ML19210E128
| ML19210E128 | |
| Person / Time | |
|---|---|
| Site: | Skagit |
| Issue date: | 10/18/1979 |
| From: | Stoker B AFFILIATION NOT ASSIGNED |
| To: | |
| Shared Package | |
| ML19210E129 | List: |
| References | |
| NUDOCS 7911290459 | |
| Download: ML19210E128 (17) | |
Text
" ~
D hb NUCLE AR REGULATORY COMMISSION
/
,si i
+[
IN THE MATTER OF:
CINCINNATI GAS & ELECTRIC COMPANY (Wm. H. Zirver Nuclear Power Plant)
Docket No 50-358 Place - Cincinnati, Ohio Date -
Thurnday, 15 November.J79 E 8' 3394 - 3608 g
4.
at -
425401 n###;;
s ACE -FEDERAL REPORTERS,INC.
OfficalReporters 444 North Capitol Street Washington, D.C. 70001 NATIONWIDE COVERAGE DALLY 7 9112 9 0 +5 7
~
3394 CR8073 1
UNITED STATES OF AMERICA 11/15/79 2,
M. BLOOM,
{
NUCLEAR REGULATORY COMMISSION
- NCON, PARKER 5
x i
l 7p 1 In the ifatter of:
e i!
CINCINNATI GAS & ELECTRIC COMPANY
- Docket No. 50-358 i
S, Utn. II. Zimmer !!uclear Power Plant) :
i
'/
x 8
Courtroom 805 j
U. S. Federal Coprthouse e
5th & Walnut Streets l
Cincinnati, Ohio 10 i i
Thursday, 15 November 1979 I
11 hearing in the above-entitled matter was convened, ti pursuant to adjournment, at 9:00 a.n.
13 l BEFORE:
!4 CHARLES E2CHHOEFER, Esq., Chairman Atomic Safety and Licensing Board, 15
- l GLENN O. BRIGHT, Member.
16l l
DR. FRANK F. HOOPER, Member.
17 '
APPEARANCES:
10 4
On behalf of the Applicant:
10 TROY B. CONNOR, Jr., Esq. and MARK J. WETTERIIAIIN, 20 Esq., Connor, Moore & Corber, 1747 Pennsylvania Avenue, N. W., Washington, D. C.
20006 l
21 On behalf of the Nuclear Regulatory Comrtission:
22 CIIARLES A. BARTH, Esq., United States Nuclear Regulatory Commission, Regulatory Staff, 23 i Washington, D. C.
20555 24 25
[l l425 02 i
I
jf 3395 wel 1j APPEARANCES: (Continued) l 2l On behalf of Intervenor, Miami Valley Power Project 5l JAMES FELDMAN, Esq., and TAWN A. FICIITER, Esq.,
216 East Ninth Street, Cincinnati, Ohio 45202.
i i
On behalf of Intervenor Fankhauser:
0t i
DR. FANKHAUSER, pro se.
7 9
6 I
s ll 10 11 12 13 14,
TC I
i 16 17 18 g
19 20 21 22 23 4 24 25 l
A25003
1 3396 l
wel l,
C_ O,N T,E,N T S_
2!;
WITNESSE3:
DIRECT CROSS REDIRECT RECROSS BOARD Il 3f E. A. Borgmann
)
Robert E. Cotta )
3413 3426 3602
- i.! Melvin fl. Abrams) i
>[
F. A. Mz.ura 3495 3498 3534 3537 3524 i
s l
O S
EXHIBITE,:
IDENTIFIED RECEIVED 10 '
Applicant's 7 (Rev. 13) 3411 3417 11 Applicant's 8 (Rev. 14) 3411 3419 l
12.
(Documents added to Applicant's 7) 3418 i
13 j tu <I 15 !
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n; I
isi s
- sl 2e '
I 21 22 i i
t y
24
- l 25 i l
1425 0~04 l'
[
lWEL/wel 1]
3397 ERQQEEglEQE 2
CHAIRMAN B3CHHOEFER:
Good morning, ladies and 0
gentlemen.
1 li l
4h Before gcing on the record this morning Ms. Fichter 5 l had a conversation with me asking advice as to when she sh1uld 5
present a certain motion or request.
I advised her that she 7
should do so at the time when I ask for procedural requests 8
or opening natters.
9 I will now ask the parties -- it's our intent this 10 l morning to begin with the Applicant's panel on electrical 11 insulation -- or insu:.ation of cables, but whether or not wt 12 are through with that panel at the beginning of this afternoon 13 we will shift over to hear Mr.
Maura, the Staff's witness on 14 control rods.
15,
After that, if we still have more of the Applicant's tc panel we will resume.
17 I now ask whether there is any preliminary matter 18 which any of the parties wish to raine?
g 19 MS. FICHTIR:
Yes.
I'd like to request that Doug i'
20 Gillman, who is seats.d on my right here, be allowed to cross-i 2;
examine the Applicant's witnesses.
Mr. Gillman has an hB in p' Biology from Oberlin College.
He has had one year of 22 g;
electrical engineering technology at Ohio College of Appliei l
?4l Sciences.
He's comp:.eted a course in differential equations 25 the University of Cincinnati.
And he has thoroughly studied at
+
y
~1425 005
.u wel 2 l
3398 l
g' all the materials in this contention and has further familiar-ized himself in this area by studying textbook scientific 1
2rticles and conforring with various professors in this area.
4 CHAIRMAN SECHHOEFER:
Do the Applicant or Staff r
have com: tents?
I assume this request is made pursuant to f
10 CFR Section 2.72 3?
3 I
MS. FICHfER:
Right.
7 I
MR. CONNOR:
Of course that section, your Honor, 8
specifies that it's a person who has scientific or tec.%1 cal g
training or experiesce to participate in behalf of the party, g
andlit has to show that the individual is qualified by 11 scientific or technical training or experience to contribute 12 i
to the development of an adequate decisional record, that g
the individual has read the testimony which he intends to g
examine or cross-examine, that the individual has prepared g
himself to conduct a meaningful and expeditious examination 16 I
17 I or cross-examination, and it must be limited to those areas within the expertise of the individual.
We submit that none of those elements are present in the representations of MVPP's counsel.
l The fact that the gentleman has an AB degree from someplace, and one fear of engineering technology -- whatever 23ll that may be -- certainly does not qualify him to conduct cross-examination ia tha area of fire protection, as in indicated is necessary from the testimony, or in electrical j
1425 006 1i
wel 3 3399 lf engineering consider;ttions, where there are genuine experts present to testify.
J l Sacondly, it remains our position that MVPP has 4
abandoned this contention, not only generally by their S,'t failure to pursue ic, but secondly because of their failure 0
tG provide the documantation as to what they world use for 7!
cross-examination.
9 I would note that it does not appear on the 9[
record that this morning Mr. Gillman I believe went around to passing out copies o.? two sheets of paper, which on their 11 face appear to relate to this fire protection cable tny 12 [
fire test, as it's stated on both documents, conducted by t
12l the Portland Cement hasociation.
1-, f This would indicate to be the type of thing he tcf would conduct as cross-examination.
Since he did not meet 15 y the mandate this Board delivered to MVPP in view of their d
17 h past failures, certainly he would not be qualified -- or it te il MVPP would not be qualified to cross-examine in this area, 4
19[
because they have failed to meet the conditions precedent t
20 that the Board properly put upon them.
21[
Finally, if MVPP had intended to do something like 22 P this, they should have brought this up in a motion prior to d
P 22 ;!
the hearing, rather than waiting until the last minute to 4
24 :]
do it.
el 23; Now, it :asy be -- we noticed yesterday the 'long 4
ow
~
~
l425 007
.i wel 4 3400 1
pauses while Mr. Gil!. man was conferring with counsel tc give 2
them questicas to ask, which took a great long time yesterday--
i 3,
and parhaps it might even speed up the hearing.
However, he 4
is not qualified under the Commission's regulations or this i
5[
2 card's ordar, and for that reason we feel he cannot be t
G[
permi'ted.
7 M3. FICHTER:
It was my understanding that we s
had to give documents that we had in our possession at the t
9, time to she applicaat.
I didn't --
10 i CIIAIRMAN EECHHOEFER:
That's correct.
I
,;j MS. FICHTER:
And we've had this for 1-1/2 days.
jg CIIAIRMAN EECHHOEFER:
Mr. Barth, do you have a 13 comment?
I f
3, l MR. BART11:
Yes, your Honor.
g I fully aupport everthing counsel for the Applicant
?
16 said, with the small exception that if the Applicant's i
witnesces testified in the area of differential equations 7
73 I should'certainly concede that this' man may cross-examine 10 l in that area.
79 He obviously is not qualified under the Agency's
.1 regulaticas.
The Appeal Board has considered this at great 22 length in Diablo Canyon in regard to the expert profferred 4
j by Businessmen for the Public Interest of Chicago.
, o_
Mr. Gillnan has not demonstrated, nor has his
,,1 i
c l
counsel demonstrated, the necessary qualif *. cations in fire
,c_
c I
L' 1425 008
3401 wel 5 I
protection of cable.s wrapoed with Kaowool.
He has demonstrated 2
no expertise in set:ing up or establishing or judging 2
experiments in fire protection.
He has shown no expertise 4
in knowledge of the plant, location of the cable trays, how fires can af' Ject them, what kind of protection is necessary.
3 He fully fails to meet any kind of modocum or
~
scintilla of Agency requirements to qualify as an expert 8
examinor.
S I would pcint out that the Staff sometime ago 10 served the Portland Cement test upon everybody.
It's been in 11 thei'r possesuion fo:: a long time.
If they felt it was 12 necessary to have an expert over and above the counsel, they 13 could have done so at the time, rather than this sandbag at 14 9:15 in the morning, in the middle of the hearing.
f5 It really defies any kind of notion of fairness 16l or justice, your Honor, or rightness.
I 17 1 I would point out, too, as the citation from 10 Vermont Yankee Supreme Court decision points out, that 19 Intervonors who do not carry their burden or respons'bilities i
20 have little or no rights whatsoever.
These people have no 2;
rights that : can see in this proceeding whatsoever, except 22 1 at yo,pr sufferance, to be here.
l 23 I would urge the motion be denied and that the 24l Very adequate and very able counsel that they have may i
25 [
proceed with cross-3xamination as she deems fit.
k ll' i:
1425 009
~ x.W wel 6 1
CHAIRMAN DECHHOEFER:
I have a couple of questions f
o here.
3f First, is there anything in these rules which 4{
even implies that the offer of a scientifically trained 3l person must be made anytime before the offer of the witness 3I himself, or the witnesses themselves?
I see nothing in this f
7 2.733.
3 MR. BARTH:
Sir, I did not refer to that as a 9
matter of regulation.
I refer to that as a matter of 10 subatantial native justice, rather than sandbagging like this 11 at this time.
This was well known, what is being offered, l
12 '
cnd your order of October 23 makes it very specific.
These 13 people must have some kind of responsibility to inform the i
14 !
parties of what they intend to do.
15 They did not provido us with their line of cross-iG examination.
They never served us with any list of documents, i
17 j and they have not yet been so served unless it's been served 10 in my absenen back in Washington, D.
C., pertaining to 19 !
cross-examination.
I s
20 l Now, we're talking here of substantial American
=
2!
justica.
We're not nit-picking on words, your Honor.
At
- 22l, this late date to offer a man whose only qualification is he f,
23l knows something about differential equations leaves something 24 '
to be desired.
1 i
25 il CFAIRMAN BECHHOEFER:
I heard something about
.c
[-
l425 610
f 3403 wel 7 electrical E
I!S. FIC; ITER:
-- engineering.
j i
1l CHAIBMAIT BECHHOEFER:
Yes.
4 11R. BAR'2H :
Sir, the qualification is in the area 5'
of heat transfarability, not conductivity of wires for I
electricity.
We're not here as electrical engineers.
We're c
i 7_
talking about the conductivity and ability of Kaowool to e!
resist the transfer of heat.
Of course, if he'd had a course in heat transfer it might be something different, but tc these, on the other hand, -are intervenore who allege that 11!
Kaowool will burn.
Kaowool is basically aluminum oxide.
12 That leaves something to be desired.
ja !
CHAIRMAN BECHHOEFER:
I had thought one of the 1;
issues was the amount of heat that one could expect to 15 emanate frou the cables themselves, in addition to the fire te '
heat.
That was ona of the areas of questioning yesterday.
liR. BARTH:
Sir, I do not wish to argue with the 17.
J 3g [
Board, but that is a separate issue which has become i
i confused with the issue of Kaowool.
You're talking abouc
- g !
20 reliability, systesa reliability, electronically.
This is 23 not something that --
CHAIRMAli BECHROEFER:
I was talking about the 22 ;
i 23 i amount cf heat that was present.
i liR. DARTH:
The amount of heat inside of the 24 a
cables.
- l y
)
it 1425 011
- 1
I 3404 wel 8 CHAIRMA'I BECIDIOEFER:
Anyplace.
4 IIR. BARTH:
The amount of heat which is produced
-l
'I by ne cables is uarelated to the ability of Kaowool to withstand outside heat, which is the subject of contention a
17.
0i CHAIRMA:4 EECHHOEFER:
Well, that's not what your witnesses said.
They said it was not substantial, but they Ei said it was not irrelevant or unrelated.
I I
ii MR. BARTH:
He said that the reliability of the i
10,
system 'vould not make a substantial difference from the i
11 l
' ntiernally generatied heat.
This is different than the i
I i
- 12. i ability of Kaowool to withstand external heat.
13 -
He have mixed up Kaowool as insulating material
- 14. ;
with reliability of the system.
Those are two different
- s !
areas.
16 i MR. CONNOR:
Mr. Chairman, to respond to your b
l a
py :'
question, wo do not suggest that there is any rule that says
- C that the motion must be duly made.
Of course, that's 19 l common legal practice.
But I think that there is a point 20 that you are overlooking.
21 These people totally failed to respond to our 22l interrogatories, number 3 of which was to identify all 1
23 individuals having expertise regarding contention 17 that i
24 l the Project has contacted, either directly or indirectly, i
25 or who has contacted the Project, directly or indirectly, H
s4 li 1425 012 i
3405 vel 9 I
regardin; Contention 17, and give a summary of any information 2
and/or opinien given by such individual with regard to the 3
merits od the contention.
4 This, of course, was sent out months ago on 6
August 26th.
And, of course, they did not respond to that.
5l Now, if uhere's no other reason in the case, their 1
7l failure to respond to the Commission's rules on discovery by i
0 identifying the exports that they were relying on -- if, 9
indeed, the rian is an expert -- certainly would disqualify to him now.
He is certainly not an electrical engineer, and 11 I agree uith everything Mr. Barth said.
12 The fact that tue questions had been allowed to 13 go beyond Kaewool does not mean that that would allow him i
14 i to come in an a witness on the limited issue of the efficacy 15 of Kaowool.
16 CHAIRMAN 3ECHHOEFER:
I don't. think he's trying 17 to be a witness.
18 MR. CONNOR:
He'd love to be.
19 In any e' rent, he does not meet the requirements 20 of 2.733, and that is the only basis for the Daard's 21 1 decision.
22 MR. BARTH:
If I may give further comment, Mr.
23 Chairman, Mr. Connor has brought up a rather, I think, 24 importan pof.nt.
Ia view of my (9mment to you about some 25{
kind of native American justice, the Staff asked Miami Valley 1
i 1425 013 i
- f vel 10 34C6 i
i uno do you have who knows anything about Contuntion 177 There was nc answer.
l We asked. them to identify any expert that they
'l
,i ]
know.
There was nc. answer.
it i
,i I am sit. ting here at 9:21 in the morning.
They l
walk in with --quot.es--our expert.
Mr. Gillman has been e
i'-l with these
- ople for some time and has had possession of i
e!
tne Portland Cement Association report, and he's had i
g !
possession of the Etaff documents.
i m!
Wa did everything humanly possible under American
- 3 [
just' ice and the Agency's regulations to find out:
Who do u
you have that knows anything about this, so that we may do g
this in an orderly, democratic, American way.
g, i I just strongly protest as I can that this gg
- ?.ndbag of hiding anybody who may know something about g
diffenntial equations is just act seemly, sir.
(The Board conferring.)
ll MS. FICHTER:
Mr. Chairman, before you rule, we g
g '; did not give Doug Gillman's name to the Staff or the 4
i applican, because we had no intentic,of using him as a y
21 ;8 witness.
And it was our understanding that thac was what l
t ase qu.istions wers related to, and we did not intend to 22 i
have him testify ao a witness.
g CHAIRMAN 3ECHHOEEER:
The Board has decided that 2=_ ] tre vill allow Mr. Gillman to conduct cross-examination, at
'l f:
d-F425 014 u
l l
3407 wel 11 least on the technical areas of the examination of the 2
Applicant's witnessas.
O We beliere it will expedite the proceeding.
If Hs. Fichter has to ask Mr. Gillman about every question, that 4
L'!
is likely to produce much more delay than if Mr. Gillman asks
!i questions himself.
We think it will expedite the proceeding.
L 7!
If it turns out that it isn't doing that, we may cut off Mr.
B:
Gillman'a examination.
i 3
B:2t I think we will let him begin, at least in the i
10 technical areas.
3 11j Ms. Fichter, I would assume, would ask questions 12i in any o*.her areas that you may have.
12 !
MS. FICHfER:
Okay.
I 14l MR. COWN")R:
Mr. Chairman, then we ask two things:
l 1r One, thai Ms. Fichter*be held directly responsible 15 l for his conduct in the event that he attempts to stray away.
17 CHAIRMAN BECHEOEFER:
That's what the rules say.
I i
10 MR. CONNOR:
But you haven't told her that, and i
19 che has a habit of :nisunderstanding the. King's English.
So 20 i I want to ma te that very clear.
t 21 l CHAIRMAN BECHHOEFER:
Yes, that's correct.
You 22f are responsible for Mr, Gillman's conduct of the cross-23 examination.
f 24h MR. CONNOR:
The other point I was going to make --
0 1
CITAIRMAN BECHHOEFER:
That's very clear from the 23
.I y
il 1425 015 h
,-.m..
j 3408 vel 12 1
1 rules.
-l MR. CONr.03:
The other point I was going to bring
- 1 up anyway, since this is a Board contention ~, and inasmuch as e
t yesterday was taher up by rather prolonged cross-examination,
'i again we are going to request that the Board begin the questioning of our panel onthe theory that more direct and
- !j!
7 !l straightforward questions could be asked, and the record made, I
6; so that it would be unnecessary to take all of these long i
0!.
pauses and wanderings around to try to get to various points.
i 10 {
This has been done in many other casos, and I think i: l it would be appropriate in this case, particularly in view i
12 of the factual situation here.
We would request that this t
12; order be followed.
14 !
MS. FICHTER:
I would object to Mr. Connor saying there were many long pauses yesterday.
I think there tg a d
1.- f were maybe two or three.
I don't believe there were many o
17 ;
long I3auses, at least not caused by myself, anyway)
Cause
- el by objections, maybe.
19l (The Board conferring.)
30 i CHAIRMAN DECHHOEFER:
The Board would prefer to 1
21 go with the usual order and have the parties conduct 22 questioning first.
The Board will try to fill in any gaps 23 that we see.
24 MR. ComOR:
I will ask the witnesses to take i
f the stand.
g; 1425 016 w
Ilit
l 3409 vel 13 i
I CHAIRMAN EECHHOEFER:
Have all of them been sworn?
" i:
o I can't remereber.
3 MR. CONNCR:
Let me say what we're going to do here
! because there's a technicality as to Revision 13 that I want
^I to clarily on the record, and see how the Board wants to S
handle it.
7 As we have previously stated in our notice to the 3
Board and the parties, as recently as our letter of October I
3 ] 30th, our witnesses will be Mr. Borgmann who, of course, is 10 the quarterback of the panel and the Company spokesman; Mr.
11 Melvin Abrams, Director of the Fire Research Department, 12 Construction Technology Laboratories of Portland Cement
'3 '
Association, the gentleman seated to my left; and the other i
M witness is Mr. Robert E. Cotta, Senior Electrical Project 5 h Engineer of Sargent re Lundy Company, the gentleman seated li 16 there on my right.
17 '
Their affidavits have been previously furnished l
10 to the Board, both trith the motion for sunstary disposition 19 f and again on September 28, 1979, all as noted in our letter 20 to the Board dated October 30, 1979.
21 The fire protection code and Revisions 1 through 12
- 22l, thereof, are already in the record as part of Applicant's i:
23l Exhibit 1.
l 24 The new and pertinent revisions are numbers 13 and U
25 14, which hat /e heretofore been sent to the Board and the 6i parties on July 13, 1979 and August 31, 1979,. respe ctively.
1425 017 I
3410 I
ldsp 1
Mr. Barth yesterday offered Revision 13 as part l
d 4spl 2]
cf the staff 's evic'.eace, which has now been physically d
fis wel
- p incorporated into the transcript of. the record following i
,[
transcript page 32'4.
!. I 3 j, We would note, however, that we have checked this U-3j!
revision 13 as it cpoears there, and apparently in xeroxing, d
7 N charts 23 ard 57 were inadvartently omitted.
3l I don't t.hink they have any particular probitive i-i value, and they are in the copies we sent to the board and g
Il gl parties.
I I'
gg We also rent to the board and parties alcng i
with Revisicn 13 a correction page which was included in it
- g dated the same date as it was transmitted, July 13, 1979.
g!
i g,l This document also was not included in the staff's offer
.w-yesterday.
So we would ask the board how it would prefer to g
have this marked; since everybody already has a copy, it 7
i l
might be the simplest way simply to mark Revision 13 as 18 s,
amended and corrected as Staff's Exhibit -- Applicant's 3g Exhibit 7 and revision 14 as Applicant's Exhibit 8 for
.n ;
a, identification for purposes of clarity in the record.
But here again we can do this any number of ways, and I would simply ask the board how it would prefer it.
(Board conferring.)
CHAIRMAN BECHHOEFER:
The board agrees that the
, a_.
c IL ll 1425 018 i
I 3411 l
,t
. i dap2
]
method 2cu just proposed is fine.
The Exhibit -- the revised 1
't
.l endment 1:- I think would be better as a whole document Am 2
which -- rather than, I guess, two.or three pages separate,
'. p isolated frc.m every.hing else.
?
They wil. appear in the record twice then, but
- . P that not too significant.
_s 9
~/
So is your --
l b l Mk. CONNOR:
And with that introduction, I would i
i, ask that Revision 13 as described be marked for identification f
10 3 as Applicant's Exhibit 7 and Revision 14 be marked for 3 ;
,]'t identification as Applicant's Exhibit 8.
And Mr. Wetterhahn I
12j will give copies to the reporter at this time.
Everybody i
- 3 i else has received, as far as I know, copies.
I g l:
CHAIRMAN BECHHOEFER:
Any objections to this?
I
'iS. FICHTER:
No objection.
,o o g.)
MR. CCUh0R:
That is'just for identification.
Il g {j CHAIRMAN BECHHOEFER:
Without objection, that is I
so ordered.
Lo J I
- g I (The above-mentioned document, 3g Revision 10., was marked as i
i f
Applicant's Exhibit 7 for
, i 22 ;
identification. )
l (The above-mentioned document,
- l3 Revision 14, was marked as Applicant's Exhibit 8 for
,,=.,
p identi '1 cation. )
'i 1425 019
I 3412 t
i dsp3 MF.. CCNNOR:
!!ay I request that Mr. Abrams and 2) l
?4r. Cott.a he sworn.
Mr. Borgmann has already been sworn.
3 (Eoard conferring.)
!L CI AIRMAN BECHHOEFER:
My fellow board members il 31 have told me that they have not actually received the Fire il C
Protection r. valuation Report.
I have. and I know that they 7h are on the certificate of service, but anyway I got it.
But i
Bl they tell ne they have never received a full copy of that, 0j so we wondered whether copies could be made available --
10 an extra copy could be made available to each of them.
11 l ME. CONNOR:
I can only say for the record, our 12 '
transmittal record of July 13 reflects distribution to the r
l is '
three board members first and then to other people.
I
- 4 g CEAIRMAN IEHHOEFER
- . I realize that.
i ME. CONNOR:
We have, I think, a couple of othe2.
15 I
g' copies we can provide today.
N.
l (Counsel handing documents to board.)
17 f
13 j (Ecard conferring.)
i 19 CEAIRMAN BECHHOEFER:
Okay.
I think two of the witnesses --
39,
23 i MR. CONNOR:
I just asked that Mr. Cotta and~
l Mr. Abrams ie sworn.
no p
Il 23 lt Whereupon, 24 ll E. A. BORGMANN 11 H
was called as a witness, and having been previously duly y
t l!'
1425 020
i l
3413 4
t<
dop4 sworn, was examined and testified as follows:
~
e li e
and 1
i 3 j; Whereupan, j
ROBERT E.,
COTTA y
C 3!!
and Uo
[!
MELVIN S. ABRAMS
- H t'
7 tj were called as witnesses, and having been first duly sworn, 4
,j were examined and testified as follows:
o g
DIRECT ETAMINATION i
g l
BY MR. C'JNNOR:
0 Mr. Abrans, did you prepare an affidavit, including
- g I
,, ~
your profes:;ional qualifications and your summary of e sas Revision 13 in this proceeding?
A (Uitness Abrams)
Yes.
4
{
Q In that the document that I previously referred to
..'I as having been transmitted to the board and parties on t
Sptember 28, 1979?
f A
Yes.
tl 10 I
O And is that document true and correct?
- g A
- Yes, m
uw I
MR. CCNNOR:
ci i May I request that this document i
[
consisting of four pages be physically incorporated in the
?? /
transcript of this proceeding at this point as if read for 22 nh the purposes of setting forth the qualifications of i
- 1r. Abrams and the summary of Revision 13.
n_,
a
?
1425 021 i
ti 3414 I
dep5 CHAIRMAN BECIIIIOEFER:
Any objections to that?
o u
e !
- :1 MS, FICIF.'U.1:
No.
t MF.. BARTE:
The staff has no objections, your
. i, Ilonor.
1
.I CHAIRMAN BECHIIOEFER:
Okay, so orderad.
O
^ i
('ihe dcctu. tent referred to follows,)
.i 1
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a l.I' l425 D22 0
STATE OF ILLINOIS
)
)
SS.
COOK COUNTY
)
AFFIDAVIT OF MELVIN S. ABRAMS MELVIN S. ABRAMS, being first duly sworn according to law comes forward and states:
1.
My name is Melvin S. Abrams.
I am employed as Director, Fire Research Department, Portland Cement Associa-tion at the Construction Technology Laboratories located in Skokie, Illinois.
2.
I received a Bachelor of Science Degree in Mathematics from Illinois Institute of Technology in 1955.
In 1958 I took graduate courses in the field of mechanics.
From 1949 to the present time, I have been employed by the Portland Cement Association.
For 'the past 20 years, I have been a member of the Fire Research Section and have managed the section since 1970.
In this position I have carried out a number.of fire test research programs.
During the.past 10 years, an important part of my work has been the inspection, A
evaluation and recommendations for repair of numerous fire damaged structui.s, including nuclear facilities.
I am a member of the American Society of Testing and Materials, the American Concrete Institute and the Liational Fire Protection Association and am a member of several committees in these
~
1425 023
organizations dealing with fire test methc.;, fire resistance
\\
and fire protection.
3.
In my position as Director of the Fire Research Department, I directed and witnessed the fire protective cable tray fire test to evaluate the performance of thermal insulation material as a fire shield to protect electrical continuity of cables which was sponsored in part by The-Cincinnati Gas & Electric Company, Dayton Power and Light Company and Columbus and Southern Ohio Electric Company.
I prepared the resulting " Fire Protective Cable Tray Fire Test Report" ("CTL Report") dated June 1979.
The materials utilized, the test equipment, the installation of the specimens in the furnace, the conduct of the test, the test results, including observations during and af ter the. test, are com-pletely described in the Report.
This Report is true and correct to the best of my knowledge, information and belief, and I incorporate it into this affidavit by reference.
4.
In summary, the following are my conclusions applicable to the present contention regarding the cable trays insulated with three one-inch layers of Zaowool which were s'ubjected to a fire exposure corresponding to ASTM designation E119-a 79:
1.
Wrapping cable crays with three 1-in.
layers of Kaowool blanket thermal in-sulation protected the circuit continuity 1425 024
.-. of cables in the trays for 94 min.
No *
(
short circuits were indicated on the light panel or by meggering before that 4
time.
2.
No short circuits occurred at a cable jacket temperature of 700C (392F), which is considered as the maximun con-tinuous service temperature for maintaining continuity of this type of cable jacketing.
'3.
Cable Tray 1 was removed from the furnace 30 min. after the end of the test.
At this time, temperatures of the cables had increased about 50F over those at end of test.
Cables were inspected visually, and it was determined that no damage occurred to cable jacketing material.
4.
Tray 4 was removed from the furnace about 3 1/2 hr. af ter the test was terminated.
Temperatures of the cables continued to rise from 100 to 200F for about 1 1/2 hr. after the test was terminated.
When the tray was removed, seme cable temperatures were still about I425 025
'the same as those at end of test.
A i
visual in.spection of cables indicated that there was some softening of jacket material.
However, one such cable was meggered and found to have circuit continuity.
?ddw YN&
~
Melv2.n S. Abrams Sworn and subscribed to before me this day,of 1979.
Notary Public My Commission expires m
1425.026
3415 1
- i dup 3 B1 ? t P.. CNMOR:
C
- ir. Cettro did you prepare a document eatitled
'bffida'. it c f Reiert E. Cotta" for saae in this proceeding ihich inclutas a statement of your professional c'2alifications
.at:r. chef theretc and a surnary of the use of Kaowool in this acocaeding?
4 A
(Fitnesu Cotta)
Yes.
]
, (I O
Ar.d is the document true and correct?
A Ytd.
' 9 p,3 l MT., COfiNOR:
May I recuest that this documer:
,{
- onsisting c f four pages and an attachment be physica lly i
l incorpo::ctec. into the record of thf s proceeding as 13 i
raad, rnflecting the professional cualification and summary g i o
y, opinion of l'r, Cotta in this proceeding.
6
.1 CEAIPJiAN BEC!mOEFER:
Any objections?
l F1F. EARTII:
The staff has no objection.
g MS. PICHTER:
No objection.
d'
,e ;J CDAEMAN BECHHOEFER:
So ordered.
(The document referred to follows.)
g 1
b),' (
- i s'
21 ]
- i 22 ',
.:, i
't 25 j iL 1425 027 d,
18
\\
STATE OF ILLINOIS
)
)
SS.
COOK COUNTY
)
AFFIDAVIT OF ROBERT E.
COTTA ROBERT E. COTTA, being first duly sworn acecrding to law, comes forward and states:
1.
My name is Robert E. Cotta.
I an employed by Sargent & Lundy as the Zenior Electrical Project Engineer for the Wm. H. Zimmer Nuclear Power Station.
In this posi-tion I oversee the electrical design and cable interface between various electrical systems.
Specifications for electrical equipment also fall in my area of responsibility.
In addition, I have participated in the development of fire protection criteria for cables 6.id cable trays and in the design and observation of various tests relating to this equipment.
2.
A statement of my professional qualifications is
~
attached hereto as Exhibit A and is incorporated by reference herein.
3.
With regard to electrical cables and cable trays, I participated in the development of fire protection cri-teria and in the development of the Fire Protection Evaluation Report
(" Fire Report") consisting of the Report and 14 revisions which form part of the Application for an operating 1425 028
license for the Zimmer Station.
This Report, as revised,
(
.is, to the best of my knowledge, information and belief, true and correct and incorporated into this affidavit by reference.-
4.
I am faniliar with the tests conducted by the Construction Technology Laboratories ("CTL") of the Portland Cement Association (Revision 13 to the Fire Report).
I observed the tests and have studied the resulting report entitled " Fire Protective Cable Tray Fire Test Report."
This report is true and correct to the best of my :nowledge, information and belief.
The cable trays utilized in the CTL test are the same type as utilized in the Wm. H. Zinmer Nuclear Power Station.
In addition, the type of Kaowool used in the tests will be the same as utilized at the Zimmer Station.
The method of application utilized in the course of the tests will also be identical to that used ac the Wm.
H. Zimmer Station.
Moreover, the cables utilized in the CTL tests were the same type which will be cocooned in Kacwool at the Zimmer Station.
5.
The 90-minute test period for the CTL test was determined after consultation with the NRC Staff.
It was
- /
It should be noted that Revision 12 which reports on tests which were run by Husky Products, Inc. for the Wm. H. Zimmer Station from September 1978 through January 1979 is only being relied upon with regard to the ampacity measurements for a cocooned cable tray.
In addition, Underwriters Lchoratories Test Report R8758 dated September 6, 1978 entitled " Report on Cable Raceway Protection Systems, Fire Test Investigation,"
while valid, has been superseded by the CTL Report con-tained in Revision 13.
I425 029
_3_
determined on the basis that if this test were passed, a
(
sufficient degree of fire protection in needed parts of the Zimmer facility would be provided considering the various locations f cable trays, ignition and fuel sources, and fire detection and fire protection measures at the various locations.
6.
All cable trays which are to be cocooned will be wrapped with three one-inch layers of Kaowool as utilized in the CTL tests.
Cables which pass through cable trays cocooned with Kaowool have been suitably derated in order that _ their design temperatures are not exceeded either in normal operation or as a result of a postulated fire.
7.
'The design of the Zimmer Station utilizes concrete curbs around penetrations of floors through which cable trays are routed such that any flammable or other liquids spilled on the floor cannot contact a vertical cable tray or penetrate into the Kaowool cocoon.
In addition, when Kaowool butta to a floor, ceiling or wall, a qualified fire retardant sealant will be used to further prevent pene-tration of any flammable liquid.
1425 UK
8.
Therefore, I conclude Miami Valley Power Project's contention 17 is completely lacking in merit.
.4 ru
/ ~ Robert E. Cotta Sworn and subscribed tu before me this
- ~
~~
day of -
, 1979.
Notary Public My Commission expires
.s 1425 031
.~
f STATEMENT OF PROFESSIONAL QUALIFICATIONS ROBERT E. COTTA SENIOR ELECTRICAL PROJECT ENGINEER SARGENT & LUNDY My name is Robert E. Cotta and I am the Senior Electrical Project. Engineer for the Wm. H. Zinner Nuclear Power Station.
My business address is Sargent & Lundy Engineers, s5 E.
Monroe Street, Chicago, Illinois 60603.
As Senior Electrical Project Engineer, my duties are to oversee the electrical design and the cabling interface between various electrical systems.
Specifications for electrical equipment also fall in my area of responsibility.
I directed the fire protection aspects of cable tray and cable design and I participated in the preparation of the i
Fire Protection Evaluation Report for the Zimmer Station.
I have completed two years of college level courses at the University of Michigan and the University of Illinois.
I am a registered professional engineer, having passed the examination in the State of Illinois, and I an also registered in the State of Ohio.
My work history includes 8 years as a plant engineer with several companies, and several years working in maintenance and operating groups for utility companies.
I have been with Sargent & Lundy for the past 13 years.
\\
1425 032
In 1966 and 1967, I was assigned to the coordination s
of electrical drawings for the Nuclear Steam Supply Systems on boiling water reactor plants.
From that time through 1972, I was assigned as the Electrical Project Engineer and subsequently Senior Electrical Project Engineer on a two unit boiling water reactor.
Tvr the past 9 1/2 years, I have been Senior Electrical Project Engineer assigned to the ZL2mer Station project.
My professional activities include membership on the Ad Hoc Work Group which developed IEEE 384, " Criteria for Independence of Class LE Equipment & Circuits," membership on the Steering Committee of the IEEE for the Task Force to develop fire stop standards, past Chairman of the IEEE Wire L Canle Systems Work Group which developed IEEE 422,
" Guide for the Design & Installation of Cable Systems in Power Generating Stations," and presently Chairman of the Station Design Subcommi' nae of IEEE.
e 1425 033
h 3416 i
BY MR. CONNOR:
3 Mr. Abrans, was the document - Mr. Abrams and
'y r12. Cott.a, you both have been here while I was identifying t
d the docrnents new identified as Applicant's Exaib:'.ts 7 and 8.
A (Mitness 7.brams)
Yes.
- t a
j A
(Fitnesa Cotta)
Yes.
i
- b O
Pr. Abrams, was the document entitled " Fire t
3; Protective Cable Tray Test Fire," identified as Applicant's i
Exhibit 7, prepaaed by you and under your supervision?
n
'i 10
.A (Witn6ss Abrams)
The last two words are " Fire
,, i Test" rather than "Tast Fire."
gl 0
I'm sorry.
A That is indeed the document identified, yes.
d O
, 4, j
And does that include the document containing some
.; changes dated July 13, 1979, which was included in that --
l I'm sorry; that's the wrong thinct.
a.
f Is this document identified as Applicant's Exhibit 7, I
, your report, true and correct?
,3-i l
A That's correct.
O
,,0 Do you adopt it as your testimony in this proceeding?
),
A Tnc.t's correct.
M*
.g
,1 2 ?. '1 MR. CONNOR:
I would recuest that Applicant's Exhibit i
7 be rece ived in evidence in this proceeding.
a CHAIRMAN DECHHOEFER:
Any objections?
- c. -
MR. FELDMAN:
No objection.
ik 1425 034 n
i 4
3417 0
6 dsp1 1
MM. DARTH:
The staff has no objection.
,i 9
4' CFMILJ1sN DECHHOEFER:
So orderKl.
'l (The document previously marked i
Applicant's Exhibit 7 for identification, was recaived into evidence.)
e 4
7 BY MR. CCNNOR:
o Mr. norgnann --
T.
Yes.
- ., y U
4, j '
O
-- ware the documents idnntified as Revision 13
[
to the Fire Protection Evaluation Report dated July 13, 1979 which wta schmitted with the Fire Protective Cable Tray Fire il l
Yest Reprt prepared by you and under your supervision?
g il
_ D A
Yes, they were.
4,, d 11
.. il 0
And does that reflect changes in the general Fire
-- p I!
Protection Feport as a result of the Fire Protective Qble
,'2 9
_ ht
'2 ray Te :t conducted by Portland Cement?
1 A
Yes, they do.
i
,.,, j,
O And is that true and correct?
1 A
Ms, it is.
es ;l MR. CONMCR:
I would request that this be received in evidence at this point as pa2:t of Applicant's Exhibit 7.
CEAIRMAN BECHUOEFER:
Technically, isn't it in
,,a, f
already or is that --
..e i
AR. CONNCE:
I beg your pardon?
,,,1 4.
lh 1425 035 9
3418 ll dspc 1
CHAIRMAN BUCIHIGEFER:
Uas that not offered as part 0
1 o: 7 Eirot?
3 :!
MR. CONNCR:
Yes.
Do you want to mark it as 7-A?
CHAIPMAN EUCHHOEFER:
No.
Is it in slready?
If II it isn't, we'll put ;t in.
I Jasn ' t - -
i 7
l MR. CONNCR:
It wasn't in already be:ause it was I
?l prepared by the Conpany rather than Portland Cement.
They il 9 lM do go tcgether, thcugh.
to(
CHAIRMAN BECHHOEFER:
Oh, okay.
r 11 !
MF. CONNOR:
They are all part of revision 13.
l.
p ja,
CHAIRMAN BECIDPPER:
Oh, I see.
Okay.
Any g,
objecticns to incolparating that as part of Exhibit 77
- 4 MR. FELDVAus No objection.
CHAIRMAN BECRKOEFER:
Okay, so ordered.
.n l.,
't
.,lj (The documents mentioned were u
i 1/
incorporated as part of Applicant's t
g Exhibit 7 for identification and gj received into evidence.)
i BY MR. CCNNOR:
- 3),
O Mr. Borgmann, I here show you Applicant's Exhibit 8, yet j
which is revision 14 to the Fire Protection Evaluation 22
?.3 Report and ask you if it was prepared by you and under c.
.n, your supervision?
1425 031 Y
A Ye3, it t e. 3.
y a
y, ii
Il h
[
3419 dsp10 1
O Ard is it true and correct?
E' A
Yes, it is.
3 ll I
ME. CONNC R:
I would ask that this be received in 4-evidenc:- in this proceeding as Applicant's Exhibit 8.
Cl! AIRMAN E3CHHOEFER:
Any objections?
<l
- I.l MR. FELDFAll:
No objections, your Honor.
b 7
MR, BARTIi:
The staff has no objection, your 1
3i
- Honor, d
i 9 !!
CHRIRMAN EECHHOEFER:
Okay, so ordered.
N 10{
(The document previ asly marked i
11 I as Applicant's F aibit 8 for ll 12 I identification, was received into 13 i evidence.)
i 14 {
BY MR. CCNUOR:
!s ;
O Mr. Bortpann, do you adopt Applicant's Exhibits 7
- G {l s.nd S together with the affidavits of Masrs. Cotta 1
5 7 ll r.d Abrr.as as the evidence of the company in this proceeding I
pg on contention 17?
h
.; 3 A
Yes, I do.
25 !
MR. CONNOR:
We have no further questions as to the 4
?{ [
identificaticn of t'te drcuments.
lj, P. 2 i.
I would prepose at this time to bring up some of i.
23[
the.r.atters that tha board asked yesterday, that i, to g4 respond to seme o f the questions.
It
$b i
1425 037 k
h 3420 1i dspil
'l DY MR. COUNOR:
O I will dir2ct any questions to you, Mr. Eorgmann,
,1 3
a.s the :;uarterback and ask that you refer them to anyone f
you - 1311
- t i
,l A
Okay.
5 J
?
O You will recil yesterday that -- I think it
,i
- {
was Dr. Bright wanted to get a definition of ampacity.
Can
-e I
O h you provide that fcr the applicant?
d.
0 lj A
I believe so.
Ampacity, as we currently use that 10 term, in the current carrying capability of a cable that
.l i
II,
would cause a cable to reach its thermal rating under a t
12i given cet of circumstances under which the cable would be n3 r utilised.
14 ;
In other words, it is the current rating of the
- 5 cable.
- E,
MR. BRIGHT:
So it is a measure of the heating 17 capacity?
'i 13 MITNESS BORGMANN:
It is expressed in amperes.
[3 so it would have a direct relationship to the heating capability 1
2 20 of the cable according to the I R law.
l i 2; i BY MR. CONNOR:
22 i 0
YO'2 will recall yestarday some questions that were o
il 33 }
asked about ihe terms Okonite and Okolon as used, for 9
- 3.. 9 example, in 3xhibit A-5 -- page A-5 of Applicant's Exhibit 7.
il 23 l Can someone on the panel provide a statement.as to what il 1425 038
j' 3421 dap12 these terms mean?
"l A
First of all, Okonite, of course, is a manufacturer l
n" and it is the compcny's name.
But Okonite is also their 4
trado name for their insulation, which is Okolon, and Okolen is merely Okonite Conpany's name for hypolon which is f
common used as a jacket over insulation on the cable.
I h
So hypolen isthe jacket and Okonite is the Ul, f.nnulation.
-L O
Do thess cables meet IEEE 383 standards?
1 C-l A
Yes, they do.
1 ': I O
Now, Mr. Borgmann, there is some question about I ?.
how the cables used in the fire test described in 13 Applicant's Exhibit 7 were sdected.
Would you state how this e
Ii was done?
i 15f A
We wanted :o conduct a fire test that would have I
1C j as few questions as possible, so a cable was selected which i
17 l!
both ourselves and our consultants believed to be the most nj susceptible to any outside fire; by being susceptible, I'm 10 ll-talking about the number of conductors rnd the thickness h.:
20 l of the insulation.
ll
?.1 So we selected a cable which we thought, if it 22 passed, it certainly would indicate all of the other cables 23 would be at least as good as far as fire resistence is 24 i concerned.
2S I
O Would the selection of a particular manufacturer of i
the cab'.cs have made any difference in this test?
i 1425 039
I 3422 dspl3 A
No, it would not because the IEEE standard 2) coirers the v:onstruction of the cable, and as I indicated ag before, the use of hypolon and Okonite -- they ara merely il trade names the since material another manufacturar would 1
ij use.
a J
Q There were several nuestions -- many questions 7o yesterday about the eff.act of having the cables energized t'l
,3 !!
during a tent as to the creation of heat.
d
,i Can you commant on the effect of energized cables
- o in terms of meeting the test?
t
- 7 ;'
A I'll try to put it somewhat into perspective.
Durinn l
a v3 y this teat there were -- there was outside heat applied to the a
- 3 /
cable trays on the order of 7 million btu's per hour, and i
3a !
calculating backwards, using conventional textbook heat
'I
- ransfer eqtations and the actual data that was obtained
)
during the test, that 7 million btu's per hour being very g,
I g.j conservative, about 30,000 btu's per hour got through to the cable, indicating a very, very effective insulating
.g ability of the Kacwool.
. :. !j t
gg h New, if the cables were energized, the cables that ll uill be encased in Kaowool have internally generated heat g
I i
at the rate of 13 watts per foot.
e
, c, l,
,, l.f Ncw, there was 10 feet of cable tested; so if you g
[h I
take the 10 feet, rultiply it by the 13 watts per foot, you g
1 come up with 130 watts that would have been generated inside
.m.s.,,
a lT l425 040
!it
0 3423 31 dap14
'h the cables; converting the 130 watts to watt hours, you come 1 )i up with 444 btu's per hour compared to the 30,000 btu's 3
par hour that would' be -- that we calculated coming throurjh into the cable of t.ha 7 millien that was applied externally.
-i
- i i
Ncw, assiving a straight line relationship, which 9;
S i again ic conservative, that would add 81 seconds to the test
'l er about I ripute End 20 seconds.
L 1
Ot So I think that pretty well corroborates the 1
9 ;t statement that it's on the order of minutes; actually, it's
!i' 1R[
on the lower order of minutes.
end dapl If !
mpb fla.
12 !}
l8 l
13 Id w
i 17 i f
b3 1
I3 t,
23 21 i
22 !
1 23l ij 2
a 1
1425 041 25 1
b
1 3424 3
1 MADELON I !
- )
Mr. Borgmann, there were also questions yacterday Elwa devid mpb1 1
as to that was called the fill of cable trays as to the amount
,1 3j of space cccupied by cables, as to the heat effects that might 1
4 i exist.
6j Can you comment on that as to leading the 90 1
f minute criterion?
7j A
Well, from an cxternal standpoint, we agree with
- l
- ? '
the testimony given yesterday, that the effect would be 3
negligible.
And it could almost be more advantageous having i
l IJ n more bulk in the cable tray for dissipation of heat.
I
- 5 Frog an internal standpoint the amount of fill f,
- 2 ji would be secondary to the restriction placed on the watts cer 13I foot, and therefore having the design criteria of how much il
- 4 '
heat would be generated per foot would limit the amount of
[g ;
internally generated heet regardless of the percent fill.
u5 d O
Are you saying that there is a second criterion 77 p as a limitation on the watts per foot oer cable tray that can n
ja!
exist?
ig]
A Yes, there is.
It does exist.
li' 19j O
Is that a company criterion?
Y 21 l A
It's a Sergent & Lundy criteria, our consultants.
22 And this is the basis for the design of the cables and cable 23.]
trays.
1 74 j C
So speakino generitally, even if it were possible iti 25 '
to overload -- in quotes -- a cable tray with cables, it woulc p
3425 4
nob 2 sta.ll be subject ta che limitation of watts per foot.
A Uell, first of all, I don't want to get to
?
physical loading.
We got into that on a prior hearing.
Put thera's a physical loading limitation which would prevent 3
physical ovarloading.
And there is a watts por foot limita-k tion uhich fould prevent the therral overloading.
0 Let's see.
I think one other question.
~
Will any trays which would be wrapped in 9
Kaowool be wrapped in only one or two layers?
k A
No.
When we made a decision to do a three hour 2: [
test we made tha further decision that any cable tray -- a i
12]
90 minuta test, I beg your pardon.
When we maue the decision 1
~5 3 to do the 90 minute test we made the further decision that
.I Ml any place that Kaowool would be used would be done on a h
chruc-layer basis.
i.
Anyple e that Kaowool was being used and will be used at Zimmer will be three inches and have the 90 minute i t rating.
g ;j Q
And that was stated in our answer to interro-2,r.
gatories so o months ago?
2; A
Yes. it was.
Our position has been consistent.
- =
n, MR. CONNOR:
We have no further questions.
r CHAIRMAN BECHHOEFER:
We're ready for cross-Oxaminacion.
-j MS. FICHTER:
Mr. Gillman will be standing near 1425 043
n 3426 l,
Il mpb 3 the witnessas tners, and I would appreciate it 12 the witnesses would speak up because he has somewhat of a hearing proalan.
MR. CONNOR:
Can't the Interrogator use the l
microphone?
-('
MR. FELDMAN:
He can't hear them, that's the t
i
- l problem.
r, 4
'i CROSS-EXAMINATION
.' h i
BY MR. GILLMAN:
'I:;
.' l O
Would you gentlemen please randomly pick points I
I* nj on i preparad data summary and graph, which are the two
'1 pages I passed out --
,1 E
MR. CONNOR:
Objection.
I-MR. BA RTl* :
Mr. Chairman, I can't hear the gentleman.
I think naybe if he'd take the toothpick out P
cf nis mouth I could hear him a little better.
But with his 17 1 back to me and muttering, I can't hear him.
13 Ij CHAIRMAN BECHHOEFER:
How far does that micro-t '.
10 li
- c. hone c..o?
How far will that stretch?
EO -
(Pause. )
21 ;j BY MR. GILLMAN:
f 2?. '
O To start, would you gentlemen please randomly t;
.2 pick points on our prepared data summary and graph, which
- .i li era the two pages I passed out, and I'd like you to check un.3m againa; the data in the PCA test.
e t'
1425 044
9 3427 i
'i D
rapb4
]
Now lator on I'm going to challenge you to point out any errors in this data summary and graph.
MR. CONNOR:
Objection.
Sir, I can't see the witnesses i
i because cou.1sel is standing between me and the witnesses.
I MR. ZA31'HAUSER:
I'm having the same problem i
with Mr. Connor, if he would sit down.
- I O
MR. BARTH:
Sir, this is creating enormous 1
f
}
- problems, tI 10 ;l MS. FICHTER:
I believe other counsel have stood 11 over here and questioned the witnesses.
I don't see any 9
12 ij problems with that.
h 4
L5 MR. 3ARTH:
I do,
- n. ;I MR. CONUOR:
I would now like to make an objec-
.1 F
tion:
jg j One, that was an impossibly compound question, iti and it was ?.ot a question at all, asking to randomly oick l
1-ll data points, so that the question is defective to begin with.
'l 4
,9.:
Mr. Gillman should know --
3<;.
MR. GILLMAN:
I intended maybe -
II
- y MR. CONNOR
If you'll let me finish my objection il before interrupting.
7,3 that he should not -- he should ask a single qgj question of a witnssa on a specific point, or ask a general l
_4.:
question calling for a specific answer.
1 1425 045 7
e 3429 s!
mph S :
But our main objection aces very simply to the 1
fact that this Coard put out an order to this Intervenor
- f setting down soma giound rules.
This morning we have been I
given comething thac nchody has even had a chance to look at.
i 3.!
We got it af ter the hearing started at nine o' clock.
And
'I i
we don't know what'n in it.
l 1
But now all of a sudden, the Intervenor comes is out of the closet with some data points that they now want 9 ;j us to analyze for them and immediately compare to a retort i
10 ;;
that we have put in consisting of about an inch of material.
i '.
Now we submit that this is totally improcer 1
- (
- 17.,l under any of the Commission's rules, and that even for U;
Intervenors the NRC proceedings do not require this kind of t~
abuse of tha process.
<- i They did not bring any of this forward, they 1
,; j did not respond to any of our discovery.
Now they want to
.I come in with something they probably worked up last night
)
- 3 ;
and bring it up.
This in totally unfair.
Thers is no
- 3 notice
- o us.
And I'm just too sorry for them that they 2e cannot follow the procedures.
But I do not believe the aj Applicant has to be subjected to this tyoe of unethical and 1
22 j improper conducc.
t 1
y, And we object on the basis of the Board's order 1
3.
that anythiag that ue're going to use had to be to us by n]
Novomber Sch, not by the morning of November the 15th.
[
]425 046 2
t
P 3429 rnp r; MR. BARTH:
The Staff supoorts and endorses What Mr. Connor says, Your Honor, fully.
We taka it very seriously.
(The Board conferring.)
CHAIM1AN DECHIIOEFER:
The Board thinks that
~
questions aLong this line should be asked on a question and an:wer basia, not by asking the panel to just analyze a graph.
I'm not cura they can sit down and do chat immediate-ly.
Could you ask them specific questions and I
.I specific annwers?
Is it possible to do it that way?
Try
}
l
]
to ask.1pecific questions so that they can respond with
.i i
,j definite answers.
I think the broad general survey of the graph is
-t I-]
unfair when they haven't Lad a chance to look at it and analyze it, and they can't just sit there and in five minutes 9
j determine this, I don't think.
So he may ask questions, but not along the line r
of just 'is this graph accurate' or....
1 I
MR. CONNOR:
Are you overruling my objection on the use of theco two pieces of paper?
CHAIRMAN BECHHOEFER:
No.
3 Ho can ask questions on the basis of these using l
tham as his notaa.
MR. CONNOR:
I would like a specific rulinq L
1425 047 l
I
U 3430 h
mnb7 0
because if the Board is going to rescind its previous i
- l drder, I think that should be in the record.
- t'q CHAIRNAN BECHHOEFER:
Well, I think they advised
. 'I that thesa piecas of paper, for one thing, were not in d
ij existenc6 --
l MR. CCNNOR:
I'm sorry, I couldn't understand you.
CHAIRb Ali DECHHOEFER:
These pieces of paper were not in existence en the 8th or 9th.
d 0
MR. CONUOR:
The Board ordered them to give us 80 any materials they were going to use on cross-examination,
't and'they didn't do it.
And if the Board is now rescinding I!
12 1
' chat --
13 CHAIRMAN BECHHOEFER:
The Board said if they 14[
had it in their possession at the time.
I 15 i MR. CONUOR:
Exception.
I t r3.
CHAIRMAN BECHHOEFER:
Pardcn?
17 -
MR. CONNOR:
Exception.
i ic CHAIRMAN BECHHOEFER:
Well, read my order.
i 19 :
MR. CCNNOR:
Then we claim surprise.
i to We demand to know that before this line of 6,
il
,3 ; 1 questioning may proceed that some indication be given to us 32 f as to what is intended t.y this line of what these points on 23 a piece of paper mean.
And they may be absolutely innocent.
a 4 4 I doubt it, but I don't know.
e 3-]
And I do not think it is fair under any standard 4
I i
1425 048 4
i
.I 3431
'l i
mpb8 l
of evidence for some people to come in at the last minute W.are discovery rules apply and start saying 'you've got to intarpret these.1 umbers, Mr. Witness' when they have given absolutely ao notico whatsoever.
3 CHAIRMAN BECHHOEFER:
I think, Mr. Gillman, you 5
could give die parsl an idea of what -- where you're driving or whers you're goi:tg, so that we can see what the frame of 3) these questions, where they fall in.
I I do think that in order for these people to s
10 answar the gr.'stiens they will have to know what you're i
trying to drive at.
j 1; l So could you make an explanation, or could Ms.
II Fichtar, either one of you?
1 s. I MR. GILLMAN:
Yes, sir.
15 il The data on this, on the graph, is data from
!c h tharmoccuplas 13, 49, 31 and 67, and these are thermocouples 1'
1-located on die bottoms of each cable tray on the outside of i3 the cable.
19 j I contand that they measure furnace temperature.
N 5 :!
Thermocauples 13 and 31 on the upper two trays are pactted 21\\
on the graph.
Now these are the lower two curves on the l
21 graph, and they show extremely wide variance from the a
ni ASTM E 119, a standard data curve for furnace tamperatures.
>t y, 3 And I contend that the upper two cable trays 3.;
w re not subjected to ASTM E 119 standard temperatures in the 1425~049
I i
3432 I
mpb9 fire t?.st.
9
-I
~
(The Ecard conferring.)
3
^
MR. GILIRAN:
Thermocouples 13, 31, 49 and 67 1j are in the therr:ocouple location number 13, and that's 4
3l indicam_d ca page 33 of the Portland Cement Association a
G
~
report, which is Figure 15, Thermocouple Locations.
/d I'm asking that the points on the graph be picked 3) at random -- let's say one or two or three points -- just to 1
0 be checked against. the temperature records and the table 3 N
on page 24 of the Portland Cement Association report.
And t
M i I simply wanted te give the gentlemen some time to possibly 12 -
check for any points that were plotted in error.
10 MR. CONNOR:
If the Board please, this hardly --
14 l If all they're talking about on one of the points is the
- D variations from the ASTM E 119 thing, it appears in our wl Table 2.
It's already listed there.
And it's well within
- /
che range for theco tests.
- c i If that's all it is, there's nothing to that.
i is{
We'va already set it forth in Table 3 a<
Secondly, I simply don't understand the reference r.-
to Figure 15, the one on page 33.
For examplo, thermocouple d
1 a
31, 4 9 and 69 don't even appear there, so there's no founda-t uL tien for whatever we're getting at here.
j,;
I'm locking at th9rmocouple 13 on page 33, and as
- ., 1 I raad it, as I 1cok at it, that happens to be on the outside 4
1p~;
050 d
3433 I
mpbl0 of the Kaowcol.
I would expect it to be rather hot.
I may ba roading thz.t incorrectly.
']
So I'm not at all sure what we ar.s trying to get 1
'I at here other than having us read the report to this gentleman 3 5 becauso he obviously doesn't understand it.
And it seems to me that this is not something that the Board should consider.
If it's something the Board wants to'get into, 3,
fine, cak the quer. tion.
But obviously approaching it this 3) vay by saying ' lock at my data points', we will say 'yes, it appears in our table 3',
for example, is hardly cross-
!I examination that vaald help this Board reach a decision.
i M;
So I r:ubmit there is no foundation for this line.
'3 (The Poard conferring.)
I M
MR. GILLMAN:
Your Honor, page 22 has Table 1, j
G which la the location and thermocouple numbers.
It indicates that, as I said, thermocouples 13, 31, 49 and 67 are in location number 13 on page 33 in the figure 15, which is fu thermocouple locations.
f.)
Furthermore there is no record of the raw 1.)
furnace tertperature data because the Portland Cement i
2 <,
Association repart states that there were eight furnace 7.q,
thermocouples, and the data for the eight furnace thermo-couplos is not precant in the Portland Cement Association s;,
report.
33 And furthermore, the locations of the furnace
- r' 1425 051
~
i
3434 i
mpbli thermocouples are not shown in the Portland Cement Association
- I report.
j MR. CON!!OR:
Your Honor, this is clearly stuff that should have baen brought up on discovery.
5l (The Baard conferring.)
- t 4
CHAIRMAN BECHHOEFER:
I think Mr. Bright would 7
like to ask a few questions to try to unravel something.
MR. BRICHT:
Just one at a time as we go on.
You have figures 28 and 29, page 42 and 43 of
~ <
10 the tesc report.
New you have the furnace atmosphere control tempera ture,. zona two and zone three.
Could tcu tell me where zone two and zone three 2
- j is, say, in relationship to figure 26, which is the end view
- 4 l of the cable trays?
- g ',
WITNESS ABRAMS:
What was the figure number you
,c '
raforred to, sir?
MR. 3RIGHT:
Figure 26, just the end view of the 1
cable trays.
- 3
.i
,9 I'm asauming that this is a fairly decent repre-a
,qo f sentation of the furnace enclosure.
2:
WITNESS ABRAMS:
That is a cross-section view of n't 22]
the furnace in the area where the trays are located.
,3 In response to your question, zones two and
,J thrno are within the ten foot zone in which the fire was c
i 3.-
,I applied to the trays, in that ten foot zone.
1425 052
i 3435 q
il mpbl2
'l MR. 3RIGHT:
So the zones refer to horizontal.
- 1 WITlGSS ABRAMS:
Yes.
They occur -- they refer to the ' en foot space between the end walls that contain the c
fire where the trayn were exposeC t the fire from one end to the other, that cona two and three for this test.
ead MADELCN WEL flwa 9d 10 3
l
't is i I
8' 13 '
14 !.i!
et Ih i
1'I l!
P 13 d i
20 4
e t-
- $2 2J e
h 1425 053~
'l 3436 2"t:L/wel 1 fla Madclon j
i MR. BRIGE'? :
So there is no measurement of any kind
of tenperacura dif fe::sntial between the top and the bottom of 2
h h
3 this arrangemant?
d
- h UITNESS A3 RAMS:
Yes, there are measurements.
The li y o arrav of thernoccuples in zone 2 and 3 to measure temperatures e,j ar.d control the fire are the spurs, both through the 10 foot li 7 q longth containing ths fire and in a vertical separation to 9 lcampletemperaturesalsointheverticaldirectioninthefire l
3 1 zone.
b y1 MR. BRIGHT:
These are the thermocouples that are i
11 on the trays themselves?
12 WITNESS A3 RAMS:
Absolutely not, sir.
The gentleman g
who explained that tae thermocouples on the tray represent 14 l furnace atmospheric temperature was completely in error.
The
..,h furnace atmosphera thermocouples are act on the trays.
They're
^ l!
in the furnace itacif at various spaces, and they are differ-3 ent than the thermocouples that are used to measure the 37 gl temperatures on the trays on the wires or what we call the 18 thermecouples that were used for each tray, as designated 39 Oi in the la thermocouple locations,
,,, i The thermacouples that are used for furnace
-L
- atrosphora measurement have to meet certain requirements which g
d x]areapelladoutintheE119 standard,whichitappearstome
~~ b g.,;.l'casnotreadbyMr.Gillmanwhenhemadethestatementthat
,,,1 the thernacouples that he has plotted, numbers 13 through 67, a
\\
0u 1425 054 c.
1 i
3437 w el 2 g
P
), thoao four on the bottom of the Kaowool on each of the trays
[. recre.:ents the furnace atmosphere temperature, they do not.
\\-
I i!
- MR. BRIGHT:
Well, this is a little puzzling.
Is le 4'
th ne a cooling mechanica of some kind going on?
h
[
WITNESS ABRAMS:
At what point are you referring to sir?
4 l'
?!
MR. BRIGHT:
Well, the discrepancy bet; ween the I
(
tetto a of both trays 1 and 2 and the bottoms of trays 4 and 3 WITNESS ADRAM3:
- Yes, May I refer you to a statement
'r y in the report concerning that Iratter, sir?
.N 11 *l MR. BRIGHT:
Please do.
' i.
'2 j I
WITNESS ABRAMS:
On page 17, under the heading a
- s l1 Teaperaturo Inforreation, paragraph 2, beginning with Table 4.
l p lj Table 4 lists temperature information, and I'm zeading from 3; q that paragraph:
mf
" Table 4 lists temperature information for the 72
'l
,h ther:. occupies at 90 minutes and at end of test.
Although ji 3 lj the furnace atmosphere temperature was closely controlled l
ij
. c. ]
to the standard fire of ASTM designation E119, and even
,c, 'ii; thouch efforts were made to separate trays from each il 2: ;
other as much as possible, higher temperatures were D
1i nd meatr: red on the bottom trays 3 and 4 than on top trays
,n i; 1 and 2.
Evidently, bottom trays acted as a heat shield
.i 7-p for op trays.
Ao noted in Pigure 26, bottom trays y
were fairly close to the burners of the furnace. "
el
/
1425 055 u
i
.iel 2 3438 4
'ihe occurrence of the difference in temperaturo has bann noted and reasons suggested for them in the report.
- ' hic do33 nct in any way invalidate the statement that
'.ha A3T:s tir,c-temperatura curve control temperatures were f
wil wi".hin the limirs allowed in ASTM-E119.
Those diffarances are given in Table 3, and those ara well within
' ~
the litaits allowed by the Standard.
3 RR. BRICHT:
This Standard E119, is thic standard configuration as well ao standard time-temperature curve?
HITNESS 1,3 RAMS:
What do you mean by standard f.
i configuration, sir?
1 MR. BRIGHT:
The vay the four trays were lcid in d
'S J there.
l
- .', 'Jl WITNESS ABRAMS:
No.
The standard does not d1 1
addreas'the position of the specimen in the furnace.
re
-l 4;
MR. BRIGHT:
Okay.
So would it be fair to say --
r ]
without leading you in any way -- that the bottom two trays 1
rej certainly reflect the quality of insulation that Kaowool l
m gives at the temperatures that follow the B119, whereas the
- c, l top two apparently have been shielded a bit, and have not I
p q bocn aubjectsd to as high a temperatura due to the configura-n tion of tha vay they ware put in thers?
WITNESS ADRAMS:
The bottom two trays were I
probably subjected to higher temperatures than would nomally n
1e canaidered to be the temperatures of e
d curve,
3 3439 wel 4 i
- l bocause of their close proximity to the burners in the
,i rurnace.
i
- l The top two trays are removed some distance by a
h physical necessity from the position of the burners.
- And, 1
1:,
3]
as you :uve abatnd, the bottom tw trays would shield those
- l
' {
trays fron 1 eat to some extent.
/:
If such a configuration were found in practice, 4
0; the same thing would probably be true.
3, so that is true.
M$
ER. BRIG'T:
Well, if we threw away the results 1
}
from trays 1 and 2 and merely considered trays 3 and 4, what 1;
- 1
- 12. g would bu your con =1usion as to the insulating value of 13 ll Kaowool?
1 I
in WITNESS ASRAMS:
My conclusion would be that the 1
10 l, results that are stated would be the same, that the failures is y would have occurred iu those two bottom trays as they are il 17j reported here and at the times they would have basically to as given in the report here.
39,
MR. BRIGHT:
And the p?'esence of the two upper se trays wouldn't necessarily have made any difference, as far q
1 mJ as the lower trays were concerned 1 n'
WITNESS A3 RAMS:
I can't answer that completely, N
,73 because if tha top two trays were not there the positioning y k od the botton two trays may have chang::d, probably muld n
have changed..
s j
I i 4 '> 5 057-
wal 5 l
3440 t
The positions of the trays were determined only en th3 r.hysical size of the furnace, the physical size of the
]
trays, and the best way to put them in the furnace to get
' d the most space between thsm and still get representative U
ii ASTM tests, and the best heat flow that possibly could have q
- r been effected in the test.
So I can't say that'just arbitrarily removing the a
n Ii 3.i top two would give you exactly the same situations of every il characteristic of the test if they were not there, as the 9
d 10 il bottom tw are concerned.
- I 1i MR. BRIGHT:
Well, I'm not familiar with the 12 '
Cotails of what this ASTM-E119 is.
What's the objective here?
l In it to subject the thing to a certain Btu input, or is it i
1.,y to have an atmosphere in which a certain time-temperature li
/
it il curvo in folicwed?
l
- C WITNESS ABRAMS:
That is correct.
It is a test 7
the validity of which is based on a temperature-time regime to j which is clearly stated in the Standard, and which is given N;
in detail in the report in Table 3.
ti 20 It does not depend on the heat input.
If you want p.; [
to have a valid ASTM test insofar as the time-temperature or
.i 22l the tempurature-time regime is concerned, then you have to ha within certain linits of the tamperatur is which they ask 23 2-y you to try to meet.
Thalimits are given because it is
,; i virtually impossible to stay right on the curve in every part
- i hi 1425 058
- I
wel 6 ;
3441 l
of the furnace, so you average all the measurements you make II 2d and reai:a adjust: cents to try to stay on the curve.
i-j They specifically spell out limits that you have to be within, using the tamperature information that you get i
from tha control thermocouples.
And if you are within there, you have a valid AUTM test.
'l
~1 y MR. BRIGIIT:
Thank you.
Gd (The Board conferring.)
1 9J MR. BRIGIIT:
Mr. Gillman, to the just casual 4
'l ic I o' server here it would appear that your line of questioning a
t H
11 !j vill'be to establich that the upper two trays did not
'2 e perience the test conditions, and are you also trying to 12
- any that this invalidates the results obtained from trays N
3 and 4?
I
- r MR. GILLMAN
Well, sir,AS?M-E119,bnderwriters n, i.
Laboratory, and the National Fire Protection Association have i
a standard for fire tests which is that the exposed surface m
n i; area of the material be 180 xIuare feet.
It's only --
m }d, MR. BRIGHT:
The exposed surface?
t MR. GILLMAN:
Sorry, sir?
Et
- d
!f
' ~ '
MR. BRIGHT:
The exposed. surface?
,q t MR. GILLMAN:
In other words, the total surface 22 g!
u a; ;j area orposed to fire in a fire test must be 180 square. feet
'i 2_;
to qualify the nitarial.
If only two cable trays in this gr tact cuatained the ASTM temperature, the surface area of dy 9
1425 059
3442 wel 7 thaso tco cable trayo will be less than 180 square feet.
So
.l
. that ISO squ. ire feet surface area of.Kaowool will not have l
bcon exposed to P.STM standards.
1j MR. BART'I:
Mr. Chairman, to follow up Mr. Bright's
'e 1
question, counsel far the Staff would request that the requirement for the 180 squcre feet of surface area be
- l referencsd as to tha proper section of the ASTM stanclard.
This II 6 l should follow the statement of the questioner.
1 9.;
CHAIRMAN BECHHOEFER:
Do you have the section that
'l Wj requires that?
Can you give a reference?
ii MR. GILLM N:
No, sir, I can't.
This information 1r was imparted to me by the witness we would have had for this i
12 y contantion, and I have not seen the figure.
I believe it is 1., j trustworthy information.
ii Ed MR. BART9:
I point out, sir, that Section 13.1 o
Ic y cays that the area exposed to fire shall not be less than u
1 gj 100 feet square, ei This is the problem, of course, Mr. Chairman, which i
ic!
goes over and beyond proper discovery, which is why the Staff sc y asimd. for discovery, why the power company asked for discovery, t; q why ve sahed who the experts were, so they could put them on aal o
- 07. I make any affirmativa case they want, il nj I'm not certain this is really speeding up the
_. ', proceeding, as the Chairman suggested it would, sir.
l 3]
MR. CONUOR:
Mr. Chairman, this has been going on I
],
i425 060
wel 8 3443 I
]i for -- you know, trere have been long conferences.
l Why not ask the witnesses -- why not have Dr. Bright.
-i Jj ask the witness how r.ho standard applies, and find out.
And i
I'm not at all sure that anybody has ever established that i
- j all four trays do r.ot meet the ASTM Standard.
Let's ask the
- l witnass the exact question, and find out, rather than take r
3 ij
- ;i all thir ti=a guassing what Mr. Gillman might or might not l
be abla to show by what he heard from somebody someplace, J
maybe?
l0 "
(Tha Board conferring.)
1; j CHAIRMW 23ECHHOEFER:
The Board thinks we will
'l take about a -- vall, 'we'll break until ten minutes of.
We M
i 12 want to talk over some of these things.
12 h (Recess.)
i Parker fid2 Il.
ic 'I; f
ID t
19 l 1*
2: ;
6 2: p 21 1 22 i l^
l d
se i
.~
?
1425 061 1
Ii
.i
(
3444 2dsp CHAIrdfAN BECHHOEFER:
Back on the record.
dspl 1
Mr. Brioht: has a few more questions he would like fis wel 3.
to led off with.
4 MR. BARTil:
Sir could I ask that the expert in 1
- ;i differe,itial equations move somehow so I can see the
- l 0j witnessas.
ii
{I CHAIRMAN BECHHOEFER:
During the period of time 7
t 3.'
when Mr. Bright is asking questions, he can move anyway.
1, a;
Otherwise, he may have to use the microphone, but --
to '
MR. BRIGHT:
Let's see, Mr. L7rgmann --
1; WITNESS BORGMANN:
Yes, sir.
ja MR. BRIGIIT:
I am personally not familiar with all la of the ramifications of the test, the required conditions 1A thereto.
i 75 Now, it appears that Mr. Gillman has a concern i
.,3 about the actual square footage.
How is that expressed in f
i
- 7 jj the test requirements?
- g{
WITNESS BORGMANN:
I'd like Mr. Abrams to 39 {
answer these; he's the expert on the test.
- g. :
ME. BRIGHT:
Fine, any one of you.
1 WITNESS ABRAMS:
The document which was referred to 2*
i gi as giving the requirements for exposure area was E 119, ASTM g,
119 and a similar NFPA standard and an Underwriters Laboratory standara that was basically the same.
h Those three standards that he referred to basically y
^ i.l iL 1425 062 i
li i!
3445 4
l contain the same information.
dsp2 This test standard, and I would like to read for I
~
your edification, if I may, the introduction so you can
, l.
~
4 ]f gat scmo idea of what it is purporting to do --
i U
MR. BRIGET:
Please do.
ti Y
WITNESS ADRANS:
-- and then specifically home y
t
.' [1, in on the area quection.
gq The standard -- the E 119 standard document is 0
9 untitled " Standard Methods of Fire Tests of Building lI f
Construction and Materials."
.,.,. g-
[
.The introduction states:
"The performance of 1,
4.
l walls, columns, and other building members under fire; 12 g
c::posure conditions is an item of major importance in
,3 s
securing constructions that are safe and that are not a menace to neighboring structures nor to the public.
t
" Recognition of this is registered in the codes of a
!G many authorities, municipal and others.
17 l' l
"It is important to secure a balance of the -
18 many units in a single building and of buildings of like 19 character and use in a community and also to promote 20.;i l
uniformity in recuirements of various authorities throughout 21 l
the country.
t 23hl "To do this it l' recessary that the fire resistent
'i properties of materials and assemblies be measured and 24 y l}
specified according to a common standard expressed in terms 25 G a
'l l
.A 1425 063
a 3446 dap3 q
that ar2 applicable alike to a wide variety of materials, situativas and conditions of exposure.
1 1
"Such a standard is found in the methods that 1
D follow:
they prescribe a standard exposing fire of controlled 3,,
e;: tent and severity.
Performance is defined as the period t
of resistence to standard exposure elapsing before the first i
critical point of behavior is observed.
7 Bi "F.esults are reported in units in which field exposuras can be judged and expressed.
The methods may be g.
- g. i cited as a standard fire test, and performance or exposure chall b3 expressed as 'two hours, six hours, half-hour,'
,, i et cetera.
- u. <
t i
"Nhen a factor of safety exceeding that inherent in the test conditions is desired, a proportional increase p
I l
should be made in the specified time classification period."
1;. i i
That defines, basically, what is defined in this
.o particular standard.
1,/ ;
Please nota that it said there are a number of 18 l i,
_ D ll, test methods that apply to different parts of a structure
!tl and materials in a structure.
There is not one single
,d,,
1 method in here.
there are several methods.
Now, the requirements for area of exposure are
?.z ;dunicue ':o each of these particular tests.
The 180 square e_
i g
feet whf.ch was cited as that required is specifically 24 !
dafined under the section that deals with floors and roofs,
..n
-l q'
tests for floors and roofs, which is -- and the size of --
4 1425 064
i 3447 and chaeaceristics of specimens which are reauired to be i
cap <
i
.]
tested 2nder the tests for floors and roofs, I read in a
.d 25.1:
'The area e:: posed to fires shall be not less than
.' l.
130 square foot, with neither-dimension less than 12 feet."
e, y
.N Sc the requirement of 180 square feet is not
!i c !!
cpplica31e t.o the test under concern.
U Also other areas given have to do with walls which a
are 100 square feet, which is a completely different test.
g,j There are no area requirements for the kind of test "hich 10 was run and reported in this particular document, the report ahich I wrote and presented here.
i, L, l MR. BRIGIIT:
You mean that there is no dimensional 1;
test for insulatiori except for thickness, perhaps?
f, lu ;
WITNESS ABRAMS:
I'm not even sure there is a test Y
e r.
l for that.
ll g[
MF. BRIGHT:
I mean ordinarily it is a matter of g
even getting R values.
There is a thickness involved.
7g i
. WITNESS ABRAMS:
I assume you're talking about g,
3, an insulation type alue; that is not a part of the standard.
The choice cf E 119 as a test method for the test which
.g it was reported here, I would presume is because the time-
.e.
.I itj temperanure exposure alluded to in the introduction is an y
9 y;
e::treme.tv severe, universally used time-temperature regime.
- f a It has a basis in fact that represents certain 15 1425 065
- i 3448 dsp5 things, and to my knowledge there is no other standard I!
that coatains a tir.e-temperature regime which is applicable ji
.j to conr,:ruction material that is more severe than this.
It is my impression and opinion that this regime is probably far mora severe than you would normally get in a situation 0
c j involving cable trays.
l L
MF. BRIGET:
Well, let me see if I can recapitulate 7
't
- t e "d just a little bit.
4 Ycu say there are no applicable standards insofar t
as curface area is concerned.
g
'l
- ) j WITNESS ABRAMS
Not for cable trays and it
!I not contained in this standard.
p' l
,_[
MR. BRIGHT:
So your objective in going to E 119 y
,,. ]
was to dake the time-temperature curve, which as you l
characterized it,was a very tough one; perhaps we could put
, q
'~
it that way.
1
.:j And in doing this test, you took a typical cable 1
tray with a typical fill and you were actually determining p{
, c.
then the insulatina value of Kaowool in this situation when K d 4
subject 7d to the E 119 time-temperature relationship.
WITNESS ABRAMS:
That is. basically correct, except 21 Il l
I did not choose the test, sir.
22 j fj MR. BRIGET:
Well, by "you" I mean whoever amongst 2: ;
you out chere makes these momentous decisions.
.E WITNESS ABRAMS:
Yes, sir, basically you are a
1425 066 4
2 4
8
.i 3449 ccrrect.
l (Board conferring.)
~f MR. BRIGEf:
So when you are referring -- I just vant to make *,his a'ocolutely clear.
When you talk about
- j 4 !i the 3 129 test, you are talking only about the time-
_i
-Ij temperature relationshiop that is layed out in those
" il r
test specifications.
- 1 WITNESS ABRAMS:
That is not absolutely correct.
o h
'Jhere are other previsions in the use of the test, even f
if you anly use tre time-temperature regime, that are spelled m"
out and should be followed.
is' j MR-BRIGET:
What are those?
Could you --
I WITNESS ABRAMS: How you measure the furnace il E lll' atmosphere temperatures, the thermocouples that have to be il
, if used for that purpose; the representation of th e end C
point in terms of one and a half hours or 90 minutes, which y
E also in the way they indicate you have to spell out the 9
i results of the test.
16 Those things also apply and were followed as they il C h appliad to the test that we performed.
2',
MR. BRIGET:
Would it be your testimony that jf due to the shielding -- apparently the shielding effect of l'i
_i t:.: Docucm two trays that the real test was run on the 23 0 botton :wo trays.
ti 24 MITNESS A3 RAMS:
I would respond to your question, 25 !i if I untierstand it correct.Ly, that the bottom two trays in 1
ll' l
1425 067
3450 d;p?
c the tes:, because of the fact that four were tested in the l
configuratic,n, they were exposed to a much more severe
?i.i environnent, and did indeed, as stated in the report, a
11
'{
effectively shield the top two trays to some extent.
6 1
- j ME, BRIGHT
I guess my --what I'm trying to find F
cut for the record ist did at least two trays show a 90 1
' f minute 7alue that woald be used by, say, the gentlemen who 0 $
wre here fcr the staff yesterday in either approving or d
9 disapproving the use of this Kaowool?
!!' [
WITNESS ABRAMS:
Absolutely.
The 94 minutes to h
- y end of ;est when the failure cccurred is based on 12.
information obtained from the bottom two trays.
i Sc they were the ones that were most critically it affected in the fire test.
t,e (Eoard conferring.)
m, CHAIRMAN DECHHOEFER:
I have a question to add:
g y would -- if the test only included trays three and four and 4
- 9 you got the results y 4 got, would that have been sufficient i
10 t to comp?.y with the requirement for tests, according to the N
tt $
E 1197 gi ;
If you only have the two trays, trays three and i-23 four --
3]
WITNESS ABRAMS:
It's very difficult to respond "t
completely to your question, sir, because ce would have run n,
a comewi.at different test if only two trays were requested to o
e, d
i425 068
4
'I t
3451 l}I dsp3 jj be tect;d.
They might have been positioned differently in the a
furnace and could have very easily had a better performance J
~
than tho two trays that we tested at the bottom of the i
"our tr'.ys.
Ecwever, it appears to me, to the best of my
-t d
knowledge, khat if us had run only the two trays as shown h
0 ;;
here, the results would have been similar to what we 3 h reportel for the four trays.
t M
M!
CHAIRMAN BECHHOEFER:
Well, would it have complied i: ;
with th3 E 119 test standards to just use the two trays?
l 0
- 2 a WITNESS ABRAMS:
Oh, yes, absolutely.
)
- 3 j CEAIRMAN BSCHHOEFER
This is what I'm trying to
!4 find out. 4 13.[l NITNESS ABRAMS: Absolutely. ,g CEAIRVAN BECHHOEFER: Why was the top tray used at U g all? h gy WITNESS ABRAMS: I can't answer that question. I' WITNESS BORGMANN, I'll try to answer that. We t i t r were sn::ious to have a test run that would preclude a lot of q; the questions that we're getting here at this hearing. I mean, .y;, we wantad the most rigorous test which would be putting y the bot.cm trayc in the flame and then have some configuration I which would be similar tc what is in the plant. ,9 So by having th( four trays -- two in the flame g i H25 069 d I
1
- )
3452 l 'I dap9 j and two above it -- it gives a more representative picture of some of the installations at the station. J And also having data on at least two trays, it 4 yould prove to the NRC that these in fact did pass and we ~.; did not just get one lucky installation. So it was the calectirn by our engineers and fire engineers that selected ~ the configuration. , I. 8H CHAIMtAN BECHHOEFER: So the conclusion, even 0 9 y if traye one and two did not reet the time-temperature 4
- 0 Il regime that you were testing for, the test could still be 1
l 1;,; vali'd en three and four. il !; ',l WITNESS BORGMANN: Very definitely. i
- e CHAIRMAN BECHEOEFER:
I see. . ~, p, j WITNESS BORGMANN: Because. 94 minutes was based on 'i, 19 !! failure of tha two lower trays upon which the fire impinged. I g;. (3 card conferring.)
- q MR. CILLMAN:
Your Honor -- your Honor -- 3 CHAIRMAN BECHROEFER: Mr. Gillman, we're back to i
- g i you now to -- this line of questioning, did it help you g,$
in some of the areas, at least, that you were trying to get U 21 ! ir.to, or is there further informatier that you wanted to t v' y; bring ot.t? ,3 ; MR. GILLMAN: Mr. Borgmann stated that the test simulates condition at Zimmer in terms of the arrangement of c -o cahie trays. ..a
- r t
1425 070
ll 3453 -' apl :' 1r you leck at figure 26 en page 40, you will note d - ] c' hat there is a diut:Ince of five inches between the edge il of the cable tray and the wall of the furnace on either i j SidO. The dicience between the -- in the center between 7 the cobic trays is not cpecified in this figure, the dimensiont
- 1
- d en thic -- five inches and approximately six or seven s
- 3 inches in the middle, and then another five inches.
There's approximately 20 inches of air flow. t I don't believe that at Zimmer where cable trays i r,. s aro" passing titrough rooms, through walls, that there is only 3.-.: a 15 to 20 inch cpace in which -- for heat to rise upward. g, I contend that Mr. Borgmands statement that the
- q cable tray arrangemant as demonstrated in figura 26 simulates
~, the conditions out at the power plant, the Zimmar power -.1 3 ctation. .u 1 MR. BARTH: Sir, I move to strike the unsworn I testimony of Mr. Gillnan.
- g.,
g CHAIRMAN BECHHOEFER: That's not testimony; it's ,g i an offer of proof. If
- 3.,.
MR. CONMO3: 17o, sir; no, sir. Objection to that. V 3j He haa no analification to make an of fer of proef. He's a 1 L. haacifying about ccMething that he isn't qualified to testify i _. 2 1 .. about and which the board has prohibited. a CIGIRWT 3EC:UIDEFI R: Ohat is not testimony. I asked t a 1425 071 1
'I 3454 it 1 it dspil l Mr. Gilltaan where i.e intended to go in his questioning from i i here, given the answars to the questions we had already fi 0:I elicited. 1 'i MF. BARTI:: He stated what the distances were in the plant, cir. CEAIR>iAN B3CHHOEFER: Well, this is what he is ,f _ -]i obviously going to ask the witnesses. His statement is b not eviience, but this is comparable to an offer of proof. y I 1 9 il MF.. CONNOR: Mr. Chairman, thereis a more fundamental U 40 y fact; their allegation is it doesn't meet the ASTM standards. t, J'are haaring noises about five inches here and two inches is 12 l there, or whatever. is !j Thereis no foundation; there is no relationship i' %0 to the ASTM E 119. 1 <5] Uithout that, why are we listening? I mean, I d don't know; it could be 1000 yards or it could be zero. But a -,b it still wouldn't show anything in terms of meeting the .i je y v.ests tnat were selected to be run here, which contention 19 d
- '. i says was not met on Kaowool, by the way; ot on cable trays.
N p,rj,; So I sinply cay that we are wasting our time on mattes which
- l 21 y are irralevant.
b (Board conferring.) "I .i 22 i! DR. HOOPER: Mr. Borgmann, what is in fact -- d f what wan in fact the positioning of the trays in the 3; 2-furnace, exactly as it was as the positioning of the trays io f 1425 072
if 3455 1 cup 1' ~ ei 1 nould b2 in the plant or -'as there a different configuration? ': 1 a WITNESS BORGMANN: I was not trying to imply that ,) the configuraticn uns exactly that of Zimmer; I was saying a 4 'I ,i that we could have ran this test on one tray. DF. HOOP 1:R: Right. 4 WITNESS LO.iGMANN: We chose to run it on as many it trays a s we could wi' hin the confinas of the furnace in c U[ uhich w.2 conducted the test, and I was mainly indicating 3 li that we were trying to protect the cable trays from external Pv 10 !! Zires. U U d And certainly the most severe case would be having P. !2 h the fire impinging on the tray which would be the case of the 4 i3 i two on the bottom, and I merely indicated that at Zimmer 14 d. we do hr.ve trays above trays. O jj And this would give some indication that the most "4
- cvere incidants wculd be on the bottom where the flame i7 would be impinging on the trays.
So I was indicating a 10 similar configuration, not implying all dimensions edch II' g!! could not be, due to the confines of the furnace, F' O' c::actly the same as at the Zimmer Power Plant. 21 But it is certainly representative of a tray over 22 j a tray. l 25 j, DR. ECOPER: In other words, you were not trying to o il '; M cxactly simulate; you were trying to approximately simulate
- i if "
and do as best. you can under the circumstances of the q i. 1425 073
- i 3456 a
- i dspl3 g,
furnace? 3 WITNESS BORGMANN: Absolutely; we were trying to ,9 gcther as much data as we could within the confines of the d a!! laboratnry that wac at our disposal to run those tests. .i 3] DE. HOOPUR: Would you anticipate any great change g in your conclusionu if the spacing within the furnace was not e::actly the spacing within the plant? What would be 7 the -- would this ceam to be biasing the results in any 3 gj vay or.not? 10.' WITNESS BORGMANN: I don't believe so. As Mr. Abramn Il testified just prior to my statements here, if you ran the .1 test on one tray or two trays, you could conceivably reposition g il those in the furnace such that it would be a less stringent g-I. I test by moving them out of the flames. t a. l s 15, h Sc we think we did everything we could, certainly, 1 y[ to demonstrate the most severe condition, which would be .s 1 , ll having the flame ir.tpinge on those bottom trays. c, DE. HOOPER: Then particularly insofar as the 18 1 A f reauirements of the E 119 are concerned, this would not le d make any differenCO as to the IOlative== the positioning ,0 of these units? 11 q ] WITNESS DCRGMANN: In my opinion, absolutely not. to j j.l I'll ask Mr. Abrama to corroborate my statement. n j, 1 P, l! WITNESS ABRAMS: That is correct. There are f no cpecf.fications to follow in ASTM 119 concerning the ( T .) ([ 1 1 1425 074
e
- f u
3457
- i t
i dspl4 1 positioning of those cable trays. "} DR. ECOPER: Right. Thank you very much. 4,j CHAIRMAN BECHHOEFER: Maybe wt avoided some of 4 ] the objections. I think that took care of at least the d !}1 latest line that you suggested. i 1 a 'l ll But you may continue from there. If there are 7lI other nr.tters that weren't covered, you may of course pick .0 0' them up. .i 9F This has to be related to thesalidity of the !!tl Mi tests to prove that the Kaowool insulation is adepate to meet t t'.! the" CoImaission 's requirements. 12 BY MR. GILLMAN: I 13f G Why didn't you run two tests with two cable i le ! trays in the furnace instead of one test with four cable i w h trays, if you are using the ASTM E 119 furnace temperature l is standards? il gF MR. CONNOR: Objection. There is no foundation
- p that the ASTM standard requires using whatever he said, a
- 9l two trays instead of four or one or anyting else.
There l} 30 j is a premise in there that is unfounded and the question is 9 irrelevant. 2g 't 23[i There is no rapirement that more than one test is 8 i 33 p required in any ever.2. li AR. BARTE: It is the staff's view that Mr. Connor il:; has cor:cetly stated the contents of E 119; we agree with q 1425 075
l 3458 i dsp15
- i him, sir.
o ?- We object to the question. t (Eoard conferring.)
- i l{
CEAIRF'AN ESCHHOEFER: Could you repeat the salient parts of your question. Really, we didn't hear -- a little i
- 1 louder; we didn't haar all of it, unfortunately.
P 7{ MF. GILLMAN: Yes, sir. i Jh BY MR. GILLMAN: u 9 :! O On page 24, table 3, in the third column is shown r Il iO ll the ASTM E 119 temperature. Does this apply only to cable !i ii ii trays three and four and not to cable tnys one and two? 12 : MR. CONNOR: Objection, your Honor. This is a ja different question, obviously. Table 3 states on its i 14 'l face that the average furnace atmosphere control temperature is hl and variations -- it doesn't purport to be the temperatures l
- jj of cable trays.
H it 'l MS. FICHTER: Your Honor, I'm going to object here. m He didn't say " purported" anything. He just asked the witness g. to answer the question if it does. He didn't say it did; he wants to know that -- what the witness thinks. <3 g f: 22 I think these objections are really getting t i 23 l ridiculous. We're going to be here all day if they
- $[
keep objecting frivolously like they are. MR. COUNGR: If they could ask a question correctly Or 1425 076 9 ti
3459 d dop16 '1 and state the pro?cr premise -- the question related to 1'-j temperatures of the trays. This das not relate to the 't 2!;) temperature of the trays on its face. It relates to average ') furnace temperatures. 5 If they can't ask an intelligent question, they shouldn:t be allowed to ask any. H T3 (Eoard conferring.) d 8i MR. BARTH: Mr. Chairman, we agree with the d, oSjection tc the question. I would like to point out, because l0 '; we are talking about temperatures, that E 119 provides in section 3.1 for an average of nine thermocouples, not a il 12 i particular measure at any particular point of any particular j:, i tray.
- f g, p This is not new.
The applicant's witnesses have p,- already testified; they're talking about average tempratures here. I do not think that the question was proper, nor ,o does it reprocent the testimony or E 119.
- g (Board conferring.)
79 CHAIRMAN BECHHOEFER: I think we will overrule TC, this objection. I think it's wasting an awful lot of time d i
- 3 l}
having an objection to every question. The witnesses can i 22 t, answer. The witness can say exactly what counsel just said -- Ti ,i to coun::el, if that is true. ,2 y;,; They can answer this kind of question, I think. So the witness may answer this one. gy a j.# ^
- )425 077
4 ] 3460 'l 'l MR. CONNC R : Your Honor, I want to make a comment, dspI7 though, on the reccrd on your ruling. It is the function of
- !j counsel to try to keep the record clear on specific p
content. ions, not to allow the opposing party or the board I to go on a wide sweeping thing beyond the contentions.
- Now, J,
6 f chat ic our duty and our function. ? !, We are objecting very strenuously to any board ;i ruling that we should not perform this function and allow anybody to ask anything them can.think of that might he il J 0l interesting, as has been overly evident in this case. i. !! i; Now, we will not withdraw from that function, and a li lE I will continue to object to any ouestions that do not meet i2 i the rules of evidence, although I, too, would like to get i !4 this hearing over. 0 10 0 CHAIRMAN BECHHOEFER: The witness may answer this n h one. You might have to repeat the question if they N '7 didn't remember it. l 15,! MR. GILIFAN: Your Honor, I am trying to -- apeat i 19l the question. Oh. 20 ! DY MR. GILLMAN: I 21 O If the -- uhy is the ASTM E 119 temperature [( 22 j! citrve listed if thermocouples 13 and 31 which indicate the r.rabient furnace temperature directly underneath . cable 12, l 6 24 trays one and two are 25 percent and 37 percent, respectively, .5-less then the ASTM E 119 standard for the 90 minute mark? 1
- [
l425 078 s
!i 3461 dspl8 i MR. CONNOR: I would note that this is a totally 2 different question. But because the chairman does not i 3j vant ut to object, I will not object, if the witnesses i U gb can understand whatever that question meant. gg MP, LARTH: I objtet, sir, because the staff -- it e'j we have to mnha a record uporc which you people can make a findi n II 7 j and the positation by the gentleman who is an e'spert in i i oj differential equations, that E 119 sets up standards in terms 'I g i; of a particular temperature and a particular place, assumes d to facts not in evidence.
- (
gi I haa pointed ot? that 3.1 of E 119 requires an 12 average of nine thermocouples; t'ais is not even related to i l E 119. .., il, You just cannot have a record built this way, your Honor. You just can't. ~, a .._ f (Deard conferring.) and dgo2 '" i I mph fis. se i I wi 20
- 3..
i 2i 12 a 23 y 24 1425 079 > i. ' - E # li
3462 i 1 2MADELON CHAIRMAN BECHHOEFER: I think on this subject the flwc dalid mpbl -] - I titink this is comething the witnesses could say, if so. 6 i They may answer. "1 'I WITMISS ABRAMS: I have stated previously that a 3l statement made concerning what the thermocouples 13 and 31 'i 6 l are mec.uuring was in error. They do not measure the furnace atmosphere temparatura. They saeasure the temperature of the t ,, 1 i Xaowool at that location. d 3l Therefore I cannot respond to the question that l IUj Vas a3kad. 11 BY MR. CILLMAN: th 5 0 Are the thermocouples in the thermoccuple loca-13$ tion number 13 exposed to the furnace temperature? le A (Witness Abrams) They are on the surface of the I E, Kaowocl at tha bottom of the tray, and basically attached, so 15 that they will be in contact with the Kaowool so that it will M record -- the thermocouple will record that particular l 10 ' temperature. !O MR. GILLMAN: Your Honor, I'm looking at l 20 Figura 15 on pago 33. 2j MR. COMIOR: We object to any argument. 22f MR. BARTH: I object to the testimony unless 2.3, thero'c a question. 2,; l BY MR. CILLMAN: t 3 C-Mr. Abrams, on page 33, figure 15, there in a fl l425 080 4 s
f b' 3463 l-l- D mpb2 l! picture of the nid 3 view of the cable tray. . l W tray n usermocouple location number 13 indicating d thermoccupl m 13, 31,.49 and G7, not even inside the cable U h tray. r.3t y a eyvbere near a cable? i' 611 u ese Abrams) Well, this is a schematic t. I. 3 6 l{ representatt.cn of whera the thermocouples are located, and D 7 !! if the figure were drawn exactly correctly, that thermo-couple tould be at what would be considered to be the bottom o cf the :<aowool, thu third outer layer of the Klowool closest 10 T.o tha fi:. e. i 11. Thermoccuple 13 is not intended to measure f. h
- 2 tempora:uren of the cables.
i 12 O Mr. Abrams, why do thermocouples 49 and 67 I N weasure a temperature at the 90 minute mark that is three \\\\ O parcent and two-teaths of a parcent respectively of the 'G p furnace temperatura? lj A I presu:re because those are the temperatures at 17 ta l the location at which they were attached to the Kaowool on I to l trays t tree and four. i I 23 O Do these temperatures of thermocouples 49 and 67 21 at the 30 mf.nuto mark fall within a confidence interval of 22 y the furnaca temperature? y[ MR, SKHH: Could I have the definition of what confide'Ica ::ene vo' re talking about, five percent, ten M v 23 f; pc cant; 30 tu enn get some meaning to the question? l,' lf 1425 081
4 1 3464 I mpc3 MR. GILLMAN: Five percent. I i WITM2ES ABR?J4S: If I understand your question, you're asking me whether the temperatures at thote two 't locations on the bottom trays relate to the furnace atmos- .1 phere in tems of the test? 5 l BY MR. GILLMAN: o l Q Yes, sir. i t 8 A (Witness Abrams) They do not relate to the 'Ii furnacs atmosph.re. Their only function is to msasure the , o.i temperatura at the point at which they're attached. They g 9 -l have absolutely no relationship to the control or measure-1 IA.j ment of furnace atmosphere temperature. 'l nj O What is the height of the furnace thermocouple 4 S 1ccatien? That is, how high is the highest furnace thermo-is couple in the furnace from the floor of the furnace? 1
- 1 A
I don't have that information in the report. i
- 7 To my zccollection, the highest one was probably about the 13.]
distanca equal to the lower part of the top trays. I don't L U know what that is in feet or inches or so forth. O i You would have to refer to Figure 26 d
- , ]
O ' lou state that there were eight furnece thermo-i
- r.
couples. 3 Why don't you show the data for the eight furnace 1 ,j charnoccuplas? j 1. We didn't feel it was necessary to ir.clude that m i
- t-j 1425 082
't
- i 3465 inch 4 in the recort.
Wc: ':ried to disperse them in accordance with ., 1 the prevision of E ~.19 to give us a uniform or a complete. 1 0 saepling of the furnace atmosphere. f I c On paga 42 and 43 of the report are furnaco i 3 atmosphera control temperature, the temperatures for zone l two and thrse. 7 How are these arrived at from the eight furnace 3' thermoccuplas? 9, A Well, in order to control the furnace effectively 10 so that fe can stay on the time-temperature curve within the 1! limits, certain of the eight thermocouples are averaged to
- - ld command the input controls of the furnace, to adjust the heat IJ so that we can stay as close to the hand-drawn curve as possible.
- r R: In this case two sets of thermocouples were a average:d in order to get the information shown on the two
- i figuras you're alluding to.
I ja O So for each figure, figure 28 and figure 29, two .c thermocouples wore averaged?
- t 3
A Probably four, probably four. O To test tha ability of Kaowool to protect cables 22 l from fire, vouldn't a better tcst have subjected all four l ,,3 cable trays to the ASTM temperacure curve? 1: I4R. CONtOR: Objection, Your Honor., The question infers that the test did not meet ? 1425 083 f t
q q 3466 f mpb5 the ASIM tamperature code, which is contrary to any evidence Al in the cace. U'! CHAIRM.N BECHHOEFER: I think that objection is A 2
- dall ^aken.
3 But tie question really could be restated, I C 4 'L think. il 74 BY MR. GILLMAN: 3 0 What is the evidence that cabla trays one and two Yy met, MTM E 119 torperature curve standards? \\ 10 a (Witnoss Abrams) The evidence you see is listed 11 !, on pago -- I think it's 17 -- No, it's on page 24, table three ,5 12 !l whara die difforcucas from the time-temperature curve are 3 13
- given, and a statomont in the report which says that those la l' variati.ons when used in the correction forrula given in IS '
ASTM E 119 aro about one and a half percent variation from 13 the tine-temperatura curve, and for a 90 minute test you must 17 stay in a saven ar.d a half percent variation.
- 0 i So therefore I conclude that anything in the
- 0 !i furnaco was subjected to an ASTM fire.
.i 10. _ C Then why are the furnace.... Okay. il f' You have not indicated the positions of the r J 22 ] furnace thermoccuplos, and so because the position of a r.: thermoccupla is relevant to understanding heau distribution, what ic tha evif.ance that the furnace temperatures indicated t 3j in tabla threg on 24 follow the thermocouple data? st 1425 084 I
3467 i 'apb6 - In other words, where in the averaging of the tharmoccupla data? MR. CONNOR: Objection, Your Honor.
- his is the type of question that should have te2n brough'.: up in discovery, it should have been gotten Into c long time ago.
And now all of a sudden they decide they suddenly vtant to see, they want to check to make sure tnat tha thermocouple data matches the average in table three. i It's far too late for that. This is something 6 that th2y supposedly were going to do a long time ago. They i didn't do it. I
- I Certainly now it is not appropriate for them to Lava to dream up soma (.ata and go check it in the files or
.i somothing to find out why this is true. The witness has already answered the question, in the first place, as to why it met the test. And, after all, that's the only relevant point. s~
- .3 MS. PICHTER:
I didn't hear Mr. Gillman ask for
- 9 the information.
He wanted to know where it was. 2, MR. CONNOR: The same objection would apply any-2: ! way. I uj CHAIiUIAN BECHROEFER: I actually think he asked why they didn't put it in. ~-
- c, But I think we'll let them answer the question.
3 The appeal board has ruled that failure to ask i 1425 085 ,i
3468 .igt? Cor information on discovery does not proclude a party from a.Cincj questiona on cresc-examination. That's the McClinton Cass. I dea't remember the number; but it's an explicit holding. 3o the objoction is overruled. WITNESS ABRAMS: What is Mr. Gillman's specific 7 question? O]i MR. BARTH: Could we rak the Reporter to read it .l back, Your Honor? It might save time. CHAIRMAN DECHHOEFER: Can the Reporter read the ii [ queistion back? 3 i' (Whoreupon, the Reporter read from the record, 5 3.' as requested.) d y NIT;!ESS ABRAMS: We do not normally put that 't H !! data in the report. This position of thermocouples-- I do t la jl not have thsir exact positions here -- were determined, one, 1 - j hy the requirements of the standard, and, two, by the ta ' physical array of material in the furnacs. 19 I.aboratories are given that discretion. You .i af can't r:. ways pu!: the thermocouple where perhaps you would bas.: li%o to put it, something is there. T.1 r, j The average is shown on page 24, are shown to i indicata that the temperatures measured in the furnace 3 i i varied from tha tima-tamperature curve to the extent shown o in :: hat tabla, and that you need that information to calculatei 1425 086 .i
o 3469 i I mpb8 whather or act your temporatures are within the saven and a half porcent roq2 ired in this particular test. 2,Y MR. GILLMAN: O Are th3 furnace thermocouples in the construc-tion -- in ':he Portland Cament Association furnace fixed, or can they be moved around? A (Witness Abrams) They are fixed for -- they are O only fixed for each test; depending on what is being tested 2 ', thay ars po.sitioned for that particular test and remain that way throughout the test. a' 11 Q So you change the position of the thermocouples 12 with ovary sst you run. g 12 And I'.n asking you, is the data of the thermo-h couple loca ion in the Portland Cement Association furnace i f- 'I still extan:, or has it been lost? o A I beliave it's still extant for this test.
- a 2;
E wsvar no did not rotate these at all. They were placed ~l in a particular position for this test in accordance with r the specifications and directions of ASTM E 119, as best as 'i 2:: ws can acet them with the cable tray array in the furnace. 2: C Why did you consider the information about the 22 ; positions o f tha furnace thermocouples not important enough 'i 23 to includa in the report? 3.; e MR. CONNOR: Objection, Your Honor. 23 That's been gone over. 9 [ l425 087~
3470 'I upb9 (The Board conferring.) CHAIRMAN BECHHOEFER: We will sustain the cbj2cci3n to tha last question. I might add, if you're going to -- Do you have any data or any indication that the averaging was not done correctly, or ara ycu just fishing around to find out? Tf there is other information, I think you ought to brirg that out because if it's just fishing around, I think .i the witnesses have testified that they have averaged. And I think many other questions along this line would be quite i '. I rcontitivo. j But if you have specific information indicating 2 d n] come faults in the averaging process, then it might be worth l
- -. 'j going further into where the data is and what it is, what it L ';
says, that type of thing. I really want to know where you're going because m
- 7 bccically the appeal board haa held that irrespective of the L) fac t that you didn't ask for it on discovery, you can ask queaticns about it.
But if it means that they're going to a n aJ have to go back and come up with their further data, you 4 3; have to make a very strong showing that there is likely to 1 ,c j be cone error, or that some error was performed, that there
- l.
1 ng was soms error in the calculation that's presented here, or j that the averaging was biased in some way. I think you have to justify getting the 3.; .I i 1425 088
3471 t mpbloI-information z.t this stage of a proceeding; if that's where -j you're going, I think you would have to make a very strong l chowing that there is something wrong. 1 So this is just a little guidelines. But you may continus with pur questioning, at least. BY MR. SILLMAN: O You stated in the report the 9truece thermocouples i wera shielded - i e; hR. BA?SH: Sir, :aay we have an answer to the 1 (c Board question as to whore he's going since the Board asked ] the question? I w zid also like to know where he's going. 11 is 12 MR. GI2 MAN: I' m sorry. O CHAIRM E BECHHOEFER: Yes. I had asksd if you ifi Ic l-could indicate where you're going on this particular line, 't nU thia line about tha averaging. k g, I had inquired what type of information you were ilj trying to bring out, or whether you're inst fishing for 3 .f a c3p possible errors or whether you had any affirmativs indica-t 39 i tion someplace that there was an error,in the averaging I'm !i g. talking about now, which is the subject of the last question. 1 3 g MR. GI2 MAN: Well, the data indicate that there 4 g_; lI is a ve y close relationship between the thercocouple U - 'j location 13 on the ':ottom two cable trays with the furnace temocraturs. ._ 4 I've bmen trying to establish why the furnace -3s o 4 1425 089 u
ti d 3472 0 mphll ( thormocouples have r.ot shown that the temperature around the it uppor two cable trays is less than it is below. Mr..%3ams stated that there was less heat i! rising to tho top of the furnace, or there was less heat
- i rising
- .o the top no cable trays, and I'm trying to ur. der-O stand from J.nformation about the furnace therm 3 couple posi-l tions why the furnace temperature curve that's on table threa on page 24 does not reflect the heat in the upper part of the
- i I
- { furnace. i-su l (The B nrd conferring.) !i CHAIRMN BECHHOEFER: I think that particular , o
- -i statement that you rade poses a question which we would li like the wiunessos to answer if they could.
14 l WITNES.3 ABRAMS: The statement was made that i 13 If they dca't reflect the temperatures at that particular point. $i 1G j The furnaco atmosphere temperatures are not supposed to 1?l raflect tamneraturas at any particular point on the assembly. D ic p They are completely different thermocouples encased in i 19} shields of either ceramic or iron material, iron pipe n 2c i matsrial.
- hey must meet certain requirements as outlined h
~1 l 21 l! in tha atandard. N 12 And those are the thermocouples that we used in ll r the test. We used those thermocouples only to control the 24 lI furnace fire as clase as we can to the time-temperature l n
- l curve which is req.2 ired.
L. 1 1425 090 ti 1
,s 3473 i i mpbl2 ' The graphs of figures 28 and 29 -- 28 and 29 on t pagan 4 2 ami 43 chaw the averaging process in terms of the "i furance atmosphere thermocouples as it relates to the curve ue're trying to utay with. And the data on page - table 3 thren, in table three on page 24, show the differences. O l BY MR. GILLMAN: 7d 0 What is the purpose of the shielded thermocouple? it a d 1 A (Witness Abrams) They're required by the ? standard. .O j C I'm corry, sir? 'i ll A They'r3 required by the standard. Y O What do they achieve? h MR. BA3TH: Sir, here he's challenging the IEEE d 4 14y standard. "'his is no place to go litigate a national il
- 5 h standard for elect.eical fire testing.
.Ia gi MR. CONNOR: The contention was is the standard 17 the right standard. As I understand, the question is whether i 13 l the taan met the standard. So anything about his opinion of !g ; what the standard might - what the years of technical i 2c. l axpertise have coma up with is hardly an issue. qt MR. BA3TH: It will not expedite the proceedings, nj sir, to liti. gate the validity of the IEEE standard 119 p; 1 MR. FANKHAUSER: Mr. Chairman, I'vo heard this 33 1.aan of Connor and Barth working all morning, and I must say g I've kept my tongua until this point. s 1425 091
f
- I 3474 1
inpb13 '- But I think that the question is what is the E thract, wha: is the purpose of these standards. And he is 1, not questioning tha standards as such, he is trying to find out what thrs purpose of these standards is. And I think that to look to the goal of those S standards i:3 an appropriate point at this juncture. MR. BARTH: In response to Mr. Fankhauser, the J gentleman read the introduction to the standards which sets v.f forth the purposa, sir, d 10 l MR. CONNOR: Dr. Fankhauser apparently was not i l 11 listening when Mr. Abrams read the introduction which points 0 t" out the purpose of the standards earlier. (The Board conferring.) 12 [d
- u. ;,
CHAIRX\\N DECHHOEFER: I think that if it isn't a '! j g] challenga to the standard, thun I think the question has 3, already been answered, 4 h yf j If it's a challenge, it's not permittsd. gg ' So ne'll uphold the objection to that question. I g ', MR. GILLMAN: Your Honor, what was the surface 3 lI area requiroment of the standard? il U y,: CHAIRMAN BECHHOEFER: The witness testified that n: there wasn't any. 3 BY MR. GILLMAN: os n :' O Does a shielded ther:nocouple shield conductive, i convective e.r radiated heat? y,y S i. T 1425 092 n
4 3475 f
- 1 l'
I i A (Witness Abrams) I'm not prepared to answer the mpbl4 !O questica. Tt was used only because it's so specified in the U
- li standard.
l -] O You don't know what the shielded thermocouple is for? 'i MR. COSMOR: Objection, Your Honor. a l The quastion has been asked and answered, simply ~ 0' that the shield was used because this is what is required 91 by the codo, and that's all that's in issue. It's irrele- '0 i vant as to ' shy the chield is put wherever it is and what it i si.: does or doaan't do. N 12 ] MR. FELD M t Your Honor, it seems to me that 'l
- ;{
Mr. Gillman is asking this as a foundation question, or may be. Ar.d I think ha should ask it for purposes of his ques-l ,; !{ tioning. It may be an insignificant question. (The Board conferring.) si ond r; h MADELON WEL flus 13 '!
- 9 !l
'i ao a. v1 l ,., a 22 s i 24 i' l425 093' s 4
! \\ 3476 Sh'EL/wel 1 fla Madelon CHAIRMAF 3ECHHOEFER: The particular question I i 2i vill suotain the obysction to. I think that has either been ,a >p answered -- it was answered, because it was part of the Cods l
- h cc tha Standard, 3rd I'm not sure why it's importt.nt, or what a
" y purpose in that Standard it serves. But anyhow, you may U, proceed with your questions. d 7 ll BY MR. GILLMAN: 'l l 0 'i Q I'm trying to find out information about -- r 3 MR. BARTH: Cot.1d we haire a question, sir, instead t 10 ! of a speech? 1i ll l CHAIRMAN BECHHOEFER: He can put a background for i! 12 " his quection. That's not a speech. Give him a chance. He l 13 I can put the premises of the questions. I 14 BY MR. GILLMAN: i, 15 ; Q How can an expert qualified to perform a fire test i is : not know what a shielded thermocouple is for? 17l MR. CONN 3R: Objection, your Honor. That misstates to the record. That's not what the witness said. Ip's t. 10 irrelovant, in any event. 20 L MR. BARTH: I've given him a chance, your Honor, 21 and I object to the question. It challenges the Standard. 22 l M3. FICHIER: I believe the witness said he was 2: fi not prepared to answer that question, so I think it was a ge ; valid qt.astion. 1 3; !! Mit. BART'I: If he's not prepared to answer it, in 7 1425 094 ail
il wel 2 l 3 017 I I] tha.h cara he's already answered it. He can't. So either way h 2 I we would objact. t \\ 3j' M3. FICHIER: He's acking why he can't answer, why he considers himself an expert in fire protection, and yet
- 'l
- he can't answer the question. i b MR. CONNDR: These snide questions that always try 7 'u to infor that something is in the minds'of these people, by a, WIPP sneaking in queution after question is reprehensible in I i 3 j, any court. But it is particularly bad when the witness said 10 he didn't answer why it was t.here because it was in the : 11 Codo', and he didn't know more than that. It doesn't mean 12 that he is less or not an expert in his field. 13 For this interrogator to misstate the record is 1 -1, totally improper, and sometime we're going to have to quit it. 6 13 ; MR. FELDMAN: Your Honor, I think that misquotes 13l the quachion. I think he asked what it was, not why -- l
- 7 ;
MR. CONNOR: We object to 16 different counsel of l I 13 the many counsel for MVPP all chiming in on the same point. 13 . One counsel should speak only. That's the lase remaining 20 y rule. I 21 CHAIRMAN BECHHOEFER: dell, I do think that that 22 : question was objectionable, and we will sustain the 23 objection to that one. 24 BY MR. GILLMAN: 25! O Wore thermal radiation shields on the thermocouples I 1425 095 ~ o
s 3478 i wel 3 i install::d in the cable trays? 4 A (Witness Abrama) No. !i 2] Q So the cable trays were unshielded? I I ' A les. t 'I i: O Thorofore, you state that the cable trays would havo been picking up radiated heat? d "3 A I didn't state that. d Q Tha PCA report lists the thermal conductivity, 9 density and specific heat of Knowool. Why doenn't it list !S ] the emiasivity? l 1; !! P.R. CONMOR: Objection, your Honor. IN the first 12, place, there should be a reference, and there's no foundation
- 3 ;i laid as to why or what emissivity should or should not be 14 h listed, whatever this interrogator may mean by it.
'l
- 5 MR. GILIJRN
Page 11. 10 - MS. FICli"2R: I think the witness can answer. If [j emissivity is not relevant, then that's why it was not d Se l included. And he can answer that as well as Mr. Connor.
- p MR. CONNOR. I object on the further ground that ao,!
this reference now given refers to a B&W description, not p: something this witness selected, in any' event. I'm sorry, i 12 i T should have said Babcock & Wilcox. r; CHAIRMAN 3ECHHOEFER: That objection we'll H n 24 !i overrule. The witness may answer that one. -i WITNESS ABRAMS: Would you repeat ycur question? 2F :l. 1425 096
I li .rel 4 3479 L I BY MR. GILIJIAN: o I! al Q Why were the emissivity characteristics of Kaowool i' 3 c.titted from your r2 port? y >j A Cfitness Drams) The specifications for Kaowool S that are in this raport were not selected by me. It is a 9 h f{ pieca of information out of a catalogue, referring to the b 7 ;l material which was bested in the test. It was included in ~ ?> the repcrt as a pieco of information in toto (s you see it d' 9 thero. We did not have anything to do with the preparation 10 of that piece of information, p 11 6 M3. FICHTER: Your Ecnor, I don't think that was 12 i responsive to the question. He asked why it was not included i-Gl in the report. Ec'3 answering that he didn't prepara this I i 14 ; pga hers. IIe asked why it was not included in the report. 1 ?E g M3. Com13R: Your Honor, that was the reference N 16 ll they gava when I raised the point. d 17 !! (The Board conferring.) 18 CHAIRMAN BECHEOEFER: Well, I think the real 19 h gocation should be: Does emissivity have anything to do with 20 tha insulating value of Kaowool? Maybe the witnessas could h 21 answer that one. !i r, y WITNESS ADRAMS: In terms of the test results as 2 ] reported here, based on the provisions of E119, we are only i 21 intorected la the information that tells us when we have
- l y]
reached a failure paint. The emissivity absolutely has
- t
- f 1425 097
wel 5 t, 3480 t $1 tl g nothing to da with that determination as reported here. 3 ! CilAIREN DECHHOEFER: So I take it that's your d ' ll reason for not including an analysis of emissivity in the n 1 ^ it report itself? WITNESS BORGHANN: Might I comment? Anytime you il id deal with a manufactured p.oduct and you want a description F 7! of that product, you go to his catalogue sheet. 8[ a l Now, when the catalogue sheet describing Kaowool i 9 j, uns included in the test report it was included simply to i 10{ show the mat rial that was used. It was not the choice of na, or the man who run the test. It was simply the choica 12 l of tha manufacturer of Kaowool as to what properties he puts i 13 : in his tabulation. And that happens to be a property that was i I t.., not included on th data shat, so that's why it was not 15
- included, t
46f CHAIRMAN BECHHOEFER: But, in othed words, it is i 17 i not relevant to the test results, one way or the other? Ia, WITNESS BORGMANN: When you get right down to it, ie, as long as the Kaowool is a consistent product, the physical i 20 h characteristics of that product are irrelevant, sinco you i! ] are really measuring the effects of the test. The key to 21 i 22 i the product is if you have a consistent product, time after i n - time, and yoa test that product it's the results. of the test .i n; y that are significant. Emissivity is just another physical il 2E ] characteristic of the product, any one of which affects the e i! 1425 098
~ a wel 6 3481
- t 3
characteris-ics, bat you're not measuring the Kacwool. You're 'i 2 0 maaauring t.';e efia:ts of the Kaowool,, how it protected the 'I cable tray. 3-4; and Eab::ck & Wilcox who makes the Kaowool does
- 1, 3,
not list that as oas of the characteristics in their tabula- ,3 y tion of characteristics that they put on their date. sheet. a p !} (The 3 card conferring.) ' il 3h CHAIRMAN BECHHOEFER: To ask further questions on ';i 3 li ersiasivity, you'll have to tie it up in some way to the l g) results of this tent, or to the requirements -- the standard-3, \\ that the test is fulfilling. 33 ; to you nay proceed. b' LY MR. GILI!!AN: Q Are you saying that you're not responsible for g knowing the emissivity 'characteristicJ of Kaowool, that . _ ',.'Eabcock & Wilco:t is responsible for knowing that? ,,3 MR. CONEOR: Objection. That presupposes that -- i MR. BARTH: Your Honor, I object. ea 19 fl MS. FICHTER: One conhsel at a time, please, I 'l know you're all -- .,c0 ? MR. CONNOR: Look who's talking now. i The fact is that it's irrelevant. This has ,,u,, e l alraady been establinhed. Mr. Borgmann just said that the 1 test was to determine the effects of heat, from whatever 3 9, courco, as to hew Knowool withstood it. So it's trrelevant 2r 'ir.., ..z ii h 1425 099
wol 7 3482 I 1 where tha helt came from. It's that simple. It doesn't 2f matter. MR. BARTH: Sir, I would refer you to your own e ' 6 l ruling, that he has to connect it up, which he has not done, .Iq 5,, before furth 2r quash:~.ons. S-C3 AIRMAN DECHHOEFER: Yes. You'll have to connect il 7 y up your questions on emissivity, to show why they're going 3 {l to be relevaAt. ? 9 !! MR. CCNNOR: There's absolutely no foundation laid ll 10 ] for this. He may as well be asking about neutron bombardment, 1: because it'a just not there, no connection. !2 Bf MR. GILLMAN: 12 - 0 Taan why were the thermal conductivity, de.,tsity !4 l and specific heat daomed important enough to include in the it i report? iG !! MR. ComiOR: Asked and answered. o 17 CHAIRMAN BECBHOEIER: I think that question has 13l been answered. So the objection is sustained on that one. 19i BY MR. GILLMAN: i Q For energized 40AWG three conductor -- 20 h, Il 21 ] C3 AIRMAN BECHHOEFER: Could you speak a litt.s it 22 louder? We' re having trouble hearing you. I 23f BT MR. GILLMAN:
- c, 3 Q
Fir enorgized 40AWG three conductor cable installed y, ', in a cable tray to a 50 percent fill, would Kaowool - be as d-1425 100 lt n
\\ 3483 I wal 8 II effective in retaining the heat generated by these cables as i 2l it is in protecting the cables from external fire? 0h A (Vitness Borgmann) The insulating properties would U 4 Nl;he the came. il 3f Q Y)u're saying there will be no more buildup of 1 1 i. heat in a cable tray that is covered and insulated, compared 7 with a cable tray that is open and uninsulated? e 3l A Taat wasn't your original question. 9i O Have you done any studies on medium sized power i l 10 y cable that is energized in a tray to determine when that 11 j' tray is covered and insulated how the ampacity is affected, i1 t' 12 and do you know,1f you have not done either calculations or 13, experiments, do you know of any? I 14 j A I'll ask Mr. Cotta to answer that. 15 A Ofitness Cotta) When the requirement came up to isl cover the trays, protect them, as a result of the fire l 17 protection evaluation report, and it was decided that we m :: *eould investigate a blanketing material auch as Knowool, the 19 first thing we did was to see what effect this would have on = 20 power' trays and the cables in those trays, i ni W looked at those areas where we would have to gg cover cable crays, at the specific trays, and we took the 1 23 ll worsu case in watts por foot that we had, and ran that out 2a to see what our loading was. g
- g W made calculations based on the thermal i
lI 1425 l01
3484 wel 9 I condu tivity of material like Kaowool, or this type of 2l ntatorial, anI then to confirm that we took the watts per foot 3, of the vorst case, :nade up a cable tray section, and ran i tests on it, to reach equilibrium temperature.with three h '{o inches c.E Kaowool, to assure that we would not exceed the 6 ft temperature rating of the cable. i ~ And that is in the worst case from a loading e 3! standpoint. 9 Q How did you determine the worst case, if the 10 Sargent & Lundy computer does not centain records of power -- 11 cable tray a.npacities? 12 A You don't need a computer to -- 13 MR. CONNOR: Objection, your Honor. I mean here i 14 again they'ri trying to shovel something in the back door. t5 ; There's noboly that said -- there's no foundation for saying f. 16 I that Sargent & Lundy's computers should or should not have 17 such information on them, and to put that in as an inference I in the question is improper. p3 19[ CHAIRMAN DECHHOE?ER: Can you restate the b 20 question to avoid that inference? } 21 !. BY MR. GILLMAN: 22l 0 How did you pick the power cable tray at Zi:mmer Power Plant that carries the most amperage? 23 II
- a j A
(ditnaas Cotta) We have a computer printout of 25 f every rcuting point -- tray section, if you will -- in the I.. 'I 1425 ~102
3485 vol 10 1 immer Station. We know every cable that is in that tray, i 2ll and we have gone back and looked at every tray that has more .) than 40 percent fill. He have reviewed every cable, the d actual load that is on that cable, and full load current of I Oy the motor, or whatev=4r the load is. 4 We ran out the I squared r, heat generation from 7 those cables. It's a very simple thing to do. It's time 3 consuming, but this is a standard practics on -- I don't 9 care if it's a nuclear plant or a fossil plant, this is 10 something you do so you don't burn up your cables. And we're 11 well within the limits that are established for these 12 tray sections. 13 Q Are you saying that you went to the Sargent & 14 Lundy ccmputer, determined which cables were in which tray, 15, identified the cables, and then manually went to the 16 architect-engineer's blueprints to determine the amperage 17 that each cable was carrying, then added them up for each 10, cable tray?
- 9 A
No. We did not go to blueprints. We went to the 20 data sheets that come back from the field giving us the 21 nameplate data for each motor. We do not trust preliminary 22 information for that type of an analysis. 23 j Q Earlier you said that you don't need to use the 21 computer. What did you mean by that? il g5 y A You do not need to use a computer to make a i l, 1425 103
n 3486 wel 11 't ceticulation on the thermal loading of a tray. ll ?ause.) 2 0 .:f the PCA test were rapcated four nore times, for i total of i'ive tes:s, what in the probability that cables 2 t l would fail beforc the 90-minute mark? .l R. CCHNOR: Objection, your Honor. That is I ] hoyond the contention. The contention is the cable would not
- t d
i neet the tes;t, not some speculation as to whether the test 'l ahculd be five times instaad of one time, or whatever, or s. i. I
- o 9 that you should do it on 20 trays instead of four, or one.
O
- i j Dut that certainly is beyond the scope of the contention, I
- 2,
once again challenging the Standard. i i g{ MS. FICHTER: I would disagree. I would say that the test itself and the design criteria of the test are y very much qusstioned in this contention, and that's what he's getting at, whether in fact it was designed adequately I to test Kaowool. iN ~~ gl t MR. CONNOR: It is an attack on the Standard to i g, suggest that five tests would be better under the Standard. g )d (The Board conferring.) 2 CHAIRMAN BECHHOEFER: I think basically only one '. ] test must be pascad. The only thing that I, myself, am a 3 .! little intarcuted in is how likely is it that the fact that _. ] the insu'.ation passed on this test was a lucky break, and if =: n It 23 {l' you did a to:it tomorrow would it still pass? h uld it still I I i L 1425 104
li 3487 wel 12 be 90 minutes? Could you just do tests until you found one l that did pass? Could you keep doing tests until you found i 3l one that passed, and then use it to say that it qualifies? 4 Taat's the only thing in my own mind that the question raises. Yarbe some people on the panel could a S h address that. I real.ize that only one test is all that has il 7 9 to be passed, but I would like to have some background as to l ~ 3 whether it's likely that this is just a lucky break that it n 9j passed this time, or is it likely that a similar test would 10 product similar results? 11 MR. CONNOR: For the record, I'm going to object 12 to that, too, becauco even though it is in the interest of 12 the Chairman, it still goes beyond the Standard. And any i Il questior. the Board asks -- 15 ! CHAIRMAN BECHHOEFER: The Chairman recognizes i !G that. I am predicating my question that way. 1:7 ' MR. CONNOR: I understand. But it also opens it 18 up for further cross-examination, and that's why we object i 19 [ to it. I 20 l CHAIRMAN 3ECHHOEFER: Well, I have shkod the Staff 21 people, I think, some similar questions. And I just think 22 a follouup en this panel could be instructive, at least. i 2;a. WITNESS ABRAMS: The question you're asking is i 24 ; extremely difficult to answer, simply because nobody has run l 25 five teats, or ten, or three tests that are the same as this i [ 1425 105
'I 3488 wel 13 1 particular test. + 2i Prom my past experience in other programs we have 1 3 used our furnaces for, where duplications or triplications i 4 h wara made under the conditions of that particu.'.ar research i 6 program, ger.erally the results duplicate quite well. b 3 there are some variations in resultu, depending 7 upon the conditicnu of the test that you are running, but 9l nostly the end points are reached very close to one another 9 [ in repetitive tents. l 10 I MR. BARTH: Mr. Chairman, it is 12:30. We would i! ' like to got Mr. Maura on and off today, because these people '.2[ cannot question him on Friday, and -- I 13 i CHAIRMAN :3ECHHOEFER: Right. Well, we were i 14 : thinking of breaking for lunch around now anyway, and coming i is back to take Mr. Maura, and then to continue on the is j insulation question. 17 MR. CONNCRs We would like to object to that.
- a t Let's finish this line of questioning, and maybe these I
e 19 witnesses could be completed. I mean it is 12:30, but let's 20 'l finish up what we're doing here. I mean we agreed to have f I.t 21 h Mr. Maura, and I'm not objecting to thnt. But I would like bil 22 ! to complete this line. 1 23 :l C3AIRKM EECHHOEFER: Well, do you have any more i 24 uuestions on this p<srticular line, o; is this a good breaking 2; point? 2 If? 1425 106
ll 0 3489 wel 14 M3. FICHTER: He's done with that line, Mr. I 1I Chairman. S'f MR. CC1mCR: No, I mean is this cross-examination h completed? d 5l M3. FICHTF.R: Oh, no. i CSAIRMAN LECHHOEFER: Well, the other parties have I 7; a chance, also. I think that we will break and ccme back e and talk about control rods, and then we'll go back to the 5 witnesses. I just don't think we can productively finish 10 [ these people before lunch. I 11 l MR. CONNOR: We might get some estimate. I mean 12 the City isn't even here, and I don't know whether Dr. N 12 Frankhauser wants to cross-cxamine. la ! CHAIRMAN BECHHOEFER: The City told me Dr. f5l; Frankhauser muld represent its interests for this particular
- c MR. COlmOR
Well, we don't know that he's going t 17 to take a long time. We don't know that Mr. Gillaan is going 1G to take a long time. All I'm suggesting is that we ought 4 19 i., try to move along. 20 CHAIRMAN EECHHOEFER: Well, we'll be back at a 21 quarter of 2:00. 22 (Tnereupon, at 12:32 p.m., the hearing was 23 racessed, to reconvene at 1:45 p.m., this same day.) l u ll 1425 107 de ns ie u !!
3490 l 5 I Cdsp f AFTCEIiCON SESSION i pi (1:48 p.m.) fle tal CHAIRMAN BECHUGEFER: I belien we're i I.; ready to proceed. The testimony -- are there preliminary matters? l 'i MR. FELDMAN: Yes, there is one preliminary 3 mater that I would like to brina up at this point if I might. I 3 jl That is that hst night it was brought to my attention that N 9 q there has been a runcr aaoat that Cincinnati Gas & Electric i 10 ', is practicinn loading the fuel rods and during this practice II !O one of them broke and some uranium escaped. 12 l And I don't know if it's just a rumor or there's i ni any signficance to it, but I talked to Allen Howard of i
- 11. I the Snquirer newspaper, and he told me that he had --
h nj 'chrouch another one of his reporters -- talked to somebody i 03 ll who had represented themselves as being a worker at the 't
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plant, that he had told them this.
- g Although it may have no foundation at all, I think 29l it's curious enough that an investigation should be instituted 4
2n just to find out if there's any truth to it at all. it l And I was wondering if such an investiostion could 21 ir I be instituted? 22 ;i
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23, (Doard conferring.) g4[ MR. CONNOR: Mr. Chairman, I think that is the d t type of rumor monnering that has marked this hearing. It is i 1 1425 108 i I I
3491 61 dop2 =;; absolutaly untrue. D d Me fuel has been lorded into the reactor. You have to have an operating license from the Nuclear Regulatory .,h 1 ,;j Commission before you can load. fuel into the reactor. G 3 I don't know why Mr. Feldman is sprehding rumors, bui gh we do hz.ve the NFC inspectors around, and so forth, and I ., {i don't bclieve anybody is trying to make such a terrifying j conspiracy that it should be brought before this board. g I g[ The NRC inspectors are up there now. CHAIRMAN DECHIIOEFER: Yes. I think loadina 10 l
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fue], is not permitted. gl MR. FELDMAN: That is the whole point. I suppose we're hopino that they are not going to tontinue. It is not -- ,3l 1.,> CHAIRMAN GECHHOEFER: I presume the MRC inspection i ataf2 has its people out there. I don't know -- I can't P IG that the applicant is not loading -- MR. FELDMAN: This is my concern, that I would like to see this rumor put to rest, if it is just a rumor. 10,: i If it is not -- you know -- I would like this to beccme 10! j public, if there's any truth to it or if there's li no truth to it. g c... s 1 (Board conferring.) 22 [l l MR. CONNOR: As counsel 6r the company, I just ..,9 D made that representation, and while I don't suppose 2'i 1425 109 if 11 1
l' 3492 dep3 i Mr. Feldman trusts anybody, that is a fact. i 3f ME. FELDMAN: I didn't hear what you said. 3 fUt. cot 1MOR: There is a rumor that there are 1f three dinoscurs loose in the containment. 5 MP. FELDMAN: Perhaps that should be investigated. G! GAIPFAN BECliHOEFER: There'c nothing that the I 7 board can "11v do on this. If specific facts are brought GI to our attention, then perhaps we can -- you can raise l
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a contention. 10 But if the applicant is violating the Commission's 11 rules by loading fuel before it gets a license to do so, 12 there are legal remedies. 13 You could request a show-cause order; that would 14 be the method of proceeding then. They would be violating 15 Co:tmission rules by acting without a license.
- g Certainly, the Commission would have jurisdiction i7 to investigate that, but this board doesn't.
10 MR. FELDMAN: Right. But I would just hope that 19 the NRC would send an inveetigator out just to at least 20 check the fuel rods to make sure they haven't been tampered with. 21 22 I think that would be a quite simple thing to do. ,g, Perhaps you're already doing it; I don't know. CHAIRMAN BECHROEFER: Tampering with fuel rods y a,l is still another question. I think putting them in the 'l 1425 110
1 il { 3493 I dsp4 reactor is one thing. Tampering with them is another thing, df and I think we certainly don't have authority to take any '9 action. But I think you can bring whatever rumors you have 'I heard to the attention of the Commission. i " d' Ycu can chow Mr. Barth or -- itI MR. FELDMAN: He will attempt to find this [ 7 engineer that we understand has brought this up, and if Gl we can locate this person and if he does exist, we will lf. bring him forward. 10 l CHAIRMAN BECHHOEFER: Because certain matters are -- l 11l-certain matters we have taken up when affidavits have been 12 presented to us setting forth the facts. 12 I'm not surethat one involving a violation of the t <, l rules is even within our jurisdiction at all. Even -- althougl. I 15 i the operating license board can consider whether any ic violations have taken place up to the time of the license. 17{ nut I don't think we would have authority to determine in i 1e p an oncoing proceeding whether there is a violation of somethinr 1 is l as basic as the applicant loading fuel without a license 20 j to do so. 2; So I don't think that would be in our jurisdiction, 22 ! but the inspection staff certainly would have authority to 23.} leek at that and determine whether it was so or no. 's n.j I have the impression that there are inspectors 0 l 25 there. Well, there were coing to be resident inspectors; E 1425 11I I
l 3494 4 i d=p5 1 uhather that nas ctarted, I'm not sure. 10 But presumably, if a resident inspector were 3 ali there, h3 wo21d be aware of whatever along this line u li . }; would happen or vould not happen. Il C, MR. FELDMAN: Okay. Thank you. l l CIRIRMAN BECHEOEFER: But there's nothing really + 7 we can do about this at this time. MR. FELDMAN: Thank you. o I have no further preliminary natters, then. 9 3e CHAIRMAN BECHHOEFER: Okay. Anybody else have any
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preliminaries? I (N response.) 12 Otherwise, we will proceed to the staff -- the g staff can proceed to present Mr. Maura on control rods. 33 MF. BARTH: We would call Mr. Maura to the stand. !L t; 6 Your Hor.or, he has previously appeared as a witness and g I been swcrn. e, At the last session of the hearing there was 18 i testinony taken regarding an affidavit by Gorman L. Reynolds g j regarding grinding on the costrol rods and the effect it ,g i might have. 21 l l The board invited the staff to come back with 22 i further evidence or statements of clarification that it 25 ; felt necessary. ,u. 9 j' Mr. Maura, a= the record shows, is with our 25 ll ne 1 l425 ll2 i
H i d d 3496 dsp7 of the page under (a), where it says "80 control rods >I ~] required grinding of a chamber." 1 J (l Instead of " chamber," that should be chamfer. So L 4 it's "f inrtead of a "b."' q 5h O With those corrections, sir, are the statements l f e O contain2d therein true and correct to the best of your i 7 ! knowledge ar.d ability and do you adopt them as your i ~ 0] testimony? f A Yes. u to " O Since the memb>rs of the audience do not have il 1: E a copy of this, what is the conclusion of the staff with II 12 !i regard to grinding on n hamfer? A My conclusions are that as a result of the u.I grinding, nc chips entered the control reds. t
- gh O
Since the grinding was done, if any chips were left, sir, vould it pose any safety problem for the 35 operation of the plant, should it ever reeive a license?
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i A Assuming any chips were left ~~ g, in. O If any chips were left, would they pose a safety } 29 l problem, should the plant receive a license? 8 A No, sir. y l l ME, BARTH: Mr. Chairman, I've provided copies _3_., of Mr. ?!aurt.'s testimony to the parties and to the reporter, l ., e, 't and I recuest that it be accepted as evidence and bound into a i 'l tha record as if it were read forth at length. I .o. \\ 'Io L i425 113 I a
i il H.. 3495 N
- t dsp6 inspection and enforcement office in Chicago.
- i Mr. Maura has investigated the matter.
I will ~ ', ;, proceed with the examination of evidence by Mr. Maura , f "Y 'It this time. il 1
- c Uhereupen, 6
FEDERICO A. MAURA 7 Il uas called as a witness, and having been previously duly N a uworn, was examined and testified as follows: a { DIRECT EXAMINATION 'I f BY MR. BARTH: to ;d Q Mr. Maura, I show you a document and ask you 1,. o to identify i'.. Will you please, sir. 12 - l A This is -- is this working? O I don't care. Speak loudly. 10 L ] A " Direct Testimony of Federico A. Maura Regarding 15 ! fl Metal Chips in Control Rods." It has three attachments. 16 !j
- j O
Was this prepared by you, Mr. Maura? 17 j l A Yes. 10 0 Was this prepared by you in response to the board's invitation at the last session of the hearings in 20 ' { crder to further clarify the staff's view of Mr. Reynold's 21 ! I affidavit? 22[ A YEs. 23,l t li Q Are the statenents contained therein true and 9.4 p correct to your knowledge and ability, sir? 25 !! A I'd like to make a correction on page 2, middle 1425'114 I I}}