Part A- Comments - Continued

DOE-STD-1024-92

use? If a comparison is not required, how will these computed numbers be

defended to the Defense Nuclear Facilities Safety Board, for example? It

appears from the background information presented in the Interim Document

that there are problems with the geo-seismological input and treatment of the

uncertainties. Having this knowledge, how can numerical manipulations of

the LLNL and EPRI curves provide a solid technical basis for seismic design

values?

INEL-2

What is the approach to implementing this interim guidance (backfit,

implement at Operational Readiness Review stage, in construction, or in

current/future design)?

INEL-3

How does one plan for the final guidance two years from now, what does

"interim guidance" specifically mean for actions, what selection criteria will be

used, and how will the criteria apply to specific projects?

INEL-4

This document does not address which plants this should be applied to, how

soon it should be implemented, and how often it should be reviewed. Priori-

ties on which facilities should be addressed first and which category of risk

are not addressed. Draft DOE Order 5480.NPH is equally confusing in this

respect and also includes deterministic seismic input as well. It points out

that one should not do anything hasty when rules change because another

change will be following soon.

INEL-5

The SWG has requested that Sandia National Laboratory prepare a

"Program Plan for Evaluation of EPRI and LLNL Seismic Hazard

Methodologies and Development of Recommendations for a Consensus

Probabilistic Seismic Hazard Methodology for the 1990s." We strongly

suggest that the recommendations for the probabilistic seismic hazard

methodology in this document take into consideration the past experiences of

the LLNL and EPRI studies, the studies that are currently being done at

Idaho National Engineering Laboratory and other DOE sites, and how

seismic hazards assessments have been and are being performed by

independent subcontractors (outside of DOE) for the U.S. Nuclear Regulatory

Commission (NRC). The resulting document that instructs DOE sites on how

to perform the seismic-hazard methodology should be peer-reviewed by a

Senior External Event Review Group-type panel, independent of DOE. Also,

the documents should be reviewed by the DOE sites as they are being

developed. Sandia National Laboratories should not prepare a Program Plan

or Probabilistic Seismic Hazard Methodology without having a participant or

representative from each DOE site and comments from all those who will

have to use and abide by it.

A-10