ML20237L816

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Testimony of He Flanders on Contention 5.* Testimony of He Flanders on Contention 5 Re Structural Integrity of Spent Fuel Pool Storage Racks.Related Correspondence
ML20237L816
Person / Time
Site: Turkey Point  NextEra Energy icon.png
Issue date: 08/31/1987
From:
WESTINGHOUSE ELECTRIC COMPANY, DIV OF CBS CORP.
To:
Shared Package
ML20237L743 List:
References
OLA-2, NUDOCS 8709090089
Download: ML20237L816 (26)


Text

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UNITED STATES OF AMERICA NUCLEAR REGULATORY COMMISSION 3 2

BEFORE THE ATOMIC SAFETY AND LICENSING BOARD 3

4 In the Matter of ) Docket Nos. 50-250-OLA-2 6 ) 50-251-OLA-2 FLORIDA POWER & LIGHT COMPANY ) (Spent Fuel Pool Expansion)

(Turkey Point Nuclear Generating )

7 Station, Units 3 & 4) )

8 )

9 Testimony Of Harry E, Flanders, Jr.

On Contention Number 5 s 10 11 12 01: Please state your name and address.

13 A1: My name is Harry E. Flanders, Jr. I am a Principal Engineer for the Advanced Engineering Analysis 14 Section of the Nuclear Components Division of 15 16 Westinghouse Electric Corporation. My business address is Westinghouse Electric Corporation, Scenic 17 Highway (State Route 90), Pensacola, Florida, 32504.

18 19 02: Please describe your professional qualifications and experience.

20 21 A2. A summary of my professional qualifications and experience is attached as Exhibit A to this testi-22 m ny and is incorporated herein by reference. I was 23 responsible for performing the seismic analysis of 24 the Turkey Point spent fuel storage racks.

25 26 03: What is the purpose of your testimony?

27 28

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1 A3: The purpose of my testimony is to address Contention

-2 5, as limited to the structural integrity of the' 3- Turkey Point Units 3 and 4 spent fuel pool storage 4 racks. The Testimony Of Edmund E. DeMario On 5 Contention Number 5 addresses the structural 6 _ integrity of the fuel assemblies to be stored in the ,

1 7 racks, and the Testimony Of Russell Gouldy On l; 8 Contention Number 5 addresses the administrative 9 controls for loading of spent fuel into.the racks.

10 Contention 5 and the bases for that contention are 11 as follows:

12 Contention 5 13 That the main safety function of the Spent Fuel Pool which is to maintain the spent 14 fuel assemblies in a safe configuration through all environmental and abnormal 15 loadings, may not be met as a result of a recently brought to light unreviewed safety 16 question involved in the current re-rack design that allows racks whose outer rows 17 overhang the support pads in the Spent Fuel Pool. Thus, the amendments should be 18 revoked.

19 Bases for Contention 20 In a February 1, 1985 letter from Williams, j FPL to Varga, NRC, which describes the 21 potential for rack lift off under seismic event conditions [ sic). This is clearly an 22 unreviewed safety question that demands a safety analysis of all seismic and hurri-23 cane conditions and their potential to increase the possibility of an accident 14 previously evaluate [ sic), or to create the possibility of a new or different kind of i 25 accident caused by loss of structural L

integrity. If integrity is lost, the 26 damaged fuel rods could cause a criticality accident.

, 27 28 l

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, 1 (Hurricane loads were rejected as a basis for this 2 contention in the Licensing Board's Memorandum and 3 Order of September 16, 1985).

4. 04: Would you please describe the arrangement and 5 . structure of the spent fuel racks in the spent fuel  !

6 pools at Turkey Point Units.3 and 4?

7 A4: The Turkey Point spent fuel pools have two storage 8 regions. These regions are shown in the overall fuel 9 pool layout depicted in Figure 1. The Region 1- .

10 storage racks, shown in Figure 2, consist of1three i 11 major sections, which are the leveling pad assembly, 12 the upper and lower grid assemblies, and individual 13 storage cells made of stainless steel. The cells 14 within a rack are interconnected by grid assemblies 15 to form an integral structure. Each rack is 16 provided with leveling pads connected to the lower 17 grid assembly which contact the floor of the spent 18 fuel pool and are remotely adjustable from above to i

19 level the' racks during installation. The racks are )

20 free-standing and are not anchored to the floor or 21 braced to the pool walls. Support pads for the new 22 racks sit on the existing floor embedment plates

'23 which are located at various places along the bottom 24 of the pool liner. Due to the location of the floor I L 25 embedment plates, some of the support pads for the 26 new racks cannot be situated at the corners of the 27 l 28 i

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. -g-1 racks. Therefore, some of the outer storage loca-2 tions on the new racks overhang (extend beyond) the 3 support pad, as shown in Figure 3.

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! 4 The Region 2 storage racks, shown in Figure 4, 5 consist of two major sections, which are the 6 leveling pad base assembly and stainless steel 7 cells. The cells are assembled in a checkerboard 8 pattern, producing a honeycomb-type of structure.

9 The cells are welded to a base support assembly and 10 to one another to form an integral structure, 11 without the use of grids of the type employed for 12 the Region 1 racks. The Region 2 storage racks, 13 like the Region 1 racks, are provided with the 14 leveling pads connected to the base support assem-15 bly, which contact the pool floor /embedment plates, 16 and which are remotely adjustable from above to 17 level the rack during installation. The racks are 18 free-standing and are not anchored to the floor or 19 braced to the pool walls. Some of the storage 20 locations on the Region 2 racks also overhang their 21 support pads.

22 05: Are there any NRC criteria applicable to seismic 23 analyses of the spent fuel racks?

24 AS: Yes. The Nuclear Regulatory Commission (NRC) Staff 25 has identified criteria which it will accept for the 26 performance of seismic analysis of spent fuel 27 storage racks. These criteria are primarily 28

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, 1E contained'in Section 9.1.2'of the Standard Review

[ 2- Plan (SRP), . entitled " Spent Fuel Storage,"'and.in.

3 the "OT. Position for Review and Acceptance of Spent  ;

4' . Fuel Storage and Handling Applications" (NRC 5 . Position Paper).

6 .Q6': What criteria are provided by SRP Section.9.1.27 L i7 A6:. SRP Section 9.1.2, Paragraph III.3.A states that'the l c 8 spent fuel pool storage racks should be classified 9 and designed.to. seismic category 1 requirements

10' (i.e., able to withstand the effects of the safe 11 shutdown earthquake (SSE) and remain functional).

12 Q7: What criteria are contained in the NRC Position 13 Paper?

14 ~ A7: Section IV of the NRC Position Paper identifies .h l

15- criteria for performing evaluations of'the mechani- ]

16 cal and structural integrity'of spent fuel pools and .

17 racks.Section IV(2) of the NRC Position Paper 'a i

18 identifies either of two industry codes,Section III 19 of the American Society of Mechanical Engineers a

20 (ASME) Code or the American Institute of Steel 21 Construction (AISC) Code, as being acceptable for 22 deriving allowable stresses in spent fuel pool-

.23 racks.Section IV(3) of the NRC Position Paper 24 identifies acceptable methods for calculating i

25 seismic loads.Section IV(5) states that SRP 26 Section 3.8.4 provides acceptable procedures for q i

27 modeling and analyzing the seismic responses of the j J

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. l' spent fuel. storage racks.Section IV(6) identifies 2 the structural acceptance criteria for the spent 3 fuel storage racks. In particular,Section IV(6) of j i

4 the NRC' Position Paper states, among other things, l 5 that'the design of a storage rack is acceptable if i 6 "the amplitudes of sliding motion are minimal, and 7 impact between adjacent rack modules or between a 8 rack module and the pool walls is prevented-provided 9 that the factors of safety against tilting are 10 within the values permitted by Section 3.8.5.II.5 of 11 the Standard Review Plan."

12 Finally,Section III of the NRC Position Paper

-13 identifies criteria for performing criticality 1 14 analyses for spent fuel pools, including criticality 15 analyses for postulated accident conditions. In ,

16 particular,Section III.l.2 of the NRC Position 17 Paper states that " Realistic environmental condi-18 tions (e.g., the presence of soluble boron) may be 19 assumed for the fuel pool and fuel assemblies" 20 during postulated accident conditions, including the 21 "effect of . . . earthquake on the deformation and 22 relative position of the fuel racks."

23 08: To what extent are the criteria set forth in the SRP 24 and in the NRC Position Paper used by the nuclear 25 industry?

26 27 28

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1 .A8: The criteria set forth .in the SRP and'in the NRC 2 Position Paper are widely used in the' nuclear j 3 industry for. performing seismic analyses of spent 4 fuel racks, and they are recognized as being conser- j 5 vative.

1 6 09:- So the new spent fuel storage racks for Turkey Point 7 conform with the criteria specified in SRP Section 8- 9.1.2?

9 .- A9: Yes. The new spent fuel storage racks for Turkey 10 Point were designed in accordance with seismic 11 category 1 requirements. Thus, the design conforms 12 with Section 9.1.2 of the SRP.

13 010: Do the spent fuel racks at Turkey Point conform.with

'14 the criteria specified in Section III.1.2 of the NRC l

15 Position Paper?

,16 Al'0 : Yes. As discussed at page 50 of the Licensing 17 Board's Memorandum and Order of March 25, 1987, the 18 presence of the soluble boron in Turkey Point spent 19 fuel pool water will maintain the stored spent fuel 20 ass 2mblies sub-critical, even under postulated i 21 accident conditions involving changes in the mechan-22 ical or geometric configuration of the fuel assem-

-23 blies or the storage racks resulting from 24 earthquake. Thus, the design conforms with Section 25 III.l.2 of the NRC Position Paper.

1 26 l

27 28

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, Qll: Was the mechanical and structural analysis of the 2 Turkey Point spent fuel storage racks performed in 3 accordance with Section IV of the NRC Position 4 -Paper?

-5 All: Yes. In particular, the' structural analysis of the 6 storage racks was based on~the allowable stresses of .

i 7 the ASME Code, as recommended by Section IV(2) of 1 8

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the NRC Position Paper.

9 Q12: Please describe the assumptions used in the mechani-10 cal and structural analysis of the Turkey Point -i 11 spent fuel storage racks.

12 Al2: During a seismic event, a. force is imposed upon a 13 structure as a result of. ground accelerations The 14 maximum seismic acceleration used in the analysis of 15 the Turkey Point spent fuel storage racks was the 16 design basis SSE acceleration for Turkey Point,

'17 which is identified in Section 2.11 and Appendix 5A 18 of the Updated Final Safety Analysis for Turkey 19 Point Units 3 and 4 (Updated FSAR). The design 20 basis SSE acceleration for Turkey Point is 0.15g 21 horizontal ground acceleration (where g is the 22 acceleration of the earth's gravity). Horizontal 23 response spectra for the spent fuel pool structure 24 are equal for both orthoginal horizontal directions.

25 As specified by Appendix SA of the FSAR, the l 26 vertical component of acceler.ation was taken as

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l 27 two-thirds of the horizontal ground acceleration.

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L. 1 The resistance to seismic displacement of a 2 given structural element is determined by its mass, 3' by the damping.(energy loss) mechanisms inherent in 4 the element, and by its method of connection to the 5 other elements of the structure. Energy loss 6 mechanisms due to damping are present in materials 7 even when the applied stresses are within the 8 elastic limits for the material. For example, when 9 a tuning fork is excited by striking it, the damping 10' inherent in the material of the fork causes its 11 vibrations to' die away rather quickly. The appro-12- priate damping value to employ for seismic analysis 13 of a given structure depends upon the nature of the 14 structure. Damping values are generally expressed 15 as a percent of the critical damping value.

16 Critical damping provides an amount of energy loss 17 that prevents or quickly eliminates vibratory motion 18 of the structure and its elements. Therefore the 19 lower the damping value in percent, the more suscep-20 tible the structure is to vibratory' motion in a 21 seismic event. The seismic analyses of the Turkey 22 point spent fuel racks used a conservative struc-23 tural damping value of 2 percent, which is consis-24 tent with the value specified in Appendix 5A of the 25 Updated FSAR, and conservative compared to the value 26 of 4 percent recommended by NRC Regulatory Guide 27 1.61 for welded steel frame structures. Damping 28

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1- provided by the water between the fuel assemblies, 2 storage cells, and rack assemblies was conserva-3 tively neglected. However, the mass of water was l

4 taken into account in the analysis.  ;

5 The close proximity of adjacent racks and 6 storage cells, as well as their size relative to the 7 size of the gaps between them, is such that the mass 8 of water in the gap provides large hydrodynamic 9 forces which oppose rack or storage cell motions 10 that are out of phase with the motions of its 11 neighbors. Since the maximum deflections, loads and 12 stresses occur when adjacent storage cells and racks 13 respond in phase, the Turkey Point racks were 14 analyzed as if they were hydrodynamically coupled 15 (move in phase).

i 16 In addition to the seismic loads, I also 17 considered whether the acceleration-induced motion 18 of the water in the pool (sloshing) would affect the  ;

19 racks. No sloshing loads are imposed on the rack 1

20 structures, which occupy roughly the lower one-third 21 of the depth of the water in the pool, because the 22 sloshing movement of the water would occur in the j i 23 upper elevations of the pool above the top of the l l

24 racks.

j 25 Since the spent fuel racks for Turkey Point are 26 free-standing, the racks would be held in place l 27 durinn a seismic event by gravity and by frictional )

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l' forces between.the rack and pool floor embedments.

.2 The frictional forces act to both excite the racks 3- and to restrain them from sliding during a postu-4 . lated seismic event. Tests'have shown that static

5. ~ and dynamic friction coefficients in the range of 6' O.2 to 0.8 are appropriate for use in the analysis 7 of the conditions that apply during a seismic. event 8- for the Turkey Point spent fuel racks. Thus, the 9 range of friction coefficients (0.2 to 0.8) was used

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in the analysis. The use of a low dynamic coeffi-11 cient of. friction-(0.2) produces a maximum rack 12 horizontal displacement.or sliding, while use of a 13 high static coefficient (0.8) produces maximum rack i

14 horizontal overturning force.

15 Q13: Please describe the methods used in-the mechanical 16 and structural analysis of the Turkey Point spent j 17 fuel storage racks.

18 A13: The dynamic response of the fuel rack assembly 19 during a seismic event determines the loads and q s

20 stresses on the structure. The dynamic response and  !

21 internal stresses and loads were obtained from a 22 seismic analysis which was performed in two phases. I 23 The first phase employed a two-dimensional model of 24 an individual storage cell and the fuel assembly it 25 contains. The results obtained from the two-26 dimensional model of the first phase analysis were 27 28

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,, 1 then employed as input to the second phase analysis,.

2 'which modeled the' complete storage rack in three

.3 dimensions.

4 The models used in both phases of.the analysis.

5 employed the finite element. method. The finite 6 element analysis method is widely used in the

.7 nuclear power'and other industries. It is accepted 8 by the NRC for the seismic analysis of.a variety of 9 nuclear power plant structures, from the containment 10 building to the instrument panel racks in the main

' ll . control room. In applying the method, the structure 12 to be analyzed is broken up into a finite number of 13 sections or elements which interact at nodal points.

} 14' A computer program is then used to evaluate the 15 stressesLproduced on the elements by the seismic 16' accelerations applied.

17 The first phase of the' analysis employed a 18 two-dimensional non-linear model of an individual' 1 19 . rack storage cell and its fuel assembly. Two

20. dir.ensions, one vertical and one horizontal, are an 21 appropriate. choice for the first phase model because

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22 the fuel assembly and storage cell are structurally 1

23- symmetric (identical) about either the X or Y  !

24 horizontal axis. The model is designated as non-l- 25' linear because it is used to calculate the fuel I

. 26' assembly to cell impact loads, the amount of I 27 leveling pad lift-off (if any), and the amount of l 28 i l'

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1 rack sliding, parameters which are non-linear 2

functions of the gap between the wall of the storage )

3 cell and the fuel assembly, energy losses at the 4

support locations of the fuel assembly within the 5 cell, and the boundary conditions at the fuel rack l 6 1 support pads. To represent the seismic event, this j 7 model used the time history of horizontal and j 8 vertical accelerations imposed on the rcck by the j i

9 spent fuel pool floor. The analytical model of the i 10 fuel assembly used in this model was verified by 11 comparison to the fuel assembly test data. f 12 The second phase analyses used a three-dimen-13 sional linear model to calculate the response (loads 14 and stresses) in a complete fuel rack assembly. It 15 is important to understand that the two-dimensional 16 non-linear model accurately predicts the response of 17 a single storage cell and its fuel assembly, appro-18 priately taking into account the non-linear effects 19 described, while the three-dimensional model accur-20 ately reflects the internal stress distribution of a 21 complete rack consisting of an array of such fuel 22 storage cells and fuel assemblies. The values used 23 in the loads and stress analyses which are subject 24 to non-linear effects are taken from the maximum 25 loaded sections of the three-dimensional linear 26 model and are corrected to agree with the maximum 27 loads and stresses predicted by the two-dimensional 28

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i l' non-linear model. Thus, the second phase analyses L 2 employing the three-dimensional linear model conser-3 vatively account for the maximum values of'the non-j 4 linear loads and stresses. 1 l

l 5 Q14: D!.d your analysis of the Turkey Point spent fuel 6- storage racks account for possible differences in-7 the loading of' spent fuel in the racks?

\

8 A14: Yes. Fuel rack seismic analyses were performed for 9 two cases involving different assumptions regarding 10 the loading pattern of fuel assemblies in the 11 overhanging locations.

12 Case 1 assumed the present basis for the spent 13 fuel pool expansion license amendments. The anal-14 ysis assumes that administrative controls are in i

15 place to prevent loading of fuel assembAies into the '

16 overhanging locations until after assemblies.are

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17 loaded into the other storage locations. )

18 f Case 2 is an analysis performed at the request 19 of Florida Power & Light Company, after NRC approval 20 of the license amendments, to determine the poten-

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21 tial effect of loading fuel assemblies into over-f 22 hanging locations. The Case 2 analysis assumes that 23 fuel assemblies are loaded in the overhanging 24 locations first, before the remaining locations are 25 loaded, as shown in Figure 3.

26 Q15: What were the results of the analyses performed for 27 the Turkey Point spent fuel storage racks?

28

.15 -

1. A15: The results of-the analysis for Case 1, which

, 2 considered full; fuel loading (fuel assemblies in all 3 storage locations) and various partial loading 4 conditions, were as follows:

5 o The fuel rack support points did not lift off 6 or lose contact with the floor of the spent 7 fuel pool when subjected to the specific 8 seismic ground accelerations. The factor of (

9 safety _against' overturning was much greater 10 than the 1.5 value specified by Section i 11 3.8.5.II.5 of the Standard Review Plan.

12 o The maximum relative displacement of a fuel 13 rack was calculated to be 0.256 inches (rela-

- 14 tive displacement accounts for sliding, struc-15' tural, and thermal movement of two adjacent o

16 racks toward each other). The gap between {

17 adjacent fuel racks is 1.11 inches, and the gap 18 between a fuel rack and the spent fuel pool 19 walls is even larger. Thus, impact between

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20 adjacent rack modules or between a rack module 21 and the pool wall is prevented and the leveling l 22 screws will not slide off the embedment plates.

23 o The fuel rack stresses are within ASME Code 1

24 allowable limits, lugt, the minimum ratio of l

25 allowable stress divided by applied stress is  !

26 greater than 1. The minimum ratios of allow-27 able stress divided by applied stress for the l- 28 '

L L:

1- leveling pads, grid assemblies, and cell ,

2 assemblies, are 1.27, 1.15, and 1.11, respec- q 3 tively. It should be noted that allowable 4 stresses do not represent the point of material 5 failure, but are values which include conser- ._

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6 vatisms inherent in the ASME Code. 7 7 Thus, the results of the Case 1 analysis ,

8 conform with the acceptance criteria in the NRC 1 .

9 Position Paper and demonstrate that the spent fuel b 10 storage racks will be maintained in a safe confi-11 guration during postulated seismic events.

12 In Case 2, the models were adjusted to account -

13 for the overhanging fuel mass shown in Figure 3, and 14 the analysis was conducted for various partial fuel 15 loading conditions with the appropriate seismic 16 ground acceleration inputs. The results of the Case a 17 2 analysis were as follows: 3 18 o The rack module was predicted to rock and 19 result in lift off of one side of the rack from 20 the support point. The maximum lift off of 21 0.18 inches was produced by loading three 22 outboard rows on the side of the rack with the 23 overhanging storage location. Lift off of 24 support points is not uncommon for freestanding 25 racks under seismic conditions and the struc- -

26 tural members of the racks are designed to 27 accommodate the stresses produced by lift off.

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1 l 1 The lift off distance was used in an overturn 1

2 . stability calculation,'and it'was shown:that 3 s the rack is stable and will not' overturn and j 4 that the minimum factor of safety against l

5 overturn is~8 (which is'substantiallyl greater 6 thanLthe.l.5 factor of' safety against'over-p .7 turning recommended by Section 3.8.5'.II.5 of-8 the'SRP). f 9- o The maximum relative displacement of a fuel 10- rack is 0.709 inches (relative displacement-11- accounts for sliding, rocking, structural, and- >

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,. 12 thermal movements: of two adjacent: racks toward-13 each other). This is less than.the gap be' tween 14' adjacent. fuel racks'and.between the fuel racks

15. and the spent fuel pool walls. Thus, impact

~ 16 ' between adjacent rack modules.or between a rack 17 module and the pool wall is prevented and the 18 leveling screws will not slide off the embed-19 ment plates.

20 o Structural loads and stresses are enveloped by 21 the condition of a fully loaded rack. Thus, 22 the maximum' stresses produced by the partially

23. loaded racks in Case 2 are less than the
24 maximum stresses calculated in Case 1.

25 Therefore, the applied stresses in Case 2 are 26 also within'the ASME Code allowable stresses.

27 28 1

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1 Thus, the results of the case 2 analyses 2- conform'with the acceptance criteria in the NRC

'3 Position Paper and demonstrate that the spent fuel 4- . storage racks will be maintained in a safe confi-5 guration during postulated seismic events. The Case 6 2 analysis demonstrates 'his t to be true even if 7 administrative controls were not in place to assure 8- that spent fuel is not loaded into overhanging 9 portions of the racks until other portions of the 10 racks have-been filled.

11 Q16: What effect would the maximum acceleration shown by 12- the analysis performed for Case 1 and Case 2 have 13 upon fuel assemblies?

14 A16: The analyses performed for Case 1 and Case 2 condi-15 tions show that the maximum acceleration imposed.on l 16 a fuel assembly is 1.6g. The ability of the fuel 17 assemblies to safely accommodate a 1.69 acceleration l 18 is discussed in the Testimony Of Edmund E. DeMario '

19 On Contention Number S. i 20 Q17: Would you please summarize your testimony?

21 A17: The Turkey Point spent fuel racks were analyzed  ;

22 employing methods approved by the NRC and by appli- l 23 cable industry standards. The results of those 24 analyses show that the fuel racks are designed so 25 that the stresses produced under SSE seismic condi-26=

tions are within the allowable limits of the ASME 27 Code, the fuel racks will not contact each other or 28 l

1

1 the. spent fuel pool walls during seismic events, and 2 the lift off produced for Case 2 (i.e., assuming no 3 administrative controls were in place) meets the 4 stability requirements of the NRC Position Paper and

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5 will not result in overturning of the racks.

6 7

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9 10 11 12 13 14 15 16 17 18 19 20 21 22 23 24 25 26 27 28

.1 i

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,2 EXHIBIT A'-

3 Professional Qualifications and Experience of Harry E. Flanders, Jr.

5 My name is Harry E. Flanders, Jr., and my business

.6 address'is' Westinghouse Electric Corporation, Scenic Highway, "

7 Pensacola, Florida, 32504. I am employed.by Westinghouse

.8 Electric Corporation (" Westinghouse") as a Principal Engineer 9- for the Advanced Engineering Analysis Section of the Nuclear 10 Components Division. j 11 I graduated from Georgia Institute of Technology, 12 with a Bachelors Degree in Mechanical Engineering in August 13- 1963. While employed by the Lockheed-Georgia Company, I

14 graduated from the Georgia Institute of Technology with a 15 Master of Science degree in Mechanical Engineering in June 16 1970. I am currently a Registered Professional Enginee.r in j 17 the state of Georgia (Certificate Number 7061), and am a 18 member of'the American Society of Mechanical Engineers (ASME).

19 In April 1974, I joined Westinghouse in the Nuclear 20 Components Division of the Water Reactor Divisions as a Senior 21 Engineer A. My duties in the Advanced Engineering Analysis 22 Department included the seismic and structural analysis of l  !

23 pressurized water reactor internal components. These analyses 24 included the determination of reactor internal component

, 25 stresses to ensure margin against the allowable stresses of 26 the ASME Boiler and Pressure Vessel Code, and other safety 27 criteria. The result of various postulated accidents and 28

7-- ,

1

. 1 normal operation conditions were analyzed to demonstrate that 2 the stresses met the required limits. I was also responsible 3 for preparing related documentation for submittal to regu-4 latory authorities.  !

5 Since that time I have had assignments of increasing ,

6 responsibility in seismic and structural analysis and was 7 promoted to the position of Principal Engineer in the 8 Commercial Products Engineering (CPE) Department in February 9 1980. My duties in the CPE Department included the prepara- l 10 tion and supervision of preparation of seismic and structural 11 analyses of spent fuel storage racks and associated spent fuel 12 storage equipment. These analyses include the determination 13 of fuel rack stresses to ensure margin against the allowable

'4 stresses of the ASME B&PV Code and other safety criteria of J i

15 the NRC. The results of various postulated accidents, seismic ]

16 events, and normal operating conditions were analyzed to 17 demonstrate that the stresses met the required limits. I was 18 also responsible for preparing related documents for submittal 19 to regulatory authorities (NRC). I was responsible for the I 20 analyses of many Westinghouse supplied spent fuel racks 21 including the Turkey Point spent fuel racks. In October 1985, 22 I was assigned to the position of acting Manager, Commercial 23 Products Engineering, with responsibility for the efforts of 24 several engineers and technicians in the design - analysis of 25 spent fuel racks and associated spent fuel equipaent. In 26 April 1986, I was assigned to the Advanced Engineering 27 28

- - .- . _ _ _ _ - _ _ - _ = _ - _ _ - _ _ _ _ - - _ _ _ _ _ _ - _ - _ _ -

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L I Analysis! group'with the responsibility for the seismic and'.

R 2 :structuralLanalyses of' spent fuel racks, spent fuel casks, and 3 pressur.ized water reactor; internal components.

J

4 ' Prior to the time.I joined Westinghouse I was 5- employed by Burlington-Industries,1Lockheed-Georgia Company,.

6 and. Newport News Shipbuilding and Dry Dock Company.

7 L From 1970 to 1974 I was employed by_Burlington 8 Industries,' Corporate'Research and Development Division, l 9 "

Greensboro, North Carolina, as a Research and Development

, 10 Engineer. .My responsibilities included the design, develop-11 ment, and dynamic' analyses of high speed textile-equipment. i

. 12

~

From 1966'to 1970 I was employed by Lockbrod-Georgia i 1

13 Company, Structures Integrity Department, Marietta, Georgia, 14' as a Senior Aircraft Structural. Engineer. My responsibilities-15 included stress' analyses of landing gear and associated com-16- ponents of the C5-A aircraft.

17 From 1964.to 1966 I was employed by Newport. News j 18 Shipbuilding and Dry Dock Company, Engineering Technical 19 Department, Newport News, Virginia, as a Design Engineer. My 20- responsibilities included stress analysis and dynamic shock I i

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-21 analyses of main machinery and associated deck machinery of 22 surface and subsurface ships.  !

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