|
---|
Category:General FR Notice Comment Letter
MONTHYEARML24262A0102024-09-17017 September 2024 Comment (1) of Victoria K. Anderson on Level 3 Probabilistic Risk Assessment Project Documentation (Volume 7) ML24262A0112024-09-13013 September 2024 Comment (2) of Frances A. Pimentel on Design-Basis Floods for Nuclear Power Plants and Guidance for Assessment of Flooding Hazards Due to Water Control Structure Failures and Incidents ML24234A0892024-08-15015 August 2024 Comment (1) of Mark Richter on Acceptable ASME Section XI Inservice Inspection Code Cases for 10 CFR Part 72 ML24200A1852024-07-17017 July 2024 Comment (1) of Frances A. Pimentel on Draft Regulatory Guides: Design-Basis Floods for Nuclear Power Plants and Guidance for Assessment of Flooding Hazards Due to Water Control Structure Failures and Incidents ML24173A0042024-06-14014 June 2024 Comment (1) of Individual on Draft NUREG: Event Report Guidelines ML24173A0052024-06-14014 June 2024 Comment (2) of Tony Brown on Behalf of Nuclear Energy Institute (NEI) on Draft NUREG: Event Report Guidelines ML24114A0252024-04-0808 April 2024 Comment (4) of Charlotte Shields on DG-5080 Uas Question ML24093A0392024-03-28028 March 2024 Comment (1) of Thomas Basso on Preparing Probabilistic Fracture Mechanics Submittals ML24081A0872024-03-14014 March 2024 Comment of Janet R. Schlueter on Behalf of NEI on Information Collection: Material Control and Accounting of Special Nuclear Material ML24058A0052024-02-23023 February 2024 Comment (5) of Tony Brown on Behalf of Nuclear Energy Institute (NEI) on Notice of Intent to Conduct Scoping Process and Prepare Environmental Impact Statement; Pacific Gas and Electric Company; Diablo Canyon Nuclear Power Plant, Units 1 an ML24009A0372023-12-13013 December 2023 Comment (2) of Bruce Montgomery on Draft DUWP-ISG-02, Radiological Survey and Dose Modeling of the Subsurface to Support License Termination ML23353A2442023-12-13013 December 2023 Comment (2) of Bruce Montgomery on Interim Staff Guidance on Subsurface Investigations, Radiological Survey and Dose Modeling of the Subsurface to Support License Termination ML23348A0732023-12-11011 December 2023 Comment (2) of Charlotte Shields on Behalf of Nuclear Energy Institute on Draft Regulatory Guide: Physical Security Event Notifications, Reports, and Records ML23348A0772023-12-11011 December 2023 Comment (1) of Charlotte Shields on Behalf of Nuclear Energy Institute on Draft Regulatory Guide: Preemption Authority, Enhanced Weapons Authority, and Firearms Background Checks ML23349A0442023-12-11011 December 2023 Comment (1) of Charlotte Shields on Draft Regulatory Guide: Suspicious Activity Reports ML23326A1172023-11-21021 November 2023 Comment (1) of Alan Campbell on Proposed Revision to Standard Review Plan Branch Technical Position 7-19, Guidance for Evaluation of Defense-In-Depth and Diversity to Address Common-Cause Failure Due to Latent Design Defects in Digital Safe ML23326A0312023-11-17017 November 2023 Comment (2) of Kati R. Austgen on Draft Regulatory Guide: General Site Suitability Criteria for Nuclear Power Stations ML23284A3892023-10-10010 October 2023 Comment (8) of Ben Holtzman on Guidance for a Technology-Inclusive Content of Application Methodology to Inform the Licensing Basis and Content of Applications for Licenses, Certifications, and Approvals for Advanced Reactors ML23270B9552023-09-27027 September 2023 Comment (2) of Stewart Yuen on Proposed Revision to Standard Review Plan Section 15.0, Introduction - Transient and Accident Analyses ML23242A0412023-08-25025 August 2023 Comment (2) of Brett Titus on Behalf of NEI on Draft NUREG: Revision to Subsequent License Renewal Guidance Documents, and Supplement to Associated Technical Bases Document ML23236A5292023-08-21021 August 2023 Comment (6) of Bruce S. Montgomery on Draft Interim Staff Guidance: Use of the Decommissioning Trust Fund During Operations for Major Radioactive Component Disposal ML23256A1122023-08-10010 August 2023 Comment (3) of Ben Holtzman on Review of Risk-Informed, Technology Inclusive Advanced Reactor Applications - Roadmap ML23256A1132023-08-10010 August 2023 Comment (4) of Ben Holtzman on Review of Risk-Informed, Technology Inclusive Advanced Reactor Applications - Roadmap ML23256A1152023-08-10010 August 2023 Comment (2) of Ben Holtzman on Review of Risk-Informed, Technology Inclusive Advanced Reactor Applications - Roadmap ML23256A1162023-08-10010 August 2023 Comment (1) of Ben Holtzman on Review of Risk-Informed, Technology Inclusive Advanced Reactor Applications - Roadmap ML23256A1192023-08-10010 August 2023 Comment (4) of Ben Holtzman on Review of Risk-Informed, Technology Inclusive Advanced Reactor Applications - Roadmap ML23256A1202023-08-10010 August 2023 Comment (2) of Ben Holtzman on Behalf of Nuclear Energy Institute on Draft Interim Staff Guidance: Review of Risk-Informed, Technology Inclusive Advanced Reactor Applications-Roadmap ML23256A1222023-08-10010 August 2023 Comment (5) of Ben Holtzman on Review of Risk-Informed, Technology Inclusive Advanced Reactor Applications - Roadmap ML23256A1232023-08-10010 August 2023 Comment (4) of Ben Holtzman on Review of Risk-Informed, Technology Inclusive Advanced Reactor Applications - Roadmap ML23256A1252023-08-10010 August 2023 Comment (4) of Ben Holtzman on Behalf of Nuclear Energy Institute on Draft Interim Staff Guidance: Review of Risk-Informed, Technology Inclusive Advanced Reactor Applicationsroadmap ML23234A0392023-08-10010 August 2023 Comment (4) of Ben Holtzman on Review of Risk-Informed, Technology Inclusive Advanced Reactor Applications - Roadmap ML23181A0292023-06-29029 June 2023 Comment (2) of Rod Mccullum on Draft Regulatory Guide: Weather-Related Administrative Controls at Independent Spent Fuel Storage Installations ML23174A0492023-06-16016 June 2023 Comment (2) of Ben Holtzman on Behalf of Nuclear Energy Institute on Draft Interim Staff Guidance: Review of Risk-Informed, Technology Inclusive Advanced Reactor Applicationsroadmap ML23158A2162023-06-0202 June 2023 Comment (2) of Alan Campbell on Draft Regulatory Guide: Guidelines for Lightning Protection for Production and Utilization Facilities ML23159A2472023-05-22022 May 2023 Comment (4) of William Gross on Perimeter Intrusion Alarm Systems ML23143A1982023-05-18018 May 2023 Comment (1) of Richard Mogavero on Behalf of Nuclear Energy Institute on Draft Regulatory Guide: Cybersecurity Event Notifications ML23130A2082023-05-0808 May 2023 Comment (9) of Mark A. Richter on Behalf of Nuclear Energy Institute on Material Compatibility for Non-Light Water Reactors ML23115A0152023-04-0707 April 2023 Comment (1) of Alan Campbell on Draft Regulatory Guide: Criteria for Programmable Digital Devices in Safety-Related Systems of Nuclear Power Plants ML24120A2702023-04-0404 April 2023 Melody Rodridguez NEI Comment on Controlled Unclassified Information ML23089A0012023-03-28028 March 2023 OMB 3150-0035, NEI Comment on 10 CFR Part 21 Information Collection Renewal 2023 ML23094A0632023-03-28028 March 2023 NRC-2022-0145- NEI Official Comment Attachment on 10 CFR Part 21 Information Collection Renewal ML23115A0172023-03-23023 March 2023 Comment (3) of Alan Campbell on Draft Regulatory Guide: Criteria for Programmable Digital Devices in Safety-Related Systems of Nuclear Power Plants ML23074A0472023-03-14014 March 2023 Comment (2) of A. J. Clore on Perimeter Intrusion Alarm Systems ML22354A2422022-12-19019 December 2022 Comment (4) of Thomas Basso on Behalf of Nuclear Energy Institute on Performance-Based Containment Leak Test Program ML23005A2412022-12-16016 December 2022 Comment (1) of Janet R. Schlueter on Report on Waste Burial Charges: Changes in Decommissioning Waste Disposal Costs at Low-Level Waste Burial Facilities ML22244A1732022-08-31031 August 2022 Comment (1) of Tony Brown on Behalf of Nuclear Energy Institute on Industry Comments on Draft Appendices to NUREG/BR-0058, Revision 5, Regulatory Analysis Guidelines of the U.S. Nuclear Regulatory Commission ML22242A0302022-08-29029 August 2022 Comment (1) of Victoria K. Anderson on High Energy Arcing Fault Hazard Frequency and Consequence Modeling ML22231B0532022-08-19019 August 2022 Comment (6) of James E. Slider on Nrc'S Fiscal Years 2023-2027 Artificial Intelligence Strategic Plan ML22230A0402022-08-15015 August 2022 Comment (4) of William R. Gross on Behalf of NEI on Update of Facility Security Clearance ML22224A1942022-08-12012 August 2022 Comment (1) of William R. Gross on Behalf of Nuclear Energy Institute on Personnel Access Authorization Requirements for Non-Immigrant Foreign Nationals Working at Nuclear Power Plants 2024-09-17
[Table view] |
Text
3/16/2021 blob:https://www.fdms.gov/f6ab1abb-9d5c-4407-a8cf-7865142c88f8 SUNI Review Complete Template=ADM-013 As of: 3/16/21 7:39 AM E-RIDS=ADM-03 Received: March 01, 2021 PUBLIC SUBMISSION ADD: Kevin Quilan, Luissette Candelario, Status: Pending_Post Tracking No. klq-z0e6-mprm Mike Lee, Mary Neely Comment (2)
Comments Due: March 01, 2021 Publication Date: Submission Type: Web 12/29/2020 Citation: 86 FR 85683 Docket: NRC-2020-0237 Considerations for Estimating Site-Specific Probable Maximum Precipitation at Nu-clear Power Plants in the United States of America Comment On: NRC-2020-0237-0001 Considerations for Estimating Site-Specific Probable Maximum Precipitation at Nuclear Power Plants in the United States of America Document: NRC-2020-0237-DRAFT-0003 Comment on FR Doc # 2020-28708 Submitter Information Email: fap@nei.org Organization: Nuclear Energy Institute General Comment NEI Comments on Draft NUREG/KM- 0015, Considerations for Estimating Site-Specific Probable Maximum Precipitation at Nuclear Power Plants in the United States of America, 85 FRN 85683-85685; Docket ID NRC-2020-0237 Attachments 03-01-21_Letter to NRC with Industry Comments on Draft NUREG KM-0015 with Attachment blob:https://www.fdms.gov/f6ab1abb-9d5c-4407-a8cf-7865142c88f8 1/1
FRANCES PIMENTEL Senior Project Manager, Risk and Technical Support 1201 F Street, NW, Suite 1100 Washington, DC 20004 NUCLEAR ENERGY INSTITUTE P: 202.739.8132 fap@nei.org nei.org March 1, 2021 Office of Administration Mail Stop: TWFN-7-A60M U.S. Nuclear Regulatory Commission Washington, DC 20555-0001 ATTN: Program Management, Announcements and Editing Staff Project Number: 689
Subject:
NEI Comments on Draft NUREG/KM- 0015, Considerations for Estimating Site-Specific Probable Maximum Precipitation at Nuclear Power Plants in the United States of America, 85 FRN 85683-85685; Docket ID NRC-2020-0237.
Subm itted via regulations.gov
Dear Program Management,
Announcements and Editing Staff, The Nuclear Energy Institute (NEI) 1, on behalf of our members, appreciates the opportunity to provide comments on the subject Draft NUREG/KM- 0015, Considerations for Estimating Site-Specific Probable Maximum Precipitation at Nuclear Power Plants in the United States of America. We are supportive of the staffs efforts to maintain and preserve knowledge concerning the lessons-learned from the recent flood hazard re-evaluations at current and planned nuclear power plant sites performed most recently in connection with the staff 2012 §50.54(f) reviews in the creation of this document.
In our review, we noted that this draft NUREG/KM summarizes the knowledge the NRC staff has developed over the course of the reviews based on the similarities and differences between methodologies pertaining to site-specific probable maximum precipitation (SSPMP) calculated at U.S. nuclear power plants. The attachment includes several recommendations to enhance the document and improve clarity for your use in finalizing this regulatory guide.
We appreciate the NRCs effort in developing this draft guidance and encourage your consideration of all stakeholder comments prior to finalizing this draft NUREG. We trust that you will find these comments useful 1
The Nuclear Energy Institute (NEI) is responsible for establishing unified policy on behalf of its members relating to matters affecting the nuclear energy industry, including the regulatory aspects of generic operational and technical issues. NEIs members include entities licensed to operate commercial nuclear power plants in the United States, nuclear plant designers, major architect and engineering firms, fuel cycle facilities, nuclear materials licensees, and other organizations involved in the nuclear energy industry.
NUCLEAR. CLEAN AIR ENERGY
Program Management, Announcements and Editing Staff March 1, 2021 Page 2 and informative. Please contact me at fap@nei.org or (202) 739-8132 with any questions or comments about the content of this letter or the attached comments.
Sincerely, Frances A. Pimentel Attachment c: Kevin Quinlan, NRR/DEX/EXHB
Attachment 1 Comments on Draft NUREG/KM- 0015, Considerations for Estimating Site-Specific Probable Maximum Precipitation at Nuclear Power Plants in the United States of America.
Section Comment/Basis Recommendation TOC / Overall The document provides guidance on how to use existing Add a section on Gathering New Information.
information to estimate Site-Specific Probable Maximum Precipitation at NPPs in the US. In many places, it talks about
- 1. professional judgement, justification and documentation.
It would be useful to have a section on Gathering New Information to fill in gaps.
TOC / Overall The document is basically a Knowledge Summary of work that Add a section on Gathering New Information.
- 2. has been performed in the US. It would be useful to have a section if similar work has been performed in Europe.
TOC / Overall It would be useful to have a section on the most common gaps Add a section on the most common gaps seen in the 50.54(f)
- 3. seen in the 50.54(f) submittals. What were the most common submittals and the most common NRC Request for Additional NRC Requests for Additional Information? Information.
Section 1.1 This sections states, GDC 2 requires, []. GDC 2 also requires Change GDC 2 requires to GDC 2 states that in the two Background [.]. sentences as described in comment/basis.
- 4. Since GDC can only be described as requirements for post-GDC plants and under particular circumstances (see COM-SECY 0020) change this wording to be, GDC 2 states that.
Section Recommend that the NUREG provide discussion on the Provide discussion as described in comment/basis.
1.6/2.2 benefits/reasons of developing and utilizing site-specific PMP 5.
analyses in lieu of generalized event derivations from sources such as Hydrometeorological Reports (HMRs).
Section Comment/Basis Recommendation Section 9.1.1 additional wording Insert new paragraph:
In a submitted LAR, artificial isohyetal storm patterns, as discussed in HMR No. 52, were not used. PMP values from an NRC-approved TP, adjusted to account for topographic influences, was generated for each grid point on a gridded network covering the entire drainage basin for given storm areas and durations. The gridded
- 6. PMP approach produces a default spatial pattern that closely follows NOAA Atlas 14 precipitation frequency patterns following the approach in HMRs 55A, 57 and 59. Since the total drainage basin consisted of numerous sub-basins and dams, a large number of spatial distributions over sub-basins and combinations of sub-basins were evaluated in the hydraulic modeling to maximize volume over various portions of the watershed to test for dam failures and to maximize stream-flow and flooding levels at plant sites.
Section 9.2 Recommend providing examples of any concerns/challenges that Provide examples as described in comment/basis.
were encountered during review of licensee site-specific PMP
- 7. estimates. Specifically, any analytical techniques or inputs that resulted in licensees revising and resubmitting site-specific PMP calculations.
Section 9.2 Additional wording After the words, historical rainfall events or different isohyetal
- 8. patterns recommend adding the words or gridded sub-basin combinations 11.1 Recommend including a discussion on how site-specific PMP Provide discussion as described in comment/basis.
Paragraph 2 estimates relate to the current licensee guidance documents.
The currently approved revision of Regulatory Guide 1.59
- 9. significantly pre-dates many of the scientific advancements, research and source documents that have made site-specific estimations a viable meteorological option.