ML19294A701

Forwards Applicants' Testimony of Conrad,Engmann & Connolly on Contentions 8 & 9 Re Fire Protection in Rebuttal to NRC 781208 Direct Testimony.Witness Will Testify on 790224

ML19294A701
Person / Time
Site:	Black Fox
Issue date:	02/09/1979
From:	Gallo J ISHAM, LINCOLN & BEALE
To:	Purdom P, Shon F, Wolfe S DREXEL UNIV., PHILADELPHIA, PA, Atomic Safety and Licensing Board Panel
References
NUDOCS 7903080201
Download: ML19294A701 (16)

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MCPWyc N RWQg 3 ISHAM, LINCOLN & BEALE COUNSELORS AT LAW 1050 9 7t* STR E ET, N. W. SCVENT M FLOOR WASHINOTOiv, O. C. 200 08 TELEPHONE 202-a33-9730 CMsCACO OFFICE ONC FIRST NATIONAL PLAZA FORTY-SECONO FLOOR CM4CAGO,ILLINO45 60603 February 9, 1979 ' ' "'", "$ '7,',*,*,'

Sheldon J. Wolfe, Esquire Mr. Frederick J. Shon, Member Atomic Safety and Licensing Atomic Safety and Licensing Board Panel Board Panel U.S. Nuclear Regulatory U.S. Nuclear Regulatory Commission Commission Washington, D.C. 20555 Washington, D.C. 20555 Dr. Paul W. Purdom, Director Environmental Studies Group Drexel University 32nd and Chestnut Street Philadelphia, Pennsylvania 19104 Re: In the Matter of the Application of )

Public Service Company of Oklahoma, )

Associated Electric Cooperative, Inc. ) Docket No. STN 50-556 and ) STN 50-557 Western Farmers Electric Cooperative )

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(Black Fox Station, Units 1 and 2) )

Gentlemen:

I am enclosing copies of Applicants' rebuttal testimony with respect to Contentions 8 and 9 concerning fire protection.

The witnesses are Messrs. Conrad, Engmann and Connolly. They will be presented to testify,as indicated in the schedule pro-vided by Mr. Davis, on Saturday, February 24, 1979.

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NRC PUBLIC DOCUMENT ROOM UNITED STATES OF AMERICA NUCLEAR REGULATORY COMMISSION BEFORE THE ATOMIC SAFETY AND LICENSING BOARD In the Matter of PUBLIC SERVICE COMPANY OF OKLAHOMA, )

ASSOCIATED ELECTRIC COOPERATIVE, INC., ) Docket Nos. STN 50-556 AND WESTERN FARMERS ELECTRIC ) STn 50-557 COOPERATIVE, INC. )

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(Black Fox Station, Units 1 and 2) )

Rebuttal Testimony of Mr. Vaughn L. Conrad Concerning Contentions 8 and 9 k

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REBUTTAL TESTIMONY OF VAUGHN L. CONRAD CONCERNING CONTENTIONS 8 AND 9 My name is Vaughn L. Conrad. I reside at 5120 S.

Richmond, Tulsa, Oklahoma, 74135. I am employed as Manager, Licensing and Compliance by Public Service Company of Oklahoma. As such, I am responsible for the environmental and safety licensing aspects of the Black Fox Station, Units 1 and 2, (BFS), and have been so designated since inception of the project. A statement of my qualifications has been previously admitted in this proceeding.

The purpose of the rebuttal testimony by Messrs.

Gary Engmann, James Connolly, and myself is to respond to direct testimony of the U.S. Nuclear Regulatory Com-mission Staff on December 8, 1978, regarding the adequacy of the Black Fox Station, Units 1 and 2 Fire Hazards Analysis. The Fire Hazards Analysis has been submitted to the Staff ~as Reference Report 16.

In its direct testimony, the NRC Staff suggested the necessity for Applicants to analyze the Black Fox

Station, considering fires initiated by external sources in addition to the realistic fire hazards analysis pre-viously performed, which was based on sources expected to be present, taking into account station design features and administrative controls. Applicants believe that the BFS Fire Hazards Analysis Report was performed in com-pliance with the guidelines of Branch Technical Position APCSB9.5-1 dated May 1, 1976. Although the NRC Staff has agreed that this report is the appropriate fire hazards analysis guidance for BFS, the definition of the design basis fire to be used in the fire hazards analysis to be performed during the post-construction permit review for the Black Fox Station remains a confused matter. Therefore, Applicants make the following commitment as a means of clarifying this issue:

Based on Branch Technical Position APCSB 9.5-1 dated May 1, 1976, and Appendix A thereto, Applicants agree and hereby commit to employ the following design basis fire for purposes of the fire hazard analysis for the Black Fox Station.

Design Basis Fires - are those that are con-sidered to cause most damage, i.e., an exposure fire that may develop in local areas assuming no manual, automatic or other firefighting action has been initiated and the fire has passed flash-over (i.e., the temperature at which auto-ignition of other combustibles in the area will occur) and has reached its peak burning rate.

f The foregoing design basis fire will be postulated for design purposes in each area of the Black Fox Station except the Reactor Building, the control room, and any further exceptions that may be approved by the NRC Staff.

With respect to the control room, a specific exposure fire has been postulated by GE and accepted by the NRC Staff. (See the testimony of Messrs. Gang and Johnson of GE, testimony at pages 7-8 following Tr. 6738, Tr. 6753, and Mr. Giardina of the NRC Staff Tr. 7035.) In the Reactor Building, exposure fires will be postulated dur-ing the post-construction permit fire analysis review by Applicants that can reasonably be expected to cause the most damage to safety related equipment, taking into account configuration and spacial separation and other methods to prevent propagation of fires within the Reactor Building. This analysis will, of course, be subject to review and approval by the NRC Staff.

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GC PUBLIC DOCU31ENT ROOM UNITED STATES OF AMERICA NUCLEAR REGULATO?Y COMMISSION BEFORE THE ATOMIC SAFETY AND LICENSING BOARD In the Matter of PUBLIC SERVICE COMPANY OF OKLAHOMA, )

ASSOCIATED ELECTRIC COOPERATIVE, INC.,) Docket Nos. STN 50-556 AND WESTERN FARMERS ELECTRIC ) STN 50-557 COOPERATIVE, INC. )

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(Black Fox Station, Units 1 and 2) )

Rebuttal Testimony of Mr. James M. Connolly Concerning Contentions 8 and 9 p 2 N

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REBUTTAL TESTIMONY OF JAMES M. CONNOLLY

,CONCERNING CONTENTIONS 8 AND 9 My name is James M. Connolly and I reside at 336 S.

Hudson Street, Westmont, Illinois. I am a Fire Protection Consultant employed by M&M Protection Consultants (M&MPC),

a Technical Service of Marsh & McLennan, Inc. A state-ment of my education and experience is included as Attachment I to my testimony.

I have reviewed the commitment made by Vaughn Conrad in light of the Fire Hazards Analysis for the Black Fox Station. It is my opinion that, with this commitment, the Black Fox Station will conform to General Design Criterion 3.

Criterion 3. has been interpreted to embody the de-fense in depth concept, and I believe that the Black Fox Station incorporates this concept. As first echelon protection, fires are prevented from starting through the use of noncombustible and fire retardant materials, and compliance with BTP 9.5-1 Appendix A in regard to training, administrative control and quality assurance.

Secondly, assuming fires occur, they would be de-tected and suppressed quickly, therefore limiting their

damage. This is accomplished by providing extensive fire detection, alarm, and extinguishing systems.

Section 1.2.1 of the FEA describes the criteria utilized in determining the need for automatic fire detection and extinguishing systems to meet this aspect of the defense in depth concept.

Thirdly, the plant safety systems are designed so that a fire that starts in spite of the fire prevention program and burns for a considerable time in spite of fire protection activities will not prevent essential plant safety functions from being performed. Based on Mr. Conrad's commitment to employ the design basis fire as he has defined it, I believe this element of the de-fense in depth concept will also be met. This will be accomplished by postulating the design basis fire, for fire hazards analysis purposes, for each area in the Black Fox Station, except for the Reactor Building and the control room. As indicated by Mr. Conrad, a specific exposure fire has been identified for the Control Room, and specific exposure fires will be postulated for the Reactor Building in order to conduct the fire hazards analysis for these areas. The exposure fires for the Control Room, the Reactor Building and the design basis fire for other areas will be evaluated to determine the impact on plant safety systems and the ability to safely shut down the reactor.

Also, application of the design basis fire, as des-cribed, will result in adequate separation of cable trays so as to prevent a recurrence at Black Fox Station of the type of fire which took place at the Browns Ferry Nuclear Plant. This includes the cable spreading room which has already been designed with adequate fire barrier separa-tion, automatic fire detection and automatic fire ex-tinguishing systems. Therefore, I believe the design would conform to 10 CFR 50, Appendix A, Criterion 3.

ATTACEMENT I BACKGROUND AND QUALIFICATIONS OF JAMES M. CONNOLLY FIRE PROTECTION CONSULTANT M&M PROTECTION CONSULTANTS, A TECHNICAL SERVICE OF MARSH & McLENNAN, INC.

EDUCATIONAL EXPERIENCE In Juna of 1978, I received a Masters Degree in Business Administration, specializing in management sys-tems from DePaul University. I received a Bachelor of Science Degree in Fire Protection and Safety Engineering from the Illinois Institute of Technology in 1974. Prior to that, I attended the University of Illinois, majoring in electrical engineering.

I was elected to the TAU BETA PI honorary engineer-ing fraternity and the Salamander Fire Protection Engineer-ing honorary fraternity.

PROFESSIONAL ASSOCIATIONS I am a member of the Institute of Electrical and Electronic Engineers (IEEE) Ad Hoc Coordination Committee on Cable Systems Fire Standards and Tests. I am currently working with several standards writing groups in regard to fire protection for electrical cable, including IEEE Standard 383 " Type Test of Class lE Electrical Cables, Field Splices, and Connections for Nuclear Power Generating Stations" and IEEE Standard P690, " Design and Installation of Cable Systems in Nuclear Power Generating Stations."

I also belong to the National Fire Protection Association and the Society of Fire Protection Engineers. I have successfully completed the Engineer-In-Training examina-tion for Professional Engineering qualification.

WORK EXPERIENCE I am a Fire Protection Ccnsultant in the seven person utility unit of M&M Protection Consultants, which provides consultation for approximately twenty utility companies located throughout the United States.

Since joining M&M Protection Consultants, I have specialized in a number of challenging disciplines, spend-ing a large portion of my time serving major electric utility' clients in the design, construction and protection of fossil and nuclear fueled generating facilities. These efforts have included initial concept conferences with management and architect-engineering firms and necessary follow-through inspection programs. Work performed is for utilities insured by Nuclear Mutual Limited and Ameri-can Nuclear Insurers, which requires a thorough working knowledge of all applicable codes and protection require-ments.

M&MPC has been providing consultation on fire pro-tection and loss prevention matters for Black Fox Station since 1974. On September 30, 1976, PSO was requested by Roger S. Boyd, Director, Division of Project Management, Office of Nuclear Reactor Regulation, to "... perform a

fire hazards analysis of your facility with assistance and the technical direction from a qualified fire protec-tion engineer." M&MPC was contacted by PSO in November.

of 1976 and entered into a contract to provide such services.

M&MPC's activities included meeting with the NRC Staff to discuss fire hazards analysis methodology, assisting in development of the methodology for conducting the fire hazards analysis, and subsequently reviewing and commenting on drafts of the analysis. The major portion of this cc-tivity took place between December, 1976, and March, 1977, and was primarily concerned with Section 2.0 of Reference Report 16, which is the Fire Hazards Analysis. M&MPC has been retained under contract to PSO for assistance in revising and reviewing the Fire Hazards Analysis.

NRQ PUBLIC DOCUMENT ROOM UNITED STATES OF AMERICA NUCLEAR REGULATORY COMMISSION BEFORE THE ATOMIC SAFETY AND LICENSING BOARD In the Matter of PUBLIC SERVICE COMPANY OF OKLAHOMA, )

ASSOCIATED ELECTRIC COOPERATIVE, INC.,) Docket Nos. STN 50-556 AND WESTERN FARMERS ELECTRIC ) STN 50-557 COOPERATIVE, INC. )

)

(Black Fox Station, Units 1 and 2) )

Rebuttal Testimony of Gary R. Engmann On Contentions 8 and 9

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February 9, 1979

REBUTTAL TESTIMONY OF GARY R. ENGMANN ON CONTENTIONS 8 AND 9 My name is Gary R. Engmann. I reside at 11409 W. 90 Terrace, Lenexa, Kansas. I am Project Engineer-Electrical Systems for the Black Fox Station design project at Black &

Veatch, Consulting Engineers in Kansas City, Missouri, an

" engineering firm retained by Public Service Company of Oklahoma. A statement of my background and qualifications has been previously included in the record as part of testimony on Contentions 7 and 8.

Mr. Behn, on behalf of the NRC Staff, identified some four areas in the Fire Hazards Analysis for the Black Fox Station in which the electrical cable tray design did not, in his opinion, meet the guidelines of Appendix A to Branch Technical Position APCSB 9.5-1, Guidelines for Fire Protection for Nuclear Power Plants, dated May 1, 1976.

Tr. 7057-62. Since submittal of the Fire Hazards Analysis, the electrical cable tray design has been revised somewhat so that certain areas identified by Mr. Behn no longer contain cable tray.

I have reviewed the current cable tray design for the Black Fox Station, and I have identified eight areas in which I believe the current design would not meet these guidelines given the design basis fire defined in Mr.

Vaughn Conrad's rebuttal testimony on Contentions 8 and 9.

These eight areas include the areas identified by Mr. Behn which still contain cable tray under the current design.

I have investigated these eight areas together with other Black and Veatch personnel having expertise in the areas of structural, mechanical, and heating, ventilation and air conditioning engineering, and we have determined that it is feasible to revise the current Black Fox Station design to meet these criteria. Specifically, it is feasible to revise the current design to establish additional Fire Areas by the addition of fire barriers, such that cable trays for redundant safety system cabling is installed in separate Fire Areas; and, therefore, safe shutdown of the reactor is assured with the design basis fire definition stated by Mr. Conrad. However, analysis of final design in these eight areas, and the cabling installed in the raceway in these areas, may show that the redundant system cabling is not necessary for safe shutdown and, therefore, additional fire barriers may not be required. These matters will be addressed as a part of the detailed design of the electrical raceways which will be accomplished during the post-construction permit review of the fire hazards analysis for the Black Fox Station. I believe that future raceway design can be accomplished such that safe shutdown of the reactor can be assured with the definition of design basis fire and the exceptions in the areas stated in Mr. Vaughn Conrad's rebuttal testimony.