ML16068A240

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Mitigation of Beyond-Design-Basis Events Proposed Rule Comment (3) - Keating (Annotated) Original Comment Submission Dated November 21, 2015 (ML15328A494)
ML16068A240
Person / Time
Issue date: 07/30/2019
From:
Office of Nuclear Reactor Regulation
To:
Reed T
References
80 FR 70609, NRC-2014-0240, RIN 3150-AJ49
Download: ML16068A240 (2)


Text

Page 1 of 2 PR 10 CFR Parts 50 and 52 80FR70609 3 As of: 11/23/15 11:10 AM Received: November 21, 2015 Status: Pending_Post PUBLIC SUBMISSION Tracking No. 1jz-8mdv-sot7 Comments Due: February 11, 2016 Submission Type: Web Docket: NRC-2014-0240 Mitigation Strategies for Beyond Design Basis Events Comment On: NRC-2014-0240-0003 Mitigation of Beyond-Design-Basis Events Document: NRC-2014-0240-DRAFT-0004 Comment on FR Doc # 2015-28589 Submitter Information Name: Tim Keating Address:

4920 ne 27th terrace Lighthouse Point, FL, 33064-7912 Email: tk-nrc@ktcnslt.com General Comment The current seven to thirty days of emergency fuel is not nearly enough, this would guarantee both a meltdown, and fuel pond fire when civilization faces the brink. What NRC should require of NPP's is a multi-year solution to prevent a massive radioactive isotope release(MRIR).

The rest of the population will be facing a mad max on steroids as the locals fight it out to survive. Forget about trucking in additional fuel. The only thing that prevents this scenario currently is the hope that things will get better shortly( I.E. After math of a hurricane strike, restore services in least affected areas first, etc).

Once that hope fades in the face of a national disaster, Yellowstone eruption/CME/EMP pulse, the population will quickly realize that they are on the own.

With no way to secure additional stocks of diesel fuel, or get replacement generators when the older ones start failing will only delay the inevitable meltdown/cool-down pool fire. [Keating 1]

What the NRC should require is on site solar/wind renewable power in the range of 2 to 4 times excess of requirements, several days of onsite LIFEPO4 battery backup, plus necessary inverters/control equipment, spare parts to kept plant in cold shutdown and a complete set of replacement solar panels in secure storage.

[Keating 2a]

Resilient onsite housing for employees, security, and their families, sufficient food stores for several years, several million rounds of ammo, etc.

file:///C:/Users/CAG/Documents/XPMigratedFolders/PRM-20-28/NRC-2014-0240-DRAFT-0004.html 11/23/2015

Page 2 of 2 All the plans in the world are useless, if there is no around around turn it on, repair when needed, and secure it from intrusion/attack.

Lastly, hope that we never need to use some of these resources. [Keating 3]

(Onsite renewable power could be added to grid, battery storage used for grid peaking/load leveling/cold start.) [Keating 2b]

The NRC plan should include recently decommissioned plants that currently maintain hot reactor assemblies in cool-down pools. NPP facilities should only be allowed reduced their compliance as they reduce the risk.

Once all fuel is in secured dry cask storage, then personal/energy requirements can be reduced to maintaining security and comms. [Keating 4]

file:///C:/Users/CAG/Documents/XPMigratedFolders/PRM-20-28/NRC-2014-0240-DRAFT-0004.html 11/23/2015