ML19254F961
| ML19254F961 | |
| Person / Time | |
|---|---|
| Site: | LaSalle, Zimmer, Shoreham File:Long Island Lighting Company icon.png |
| Issue date: | 10/30/1979 |
| From: | Robin Barnes, Cohn B, Harrison G GAGE-BABCOCK ASSOCIATES, INC., Office of Nuclear Reactor Regulation |
| To: | |
| Shared Package | |
| ML19254F962 | List: |
| References | |
| NUDOCS 7911190528 | |
| Download: ML19254F961 (15) | |
Text
October 30, 979 Ny
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ULIC Dp~,..Sgg, ll0Qy UNITED STATES OF AMERICA NUCLEAP, REGULATORY COMMISSION BEFORE THE ATOMIC SAFETY AND LICENSING BOARD In the Matter of
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CINCINNATI GAS & ELECTRIC COMPANY
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Docket No. 50-358
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(Wm. H. Zimmer Nuclear Power Plant)
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9 Direct Testimony of Gregory A. Harrison 4 9 j
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Bert M. Cohn, and Robert D. Barnes d((g/
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Regarding Contention No.17, Kaowool As A Fire Barrier For Cable Trays E
A ta Gregory A. Harrison hereby states as follows:
.i I am employed as a Fire Protection Engineer in the Auxiliary Systems Branch, Division of Systems Safety, Fuclear Regulatory Commission, Bethesda, Maryland. My educational and professional qualifications are set forth immediately below:
Education B.S. Fire Protection Engineering, University of Maryland 1966; M.S. Civil Engineering, University of Maryland 1970; and ft.S. Engineering Admini-stration, George Washington 1979 I have received a certificate from Oak Ridge University covering the Radiation Safety Training Program.
In 1345 001 7 9111 goM f
' addition, I hold professional engineering registrations in California and Maryland in fire protection and civil engineering.
I belong to the Society of Fire Protection Engineers, the National Fire Protection Association and have authored numerous publications.
Experience I joined the USNRC in August,1977 as a fire protection engineer.
In this capacity I have performed inspections of power reactors during the con-struction stage to ascertain conformity with fire protection criteria, including the Zirmer facility; evaluated the adequacy of licensees' fire protection programs and its relation to the safety of operations.
Finally, I have prepared fire protection sections of the Staff's safety evaluations, for both BWR and PWR plants including the Zimmer facility, the appropriate pages of which are attached hereto and made a part of this testimony.
Prior to joining the Commission I worked two years for the Arabian American Oil Company (ARAMCO) in Dhahran, Saudi Arabia.
I held the position of Chief, Fire Protection Engineer for the Facilities Engineering Division.
From January,1973, to July,1975, I worked for the National Bureau of Standards in Gaithersburg, Maryland as fire protection engineer in fire research testing.
From July,1969, to January,1973, I worked as a general engineer with the Naval Ship Engineering Center, Washington, D.C.
From May,1967, to July,1969, I worked as a fire protection engineer for NASA at Goddard Space Flight Center, Greenbelt, Maryland.
1345 002
4 Bert M. Cohn hereby states as follows:
I am a consulting engineer specializing in fire protection and safety,, building code analysis, and physical security by Gage-Babcock & Associates (GBA),135 Addison Ave., Elmhurst, Illinois, where I hold the positions of Senior Vice President and Treasurer. GBA is a consulting firm specializing in fire testing and fire protection.
GBA is under contract with the U.S. Nuclear Reguilatory Commission to provide technical assistance for nuclear power plant fire protection program reviews and evaluations.
GBA has been providing fire protection consulting services and technical assistance to NRC since 1976.
I have been the project director for a major portion of this work.
Robert D. Barnes of GBA who works under my direct supervision is the project engineer for the Zimmer Nuclear Power Station.
Education and Experience of Bert M. Cohn I have a B.S. in Fire Protection and Safety Engineering, Illinois Institute A
of Technology,1952 and auRegistered Professional Engineer in Illinois, New 4
Jersey, New York, Virginia, and Alabama.
I am a Certified Protection Professional (American Society for Industrial Security) and Certified Fallout Shelter Analyst (Federal Emergency Management Agency).
13AS 003
. I have been employed by Gage-Bab' cock & Associates since 1977 as Senior Engineer and fire protection and safety consultant.
My major activities have been in the area of (1) life safety code compliance surveys of institutional properties, (2) design of fire detection systems, (3) municipal fire department evaluations, and (4) nuclear power plant fire protection program reivew and evaluation.
Prior thereto I was employed by Insurance Services Office, Wisconsin (1969-75), National Fire Protection Association, Boston (1975), Insurance Company of North America, Midwest Region (1975-76), and Veterans Administration, Wood, Wisc. (1976-77).
I am a member of Society of Fire Protection Engineers, American Society of Safety Engineers, American Society for Industrial Security, and American Society for Testing and Materials; Chairman of subcommittee on Combustibility standards, ASTM Committee E5 on Fire Standards; Member of Record Protection and Firesafety Symbols committees, National Fire Protection Association; and Chairman of Board of Fire and Police Commissioners, City of Elmhurst, Illinois.
I have lectured at college and professional symposia and have been a frequent speaker at professional society meetings and conferences, and authored numerous articles and reports.
I have been employed by Gage-Babcock & Associates since 1957; its vice president since 1963 and treasurer since 1968.
I have participated in and directed hundreds of projects, including design and specification of detection, alarm and 045 004
. ' fire extinguishing systems; risk analysis studies in industrial and institutional properties; loss investigations of equipment failures, fires and explosions; systems analysis for code trade-offs and equivalencies; and research and testing.
Prior to being employed by GBA I was employed by the U.S. Army Forces Far East in Japan and Korea as chief of fire protection sections (1955-57) and served in the U.S. Army in fire protection engineering positions at the Army Engineer Research & Development Laboratories and Army Forces Far East headquarters (1953-55).
Robert D. Barnes hereby states as follows:
Education and Experience I have a B.S. in Fire Protection Engineering, Illinois Institute of Technology, 1969.
Registered Professional Enginear in Wisconsin.
I am a member of the Society of Fire Protection Engineers.
I have been employed by GBA as a fire protection engineer since 1976 specializing in reviewing fire hazard and fire protection programs for nuclear power plants.
I work under the direct supervision of Bert M. Cohn, Prior to being employed by GBA I worked in fire protection analysis for several insurance companies.
I have witnessed tests of Kaowool and am familiar with its fire resistant properties.
The Miami Valley Power Project has raised Contention 17, regarding fire protection, which is set forth at length below.
1345 005
. C_of erition 17 t
'i, 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 perfonned in that conditions which will exist during operation were not adequately simulated.
This matter is addressed in the fire protection section of the Staff's Supple-ment No.1 to the Safety Evaluation, the two pertinent pages of which are attached hereto and made a part of this testimony.
In further amplification of the protective value of Kaowool we state as follows.
Mr. Cohn and Mr. Barnes are associated with Gage-Babcock & Associates, Inc.
and act as consultants to the NRC in the evaluation of fire protection programs for nuc1;ar power plants.
Messrs. Robert D. Barnes and Bert Cohn have participated in the NRC review and evaluation of the adequacy of fire safety measures to be incorporated in the Zimmer Nuclear Power Station including measures to protect electrical cables and cable trays.
This work was done for and in close cooperation with the staff of Division of Systems Safety, NRC and in particular with Mr. Greg Harrison of the NRC.
Using NRC guidelines (BTP 9.5-1) and nationally recognized fire protection standards, Mr. Barnes and Mr. Harrison reviewed the fire pro-tection evaluation report submitted by the applicant for the Zimmer plant, provided comments, questions, and evaluations as to the adequacy of the fire protection features and tests, and performed an on-site, 3-day 1345 006
. survey at Zimmer, attended meetings with the applicant to resolve differences as to tha need for protective measures.
Mr. Cohn 's invol vo-ment with Zimmer was periodically to review the progress of Mr. Barnes' review and assist in resolving technical issues.
In addition, Mr. Cohn witnessed, at the request of the NRC, the test of Kaowool as fire protec-tive insulating material on cable trays by Portland Cement Association at their Construction Technology Laboratories on June 6,1979, a copy of which is appended to this testimony.
This report was written by fielvin S. Abrams.
All of us, Messrs. Cohn, Barnes, and Harrison recognize Mr. Abrams as an acknowledged expert in the testing of fire resistant materials.
The test procedures, equipment, and results are, based on our professiona knowledge and expertise, accurately set forth in the report authored by Mr. Abrams.
We fully concur in the conclusions reached by Mr. Abrams that the Kaowool material and the design tested offers a 1-1/2 fire resistant rating for cable trays.
Our principal concern in the review and evaluation process is to asrist the NRC to assure that an adequate level of fire protection is provided in areas where wiring and equipment serve safety equipment and could be subject to damage from a single fire incident.
In the situation of cable trays, the location of each tray to the other, the location of trays within the space, the separation between redundant divisions, the presence of materials and equipment creating a fire exposure, the acces-sibility of the space for firefighting, the presence of fire dete: tion and fire suppression equipment, and other factors are considered
'n establishing whether additional protective measures, such as fire barriers or insulation are required, and if so, what those additior al 13A5 007 protective measures should be.
These determinations are made based upon our expertise in this situation. Both Messrs Barnes and Harrison have inspected the Zimmer facility.
For Zimmer, Barnes determined, with Mr. Harrison concurring, that there were several areas requiring additional measures of protection. The applicant has agreed to the installation of fire barriers, protective insulation, automatic sprinklers, or combinati.ons thereof in those places recommended by Bares and Harrison for additional protection.
The applicant proposed to use Kaowool as a protective insulation material upon cable trays and conducted tests to sFow its adequacy for the purpose (Revision 12 to 7immer Fire Protection Evaluation Report).
Both Mr. Cohn and Mr. Barnes recommended to the NRC staff that these tests be rejected because they did not simulate standard ASTM E119 fire test conditions.
In a memo to the Zimmer proj.ct manager dated April 19, 1979, from Stoltz to Bergman, the NRC staff ptated that all fire tests todate submitted by Zimmer did not suppor,t a 1-1/2 hour fire rating and, Sence, an open item existed (see staff legal filing 5/7/79).
An additional test was then scheduled by Zimmer, at the request of the NRC, to be conducted under standard test conditions, using the ASTM E119 procedures, at PCA Laboratories.
Mr. Cohn reviewed the test pro-cedures and equipment prior to the test and was satisfied that the test would represent at least as severe a condition as could reasonably be envisioned under actual use conditions in the Zinmer facility.
PCA Lt.boratories and its manager of the fire research section (Mr. Abrams) are known by us to be experts, thoroughly familiar with _ standard fire 1345 008
. test procedures and able to conduct such tests impartially and objec-tively.
This test, using four fully loaded cable trays, each indivi-dually wrapped with Kaowool insulation, was conducted on June 6,1979.
Fvery few minutes during the test, Mr. Cohn checked the temperature recorders and observed the test specimens in the furnace for indications of premature failure.
There were none. The protected trays successfully resisted the effects of the exposure fire for a period of not less then 90 min.
This test is described in the report by Melvin S. Abrams, entitled
" Fire Protective Cable Tray Fire Test," dated June,1979, copy' attached nereto.
Mr. Cohn subsequently submitted his approval to the NRC via a letter " Fire Test of Cable Trays, Zimmer Nuclear Power Station,"- dated 12 June 1979.
Although the cables did not carry full electrical loads, which would liberate some heat internally to the trays, we know that this parameter is not a major one because the issue involves an external fire exposure.
The degree to which energized cables could hasten a test failure is well within the range of the normal variances one could expect from tests of this nature and, hence, externally minimal, e.g.
a few minutes.
We are familiar with the fire test conducted under the' auspices of Sandia Laboratories at Underwriters Laboratories on September 15, 1978, reported in NUREG/CR-0596, A Preliminary Report on Fire Protection.
This test was to demonstrate the effectiveness of Kaowool and automa: tic sprinklers in protecting cables in vertical cable trays. We assi sted in developing some of the criteria for this test.
The fuel, 2 gal. of a flammable liquid (heptane), was poured on the floor, and some of' it seeped under and through the Kaowool which was wrapped around the v ertical cable tray.
1345 009 Because of this, some of the heptane burned within and inside the Kaowool blanket and damaged some of the electrical cables.
The Kaowool is totally noncombustible [ composed primarily of silica and alumina compounds (SiO2 and Al 0 )], cannot burn, and did not contribute to the fire.
The effective-23 ness of this...aterial as a fire protective insulation was not challenged by this test, and it did not fail. An adhesive material and a simple curb or sheet metal shield around the base of the insulating material would have prevented the liquid from seeping under and into the insulation.
The applicant has agreed to provide curbs or shields and an adhesive coating wherever this situation exists at Zimmer.
The fire protection Section IV SER Supplement No.1 (copy attached hereto) for Zimmer states that the PCA fire test conclusively demonstrates the adequacy of the Kaowool design and that Kaowool is acceptable as a fire barrier.
All of us signing this testimony concur with that conclusion.
We f.urther conclude that a 1 inch layer of Kaowool wrapped around a cable tray will provide a 30-minute effective fire resistant barrier, a 2 inch will provide a 60-minute barrier, e 3 inch will provide a 90-minute barrier.
By an effective barrier, we mean that the cables contained in PAS 010
. the tray will be able to perform their function without failure for the quoted time period.
Gre9ery A. Harrison Bert M. Cohn Robert D. Barnes Dated at Bethesda, Maryland, this 30th day of October,1979.
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SER Supp. No.1 - Zimer Facility E.
Plant Areas Containina Redundant Divisions A number of plant areas have physical arrangements wherein redundant divisions of cables / conduits and equipment are in close proximity to each other and, therefore, cculd be vulneraole to a single, transient fire event. Originally, the applicant was relying solely administrative controls to preclude a fire event from taking olace 17 affected areas. Based on experience, adninistrative controls alone are not sufficient to prevent storage of combustibles, occurrence of all ignition sources, etc. We requested, and the applicant agreed in revision 13, to provide 1 1/2 hour fire rated barriers for one of the divisions. This additional measure will serve as the equivalent of adequate physical separation. Areas that come under this considerati,on are as folicws:
Elec. Dwc.#
FRA Dwc.#
Elev.
Area Div.
202 14 473'5" Off-Gas I,II,III 211 13 503'6" Reactor Bldg (N/W)
I,II 211 13 503'6" Reactor Bldg (S/W)
I,III 21"_(+232) 13 496'0" I,II,III 221 11 525'7" Reactor Bldg (N/E)
I,II 222 11 525'7" Reactor Bldg (N/W)
I,II' 222 11 525'7" Reactor Bldg (S/W)
I,II 223 11 536'0" CSR I,II,III 223
- 11 521 '0" Aux. Equip. Pa.
I,II,III 224 11 525'7" Div. II Switchgear I,II,III 224 11 E25'7" Lif t Truck Route I,II,III 1345 Ol2
SER Supp. No.1 - Zimmer Facility Elec. Dwo.#
FHA Dwa.#
Elev.
- Area, Div.
232 12 51 0'6" Div. III Switchgear I,II,III 234 10 546'0" Reactor Bldg (S/E)
I,II 235 10 546'0" Reactor Bldg (S/W)
I,II 237 10 546'0" Div. I Ssitchgear I,II 237 10 546'0" Heater Bay I.,I I 240 15 567'5" HVAC hrea.
I,II 241 15 570'6" Reactor Bldg I,II 244 593'6" Reactor Bldg (S/W)
I,II 264 Various Manholes I,II,III At.our recuest, the acolicant acreed to perform a fire test to verify the fire rating of the proposed 1-1/2 hour fire barrier design. On June 6,1979, a fire test was perfomed by the Portland Cement Association L'aboratories (.PCAL) Skokie, Illinois.
The fire test followed the ASTM E-119 test procedure in a beam fur-na:e and was witnessed by a fire protectfon consultant to the NRC.
The test results are contained in a report prepared by PCAL entitled,
" Fire Protective Cable Tray Fire Test" dated June,1979. The fire test. demonstrated conclusively that the proposed fire barrier design is satisfactory and is, therefore, acceptable.
We have reviewed the areas containing redundant divisions of equip-meat and cable and conclude that with the modifications, the fire
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protection meeis Accendix d to BTP 9.5-1 and 's, therefore, acceptable.
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UNITED STATES OF AMERICA NUCLEAR REGULATORY COMISSION
'BEFORE THE ATOMIC SAFETY AND LICENSING BOARD In the Matter of
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CINCINNATI GAS AND ELECTRIC
)
Docket No. 358 COMPANY, et al.
(Wm. H. Zimer Nuclear Power
)
Station, Unit No.1)
)
CERTIFICATE OF SERVICE I hereby certify that copies of " Direct Testimony of Gregory A. Harrison, Bert M.
Cohn, and Robert D. Barnes Regarding Contention No.17, Kaowool As A Fire Barrier For Cable Trays" and " Direct Testimony of Frederico A. Maura Regardin5 Metal Chips in Control Rods" in the above-captioned proceedin~g 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 interna'.' mail system, this 30th day of October, 1979:
Charles Bechhoefer, Esq., Chairman
- Leah S. Kosik, Esq.
Atomic Safety and Licensing 3454 Cornell Place Board Panel C hcinnati, Ohio 45220 U.S. Nuclear Regulatory Commis'sion 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 Comissioners Mr. Glenn 0. Bright
- 50 Market Street Atomic Safety and Licensing
. Clermont County Board Panel Batavia, Ohio 45103 U.S. Nuclear Regulatcry 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.
20006 1345 014
2-i l
William J. Moran, Esq.
Atomic Safety and Licensing General Counsel Aopeal Board
- Cincinnati Gas & Electric Company U.S. Nuclear Regulatory Commission P.O. Box i60 Washington, D. C.
205t,5 Cincinnats, Ohio 45201 Docketing and Service Section*
Atomic Safety and Licensing Office of the Secretr.ry
, Board Panel
- U.S. Nuclear Regulatory Commission U.S. Nuclear Regulatory Conmission Washington, D. C.
20555 Washington, D. C.
20555 David Martin, Esq.
Office of the Attorne,' General 209 St. Clair Street First Floor Frankfort, Kentucky 40601 o
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Charles A. Barth Counsel for ilRC Staf'f
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s O g en g
TESTS.0F KA0 WOOL AS A FIRE PROTECTION INSULATION MATERIAL 9
a' 1345 016 9
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