ML20096E978

Comment on Proposed Suppl to GL 83-11, Licensee Qualification for Performing Safety Analyses in Support of Licensing Actions

ML20096E978
Person / Time
Site:	Davis Besse
Issue date:	01/08/1996
From:	Stetz J CENTERIOR ENERGY
To:	NRC OFFICE OF ADMINISTRATION (ADM)
References
FRN-60FR54712 60FR54712, GL-83-11, TAC-M91599, NUDOCS 9601230143
Download: ML20096E978 (2)

Text

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V ENERGY 300 Modison Avenue John P. Seser l Toledo. OH 43652 0001 Vice President Nuclear 419-249-2300 povts. geese

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/ fy Docket Number 50-346 License Number NPF-3 Serial Number 2348 g re -

January 8, 1996 u  ;;

c, J Chief, Rules Review and Directives Branch pi" ] , c)

United States Nuclear Regulatory Commission (' ' 7; Mail Stop T-6D-69, Washington, D. C. 20555-0001 O. >

9 r0

Subject:

Comments Regarding Proposed Generic Communication:  : m Licensee Qualification and Performing Safety Analyses' (M91599)

Gentlemen:

Toledo Edison (TE), a subsidiary of Centerior Energy, is partial owner of and is responsible for operation of the Davis-Besse Nuclear Power .

Station (DBNPS). As a 10 CFR Part 50 licensee, TE has a vested I 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.

Toledo Edison has reviewed the proposed supplement to Generic Letter 83-11 " Licensee Qualification for Performing Safety Analyses in Support of Licensing Actions' (60FR54712). Based on this review, TE provides 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 i 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 f r rea t r physics analyses. Several OM 9601230143 960108 PDR ADOCK 05000346 P PDR l Operating Companies:

Cleveland Electnc illuminating Toledo Edison

( Docket Number 50-346 License Number NPF-3 t

Serial Number 2348 Page 2 i

i utilities have submitted topical reports to the NRC '

based upon these computer codes and have obtained NRC approval of their use. Studsvik, however, has not submitted their codes and methods to the NRC for i 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 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. i However, other computer codes exist which are' capable  ;

of being used for some portions of safety analyses  !

with similar accuracy and reliability. Therefore, TE recommends that the proposed guidance be sufficiently i flexible to allow substitution of computer codes within an approved analytical methodology.  !

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3. At present, there is no simple means for a utility to I discern which codes and methods have been approved by the NRC. Therefore, TE recommends that the NRC establish, and maintain readily available, a listing i of the codes or methods it has approved. j l

4. The proposed generic letter supplement contains l provisions for licensees in implementing vendor l updates in computer codes. However, at some point in 1 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 i Mr. Peter W. Smith, Acting Manager - Regulatory Affairs, at (419) 249-2366.

Very truly yours, GAB / eld l l

cc: L. L. Gundrum, NRC Project Manager i H. J. Miller, Regional Administrator, NRC Region III i S. Stasek, DB-1 NRC Senior Resident Inspector USNRC Document Control Desk  ;

Utility Radiological Safety Board )

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