Licensee Qualification for Performing Safety Analyses in Support of Licensing Actions (Generic Letter No. 83-11)
UNITED STATES
NUCLEAR REGULATORY COMMISSION
WASHINGTON, D. C. 20555
February 8, 1983
TO ALL OPERATING REACTOR LICENSEES
SUBJECT: LICENSEE QUALIFICATION FOR PERFORMING SAFETY ANALYSES IN SUPPORT
OF LICENSING ACTIONS (Generic Letter No. 83-11)
Gentlemen:
The purpose of this letter is to inform you of the current NRR practice
regarding licensee qualification for performing safety analyses in support
of licensing actions.
Over the past few years, the number of licensees electing to perform their
own safety analyses to support reload applications, technical specification
amendments, etc... rather than contract the work out to their NSSS vendor or
other organizations has increased substantially. We encourage utilities to
perform their own safety analyses since it significantly improves their
understanding of plant behavior.
NRC's experience with safety analyses using large, complex thermal-hydraulic
computer codes such as RELAP and TRAC has shown that a large percentage ,of
all errors or discrepancies discovered in safety analyses can be traced to
the user rather than to the code itself. This realization has led NRR to
place additional emphasis on assuring the capabilities of the code users as
well as on the codes themselves. For example, for the past two years NRR has
been working with the Vendor Inspection Branch in Region IV to inspect the
acceptability of the QA procedures used for code development, verification,
use, and maintenance for all licensees and vendors involved with safety
analysis codes presently under staff review. While this aspect of our review
focuses primarily on the competence of the licensee and vendors regarding
quality assurance practices, the technical competence of the licensees and
vendors with respect to their ability to set up an input deck, execute a
code, and properly interpret the results must also be assured. NRR obtains
this assurance by reviewing the code verification information submitted by
the licensee or vendor. The information we look for includes comparisons
performed by the user of the code results to experimental data, plant
operational data, or other benchmarked analyses.
We are concerned however, that some licensees planning to perform their own
safety analyses may not intend to demonstrate their ability to use the code
by performing their own code verification. Rather, they plan to rely on the
code verification work previously performed by the code developer or others.
8302080304
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NRR does not consider this acceptable and each licensee or vendor who
intends to use a safety analysis computer code to support licensing actions
should demonstrate their proficiency in using the code by submitting code
verification performed by them, not others.
In order to eliminate problems on future licensing submittals, I request
that you factor this into your future licensing submittal plans.
Darrell G. Eisenhut, Director
Division of Licensing
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