ML19208C321
| ML19208C321 | |
| Person / Time | |
|---|---|
| Site: | Zimmer |
| Issue date: | 08/16/1979 |
| From: | Barth C NRC OFFICE OF THE EXECUTIVE LEGAL DIRECTOR (OELD) |
| To: | |
| References | |
| NUDOCS 7909260058 | |
| Download: ML19208C321 (8) | |
Text
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August 16, 1979 NRC PimLIC DOCUMEW WND STATES OF AI' ERICA
!!UCLLAR REGULATORY CO:'/11SSION gg ~W~r%.
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Docket lio. 50-358 C0i1 patly, et al.
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Ne' NRC STAFF INTERROGATORIES TO ROBERT HOFSTADTER, 312 LEE STREET, EVANST0il, ILLINDIS 60202 REGARDII'G T1I AT11 VALLEY PO'.-!ER PROJECT CONTENTI0:1 fiU1BER 17 Pursuant to 10 CFR hP. 7405 and the Order of the Licensing Board dated August 7, 1979, the NP,C Staff hereby requires Robert Hofstadter, a witness for Intervenor, Miami Valley Power Project (MVPP) to answer separately and fully, in writing and under oath or affirmation, the following Interrogatories on or before August 30, 1979. All Interrogatories relate to liiami Valley Power Project Contention 17 which is set forth below:
Contention 17 Fire insulation material which is beirg used to protect the cables in the cable trays from fire is inadequate to protect the cables in light of the cable tray installation design and cable tray load.
The tests of the fire insula tion material were improperly performed in that conditions which will exist during operation were not adequately simulated.
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1(a).
Identify by time of day, date of month, year and geographic location where the " improperly performed" tests of fire insulation naterial were performed.
1(b).
Who (what corporation or organization) perforned the tests referred to above?
1(c).
Who by name, title, position and corporate affiliation was present during the tests?
1(d).
Describe, step by step, how the tests were performed, including a description of the physical and mechanical equipment used to perform the tests.
1(e).
Describe the design basis scenario for which cable fire insulation protection is required for reactor safety, s
1(f). Specify which plant cables require plant fire protection for reactor safety and why they are essential.
2.
Identify with particularity which test (or tests) was improperly performed and describe the impropriety alleged to have occurred.
t 3.
Describe how the design of the cable trays affects the performance of the fire insulation material.
4.
Describe how the " cable tray load" affects the performance of the fire insulation material.
5.
What " conditions... will exist during operation [that] were not adequately simulated" in the tests?
1015 134 W
6.
Itow will the non-simulated operation conditions affect the ability of the cables to be protected from fire and to perform their required function to transmit their required signals or energy?
7.
What is the basis of the assertion that the test results were not documented (page 2, MVPP filing dated April 30,1979)?
8.
Identify the applicable standards for standard methods of fire tests of materials.
9.
Set forth your educational background and work experience, including your employment with Uiderwriters Laboratory.
10.
Describe with detail any experience which may qualify you as an expert on fire testing of material and fire testing of electrical cables.
11.
Summarize in meaningful detail your testimony regarding Contention fiumber 17.
12.
Identify by date, author cad title all graphic materials of any kind which substantiate in any way Contention 17.
13(a).
llave you read, reviewed or seen Underwriters Laboratory Inc. File R 8758, Project 78 f(K 5345, September 6,1978, Report on Cable Raceway Protection Systems Fire Test Investigation?
13(b).
Do you have a copy of the aforesaid report in your possession or control?
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_4-13(c).
If the answer to 13(a) or 13(b) is yes, then identify by page and paragraph the parts of said report that substantiate the allegation that the tests were improperly performed and describe the alleged improprieties.
13(d).
Do you have any graphic material other than the aforesaid report which demonstrate any impropriety in testing fire insulating material?
14.
Identify by trade name and manufacturer the fire insulation material referred to in Contention 17.
15(a). State in detail the basis for MVPP's allegation that Kaowool caught fire when it was tested (Tr. p.175, line 19).
15(b). At what temperature and pressure did the Kaowool catch fire?
15(c).
Identify the test during which the Kaowool caught fire.
16(a).
Describe your position and role in the Underwriters Laboratory testing of Kaowool.
16(b).
Did you witness any of the tests identified in Interrogatory llumber l?
16(c).
Did you participate in any of the tests identified in Interrogatory Number 1 and if so describe your participation?
1015 136 16(d). Did you participate in the analysis of any of the tests identified in Interrogatory flumber 1 and if so describe your analysis?
- 17. Are there industry standards for fire tests of material and if so identify them?
18.
If there are industry standards for fire testing material, did the tests identified in Interrogatory fiumber 1 conform to these standards?
19.
If the answer to Interrogatory 18 is not categorically affirmative, identify in all respects how the tests failed to conform to the aforesaid industry standards.
- 20. Set forth the results, in terms of fire protection and loss of cable function, of the tests identified in response to Interrogatory fiumber 1.
21.
MVPP's filing of April 30, 1979, states that "Edwin ilofstadter, in a confidential manner, secured details of a test of the fire insulation material which show the material failed to pass the test."
(a). What relation is Edwin Hofstadter to you?
(b).
Do you have, or have you had, access to the details of a test where the material failed to pass the test?
(c).
If the reply to Interrogatory 21(b) is affirmative, then identify the test and set forth these details.
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. (d).
Describe in detail the " test performance and standards" that the fire insulation material was supposed to pass.
22.
Describe fully the environmental conditions, including mitigating facilities such as sprinklers and alarms, which you allege would properly test Kaoviool and identify the deficiencies in these environmental conditions, including mitigating facilities, which made the tests improper; also identify which tests these were.
23.
For each of the tests identified in response to Interrogatory flumber 1 above, describe in detail the cables that were tested, i.e., size, length, type of material, load carried, etc.
24.
For each of the tests identified in response to Interrogatory 1, identify the type of cable tray used.
25.
Identify by name and address all persons known to you to support your allegations that the tests were improperly performed or that Kaowool failed to pass any of the tests identified in response to Interrogatory flumber 1.
Respectfully submitted,
/
k.cnd Charles A. Barth Counsel for flRC Staff Dated at Bethesda, Maryland, this 16th day of August,1979.
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UllITED STATES OF /JERICA NUCLEAR REGULATORY COMMISSION
~BEFORE THE ATOMIC SAFETY AND LICENSING COARD In the Matter of
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CIf;CIflNATI GAS A'iD ELECTRIC
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Docket No. 50-358 COMPANY, et al.
(Wm. H. Zir:::ier riuclear Power
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Station, Unit No.1)
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CERTIFICATE OF SERVICE I hereby certify that copies of "f;RC STAFF INTERROGATGRIES TO ROBERT HOFSTADTER, 312 LEE STREET, EVANSTUN, ILLINDIS 60202 REGARDII;3 MIAMI VALLEY POWER PROJECT CONTEi1 TION HUMBER 17" 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 by deposit in the fluclear Regulatory Commission internal mail system, this 16th day of August,1979:
Charles Bechhoefer, Esq., Chairman
- Leah S. Kosik, Esq.
Atomic Safety and Licensing 3454 Cornell Place Board Panel Cincinnati, Ohio 45220 U.S. fluclear Regulatory Ccmmission Washington, D.C.
20555 W. Peter Heile, Esq.
Assistant City Solicitor Dr. Frank F. Hooper Room 214, City Hall School of Natural Resources Cincinnati, Ohio 45220 University of Michigan Ann Arbor, Michigan 48109 Timothy S. Hogan, Jr., Chairman Board of Conaissioners Mr. Glenn 0. Bright
- 50 Market Street Atomic Safety and Licensing Clennont County Board Panel Batavia, Ohio 45103 U.S. Nuclear Regulatory Commission Washington, D.C.
20555 John D. Woliver, Esq.
Clermont County Corr:aunity Council Troy B. Conner, Esq.
Box 181 Conner, Moore and Corber Batavia, Ohio 45103 1747 Pennsylvania Avenue, N.W.
Washington, D.C.
20006 4
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2-William J. fioran, Esq.
Atomic Safety and Licensinci General Counsel Aopeal Board
- Cincinnati Gas & Electric Company U.S. fluclear Regulatory Coninission P.O. Box 960 Washington, D. C.
20555 Cincinnati, Ohio 45201 Docketing and Service Section*
Atomic Safety and Licensing Office of the Secretary Board Panel
- U.S. fluclear Regulatory Ccm ission U.S. fluclear Regulatory Comission Washington, D. C.
20555 Washington, D. C.
20555 CO h / 7xq!
Charles A. Barth Lounsel for f1RC Staff a
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