Letter to Comment on Proposed Federal Rule Change Regarding geologic and seismologic characteristics

STATE OF CALIFORNIA—THE RESOURCES AGENCY GRAY DAVIS, GOVERNOR CALIFORNIA COASTAL COMMISSION 45 FREMONT, SUITE 2000 SAN FRANCISCO, CA 94105- 2219 VOICE AND TDD (415) 904- 5200 FAX ( 415) 904- 5400 16 October 2002 Secretary, U.S. Nuclear Regulatory Commission Washington, DC 20555-0001 Dear Commissioners, This letter is to express the concerns of the California Coastal Commission staff with respect to the proposed rule change regarding geologic and seismologic characteristics for siting and design of dry cask independent spent fuel storage installations (ISFSI) and monitored retrievable storage (MRS) installations, described in the Federal Register (v. 67, n. 140, pg 47745-47755). As detailed in the Federal Register, the proposed changes to 10 CFR Part 72 would have three functions: 1. Require a new specific license applicant for a dry cask storage facility located in either the western U.S. or in areas of known seismic activity in the eastern U.S., and not co-located with a nuclear power plant, to address uncertainties in seismic hazard analysis by using appropriate analyses, such as a probabilistic seismic hazard analysis (PSHA) or suitable sensitivity analyses, for determining the design earthquake ground motion (DE). All other new specific license applicants for dry cask storage facilities would have the option of complying with the proposed requirement to use a PSHA or suitable sensitivity analyses to address uncertainties in seismic ...