Part A- Comments - Continued

DOE-STD-1024-92

It is interesting to note that when the interim position is applied to Rocky Flats,

the High Hazard Zero Period Acceleration (ZPA) would apparently decrease

from .219 to .169. This deviation in ZPA levels adds to the need for the planned

new site specific seismicity study.

RF-2

As requested, the Systematic Evaluation Program (SEP) has briefly reviewed

DOE's interim position with respect to LLNL and EPRI seismic hazard curves.

Without detailed review of predecessor documents, SEP has no significant

technical comments. The proposed interim methodology appears to adequately

.account for differences/uncertainties between the LLNL and EPRI approaches.

Systematic Evaluation Program agrees with and strongly supports the

DOE/EPRI/NRC joint effort to resolve seismic hazard issues on a "permanent" or

better yet, a "renewable" basis.

In SEP's opinion, the following technical issues should be emphasized:

Attenuation relationships; and

Site soil amplification/deamplification

These issues have the potential and disproportionately large uncertainties both

on a regional basis and in site-specific applications.

AL - I

Page 4, Paragraph 3, Last Sentence - This sentence is misstated. University of

California Research Laboratory (UCRL-15910) provides two different

probabilities, either of which may be used, the performance and exceedance

goal probabilities. The sentence should be rewritten to read: "UCRL-15910

allows the use of either performance goal probability or hazard exceedance

probability dependent on the design/analysis technique used."

Attached is a copy of a memorandum (J. Schinkle to Albuquerque Field Office

(AL) Area Managers) explaining the use of these two probabilities.

The DOE General Design Criteria Manual (DOE Order 6430.1A) requires the

consideration of natural phenomena hazards in the design of all new DOE

facilities and a comparison of criteria noncompliances for all existing facilities as

their Safety Analysis Reports (SARs) are updated. Department of Energy Order

6430.IA requires the use of the UCRL document, "Design and Evaluation

Guidelines for DOE Facilities Subjected to Natural Phenomena Hazards, UCRL-

15910, June 1990," for these design considerations.

During the January 1992 DOE Natural Phenomena Hazards Workshop, the

document's authors reported that a general misinterpretation in the application of

UCRL-15910 has been occurring. We are bringing to your attention this

A-12