NRC-2010-0187, Comment (14) of Gary Degraw on NRC-2010-0187-0001, Draft Regulatory Guide: Issuance, Availability

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Comment (14) of Gary Degraw on NRC-2010-0187-0001, Draft Regulatory Guide: Issuance, Availability
ML102720829
Person / Time
Site: River Bend Entergy icon.png
Issue date: 08/25/2010
From: Degraw G
Entergy Corp
To:
Rulemaking, Directives, and Editing Branch
References
75FR29785 00014, DG-1248, NRC-2010-0187-0001
Download: ML102720829 (22)
v • d • e


Text

Mendiola, Doris

Subject:

FW: DG-1248 Comments Attachments:

DG1248 Comments.pdf From: DEGRAW, GARY D [1]

Sent: Wednesday, August 25, 2010 6:02 PM To: Carpenter, Robert Cc: Vick, Lawrence

Subject:

DG-1248 Comments j75-fAJ c~ ~% ~2&Mr. Carpenter, Attached are River Bend Station comments on the NRC Draft Guide DG-1248.Thank You, Gary Degraw Supt., Simulator and Training Support River Bend Station (225)378-3527.qde raw(@enterqy.com

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River Bend Station Comments DRAFT REGULATORY GUIDE DG-1248 Page 3, 2 nd N/A The commission should state Add to the 2 nd paragraph: "The paragraph under; that it recognizes exceptions commission recognizes exceptions"Plant-Referenced taken on initial certification of taken on initial certification of Simulator simulation facilities.

simulation facilities; these exceptions Performance may be carried forward as applicable Testing" to the ANS-3.5-2009 Standard." 2 Page 3, 3 rd Additionally, the This comment implies that the Add to the 3 rd paragraph: "Facility paragraph under; Commission's regulations only testing acceptance criteria licensees that.propose to use a plant-"Plant-Referenced in 10 CFR 55.46(c)(2) for experience requirement referenced simulator to meet the Simulator

/require that facility criteria are items (1) and (2) of experience requirements in 10 CFR Performance licensees that propose to use this paragraph.

55.3 1(a)(5) shall validate the Testing" a plant-referenced simulator performance of the simulator via to meet the experience The regulator should reference simulator reactor core performance requirements in 10 CFR scenario-based testing testing and scenario-based testing 55.3 1(a)(5) ensure that (1) acceptance criteria in Section utilizing acceptance criteria in the plant-referenced 4.4.3.2 or clearly state any sections 4.4.3.2 and 4.4.3.3 of the simulator utilizes models additional acceptance criteria in Standard, respectively." relating to nuclear and the regulatory guide. This thermal-hydraulic comment also applies to DG characteristics that replicate 1248 Appendix B, Item 5 for the the most recent core load in experience requirement.

the nuclear power reference plant for which a license is being sought, and (2)simulator fidelity has been demonstrated so that significant control Page 1 of 21 River Bend Station Comments DRAFT REGULATORY GUIDE DG-1248 Item' Reference I DG-e248 -.ProposedRevision.

_ _ _i OriginalText Po eDGRevisio manipulations are completed without procedural exceptions, simulator performance exceptions, or deviation from the approved training scenario sequence.-I. +3 Page 4, 2 nd paragraph under;NEI 09-09,"Nuclear Power Plant-Referenced Simulator Scenario Based Testing Methodology" i On December 8, 2009, NEI provided for NRC review and endorsement of 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.

NEI-09-09, Revision 1, also supports Section 4.4.3.2,"Simulator Scenario-The last sentence should be deleted from this paragraph.

It implies a "back fit" from the proposed revision 4 of Regulatory Guide 1.149 to a previous edition of the ANS-3.5 Standard.On December 8, 2009, NEI provided for NRC review and endorsement of 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.

NEIT 0 09, Revision 1, also supports Seetien'1 A 2 "Sm.ihtr L..'nri. "H' e. i" -XTC'T/ AXTC ' I C 1 AflO-... 51 -ý -- .1- -X I -Page 2 of 21 River Bend Station Comments DRAFT REGULATORY GUIDE DG-1248 Based Testing," of ANSI/ANS-3.5-1998.

4 Page 5, Section 2.b under; NEI 09-09,"NRC Acceptance and Endorsement of ANSI/ANS-3.5-2009" b. In regard to Section 3.1.4,"Malfunctions," simulation facility licensees should demonstrate that they have conducted performance testing of the malfunctions listed in the standard, as applicable to the design of the reference plant, at least once in the life of the simulation facility and that the associated test documentation includes the completed test results. If performance testing of a malfunction has been completed more than once, then the licensee need only retain the latest test results.The staff recognizes that simulator malfunction test results may be retained longer than 4 years after the completion of each This paragraph should be deleted from this section. This paragraph is not consistent with the records retention requirement in 1OCFR55.46(d)(1) which states that "The results of performance tests must be retained for four years after the completion of each performance test or until superseded by updated test results." The CFR reference allows malfunction tests to be discarded after four years. There is no requirement to maintain performance tests records longer than four years.Additionally, the NRC has previously inspected the results of the ANS-3.5-1985 Standard malfunction testing and approved initial certification of I-. T ..., ...-1 1 AI IJ. 1 JI ICh11% J Lt[.PSJL LAfl .C LT, 1"Malfunctiens," simulation facility licensees should demionstr.ate that they have eondueted per-formance testing of the malfunctiens listed in the stanmdar-d, as applicable.

ten the design of the r.efer.ence pla tet onee in the life of the simulation facility and that the associated test testFesilts.

impfui ae tetn of'~ tL mnalfunction has beent copee mnore than once, then the licensee need only retain the latest ts r-esults.

The staff rcceognizs that sim.ulator

...fun .tion test results may be r-etainied longer than 4 years.after the completion of each,-malfunction test. Therefore, regardless of how long it has been since the malfunction test has been performed, the NRC expect-s simi~ulation facility licensees to make the results of these nalfunetion performance tests available for NRC Page 3 of 21 River Bend Station Comments DRAFT REGULATORY GUIDE DG-1248 Item RfrneD-28Comment

-Proposed Revision item! -Reference

.DG-1248.. Original Text- -to DG-1248 malfunction test. Therefore, the simulators which included review, either- before, or- concurrent regardless of how long it the malfunction tests. with, the preparation for each.has been since the operating test or-malfunction test has been p-ca spee.tin.performed, the NRC expects simulation facility licensees to make the results of these malfunction performance tests available for NRC review, either before, or concurrent with, the preparation for each operating test or requalification program inspection.

5 Page 6, Section 2.d d. In regard to Section Delete "(such as just-in time d. In regard to Section 3.4.3.2, under; NEI 09-09, 3.4.3.2, "Simulator training and routine plant system "Simulator Scenario-Based Testing,""NRC Acceptance Scenario-Based Testing," and equipment startup and simulation facility licensees and Endorsement of simulation facility licensees shutdown training)", should meet the requirements of the ANSI/ANS-3.5-should meet the standard with respect to the following 2009" requirements of the standard The perceived intent of this type of SBTs for inclusion as with respect to the sentence was to provide simulator performance tests: (1) NRC following type of SBTs for examples when operator and initial license examination (operating inclusion as senior operator training test) scenarios, (2) licensed simulator performance tests: simulator scenarios are excluded operator requalification annual (1) NRC initial license from SBT for purposes of examination (operating test) simulator examination (operating test) meeting the standard's SBT scenarios, and (3) scenarios used Page 4 of 21 River Bend Station Comments DRAFT REGULATORY GUIDE DG-1248[Item .R__~Rlfer'c~

[7) -02proped RC Isi7 6-Xg,46J.4 scenarios, (2) licensed 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 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.

requirements; however, the examples provided within the parentheses is not all inclusive when operator and senior operator training simulator scenarios may excluded from SBT for purposes of meeting the standard's SBT requirements.

It could be perceived by licensees and inspectors that these are the only occasions when operator and senior operator training simulator scenarios are excluded from SBT for purposes of meeting the standard's SBT requirements, despite the fact that the three requirements are listed in this section.for performing applicant control manipulations that affect reactivity to establish eligibility for an operator's license. All other operator and senior operator training simulator scenarios (such as just in time training,,x- ..oj.L u ul al-t. 14 Funl. -..i .y -...'h alt equipmelnt Lta (it. O wfl n.4.VV ii t-'aiiing) are excluded from SBT for purposes of meeting the standard's SBT requirements.

6 Page 6, Section 2.e e. In regard to Section Delete this section in its entirety.

e. in regard to Seition 4.434-, under; NEI 09-09, 4.4.3.1, "Simulator It does not clarify or add any "NRC Acceptance Operability Testing," additional guidance than that Footnote 6, as refer.enced to and Endorsement of Footnote 6, as referenced to already noted in the Standard Appendix A, "Guideline foe ANSIANS-3.5-Appendix A, "Guideline for and could only add to confusion.

Decumentatien of Simnulater Design 2009" Documentation of Simulator and -Tes "Peformance," .simulati Page 5 of 21 River Bend Station Comments DRAFT REGULATORY GUIDE DG-1248 Item Reference-, DG-1248 -.,Comment Proposed Revision,_____ .__.... Original Text ____-.to DG-__ 248_......

Design and Test fa-ility li.ensees should note that Performance," simulation Appendix A provides examples that facility licensees should are applicable to Section .4.3. 1.note that Appendix A provides examples that are applicable to Section 4.4.3.1.7 Page 6, Section 2.f f. In regard to Section Editorial; delete words "other" f. In regard to Section 4.4.3.2, under; NEI 09-09, 4.4.3.2, "Simulator and "such as that" from the last "Simulator Scenario-Based Testing,""NRC Acceptance Scenario-Based Testing," sentence to provide clarity in simulation facility licensees should and Endorsement of simulation facility licensees regards to the regulator's also adhere to the NEI standardized ANSI/ANS-3.5-should also adhere to the expectations.

approach for the conduct, 2009" NEI standardized approach performance, and documentation of for the conduct, simulator SBT, as described in NEI performance, and 09-09, Revision 1. The NRC expects documentation of simulator licensees to perform othef-simulator SBT, as described in NEI performance testing, sueh as that 09-09, Revision 1. The described in Section 4.4.3.1, NRC expects licensees to "Simulator Operability Testing";perform other Section 4.4.3.3, "Simulator Reactor simulator performance Core Performance Testing", and testing, such as that Section 4.4.3.4, "Post-Event described in Section 4.4.3.1, Simulator Testing," separately and"Simulator Operability independently from the testing Testing";

described in Section 4.4.3.2.Section 4.4.3.3, "Simulator Reactor Core Performance Page 6 of 21 River Bend Station Comments DRAFT REGULATORY GUIDE DG-1248 Itemi Reference DG-1248 '" Comment Proposed Revision____.... original Text .to DG-1248 Testing", and Section 4.4.3.4, "Post-Event Simulator Testing," separately and independently from the testing described in Section 4.4.3.2.8 Page 6, Section 2.g under; NEI 09-09,"NRC Acceptance and Endorsement of ANSI/ANS-3.5-2009" g. 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 and the conduct of core evolutions involved.

The NRC expects a facility licensee's plant-referenced simulator to utilize models relating to nuclear and thermal-hydraulic characteristics that replicate a core load in the nuclear power reference plant. If the plant-referenced simulator is used to meet NRC applicant First sentence: 1. Add "within the scope of simulation" to be consistent with Section 3.4.3.3 of Standard.2. Delete "with respect to real time"; there are some simulator performance tests that would require an eight hour run time (such as a peak xenon test). Simulation facilities appreciate the use of the fast time simulation feature to conduct tests that would require an extensive amount of run time in an age where simulator utilization by the operations training g. In regard to Section 4.4.3.3,"Simulator Reactor Core Performance Testing," simulation facility licensees should meet the requirements of the standard within the scope of simulation with r.espe.t to real time and the conduct of core evolutions involved.

The NRC expects a facility licensee's plant-referenced simulator to utilize models relating to nuclear and thermal-hydraulic characteristics that replicate a core load in the nuclear power reference plant. If the plant-referenced simulator is used to meet NRC applicant experience requirements, as described in 10 CFR 55.3 1(a)(5), then the most recent core load (e.g., the core load(s) that existed during the time of the NRC applicant's initial training program;Page 7 of 21 River Bend Station Comments DRAFT REGULATORY GUIDE DG-1248 experience requirements, as described in 10 CFR 55.3 1(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.programs is very high.3. Clarify "and the conduct of core evolutions involved".

This appears to be an incomplete sentence.The third sentence references"the most recent core load".License classes may run through more than one fuel operating cycle, so reactivity manipulations may be conducted on core loads that precede and follow a refueling outage, therefore, reactivity manipulations may not be performed in the same fuel cycle.Additional clarification is required in the third sentence taking into account the preceding comment. Consider defining the "most recent core load" as "the core load(s) that existed during the time of the NRC applicant's initial training reactivity manipulations may be conducted on core loads that precede and follow a refueling outage, therefore, reactivity manipulations may be- performed in more than one fuel cycle) the cur-ent referenc.

plant eor-e lead, Or- if the r-efer-nee plant i~in a refueling outage, the eor-e lead just pr-evious to the eutage) in the nuclear power reference plant for which a license is being sought must be utilized.I Page 8 of 21 River Bend Station Comments DRAFT REGULATORY GUIDE DG-1248 Item Re'ference G-1248 Comment. .Proposed Revision, Orgina1 Text .ptorDG-1248

_____ I _____________program~'

".9 Page 6, Section 2.h under; NEI 09-09,"NRC Acceptance and Endorsement of ANSI/ANS-3.5-2009" h. 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 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 event. As a minimum, a licensee should demonstrate on the plant-referenced simulator those reference plant events that result in (1) the automatic initiation of an engineered safety system, (2) the manual or automatic trip of the nuclear Second sentence: 1. Delete "As a minimum" to place focus on demonstrating simulator performance for items 1 through 4.2. Delete "reference plant events" and "such as" and add "relevant unplanned or unexpected (off-normal) events-deemed appropriate by the facility licensee";

this language provides some degree of flexibility to the licensee and is consistent with the intent of Sections 3.4.3.4 and 4.4.3.4 in the Standard.

The items listed in Section 2.h can occur during normal plant evolutions and routine surveillance testing, the scope of testing could be very great. Therefore, it h. 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 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 event. As a minimum, a licensee should demonstrate on the plant-referenced simulator those relevant unplanned or unexpected (off-normal) events r.efer.en.e pla events deemed appropriate by the facility licensee, such as that fesult in (1) the automatic initiation of an engineered safety system, (2) the manual or automatic trip of the nuclear reactor, (3) a significant unplanned or .. .,.-reactivity change, and (4) the manual or automatic trip of the main turbine-generator while online with the electrical grid, and (5) any other- event Page 9 of 21

.River Bend Station Comments DRAFT REGULATORY GUIDE DG-1248 tem. Reference W_1~i248;1

ýv t CPtmnt .Com e ýJzý1248P ii.. ... --. ......... ...- -. .. ..- -. .... .... ........i ......... ... .. ...-.. ...-...... .. .... .-. ... ....... ... ... ......-reactor, (3) a significant unplanned or unexpected reactivity change, (4) the manual or automatic trip of the main turbine-generator while online with the electrical grid, and (5) any other event deemed appropriate by the facility licensee within 60 calendar days following the event to ensure that fidelity is being met and maintained.

should be clarified that the unplanned, unexpected, and off-normal events should be the focus of post event simulator testing.3. Delete item 5 from the list and add the following clarification: "The comparison should be performed and any significant deviations identified within 60 days of the event." This is to clarify that resolutions to noted deviations are not required to be resolved within 60 days; depending on scope of deviation, efforts to resolve could take longer than 60 days (and may require vendor support or model replacements).

deemed appr-epr-iate by. thc faeility licensee within 60 calendarpay-s following the event to ensuire that fidelity is being met and maintained-.

The comparison should be performed and any significant deviations identified within 60 days of the event.10 Page 6, Section 3 The NRC staff has reviewed The reference to ANS-3.5-1998 The NRC staff has reviewed NEI-09-under; "NRC NEI-09-09, Revision 1, and should be deleted from the 09, Revision 1, and finds the Acceptance and finds the implementation second sentence.

It implies a implementation guidance an Endorsement of guidance an acceptable "back fit" from the proposed acceptable method for simulation Page 10 of 21 River Bend Station Comments DRAFT REGULATORY GUIDE DG-1248 Iti ~Rf~ie P-1248 -CJ 6111~h~MIR 112._ " o1I-14.NEI-09-09, Revision 1" 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 (and ANSIIANS-3.5-1998, which NEI-09-09, Revision 0, supported).

Implementation of NEI-09-09, Revision 1, ensures that simulation facility licensees will demonstrate expected plant response to operator input and to -normal, transient, and accident conditions to which the simulator has been revision 4 of Regulatory Guide 1.149 to a previous edition of the ANS-3.5 Standard.Delete third sentence in its entirety.

The NEI 09-09 document does not, by itself, satisfy the 1OCFR55.46 requirements to: (1) demonstrate expected plant response to operator input and to normal, transient, and accident conditions to which the simulator has been designed to respond (10CFR55.46(c)), and (2) that significant control manipulations are completed without procedural exceptions, simulator performance exceptions, or deviation from the approved training scenario sequence (10CFR55.46(c)(2)(ii)).

The simulator's testing program as described in Sections 3.4 and 4.4 of the Standard is designed to meet the requirements in 1OCFR55.46.

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 (a-d ANSI/ANS 3.5 1998, which NEI 09 09, Revision 0, supp.rted

-.implementation of NEI 09 09, Revision 1, ensures that simulation facility licensees will demonstrateplant response to operater input and to normal, transientt, and accident conditionis to which the simulator-has been designed to respond, so that significant control maniplations are completed proceedur-al exceeptions, simutlator per-formanceecetos or deviation frmn the approved trainingseai sequenee7-Page 11 of 21 River Bend Station Comments DRAFT REGULATORY GUIDE DG-1248.Item Reference DG-1248o.

Comment Proposed Revision...... Original Text itoDG-1248 designed to respond, so that significant control manipulations are completed without procedural exceptions, simulator performance exceptions, or deviation from the approved training scenario sequence.11 Page 7, Section 4 under;"Acceptability of Licensee's Simulation Facility" Licensees who 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 staff recognizes that it will take some time for these simulation facility licensees to transition to ANSI/ANS-3.5-2009.

First sentence: 1. Substitute "testing documentation" with"testing methodology".

It is not perceived that previous simulator documentation would be revised to transition to ANS-3.5-2009.

2. The idea that "the NRC encourages simulation facilities to, but do not require simulation facilities to..." and "the NRC staff anticipates that simulation facility licensees will voluntarily move to 4. Acceptability of Licensee's Simulation Facility Licensees who 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 deeumentati methodology to maintain the simulation facility in accordance with ANSI/ANS-3.5-2009.

The NRC staff recognizes that it will take some time for these simulation facility licensees to transition to ANSI/ANS-3.5-2009.

Therefore, the NRC staf anicieiates that simulation rot6, tb elt ! .el&nsi Iitv IIwenw 1 xviii o ntnri Iv Page 12 of 21 River Bend Station Comments DRAFT REGULATORY GUIDE DG-1248 Item R r e DG-1248 Comment Proposed Revson_ __ .Original Text to DG-1248.Therefore, the NRC staff ANSIIANS-3.5-2009" move to A"SI/AT NS 3.5 2009 anticipates that simulation appears to be contradictory.

following the date of the fina.facility licensees will -egulatefy voluntarily move to There is a recommendation, guide (e.g., Regulatry Guide 1. 149, ANSI/ANS-3.5-2009 followed by a soft requirement; Revision4).

following the date of the there is direction, but no final regulatory direction.

guide (e.g., Regulatory Guide 1.149, Revision 4). Recommend either: (1) deletion of last sentence, or (2) absolute direction to the industry regarding transition to one Standard.12 Page 7, Section 5, The NRC will only This statement should be The NRC will only administer second paragraph administer operating tests applicable to single/multiple unit operating tests on a single/multiple under; "Use of on a plant-referenced plants. plant-referenced simulator that meets Simulation Facility simulator that meets the the Commission's requirements, as for Multiple Plants" Commission's Correct typo "plant-referenced".

described in 10 CFR 55.46. In requirements, as described addition, a licensee must request in 10 CFR 55.46. In May need to address use of Commission approval if it plans to addition, a licensee must single unit plant-referenced administer the NRC operating test request simulator in separate section using other than a-plant-referenced Commission approval if it since Section 5 is specific to simulator or the plant.plans to administer the NRC multiple plants.operating test using other than a -plant-referenced simulator or the plant.Page 13 of 21 River Bend Station Comments DRAFT REGULATORY GUIDE DG-1248 item r. Reference DG-1248 -Comment, Proposed Revision... .Original Text C to DG-1248 13 Page 8, Section D, third paragraph under;"Implementation" The NRC staff recognizes that a commitment to ANSI/ANS-3.5-2009 is voluntary on the part of simulation facility licensees.

Since its last revision to Regulatory Guide 1.149, the NRC staff has worked closely with simulation facility licensees and other interested stakeholders through the NEI LOFG to facilitate voluntary movement to a single industry consensus standard.The NRC has determined that movement to a single consensus standard is in the best interest of simulation facility licensees, as well as NRC inspectors and examiners and the general public. The NRC is confident that such a movement will be seamless and transparent The WESTRAIN Simulator Subcommittee disagrees that"such a movement will be seamless and transparent with minimal burden".See comments associated with Item 4 above.Producing malfunction test documentation to satisfy Section 2.b will be a significant burden and costly if the licensee will be required to conduct old malfunction tests. This is particularly true for those facilities that eliminated records over 4 years old as allowed by 1OCFR 55.46.Also, additional documentation associated with NE10909 is considered excessive and an unnecessary burden. Marking up and retaining all procedures used during the scenario-based test is of no advantage to the N/A Page 14 of 21 River Bend Station Comments DRAFT REGULATORY GUIDE DG-1248 Item Reference DG-1248 Comment j Proposed Revision Original Text ..topDG124&d.eis with minimal burden, if any. facility except to demonstrate As a result, NRC review compliance in the NRC and inspection of inspection process. The plant-referenced simulators affirmation of the acceptance for compliance with the criteria by the lead instructor is requirements of 10 CFR sufficient.

The WESTRAIN 55..46 will be more uniform Simulator Subcommittee agrees and consistently that capturing alarms and trends implemented when the staff can provide some value to the carries out the Reactor lead instructor during the SBT;Oversight Process baseline however, this requirement is in Inspection Procedure, IP- fact additional burden.71111.11, "Licensed Operator Requalification Program." 14 Page 9, 5t" Revision of Regulatory Is this revision of Regulatory Revision of Regulatory Guide 1.149 paragraph under; Guide 1.149 is necessary for Guide 1.149 necessary for is necessary for (1) the NRC to"Regulatory (1) the NRC to endorse the simulation facility licensees to endorse the use of ANSI/ANS-3.5-Analysis" use of voluntarily move to a single 2009 as a technical standard to ensure ANSI/ANS-3.5-2009 as a consensus standard and carry compliance with the Commission's technical standard to ensure out its requirements?

simulation facility scope and fidelity compliance with the requirements, (2) si.muation facilit Commission's simulation Item 2 does not meet the intent li..ns.es to v.luntar-ily move to a facility scope and fidelity of DG 1248, whereas the other gin&e requirements, (2) simulation three items do; delete item 2. consensus standard and earry out its facility licensees to .ieniý -(2) the NRC to voluntarily move to a single communicate its expectations, and Page 15 of 21 River Bend Station Comments DRAFT REGULATORY GUIDE DG-1248 Item Reference, DG-1248,.

.-Comment 1. Proposed Revision-O_ original Text to DG-1248-..

consensus standard and (3) facilitation of a common approach carry out its requirements, and methodology for conducting and (3) the NRC to documenting simulator communicate its scenario-based performance testing.expectations, and (4) facilitation of a common approach and methodology for conducting and documenting simulator scenario-based performance testing.15 Page 10, 1st The benefit of updating and Revising Regulatory Guide The benefit of updating and revising paragraph under; revising Regulatory Guide 1.149 will not preclude negative Regulatory Guide 1.149 is that it"Alternative 1.149 is that it would training and inappropriate would provide guidance to Approaches" provide guidance to operator license evaluations, ensure that nuclear power plant ensure that nuclear power simulation facilities used for operator plant simulation facilities Strike this phrase from this training, license examinations, and used for operator training, paragraph; it appears nafve. applicant experience requirements are license examinations, and Implementation of the maintained in accordance with the applicant experience Regulatory Guide 1.149 industry's most recent requirements are maintained Revision 4 and the ANS-3.5- consensus standard-w,'hic-wil4 in accordance with the 2009 Standard will not by itself pr.elude negative training and-industry's most recent preclude negative training inappropriate oper-at, r lien..consensus standard, which ("...preclude negative evaluations.

will preclude negative training..." is an absolute Simulation facilities that meet the training and inappropriate statement).

minimum scope and fidelity__ operator license evaluations.

requirements of ANSI/ANS-3.5-2009 Page 16 of 21 River Bend Station Comments DRAFT REGULATORY GUIDE DG-1248 Item Reference DG-1248--.

Comment. -Proposed Revision'Original Text- to DG-1248 Simulation facilities that must meet the minimum scope be able to demonstrate, on a and fidelity requirements of continuing basis, compliance with the ANSI/ANS-3.5-2009 must Commission' s simulation facility be able to demonstrate, on a regulations, as described in 10 CFR continuing basis, 55.46.compliance with the Commission's simulation facility regulations, as described in 10 CFR 55.46.16 Page 10, 2nd The impact to the NRC The WESTRAIN Simulator N/A paragraph under; would be the costs Subcommittee believes that it is"Alternative associated with preparing inappropriate for the NRC staff Approaches" and issuing the revised to "believes that simulation regulatory guide. The facility licensees would incur impact to the public would little or no cost" (See comments be the voluntary costs associated with items 4 and 13 associated with reviewing above).and providing comments to the The WESTRAIN Simulator NRC during the public Subcommittee agrees that comment period. The "significant human resource impact to facility licensees burdens ... are anticipated as a would be the cost of result of moving to one implementing the new standard." standard.

The value to the Page 17 of 21 River Bend Station Comments DRAFT REGULATORY GUIDE DG-1248 Item Reference DG-1248 COmment -Proposed Revision-1 O riginal Text to DG-1248 ..-NRC staff and facility licensees would be the benefits associated with enhanced efficiency and effectiveness in using a common guidance document as the technical basis for demonstrating compliance with the Commission's simulation facility scope and fidelity requirements, as described in 10 CFR 55.46, and during other interactions between the NRC and facility licensees.

The staff believes that simulation facility licensees would incur little or no cost (for licensees who have not already moved to ANSIIANS-3.5-2009, the cost is expected to be minimal, if any, since significant human resource burdens and simulator Where is human resource burdens reduced? Transition from 1998 to 2009 requires additional burden for SBT documentation, core performance testing, and post event simulator testing.The WESTRAIN Simulator Subcommittee agrees that there was some burden removed during transition from the ANS-3.5-1985 Standard to the ANS-3.5-1998 Standard.Page 18 of 21 River Bend Station Comments DRAFT REGULATORY GUIDE DG-1248 item ReferenceDG14.,omn Fltem,[a TeDxt Proposed Revision.....Ie! L. eee e je rigina'l Tex -DG e1s24& performance testing time savings are anticipated as a result of moving to one standard, which the proposed guide is advocating).

17 Page 11 under; N/A Add definitions for: (1) N/A"Glossary" replicate, (2) significant deviation, (3) compare favorably, (4) procedural exception.

18 Appendix B, Item 2 N/A Please clarify; do "Simulator N/A initial conditions (IC) agreed with reference plant with respect to reactor status, plant configuration, and system operation" only apply to scenarios associated with reactivity manipulations?

19 Appendix B, Item SBT conducted in a manner Reference to ANS-3.5-2009 is SBT conducted in a manner sufficient 10 sufficient (i.e., meets redundant in this proposed (i.e., meets r.equir.ements .t requirements of revision 4 to Regulatory Guide ANS/ANS 3.5 2009) to ensure that ANSI/ANS-3.5-2009) to 1.149. simulator fidelity has been ensure that simulator demonstrated and met for this fidelity has been Delete reference to ANSI/ANS-scenario.

Note: Attach relevant "as-Page 19 of 21 River Bend Station Comments DRAFT REGULATORY GUIDE DG-1248 Item Reference DG-1248 'Comment Proposed Revision._Original Text .toDG-1248 demonstrated and met 3.5-2009.

run marked-up plant procedures and for this scenario.

Note: or procedure portions/pages utilized Attach relevant "as-run" to support assertion.

marked-up plant procedures and or procedure portions/pages utilized to support assertion.

20 Appendix B, Item Modeling and hardware Regarding the sentence; Modeling and hardware discrepancies 11 discrepancies identified "Modeling and hardware identified during the conduct of SBT during the conduct of SBT discrepancies identified during are are the conduct of SBT are documented aAd-entered-in documented and entered in documented and entered in accordance with the site simulator accordance with the site accordance with the site configuration simulator configuration simulator configuration management procedures.

Note.management procedures.

management procedures"...

Discrepancies that directly affect Note: Discrepancies that operator response (or directly affect operator The term "and entered" is action) or expected plant response response (or redundant to "documented" in must be resolved before the SBT test action) or expected plant the configuration management results can be response must be resolved process. Strike the phrase "and judged as satisfactory.

before the SBT test results entered".can be judged as satisfactory.

21 Appendix B, Page The draft regulatory guide In regards to the italicized note N/A B-1 includes this appendix so at the bottom of Page B-1...that the public can discern Page 20 of 21 River Bend Station Comments DRAFT REGULATORY GUIDE DG-1248 Itemrn Reference*

DG-1248 Comment Proposed Revision L IOriginal Text toDG-1248 the staff's acceptance and The WESTRAIN Simulator endorsement of the Subcommittee recommends that Nuclear Energy Institute

's this appendix not be included in (NEI) industry technical final regulatory guide; remove guidance document, NEI- any references to it in the body 09-09, Revision 1. Thefinal of the proposed revision to the guide may or may not regulatory guide.include this appendix.Page 21 of 21

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