ML12027A007

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Comment (1) of Sce&G Draft NUREG-xxxx, Common - Cause Failure Analysis in Event and Condition Assessment: Guidance and Research
ML12027A007
Person / Time
Site: Summer South Carolina Electric & Gas Company icon.png
Issue date: 01/23/2012
From:
South Carolina Electric & Gas Co
To:
Rulemaking, Directives, and Editing Branch
References
76FR67764 00001
Download: ML12027A007 (2)


Text

Page 1 of 1 As of: January 24, 2012 Received: January 23, 2012 Status: Pending Post PUBLIC SUBMISSION Tracking No. 80fa1037 Comments Due: January 31, 2012 Submission Type: Web Docket: NRC-2011-0254 Common-Cause Failure Analysis in Event and Condition Assessment: Guidance and Research Comment On: NRC-2011-0254-0003 Common-Cause Failure Analysis in Event and Condition Assessment: Guidance and Research, Draft Report for Comment; Correction Document: NRC-2011-0254-DRAFT-0002 Comment on FR Doc # 2011-29436 177&1,711 Submitter Information Organization: SCE&G, Virgil C. Summer Nuclear Station General Comment See attached document for comments.

Attachments Comments on Draft NUREG xxxx

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Comments on Draft NUREG xxxx, Common-Cause Failure Analysis in Event and Condition Assessment:

Guidance and Research Numerous technical errors are present throughout the document, which are identified below. The majority deal with the omission of/or incorrect reference to equations, or not following a standard presentation of terms in the equations.

Page 7 Missing equation for a Page 21 Missing equation for M, the Markov transition matrix Page 22 Missing equation for X1k Page 22 Missing equation for conditional probabilities Page 22 Missing reduced transition matrix Page 23 Missing equation for conditional probabilities Page 23 Missing equation for conditional initiating event frequency There is a reference to eq. 3.5, when the written annotation is (5) in section 3.

Page 24 There is a reference to eq. 3.6, when the written annotation is (6) in section 3.

Page 25 There is a reference to eq. 3.6, when the written annotation is (6) in section 3.

Page 26 In two places, there is a reference to eq. 3.6, when the written annotation is (6) in section 3.

General comment for pages 23-26: The equation(s) referenced should be clearly stated with equations numbered accordingly.

Page 35 In A.8, the final term should read: Q3(3)=a3Qt (vice Q,(3)

Page 45 In 3 paragraph, notation for nkS should read: nk' (s should be italicized superscript)

Page 46 Before eq. (B.16), notation for Qks should read: Qk' (s should be italicized superscript)

Page 47 Before eq. (B.18), notation for akS should read: ak' . (s should be italicized superscript)

Page 47 In last sentence, ak should read: ak (k should be italicized)