTH EDISON CO.
To:	Office of Nuclear Reactor Regulation
Shared Package
ML20247M747	List: ML20247M741 ML20247M758 ML20247M766 ML20247M780 ML20247M786 ML20247M792 ML20247M801 ML20247M820 ML20247M866 ML20247M874 ML20247M915 ML20247N042 ML20247N062
References
NUDOCS 8908020210
Download: ML20247M741 (11)

Text

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.,' Commonwrith Edison

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'fM# 72 v West Adams Street, Chicago, Illinois .

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j l g'V Chcago, Illinois 60690 0767J. Kddress Rippli to

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July 27, 1989 Director of Nuclear Reactor Regulation US Nuclear Regulatory Commission j Mail Station P1-137 1 Washington, DC 20555- ')

Subject:

' Byron /Braidwood Simulator Facility Response to Request for Additional Information '

NRC Docket'Nos. 50-454, 455. 456. and 457

Reference:

'May 26, 1989 letter from S.P. Sands to T.J. Kovach Gentlemen 1 l

Our submittal of October 7, 1988 provided information pursuant to 1

-10 CFR 55.45.b.5 in order to attain Certification of the Braidwood Simulation l Facility. Your review'of our submittal indicated the need_for additional information in order to ensure the completeness of the documentation associated with the certification. process. Your request for additional

-information was transmitted to us by the letter indicated in the above' ,

reference. Our response to your request is provided in the Attachment'to this I letter.

Each of the seventeen questions contained in your Enclosure was addressed by the Simulator Review Board. This Board is composed of members with responsibilities in the areas of Simulator Configuration Management .j Control and Simulator Fidelity. In addition, the Board included the Siinulator .

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Training Supervisor and Senior Reactor Operator representatives from both l Byron and Braidwood Stations. j

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The responses to the questions in your request are supported by seventeen additional Attachments. One copy of these Attachments is being provided at this time. Please advise us if you require additional copies of this material.

Please forward any questions that you may have regarding this matter to this office. 1 j

very truly yours,

/  !

i G.E. Trzyna Nuclear Licensing Administrator ,

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/scJ 0222T 1 Att.

cc A.B. Davis-w/o Att.'s 00 S.P. Sands-w/o Att.'s I

'I l 1 8908020210 890727 3 PDR ADOCK 05000454 .i

p. PDC l

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BRAIDWOOD SIMULATOR CERTIFICATION l- .

RESPONSE TO NRC QUESTIONS w

l 11 ATTACHMENTS

1. Normal Operations Test Abstract (NO-1) 1

2. Real Time Test Abstract (RT-1)

3. Valve Stroke Time Test Abstract (ST-1)

4. Surveillance Test Abstract (SV-1)

5. Malfunction Tests Abstract / Initial Conditions

6. Simulator Tasting Program Procedure

7. Dyron Units 1/2 Control Room Layout

8. Braidwood Units 1/2 Control Room Layout

9. Simulator Control Room Layout

10. Revised Panels / Equipment Listing

11. Transient Tests Baseline Data

12. Rx Trip /SI Procedure - Braidwood Unit 1

13. Rx Trip /SI Procedure - Braidwood Unit 2

14. Rx Trip /SI Procedure - Byron Unit 1

15. Rx Trip /SI Procedure - Byron Unit 2

16. Braidwood Procedure Generation Package

17. Steady State Test (SS-1) 0222T:2

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JOusation;1:j Your submittal includsd performance. test abstracts only for' steady state l tests.atl30%,i SO%, 75%, and 100% power and the' ten ANSI /ANS-3.5-1985,

[.. Appendix B transient' tests. Regulatory Guide 1.149 explains that the performance testing to be performed is that' described 'in ANSI /ANS-3.5-1985,' Section 5.4, " Simulator Testing." This section states that the' simulator's performance shall be compared to the requirements of Section 4, " Performance Criteria." Section 4' requires tests for the limiting cases of the evolutions in Sections 3.1.1, " Normal Plant Evolutions,'? and 3.1.2, ." Plant Malfunctions." Tests demonstrating-compliance with-the criteria-of Section 4.3, "S3mulator Operating Limits,"

are also required. Please. provide; performance tests abstracts for these additional tests or provide justification for. exception to the s

requirements'for these tests.

Response 1:

Per your request, Attachments 1-5 are test abstracts for " Normal Plant Evolutior.s", " Plant Malfunctions", and " Simulator Operating Limits".

Attachment 6 describes the administration of'the simulator testing program.

Question 2:

Regarding DR #3 in Attachment A to Form 474; please explain why the simulator and station performed their tests at different core ages'(1.e.

why not initialize the simulator to the same core age as that'for which the data exists)?

Response'2 l

l' The Simulator Review Board has concluded that the steady state test and analysis are valid,as performed. The simulator performed steady state L testing using beginning-of-life (BOL) initial conditions. The simulator BOL initial conditions were not the same core Ege as the. station when it performed its steady state testing. The simulator's boron concentration does not detract from training and'it is not cost-effective to change the simulator's core model in order to change'its core age (boron concentration).

Question 3:

Regarding DR #7 in Attachment A to Form 474; please provide justification for use of this valve stroke time criteria. Include in this justification an explanation of whether the criteria of ANSI /ANS-3.5-1985, Section 4.2,

" Transient Operation," are met. Of particular concern are automatically p actuated valves with stroke times of less than 20 seconds.

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, iRasponsaL33 .c ,

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'IANSI/ANS-3.5-1985, Saction 4.2'critoria are mat. Section 4.11critoria has.

been modified for valve stroke times less than twenty' seconds. The p . . acceptance' criteria for each valve's stroke time is 1-10% of the reference

. plant valve's stroke: time. However, 1 10% of most: valve's stroke time would yield a small tolerance which does not lend itself' to enhanced Loperatoritraining'due'to the fact that the: operator is but directly af fected: by a difference 'in valve stroke time of a f as seconds.

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In response to the 6o-ential problem of changing most valve's stroke. time to that of Braidwoon , our tolerance was changed to 310% or 12 seconds, whichever is greater as long as Braidwood acceptance criteria is not violated. A biennial comparison of Braidwood Unit I valve stroke times to the. simulator valve stroke times will be performed to ensure that the revised valve stroke time critoria will be mainte.'ned. 'See Attachment 3' for a copy of the valve stroke time' test (ST-1). This minor' change in the criteria will not detract.from operator training.

Question 4:

' Item'9, on page 10c/5 in the " Simulator Information" portion of your submittal states lthat the plant computer is not. fully modeled.

ANSI /ANS-3.5-1985, Section 3.2.2,." Controls on Panels," requires "... plant computer interface hardware and other components or displays-that would function during normal, abnormal, and emergency evolutions shall be included in'the simulator." Please confirm that this criteria is met even though the plant computer is not fully modeled or provide justification for' exception.

Response 4:

The in-plant computer possesses sufficient modeling for the operators to review ~che necessary data for the normal, abnormal, and emergency evolutions required by ANSI /ANS-3'.5-1985. Full modeling of the Braidwood in-plant computer will be completed after SUN Computer installation.

Differences exist'between the Byron computer hardware and the simulator computer hardware, however, these differences will not adversely impact training.

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Ou:stion 5:

Ragarding Saction A.1.2.2, " Pan'als/Equipmant," in the " Simulator

'Information" portion of your submittal; it is difficult to determine the

. scope of your panel and equipment simulation as compared to anch of the units'for which you are certifying the simulator. ANSI /ANS-3.5-1985, l Section 3.2.1, " Degree of Panel Simulation," requires that the simulator contain sufficient operational panels to provide the controls, instrumentation, alarms, and other man-machine interfaces to conduct the j normal plant evolutions of 3.1.1 and respond to the malfunctions of 3.1.2. Please confirm that the Braidwood Unit 1 simulator meets these criteria for Braidwood Units 1 &- 2 and Byron Units 1 & 2. Floor plan sketches,-including full panel names, of the simulator and each of the plant control rooms would be helpful. Any differences which preclude operations required by 3.1.1 or 3.1.2 of ANSI /ANS-3.5-1985 should be noted as exceptions and justifications should be provided.

Response 5:

The Braidwood Simulator contains sufficient operational panels to provide the controls, instrumentation, alarms, and other man-machine interfaces to conduct normal plant evolutions of 3.1.1 and respond tc the malfunctions of 3.1.2 for each of the Braidwood and Byron Units to the extent identified in the certification Report. Attachments 7-9 are control room layouts of Byron Units 1/2, Braidwood Units 1/2, and the simulator.

Attachment 10 is a revised listing (page 10c/5 of the Certification Report) of the simulator's Panels / Equipment.

Question 6:

ANSI /ANS-3.5-1985, Section 3.3.1, " Systems Controlled from the Control Room," requires the inclusion of systems and the degree of simulation to be to the extent necessary to perform the normal plant evolutions in 3.1.1 and respond to the n malfunctions in 3.1.2. Items 4,7,8,9 and 10 under A.1.2.2, " Panels / Equipment," and section A.I.2.3, " Systems," in the

" Simulator Information" portion of your submittal, would appear to indicate that the criteria of 3.3.1 of ANSI /ANS-3.5-1985 may not be met in all cases. Any discrepancies which preclude operations required by 3.1.1 or 3.1.2 of ANSI /ANS-3.5-1985, for any of the four units, should be noted as exceptions and justification should be provided.

Response 6:

The minor differences in the Essential Service Water System, Circulating Water System, and Suitchyard/ Electrical Bus nomenclature between the Byron Units and the simulator do not detract from training. In addition, these differences do not impact on the ability to perform the normal plant evolutions in 3.1.1 or respond to the malfunctions in 3.1.2. Most of the tasks related to these differences are minor in nature and are handled administrative 1y.

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Raspon33.6 (Con't) ' s The systems.that are not modelsd'(Saction A.1.2.3 offths Certification

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g Report) do notidetract'from training. The tasks related to-these systems

f. ;are handled administrative 1y to ensure procedural compliance is

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maintained. The Turbine-Generator Temperature Monitoring System, Fire Protection Detection System,'and Radiation Monitors (RM-23's)'are located Joutsidelthe normal operating area. In' addition, these non-modeled systems

'do not impact on the ability to perform the normal plant evolutions in L

.3.1.1 or respond to the malfunctions in 3.1~.2. The Equipment Status

} Display (ESD)~ is located inside the normal operating area 'and is considered' visually simulated hardware until SUN Computer installation.

Question 7:

Regarding item 6 " der A.l.2.2, " Panels / Equipment," in the " Simulator Information" portron of your submittal; it appears that you-are utilizing-

-an operator a10 the sinulator which does not exist in the plant. For examination purpt.an, operator aids which are not used in the plant should

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not be used in thel simulator. Please describe your intentions in this regard.

Response 7:

Operator aids are not used in the simulator unless they are approved for use in the plant. Item 6 of'A.1.2.2 did not intend to imply that meter sideplates were operator aids. However, since the submittal of the Certification Report, ,a Computer-Aided-Drafting System has been developed which can replicate the meter sideplates currently installed at the station. . Work Requests have been written for changing the simulator's meter sideplates to match the plant's meter sideplates. Estimated completion date is January 1, 1990.

Question 8:

Regarding item 18 under A.1.2.2, " Panels / Equipment," in the "Simulat or Information" portion of your submittal; please provide justification for the acceptability'of the failure of'the recorder paper drives to deenergize upon a loss of power to the chart recorders.

Response 8:

The Simulator Review Board has determined that negative training does not occur with the chart drive motors being continuously driven. The chart drive motors are continuously driven to minimize maintenance upkeep. If the chart drive motors are deenergized for a long period of time (i.e.,

weekend / loss of power), the recorder pens become dryed out/ clogged due to a loss of capillary flow and extensive maintenance work would then be required to restore the recorder pens to operable status. Dyron and Braidwood Stations are considering a change to felt-tip pens. If this change occurs, we will reevaluate our position on this matter.

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Ra:ponso'8_(Con't):

Static simulator exams on a frozen simulator can be successfully accomplished by deenergizing each chart recorder by its "on-off" switch.

Question 9 ANSI /ANS-3.5-1985, Section 3.2.3, " Control Room Environment", requires communication systems that a control room operator would use to communicate with an' auxiliary operator or other support activities to be operational to the extent that the simulator instructor, when performing these remote activities, shall be able to communicate over the appropriate communication system. Please provide-justification for the lack of sound powered phone jacks and the lack of simulation of the plant's radio system.

Response 9: ,

The lack of sound-powered phone jacks does not detract from training since sound-powered phones are normally used for maintenance activities in the plant.

The lack of a simulated plant radio system does not detract f rom training since the page'and telephone systems adequately address communications outside the control room.

Question 10:

It is not clear that simulator design data updating and simulator modifications will be performed in accordance with the time frames of ANSI /ANS-3.5-1985, Section 5.2, " Simulator Update Design Data," and 5.3

" Simulator Modifications." Please confirm that these criteria are met or provide justification for exception. Also, please provide a schedule for the planned corrections listed on page 10c/10 of A.1.2.2 of your submittal and for installation of the SUN computer.

Response 10:

The simulator update and modification program meets the requirements of ANSI /ANS-3.5-1985, Sections 5.2 and 5.3. See Attachment 6, Section 3.k.

The status of the items listed on page 10c/10 are listed belows

- Difference #2 (PI-403/405A meter scales), #12 (FW-9 valve operation),

813 (RCFC vibration moniters) and #17 (turbine audio block circuit) ,

i have already been corrected.

- Difference #14 (SPDS subcooling/ lou setpoints) will be corrected upon SUN computer installation. Eatimated completion date for SUN Computer installation is November, 1990.

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.Qupstion 112 ,

' i Ws Ti DANSI/ANS-3.5-19'85,- Section 3.4.1,:" Initial. Conditions," rsquires initial

' ' conditions to-include.various times in core life. The set of initial

, i  ! conditions provided with your certification does not include any

, end-of-life (EOL). conditions. Please provide justification for the-lack.

} of such, initial conditions.

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Response lit.

The' list of initial conditions (IC's). incorrectly;11sted.IC-26,:28-30 as beginning-of-lifeL(BOL), initial conditions. IC-26,-28-30 are end-of-lifo

.(EOL). initial conditions. See Attachment 5 for the list'of initial-L conditions.

s.

LQuestion 12: I 10 CFR.55.45(b)('5)(vi) r+ quires "...the conduct of approximately 25 percent of the performance testa per year for the subsequent four years" following any certification report. However,'your " Proposed' Simulator

. Malfunction Testing -Schedule" indicates that you intend to perform 33

. percent of the testing in the fourth. year. It is recommended that you revise'your schedule-to more nearly perform 25. percent per year. Please provide a revised schedule.or provide jur.tification for not doing so.

( Response 12:

A revised simulator testing schedule for.the four years of fpost-certification malfunction testing is listed in Attachment B of Attachment 6. 'Please note that a new malfunction (AUX-17) hasibeen added to the malfunction testing schedule. Each year of malfunction testing contains 25% 12.5% of the total malfunctions required to be tested.

Please note that Attachment C of Attachment 6 contains non-certified' a malfunctions that are currently used to enhance operator training.

. Question 13:

NUREG-1258 states, "it is essential, for the conduct of a license examination,.that the simulation facility permit a candidate to' mitigate

.the consequences of an event using the reference plant's Umergency Operating Procedures (EOPs). It must also be possible for the candidate

,to employ the reference plant's normal and abnormal operating procedures as required." Regarding Attachment 1, " Reg. Guide 1.149 Requirements for Dual Plant Simulation Facility," to Form 474, pages 11c/119 and 11c/120; please ' provide justification for not using the Unit 2 training disc for abnormal operations or casualty training, and for not maintaining Unit 2 abnormal and emergency procedures for the simulator.

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R2sponta 13:

Sinco Unit l'and Unit 2 are almost idantical, except for the steam l

generator model (the differences are listed on pages 11c/119-120 of the

,- Certification Report), adequate Unit 2 training is conducted by

, concentrating on low-power operations (i.e., startups, shutoowns, abnormal and casualty operations up to 30%) by using the Unit 2 training disc. The l Unit 1 disc correctly simulates plant response for both units above 30%.

Since the' submittal of the Certification Report, abnormal operations and casualty training have been conducted on the Unit 2 training disc.

Unit 2 abnormal and emergency procedures are not maintained in the simulator since the Unit I abnormal and emergency procedures are utilized for Unit 2 abnormal operations and casualty training. The Unit 2 abnormal ano. emergency procedures are developed from Unit 1 abnormal and emergency-procedures and are almost identical as shown by the "Rx Trip /SI Procedure" in Attachments 12-15 for each of the four units (Units 1/2 for Byron and Braidwood). Byron and Braidwood emergency procedures are validated on the simulator. Attachment 16, page 3 of 50 states that commonality between Byron and Braidwood Stations allow the reference validation method to provide validation of the other three units emergency procedures. In addition, page 4 of 9 (section 6.3) discusses the step-by-step review of the individual Braidwood and Byron emergency procedure revisions to ensure consistency of information between each of the four units. Attachment 16 also contains setpoint documentation sheets that are utilized for Units 1/2 emergency procedure setpoints. The only setpoint deviations between Units 1/2 are on pages 62, 65 and 67 for the no-load S/G 1evel and the HI-2 S/G 1evel setpoints.

The NRC has successfully completed Unit 2 examinations on the simulator for both stations. The Braidwood exam was September, 1987 and the Byron exam was September, 1986.

Question 14:

Regarding Attachment 2, " Annual Steady / Transient Test Results," Test Number SS-1, Objectives 2 and 3; the 2% and 10% criteria for critical and non-critical parameters, respectively, do not necessarily detormine whether something detracts from training. The criterion, "shall not detract from training," is an additional, more strict, performance criterion. Please confirm that the differences were determined not to detract from training in addition to meeting the 2% and 10% criteria or provide justification for exception to this requirement.

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Rasponse.14 :

_4

~73 Steady stateltest (SS-1) has been revised to. ensure that tha"2 2%/310%

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criteria and.the "does not detract from training" criteria are separate p requirements., Steady state test results for 1988 and 1989 have been.

v'erified to trieet the above criteria. .See Attachment 17 for the revised steady. state' test.(SS-1).

l4 i' Question 15:

Regarding the transient tests included in Attachment 2 to Form 474; please provide the baseline' graphs.against which the' simulator graphs may be

., compared. If such graphs are not available please provide a e.escription l" of the baseline data used to determine. fidelity to the. reference plant.

If.the baseline' data used was the judgement of a panel'of' experts, then documentation of their review, sufficient for a third party to evaluate the adequacy of the tests and results, should be included. This.

documentation should include such items as the makeup and qualifications of.the panel and any differing professional opinions as to the outcome of the tests.

Response 152-The baseline data was developed using either plant data, where available,-

l ,or_the; judgement of a Transient Test Baseline Data Review Board.

L Attachment 11 includes the makeup and qualifications of the review board.

Land the'results of each test' review.

. Question 16:

, ANSI /ANS-3.5-1985,- Appendix B, D.2.2(7) requires a transient performance L test of a maximum rate power ramp from approximately 100%_down to approximately 75% and back up to 100% a 25% power change in each

' direction. However,-in Test Numoer TR-7, " Maximum Rate _ Power Ramp" you only' performed a 10% load. swing from-96% to approximately 88%. -Please provide justification for performing this test other than as described in

-ANSI /ANS-3.5-1985.

Response 36:

^

ANSI /ANS-3.5-1985, Section 5.4.2, Simulator Operability Testing, (footnote

3) recommends substitution of Appendix B transient tests if these tests provide a more representative comparison to actual or predicted reference plant per:formance. In accordance with this recommendation, Braidwood Startup Test (BwSU NR-36), 10% Turbine Load Change, was substituted for U the trpendix B, Section B.2.2(7) maximum rate power ramp test.

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Ousstion 17:-

In Examination Raports dated May 20, 1987 and June 17, 1987 it was noted  ;

that the simulator instrumentation drifted while in freeze. This may have 1 an impact on future examinations in which candidates are asked questions related to a " frozen" simulator. Please indicate whether you have-corrected this problem. If not, please provide a schedule for ccrrecting it or justification for not correcting it.

Response 17:

Thr simulator instrumentation drif t problem has been corrected.

Fluctuating power supplies were responsible for the drifting q instrumentation noted during the May, 1987 and June, 1987 examinations.

Af ter the power supplies were replaced, numerous " frozen" simulator exams have been administered including an April, 1989 NRC " frozen / static" simulator examination. No recurring problems were noted.

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