NRC-10-0066, Comment (8) of Rodney W. Johnson, on Behalf of Detroit Edison, on NRC Draft Regulatory Guide DG-1248
| ML102420398 | |
| Person / Time | |
|---|---|
| Site: | Fermi  |
| Issue date: | 08/26/2010 |
| From: | Johnson R W Detroit Edison |
| To: | Rulemaking, Directives, and Editing Branch |
| References | |
| 2010-0187, 75FR29785 00008, DG-1248, NRC-10-0066 | |
| Download: ML102420398 (3) | |
Text
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August 26, 2010 / N NRC-10-0066 Rules, Announcements, and Directives Branch Mail Stop: TWB-05-BO1M Office of Administration U. S. Nuclear Regulatory Commission Washington, D C 20555-0001
References:
- 1) Fermi 2 NRC Docket No. 50-341 NRC License No. NPF-43 2) NRC Draft Regulatory Guide DG- 1248, "Nuclear Power Plant Simulation Facilities for Use in Operator Training, License Examinations, and Applicant Experience Requirements," (75 FR 29785, dated May 27, 2010)Comments on NRC Draft Regulatory Guide DG- 1248
Subject:
Detroit Edison has reviewed the draft Regulatory Guide DG-1248 (Reference 2). This regulatory guide describes a method acceptable to the 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, license examination operating tests, and meeting applicant experience requirements.
Section C.2. of the draft regulatory guide states that NRC accepts and endorses ANSI/ANS-3.5-2009 with several clarifications as outlined in the same section.Detroit Edison would like to make the following comments on the draft regulatory guide: 60 '-p527 A DTE Energy Company USNRC NRC- 10-0066 Page 2 1. ANSI/ANS-3.5-2009, Section 4.1.3.2, states: "The performance of procedures on the simulator shall be compared and demonstrated to represent correctly the response of the reference units at the same power level consistent with reference unit procedures and data availability.
It shall be demonstrated that simulator response during conduct of the normal evolutions identified in Sec. 3.1.3.2 meets the following acceptance criteria..." No guidance is provided on the frequency of performing normal evolution testing for plant startups, shutdowns, and load changes as identified in section 3.1.3.2. It is recommended that guidance be included in DG-1248 regarding the frequency similar to the guidance provided in subsection C.2.b. for ANSI/ANS 3.5-2009 section 3.1.4.2. ANSI/ANS-3.5-2009, Section 4.4.2, first paragraph, states: "It shall be demonstrated that simulator validation testing is performed by comparison of simulator model results to actual or predicted reference unit data as defined by Sec. 3, General Requirements." Furthermore, Section 4.4.2, second paragraph, states: "Validation tests shall be conducted prior to the simulator's use in training and examination for the following situations:
... (3) whenever there are changes that have the potential to affect simulator capabilities or repeatability, including changes to computer platforms, operating systems and run-time utilities, interface systems, or instructor stations." This implies that for "changes that have the potential to affect simulator capabilities or repeatability, including changes to computer platforms, operating systems and run-time utilities, interface systems, or instructor stations", all testing defined/described in Section 3 of ANSI/ANS-3.5-2009 must be performed (e.g. Real Time Testing, Limits of Simulation Testing, Steady State and Normal Evolutions, and Malfunctions).
It is recommended that clarification be provided in DG-1248 on validation testing expectations for limited scope simulator changes such as computer platforms, operating systems and run time utilities, interface systems, or instructor
- stations, USNRC NRC- 10-0066 Page 3 Detroit Edison appreciates the opportunity to comment on draft regulatory guide DG-1248. If you have any questions, please contact Mr. Bryan D. Crone, Supervisor
-Operations Training Program at (734) 586-4173.Sincerely, Rodney W. Johnson Manager, Nuclear Licensing cc: USNRC Document Control Desk NRC Project Manager NRC Resident Office Reactor Projects Chief, Branch 4, Region III Regional Administrator, Region III Supervisor, Electric Operators, Michigan Public Service Commission