ML20196G028

Forwards Summary of Staff Comments & D Ziemann Response from 770927 Telcon Re Draft Commission Paper & Discussion Paper Submitted w/770923 Memo

ML20196G028
Person / Time
Issue date:	10/03/1977
From:	Minogue R NRC OFFICE OF STANDARDS DEVELOPMENT
To:	Stello V Office of Nuclear Reactor Regulation
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References
FOIA-87-854 NUDOCS 8803040322
Download: ML20196G028 (2)

Text

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1 OCT D71 '

MEMORANDUM FOR: Victor Stello, Jr. Director. Divi ton of  !

Operating Reactors, NRR FROM:

Robert B. Minogue. Director. Office of l Standards Development

SUBJECT:

SYSTEMATIC EVALUATION PROGRAM (SEP)

The draft Comission paper and its enclosed Discussion Paper on the SEP have been reviewed as requested by your memorandum of September 23, 1977.

In view of the short time allowed for answering your request, our coments were discussed with D. Zieman'n by G. Arndt via telephone on Septenber 27. 1977. Our comments and Ziemann's responses are sumarized in the enclosure.  !

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Robert B. Minogue, Director Office of Standards Development T' -

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8803040322 080229 PDR FOIA CONNORB7-054 PDR F-s5

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Comments and Responses on SEP Staff Paper

1. (pp.9,9a) There appears to be a conflict in the example given on containment negative pressure in considering the probability too small to review, but still requiring consideration for design.

Response: The requirement to consider this in design applies only to new plants, and the impact is nominal when compared with the beneTits mentioned in the discussion.

2. (Attachment 1, pp.13,14) Are all accidents considered in t is reviewwhichhaveaprobabilityofoccurrencbhigherthan10g?

Response: It is felt that all initiating accidents which are not determined to be of "lesser safety significance" are included, but this will be reviewed.

3. (pp.13) Can non-safety systems be used to perform safety functions?

For example, they may not be seismically qualified.

Response: This item is only listed for possible consideration, when it is determined that some credit can be granted for the non-safety system. For example, seismic qualification may be possible, or it may not be relevant. This is a discretionary item.

4. (pp. 27) The difference between Alternate #3 and the proposed program is not clear.

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Response: There are a number of blank spaces which will be filled in later, ar,d these will clarify the writeup. They will clarify references to a previous proposal and the current proposal. .

All other comments were of a minor nature, l

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