ML19209A353
| ML19209A353 | |
| Person / Time | |
|---|---|
| Site: | Trojan File:Portland General Electric icon.png |
| Issue date: | 08/27/1979 |
| From: | PORTLAND GENERAL ELECTRIC CO. |
| To: | |
| Shared Package | |
| ML19209A316 | List: |
| References | |
| NUDOCS 7910030643 | |
| Download: ML19209A353 (6) | |
Text
.
UNITED STATFS OF AMERICA NUCLEAR REGULAL RY CO!CIISSION BEFORE THE ATOMIC SAFETY AND LICENSING BOARD In the Matter of
)
)
PORTLAND GENERAL ELECTRIC COMPANY, )
Docket No. 50-344 et al.
)
(Control Building
)
Proceeding)
(Trojan Nuclear Plant)
)
ARGUMENT AND DOCUMENTATION IN SUPPORT OF MOTION FOR
SUMMARY
DISPOSITION OF C_O_NSOLIDATED IMTERVENORS' COliTENTIONS t!OS. 2A AND C.
I.
The Contentions At the prehearing conference on March 29, 1979, Consolidated Intervenors' Contentions Nos. 2a and c were admitted (Tr. 3103) and read as follows:
Licensee has not shown that there will be adequate fire protection at the Trojan Plant during modifi-cations in the following areas:
a) fire protection of cable penetrations; c) with respect to welding, particularly in the Cable Spreading Room.
II.
Material Facts As To Which There Is tio Genuine Issue To Be Heard A.
The proposed nodification work will require some welding and cutting in the vicinity of the cables that pass through the Control Building west (R line) wall that separates the Control Building from the Turbine Building.
- Welding, using arc welding equipment, will take place on the west side of that wall (in the Turbine Building) to join the steel plates to be bolted thereto.
In addition, electric 1086 0B7 7810 oso di(/:3;
. arc or oxyacetylene cutting torches will be used to trim two inches from a steel girder supporting the floor in the Turbine Building at el. 93 ft.
B.
All cable penetrations through fire protection barriers at the Trojan Plant are sealed with silicene foam to maintain the integrity of those barriers in accordance with the requirements of the N3C Operating License.
These siliccne foam seals will not be affected by the
" splatter" resulting from welding or the " slag" resulting from cutting.
C.
The cables in the Trojan Plant are covered with layers of self-extinguishing insulation and jacket material.
The aforementioned.vid:Lg and cutting activities pose no risk of Zire to chose cables.
D.
All cables in the vicinity of any welding or cutting activities during the modification work will be covered by non-combustible fire protective blankets, which will prevent damage to the cables from welding splatter and cutting slag.
These blankets will be either Clarenont Weld Shield style no. 800-24 or Fabri Cote 1584-white.
Documentation of fire tests on such blankets establishes their acceptability.
E.
In addition to the non-combustible blankets, standard Plant fire protection measu es, including the obtaining of a Welding and Cutting Permit and compliance with the requirements thereof, will be taken during any welding or cutting in the vicinity of cable penetrations.
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. F.
Any additional flammable materials, such as rags, etc.,
necessary to perform the modification work in the vicinity of cable penetrations will be kept in self-closing con-tainers and removed each day.
Wood form materials will be removed before any welding or cutting operations in their vicinity are begun.
G.
All other welding necessary to perform the modification work will be done in accordance with st:ndard Plant proce-dures which will protect against any risk of fire from those activities.
These material facts are supported in tho attachca affidavit of Mr.
E.
W.
Edwards on Consolidated Intervenors
~ ]ntentions 2A and C.
III.
Discus,sion The attached affidavit of Mr.
E.
U.
Edwards shows that during the modification work adequate fire protection measures will be taken in the vicinity of cable penetrations and with respect to all welding.
In explaining its Contentions 2a and c at the preheering conference, CI indicated that its primary concern was with the ability of protective blanketc to orotect cables in the Plant against fire during modification work.
(Tr. 3101)
That con-cern was reaffirmed in CI's response to Licensee's Interrogatory 1 (First Set).
CI also alleged that welding work, additional flammable materials, and workers unfamiliar with "necessary precautions" could contribute to an increased risk of fire to
\\086 089 cable penetrations in the vicinity of modification work.-*/
These concerns have been fully addressed in the affidavit of Mr. Edwards, and there are no disputed facts relating thereto.
CI's responses show that it misunderstands the nature of the work being done and the fire protection measures amployed at the Trojan Plant.
As the attached affidavit of Mr. Edwards shows (paragraph 6), a cable penetration itself is not subject to a risk of fire.
A cable penetration is simply an opening in a wall to allow cable trays or conduits to pass through.
If a cable penetration in the Plant is located in a structure which is a fire barrier, it is sealed with silicane foam in accordance with the requirements of the NRC Operating License.--**/
These silicone foam seals will not be affected by the " splatter" resulting from welding or the " slag" resciting from cutting.
The only modification work which might present an in-creased risk of fire in the vicinity of any cable penetrations
-*/
CI has identified no other specific concerns relating to these contentions.
In fact, CI has admitted that it is not contend-ing that fire protection measures for cable penetrations durinc modification work are inadequate; instead, CI is contending that Licensee has not shown that fire protection measures dur-ing modification work will be adequate.
(Response to Staff C2-2(a)).
CI failed to respond to Licensee's follow-up In-terrogatory 15 (Second Set) which was addressed to its con-cerns, and the bases therefore, expressed in its earlier responses.
CI is also in default on the Board's Order of June 5 ordering it to respond to that interrogatory.
- / In its response to Licensee 's Interrogatory 1(a) (iii), CI asserted its " understanding that PGE cable penetration fire stop tests have not been completed."
As part of the on-going program to evaluate fire protection at the Plant, the Licensee is providing additional information to the NRC in a number of areas.
This program, however, is not related to the Control B;.ilding proceeding.
The only relevant fact is that the Plant satisfies the requirements of the NRC Operating License.
1086 090 is welding and cutting work to be done on the west side of the R line wall.
(Affidavit, paragraph 5)
As the affidavit shows (paragraphs 7-10) all welding and cutting work will be done in accordance with standard Plant procedures which will protect fully against any risk of fire from those activities.
Among other things, those procedures require that any flanmable material in the vicinity of the welding and cutting be moved or protected, and that properly equipped personnel (a fire watch) trained in fire protection measures be present during -
and after - the welding and cutting work.
CI misunderstands the reason for covering cables with protective blankets during weldic; and cutting work.
As the affidavit shows (paragraph 7) splatter and slag from the welding and cutting work will not cause cables in the Plant to ignite.
The purpose of the blankets is to prevent the splatter or slag from these activities trom melting into the insulation and damaging the cables.
(Id.) In any event, the ability of the blankets to perform their function has been documented, and that documentation has been supplied to all parties - including CI - by Licensee.
(Id.)
Thus CI's concern that the ability of the blankets to protect against fire be proven has been fully satisfied.
As the affidavit states (paragraph 11), there is no weld-ing planned in the Cable Spreading Room.
CI has refused to answer Licensee's and the NRC Staff's discovery requests which sought to learn what other welding CI had in mind.
In any event, welding necessitated by the modification work will be 1086 091
_s_
done in accordance with the Plant procedures described in the affidavit (paragraphs 7-10), which assure protection against any risk of fire from welding.
Since no factual issues have been raised by CI which contradict the facts recited in Mr. Edwards' affidavit, the motion for summary disposition related to CI's Contentions Noc.
2a and c should be granted as a matter of law.
As noted above, CI has refused to respond to relevant interrogatories filed by Licensee and is in clear default on the Board's Order of June 5, 1979, entered pursuant to 10 CFR S2.740, ordering it to respond to Licensee's interrogstories.
Therefor the Board should, pursuant to 10 CFR S2.707(a), " find the facts as to matters regarding which the order [ issued pursuant to 2.740] was made in accordance with the claims of the party obtaining the order.
Thus, the Board should now find in favor of Licensee, and in a manner adverse to CI, as to the facts set out in the affidavit of Mr. Edwards.
1086 092