Page 42 - May-June 2013

(Continued on page 44)
42 NuclearPlantJournal.com Nuclear Plant Journal, May-June 2013
Simulator
Scenario
Based
Testing
By Gregg Ludlam, Exelon Nuclear.
Gregg Ludlam
Gregg Ludlam is Director – Fleet
Training for Exelon Generation. In
this position, he has oversight of all
accredited and non-
accredited training
programs for 11
nuclear plants in
Pennsylvania, New
Jersey, Illinois and
Nebraska with
direct focus on
operator training
programs. Prior
to his current
assignment,
Gregg was Site
Training Director
at Oyster Creek
and Robinson and
served in several
operator training
leadership roles at Robinson, Brunswick,
Susquehanna and Vermont Yankee.
Gregg is a U.S. Navy submarine service
veteran, having served for 8 years.
Nuclear Energy Institute’s Top Industry
Practice (TIP) Awards highlight the
nuclear industry’s most innovative
techniques and ideas.
This was a 2012 NEI Process Award
Winner.
The team members who participated
included: Gregg W. Ludlam, Director,
Fleet Operator Training, Exelon
Nuclear; Shawn Quick, Operations
Training Program Manager, Exelon
Nuclear; Robin Brown, Simulator
Coordinator, Oyster Creek Generating
Station; Mark Honzell, Simulator
Coordinator, Clinton Power Station;
Steve Lentz, Manager, Fleet Simulator
Support, Exelon Nuclear.
Summary
InOctober of 2001, theNRCendorsed
ANSI/ANS-3.5-1998, Nuclear Power
Plant Simulators For Use In Operator
Training and Examination. Scenario
Based Testing (SBT), first conceived in
this version of the standard, was intended
as the replacement for the 1985 standard’s
requirement to perform malfunction
testing as the primary method of periodic
simulator performance testing. Paragraph
4.4.3.2 of the 1998 standard describes
the concept of simulator scenario
based testing as a means of conducting
ongoing performance testing on plant
referenced control room simulators but
does not provide a methodology for the
actual conduct and
documentation of
such tests. By 2006,
approximately half
of the country’s
simulators utilized
the 1998 version of
the standard, while
the other half still
utilized the 1985
and 1993 versions.
Utilities that adopted
the 1998 standard
since its approval
in 2001 have
been challenged
with regulatory
uncertainty with
regard to what constitutes acceptable SBT
during Nuclear Regulatory Commission
(NRC) IP-71111.11 (Licensed Operator
Requalification Program and Licensed
Operator Performance )inspections. Other
utilities delayed transition to the 1998
standard for the same reasons. It was
quickly realized among industry Training
professionals that written guidance was
needed for SBT. This was especially
important as a new version of ANSI/
ANS-3.5 was being completed and the
NRC expressed a desire for all utilities to
move to this latest version as the single
recognized standard for simulator fidelity
and configuration management.
Exelon Nuclear, working closely
with the NRC through their chairmanship
of NEI’s Licensed Operator Focus
Group, wrote NEI 09-09 (Nuclear
Power Plant-Referenced Simulator
Scenario Based Testing Methodology)
Rev. 0 and Rev. 1, Nuclear Power Plant-
Referenced Simulator Scenario Based
Testing Methodology. For the first time, a
methodology was crafted for industry use
based on the author’s extensive experience
designing and implementing SBT at
several plant sites. It describes a process
in which simulator performance testing is
conducted inparallel, not series, to training
and evaluation preparation activities by
training instructors. This process results
in minimal personnel resource impact,
reduction of testing that adds little or
no value, and the identification of more
simulator performance discrepancies
before the conduct of training or
evaluation. With SBT, multiple simulator
models are exercised concurrently as part
of the process instructors use to prepare
for simulator training and evaluation.
An added benefit of following NEI
09-09 is improved simulator training
and evaluation quality through better
instructor preparation and higher scrutiny
of simulator performance and better
instructor knowledge of scenario content
and execution.
In several public meetings beginning
in 2007, the NRC reviewed and eventually
endorsed the methodology (NEI 09-
09) as the accepted means of conducing
SBT. In September of 2009, the latest
version of ANSI/ANS-3.5 was released;
correspondingly, the author revised NEI
09-09 through the release of Rev. 1 to
match the new standard. As the NRC
has worked to officially recognize ANSI/
ANS-3.5-2009 as the single recognized
simulator testing standard, NEI 09-09
Rev. 1 is fully endorsed as the acceptable
means to conduct SBT throughRegulatory
Guide 1.149 Rev. 4 (Nuclear Power Plant
Simulation Facilities for Use in Operator
Training, License Examinations, and
Applicant Experience Requirements). In
doing so, the methodology authored by
Exelon Nuclear has become the single
regulator-acknowledged means for the
industry to conduct SBT; regulatory
uncertainty has been eliminated, and the
idea of the industry moving to a single
standard for the maintenance of control
room simulators can be realized for the
first time since issuance of the 1985
version. Having all utilities using the
same standard with the same simulator
performance testing methodology will
eliminate regulatory uncertainty, allow for
benchmarking and operating experience
exchanges, drive consistency in
simulator performance testing, and drive