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 EnclML20213A033 |
Person / Time |
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Site: |
Diablo Canyon ![Pacific Gas & Electric icon.png](/w/images/f/ff/Pacific_Gas_%26_Electric_icon.png) |
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Issue date: |
01/13/1987 |
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From: |
Singh K HOLTEC INTERNATIONAL |
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To: |
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Shared Package |
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ML20212R698 |
List: |
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References |
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OLA, NUDOCS 8702030066 |
Download: ML20213A033 (5) |
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Category:AFFIDAVITS
MONTHYEARML20064D1961994-03-0404 March 1994 Affidavit of Mj Angus Re Motion to Reopen Record ML20057B0261993-08-0909 August 1993 Affidavit of non-disclosure in Support of Access to Excerpts from INPO Rept Re Maint & Surveillance Activities at Plant ML20057B0301993-08-0505 August 1993 Affidavit of non-disclosure in Support of Access to Excerpts from INPO Rept Re Maint & Surveillance of Activities at Plant ML20057B0271993-08-0505 August 1993 Affidavit of non-disclosure in Support of Access to Excerpts from INPO Re Maint & Surveillance Activities at Plant ML20057B0181993-08-0404 August 1993 Affidavit of non-disclosure in Support of Access to Excerpts from Rept Prepared by INPO Re Maint & Surveillance Activities at Plant ML20057B0221993-08-0404 August 1993 Affidavit of non-disclosure in Support of Access to Excerpts from INPO Rept Re Maint & Surveillance Activities at Plant ML20045G9811993-06-30030 June 1993 Affidavit.* INPO Rept Should Not Be Disclosed Because San Luis Obispo Mothers for Peace Need for Document Do Not Outweigh Interests of Pg&E,Inpo & NRC & Public in Disclosure.W/Certificate of Svc ML20045G9821993-06-25025 June 1993 Affidavit.* Affidavit of Bw Giffin Re Info Contained in Util Response to Third Set of Supplemental Interrogatories & Requests for Production of Documents (Aging) Filed by San Luis Obispo Mothers for Peace ML20045G9901993-06-25025 June 1993 Affidavit.* Affidavit of Bw Giffin Re Info Contained in Util Supplemental Response to Second Set of Interrogatories & Requests for Production of Documents Filed by San Luis Obispo Mothers for Peace ML20045A7031993-05-26026 May 1993 Affidavit of Je Molden Re Util Response to Supplemental Interrogatories Re First Set of Interrogatories & Requests for Production of Documents (Cable Failures) ML20045A7041993-05-26026 May 1993 Affidavit of Je Molden Re Util Response to Miscellaneous Requests for Production of Documents ML20045G9931993-04-13013 April 1993 Affidavit.* Affidavit of Bw Giffin Re Info Contained in Util Response to Second Set of Interragotories & Request for Production of Documents Filed by San Luis Obispo Mothers for Peace ML20128B8341992-11-30030 November 1992 Affidavit of as Masciantonio in Support of NRC Staff Response to Mothers for Peace Suppl to Petition to Intervene.* W/Certificate of Svc ML20116F0631992-10-0707 October 1992 Affidavit of R Becker.* Concerns Re Safety of Plant Operation During Period of CP Recapture Expressed ML20116F0361992-10-0606 October 1992 Affidavit of N Culver.* Affidavit Re Safety Concerns of Plant Operation During CP Recapture ML20116F0701992-10-0606 October 1992 Affidavit of Biesek.* Concerns Re Safety of Plant Operation During Period of CP Recapture Expressed. Encl ML20116F0551992-10-0606 October 1992 Affidavit of E Holder.* Concerns Re Safety of Plant Operation During Period of CP Recapture Expressed ML20235S0091987-10-0202 October 1987 Affidavit of Jd Shiffer.* Explains Util Planned Expansion of Facility Spent Fuel Storage Capacity & Why Delay in Reracking Schedule,Such as Would Be Occassioned by Stay,Will Cause Substantial Harm to Util.Certificate of Svc List Encl ML20216J8641987-06-29029 June 1987 Declaration of Ef Lowry.* Tm Novak Board Notification 87-05 Re Draft BNL Rept Beyond Design-Basis Accidents in Spent Fuel Pools (Generic Issue 82) Received in Late Mar or Early Apr 1987.Proof of Svc Encl ML20216J8471987-06-26026 June 1987 Affidavit of SA Silver Informing That Draft BNL Rept, Beyond Design-Basis Accidents in Spent Fuel Pools (Generic Issue 82) Not Received ML20216J8191987-06-25025 June 1987 Affidavit of RB Ferguson Re Notification of Generic Issue 82.* Board Notification 87-05 Re Generic Issue 82 Concerning Beyond design-basis Accidents in Spent Fuel Pools False & Misleading ML20216J8371987-06-25025 June 1987 Affidavit of N Culver Informing That Board Notification 87-05 Re Draft BNL Rept on Spent Fuel Pool Accidents Never Received ML20213A0331987-01-13013 January 1987 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 ML20205F6271986-08-15015 August 1986 Affidavit of Pw Niles Reporting Results of Calculations Performed on Postulated Hosgri Event Data ML20206J4201986-06-24024 June 1986 Affidavit of Rc Herrick on 860624 Re Intervenors 860616 Application for Stay & RB Ferguson Affidavit Re Proposed Reracking of Spent Fuel Storage Sys ML20206J4751986-06-24024 June 1986 Affidavit of Wl Brooks Re Intervenors 860616 Application for Stay & RB Ferguson 860616 Affidavit Re Expansion of Spent Fuel Pools.Certificate of Svc Encl ML20206D7501986-06-18018 June 1986 Affidavit of Jd Shiffer Re Proposal to Increase Spent Fuel Storage Capacity,Approved by NRC on 860530.Intervenor Risk Allegations Refuted.W/Certificate of Svc ML20199D1271986-06-15015 June 1986 Affidavit of RB Ferguson Concluding That Spent Fuel Reracking at Facilities Presents Significant Safety Hazard to Surrounding Environ & Population & Poses Risk of Irreversible Contamination ML20099H6491985-03-0505 March 1985 Affidavit of a Jackson Supporting Jl Mcdermott & Tj O'Neill 840731 Petition Re Technical & Safety Significance of Issues Raised in 841115 Affidavit Re Flud Computer Program.Errors in Program May Lead to 100% Inaccurate Predictions ML20099H6261985-03-0404 March 1985 Affidavit of L Kinney Supporting Jl Mcdermott & Tj O'Neill 840731 Petition Re Charges of Matl False Statements by Util in Response to Allegations Jir 75-78 & 80 ML20099H6061985-02-24024 February 1985 Anonymous Affidavit Supporting Jl Mcdermott & Tj O'Neill 840731 Petition Re Concern Over NRC Response to 841127 Disclosure of Significant Engineering Errors & QA Violations in Design of Pipe Supports ML20099H7281985-02-22022 February 1985 Affidavit of Tj O'Neill Supporting Jl Mcdermott & Tj O'Neill 840731 Petition Re Matl Licensing Issues Resolved by NRC on Basis of False Statements & Omissions.Failure of Diablo Canyon Allegation Mgt Program Described.New Info Encl ML20099H5021985-02-0606 February 1985 Anonymous Affidavit Supporting Jl Mcdermott & Tj O'Neill 840731 Petition Re Deficiencies W/Engineering Practices on Large Bore Piping & Pipe Supports ML20099H5591985-02-0404 February 1985 Anonymous Affidavit Supporting Jl Mcdermott & Tj O'Neill 840731 Petition Re QA Problems in Drafting Dept,Hardware Deficiencies,Mgt Opposition to Reporting Deficiencies to QA & Failure to Follow Engineering Specs ML20099H5741985-01-23023 January 1985 Affidavit of Ho Hudson Supporting Jl Mcdermott & Tj O'Neill 840731 Petition Re Deficiencies in Cardinal Industrial Products Qa.Corrective Actions Did Not Address Matls Previously Installed.Supporting Documents Encl ML20099H7751985-01-23023 January 1985 Affidavit of Mc Thompson Supporting Jl Mcdermott & Tj O'Neill 840731 Petition Re Addl Concerns on Issues Examined in 850108 Interview.Supporting Documentation Encl ML20099H5271985-01-22022 January 1985 Affidavit of P Haffey Supporting Jl Mcdermott & Tj O'Neill 840731 Petition Re Allegations of Misconducting by Region V & of Util Matl False Statements Concerning Previous Allegations ML20099H6631985-01-21021 January 1985 Affidavit of Jl Mcdermott Supporting Jl Mcdermott & Tj O'Neill 840731 Petition Re NRC Mishandling of Previous Allegations.Fifteen New Allegations Listed ML20099H7541985-01-18018 January 1985 Affidavit of CC Stokes Supporting Jl Mcdermott & Tj O'Neill 840731 Petition Re Failure of NRC to Honor Rules of Allegation Mgt Program & Matl False Statements by Util in Response to Previous Allegations ML20107C4871984-11-0101 November 1984 Affidavit of Tm Devine Re Employee Concerns That Reactor Vessel Level Instrumentation Sys May Not Provide Reliable Readings ML20107C5011984-10-29029 October 1984 Affidavit of Lockert Re Const Qa,Licensee Character & Competence ML20107C4751984-10-22022 October 1984 Marked-up Affidavit of Mc Thompson Re Possible Fake Welds on Stanchions Holding Up Safety Injection Sys Lines in Unit 1 ML20098F9381984-10-0101 October 1984 Affidavit of Mj Jacobson & Tg De Uriarte,Signed Only by Tg De Uriarte,Re QA Program.Certificate of Svc Encl ML20093N2341984-07-30030 July 1984 Affidavit of Jl Mcdermott Re Need for Reinsps & Systematic Retraining of All Personnel at Facility ML20093K0621984-07-27027 July 1984 Affidavit of Dh Hamilton Re Location & Subsurface Geometry of Hosgri Fault & Tectonic Deformation in Region of Fault ML20093K0811984-07-27027 July 1984 Affidavit of Wh White Re Hosgri Fault Design Bases. Certificate of Svc Encl ML20093K0691984-07-26026 July 1984 Affidavit of SW Smith Re Regional Seismicity & Morgan Hill Earthquake ML20093J3481984-07-24024 July 1984 Affidavit of DG Bridenbaugh,Restating 810811 Affidavit Re Potential Hazards of built-up Fission Products Release. Certificate of Svc Encl ML20090A8501984-07-11011 July 1984 Affidavit of T Devine Notifying of Resignation of I Yin from Review Team Overseeing Plant Readiness for Commercial Operation ML20092B6621984-06-19019 June 1984 Affidavit of DA Rockwell Re Allegations of Mgt Harassment. Related Correspondence 1994-03-04
[Table view] Category:LEGAL TRANSCRIPTS & ORDERS & PLEADINGS
MONTHYEARDCL-99-123, Comment on Prs 10CFR50 & 72 Re Reporting Requirements for Nuclear Power Reactors & Draft NUREG-1022, Event Reporting Guidelines. Util Areas of Concern Includes ESF Actuations, Significantly Degraded Components & Historical Limitations1999-09-20020 September 1999 Comment on Prs 10CFR50 & 72 Re Reporting Requirements for Nuclear Power Reactors & Draft NUREG-1022, Event Reporting Guidelines. Util Areas of Concern Includes ESF Actuations, Significantly Degraded Components & Historical Limitations ML20205N4081999-04-14014 April 1999 Comments Opposing Proposed Rules 10CFR2,19 & 20 Re Proposed Repository at Yucca Mountain.Requests Information on How Much Radiation Being Released Now at Diablo & Hanford NPPs ML20205N4601999-03-21021 March 1999 Introduces K Schumann as Representative of Nuclear Waste Committee (Nuwic) of San Lius Obispo County.Informs That Nuwic & Nuclear Waste Management Committee Concerned with Transportation of Spent Nuclear Fuel Rods from Dcnpp ML20195E8841998-11-24024 November 1998 Petition for Mod to OLs to Require Plant Owner to Have Independent Contractor Evaluate Plant Safety Culture ML20236T3011998-07-24024 July 1998 Order Prohibiting Involvement in NRC Licensed Avtivities (Effective Immediately).Lh Brooks Prohibited for 5 Yrs from Date of Order from Engaging in NRC Licensed Activities ML20248C2261998-05-22022 May 1998 Comment Opposing Revised Proposed Rule 10CFR50 Re Protection & Safety Sys ML20129J4191996-10-18018 October 1996 Order Approving Application Re Corporate Restructuring of Pacific Gas & Electric Company by Establishment of Holding Company DCL-95-206, Comment Supporting Petition for Rulemaking PRM-50-61 Re Improving Fire Protection Regulations1995-10-0606 October 1995 Comment Supporting Petition for Rulemaking PRM-50-61 Re Improving Fire Protection Regulations ML20091P8721995-08-23023 August 1995 Comment Opposing Petition for Rulemaking PRM-50-61 Re Nuclear Energy Institute Proposed Amends on Fire Safety for All NPPs DCL-95-001, Comment on Proposed Changes to Reactor Pressure Vessel Integrity Rule 10CFR50.Endorses NEI Comments1995-01-0303 January 1995 Comment on Proposed Changes to Reactor Pressure Vessel Integrity Rule 10CFR50.Endorses NEI Comments ML20077M7521994-12-30030 December 1994 Comment Opposing Proposed Rule 10CFR50 Re Shutdown & Low Power Operation for Nuclear Power Reactors DCL-94-270, Comment on Proposed Rules 10CFR2,51 & 54 Re Rulemaking for NPP License Renewal.Endorses Comments & Changes Proposed by NEI 941208 Submittal1994-12-0808 December 1994 Comment on Proposed Rules 10CFR2,51 & 54 Re Rulemaking for NPP License Renewal.Endorses Comments & Changes Proposed by NEI 941208 Submittal ML20149H0851994-11-0404 November 1994 Initial Decision (Construction Period Recovery/Recapture).* Renewed Motion to Reopen Record 940808,denied.Served on 941104.W/Certificate of Svc ML20072L2651994-08-23023 August 1994 PG&E Opposition to San Luis Obispo Mothers for Peace Renewed Motion to Reopen Record.* Util Opposes San Luis Obispo for Peace Motion Based on Affidavit Stating No Evidence Found in Motion Re Flaw in Program.W/Certificate of Svc ML20072F0291994-08-12012 August 1994 Erratum to San Luis Obispo Mothers for Peace Motion to Reopen Record.* Intervenors Corrects Error in Renewed Motion to Reopen Record Re Application for License Amend to Extend Term of Operating License for Plant.W/Certificate of Svc ML20072B2651994-08-0909 August 1994 Comment Supporting Proposed Rule 10CFR26 Re FFD Requirements Concerning Random Drug Testing ML20072A5821994-08-0808 August 1994 San Luis Obispo Mothers for Peace Renewed Motion to Reopen Record Re PG&E Application for Amend to Extend Term of OL for Plant.* Motion to Reopen Record to Introduce Insp Rept Identifying Alleged Problems W/Plant.W/Certificate of Svc ML20071L2061994-07-26026 July 1994 Comment Supporting Proposed Rule 10CFR26 Re Changing Current Drug Testing Policies to Exclude All Personnel in nonsafety-related Positions ML20072B8481994-07-26026 July 1994 Comment Opposing Proposed Rule 10CFR26 Re Changes to FFD Requirements Concerning Random Drug Testing ML20071L1901994-07-20020 July 1994 Comments on Proposed Rule 10CFR26 Re Relaxing Rule on Drug Testing of Employees Working at NPP DCL-94-134, Comment Supporting Petition for Rulemaking PRM-50-60 Re Amend to 10CFR50.54 by Changing Frequency W/Which Each Licensee Conducts Independent Reviews of Emergency Preparedness Program1994-06-27027 June 1994 Comment Supporting Petition for Rulemaking PRM-50-60 Re Amend to 10CFR50.54 by Changing Frequency W/Which Each Licensee Conducts Independent Reviews of Emergency Preparedness Program DCL-94-135, Comment Supporting Petition for Rulemaking PRM-50-59 Re Proposed Amend to 10CFR50.54(p) Concerning Frequency W/Which Licensee Conducts Independent Reviews of Security Programs1994-06-27027 June 1994 Comment Supporting Petition for Rulemaking PRM-50-59 Re Proposed Amend to 10CFR50.54(p) Concerning Frequency W/Which Licensee Conducts Independent Reviews of Security Programs ML20064D1791994-03-0707 March 1994 Pacific Gas and Electric Co Reply in Opposition to San Luis Obispo Mothers for Peace Motion to Reopen Record.* Motion to Reopen Record Denied.W/Certificate of Svc ML20064D1961994-03-0404 March 1994 Affidavit of Mj Angus Re Motion to Reopen Record ML20063L5721994-02-25025 February 1994 San Luis Obispo Mothers for Peace Re Util Application for License Amend to Extend Term of Operating License for Plant.* Advises That Record of Proceeding Should Be Reopened to Consider Insp 93-36 Re Util Surveillance of Asw Sys DCL-94-021, Comment Supporting Petition for Rulemaking PRM-21-2 Re Commercial Grade Item Dedication Facilitation1994-01-26026 January 1994 Comment Supporting Petition for Rulemaking PRM-21-2 Re Commercial Grade Item Dedication Facilitation ML20059D2431994-01-0707 January 1994 Package of Intervenor Exhibits Consisting of Related Correspondence Not Admitted Into Evidence.Related Correspondence ML20062N0001993-12-30030 December 1993 PG&E Reply Findings of Fact & Conclusions of Law.* Mothers for Peace Proposed Findings & Conclusions Do Not Provide Any Supportable Rationale to Change Findings & Conclusions Previously Proposed by Pg&E.W/Certificate of Svc ML20058P3931993-12-22022 December 1993 NRC Staff Findings of Fact & Conclusions of Law in Form of Initial Decision.* Certificate of Svc ML20058K7491993-12-0202 December 1993 NRC Staff Motion for Extension of Time.* Board Has Extended Filing Time for Util Until 931230.W/Certificate of Svc. Served on 931206.Granted for Board on 931203 ML20058K8771993-12-0202 December 1993 NRC Staff Motion for Extension of Time.* Requests That Board Extend Date for Staff to File Findings Until 931222. W/Certificate of Svc ML20059M5291993-11-19019 November 1993 Applicant Exhibits A-21,A-22,A-24,A-25,A-26,A-29 & A-F1, Consisting of Related Correspondence Not Admitted Into Evidence.Related Correspondence ML20058E0741993-11-19019 November 1993 San Luis Obispo Mothers for Peace Proposed Findings of Fact & Conclusions of Law Re Licensee Application for License Amend to Extend Term of Operating License for Plant.* W/ Certificate of Svc ML20059E8931993-10-28028 October 1993 Memorandum & Order (Motion for Extension of Time).* San Luis Obispo Mothers for Peace 931018 Request for two-wk Extension of Time to File Proposed Findings of Fact & Conclusions of Law Granted.W/Certificate of Svc.Served on 931029 ML20059E8531993-10-27027 October 1993 NRC Staff Response to Board Memorandum & Order Re Extension of Time.* Staff Believes That San Luis Obispo Mothers for Peace Has Shown No Good Cause for Requesting Extension to File Proposed Findings of Fact.W/Certificate of Svc ML20059E8631993-10-25025 October 1993 Pacific Gas & Electric Co Response to Motion for Extension of Time.* Util Does Not Agree W/Board Assessment That Mothers for Peace Request Appears to Be Reasonable But Will Not Oppose Request.W/Certificate of Svc ML20059B2191993-10-19019 October 1993 Memorandum & Order (Responses to Motion for Extension of Time).* Board Believes Intervenor Request for Extension of Time to File Proposed Findings of Fact Appears Reasonable. W/Certificate of Svc.Served on 931019 ML20059B1071993-10-18018 October 1993 San Luis Obispo Mothers for Peace Motion for Extension of Time for Filing Proposing Findings of Fact & Conclusions of Law.* Requests Extension of Two Wks or Until 931119 to File Proposed Findings of Fact.W/Certificate of Svc ML20057D0531993-09-23023 September 1993 Notice of Appearance.* Notice Given That Undersigned Attorney Enters Appearance in Listed Matter & Listed Info Provided.W/Certificate of Svc ML20057B0401993-09-14014 September 1993 NRC Staff Reply to PG&E Response to Staff Motion to Amend Protective Order.* NRC Staff Moves Board to Adopt Language Requested in 930817 Motion as Stated.W/Certificate of Svc ML20056G4891993-08-30030 August 1993 Pacific Gas & Electric Co Response to Motion to Amend Protective Order.* Staff Asks That Protective Order Be Clarified by Adding New Footnote to Paragraph 3 of Order. W/Certificate of Svc ML20059C7361993-08-24024 August 1993 Intervenor Exhibit I-MFP-88,consisting of NRC Insp of Diablo Canyon Units 1 & 2 IR 05000275/19920161993-08-24024 August 1993 Intervenor Exhibit I-MFP-137,consisting of Insp Rept Re Dockets 50-275/92-16 & 50-323/92-16,dtd 920707 IR 05000275/19930111993-08-24024 August 1993 Intervenor Exhibit I-MFP-26,consisting of Re Insp Repts 50-275/93-11 & 50-323/93-11 ML20059M1381993-08-24024 August 1993 Staff Exhibit S-1,consisting of Re 920519 Enforcement Conference IR 05000275/19920131993-08-24024 August 1993 Intervenor Exhibit I-MFP-140,consisting of 920416,mgt Meeting Repts 50-275/92-13 & 50-323/92-13 ML20059D0841993-08-24024 August 1993 Intervenor Exhibit I-MFP-139,consisting of Insp Rept Re Dockets 50-275 & 50-323,dtd 920417 IR 05000275/19920261993-08-24024 August 1993 Intervenor Exhibit I-MFP-118,consisting of Notice of Violation & Insp Rept Re Docket 50-275/92-26 & 50-323/93-26,dtd 921113 ML20059M5041993-08-24024 August 1993 Staff Exhibit S-2,consisting of Re Notice of Violation ML20059M8621993-08-24024 August 1993 Intervenor Exhibit I-MFP-35,consisting of Rept, Self- Evaluation of Diablo Canyon Power Plant, Dtd Jul 1993 1999-09-20
[Table view] |
Text
...
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
r o
O i
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
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
- 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.
l l
1