Part A- Comments

DOE-STD-1024-92

Appendix A

COMMENT - RESOLUTION DOCUMENT

Development of a DOE Wide Position Regarding the Use

of LLNL and EPRI Probabilistic Seismic

Hazard Curves

PART A - COMMENTS

Provided below is the set of comments received from Department of Energy (DOE)

organizations who reviewed the Draft Interim Position Regarding the use of

Lawrence Livermore National Laboratory (LLNL) and Electric Power Research

Institute (EPRI) Seismic Hazard Curves dated March 19, 1992. The comments

have been organized using the originating organizations abbreviations. Minor

editing of comments has been completed removing reference to attachments that

would unnecessarily clutter this document. The consolidated comments are

followed by a response document which cross-references the comments.

NS-1

As requested, this memorandum provides the Office of Nuclear Safety's (NS)

comments on the DOE Seismic Working Group's (SWG) draft report and interim

position on the use of seismic hazard curves. The draft report gives insights

and recommendations that go beyond the guidance currently provided by

UCRL-15910 for establishing earthquakes for the design and review of DOE

facilities. The draft interim position gives innovative and workable criteria for

using hazard curves developed from the LLNL and the EPRI methodologies.

The SWG intended that LLNL and EPRI seismic hazard curves be used as

state-of-the-art replacements for the older TERA, Inc. seismic hazard curves,

which are the basis for the recommended earthquake levels in Table 4-4 of

UCRL-15910.

Office of Nuclear Safety believes that the draft interim position's general

approach for selecting review earthquakes is a rational and practical way to use

the LLNL and EPRI hazard curves However, there are newly-discovered

technical issues within the draft interim position, and with its use with UCRL-

15910, that must be resolved prior to its endorsement by DOE. These issues

should be resolved in close coordination with the Office of Environmental

Restoration and Waste Managements (EM) development of seismic guidelines

for high level waste storage tanks, and the Office of Nuclear Safety Policy and

Standards (NE-70's) development of natural phenomena review guidelines (the

latter are intended to improve and codify the guidance of UCRL-15910).

Because of the use of performance goals by these guidelines and the resulting

interrelationship between earthquake selection and structural evaluation

criteria, we recommend that the completion of a final version of the SWG's

interim position be carefully integrated with EM and NE-70's new structural

evaluation criteria.

A-1