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DOE-STD-1024-92
But what other seismic zones would qualify as being 'seismogenically active.' It
appears that the intent is to exclude those sites that lie near anomalously
active zones, but the discussion is unclear. If, in fact, those DOE sites that are
believed by the SWG to lie near active sources can be explicitly identified in
the document, the issue would not be left to the discretion of the sites to
identify themselves.
Assuming that one determines that his site lies within 50 km of an active
seismogenic source, what happens then? No guidance is given.
LLNL-15
It is not clear to us which sites have both LLNL and EPRI results and which
sites only have one or the other. Is there a published list of these? Has
seismic hazard actually been calculated at specific DOE sites, or at
commercial nuclear power plants nearby? Clarification is needed.
LLNL-16
It is likely that the assessment of low frequency ground motion hazard based
on a mixture of direct spectral ordinate attenuation relationships with average
spectral shapes anchored to PGA attenuation relationships is leading to the
large variability observed. These differences will be exaggerated at sites
where the dominant magnitude is significantly smaller than that associated with
the average spectral shapes. The effect is also increased by the difference in
frequency content of EUS ground motions represented by some of the more
recently developed attenuation relationships compared to spectral shapes
based on Western United States (WUS) recordings.
LLNL-17
It might be useful to comment on an alternative approach of establishing
"pseudomeans" for each study and then averaging these rather than
averaging the standard errors. I do not think that the results are equivalent,
though they may be close for the average case considered here. Averaging
"pseudo-means" will carry a little more site specific information than
averaging the medians, unless global average ratios of the 85th-
percentile/median are to be used always.
INEL-1
The Interim Position gives guidance on how to determine peak ground
accelerations and spectra based on using numerical adjustments to reconcile
the discrepancies in the LLNL and EPRI curves. While this may be
mathematically and statistically correct, we question how well these
computational results reflect the geological and seismological "real world'
data at a particular site. The intent is that this practice will provide enough
conservatism. However, what type of comparisons have and will be made on
these results with what is known at a particular site? Should the guidance
require a comparison to the geological conditions at the site for its intended
A-9


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