FRN Public Comment No. 1

Page 1 of I

As of: October 03, 2014
Received: September 22, 2014

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Comments Due: November 06, 2014
Submission Type: Web
Docket: NRC-2014-0187
Treatment of Natural Phenomena Hazards in Fuel Cycle Facilities

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Comment On: NRC-2014-0187-0001
Treatment of Natural Phenomena Hazards in Fuel Cycle Facilities; Request for Comment
Document: NRC-2014-0187-DRAFT-0002
Comment on FR Doc # 2014-18818
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Submitter Information
Name: Stephen McDuffie
Address:

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177 Llandwood Court

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Richland, WA, 99352
Email: stevemcduffie@charter.net

General Comment
First comment: The fourth paragraph of the discussion section of the document refers to updated seismic hazard
information from the U.S. Geological Survey. Presumably, this means either the 2008 or 2014 updates to the
USGS National Seismic Hazard Map (NSHM). Given that this Generic Letter is directed at nuclear facilities,
was consideration given to instead referring to the updated seismic source characterization provided in 2012 by
the Central and Eastern United States Seismic Source Characterization (CEUS-SSC) for Nuclear Facilities,
NUREG-2115? The facilities targeted in this Generic Letter presumably have a number of Structures, Systems,
and Components (SSCs) that would be categorized as Seismic Design Category (SDC) 2 or 3 per the
categorization scheme of ANSI/ANS-2.26-2004 (R2010), Categorization of Nuclear Facility Structures,
Systems, and Components for Seismic Design. Although ANS-2.26 Table A.2 recommends using the USGS
2500-year return period ground motion for SDC-2 SSCs, SDC-3 SSCs should use a site-specific uniform hazard
response spectrum at the 4E-4 annual frequency of exceedance for the design basis ground motion. Applying the
CEUS-SSC model would meet this standard for SDC-3 SSCs.
Second comment: Requested action L.a asks the addressees to submit their definitions of unlikely, highly
unlikely, and credible for natural phenomena hazard events. Why does not the NRC provide uniform definitions
of these terms, i.e., annual expected frequencies such as 1E-2 for credible, 1E-3 for unlikely, and 1E-4 for
highly unlikely? This should be the role of the regulator. Varying definitions from each licensee does not seem
sensible.
SUNSI Review Complete
Template = ADM - 013

E-RIDS= ADM-03
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