ML19249D958
| ML19249D958 | |
| Person / Time | |
|---|---|
| Site: | Zimmer |
| Issue date: | 08/22/1979 |
| From: | Barth C NRC OFFICE OF THE EXECUTIVE LEGAL DIRECTOR (OELD) |
| To: | |
| References | |
| NUDOCS 7909250609 | |
| Download: ML19249D958 (9) | |
Text
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August 22, 1979
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UNITED STATES OF AMERICA NUCLEAR REGULA10RY LCMMISSION BEFORE THE ATOMIC SAFETY AND LICENSING BOARD In the Matter of
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CINCINNATI GAS AND ELECTRIC
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Docket No. 50-358 l
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sN To:
Leah S. Kosik, Esq.
Counsel for Miami Valley
/g g 4 Power Project 3454 Cornell Place Cincinnati, Ohio 45220 NRC STAFF INTERROGATORIES TO MIAMI VALLEY POWER PROJECT REGARDING CONTENTION NUMBER 17 Pursuant to 10 CFR 52.740b and the Order of the Licensing Board dated August 7, 1979, the NRC Staff hereby requires Miami Valley Power Project (MVPP) to answer separately and fully, in writing and under oath or affinnation, the following Interrogatories on or before September 6,1979. All Interrogatories relate to Miami Valley Power Project Contention 17 which is set forth below:
Contention 17 Fire insulation material which is being used to protect the cables in the cable trays from fire is inadequate to protect the cables in light of the cable tray installation design and cable tray load.
The tests of the fire insulation material were improperly performed in that conditions which will exist during operation were not adequately simulated.
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< 1.
Identify all persons by name, address, position and employment upon whom MVPP relies to substantiate their Contention Number 17.
2.
Identify all experts by name, address, position and employment wno may be called by MVPP as witnesses in this proceeding to substantiate their Contention Number 17.
3.
Have each expert identified in Interrogatory 2 above summarize his testimony.
4.
Identify by author, title, date and publication all graphic materials of any kind upon which MVPP or any of its advisors, consultants or experts relies to substantiate Contention Number 17.
5.
Will MVPP voluntarily make all graphic materials identified in response to Interrogatory Number 4 above available to the NRC Staff for examination and copying?
6.
Provide all independent calculations made by MVPP or their consultants, advisors or experts which may supi ort their Contention Number 17 or their allegation that Kaowool caught fire when it was tested (Tr. p.175, line 19).
7.
Describe fully all physical and/or mathematical models used by MVPP or their consultants, advisors or experts to substantiate Contention Number 17.
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8.
Is Kaowool the fire insulation material referred to in Contention Number 17?
9.
If the answer to Interrogatory Number 8 is yes, in whole or in part, provide the basis for your assertion that Kaowool will be used in the Zimmer facility.
10'.
Identify by raceway, bus, er cable tray where Kaowool will be, or is, used in the Zimmer facility.
11(a).
Identify by time of day, date of month, year and geographic location where the " improperly performed" tests of fire insulation material were performed.
11(b). Who (what corporation or organization) performed the tests referred to above?
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ll(c). Who by name, title, position and corporate affiliation was present durin;
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the tests?
V 11(d).
Describe, step by step, how the tests were performed, including a description of the physical and mechanical equipment used to perfonn the tests.
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ll(e). Describe the design basis scenario for which cable fire insulation protection is required for reactor safety.
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. ll(f). Specify which plant cables require plant fire protection for reactor safety and why they are essential.
12.
Identify with particularity which test (or tests) was improperly performed and describe the impropriety alleged to have occurred.
- 13. Describe how the design of the cable trays affects the performance of the fire insulation material.
14.
Describe how the " cable tray load" affects the performance of the fire insulation material.
- 15. What " conditions... will exist durino operation [that] were not adequately simulated" in the tests?
- 16. How will the non-simulated operation conditions affect the ability of the cables to be protected from fire and to perform their required function to transmit their required signals or energy?
- 17. What is the basis of the assertion that the test results were not documented (page 2, MVPP filing dated April 30, 1979)?
18.
Identify the applicable standards for standard methods of fire tests of materials.
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4 19(a). Has MVPP or its experts, advisors or consultants read, reviewed cr seen Underwriters Laboratory Inc. File R 8758, Project 78 NK 5345, September 6, 1978, Report on Cable Raceway Protection Systems Fire Test Investigationt 19(b).
Does MVPP have a copy of the aforesaid report in its possession or control?
19(c).
If the answer to 19(a) or 19(b) is yes, then identify by page and paragraph the parts of said report that substantiate the allegation that tne tests were improperly performed and describe the alleged improprieties.
19(d). Does MVPP or its consultants, advisors or experts have any graphic material other than the aforesaid report which demonstrate any impropriety in testing fire insulating material?
19(e).
If the answer in whole or in part to Interrogatories 19(c) or 19(d) is yes, then identify by name and address the person concerned.
20.
Identify by trade name and manufacturer the fire insulation material referred to in Contention 17.
21(a).
State in detail the basis for MVPP's allegation that Xaowool caught fire when it was tested (Tr. p.175, line 19).
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~ 21(b). At what temperature and pressure did the Kaowool catch fire?
21(c).
Identify the test during which the Kaowool caught fire.
- 22. Are there industry standards for fire tests of material and if so identify them?
23.
If there are industry standards for fire testing material, did the tests identified in Interrogatory Number 11 conform to these standards?
24.
If the answer to Interrogatory 23 is no't categorically affirmative, identify in all respects how the tests failed to conform to the aforesaid industry standards.
- 25. Set forth the results, in terms of fire protection and loss of cable function, of the tests identified in response to -Interrogatory Number 11,
- 26. MVPP's filing of April 30, 1979, states that "Edwin Hofstadter, in a confidential manner, secured details of a test of the fire insulation material which show the material failed to pass the test."
(a).
Does MVPP have, or have they had, access to the details of a test where the raterial failed to pass the test?
(b).
If the reply to Interrogatory 26(a) is affirmative, then identify the test and set forth these details.
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-7 I (c). Describe in detail the " test perform 6nce and standards" that the fire insulation material was supposed to pass.
27.
Describe fully the environmental conditions, including mitigating facilities such as sprinklers and alarms, which MVPP alleges would properly test Kaowool and identify the deficiencies in these environmental conditions, including mitigating facilities, which made the tests improper; also identify which tests these were.
28.
For each of the tests identified in response to Interrogatory Nutrber 11 above, describe in detail the cables that were tested, i.e., size, length, type of material, load carried, etc.
- 29. For each of the tests identified in response to Interrogatory 11, ide.1tify the type of cable tray used.
30.
Identify by name and address all persons known to you to support MVPF's allegations tha,t the tests were improperly perferred or that Kaowool failed to pass any of the tests identified in response to Interrogatory Number 1.
31.
Identify for each Interrogatory by name, address and employment position all persons who wrote or substantially contributed to MVFP's response.
Respectfully submitted, Charles A. Barth Counsel for NRC Staff Dated at Bethesda, Maryland, this 22nd day of August,1979.
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UNITED STATES OF AMERICA NUCLEAR REGULATORY COMMISSION r
BEFORE THE ATOMIC SAFETY AND LICENSING E0ARD In the Matter of CINCINNATI GAS AND ELECTRIC Docket No. 50-358 COMPANY, et al.
(Nm. H. Zimmer Nuclear Power
)
Station, Unit No.1)
)
CERTITICATE OF SERVICE I hereby certify that copies of "NRC STAFF INTERR0GATORIES TO MIAMI VALLEY POWER PROJECT REGARDING CONTENTION NUMBER 17" in tne above-captioned proceeding have been served on the following by deposit in the United States. mail, first class, or, as indicated by an asterisk by deposit in the Nuclear Regulatory Commission internal mail system, this 22nd day of August,1979:
Charles Bechhoefer, Esq., Chairman
- Leah S. Kosik, Esq.
Atomic Safety and Licensing 3454 Cornell Place Board Panel Cincinnati, Ohio 45220 U.S. Nuclear Regulatory Commission Washington, D.C.
20555 W. Peter Heile, Esg.
Assistant City Solicitor Dr. Frank F. Hooper Room 214, City Hall School of Natural Resources Cincinnati, Ohio 45220 University of Michigan Ann Arbor, Michigan 48109 Timothy S. Hogan, Jr., Chairman Board of Commissioners Mr. Glenn 0. Bright
- 50 Market Street Atomic Safety and Licensing Clermont County Board Panel Batavia, Ohio 45103 U.S. Nuclear Regulatory Commission Washington, D.C.
20555 John D. Woliver, Esq.
Clermont County Community Council Troy B. Conner, Esq.
Box 181 Conner, Moore and Corber Batavia, Ohio 45103 1747 Pennsylvania Avenue, N.W.
Washington, D.C.
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2-l' William J. Moran, Esq.
Atomic Safety and Licensinq General Cognsel Aopeal Board
- Cincinnati Gas & Electric Company U.S. Nuclear Regulatory Comission P.O. Box 960 Washington, D. C.
20555 Cincinnati, Ohio 45201 Docketina and Se vice Section*
Atomic Safety and Licensing Office of the Secretary
, Board Panel
- U.S. Nuclear Regulatory Comission U.S. Nuclear Regulatory Coninission Washington, D. C.
20:35 Washington, D. C.
20555 AS Cnaries A. Barth Counsel for NRC Staff oo e4 1027 111 i
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