NLS2010078, Comment (4) of David W. Van Der Kamp on Behalf of Nebraska Public Power District, on Draft Regulatory Guide DG-1248, Nuclear Power Plant Simulation Facilities for Use in Operator Training, License Examinations, and Applicant Experience Re

Comment (4) of David W. Van Der Kamp on Behalf of Nebraska Public Power District, on Draft Regulatory Guide DG-1248, Nuclear Power Plant Simulation Facilities for Use in Operator Training, License Examinations, and Applicant Experience Requ

ML102360142
Person / Time
Site:	Cooper
Issue date:	08/16/2010
From:	Vanderkamp D Nebraska Public Power District (NPPD)
To:	Rulemaking, Directives, and Editing Branch
References
75FR29785 00004, DG-1248, NLS2010078
Download: ML102360142 (25)

Text

H Nebraska Public Power District Always there when you need us NLS2010078 August 16, 2010

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C C-3 C

m cr5 Rules, Announcements, and Directives Branch Office of Administration U.S. Nuclear Regulatory Commission Washington, D.C. 20555-0001 e)

Reference:

Comments on Draft Regulatory Guide DG-1248, "Nuclear Power Plant Simulation Facilities for Use in Operator Training, License Examinations, and Applicant Experience Requirements" Cooper Nuclear Station, Docket No. 50-298, DPR-46 Draft Regulatory Guide DG-1248, "Nuclear Power Plant Simulation Facilities for Use in Operator Training, License Examinations, and Applicant Experience Requirements"

Dear Sir or Madam:

The purpose of this letter is to transmit comments to the Nuclear Regulatory Commission regarding Draft Regulatory Guide DG-1248 (Reference). The comments are presented as the enclosure to this letter.

Comments on DG-1248 have also been provided to the Nuclear Energy Institute.

Should you have any comments or require additional information, please contact James Florence, Simulator Services Supervisor, at (402) 825-5700.

Sincerely, David W. Van Der Kamp Licensing Manager

/jo Enclosure 5 OL)5jr I~'

~2 COOPER NUCLEAR STATION P.O. Box 98 / Brownville, NE 68321-0098 Telephone: (402) 825-3811 / Fax: (402) 825-5211 www.nppd.com

,C

NLS2010078 Page 2 of 2 cc: Regional Administrator w/ enclosure USNRC - Region IV Cooper Project Manager w/ enclosure USNRC - NRR Project Directorate IV-I Senior Resident Inspector w/ enclosure USNRC - CNS NPG Distribution w/o enclosure CNS Records w/ enclosure

NLS2010078 Enclosure Page 1 of 22 WESTRAIN Simulator Subcommittee Comments Draft Regulatory Guide DG-1248

WESTRAIN Simulator Subcommittee Comments DRAFT REGULATORY GUIDE DG-1248 I

Page 3, 2' paragraph under; "Plant-Referenced Simulator Performance Testing" N/A The commission should state that it recognizes exceptions taken on initial certification of simulation facilities.

Add to the 2na paragraph: "The commission recognzes exceptions taken on initial certification of simulation facilities; these exceptions may be carried forward as applicable to the ANS-3.5-2009 Standard."

2 Page 3, 3 rd paragraph under; "Plant-Referenced Simulator Performance Testing" 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 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 This comment implies that the only testing acceptance criteria for experience requirement criteria are items (1) and (2) of this paragraph.

The regulator should reference scenario-based testing acceptance criteria in Section 4.4.3.2 or clearly state any additional acceptance criteria in the regulatory guide. This comment also applies to DG 1248 Appendix B, Item 5 for the experience requirement.

Page 1 of 21

WESTRA1N Simulator Subcommittee Comments DRAFT REGULATORY GUIDE DG-1248 1*

manipulations are completed without procedural exceptions, simulator performance exceptions, or deviation from the approved training scenario sequence.

3 Page 4, 2n" paragraph under; NEI 09-09, "Nuclear Power Plant-Referenced Simulator Scenario Based Testing Methodology" 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. N4lO90 ReVkion~ 1, a!58 SUPPE)AS Svctfiff 4.4.3.2, "Simulater-Sconar-io Based Testing," of A.NS/A.NS 3.5 1998.

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Page 2 of 21

WESTRAIN Simulator Subcommittee Comments DRAFT REGULATORY GUIDE DG-1248

• 1*

I Based Testing," of ANSI/ANS-3.5-1998.

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+

4 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 1 OCFR55.46(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 Page 3 of 21

WESTRAIN Simulator Subcommittee Comments DRAFT REGULATORY GUIDE DG-1248 malfunction test. Therefore, regardless of how long it has been since the malfunction test has been 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.

the simulators which included the malfunction tests.

reVieW, eithfr befOre0, or-eeneurrcnt With,00pfeOpeatiOAOR f6Faek eieeiets r-eulfi-ti 5

Page 6, Section 2.d under; NEI 09-09, "NRC Acceptance and Endorsement of ANSI/ANS-3.5-2009"

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)

Delete "(such as just-in time training and routine plant system and equipment startup and shutdown training)".

The perceived intent of this sentence was to provide examples when operator and senior operator training simulator scenarios are excluded from SBT for purposes of meeting the standard's SBT

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 Page 4 of 21

WESTRAIN Simulator Subcommittee Comments DRAFT REGULATORY GUIDE DG-1248 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 awjust in timne taining t

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. I regard to Section 1.4.3.4, under; NEI 09-09, 4.4.3. 1, "Simulator It does not clarify or add any "Simulator per*ability Testing,"

"NRC Acceptance Operability Testing,"

additional guidance than that Footnote 6, as refer-eneedto and Endorsement of Footnote 6, as referenced to already noted in the Standard App A, "Guidel-ine ANSI/ANS-3.5-Appendix A, "Guideline for and could only add to confusion. Deumn-'o Design 2009" Documentation of Simulator,_I and Test peformafte,", -54i fti Page 5 of 21

WESTRAIN Simulator Subcommittee Comments DRAFT REGULATORY GUIDE DG-1248 Design and Test fielt iesessol oeta Performance," simulation Ar:

1.

the facility licensees should able to Seon 4.4.3.1.

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 ether-simulator SBT, as described in NEI performance testing, such*-s-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

WESTRAIN Simulator Subcommittee Comments DRAFT REGULATORY GUIDE 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

g. In regard to Section First sentence:

g. In regard to Section 4.4.3.3, under; NEI 09-09, 4.4.3.3, "Simulator Reactor "Simulator Reactor Core Performance "NRC Acceptance Core Performance Testing,"

1. Add "within the scope of Testing," simulation facility licensees and Endorsement of simulation facility simulation" to be consistent should meet the requirements of the ANSI/ANS-3.5-licensees should meet the with Section 3.4.3.3 of standard within the scope of 2009" requirements of the standard Standard.

simulation %ith r-esp* t to foal time with respect to real time and and the conduct of core evolutions the conduct of core

2. Delete "with respect to real involved. The NRC expects a facility evolutions involved. The time"; there are some licensee's plant-referenced simulator NRC expects a facility simulator performance tests to utilize models relating to nuclear licensee's plant-referenced that would require an eight and thermal-hydraulic characteristics simulator to utilize models hour run time (such as a that replicate a core load in the relating to nuclear and peak xenon test). Simulation nuclear power reference plant. If the thermal-hydraulic facilities appreciate the use plant-referenced simulator is used to characteristics that replicate of the fast time simulation meet NRC applicant experience a core load in the nuclear feature to conduct tests that requirements, as described in 10 CFR power would require an extensive 55.31 (a)(5), then the most recent core reference plant. If the plant-amount of run time in an age load (e.g., the core load(s) that existed referenced simulator is used where simulator utilization during the time of the NRC to meet NRC applicant by the operations training applicant's initial training program; Page 7 of 21

WESTRAIN Simulator Subcommittee Comments DRAFT REGULATORY GUIDE DG-1248 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.

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 refuel-ing outage, therefore, reactivity manipulations may be performed in more than one felyce) the r feb tb just pr..viet.+ to the eutage)- n the nuclear power reference plant for which a license is being sought must be utilized.

Page 8 of 21

WESTRAIN Simulator Subcommittee Comments DRAFT REGULATORY GUIDE DG-1248

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4

+

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.fefef.aeo; 1 "'1 o..deemed appropriate by the facility licensee, such as tha estit (1) the automatic initiation of an engineered safety system, (2) the manual or automatic trip of the nuclear reactor, (3) a significant unpl ed er u--.peted reactivity change, and (4) the manual or automatic trip of the main turbine-generator while online with the electrical grid, and (5) mny othor o-on Page 9 of 21

WESTRA1N Simulator Subcommittee Comments DRAFT REGULATORY GUIDE DG-1248

-Y 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).

1ioonsee within 60 ealendar-days following the o;'ont to easuro ha fidelity, is being m4e and maintaiincd 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 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

WESTRAIN Simulator Subcommittee Comments DRAFT REGULATORY GUIDE DG-1248

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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 ANSI/ANS-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 IOCFR55.46 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 10CFR55.46.

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 (aai A7PN~bL'AP

-4.9 4 ý091, WH461n 99i

~

09, Rev'ision 0, supported).

Revision 1, efisurm tlui simuleaio fiwiliylieemees wiNdemnenstmt.

input and to aFl~mal, srnient, and Arsiet P-ndtono s t: oI th-AsQ;jetA:has.- beefrdesignde rcopond, so thAt significant conitroel seqiienee.

i Page 11 of 21

WESTRAIN Simulator Subcommittee Comments DRAFT REGULATORY GUIDE DG-1248 I

designed to respond, so that significant control manipulations are completed without procedural exceptions, simulator performance exceptions, or deviation from the approved training scenario sequence.

I

-t 4-4-

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 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. Th**efore, the NRCt*t s

aniapme h~t 4M-uatieni I

I I

I el eeieSWil V1e~ai h

a Page 12 of 21

WESTRAIN Simulator Subcommittee Comments DRAFT REGULATORY GUIDE DG-1248 Therefore, the NRC staff anticipates that simulation facility licensees will voluntarily move to ANSI/ANS-3.5-2009 following the date of the final regulatory guide (e.g., Regulatory Guide 1.149, Revision 4).

ANSI/ANS-3.5-2009" appears to be contradictory.

There is a recommendation, followed by a soft requirement; there is direction, but no direction.

Recommend either: (1) deletion of last sentence, or (2) absolute direction to the industry regarding transition to one Standard.

moeve to zL':.NyW+

4=1 -Adw fellewifte the date ef the iAl euide (e. e.. Reetulator; Guide 1. 149.

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12 Page 7, Section 5, second paragraph under; "Use of Simulation Facility for Multiple Plants" The NRC will only administer operating tests 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 it plans to administer the NRC operating test using other than a -plant-referenced simulator or the plant.

This statement should be applicable to single/multiple unit plants.

Correct typo "plant-referenced".

May need to address use of single unit plant-referenced simulator in separate section since Section 5 is specific to multiple plants.

The NRC will only administer operating tests on a single/multiple 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 it plans to administer the NRC operating test using other than a-plant-referenced simulator or the plant.

Page 13 of 21

WESTRAIN Simulator Subcommittee Comments DRAFT REGULATORY GUIDE DG-1248 Ihtm[

Rfrne D6-f248:

Comm ent Proposed Revision

___Originial Text J

to DG-1248ý-

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 OCFR 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

WESTRAIN Simulator Subcommittee Comments DRAFT REGULATORY GUIDE DG-1248

-q with minimal burden, if any.

As a result, NRC review and inspection of plant-referenced simulators for compliance with the requirements of 10 CFR 55.46 will be more uniform and consistently implemented when the staff carries out the Reactor Oversight Process baseline Inspection Procedure, IP-71111.11, "Licensed Operator Requalification Program."

facility except to demonstrate compliance in the NRC inspection process. The affirmation of the acceptance criteria by the lead instructor is sufficient. The WESTRAIN Simulator Subcommittee agrees that capturing alarms and trends can provide some value to the lead instructor during the SBT; however, this requirement is in fact additional burden.

14 Page 9, 5tu paragraph under; "Regulatory Analysis" Revision of Regulatory Guide 1.149 is necessary for (1) the NRC to endorse the use of ANSIIANS-3.5-2009 as a technical standard to ensure compliance with the Commission's simulation facility scope and fidelity requirements, (2) simulation facility licensees to voluntarily move to a single Is this revision of Regulatory Guide 1.149 necessary for simulation facility licensees to voluntarily move to a single consensus standard and carry out its requirements?

Item 2 does not meet the intent of DG 1248, whereas the other three items do; delete item 2.

Revision of Regulatory Guide 1.149 is necessary for (1) the NRC to endorse the use of ANSI/ANS-3.5-2009 as a technical standard to ensure compliance with the Commission's simulation facility scope and fidelity requirements, (2) siultinf

'-l" liconefies to Voluatffily moeve to

&in&e eonsensus standard and e"rr out its com municate the NRC to communicate its expectations, and Page 15 of 21

WESTRAIN Simulator Subcommittee Comments DRAFT REGULATORY GUIDE DG-1248

-q consensus standard and carry out its requirements, (3) the NRC to communicate its expectations, and (4) facilitation of a common approach and methodology for conducting and documenting simulator scenario-based performance testing.

(3) facilitation of a common approach and methodology for conducting and documenting simulator scenario-based performance testing.

4

-~

J 15 Page 10, 1" paragraph under; "Alternative Approaches" The benefit of updating and revising Regulatory Guide 1.149 is that it would provide guidance to ensure that nuclear power plant simulation facilities used for operator training, license examinations, and applicant experience requirements are maintained in accordance with the industry's most recent consensus standard, which will preclude negative training and inappropriate operator license evaluations.

Revising Regulatory Guide 1.149 will not preclude negative training and inappropriate operator license evaluations.

Strike this phrase from this paragraph; it appears na've.

Implementation of the Regulatory Guide 1.149 Revision 4 and the ANS-3.5-2009 Standard will not by itself preclude negative training

("...preclude negative training..." is an absolute statement).

The benefit of updating and revising Regulatory Guide 1.149 is that it would provide guidance to ensure that nuclear power plant simulation facilities used for operator training, license examinations, and applicant experience requirements are maintained in accordance with the industry's most recent consensus standard-,whieh-wil pmeclue aegativc traiing and imth naater. hemse

.yawsafiefi.s Simulation facilities that meet the minimum scope and fidelity requirements of ANSI/ANS-3.5-2009 Page 16 of 21

WESTRAIN Simulator Subcommittee Comments DRAFT REGULATORY GUIDE DG-1248 Item Reference DG'1248 Commen 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 I

II Page 17 of 21

WESTRAIN Simulator Subcommittee Comments DRAFT REGULATORY GUIDE DG-1248

[iIem

' Reference I

Gi248 Coý entii.

ProposedkRevision.

Original Text Jto 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 ANSI/ANS-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

WESTRAIN Simulator Subcommittee Comments DRAFT REGULATORY GUIDE DG-1248 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., mcet_ requirements of requirements of revision 4 to Regulatory Guide ANSI/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

WESTRAIN Simulator Subcommittee Comments DRAFT REGULATORY GUIDE DG-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 ain 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-i includes this appendix so at the bottom of Page B-1...

that the public can discern Page 20 of 21

WESTRAIN Simulator Subcommittee Comments DRAFT REGULATORY GUIDE DG-1248 Item]

Reference DG-1248 Comment

[

Proposed Revision

___Original Text

[-to DG-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

ATTACHMENT 3 LIST OF REGULATORY COMMITMENTS© 4 ATTACHMENT 3 LIST OF REGULATORY COMMITMENTS@4 Correspondence Number:

NLS2010078 The following table identifies those actions committed to by Nebraska Public Power District (NPPD) in this document. Any other actions discussed in the submittal represent intended or planned actions by NPPD. They are described for information only and are not regulatory commitments. Please notify the Licensing Manager at Cooper Nuclear Station of any questions regarding this document or any associated regulatory commitments.

COMMITMENT COMMITTED DATE COMMITMENT NUMBER OR OUTAGE None 1*

1-4 4

4 4-

+

4-

+

4-PROCEDURE 0.42 REVISION 25 PAGE 18 OF 25