ML20140F517
| ML20140F517 | |
| Person / Time | |
|---|---|
| Issue date: | 08/18/1992 |
| From: | Beckjord E NRC OFFICE OF NUCLEAR REGULATORY RESEARCH (RES) |
| To: | Colvin J NUCLEAR ENERGY INSTITUTE (FORMERLY NUCLEAR MGMT & |
| Shared Package | |
| ML20007G200 | List: |
| References | |
| FRN-57FR47802, RULE-PR-100, RULE-PR-50, RULE-PR-52 AD93-1-026, AD93-1-26, NUDOCS 9705050036 | |
| Download: ML20140F517 (5) | |
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o UNITED STATES l
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NUCLEAR REGULATORY COMMISSION g
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AUG 181992
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Mr. Joseph Colvin President & Chief Exet'tive Officer Nuclear Management and Resources Council 1776 Eye Street, N.W., Suite 300 Washington, D.C. 20006-3706
Dear Mr. Colvin:
I am responding to Mr. Lee's letter dated June 22, 1992, to Chairman Selin which expressed an industry concern that the proposed Appendix B to 10 CFR Part 100 is too prescriptive.
It also forwarded your request that the changes recomended in the May 8,1992 letter from Mr. William H. Rasin be considered 1
for incorporation in the proposed Appendix B prior to its release for public comment. At issue is the specific phrase in Appendix B that "both determinis-tic and probabilistic evaluations must be conducted to determine site suit-ability and seismic design requirements for the site." The question is whether this is necessary or appropriate, and we think it is best to raise the issue, directly and specifically for public coment.
In the way we are l
proposing we can be assured of receiving coments, both pro and con, on our l
proposed evaluation approach.
I also want to reemphasize a statement in my earlier letter to Mr. Rasin that your comments and other comments received during the public comment period will receive serious consideration during the development of the final regulation and supporting regulatory guides.
When final regulations are submitted to review committees (i.e., ACRS and CRGR) and the Commissioners for their approval, the staff will provide a summary of the public comments and the staff's recommended resolution.
By this means, the review committees and the Commissioners are aware of the public concerns, and in this case, will be j
able to independently review the issue, the public comments received, and the l
proposed resolution.
I want to acknowledge the interest of NUMARC and industry in this important rulemaking effort as reflected in several public meetings.
t l
l Sincerely, i
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- O l
r of Nucle (ar Regulatory Research
'cEjor Director Er j
Of cc:
The Chairman Commissioner Rogers Commissioner Curtiss Commissioner Remick Commissioner de Planque James M. Taylor, EDO SECY OGC 97050500 5 ~
22 PDR Pn 50 57FR47802 sR
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I Mr. Joseph Colvin AUG 181992 President & Chief Executive Officer Nuclear Management and Resources Council 1776 Eye Street, N.W., Suite 300 Washington, D.C. 20006-3706
Dear Mr. Colvin:
l I am responding to Mr. Lee's letter dated June 22, 1992, to Chairman Selin which expressed an industry concern that the proposed Appendix B to 10 CFR Part 100 is too prescriptive.
It also forwarded your request that the changes recommended in the May 8,1992 letter from Mr. William H. Rasin be considered for incorporation in the proposed Appendix B prior to its release for public comment. At issue is the specific phrase in Appendix B that "both determinis-tic and probabilistic evaluations must be conducted to determine site suit-ability and seismic design requirements for the site." The question is whether this is necessary or appropriate, and we think it is best to raise the issue, directly and specifically for public comment.
In the way we are proposing we can be assured of receiving comments, both pro and con, on our proposed evaluation approach.
I also want to reemphasize a statement in my earlier letter to Mr. Rasin that j
your comments and other comments received during the public comment period i
will receive serious consideration during the development of the final regulation and supporting regulatory guides. When final regulations are submitted to review committees (i.e., ACRS and CRGR) and the Commissioners for their approval, the staff will provide a summary of the public comments and the staff's recommended resolution.
By this means, the review committees and the Commissioners are aware of the public concerns, and in this case, will be able to independently review the issue, the public comments received, and the l
proposed resolution.
I want to acknowledge the interest of NUMARC and industry in this important rulemaking effort as reflected in several public meetings.
Sincerely, Original Slgned By:
C. J. Heltemes,Jr.
Eric S. Beckjord, Director J Office of Nuclear Regulatory Research l
cc:
The Chairman Commissioner Rogers Commissioner Curtiss l
Commissioner Remick Commissioner de Planque i
James M. Taylor, ED0 l
SECY l
OGC DISTRIBUTION: RESReading RKenneally NChokshi AMurphy RBosnak LShao 4
TSpeis EBeckjord
- See previous concurdrences SSEB/DE/RES* SSEB/DE/RES* SSEB/DE/RES* DD:DE/RES* D:DE/RES* DD:RES RXenneally:fkm NChokshi AMurphy R80snak LShao TSpeis EB rd 8/05/92 8/05/92 8/05/92 8/12/92 8/12/92 8/ 92 8//g/92 l
Mr. Joseph Colvin President & Chief Executive Officer Nuclear Management and Resources Council 1776 Eye Street, N.W., Suite 300 Washington, D.C. 20006-3706
Dear Mr. Colvin:
I I am respondin to Mr. Lee's letter dated June 22, 1992, to Chairman Selin which expressed 'n industry concern that the proposed Appendix B to 10 CFR Part 100 is too p scriptive.
recommended in the(May 8, 1992 letter from Mr. William H. Rasin be consideredIt also for incorporation in'the proposed Appendix B prior to its release for public comment. At issue is th tic and probabilistic ev,e specific phrase in Appendix B that "both determinis-aluations must be conducted to determine site suit-ability and seismic design. requirements for the site." The question is whether this is necessary or appropriate, and we think it is best to raise the s
issue, directly and specifically for public comment.
In the way we are proposing we can be assured of receiving comments, both pro and con, on our proposed evaluation approach.
I also want to reemphasize a statement in my earlier letter to Mr. Rasin that your comments and other comments received during the public comment period will recebe sericus consideration during the development of the final regulation and supporting regulatory huides. When final regulations are submitted to review committees (i.e., ACRS and CRGR) and the Commissioners for their approval, the staff will provide a' summary of the public comments and the staff's recommended resolution. By this means, the review committees and the Commissioners are aware of the public concerns, and in this case, will be able to independently review the issue, the public comments received, and the proposed.
I want to acknowledge the interest of NUMARC and industry in this important rulemaking effort as reflected in several public meetings.
Sincerely, Eric S. Beckjord, Director Office of Nuclear Regulatory Research
\\
h cc:
The Chairman Commissioner Rogers s
Commissioner Curtiss
(
Commissioner Remick Commissioner de Planque
'k James M. Taylor, ED0 SECY l
OGC DISTRIBUTION:
RESReading RXenneally NChokshi AMurphy RBosnak LShao TSpeis EBeckjord
- See previous concurdrences d
SSEB/DE/RES* SSEB/DE/RES* SSEB/DE/RES* DD:DE/RES* D:DE/RES* DD: ES D:RES RKenneally:fkm NChokshi AMurphy RBosnak LShao TSpeis EBeckjord 8/05/92 8/05/92 8/05/92 8/12/92 8/12/92 8/ 92 8/ /92
Mr. Joseph Colvin l
President & Chief Executive Officer Nuclear Management and Resources Council l
1776 Eye Street, N.W., Suite 300 Washington, D.C. 20006-3706
Dear Mr. Colvin:
I am responding to your letter dated June 22, 1992, to Chairman Selin which expressed an industry concern that the proposed Appendix B to 10 CFR Part 100 is too prescriptive.
It also forwarded your request that the changes recom-mended in the May 8,1992 letter from Mr. William H. Rasin be considered for incorporation in the proposed Appendix B prior to its release for public comment. At issue is the specific phrase in Appendix B that "both determinis-tic and probabilistic evaluations must be conducted to determine site suit-ability and seismic design requirements for the site." We believe that it is preferable in the public comment version to employ specific wording which states that probabilistic and deterministic evaluations are required rather than to be noncommittal as you have requested. Only in the way we are proposing can we be assured of receiving comments, both pro and con, on our proposed evaluation methodology.
I want to assure you that the Commission has had the benefit of your views and prior to reaching its decision to publish, careful consideration will be given to your concerns.
I also want to reemphasize a statement in my earlier letter i
to Mr. Rasin that your comments and other comments received during the public comment period will receive serious consideration during the development of the final regulation and supporting regulatory guides. When final regulations are submitted to review committees (i.e., ACRS and CRGR) and the Commissioners for their approval the staff is reqrired to provide a summary of the public comments and the staff's recommended resolution. Thereby, the review commit-tees and the Commissioners are aware of the public concerns.
I want to acknowledge the interest of NUMARC and industry in this important rulemaking effort as reflected in several public meetings.
Sincerely, Eric S. Beckjord, Director Office of Nuclear Regulatory Research cc:
The Chairman Commissioner Rogers Commissioner Curtiss Commissioner Remick Commissioner de Planque James M. Taylor, ED0 SECY l
OGC DISTRIBUTION:
RESReading RKenneally NChokshi AMurphy RBosnak LShao TSpeis EBeckjord
- See previous concurrence MpA SSEB/DE/RES* SSEB/DE/RES* SSEB/DE/RES* D E/RES (T:(IE/RES DD:RES D:RES RKenneally:fkm NChokshi AMurphy RBosnak LShao TSpeis EBeckjord 8/ /92 8/ /92 8/ /92 8//h92 8//P/92 8/ 92 8/ /92
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L-1 l
,1 Mr. Byron Lee, Jr.
i President & Chief Executive Officer Nuclear Management and Resources Council 1776 Eye Street, N.W., Suite 300 Washington, D.C. 20006-3706 i
Dear Mr. Lee:
l I am responding to your letter dated June 22, 1992, to Chairman Selin which l
expressed an industry concern that the proposed Appendix B to 10 CFR Part 100 l
is too prescriptive.
It also forwarded your request that the changes recom-mended in the May 8, 1992 letter from Mr. William H. Rasin be considered for incorporation in the proposed Appendix B prior to its release for public comment. At issue is the specific phrase in Appendix B that "both determinis-l tic and probabilistic evaluations must be conducted to determine site suit-l ability and seismic design requirements for the site."
l I want to assure you that the Commission has had the benefit of your views and prior to reaching its decision to publish, careful consideration will be given to your concerns.
I also want to reemphasize a statement in my earlier letter l
to Mr. Rasin that your comments and other comments received during the public comment period will receive serious consideration during the development of i
the final regulation and supporting regulatory guides. When final regulations are submitted to review committies (i.e., ACRS and CRGR) and the Commissioners
'for their approval the staff is required to provide a summary of the public comments and the staff's recommended resolution.
Thereby, the review commit-tees and the Commissioners are aware of the public concerns.
I want to acknowledge the interest of NUMARC and industry in this important rulemaking effort as reflected in several public meetings.
Sincerely, Eric S. Beckjord,' Director Office of Nuclear Regulatory Research j
cc:
The Chairman l
Commissioner Rogers Commissioner Curtiss Commissioner Remik Commissioner de Planque James M. Taylor, ED0 SECY OGC DISTRIBUTION:
RESReading RKenneally NChokshi AMurphy RBosnak-LShao l
TSpeis EBeckjord l
SSEB/DE/RES SSEB/DE/RES SSEB/DE/RES DD:DE/RES D:DE/RES DD:RES D:RES R
ally:fkm i
AMurph RBosnak LShao TSpeis EBeckjord l
8/5 /92 8/ 5 /92 8/g 92 8/ /92 8/ /92 8/ 92 8/ /92 d
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UNITED STATES o
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'n NUCLEAR REGULATORY COMMISSION g.
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WASmGTON, D. C. 20555 a.....
SEP 3 15.2 MEMORANDUM FOR:
Lawrence C. Shao, Director Division of Engineering, RES FROM:
Andrew J. Murphy, Chief Structural & Seismic Engineering Branch Division of Engineering, RES
SUBJECT:
SUMMARY
OF PUBLIC MEETING ON THE REVISION OF APPENDIX A,
" SEISMIC AND GE0 LOGIC SITING CRITERIA FOR NUCLEAR POWER PLANTS," TO 10 CFR PART 100 On June 17, 1992, the NRC staff met with the staff of the Nuclear Management and Resources Council (NUMARC) and other industry representatives to discuss the proposed revision of Appendix A, " Seismic and Geologic Siting Criteria for Nuclear Power Plants," to 10 CFR Part 100. A public meeting notice appeared in the Federal Reaister on June 4,1992, Vol 57, page 23548. is a list of attendees.
The meeting, scheduled at the request of NUMARC staff, was a follow-up to a meeting held on April 23, 1992. On April 23, NUMARC staff and members of their Ad Hoc Advisory Committee on Appendix A Revision met with the staff to make sure they understood what the proposed regulations would require and the staff rational for the requirements. At this meeting (June 17) NUMARC staff and members of their Ad Hoc Advisory Committee on Appendix A Revision ex-pressed their concerns about the proposed regulations and offered suggested modifications.
The discussion focused on Proposed Apper '
B, " Criteria for the Seismic and Geologic Siting of Nuclear Power Plants After [ Effective Date]," to Part 100 and the supporting draft regulatory guide DG-1015.
I opened the meeting by stating that the Comittee to Review Generic Require-ments (CRGR) had approved the proposed rulemaking to publish for public coment.
The Executive Director for Operation (ED0) had submitted the rulemaking to the Comissions on June 12, 1992 to obtain their approval to publish for public coment. A Commission briefing is scheduled for June 24, 1992.
It is anticipated that the rulemaking will be published in the Federal Reaister around the first of August.
The meeting was then turned over to Raymond Ng and John Butler, NUMARC, and Carl Stepp, EPRI, (member of the Ad Hoc Comittee) to discuss industry comments on the seismic siting portion of the rulemaking.
Their vugraphs are included as Enclosure 2.
The major industry concern with the regulation (Proposed Appendix B to Part 100), is the requirement to perform both deterministic and probabilistic evaluations.
It was noted that this concern was also raised in a letter from William Rasin, NUMARC, to Eric Beckjord, NRC, which identified wording changes.
NUMARC staff stated that these changes are needed now to provide assurance that the final rule is not fundamentally different from the public l
l N
b
SEP 312-Lawrence C. Shao 2
coment version. There was a discussion about the need to notify the regula-tion and the potential for additional ACRS and CRGR meetings if the regula-tions were changed.
It was also noted that some documents have been signifi-cantly changed as a result of public comments without adverse implementation problems.
A point not mentioned during the meeting but one that should be put on public record is that the final rulemaking package undergoes the same reviews and public meetings as the proposed rulemaking. When the final regulations are submitted to the review committees (i.e., ACRS, CRGR) and the Commissioners for their approval, the staff will provide a summary of the public comments and the staff's recommended resolution.
By this means, the review committees and the Commissioners are aware of all public concerns, and in this case, will be able to independently review the issue, the comments received, and the proposed resolution.
The remainder of the meeting focused on the Draft Regulatory Guide DG-1015,
" Identification and Characterization of Seismic Sources, Deterministic Source Earthquakes and Ground Motion," that contains staff guidance on the implemen-tation of Proposed Appendix B to Part 100. An alternative approach is being proposed by industry.
It was presented as an integration of the probabilistic and deterministic evaluations rather than explicit independent evaluations; thus their concern with the wording in the proposed regulation.
The staff indicated that their approach had merit and encouraged its develop-ment.
Sample calculations performed in support of industry's position should be completed by the next scheduled public meeting on July 10, 1992 (FRN Vol. 57, June 17, 1992, page 27006). Attendees were informed that written documentation of their position would be required prior to obtaining formal staff comment.
90 Andrew J.
urphy, Chief Structural & Seismic Engineering Branch Division of Engineering, RES
Enclosures:
As Stated cc:
R. Ng, NUMARC R. Bosnak, RES T. King, RES C. Ader, RES G. Bagchi, NRR N. Chokshi, RES R. Rothman, NRR R. McMullen, RES
I En c \\ o.s v,-e L ATTENDEES i
l PUBLIC MEETING REVISION OF 10 CFR PART 100, APPENDIX A, SEISMIC AND GEOLOGIC SITING CRITERIA FOR NUCLEAR POWER PLANTS June 17, 1992 NRC Headquarters, 0WFN, 1F7/9 1:00 PM NMiE AFFILIATION '
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ATTENDEES PUBLIC MEETING l
REVISION OF 10 CFR PART 100, APPENDIX A, SEISMIC AND GEOLOGIC SITING CRITERIA FOR NUCLEAR POWER PLANTS June 17, 1992 NRC Headquarters, OWFN, 1F7/9 1:00 PM i
o tLAtiE AFFILIATION R o n E Q X 1%. 1.d H o fL T o d Emv CAR.tWA Eu=c. k gas SAM 5 r ou ts i var Em FEdoseu/os
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1 Seismic Siting Rulemaking "10 CFR Part 100 Appendix A" l
l 1
i i
NUMARC/NRC Meeting Washington, DC June 17,1992 I
k
4i' AGENDA i
)
o Industry Perspectives on Appendix B and DG-1015 i
i i
I o
Description of Decision - Making Approach l
o Planned Analyses, Applications and Demonstrations o
Staff Comments & Feedback NUMARC 1
~
DRAFT APPENDIX B 1
o Requires both probabilistic and deterministic 4
evaluations 4
Language " locks-in" current seismic siting technology j
o Siting technology and methods are continually evolving o
inhibits introduction and application of new l
information, state-of-the-art technology, and l
analytical methods o
Experience with Appendix A has shown
)
prescriptive language to be a problem j
l o
To avoid these problems:
Identify required investigations and determinations, not methods.
Acceptable methods identified in regulatory guides NUMARc 2
~
DRAFT APPENDIX B, CONT...
i 1
5 o
NUMARC's letter to Beckjord (dated May 8, 1992) identifies wording changes to:
Remove language which prescribes the 4
methods 4
1 i
Maintain language which identifies necessary investigations and determinations i
l o
Changes are needed now to provide assurance that the final rule is not fundamentally different from the public l
comment version i
4 1
T it t
I NUMARC 3
i
1 l
DRAFT DG-1015 l
l Scope o
General l
Decision framework, issues Decision guidelines Area of applicability Direction 1
i Areas for potential improvement l
o Proposed decision-making approach l
l l
l o
Planned analyses to demonstrate proposed i
decision-making approach 1
l l
J NUMARC 4
l
1 l'
DG-1015 l
General o
Decision Framework, Issues i
Estimates of seismic hazard have large associated uncertainty Decision approach must accomodate uncertainty l
Past approach to siting lacks stability in implementation and is not robust with respect to new information l
NUMARC 5
i
~
DG-1015 General o
Decision Guidelines Incorporate the uncertainty in interpretations of earthquake phenomena Evaluate site-specific geologic and seismic information for all new sites Provide information that facilitates evaluation and review of site-specific seismic hazard acceptability considering all new site-specific data Must be generally accepted by regulated, regulator and technical / professional community Must be reproducible Should be robust with respect to evolving i
understanding of earthquake processes and phenomena i
NUMARC G
DG-1015 4
General 1
i o
Areas of Application Gv.7erally applicable to all tectonic i
environments Assure applicability in tectonic environments having greatest uncertainty about earthquake processes and phenomena o
Objective Develop and evaluate decision approaches Demonstrate recommended approach meets guidelines for stable regulatory decision-making NUMARC 7
DG-1015
^
General o
Direction Build on foundation established by U.S.
I NRC Draft DG-1015 a.
Recognize that a PSHA ensures that uncertainty has been included in SSE ground motion assessment b.
Acceptable SSE ground-motion for future sites should be consistent with that of current population of plants c.
Perform site-specific geological, seismological and geophysical investigations d.
De-aggregation of PSHA to provide an information base for evaluation and review of site-specific investigations before final determination of SSE ground motion Make strong use of technical advances of past ten years NUMARC 8
DG-1015 Areais Of Potential Improvement o
Dual-deterministic and probabilistic assessments Deterministic seismic sources are only one realization of the uncertainty in scientific interpretations Selection of deterministic source parameters introduces additional regulatory instability Lacks site-to-site consistency --> likely disparate results at future sites SSE ground-motion decision process is inherently probabilistic --> inappropriate to lay side-by-side probabilistic and deterministic evaluations NUMARC 9
i L
DG-1015 Areas of Potential Improvement o
Regulatory decision-making stability can be better achieved with an integrated decision-making approach, which Integrates assessment of SSE ground-motion, based on:
a)
New site-specific geological, seismological and geophysical information b)
Existing seismic source interpretations i
NUMARC 10
DG-1015 Decision-Making Approach l
l o
Approach involves determination of site-specific SSE ground motion based on an integrated assessment l
Compile site-specific geological, seismological and geophysical information l
l Determine whether existing seismic source interpretations are robust with respect to new information Assess site-specific SSE ground-motion l
uaing PSHA procedures, existing sources, and new ground-motion attenuation models Determine M, D pairs at selected ground-motion frequencies for:
a)
Composite seismic hazard b)
Seismic hazard source-by-source i
NUMARC 1
11
O DG-1015 Decision Making Approach Evaluate derived M, D information against new geological, seismological and geophysical data for the site If needed, perform separate seismic hazard analysis based on new information to verify that derived hazard is consistent with site's PSHA results NUMARC 12
\\
O l
DG-1015 Hazard Assessments To Be Performed l
o Trial applications of alternative approaches for evaluating the SSE ground-motion will be performed at a number of sites o
Evaluations will assess:
M and D for the total (all source) hazard M and D for each seismic source o
Sites - existing plant sites and sites located in proximity to high seismic regions i
l I
I i
NUMARC 13