NRC-2011-0299, Comment (14) of James Becker on Draft Regulatory Basis Document to Support Potential Amendment to Regulations Concerning Nuclear Power Plant Licensees' Station Blackout Mitigatin Strategies (10 CFR Parts 50 and 52), (NRC-2011-0299)

Comment (14) of James Becker on Draft Regulatory Basis Document to Support Potential Amendment to Regulations Concerning Nuclear Power Plant Licensees' Station Blackout Mitigatin Strategies (10 CFR Parts 50 and 52), (NRC-2011-0299)

ML13176A450
Person / Time
Site:	Palo Verde, Wolf Creek, Diablo Canyon, Callaway, South Texas, San Onofre, Comanche Peak
Issue date:	06/24/2013
From:	Becker J STARS Alliance
To:	Annette Vietti-Cook NRC/SECY/RAS
SECY/RAS
References
78FR21275 00014, EA-12-049, NRC-2011-0299, STARS 13004
Download: ML13176A450 (3)

Text

PR 10 CFR Parts 50 and 52 14 (78FR21275)

STARS Alliance Alliance Members:

Callaway Energy Center Comanche Peak Nuclear Power Plant Diablo Canyon Power Plant www.starsalliance.com Palo Verde Nuclear Generating Station 1626 N. Litchfield Rd., Suite 230 San Onofre Nuclear Generating Station Goodyear, AZ 85395 South Texas Project T: 623-209-7549 Wolf Creek Generating Station STARS 13004 June 24, 2013 Secretary U. S. Nuclear Regulatory Commission Washington, DC 20555-0001 ATTN: Rulemakings and Adjudications Staff

Subject:

STARS Alliance LLC Comments on Station Blackout Mitigation Strategies Draft Regulatory Basis and Draft Rule Concepts

References:

1. Federal Register Vol. 78, No. 69, April 10, 2013, pp. 21275-21276

2. Letter from J. E. Pollock, NEI, to A. L. Vietti-Cook, Secretary, USNRC, NEI Comments on Station Blackout Mitigation Strategies Regulatory Basis and Draft Rule Concepts, dated June 20, 2013

3. Rulemaking for Station Blackout Mitigation Strategies, NRC Docket ID: NRC-2011-0299, RIN number:

3150-AJO8 (ML13077A453)

Dear Ms. Vietti-Cook,

STARS Alliance LLC (STARS) submits the following comments in response to the Federal Register notice (Reference 1) soliciting comments on the Station Blackout Mitigation Strategies draft regulatory basis and draft rule concepts. STARS appreciates the opportunity to comment on the draft regulatory basis and rule concepts.

STARS endorses the comments submitted by NEI (Reference 2) on the draft regulatory basis and rule concepts. STARS would like to emphasize the following points listed below.

• STARS agrees with the NRC staffs conclusion that rulemaking is warranted to apply the requirements of Order EA-12-049 to all existing and proposed nuclear power plants. However, for licensees currently implementing the Order, the regulatory framework should ensure that it will allow for future relaxation of the Order in its entirety in order to preclude conflicting requirements.

• The regulatory requirements should be structured to recognize and appropriately credit the enhanced capabilities of new plant designs.

• STARS believes that linking the current station blackout (SBO) rule with the mitigating strategies can best be accomplished by addressing mitigating strategies in a section of the regulations separate from 10 CFR 50.63 and/or 10 CFR 50.54(hh)(2). This regulatory objective should be evaluated further.

• The draft rule concepts proposed by the NRC address many design and implementation details.

STARS believes that most of those details belong in endorsed guidance.

• STARS agrees with combining the SBO rulemaking with the spent fuel pool instrumentation rulemaking but also believes elements of Recommendation 8 rulemaking should be included.

If you have any question on these comments, please contact me at 623-239-3548, or Steve Meyer at 314-225-1483, or steve.meyer@starsalliance.com.

Si James cker President, STARS Alliance LLC james.becker@starsalliance.com SJ M

RulemakingComments Resource From: Gallagher, Carol Sent: Monday, June 24, 2013 2:04 PM To: RulemakingComments Resource Cc: Reed, Timothy

Subject:

FW: STARS comments on NRC Docket ID: NRC-2011-0299 Attachments: STARS Alliance SBO comment letter.PDF Attached for docketing is a comment on Station Blackout Mitigation Strategies (78 FR 21275; April 10, 2013)

(3150-AJ08).

Thanks, Carol From: Meyer, Stephen J [1]

Sent: Monday, June 24, 2013 1:39 PM To: Gallagher, Carol Cc: steve.meyer@starsalliance.com; Meyer, Stephen J; Buschbaum, Denny

Subject:

STARS comments on NRC Docket ID: NRC-2011-0299

Carol, Here is the comment letter we just discussed on the telephone. Thank you in advance for getting this to the right place.

Steve Meyer STARS Regulatory Affairs 314.225.1483 The information contained in this message may be privileged and/or confidential and protected from disclosure.

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