ML20134F993
| ML20134F993 | |
| Person / Time | |
|---|---|
| Issue date: | 01/27/1997 |
| From: | John Kramer NRC |
| To: | Fuld R ABB COMBUSTION ENGINEERING NUCLEAR FUEL (FORMERLY |
| Shared Package | |
| ML20134F986 | List: |
| References | |
| RTR-REGGD-XX.XXX FACA, NUDOCS 9702100232 | |
| Download: ML20134F993 (1) | |
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Mobert B. Fuld/CENSYS/USNUS/ABB @ ABB_USSEV_IMS@ABB_ NOTES i
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From:
JJK1 GP nrc. gov @usinet @ ABB_ NOTES Date:
01/27/97 07:24:46 AM l
Subject:
DG-1052 Comments Reply
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j Just to get things into the system more officially, as the foctnote on the frcr.t page of DG-1052 states, please FAX to Dave Meyers at 301-415-5144 Thnx much!I Joel
>>> < robert.b.fuldaussev. mail.abb.com> 01/24/97 00:01pm >>>
Joel--I'm still sidelined from the Internet, but if you can carry the ball belcw (which I've also f axed), then I met my deadline. Thanks, and I hope this helps.
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................................................ ccMggn;s og og.1052 / RSSpONSE A
TO ACRS COMMENTS ON DG-1040 i
As a menber of the ANS Working group that developed ANSI /ANS-58.8 1994, I wish to comment en that Standard and on the proposed Reg Guide that would l
endorse it.
l 3eneral 4
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As stated in both those documents, it is plant design criteria, and not human performance criteria, that the methodology provides, supporting the analysis of
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design basis events in SARs. The methodology is unique in that it substantively i
addresses the issue known in human factors jargon as function allecation. I r.
is, I believe, commendable in doing so with only a modest extension of the existing plant safety analysis framework, And it is hard to disputa that i* in far more cractical, oblective, empirically-based, and safety-relevant tha, tha i
competing state-of-the-art methods urged. if not irrrosed, by Sactier 4.4 1 of NUREG-O'l11 ()timan Factors Engineering Program Review Model!.
i Respcnse to ACRS Comments on D3-1040 In a letter dated November 14, 1995, the ACES raised several ohjaetinra tn D0 1040, which are discussed below.
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- 1. We find no technical basis for the estimates of minimum timam fnr npavator j
actions in ANSI /ANS-58.8-1994. - The technical banin in for *h= cri*eria on time response, rather than for any particular tima amtimatas, and that basis is summarized in the Appendix to the 59.E Standard. Tn enntraat, time eatinates are based largely en analysis of the time requirad for tha nparators tasks, guided by the rather conservative rule to allow nna irirvra per manipulatien. rhe l
technical basis for any particular time antimata remairs the responsibility of
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the analysts, who must be able to :)ustify their mndalirg nf nperator tasks as 9702100232 961119 PDR REGGD XX.XXX C PDR
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