[Federal Register Volume 60, Number 206 (Wednesday, October 25, 1995)]
[Notices]
[Pages 54712-54714]
From the Federal Register Online via the Government Publishing Office [www.gpo.gov]
[FR Doc No: 95-26421]



-----------------------------------------------------------------------


NUCLEAR REGULATORY COMMISSION

Proposed Generic Communication; Licensee Qualification for 
Performing Safety Analyses (M91599)

AGENCY: Nuclear Regulatory Commission.

ACTION: Notice of opportunity for public comment.

-----------------------------------------------------------------------

SUMMARY: The Nuclear Regulatory Commission (NRC) is proposing to issue 
Supplement 1 to Generic Letter 83-11 concerning licensee qualification 
for performing their own safety analyses. This draft generic letter 
supplement provides an alternative method for licensee qualification. 
The NRC is seeking comment from interested parties regarding both the 
technical and regulatory aspects of the proposed generic letter 
supplement presented under the Supplementary Information heading.
    This proposed generic letter supplement was endorsed by the 
Committee to Review Generic Requirements (CRGR) on September 26, 1995. 
The relevant information that was sent to the CRGR will be placed in 
the NRC Public Document Room. The NRC will consider comments received 
from interested parties in the final evaluation of the proposed generic 
letter supplement. The NRC's final evaluation will include a review of 
the technical position and, as appropriate, an analysis of the value/
impact on licensees. Should this generic letter supplement be issued by 
the NRC, it will become available for public inspection in the NRC 
Public Document Room.
    In addition to the proposed supplement to Generic Letter 83-11, the 
NRC staff is also investigating modified procedures for reducing the 
resource effort for acceptance of new or revised licensee or vendor 
analysis methods. Currently, topical reports are submitted to the NRC 
which require a relatively long review and approval process. In this 
regard, the NRC requests comments on the following:
    (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?
    (a) What capabilities should be required of a third-party reviewer?
    (b) What is the safety significance of not having the NRC perform 
the review?
    (c) What documentation should be submitted to the NRC by the third-
party reviewer and/or by the licensee?
    (d) What type of acceptance (e.g., a safety evaluation report) 
should be issued?
    (e) How would approved references (e.g., Core Operating Limits 
Report (COLR) parameters in technical specification reporting 
requirements) be handled?
    (f) What information, if any, should be available for NRC audit?
    (2) What other viable approaches can be used for 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?
    (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.

DATES: Comment period expires December 11, 1995. Comments submitted 
after this date will be considered if it is practical to do so, but 
assurance of consideration cannot be given except for comments received 
on or before this date.

ADDRESSEES: Submit written comments to Chief, Rules Review and 
Directives Branch, U.S. Nuclear Regulatory Commission, Mail Stop T-6D-
69, Washington, DC 20555-0001. Written comments may also be delivered 
to 11545 Rockville Pike, Rockville, Maryland, from 7:30 am to 4:15 pm, 
Federal workdays. Copies of written comments received may be examined 
at the NRC Public Document Room, 2120 L Street, N.W. (Lower Level), 
Washington, D.C.

FOR FURTHER INFORMATION CONTACT: Laurence I. Kopp (301) 415-2879.

SUPPLEMENTARY INFORMATION:

NRC Generic Letter 83-11, Supplement 1: Licensee Qualification for 
Performing Safety Analyses

Addressees

    All holders of operating licenses or construction permits for 
nuclear power reactors.

Purpose

    The U.S. Nuclear Regulatory Commission (NRC) is issuing this 
supplement to Generic Letter (GL) 83-11 to notify licensees and 
applicants of modifications to the Office of Nuclear Reactor Regulation 
(NRR) practice regarding licensee qualification for performing their 
own safety analyses. It is expected that recipients will review the 
information for applicability to their facilities. However, suggestions 
contained in this supplement to the generic letter are not NRC 
requirements; therefore, no specific action or written response is 
required.

Background

    Over the past decade, substantially more licensees have been 
electing to perform their own safety analyses to support such tasks as 
reload applications and technical specification amendments, rather than 
contract the work out to their nuclear steam supply 

[[Page 54713]]
system (NSSS) vendor, fuel vendor, or some other organization. The NRC 
encourages utilities to perform their own safety analyses since doing 
this significantly improves licensee understanding of plant behavior. 
GL 83-11 presented guidance on the information that NRC needs in order 
to qualify licensees to perform their own safety analyses using 
approved computer codes.

Description of Circumstances

    NRC experience with safety analyses using large, complex computer 
codes has shown many times that errors or discrepancies discovered in 
safety analyses can be traced to the user rather than to the code 
itself. This realization has led the NRC to place additional emphasis 
on assuring the capabilities of the code users as well as on assuring 
the codes themselves. In the past, NRC obtained this assurance by 
reviewing the code verification information submitted by the licensee. 
The review focused primarily on the licensee's quality assurance 
practices and the technical competence of the licensee with respect to 
their ability to set up an input deck, execute a code, and properly 
interpret the results. The information which was reviewed generally 
included comparisons (performed by the user of the code results) with 
experimental data, plant operational data, or other benchmarked 
analyses, as well as compliance with any restrictions or limitations 
stated in the generic NRC Safety Evaluation Report (SER) that approved 
the code.
    Since GL 83-11 was issued, many licensees have submitted 
information in the form of topical reports demonstrating their ability 
to perform their own safety analyses, such as reload analyses, using 
NRC-approved methods and codes. The preparation and review of a 
qualification topical report is resource intensive for both the 
licensee and the staff, and because the review is usually assigned a 
low priority, it is difficult to schedule the review for timely 
completion.

Discussion

    To help shorten the lengthy review and approval process, the NRC 
has adopted a generic set of guidelines which, if met, would eliminate 
the need to submit detailed topical reports for NRC review before a 
licensee could use approved codes and methods. These guidelines are 
presented in Attachment 1. Using this approach, which is consistent 
with the regulatory basis provided by Criteria II and III of Appendix B 
to Part 50 of Title 10 of the Code of Federal Regulations (10 CFR 50), 
the licensee would institute a program (such as training, procedures, 
and benchmarking) that follows the guidelines, and would notify NRC by 
letter that it has done this and that the documentation is available 
for NRC audit.

Summary

    The revised guidance on licensee qualification for using safety 
analysis codes is intended for licensees who wish to perform their own 
licensing analyses using methods that have been reviewed and approved 
by the NRC.

Backfit Discussion

    This supplement does not involve a backfit as defined in 10 CFR 
50.109(a)(1), it provides guidance as to an acceptable means by which a 
licensee may verify to the NRC its qualifications to use approved codes 
and methods for performing safety analyses. Therefore the staff has not 
prepared a backfit analysis.

Attachment 1--Guidelines for Qualifying Licensees To Use Generically 
Approved Analysis Methods

1.0  Introduction
    This attachment presents a simplified approach for qualifying 
licensees to use NRC-approved analysis methods. Typically, these 
methods are developed by a fuel vendor or an organization such as the 
Electric Power Research Institute, Incorporated (EPRI). To use these 
approved methods, the licensee would institute a program (e.g., 
training, procedures) that follows the guidelines below and notify the 
NRC that it has done so.
2.0  Guidelines
    A commitment on the part of a licensee to implement the guidelines 
delineated in this document is sufficient information for the NRC to 
accept the licensee's qualification to use an approved code or method 
to perform safety-related evaluations. To document its qualification in 
this manner, the licensee must send the NRC a notification of its 
having followed the guidelines at least three months before the date of 
its intended first licensing application.
2.1  Eligibility
    The only codes and methods that are addressed by this process are 
those that NRC has reviewed and approved.
2.2   Application Procedures
    In-house application procedures, which ensure that the use of 
approved methods is consistent with the code qualification and approved 
application of the methodology, should be established and implemented. 
These procedures should contain a section describing the application of 
the code and a section delineating the code limitations and 
restrictions, including any defined in the licensing topical report, 
correspondence with the NRC, and the safety evaluation report (SER).
2.3  Training and Qualification of Licensee Personnel
    A training program should be established and implemented to ensure 
that each qualified user of an approved methodology has a good working 
knowledge of the codes and methods, and will be able to set up the 
input, to understand and interpret the output results, to understand 
the applications and limitations of the code, and to perform analyses 
in compliance with the application procedure.
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 results. These comparisons should be 
documented in a report which is part of the licensee's quality 
assurance (QA) records. Any deviations in the calculations of safety-
related parameters should be justified in the report. All comparisons 
with startup test data should agree within the acceptance criteria 
defined in the plant startup test plan.
2.5  Quality Assurance and Change 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 which complies with the 
requirements of Appendix B to Part 50 of Title 10 of the Code of 
Federal Regulations (10 CFR 50). The licensee's QA program should also 
include the following:
    (1) A provision for implementing vendor updates in codes, methods, 
and procedures (if applicable); and
    (2) A provision for informing vendors of any problems or errors 
discovered while using their codes, methods, or procedures.

    Dated at Rockville, Maryland, this 18th day of October 1995.


[[Page 54714]]

    For the Nuclear Regulatory Commission.
Dennis M. Crutchfield,
Director, Division of Reactor Program Management, Office of Nuclear 
Reactor Regulation.
[FR Doc. 95-26421 Filed 10-24-95; 8:45 am]
BILLING CODE 7590-01-P