DCL-95-272, Supports Comments Submitted by NEI Re Licensee Qualification for Performing Safety Analyses,With Listed Exception.Nrc Should Allow Traning Requirement to Be Met by on-job Training
| ML20196E986 | |
| Person / Time | |
|---|---|
| Site: | Diablo Canyon  |
| Issue date: | 12/11/1995 |
| From: | Rueger G PACIFIC GAS & ELECTRIC CO. |
| To: | Meyers D NRC OFFICE OF INFORMATION RESOURCES MANAGEMENT (IRM) |
| Shared Package | |
| ML20196D712 | List: |
| References | |
| DCL-95-272, NUDOCS 9906290070 | |
| Download: ML20196E986 (2) | |
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415/973-4584 December 11,1995 Fax 415/973 2313 PG&E Letter DCL-95-272 Mr. David L. Meyers e,
Chief, Rules Review and Directives Branch Mail Stop T-6D-69 U.S. Nuclear Regulatory Commission ATTN: Document Control Desk Washington, D.C. 20555-0001 Docket No. 50-275, OL-DPR-80 Docket No. 50-323, OL-DPR-82 .
Diablo Car: yon Units 1 and 2 -
Feoposed Generic Communication: Licensee Quaf.'icanon for Performino Safety Analyses (60 Federa/ Reoister 54712. October 25.1995). Reouest for Comments l
Dear Mr. Meyers:
I PG&E supports the comments submitted to you by the Nuclear Energy institute (NEI) regarding licensee qualification for performing safety analyses, with the following exception:
NEl refers to support for the concept of eliminating a licensee qualification report for performing " core reload safety analysis." PG&E believes this !
should not be limited to core analysis, but should apply to other codes, for example RETRAN and RELAP, that arts used for other types of safety analysis.
In addition, PG&E has the following comment:
The NRC should allow the training requirement to be met by on-the-job training.
Sincerely, I
f
&9 Gregory M. Rueger 9906290070 990625 PDR I&E MISC PDR
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Mr. D:vid L. Maytrs December 11,1995 Page 2 cc:- Steven D. Bloom L. J. Callan Kenneth E. Perkins Michael D. Tschiltz DCL95272/RLJ l
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U.S. Nuclear Regulatory Commission Washington, DC 20555-0001 Attention: Chief, Rules Review and Directives Branch '
Mail Stop T-6D-69 ,
Subject:
Proposed Generic Communication; Licensee Qualification for Performing Safey '
Analyses (M91599) (60 FR 54712, dated October 25,1995) ')
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Dear Madam / Sir:
Yankee Atomic Electric Company (Yankee) appreciates the opponunity to comment on the subject proposed generic communication regarding licensee qualification for performing safety analyses. Yankee's Nuclear Services Division provides engineering and licensing services to nuclear power facilities in the New England region.
We support the proposed Supplement I to Generic Letter 83-11 with regard to the conduct of safety analyses by a licensee using NRC-approved codes and methods which have been provided by an organization other than itself. Adoption of a generic set ofguidelines, as described in the proposed Supplement, would allow for more efficient use of both NRC and utility resources. The proposed approach will ensure that personnel who set up and apply the codes have the necessary training and understand the limitations of the methodology.
It is our understanding that the Supplement 1 te Generic Letter 83-11 will only apply to licensees who use another organization's methods and codes and will not apply to an organization that both receives approval for its codes and methods and conducts safety analyses using those codes and methods. If an organization such as a utility receives NRC approval ofnew or revised methods, that approval constitutes qualification and is, therefore, not replaced by the proposed Supplement 1 to GL 83-11.
We also recommend for completeness that the Supplement also note that, aside from EPRI and fuel vendors, other organizations, such as ut ilities and engineering services companies, have developed codes and methods which have been approved by the NRC. The remaining comments are in response to the specific questions on how to modify procedures for acceptance of new or revised analysis methods.
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Lener, YAEC to U.S. NuclearRegulatory Comminion December 8,1995 Page 2 Response to Ouestions Yankee supports the concept of providing an alternative process for the review of new or revised analysis methods. The current process of reviewing new or revised methods ensures independent verification; however, it is also time consunsng and resource intensive. Revisions to the process should improve timeliness but not at the expense ofindependence and review quality.
I (1) To what extent can an ornanintion other than the NRC (a third-nartv) review a new l methodolony or a minnificant change to an existing methodolonv7 .
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Yankee believes that the NRC should continue to be involved in the review of new or revised methodology to ensure independence and high quality ofreview. However, the process could be changed to lessen the burden on the NRC staff and improve timeliness of the reviews. For exa iple, the NRC could maintain a list ofqualiGed reviewers. An organization, or individual, desiring to be a qualified reviewer would submit his or her qualifications to the NRC for review and approval. An organization, who has created or wishes to revise its methodology, would obtain the list of qualified third-party reviewers i from the NRC and negotiate the cost and schedule for the review directly with the qualified organization. When the review is complete, the licensee shall provide the reviewer's evaluation report to the NRC for their ultimate approval. The NRC should still provide a document of approval for reference to the organization creating or revising the methodology.
(la) What capabilities should be required of a third-party reviewer?
The NRC presently reviews the capabilities ofits subcontractors for reviewing )
methodology. The NRC should apply this same process to third-party reviewers.
(Ib) What is the safety significance of not having the NRC perform the review?
There should be no change in the safety significance because the NRC will still review the capabilities of the third-party reviewers and the NRC will still have an opportunity to review the third-party's evaluation of the methodology before it is applied.
(Ic) What documentation should be submitted to the NRC by the third-party reviewer and/or
- the licennee?
When a licensee requests NRC approval of new or revised methodology, the licensee should submit the request to the NRC. The application should include the methodology, indicate how the methods are being used, a; d attach a copy of the independent th.rd-pany review report. This submittal forms the basis for the NRC's review and approval.
A Letter, YAEC to U.S NuclearRegulatory Commlulon December 8,1995 Page 3 (Id) What tvoc of acceptance. e.g. a safety evaluation report. should be issued?
The licensee will still need to obtain from the NRC a document of approval. However, the approval need not be in the form of a safety evaluation report as such a document would require an effort that may duplicate that of the third-party review. The document of approval should reflect a level of effort that is commensurate with the credit that is being taken for the third-party review.
(le) How would approved references. e g. Core Operating T imits Report (COLR) carameters in technical specification reporting reauirements. be handled?
As stated above, the licensee will obtain a document of approval which could be referenced as appropriate.
(If) What information if any. should be available forNRC audit? -
Records of the third-party review should be maintained and be available for audit by the NRC. This information should include questions and responses, the results of any code comparisons, benchmarking, time step studies, nodalization studies, me. that demonstrate the thoroughness of the review.
(2) What other viable approach can be used for accepting new or revised methods?
Yankee believes that the above process is the most effective approach for accepting new or revised methods.
(2a) Should a renulatory nuide be developed?
Yankee believes a regulatay guide would be too restrictive for methods development in this area.
(2b) Can a set of criteria. as proposed in the generic letter supplement for previously aoproved generic methods. also be developed for new methods?
I Yankee believes a set ofguidance criteria could be developed. These guidance criteria could be an aid to the third-party reviewer.
(3) To what technical disciplines should this process apply?
l This process could apply to any technical discipline that provides input to or performs the j safety analyses.
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Exner, YAEC to U.S. NuclearRegulatory Comminion December 8,1995 Page 4 In conclusion, we wish to commend the NRC for undertaking this effort to improve the process for review and approval of safety analyses codes and methods. Should you have any questions conceming any of our comments, please contact Mr. James Chapman at 508-779-6711.
Sincerely, YANKEE ATOMIC ELECTRIC COMPANY .
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1 Jhd M. Grant !
Magager, Regulatory and Industry Affairs c: Morton B. Fairtile, NRC, NRR ,
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INDIANA AMCHIGAN POWER December II, 1995 AEP:NRC:1240 Docket Nos.: 50-315 50-316 Chief, Rules Review & Dire.ctives Branch U. S. Nuclear Regulatory Commission l Mail Stop T-6D-69 f Washington, DC 20555-0001 l
Gentlemen: 1 Donald C. Cook Nuclear Plant Units 1 and 2 I COMMENTS ON DRAFT CENERIC LETTER 83-11, SUPPLEMENT 1 )
(LICENSEE QUALIFICATION FOR PERFORMING SAFETY ANALYSES)
In the October 25, 1995, Federal. Register Notice (60 FRN 54712),
the NRC promulgated a draft set of revised guidelines to licensees who wish to perform their own safety and reactor core design analyses. This set of guidelines would replace those in Generic l i
Letter (CL) 83-11, issued February 8, 1983. The purpose of this letter is to provide comments regarding the draft guidelines.
We concur with the NRC's decision to shorten the review and I approval process by eliminating the need to submit detailed topical )
reports. We believe the guidelines provided in Attachment 1 to the generic letter supplement will continue to assure that the design analysis is performed using a valid methodology. Also, the new 1 approach will save limited NRC resources currently required for '
methodology review and result in more eficient use of utility resources if there is no waiting period after completion of the methodology work.
As a recommended clarification on one of the points given in the generic letter supplement, the following comment is provided.
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? j U. S. Nuclear Regula' tory Commission AEP:NRC:1240 Page 2 Comment -
Attachment 1 to the draft generic letter supplement provides guidelines for licensees to use approved codes. Section 2.1 in Attachment 1 states: "The only codes and methods that are addressed by this process are those that the NRC has reviewed and approved."
Different versions of previously approved codes (e.g. ,
core design codes) that have been modified by the vendor to correct errors or to incorporate enhancements to the codes should be acceptable. It is suggested that, as long as the calculational methodology is not changed, the licensee should be al'e to use the new version of the code.
Sincerely, i
E. E. Fitzpatrick Vice President eh cc: A. A. Blind C. Charnoff H. J. Miller NFEM Section Chief NRC Resident Inspector - Brf.dgman J. R. Padgett T. E. Tipton - NEI 4
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l'7 December 18,1995 0CAN129502 Chief, Rules Review and Directives Branch U. S. Nuclear Regulatory Commission .
Mail Stop T-6D-69 '
Washington, DC 20555-0001 i j
Subject:
Arkansas Nuclear One- Units 1 and 2 Docket Nos. 50-313 and 50-368 License Nos. DPR-51 and NPF-6 Comments on Drafi Supplement I to Generic Letter 83-11
" Licensee Qualification for Performing Safety Analyses" Gentlemen:
i The purpose of this letter is to provide Entergy Operations' comments for Arkansas Nuclear One to the drafi Supplement I to Generic Letter 83-11. In addition to comments on the proposed supplement, the Staff requested comments on three questions. The following are comments on the requested questions. l (1) To what extent can an organization other than the NRC (a third party) review a new methodology or a significant change to an existing methodology?
Since many of the NRC reviews of methodologies are currently assigned to subcontractors, it would seem that third pany reviews would not be significantly different.
There would be concerns with the " independence" of the review but such reviews / audits are currently practiced in other industries, such as the financial sector; therefore, it would appear to be a reasonable approach. An alternative might be the development of a set of NRC-approved standards and criteria that the third pany reviewer would be required to maintain in which licensees could hold the third party reviewer accountable.
(a) What capabilities should be required of a third-party reviewer?
These third pany reviewers would obviously have to possess the appropriate technical and licensing capabilities to provide a defensible review. The NRC should establish a certification process for third pany reviewers. This would ensure an adequate supply of qualified reviewers. This could include current /former NRC contractors in the area of interest, documented expertise N the required field, and documented experience in
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- OCAN129502 Page 2 performing analyses of the type being reviewed, etc. It would seem that such capabilities / requirements would already be compiled for current NRC contractors.
- (b) What is the safety significance of not having the NRC perform the review?
With appropriate controls placed upon thu quality of reviews, comparison to other vendor -
methodologies and the exercising of sound engineering judgment, the safety significance l would be minimal.
. (c) What documentation should be submitted to the NRC by the third-party reviewer ,
and/or by the licensee?
A report summarizing the methodology and applications that were reviewed, a synopsis of the review process and depth, and comparisons to standardized problems or other industry results that would support reviewers' judgments regarding the subject. Additionally, the reviewer would prepare a licensing assessment including comparisons to existing regulatory requirements and issue a safety evaluation renort. In short, the report should j inchde the information necessary for the NPA to audit the controls over the application of l the methodology. This report should include a clear delineation of the applicability of the l methodology and could possibly be required to have a pre-defined format and content. l (d) What type of acceptance (e.g., a safety evaluation report) should Le issued?
A cover letter reflecting receipt of the licensee / contractor review report and the l applicability / limitations of the methodology should be issued. The letter could state that j application of the methodology is permissible within the constraints outlined in the j submitted report and that future NRC audits / inspections would verify compliance with the l report. ,
(e) How would approved references (e.g., Core Operating Limits Repott (COLR) parameters in technical specification reporting requirements) be handled?
Referencing the submittal reports and NRC approval letters that described the methodology and application would be a method of handling approved references.
(f) What information, if any, should be available for NRC audit? i The same information that would currently be available for topical report reviews -- all of it. l
' (2) What other viable approaches can be used for accepting new or revised methods?
Standard benchmark cases might provide a means of determining the validity of methods.
With the extensive benchmark data from the NRC's own development of RELAPS and other methods, such benchmark cases could be readily compiled.
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December 18,1995 - - - - -
( OCAN129502 Pcge 3 (a) Should a regulatory guide be developed?
A regulatory guide would be valuable in order to ensure consistency in documentation content and format and for ease in NRC audit / inspection.
(b) Can a set of criteria,'as proposed in the generic letter supplemer.t for previously approved generic methods, also be developed for new methods?
This could be done on a case by case basis.
(3) To what technical disciplines should this process apply? Commentors should clearly differentiate any comments submitted in response to these questions from comments on the generic letter supplement.
The above responses are from the perspective of reactor physics, accident, and transient analysis.
The following are general comments on the proposed Attachment 1 of the draft Supplement I to Generic Letter 83-11. With the increasing frequency with which utilities switch fuel vendors, the applicability of a particular method to either a specific fuel design or to a core which contains a mixture of fuel types will be imponant. Use of a vendor's hot channel analysis code with an EPRI or different vendor's transient codes may not necessarily yield conservative results and, in fact, may not be consistent with the " reload analysis package" that
'has been approved by the NRC. In-house application procedures should have the proper ,
controls to preclude such a misapplication but should also be permitted to include the l flexibility to perform comparison tests between the different methodologies, possibly with vendor assistance, to show that a conservative assessment can be made. This, in effect, would be a deviation from " approved" methodologies but one that is supponed by analysis and acceptable under 10CFR50.59.
Compliance with the generic letter would be easier if an NRC inspection procedere was developed concurrently so licensees would know the requirements, and specifically, what questions and documentation requests might be needed to suppon audits. The effon to provide both the generic letter and the inspection procedure at the same time would probably ;
make the documents more consistent. Also, the NRC should consider providing licensees the flexibility to conduct its own assessment of a third pany reviewer similar to what is currently allowed in NRC Inspection Modul 40501, " Licensee Self-Assessments Related to Team Inspections".
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December 18,1995 - -- - ,- -- - - - - -
- - .' OCAN129502 Page 4 Should you have'any questio'ns, please contact me.
Very truly yours, 1
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- Dwight C. ms Director, Nuclear Safety DCM/nbm lcc: : Mr. Leonard J. Callan
~ Regional' Administrator U. S. Nuclear Regulatory Commission
. Region IV 611 Ryan Plaza Drive, Suite 400 ,
Arlington, TX 76011-8064 NRC Senior Resident Inspector.
Arkansas Nuclear One P.O. Box 310 London, AR 72847-Mr. George Kalman NRR Project Manager Region IV/ANO-1 & 2 U. S. Nuclear Regulatory Commission NRR Mail Stop 13-H . One White Flint North
- i. . . I1555 Rockville Pike Rockville, MD 20852 U. S. Nuclear Regulatory Commission Document Control Desk Mail Station PI-137
- Washington, DC 20555 -
Mr. Jim Eaton Nuclear Energy Institute 17761 Street, NW Suite 400 Washington, DC 200%-3708 s
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1 ? 'l WILLIAM L STEWART 102-03572-WLS/AKK/ GAM
""7lcflll"*" December 20,-1995 Chief, Rules Review and Directives Branch U. S. Nuclear Regulatory Commission Mail Stop T-6D-69 Washington, DC 20555-0001 Dear Sir;
Subject:
Palo Verde Nuclear Generating Station (PVNGS) ,
Units 1,2. and 3 j Docket Nos. STN 50-528/529/530 )
Comments on Proposed Supplement 1 to Generic Letter 83-11 and !
NRC Questions Regarding New or Revised Analysis Methods (l On October 25,1995, the Nuclear Regulatory Commission (NRC) published for public comment, in the Federal Register (60 FR 54712), proposed Supplement 1 to Generic )
Letter 83-11 conceming licensee qualification for performing their own safety analyses.
The Federal Register notice also contained a list of questions regarding the process of acceptance of new or revised safety analysis methods. Arizona Public Service Company is pleased to provide, as an enclosure to this letter, comments on the proposed Supplement to GL 83-11 and responses to the questions posed in the Federal Register.
APS also endorses the comments that are being submitted for the industry by the Nuclear Energy Institute (NEI).
Should you have any questions, please contact Scott Bauer at (602) 393-5978.
Sincerely, W OLS WLS/AKK/ GAM /pv
Enclosure:
Comments on Proposed Supplement 1 to Generic Letter 83-11 and NRC Questions Regarding New or Revised Analysis Methods cc: B. E. Holian
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ENCLOSURE COMMENTS ON PROPOSED SUPPLEMENT 1 TO GENERIC LETTER 83-11 AND NRC QUESTIONS REGARDING NEW OR REVISED l
ANALYSIS METHODS l
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COMMENTS ON PROPOSED SUPPLEMENT 1 TO GENERIC LETTER 83-11 AND NRC QUESTIONS REGARDING NEW OR REVISED ANALYSIS METHODS 1
APS supports the concept of eliminating a licensee qualification topical report for performing reload safety analysis. The guidelines proposed appear to be reasonable ,
to implement and will result in significant savings to the NRC staff and licensees in both time and resources. APS currently has in place all the elements of these guidelines I and plans an increased role in performing all reload safety analyses in support of the PVNGS units.
Provided below are specific comments related to the proposed Supplement 1 of NRC Generic Letter 83-11, published in the Federal Register on October 25,1995 (60 FR 5471?). The section numbers specified refer to sections in Attachment 1 to proposed Supplement 1 to Generic Letter 83-11. Several of the comments are characterized as interpretations of how APS would implement the guidance as written. It is expected that by providing these interpretations, the author of the proposed supplement would be able to determine if the intent of the supplement is understood properly, or if additional clarification should be provided in the final version of the supplement.
Responses are also provided to the NRC questions published in the same Federal Register notice regarding proposed modified procedures related to new or revised analytical methods.
Section 2.0 - Guidelines
" the licensee must send the NRC a notification ofits having followed the guidelines at least three months before the date ofits intended first licensing application."
APS Comments:
The "first licensing application" is interpreted by APS as being the first proposed license amendment or other licensing basis change requiring prior NRC review and approval that was supported by safety analyses performed by the licensee instead of a vendor. In other words, the licensee would provide notification of having followed the guidelines of Supplement 1 to GL 83-11 at least three months prior to the submittal of the first proposed license amendment that is supported by the analyses performed by the licensee. The licensee would provide a simple letter to notify the NRC. Detailed supporting information would not typically be sent with such a notification.
With respect to plant applications of safety analyses performed by the licensee that would not involve changes requiring prior NRC approval, such as a reload
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analysis that would not involve a license amendment or an unreviewed safety question, APS would expect to implement the guidelines of Supplement 1 to )
Generic Letter 83-11 prior to performing the analyses, but would not expect to l submit a special notification to the NRC. Any changes would be evaluated under 10 CFR 50.59 and reported to the NRC in the routine 50.59 report.
This interpretation would be confirmed if the guidance in the GL supplement were to state '..the licensee must send the NRC a notification of its having followed the guidelines at least three months before submitting the first proposed licensing basis change that would require NRC approvalprior to implementation that is supported by analysis performed by the licensee."
Section 2.1 - Elialbility
... 'The only codes and methods that are addressed by this process are those that NRC has reviewed and approved."
l APS Comments: '
APS would interpret this to mean that code packages (i.e., RETRAN, SIMULATE) previously approved in topical reports or license amendments for other plants ..ould be generically approved.
With respect to code uncertainties in approved codes, APS would Interpret that
. plant specific uncertainties could be used without additional NRC review, even if these uncertainties are less than the generically approved uncertainties.
Section 2.2 - Application Procedures
'In-house application procedures which ensure that the use of approved methods is consistent with the code quali6 cation and approved application of the methodology, should be established andimplemented."
APS Comments:
i APS would expect to comply with this guidance through general analysis and I software ' quality assurance procedures which require that only qualified software !
be used for safety related calculations. Changes to methodology would be
. controlled by design control procedures and subject to 50.59 evaluations if ,
appropriate. 1 i
Section 2.4 - Comparison Calculations
' Licensees should verify their ability to use the methods by comparing their calculated results to an appropriate set of benchmark data, such as physics ,
startup tests, measured flux detector data during an operating cycle, and vendor l 2
., w . . . . - . . , a results. These comparisons should be documentedin a report which is part of the licensee's quality assurance (QA) records."...
' APS Comments:
APS' would consider "an appropriate set of benchmark data" to include other ,, a4-acknowledged industry standard data or criteria (e.g., obtaining similar results to other already approved methods).
Section 2.5 - Quality Assurance and Channe Control "All safety related licensing calculations performed by a licensee using NRC approved codes and methods should be conducted under the control of a Quality Assurance (QA) program.....The licensee's QA program should also include the 16l lowing:
p) A provision forimplementing vendor updates in cod =s. methods, and procedures (if applicable); and (2) A provision forinforming vendors of any problems or errors discovered while using their codes, methods orprocedures."
APS Comments:
It is suggested that paragraph (1) be revised to state: "(1) A provision for ,q evaluating vendor updates andimplementing those updates, if applicable, in
. codes, methods, and procedures..."
APS Comments on NRC Questions Reaardina New or Revised Analysis Methods NRC Question:
. (1) To what extent can an organization other than the NRC (a third party) review a new l methodology or a significant change to an existing methodology?
APS Comments:
- The use of third party reviewers is feasible if consistent guidelines were prepared by the NRC for use by the third party reviewers.' This would ensure that qualified but independent reviews would be consistently applied. APS would recommend that communications be allowed between the third party reviewer and the licensee directly.
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NRC Question:
(a) What capabilities should be required of a third-party reviewer?
APS Comments:
(1) In-depth knowledge of the current theory and application of the method and code (s), (2) Experience with the methods or code in a commercial and developmental application, (3) A willingness to review new methodology on it's own merits and without an intent to force conformance to previous standards, (4)
"the ability to meet the review schedule as agreed to by the reviewer, the NRC and the licensee.
NRC Question:
. (b) What is the safety significance of not having the NRC perform the review?
APS Comments:
None,'if the NRC expectations and acceptance criteria are adhered to by the third party.
NRC Question: i (c) What documentation should be submitted to the NRC by the third-party reviewer and/or by the licensee?
l APS Comments:
Enough documentation should be provided to enable the NRC to write a safety evaluation report. I t
. NRC Question:
' (d) What type of acceptance (e.g., a safety evaluation report) should be issued?
APS Comments:
An SER or other official communication which could be referenced by the licensee.
NRC Question:
' (e) How would approved references (e.g., Core Operating Limits Report (COLR) parameters in technical specification reporting requirements) be handled?
4
APS Comments:
One advantage of the adoption of the COLR was that reload related changes no longer required NRC review prior to implementation. This significantly reduced
' the administrative burden on the NRC and licensee for such changes. This provision was acceptable for changes identified from the use of methods previously reviewed and approved by the NRC.
With respect to the future use of the COLR, APS recommends that: (1) the list of topical reports and safety evaluation reports be removed from the Technical Specifications and placed in the COLR, (2) the COLR list of topical reports be limited to those which describe methods specifically related to cycle specific parameter limits in Technical Specifications (i.e., the list will not become a collection point for all non-COLR-related topicals), and (3) appropriate wording be maintained in the Technical Specifications requiring the use of NRC approved methods.
Consider the case where a reload related method change is requested by a licensee. In many cases, approval of a new method is requested independent of 2 a specific reload due to the uncertainty associated with the time related to the approval process. Following approval of the method, the Technical Specifications must then be changed to list the new reference (requiring a license amendment). If the list of analytical methods is moved from the Technical Specifications to the COLR, the new approved method could be i implemented by the licensee as soon as the new method is approved or as part of a future reload evaluation. This would eliminate the additional administrative burden on the NRC or licensee to update the approved methodology list in the Technical Specifications, while still ensuring that only NRC approved methods are used.
NRC Question:
(f) What information, if any, should be available for NRC audit?
APS Comrcents:
Al'l relevant iriformation supporting the code or methods change.
NRC Ques, tion:
(2) % hat ciher viable approaches can be used fcr accepting new or revised methods?
(a) Should a regulatory guide be developed?
(b) Can a set of criteria, as proposed in the generic letter supplement for previously approved generic methods, also be developed for new methods?
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APS Comments:
The criteria for new methods should allow implementation of new methods if the licensee meets the applicable standards and a 10 CFR 50.59 evaluation is -
performed.
APS also believes that the new methods should be acceptable if it can be demonstrated that the new method performs as well or better than the old approved m'ethod. This could be done by benchmarking the new and old methods side by side against plant data or ' y comparing uncertainties obtained by the new method with those obtained using the old method.
J NRCLQuestion:
(3) To what technical disciplines should this process apply?
Arai Comments:
l Reactor Physics, Thermal Hydraulic, and Safety Analysis. l l
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CENTERDOR ENERGY M,
'!J 300 Madison Avenue John P. Sletr loiedo, OH 43652-0001 Vice President Nudeor 419 249-2300 Davis-Besse Docket Number 50-346 License Number NPF-3 Serial Number 2348 -
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January 8, 1996
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I Chief, Rules Review and Directives Branch '-
1 United States Nuclear Regulatory Commission Mail Stop T-6D-69, .
Washington, D. C. 20555-0001 ,y ,.;
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Subject:
Comments Regarding Proposed Generic Communication: >
Licensee Qualification and Performing Safety Analyses I (M91599)
Gentlemen:
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Toledo Edison (TE), a subsidiary of Centerior Energy, is partial owner of and is responsible for operation of the Davis-Besse Nuclear Power l Station (DBNPS). As a 10 CFR Part 50 licensee, TE has a vested j interest in both the technical and regulatory aspects of the proposed '
generic letter supplement which provides an alternative method for licensees to perform their own safety analyses. ;
1 Toledo Edison has reviewed the preposed supplement to Generic Letter i 83-11 " Licensee Qualification for Performing Safety Analyses in I 9upport of Licensing Actions" (60FR54712). Based on this review, TE
. ,vides the following comments: ,
- 1. The proposed generic letter supplement appears to be geared toward organizations, such as Nuclear Steam Supply System (NSSS) vendors or the Electric Power Research Institute (EPRI), that routinely submit topical reports to the Nuclear Regulatory Commission (NRC) for review. Toledo Edison recommends that the guidance be explicit enough to allow for utilities to reference topical reports submitted by non-NSSS vendors, in particular, other utilities. For example, Studsvik of America has developed the CASMO-3/ SIMULATE-3 computer code package that is used extensively by utilities throughout the United States for reactor physics analyses. Several Operating Companies Cleveland Electne liluminahng 0* **
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1 Page 2 utilities have submitted topical reports to the NRC j based upon these computer codes and have obtained NRC approval of their use. Studsvik, however, has not I submitted their codes and methods to the NRC for generic approval and will not likely do so.
- 2. The guidance contained in the proposed generic letter should insure that sufficient flexibility exists to allow utilities to optimize their resources in 1 performing their own safety analyses. Most NSSS and fuel vendors obtain NRC approval of their analytical methods which employ a certain set of computer codes to perform various portions of their safety analyses.
However, other computer codes exist which are capable of being used for some portions of safety arialyses with similar accuracy and reliability. Therefore, TE recommenls that the proposed guidance be sufficiently flexible to allow substitution of computer codes within an approved analytical we hodology.
- 3. At present, there is no simple means for a utility to '
discern which codes and nethods have been approved by the NRC. Therefore, TE recommends that the NRC
.3tablish, and maintain readily available, a listing of the codes or methods it has approved.
- 4. The proposed generic letter supplement contains provisions for licensees in implementing vendor updates in computer codes. However, at some point in time, it is possible that these incremental updates could result in significant changes to an approved code or method, which may require NRC reapproval.
Therefore, TE recommends that the NRC define the point at which reapproval is necessary so as to avoid any future ambiguities over the updates for users and vendors, as well as for the NRC.
Should you have any questions regarding these comments, please contact Mr. Peter W. Smith, Acting Manager - Regulatory Affairs, at (419) 249-2366.
l Very truly yours, GAB / eld cc: L. L. Gundrum, NRC Project Manager H. J. Niiler, Regional Administrator, NRC Region III S. Stasek, DB-1 NRC Senior Resident Inspector USNRC Document Control Desk )
i Utility Radiological Safety Board
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