ML16061A124

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Mitigation Beyond-Design-Basis Events Proposed Rule Comment (16) - Stein (Annotated) Original Submission Dated Fedruary 11, 2016 (ML16043A117)
ML16061A124
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: ML16061A124 (2)


Text

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