ML20236A746

Requests Addl Info Re Simulator Certification Submittal by 890428

ML20236A746
Person / Time
Site:	Callaway
Issue date:	03/10/1989
From:	Alexion T Office of Nuclear Reactor Regulation
To:	Schnell D UNION ELECTRIC CO.
References
NUDOCS 8903200144
Download: ML20236A746 (7)

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. r y March 10,'1989-

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' Docket No. 50 483 DISTRIBUTION:

155Td6711esj NRC & Local PDRs '

PDIII-3 Wf" GHolahan MVirgilio JHannon Mr. Donald F. Schnell TAlexion PKreutzer Senior Vice President - Nuclear OGC-WF1 EJordan i Union Electric Company BGrimes ACRS(10) l Post Office Box 149 PDIII-3 Gray j St. Louis, Missouri 63166 j

Dear Mr. Schnell:

The staff has completed its review of your initial Sinvjlator Certification submittal and of the additional information submitted in response to our comments on this submittal. The staff's review has identified several areas >

in which there is, as yet, inadequate infnrmetion and data- to ensure complete ,

, documentation of your certification. These areas are described in Enclosures 1 and 2.. You are requested to provide the additional data and your reply to.the questions no later than April 28, 1989 so that this information may be probptly J incorporated in the staff's' records. If you cannot meet thic-schedule, please l contact me as soon as possible.

As-indicated above, our review is only to ensure com)1eteness of documentation.

The review- does not, nor is it intended to, verify t1e accuracy cf the data or statements made in the certification, nor provide NRC approval of the acceptability of a particular simulator for use.in administering operating: tests. .j This request for information affects fewer than 10 respondents;.therefore, OMB clearance is not. required under Pub. L.96-511.

If you require additional information or clarification about this-letter or

its enclosures, please contact me on (301) 492-1387.

4 Yours truly,

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Thomas W. Alexion, Project Manager Project Directorate III-3 Division of Reactor Projects - III, IV, V and.Special Projects Office of Nuclear Reactor Regulaticn Knciosures: 1 As stated -l W10tiSLY'CONCURRE&' gi gi p Office:

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, Surname: PKr#uder TAlexion/tg O I l

Date: g/g/89 40/ p9/rG f[MHannon

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, 'Mr. D. F. Schnell '

Callaway Plant f Union Electric Company Unit No. 1-

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Dr. J. O. Camack Mr. Bart D. Withers )

CFA Inc. . President and Chief i 4 Professional Dr., Suite 110 Executive Officer l Gaithersburg, MD 20879 Wolf Creek Nuclear Operating Corporation Gerald Charnoff, Esq. P. O. Box 411

, Thomas A. Baxter, Esq. Burlington, Kansas 66839 "

,., Shaw, Pittman, Potts and Trowbridge

" 2300 N Street, NW Mr. Dan I. Bolef, President a Washington, DC 20037 Kay Drey, Representative l Board of Directors Coalition q Mr. T. P. Starkey for the Environment i Supervising Engineer, St. Louis Region j Site Licensing. 6267 Delmar Boulevard j Unica Electric Compaqy University City, Missouri 63130 .]

Post Office Box 620  ;

Fulton, Missouri 65251

'U. S. Nuclear Regulatory Commission {

' Resident Inspectors Office l RR#1 Steedman, Missouri 65077' Mr. Alan C. Passwater, Manager Licensing and Fuels j

' Union Electric Company '

Post Office Box 149 )

St. Louis, Missouri 63166 Manager - Electric Department I Missouri Public Service Commission  !

301 W, High 'I Post-Office Box 360 J Jefferson City, Missouri 65102 1 I

Regional Administrator  !

U. S. NRC Regian III 799 Roosevelt Road J>

Glen Ellyn, Illinois 60137 i

Mr. Ronald A. Kucera, Deputy Director l Department of Natural Resources J P. O. Box 176 Jefferson City, Missouri 65102 f l l i1

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4 ENCLOSURE 1

'COMMENTSONULNRC'-18b9,CALLAWAYPLANTRESPONSETONRC'S  ;

LREQUEST FOR ADDITICNAL DATA

1. Your a~ n swer to General Question number 4. refers specifically to ' tests.

Do you also take no~ exceptions to those parts of the Standard. ,

which refer to the extent and degree of simulation required?:

2. Regarding the " Annual Reportt Enclosure B to Form 474, Page 4, .

j Section 2.10," you state that " Baseline data from the plant is only avail- ,

able for the reactor trip transient." For clarification, baseline dita may cone from actual plant data, engineering code .best estimato, or the judgement of a panel of' experts. For the remainder of the tests you have chosen to use'a panel of experts.; however, your documentation of. their-review is. insufficient for o third party to evaluate the adequacy of the.

test (s)andresults. Please. provide such' documentation which may include such itens as.the makeup and qualifications of the panel and any differing  ;

professional opinions as to the outcome of the test (s). ,

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3. Regarding the " Checklist

Attachment:

Att'achment 1 to Enclosure B to Form 9 474, Page 6,' Item 1.13," your response remains unclear. Section 3 of'the i Standard requires that "The extent of simulation shall be such that the.

operator is required to'take the same action on the simulator to conduct .

an evolution as on the reference plant using similar procedures." The i required cperator actions are defined by the. reference plant's procedures. ]

Those procedures may include normal integrated plant operations, annunci- {

cator response, systems operations, abnormal operations, emer0ency opera-tions, and emergency plan procedures. All of these procedures are referred to in 10 CFR 55.45.. The Standard has further delineated'the minimum 3 evolutions that a simulator shall be capable of performing in Section 3.1.

A full scope simulator includes the hardware and software necessary to per-form those procedures which, when performed, are.normally conducted by operators. Therefore any hardware or software deficiency which ' precludes

, the operator from conducting ar. evolution in accordance with reference plant procedures should be noted as an exception to the Standard. Please confirm that you are taking no such exceptions or provide justifications for such.

4.a. Siegarding the " Steady State Tests: Attachment 3 to Enclosure B to Form 474," from your response it remains unclear why you do not initialize the simulator to the cycle tinae for which you have reference plant data.

• Please provide additionel clarification.

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4.b. Your method for calculating differences by normalizing scales appears to be inconsistent with respect to conservatism and not in accordance with the Standard. TheStandardrequires,inSections4.1(3)and4.1(4),that parameters agree within given tolerances of the plant parameters, not the scales on which those parameters are indicated. For example, if a non-critical parameter normally reads 32 on a scale of 0-100 then the allow- l able deviation is i 3.2, not i 10. Your use of the method you describe should i be noted as an exception to the Standard and justification should be 1 provided. 1

5. Section 3.1.2(1)(c) of the Standard requires malfunctions for "large and small reactor coolant breaks including demonstrations of saturation condi-tion." In Attachment E of your response only one malfunction was found to be pplicable to this requirement: Record #312, Test T0312, Malfunction RCS6. However, RCS6, as described in Attachment F, has a maximum break 4 size of 5 inches or 3000 GPM and does not address the " demonstration of I saturation condition." Please confirm that the Callaway simulator meets i this requirement or provide justification for exception to the Standard.

E. Attachment E to your response references tests T0238, T0242, T0243, l T0253, T0689 through T0709, and T0837'none of which are included in Attachment F. Please provide these missing " SIFT" sheets and malfunction descriptions.

7. Section 3.1.2(4) requires malfunctions for " Loss of forced core coolant flow due to single or multiple pump failure." It is not clear that the malfunctions referenced to this requirement, RCS-3 and RCS-4, are capable of multiple pump failures. Please confirm this capability exists or pro-vide justification for exception to the Standard.

E. Attachment G to your response does not indicate that you intend to perform <

approximately 25 percent of the performance tests per year as required by 10 CFR 55.45(b)(5)(vi). Please provide a more detailed schedule from which the percentage of performance tests scheduled per year can be determined, i

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ENCLOSURE 2 ADDITI.0HAL C0i4MENTS ON ORIGINAL SUBMITTAL The fo110 wing 3 comments are in regard to Enclosure "A" to ULNRC 1686.

This is Nuclear Function Administrative Procedure APA-ZZ-00645 Simulator Configuration Management.  ;

1. Section 3.1.1 (10) of the Standard requires the simulator to be capable of performing operator conducted surveillance testing on safety-related equipment or systems. In paragraph 4.1.1.10 of your procedure you use the phrase " Applicable operator conducted surveillance testing." Please define your use of the term " Applicable." Any " operator conducted surveillance testing on safety-related equipment or systems" which you consider to be not applicable should be.noted as an exception to the i Standard and justification should be provided.

2. Section 4.1 (4) of the Standard requires noncritical parameters to be within .10% of the plant parameters and also that tMy not detract ftom training. In paragraph 5.2.4_of your procedure you have substituted the word "or" for the word "and." This implies that an error greater than  ;

10%.is acceptable if such error does not detract from training, and conversely, that if an error detracts from tra$ning it is acceptable if.

such error is.less than 10%. All errors which either exceed i 10% or ,

detract'from. training should be corrected or noted as exceptions to the Standard. Please confirm you are taking no such exceptions or provide justification for these exceptions.

3. Section 5.4.1 of the Standard requires performance tests to meet the criteria of Section 4. Section 4 of the Standard includes criteria for Simulator Operating Limits. You have not indicated that you have performed tests. verifying that your simulator meets these criteria. The lack of such tests should be taken as an exception to .the Standard.

Please confirm that such tests have been performed or provide justification for exception.

The 2 following comments are in regard to Enclosure "B" to VLNRC 1686.

l This is the Callaway Plant Simulator Annual Report.

I. Section 4.1 of the Standard requires critical parameters to agree within i 2% of the plant parameters and noncritical parameters to agree within i 10%. In paragraph 2.8 of your report you state that differences greater than 10% were evaluated for impact on operator training. For noncritical 4 parameters any difference greater than 10% should be taken as an exception to 4.1(4) of the Standard. For critical parameters any difference ,

greater than 2% should be taken as an exception' to 4.1(3) of the i Standard. Please confirm you are taking no such exceptions or provide i justification for such. ,

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, 2. In paragraph 2.10 of your report you state "Other simulators providing i transient graphs can also be used to verify and validate the transients j graphed on the Callaway Plant Simulator." This statement requires '

explanation. The intent of benchmark transient tests is to compare rimulator performance to reference plant performance. Comparison to other j simulators would appear to be invalid unless they are referenced to your j plant. l l

The following 2 comments apply to the " Attachment to APA-ZZ-00645, Checklist 1."

1. Section 3.2.1 of the Standard requires that the simulator contain  ;

sufficient operational panels to provide the controls, instrumentation, )

elarms, and other man-machine interfaces to conduct the normal plant i evolutions of 3.1.1 and respond to the malfunctions of 3.1.2. In l checklist item 12, your floo* plan, comparison, you state that "All main j centrol board panels are simulated." Please clarify what you mean by  ;

" main control board panelt." Floor plan sketches of both the control j room and the simulator would be helpful. Any differences which preclude  ;

operations required by 3.1.1 or 3.1.2 of the Standard should be noted as exceptions to the Standard and justification should be provided. j

2. For steady state operation the Standard requires, in Sections 4.1(3)  !

and 4.1(4) respectively, that critical pcrameters agree within 2% and )

noncritical parameters within Ibi of the plant pcraineters and neither shall detract from training. In item 3.1, " Technical Specification Lngs,"

you state that any difference groater than 10% was evaluated for potential impact on training. The " potential impact on training" should be applied as an additional more strict criteria than the 2% and 10%

criteria for critical and noncritical parameters. Any other use of the

" impact on training" criteria should be noted as an exception to the S tar,da rd. please confirm you are taking no such exceptions or provide justification for such.

The following comment applie to "Callaway Plant Simulator Annual Report 1987 Attachment 4 Transients (Test 1 thrcugh 10).

1. Appendix B of the Standard, in Section B.2.2, requires that these j trarsients be run "from an iaitial condition of approximately 100% power, 1 steady state xenon and decay heat with no operator followup action l (unless otherwise noted)." Please specify the details of the initial conditions used for each of these telts. Include power level, power history, fission product concentrations, mode, and any other data significant to the given initial condition. l l

Acceptance criteria for these tests is provided in Section 4.2 of the standard. Please provide abstracts of these tests which include:

a. Final conditions.

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b. A ' description of the baseline data used to determine fidelity to the reference plant. If this was the judgement of a panel of experts-then inc'lude sufficient documentation of their review for a third' party to evaluate the adequacy of the test (s) and results. .This documentation may-include such items as the makeup and qualifications l of the panel and any differing professional opinions as to the  ;

outcomeofthetest(s). l

c. Deficienciesfoundasaresultofthetest(s)andcorrectiveaction-l.

planned including the schedule.

d. Exceptions taken to the Standard as a result of the test (s), with justification.

The following 3 comments are in regard to "Callaway Plant Simulator .

1 Annual Report 1987, Attachment 5, Callaway Plant' Simulator Benchmark Graphs."

la Thetimescaleforthesimulatorpowerrangegraph(inAttachment4) l differs from that of the RETRA.N estimate by a factor of ten. Please  !

explain, ,

2. The pressurizer pressure graph (in Attachment 4) for the simulator shows-an initial jump which is not indicated in the graph in Attachment 5.

Please' explain.

3. The steam generator pressure graph for the simulator (in Attachment 4) shows a valley after the initial peak which is not indicated 17 the graph in Attachment 5. Please explain.

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