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Category:Rulemaking-Comment
MONTHYEARML16068A2482019-07-30030 July 2019 Mitigation Beyond-Design-Basis Events Proposed Rule Comment (18) - NuScale Power (Annotated) Original Submission Dated February 11, 2016 (ML16048A103) ML16068A2402019-07-30030 July 2019 Mitigation of Beyond-Design-Basis Events Proposed Rule Comment (3) - Keating (Annotated) Original Comment Submission Dated November 21, 2015 (ML15328A494) ML16067A1042019-07-30030 July 2019 Mitigation Beyond-Design-Basis Events Proposed Rule Comment (11) - Union of Concerned Scientists (Annotated) Original Submission Dated February 11, 2016 (ML16042A095) ML16067A1002019-07-30030 July 2019 Mitigation Beyond-Design-Basis Events Proposed Rule Comment (12) - South Carolina Electric and Gas (Annotated) Original Submission Dated February 10, 2016 (ML16042A565) ML16067A0942019-07-30030 July 2019 Mitigation Beyond-Design-Basis Events Proposed Rule Comment (13) - First Energy Nuclear Operating Company (Annotated) Original Submission Dated February 11, 2016 (ML16042A597) ML16061A1402019-07-30030 July 2019 Mitigation Beyond-Design-Basis Events Proposed Rule Comment (15) - Lutz Safety Consultant (Annotated) Original Submission Dated February 11, 2016 (ML16043A113) ML16061A1242019-07-30030 July 2019 Mitigation Beyond-Design-Basis Events Proposed Rule Comment (16) - Stein (Annotated) Original Submission Dated Fedruary 11, 2016 (ML16043A117) ML16061A1202019-07-30030 July 2019 Mitigation Beyond-Design-Basis Events Proposed Rule Comment (17) - Foundation for Resilient Societies (Annotated) Original Submission Dated February 11, 2016 (ML16043A116) ML16061A1132019-07-30030 July 2019 Mitigation Beyond-Design-Basis Events Proposed Rule Comment (19) - Exelon Generation Co, LLC (Annotated) Original Submission Dated February 10, 2016 (ML16056A568) ML0534803992005-12-0909 December 2005 Email from David Desaulniers Responding to Doug Beck Email Comments Re Proposed PR-26, Regarding Fitness for Duty Programs ML23152A1411998-09-23023 September 1998 PR-050 and 140 - 63FR50815 - Financial Protection Requirements for Permanently Shutdown Nuclear Power Reactors ML23156A3651991-09-0303 September 1991 PR-15 - 56FR43624 - Privacy Act of 1974; Establishment of a New System of Records 2019-07-30
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Page 1 of 1 PR 10 CFR Parts 50 and 52 80FR70609 16 As of: 2/12/16 9:01 AM Received: February 11, 2016 Status: Pending_Post PUBLIC SUBMISSION Tracking No. 1k0-8nwr-sk47 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-0021 Comment on FR Doc # 2015-28589 Submitter Information Name: Richard Stein General Comment
- 1. [The proposed rule and guidance for mitigation strategies hazard protection appear to establish inconsistent levels of protection for various hazards. The guidance discusses protection from high winds to the 1 million year event, and lower levels of protection from flooding and seismic events allowing some plants to provide marginal performance for a 10,000 year event. The rule and guidance allows for the design of mitigation strategies that provides minimal to no protection for events even slightly greater than a 10,000 year event. A common performance goals for mitigation strategies should be established to ensure plants can cope with a 100,000 year hazard events to complement the existing design basis framework for nuclear safety. Mitigation strategies should be more robust than existing safety equipment not less to provide effective defense-in-depth.
Stein-1]
- 2. [The proposed rule and guidance should include formal treatment of uncertainties associated with the reevaluated hazards. Consideration of uncertainties would inform the mitigation strategies to ensure they provide equal and creditable protection for nuclear plants. Stein-2]
https://www.fdms.gov/fdms/getcontent?objectId=0900006481e676c6&format=xml&showorig=false 02/12/2016