Part A- Comments - Continued

DOE-STD-1024-92

We understand that the Interim Position will be superseded by a final position

developed jointly by DOE, the NRC, and EPRI in about 18 to 24 months. It

should be clearly noted both in the Interim Position and in the final position that

DOE sites that are to be licensed by the NRC (e.g., the Monitored Retrievable

Storage facility) will have to follow NRC guidelines and are exempt from the

DOE Interim Position and final position to avoid duplicative requirements and/or

conflicting results. Statements to this effect are provided in the Memorandum of

Agreement between NS and RW, the DOE proposed rule 10 CFR Part 830,

"Nuclear Safety Management", and the draft DOE Order 5480.NPH on Natural

Phenomena Hazards."

Pursuant to your request, we have provided technical comments and alternative

approaches.

RW-2

The use of low frequency ground motion is essential for this procedure, yet it is

for low frequencies that the assumptions used by Dr. Cornell break down (P. 5,

Para. 1 of his attachment). A critical review might ask why low frequencies are

neglected in one procedure and required for another.

RW-3

Earlier discussions indicated that the median curve was the preferred choice, but

here the mean is chosen. Some clarification may be necessary.

How is "doubt" determined about the estimate being realistic? Can there be

quantitative criteria?

"pseudo-mean" (here and elsewhere in the paper) is too ambiguous as a term

and implies falseness. "Adjusted mean" would still be ambiguous but may be a

better term.

RW-4

The statement is made that the method of analysis can change if major

engineering upgrades are necessary. That would seem to leave the guidelines

or the strength of their underlying rationale open to critical questioning.

RW-5

The statement is made that some very low hazard sites do not fit the analysis,

and reasons for this inconsistency are discussed in the main paper. Yet it is

disconcerting that the basis of the analysis does not work for very low hazards.

The inconsistency raises doubts about the applicability of the method for sites

with higher risk. I think that these doubts could be reduced if it were shown that

the method still works satisfactorily for these very low risk sites by including

several in Tables 2 and 3 and adding discussion about why it still works.

A-19