ML20213A033

Affidavit of Kp Singh Re Mothers for Peace & Sierra Club 861215 Motion for Summary Disposition Concerning Design of high-density Spent Fuel Racks.Racks Designed in Compliance W/Applicable NRC & SRP Requirements.Certificate of Svc Encl

ML20213A033
Person / Time
Site:	Diablo Canyon
Issue date:	01/13/1987
From:	Singh K HOLTEC INTERNATIONAL
To:
Shared Package
ML20212R698	List: ML20212R696 ML20213A033
References
OLA, NUDOCS 8702030066
Download: ML20213A033 (5)

Text

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o DOLMETED uumc UNITED STATES OF AMERICA

NUCLEAR REGULATORY COMMISSION 87 JAN 28 A9

02 BEFORE THE ATOMIC SAFETY AND LICENSING BOARD OFF.. ' '

50CSEl' In the Matter of ) Docket No. 50-275

) 50-323 PACIFIC GAS AND ELECTRIC COMPANY )

) (Reracking of Spent (Diablo Canyon Nuclear Power ) Fuel Pools)

Plant Units 1 and 2) )

) January 13, 1987 AFFIDAVIT OF KRISHNA P. SINGH re Krishna P. Singh, being first duly sworn, states as follows:

1. I am President of Holtec International, Mount Laurel, New Jersey.

2. Prior to November 1986, I was Vice President of Engineering for Joseph Oat Corporation, where I supervised the analysis and design work for the Diablo Canyon high density spent fuel racks.

3. I have reviewed the Motion for Summary Disposition filed on December 15, 1986, by the Mothers for Peace and the Sierra Club. In particular, I have reviewed the discussion in the Motion with respect to compliance with NRC criteria in the design of the high density spent fuel racks.

4. It is my belief that these racks were designed in compliance with applicable NRC regulatory requirements and l g203OO66870134 G ADOCK 05000275 PDR

9 appropriate portions of NRC technical guidance documents, such as the Standard Review Plan (NUREG-0800) and the NRC OT Position Paper (Review and Acceptance of Spent Fuel Storage and Handling Applications).

5. As I interpret the NRC guidance oA the acceptance criteria for the design of the high density spent fuel racks, contained in the Standard Review Plan, Section 3'.8.4, Appendix D, Paragraph (6), the NRC does not categorically preclude impact between racks. Contrary to the allegations contained in the Motion at pages 7-10, the guidance of Paragraph (6) includes specific provisions for impact loadings. -

6. With respect to the reference to my paper titled

" Seismic Response of a Free Standing Fuel Rack Construction to 3-D Floor Motion," I believe the following information is useful to clarify any misunderstanding which may arise from the quote on page 11 of Joint Intervenors' Motion for Summary Disposition.

The purpose of the paper, and the analyses described in the paper, was to discuss the difference in modeling and results between two different rack design types. Rack impacts were precluded, solely as a means to simplify the analytical

comparisons. It was not the intent of the paper to consider the

! regulatory positions or acceptance criteria for such impacts. In that regard, it should be noted that the racks considered in the paper were specifically not designed for impact loadings and did not incorporate specific features to accommodate such rack interactions. However, as stated above, NRC requirements and

guidance documents do allow rack impacts, if, as in the case of the Diablo Canyon racks, these impacts are incorporated in the design.

e HOLTEC INTERNATIONAL

7. Similarly, with respect to the other references discussed in the Motion at page 11 (i.e., the December 5, 1985 meeting notes and the Planning Study), the information presented in those documents was intended as a general discussion of contrasts in rack design experience at other p'lants, rather than a representation of the rack design at Diablo Canyon.

I swear that the foregoing is true and correct to the best -

of my knowledge.

Dated OA Ib 7 W

• YtAr cfN KRISHNA P. SINGH Subscribed and sworn t before me this 13 d day of L . , 1987.

/ 0 Cm W _.= .O 0 # Notary Public Mac* int. M ' n; v an;r*"Y STA Tf* GL i /J ,. 1 MY C'. " . .3 f Ed. 1 5, t4 a0

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DMy(g:

g UNITED STATES OF AMERICA '87 JAN 28 A9:02 NUCLEAR REGULATORY COMMISSION boc)I~ > r* ni O w.>

) Docket Nos. 50-275 In the Matter of ) .50-323

)

PACIFIC GAS AND ELECTRIC COMPANY ) (Reracking of Spent Fuel Pools)

)

(Diablo Canyon Nuclear Power )

Plant Units 1 and 2) )

)

CERTIFICATE OF SERVICE I hereby certify that on January 14, 1987, copies of the following document in the above-captioned proceeding have been served on the following by deposit in the United States mail, first class, or as indicated by an asterisk through delivery by Federal Express: ANSHER OF PACIFIC GAS AND ELECTRIC COMPANY IN OPPOSITION TO MOTION FOR

SUMMARY

DISPOSITION.

B. Paul Cotter, Jr., Chairman

• Docketing and Service Branch Administrative Judge Office of the Secretary Atomic Safety and Licensing U.S. Nuclear Regulatory Commission Board Panel Hashington DC 20555 U.S. Nuclear Regulatory Commission 4350 East West Highway 4th Floor Bethesda MD 20814 Glenn 0. Bright

• Lawrence Chandler, Esq.*

Administrative Judge Henry J. McGurren, Esq.

Atomic Safety and Licensing Office of Executive Legal Director Board Panel U.S. Nuclear Regulatory Commission U.S. Nuclear Regulatory Commission Maryland National Bank Building 4350 East Hest Highway 4th Floor Room 9604 Bethesda MD 20814 7735 Old Georgetown Road Bethesda MD 20814 i Dr. Jerry Harbour

• Lewis Shollenberger

Administrative Judge Regional Counsel Atomic Safety and Licensing U.S. Nuclear Regulatory Commission Board Panel Region V U.S. Nuclear Regulatory Commission 1450 Maria Lane, Suite 210 4350 East Hest Highway 4th Floor Halnut Creek CA 94596 Bethesda MD 20814 I

a B

Diablo Canyon Service List Atomic Safety and Licensing Diane M. Grueneich' Board Panel Grueneich & Lowry U.S. Nuclear Regulatory Commission 345 Franklin Street Washington DC 20555 San Francisco CA 94102 Atomic Safety and Licensing JacquelynWheekr Appeal Board Panel 2455 Leona Str.eet U.S. Nuclear Regulatory Commission San Luis Obispo CA 93401 Washington DC 20555 ,

Mr. Lee M. Gustafson C.O.D.E.S.

Pacific Gas and Electric Company 731 Pacific Street Suite #42 1726 M Street NH Suite 1100 San Luis Obispo CA 93401 Hashington DC 20036-4502 -

Managing Editor Janice E. Kerr, Esq. San Luis Obisoo County Public Utilities Commission Telearam-Tribune 5246 State Building 1321 Johnson Avenue 350 McAllister Street San Luis Obispo CA 93406 San Francisco CA 94102 Richard E. Blankenburg Nancy Culver, Co-publisher 192 Luneta Street Hayne A. Soroyan, News Reporter San Luis Obispo CA 93401 South County Publishing Company P. O. Box 460 Arroyo Grande CA 93420 Dr. Richard Ferguson*

Vice-Chairman Sierra Club Rocky Canyon Star Route Creston CA 93432 ,

U Richard F. Locke Pacific Gas and Electric Company 77 Beale Street, 31st Floor San Francisco, CA 94106 Dated at San Francisco, California, this 14th day of January,1987.

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