Comment (2) of Doug True on FR Doc # 2011-33471

This document is premature and should be withdrawn. A more appropriate course would be for the appropriate Standards Development Organization, in this case the ASME/ANS Joint Committee on Nuclear Risk Management, to first define the requirements that would be part of a draft Standard for low power and shutdown fire PRA, then develop the guidelines to meet those requirements, then pilot those guidelines in an approriate number of pilots to effectively exercise the technical methods outlined in guidelines and requirements, then revise the draft Standard and guidelines BEFORE issuance of the final guideline document. Failure to follow such a process will lead to the same problems that were introduced when the NRC issued NUREG/CR-6850 prior to (a) a Standard being developed, (b) appropriate piloting, and (c) incorporation of the lessons learned from pilots.