ML20147B653

Transcript of Hearing on 781207 in Tulsa,Ok.Pp 6728-6899

ML20147B653
Person / Time
Site:	Black Fox
Issue date:	12/07/1978
From:	Purdom P, Shon F, Wolfe S Atomic Safety and Licensing Board Panel
To:
References
NUDOCS 7812150364
Download: ML20147B653 (171)

Text

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pr PUBLIC DOCU.1ENT ROC'.'.i NUCLE AR REGUL ATORY COMMISSION IN THE MATTER OF:

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ACE FEDERAL REPORTERS,INC.

OfficialReponen R. 444 North C pitel Street Weshington. D.C. 20001 NADONWIDE COVERAGE . DAILY 7 812150 M42

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4 In the mattar of: -

3! PUDLIC SEPNICE CD"A:1v nm -

DICJ,.itn'tA N:FncP"T*1 ELET".IC t l 5, COOPEItATIVE, IUC., and  : Docket ilos.

1: ESTER:7 FAR*tE'.S ELECT 7.IC  :

7 COOPritATIvr  : 5'i-5'M

50-557 (Black Fox Station, Units 1 and 2) -

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g1 _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _x ,

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10 Uni'.cd States Courthouse 11 carerocn *!.>. 1 '

333 t'. At?,, Ftreet 12 Tulsa, Ok.1.ahona 13 Thursday, recenber 7. 1978 14

- The hearing in the above-entitled natter was 1

15 !'

reconvened, nursuant to adjournment, at 10 00 a.n.

i 16 DEFORE:

l 17 SI!ELDO!i .T. ?*nLPE, ESn . , Chairman ,

+

gg Atomic Safety & Licensing Doard. ,

Dit. PAUL U. PURDO't, 'tenber.

39 I

j ;0 ,. FRFDERICK .T. SItO!!, 'tenber .

t 3

~1 i APPEARAliCES:

4 22 (As heretofere noted.)

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ar 6729 1 CQEZEEEE

, 2 Witness: Direct Cross Redir. Recr. Board 3

Richard B. Johnson )

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4 William C. Gang

)

)

6736 6741 6823 6824 6829 6825 5

6 Gary R. Engmann )

.) 6831 6840 7 Dr. E. L. Cox )

8 9

10 11 12

) EXHIBITS: For Identification: Received:

14 Applicant's Exhibit No. 33

,s o_

(Reference Report 16) 6836 6840 16 17 18 19 20 21 22 23 U

s i

G730 limL wel 1 1 P R O,C,E E D,I N G S_

s 2l CHAIR' TAN 170LFE: The hearing is resumed.

3 fir. Gallo, could you report whether you've been 4 4 able to make an adjustment and have your Itcscrs. Gang and I

i 5} Marcus here on Deard Question 10-4 prior to Thursday next?

6' MR. GALLO:  !!ay we go off the record for a bench 7 conference?

8 CIIAIRMAN tiOLFE: All right.

9 (Bench conference.)

i 10 CHAIRMAN WOLFE: All right. We will now proceed ,

11 with the taking of evidence on contentions 7, 8 and 9.

12 MR. NELSON: Mr. Chairman, Applicants have a 13 preliminary matter to be addressed by !!r. Gallo. ,

14 ftR. GALLO: fir. Chairman, I've written a letter to 15 the Licer 'g Board dated December 6, and I have here copies 16 for the Board. I apologize for the si=e of the package. I 2

17 have already distributed copies to counsel for the Intervenors j

) ja and counsel for the 3raff.

19 The letter is self explanatory, and the attachments 20 concern containment matters. Ue're furnishing the information 21 for the benefit of the parties and the Board at this time.

22 That's all I have, Mr. Chairnan, unless there are i 23 questions and further discussion necessary at this point.

CHAIRMAN WOLFE Any comments, Mr. Farris, at this 24 25 Di""?

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I i 6731 wel 2 i

(

1 f tR. FARRIS: No, sir.

. . , t 2 CHAIRMAN UCLFE:  !!r. Davis?

3 MR.-DAVIS: No, sir.

4 CIIAIR! TAN UOLFE: All right. !ir. Melson?

5 MR. HELSCH: Mr. Chai man, I would like to first i l .

s outline how Applicants are proposing to handle Contentions 7 numbers 7, 9 and 9.

3 The first item is that I would present the prefiled 9 objections to the testimony by Mr. Gregory C. Minor for the il 10 Intervenors.

Secondly, we would offer our witnesses, Mr. Richard 12 Johnson and Mr. Willian Gang, to testify on Contentions 7 and g3 3 as they relate to the GE scope of supply. They would then

)

be offered for cross-examination and for questioning by the 14 l t

3 Board.  ;

l 16 After that, my eclieague, Mr. Gallo, will present )

17 the witnesses Messrs. Gary Engman and Ed Cox, to testify on 18 Contentions 7, 3 and 9, as they relate to the Black and Voatch j l

gg scope of supply. They will then be presented for cross-e:camina-l l

20 tion and for questioning by the Board.

2; After that, when the Staff witnesses are presented gg Mr. Gallo will handle the cross-examination of those witnesses.

O m After that, when Mr. Minor is offered as the Intervencrs' witness, I will handle the cross-examination of 24

-- ) 25 N#* Ui" #*

wol 3 6732 1 I just wanted to explain that so it wouldn't come  !

2 ] as a surprise 'later on, j 3 Turning then to the --

i 9 4 CHAIRMAN WCLFE: Just a moment, Mr. Nelson. I i

5 (The Board conferring.)  ;

6 CIIAIIt1AN WOLFE: All right, Mr. Nelson. I 7 MR. NELSON: Turning to the prefiled objections i

g with respect to Mr. Minor's testimony, which occurs on page .

9 3 of our prefiled objections, the objection addresses one 10 paragraph, which is paragraph number 3.2.3, titled, " Cable 33 Traceability," Mr. Chairman, the objection is based on two 12 bases: ,

First off we point out that traceability is 13

)

14 addressed in 10 CFR Part 50, Appendix 3, Criterion 8, in the part dealing with quality assurance. Today we are concerned 15 with 10 CFR Part 50, Appendix A, Criterion 3. The paragraph 16 testimony is irrelevant. It is not within the scope of 17 18 the questiens we are considering, fire protaction, 'and on the I gg grounds of irrelevancy it is objectionable. p 20-Secondly, the motion for summary disposition with 21 respect to Contention 10, the quality assurance contentions, and the Board's ruling. on page 32, address the subject of 22 O , the requirement for cab 1e eraceabi11ey a=d determined thae in y fact this was not required. For that reason we point out that e a ard as already M ed on de s M eet p g orted to M 25

il ..

6733 ii wel 4- ,

I addressed in'this paragraph, and has ruled against the position that Mr. Minor is espousing.  !

3 It's a question which has already been heard by 4- ,

the Board, and should not be raised again. v Therefore, we mo'e that it be strickan.

5 MR. FARRIS: Mr. Chairman, our Contention 7 is as a ~

' i follows:

1 .

3i "Intervenors contend that in order for the Applicant '

9 to meet 10 CFR Part 50 Appendix A criterien 3, Black Fox i

to 1 and 2 must utilise cables with fire-retardant insulation.i"

, i 11 The paragraph t at Mr. Nelson refers to talks about 12 the utilization of fire-retardant insulation. It seems

} 13 patently obvious to me that if you're going to talk about i 14 utilization, you have to talk about utilization;-that is, j 15 using it in place, and how do you ensure that the fire- ,

i 16 retardant insulation has in fact been used? Not that it's '

t 17 intended to be used, but that it is, in fact, used. I 16 Our contantion has not been narrowed, to my 13 understanding, to any Board question, but stands as written, N i 20 as do all the contentiens, 7, 8 and 9, dealing with fire 1

21 protection. j i

22 Therefore, it's clearly relevant in our opinion.

4 O 23 CHAIRMAN WOLFE Ms. Woodhead?

! 24 MS. WOODEEAD: Mr. Chairman, the Staff supports E5 the Applicants' view of this section, and thinks that it is i

e

6734 wal 5 1 irrelevant, in that it seems to imply that even though certain

- 2 insulatien might be required, it would not, indeed, be l'

3 installed in the plant.

h 4 It's a circular sort of argument, ar d not a 5 particularly relevant argument to Critarion 3.

I 6 (The Board ccnferring.)

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9 10 11 12 3 13 14 15 16 17 18 ,

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21 22 23 24

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673a tape 2 t CHAIR $AN WOLFE: We have consif.ered the age.ments i,

• i and find apolicant's objections to be rell takan, and

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[ therefore the objection is sustained, and section 3.2.3 of G/

4 lI the written testimony of Mr. ?^inor is stricken.

l 3l MR. SHON: It is evident to the betrd that the 6[ i recruirements in Appendi:c A of Part 50 plus criterion eight of 7i Part 3 which is intended to make certain that proper i t

3 ,

identification of installed parts is made to insure 9 exactly what Mr. Parris is talking about, that this thing 10 is built the way it is sunnosed to be built.

I 11 In the matter of the insurance appendix, Appendi:c 12 B, we note in our order before -- or our order on motion 13 for su::mtary disposition that traceability is not set forth 14 l as the only way of assuring this. It is one of tfo 15 alternatives, in fact. ,

I 16 And we feel that either of these alternatives 17 can serve the purpose that Mr. Farris outlined. l i

1 i

18 CHAIPJ1AN WCLFE: Mr. Nelson?

19 MR. NELSON: We call Messrs. Gang and Johnson.

20 Mr. Gang has been sworn. Mr. Johnson has not.

21 Whereupon, 22 WILLINT G. CANG O 23 was called as a witness, and having been previously duly 24 sworn, was examined and testified as follcws:

9 '

25 and ,

1 i

. .. . 9

[

6736 I RICHARD B. JOfi?iSON david 2

^ 2

) was called as a witness, and having been duly sworn, was 1

o examined and testified as follows:

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DIRECT EXAMINATION 5 BY MR. NEI. SON:

6 q Starting with Mr. Gang; in your capacity as 7 project manager for the Black Fox nroject at General 8 Electric, have you had cecasion to prepare testimony 9 regardina contingents seven and eight?

10 -

A (Witanss Gang) I have.

II O I hand you a document entitled ""estimony of 12 Messrs. William G. Gang and Richard B. Johnson ancerning

) 13 Contentions 7 and B (Fire Protection) ," and ask you if that 14 is the testimony that you prepared.

15 (Handing document to witness.)

16 A It is.

17 0 Do you have any corrections or additions at 18 this time?

19 A YEs. There is a typographical error on cage 20 1 under footnote number 1, the first line. It says, " Inter-21 venors content."

22 THat should be " contend." Substitute the T for -

O 23 a D.

24 q Do you have any other corrections or additions?

' No, sir.

25 A

! I l' I

! 6737 i l l

i I ,

Q. Which parts of this testimony did you participate ,

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l il in preparing, Mr. Gang? ,

V  !! . 1 3f A I assisted with all parts. l ps 4!

0 Is the testimony true and accurate to the best

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3 ,. of your knowledge and belief? j l

6' A Yes, sir.  !,

I 7'Ii G Mr. Johnson, by whom are you employed? [

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3! ,

A (Witness Johnson) General Electric Company. -

'l 9 Q What capacitv?

10 j A Senior licensing engineer, nuclear energy. division.

i 11! n In that caoacity, did you carticipate. in i

l a ', preparation on testimony on contentions seven and eight? ,

13 i A Yes, I did.

} ,l t 14! O I mu handing you the same document which I e

i 15 just handed Mr. Gang.. I will ask if this is the cestimony i

16 that you participated in preparing?

I7 (Handing document to witness.)

i Yes, this is.

A lal 19 0 Directing your attention to attachment number 20 ene of the testimony, is that a statement of your

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21 professional cualifications?

22 A YEs, it is.

O 23 ,

O Mr. Johnson, do you have any corrections or 24 additions'to this testimony at this time?

25 A A typographical error on cualifications.

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6738 i

david 4 1 q Would you state it?

2 A The first line of e::periences states that a

I am currently the licensing engineer recconsible. It 3

C 4 should read: "I am currently the licensing engineer,"

instead of ingineering responsible."

5 6 Q Any others?

A That's all.

7 0 m . h son, which parts of'this testimony did 8

g you assist in preparing?

A All parts.

10 O Is the testimony true and accurate to the g

12 best of your kncwledge and belief?

. A Yes, it is.

MR. NELSON: Mr. Chairman, we will at this time g

move the introduction of the testimony, and I am handinc -

15 the court reporter 20 copies of the testimony that was prefiled. I am asking that it be bound into.the record as if read. ,

18 l And could I go off the record for just a moment? i CUAIR!iAN WOIEI:: All right.

(Discussion off the record.)

MR. NELSON: Back on the record. J 22 O m we offer the testimony into evidence et ent-time.

24

--.) 25 CHAIRMAN WOIEZ: There having been no objecions, the testimony is incorporated into the record as if read.

(Document follows.)

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?. .

UNITED STATES OF AMERICA NUCLEAR REGULATORY COMMISSION BEFORE THE ATOMIC SAFETY AND LICENSING BOARD I

- In the Matter of )

)

PUBLIC SERVICE COMPANY OF OKLAHOMA, ) Docket Nos. STN 50-556 ASSOCIATED ELECTRIC COOPERATIVE, INC. ) STN 50-557 AND WESTERN FARMERS ELECTRIC )

COOPERATIVE, INC. )

)

(Black Fox Station, Units 1 and 2) )

L

--.s '

Testimony of Messrs William G. Gang and

• s_ Richard B. Johnson Concerning Contentions 7 and 8 (Fire Protection)

September 25, 1978 j,**.

G 4

j

. , , . . . - . . _ . . ~ _ . . . . . . , . . , . .

TESTIMONY OF WILLIAM G. GANG AND RICHARD B. JOF.NSON 1 Concerning Contentions 7 and 8 (Fire Protection)

_f My name is William G. Gang and I reside at 6428 Paso Los Ceritos, San Jose, California. I am the Project Manager for supply of nuclear steam supply compcnents for the Black Fox Station working within the Nuclear Energy Projects Division of General Electric Company. A statement of my background and qualifications is attached to my testimony on Cor.tention 3.

My name is Richard B. Johnson and my business address is General Electric Company, 175 Curtner Avenue, San Jose, California.

I am employed by the General Electric Company as a Senior Licensing Engineer in the Nuclear Energy Projects Division. A Statement of my background and qualifications is attached as Attachment I to this testimony.

This testimony concerns Intervenors' Contentions No. 7 and 81/ concerning and the compliance of the Black Fox Station cabling with the flame retardancy and separation requirements of 10 CFR Part 50, Appendix A, Criterion 3.

,l/ 7. Intervenors content that in order for the Applicant to meet 10 CFR Part 50, Appendix A, Criterion 3,

(

Black Fox, 1 and 2 must utilize cables with fire s -- retardant insulation.

8. Intervenors contend that in order to meet 10 CFR 3 Part 50, Appendix A, Criterion 3, the Applicant

) must separate the cable trays, including those in the cable spreading rooms so as to prevent a recurrence at Black Fox, 1 and 2 of the type of fire which took place in the cable spreading room at Browns Ferry.

Black Fox Station cabling in the GE scope of supply will meet the requirements of 10 CFR Part 50, Appendix A, Criterion s 3. Information supporting this position as it relates to the

, reactor manufacturer, General Electric Company, is supplied herein. GE's scope of supply, for purposes of these conten-tions, includes the Power Generation Control Complex (PGCC),

which consists of three major sets of assemblies: 1) termina-tion cabinets, 2) steel floor sections, and 3) interpanel cables. .GE also supplies the control panels in the control room and certain local panels throughout the plant. Testimony concerning the cabling within the scope of supply furnished by the architect engineer, Black & Veatch Consulting Engineers,

._ is set forth in Mr. Engmann's testimony. Black & Veatch's i

s_ ) scope of supply, for purposes of these contentions and in relation to that of GE, originates at the termination points within the termination cabinets of the PGCC design and at other termination points throughout the plant, extending to the remainder of the plant. This also includes the interface with the fire protection features (detection and suppression) pro-vided in the GE scope of supply.

Criterion 3 to Appendix A of 10 CFR Part 50 requires that structures, systems and components important to safety shall

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be designed and located to minimize, consistent with other Q

safety requirements, the probability and effects of fire and 7)

explosions. With respect to the PGCC for the Black Fox Station, Tefzel cable insulation is used on substantially all cables.2/

- m. Tefzel, a Dupont Trade name, is a high temperature, flame retardant fluoropolymer material which has passed the IEEE 383 (1974) flame test and is required by GE specification.3/ This test is appropriate for, electrical cable construction included in the PGCC.$/

Where it may be desirable to use cabling material other than Tef:el, other materials which meet IEEE 383 (1974) will be used. In addition to GE's use of flame retardant insula-tion, any cables added to th'e PGCC by the applicant /AE must be

_s Tefzel or its equivalent from the standpoint of flame retardant properties. Tests conducted by the Structural Research Laboratory of the University of California at Berkeley, and witnessed and approved by NRC representatives, showed that the PGCC floor sections provided adequate fire protection features to meet the requirements of Ceneral Design Criterion 3. In addition to the use of flams retardant insulation, the PGCC design contains other featu2.u to minimize the probability of

-2/ See NEDO-10466, Rev. 2, " Power Generation Control Complex

, Design Criteria and Safety Evaluation," page 4-11.

3/ Ibid., Section 5.1.8, page 5-2.

~

4/ Regulatory Guide 1.120, Revision 1, " Fire Protection T Guidelines for Nuclear Power Plants," dated November 1977,

- p. 120-13.

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fires and protect plant personnel. Industry codes and standards

, provide more than adequate safety margins on the selection of wire for electrical loads, precluding the possibility of ignition j from an electrical overload. Additionally, PGCC floor sections are designed to limit the flow of air and exhaust gases that may be generated from a fire by the enclosed nature of the floor sections and by sealing of all penetrations with semi-permanent fire stops. Thus, should a fire start it would i have only a limited amount of oxygen available and hence .

would be suffocated. This was demonstrated by the tests conducted at Berkeley which are referenced above. Also, the PGCC for Black Fox Station, will have fire suppression and detection systems installed. These systems of the PGCC are l

- 1

) covered in detail in NEDO 10466, Rev. 2. The use of fully- l s )

enclosed electrical raceways in underfloor spaces which characterizes the PGCC floor sections is consistent with the requirements of Regulatory Guide 1.120, Rev. 1. l With respect to the requirement for cable separation, the tests referenced above also showed that the cable separa-l tion within the PGCC floor sections satisfies IEEE 384-1974 I relating to separation of Class lE equipment. IEEE 384 i specifies that under certain circumstances, which are appli-cable to the PGCC floor sections, separarion criteria (i.e.,

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minimum separation distance and/or adequate separation barriers) l can be established by analysis and testing of the proposed cable w

U installation. As Regulatory Guide 1.75 indicates, the IEEE 384

5-cable separation test has been accepted as satisfying 10 CFR Part 50, Appendix A, Criterion 3. The referenced tests and e s. analysis established that the cable installation in the PGCC

\

._. floor section provide adequate separation. This installation will be used at Black Fox Station. The Black Fox PGCC cable design complies with the requirements of Regulatory Guide 1.75.

In its " Order Ruling on Motions for Summary Disposition,"

the Licensing Board appears to have concluded that IEEE 383 (1974) and IEEE 384 (1974) standards have been invalidated by the occurrence of the Browns Ferry fire. This is indeed not the case. IEEE 383 (1974) and IEEE 384 (1974) remain the

,_s applicable standards required by the NRC. Browns Ferry was T

,/ designed prior to the adoption of these 1974 standards, and was not necessarily designed to meet the equivalent require-ments. The entire area of fire protection for nuclear power reactors has been reviewed as a result of the Browns Ferry fire experience (see the report by Hanauer entitled NUREG-0050,

" Recommendations Related to the Browns Ferry Fire," published in February, 1976), and these 1974 standards remain the appli-cable standards for present plant design.

The guidelines of the Hanauer report have been included s

( ) in Regulatory Guide 1.120, Rev. 1, and PGCC for Black Fox Station meets this Regulatory Guide. Gage-Babcock, mentioned

+ by the Licensing Board in its Order at p. 26 as a new source

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of information, participated in the review of NEDO 10466, l Rev. 2, as NRC consultants. They concurred with the NRC

-s evaluation and conclusions as stated in the NRC approval

) letter for this report (Olan D. Parr, NRC, to Dr. G. G.

Sherwood, GE, dated July 13, 1978) (copy attached as Attach-ment II).

It has also been suggested that the use of rheeways under the false floor for the PGCC, as contemplated by GE in its design, conflicts with that portion of' item J (p. 29) of l

BTP 9.5-1 (dated May 1, 1976) which provides: l 1

" Cables should not be installed in floor l trenches or culverts in the control room."

' 'N This assertion is incorrect. Cables for the PGCC for the Black Fox Station will be installed in cable trays, raceways and conduit as distinguished from trenches or culverts. Race-ways, cable trays and conduits are not considered to be a synonomous term with trenches or culverts. Trenches or culverts are, in GE's opinion, recesses in a floor which could collect water during the course of a fire suppression activity using water. This water could cause electrical short circuits in cables in the trenches or culverts. This result should be avoided and raceways, cable trays, and conduit, proposed by

, GE to be installed under the false floor of the PGCC will not collect water. In any event, the May 1976, issue of Branch l l

l I

.._ . . ~ . . .._.-..-- _ _._-._..-,, _ __- ._.

Technical Position (BTP) 9.5-1, which is the source of inter-venors' question has been superseded by BTP 9.5-1, Revision 1, issued in Spring of 1978. This revision does not contain the n

, provision cf item (j) mentioned above.5/

.s A question has also been raised as to whether the PGCC for the Black Fox Station meets a " requirement" in Reg. Guide 1.120, Rev. 1 for an automatically initiated area fire suppres-sion system in the event underfloor cables are used in fully enclosed raceways which are not protected by an automatic suppression system. At the time Reg. Guide 1.120 was proposed, state-of-the-art technology for cable insulation used in nuclear power plants did not account for the excellent flame retardant characteristics of Tefzal insulated cabling. Accordingly, a s

requirement for an automatic suppression system as stated above was included in Reg. Guide 1.120 as initially proposed. How-ever, as a result of favorable test experience on Tefzel insulated cable, GE revised its fire protection guidelines as provided to the NRC Staff in March 1978 to state that:

"For Tefzel insulated cable-cased plants, the fire suppression system shall be manually initiated. For non-Tefzel based plants, the fire system shall be automatically initiated."

(NEDO-10466 Rev. 2, Erratta and Addenda Sheet, dated June, 1978, Section 5.1.9, P. 5-2).

v) 5/

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It should be noted that Revision 1 to BTP 9.5-1 is the same in content as Regulatory Guide 1.120, Rev. 1.

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4

8-1 1

. . In apparent recognition of the fire retardant qualities of Tefzel, the NRC Staff approved this design requirement as a

'part of its approval. In Attachment II the NRC states that:

, " Based on our review of the design basis and criteria for fire protection, interface infor-mation, and the fire tests, we conclude that the proposed design is in accordance with Regulatory Guide 1.120 and General Design Criterion 3, and is, therefore, acceptable."

For the above stated reasons, the Black Fox cabling supplied by GE meets Criterion 3 of Appendix A to 10 CFR, Part 50 and the NRC Staff concurrence to that effect is set forth in the attached letter.

v

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Attachment I RICHARD B. JOHNSON EDUCATION:

BS, Engineering, University of South Florida, 197,0 EXPERIENCE:

I am currently the licensing engineering responsible for the generic licensability of the PGCC design (including the fire protection features) and the fire protection features of the GE standard plant design. I have held the position of iro.<ect licensing engineer since 1973 and in this capacity ce the responsibility for all GE licensing activities associated with the Hartsville Nuclear Plant, the Phipps Bend i Nuclear Plant, the Zimmer Power Station and various generic  ;

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licensing issues such as PGCC, GE Standard Reactor Island Design (STRIDE), High Pressure Core Spray (HPCS) System Diesel Generator Power Supply and BWR/S Recirculaticn Flow Control.

i My general duties include the coordination and prepara-tion of technical information needed to demonstrate the design adequacy, or justification of the generic GE position for the issues under my responsibility, and the necessary licensing support to reach resolution and NRC approval. My project duties include the coordination and preparation of answers to

~),j questions regarding the normal Nuclear Steam Supply System (NSSS) and the extended scope of the Standard Reactor Island l Design (STRIDE).

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.2-Following graduation from the University of South Florida, I was employed by Florida Power Corporation where I served successisely as a Design Engineer in the Generation Engineer-ing Department and as a Quality Surveillance Engineer in the

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Generation Quality and Standards Department. In these posi-tions, I was involved with the design and construction of the Crystal River Unit No. 3 Nuclear Plant. As a Quality Surveil-lance Engineer, I was a site corporate representative for assuring adequate QA and QC operations during construction.

I joined General Electric Company in 1973.

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.,g r NUCLEAn REGULATORY COMMtsslON WASHinJC TOPJ D. C. 20555 i S,, Y- Attgchment II

.; =....

1 Central Files - Topical Reports JUL 131973 General Electric Company ATTN: Dr. G. G. Sherwood, Manager b).-

Safety and Licensing 175 Curtner Avenue -

j San Jose, California 95114 1

I Gentlemen:

1

SUBJECT:

REVIEW OF GENERAL ELECTRIC TOPICAL REPORT.NEDO-10466, i

" POWER GENERATION CONTROL COMPLEX DESIGN CRITERIA AND

] SAFETY EVALUATIOM"

' We have completed our review of Revision 2 of the subject topical report. Based on this review, we conclude that toe report is acceptable for reference in license applications as e,pecified in i

the enclosed evaluation.

The staff does not intend to repeat its revie- this topical

)] report when it appears as a reference in see-except to assure that the topical report d license applications, plants involved.

.(cable to the specific d

l

} Should regulatory criteria or regulations changc such that our

,:onclusions concerning this topical report are invalidated, you will pe notified and will be given the opportunity to revise and resubmit j four topical report for review, should you so desire, i

in accordance with established procedure, we request that General l Electric issue a revised version of the subject topical report to q

include any supplementary information provided for our review of the

report, this acceptance letter, and the enclosed staff evaluation.

, Sincerely, i

j da 0.anEParr,I%nief .

Light Water Reactors Branch No. 3 Division of Project Management I

Enclosure:

._ Topical Report Evaluation xy L ec 6 M1osure:

" Mr 'ifford Gen s 'lectric Company 472C .gomery Lane

'j Beth, Ma ryla nd 20014 i ,

j .

'/

/ -.

ENCLOSURE TOPICAL REPORT EVALUATION

/ m Report No.:

Report

Title:

NED0-10465, Revision 2 Power Generation Control Complex Design i , Report Date: Criteria and Safety Evaluation

\ March 1978

) Originating Organization:

1 Review By: General Electric Company Auxiliary Systems Branch ,

Instrumentation and Control Systems Branch

SUMMARY

OF TOPICAL __ REPORT 1i i

\ The Power Generation Control Complex (PGCC) is a prefabrication

\ for routing water reactors. and installing cabling for the control room of boiling PGCC consists of three major assemblies:

(q of steci floor sections (2) a set of termination cabinets, one for(1) a set  %

i each floor section, and (3) a set of interpanel cables. The steel 3 interpanel cabling. floor sections contain raceways to provide routing

" panels will be mounted on the floor sections.The operator panels and th considered a part of FGCC and will be reviewed on a plant-by-plantThese basis.

j installed cabling and the factory installed cables in th 3 The fire protection system for the PGCC will consist of fire detection .

and suppression termination cabinets.for the floor sections and fire detection for the

/

SUMMARY

_OF REGULATOR _Y EVA,LUATION 4 The staff's review of the original revision of the topical report was I not completed to separation of pending electricalthe development of regulatory guidance with respec systems.

Regulatory Guide 1.75, " Physical Independence of Electric System Subsequently guide. GE revised the topical report to address this regulatory One ways wire area of concern in the was the physical separation of the cabling of the floor sections.

circuits or Class IE and Non Class IE circuits, are -In some cases, inderta metal barrier within the floor section. rated by only a

'] GE to demonstrate that there was sufficient independence between t i

circuits.

1 This was done by a series of fire tests and analyses.

i 1 The NRC consultants, Gage-Babock and Associates, Inc. of Chicago .

participated in the review of the PGCC Topical Report and of the fire barrier tests (described below) .

dations of the consultants. This evaluation includes the recommen-i ( g] with our evaluation and conclusions, Gage-Babock and Associates, Inc. concur i

l m -

_ . _ _ _ _ n,, e _

. - .  ! . . . - - , , . . - . , - - - - - . - . . . ~. . - ,

./ -

General Electric has performed fire barrier tests for the floor sections

,0f PCCC at the University of California laboratories in order to demon-f strate that a fire in one cable safety division would not proporpte or

.cause unacceptable damage to a redundant cable safety division in an

.edjacent racaway. The test fire and acceptance criteria were aqrced ,

/3 '

to by GE and the staff before the tests. The tests were performed to

, demonstrate that PCCC had acceptable fire barriers between cable divisions.

/ Jescription of the fire tests enri their results are contained in the

. t Topical Report.

Conservative fi;a tests were cunducted by placing

' combustible material within one cable division raceway and removing floor plates from each end of a floor section to provide ventilation.

These tests were performed with no fire suppression throughout the

, duration of the tests. The fire test results showed that (a) non-Tefzel 3

. cable resulted in a fire which propagated partially in one raceway and produced considerable smoke; and (b) Tefzel insulated cable resulted in little or no fire propagation in the raceway and coasiderably less smoke

[ . generation throughout the test.

J At etr request, General Electric has included provisions for a gas fire suppression, system (Halon 1301) in the floor sections for all PGCC J configurations. These systems will be automatic for non-Tefzel insultated

, cable based plants. The Halon supply system external to the floor sections will be the responsibility of applicant referencing PGCC. GE has provided I acceptable interfaces for the design of the Halon system. GE has also provided quick opening covers on the floor sections for manual fire fighting purposes.

1 ..)

g-Fire detection for the floor sections will consist of two thermal and one product of combustion detector in each longitudinal raceway. These e

detectors of a fire bywill be section.

floor connected in a zoned conficuration to indicate location

~

l' Applicants referencing PGCC will be responsible for the zoned system external to the PGCC.

For fire protection evaluation purposes, the termination cabinets for the

' PGCC design are similar to cabinets in other plant designs ar.d were not tested. 'w'e required that GE provide a means for detecting fires in those termination cabinets which contain redundant safety divisions. GE provided product of combustion detectors at the top of each cabinet which contains J redundant safety cable divisions to detect a fire in any bay. Each cable division will also be separated by a metal fire barrier within the termination cabinets. The detectors will alarm locally for those plants where the cabinets are located in the control room. If the cabinets are located outside the control room, then the detectors will be connected to the main cnntrol room fire protection panel.

1

! The termination cabinets will also be readily accessible for n.anual fire L

fighting by means of hinged doors on the front of each cabinet that will be kept unlocked for quick access.

V; l

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,e. .

/ r  ! -

REGULATORY. POSITION i

j All panels, consoles, and cabinets other than the termination cabinets

' N will be. evaluated for fire protection on a plant-by-plant basis since they are not included in PGCC Topical Report.

i j Based on the overall review of the PGCC we conclude that the PGCC design provides sufficient independence between the Class IE circuits

~i .

and physical and betweenseparation.

the Class IE and None IE circuits by utilizing barriers Therefore, the PGCC design is acceptable with respect to the physical

, independence of electric systems and Regulatory Guide 1.75.

, Based on our review of the design basis and criteria for fire protection, interface information, and the fire tests, we conclude that the proposed design is in accordance with Regulatory Guide 1.120 and General Design

. Crit,erion 3 and is, therefore, acceptable.

I

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• 1 573n i layin david 5 Ili 3Y !!R. NELSON: l s q lir. Johnson, did you also have occasion to .

2[l .

3h prepare a tooical report with respect to the power l

. 4i generation control ccmple::? j 5I A (Witness Johnson) Yes. I directed and coordinatedI i i 6; the writing of that topical renort revision ene and revision i' S h 7; two and the errata sheets attached to revision twe. 1 i.

i.

8: O I am handing you a chotococy of a report j I I, 9, entitled, " Licensing Topical Report power Generation Control l.

10 j Complex Design Criteria and Safety Evaluation."

i 11 ; Up in the upper righthand corner it is noted NEDO l

10466, and then it says revision two.

12[

13 I ask you if this is the report that you 14 assisted in preparing? l I

15 ; (Handing document to witness.)

i 16[ A Yes, this is the report, and errata to the report.

I O Next I am handing you a sheet entitled, "2rrata 17 }!

gg l and Addenda Sheet, June 1973," and with the note that it has.the same NEDO number and revision number two, and ask 19 20l you if this is the erata to the recort.

I 21 i A That is correct. This is the errata to the report.

22

_J 3 Q Considering tcgether the errata and the original re rt, is this report new true and accurate to the best 24

' f y ur knowledge and belief?

25l

+~~-.w--- , , , . . . --y,~.s m --y. ,. , . , , , , , , , -

i G740 i

david 6 A Yes, it is.

2 Mr. Chairman, we would ask that the MR. NELSON:

3 report be designated -- I believe it is acplicant's exMbit m '

4 number 32, and I would suggest 32-A and the errata sheet 5

as 32-B.

6 All richt. They will be so CHAIRMAN WOLFE:

7 marked.

8 (The above-entitled documents were 9 marked Aeplicants Exhibits 32, 32-A 10 and 32-B for identification.)

11 MR. NELSON: I have handed the court reporter 12 three copies of the report which has been marked has S US Applicants Exhibit No. 32-A and-three copies of the i

14 errata sheet which has been marked as Applicants Exhibit No.

15 32-B.

16 And at this time we move those into evidence.

17 CHAIRMAN WOIJE: Any objection?

13 MR. FARRIS: We have no objection to the 19 admission, but we would like to have a copy of the errata 20 sheet. I don't believe we have been furnished with a 21 copy of that.

22 15. WOODEEAD: No objection from the staf f.

23 CHAIRMAN WOLFE: Applicants Exhibit 32-A and 32-B 24 are admitted into evidence.

25

. . _ . . - - . . ~ . , . . - _ . _ _ _ _ . - . _ _

a

!i  !

e i

I i

6741 I l

david 7 I (Applicants Exhibits 32-A and 32-3 '

i r 2l were received into evidence.)  !

4i MR. N'acOM: The witnesses are available for

) 4 cross examinacion. '

' CHAIPS.N WOL7E : Ms. Ucodhend.

5[

6 MS. WOODEEAD: Thank you, Mr. Chairman.

7: CROSS EXAMnIATION l 8 BY MS. WOODHEAD: .

9 Q Mr. Johnson and Mr. Gang, I will direct my 1

to ~ questions to either one of you to answer a.s you think best. ,

11 On page 3 of your testimony, the first paragraph, 12 you state Tefzel'will be used in substantially all cables I '

^

13 1 in the pGCC. Can you tell me what cables would not be?

)

14 A (Witness Johnson) As we described in -he tsa epical report, there is a small percentage of ncn-tefzel 1

16 , cables. That percentage is less than 10 percent throughout 17 the.antire groupin gcf flcer assemblies.

18 This cabling is used for special circuitry'that 19 r'equires coaxial cable, and at present Taf:e1 does not 20 make a coaxial type cable which would be used.

21 So we used the Flamtrol cable. F-1-a-m-t-r-o-1. l 22 Q These non-tefzel, what criteria -- would they l

Kl) 23 I

meet criteria IEEE-383? l 24 , A Yes. All cabling in the complex meets the .

1 25 I requirements of the NRC and of GE snecifications.

I l

I G742 david 8 1- Furthermore, this cable that is non-tef=el was also 2 tested at Berkeley during the fire test: that are clso 3 reported in the topical report.

rs- 4

, O Thank you.

5 You mentioned the tests at Berkeley, and I would 6 like to know if you are familiar with the tests on Tefsel at 7 UL in Chicago in September '76 sponsored by GE?

8 A Yes, I Em familiar with tne results of that test.

9 0 Could you explain the scope of those tests on 10 Tefzel?

It A Briefly, there were a series of tests performed, 12 not only on Tef:el, but other cabling, non-tefzel cabling,

) la and there were certain modifications made to the IEEE-383 14 test.

15 The standard test recuires, I believe, 70 or 16 90,000 BTU flame scurce. And it is projected at a vertical 17 cable tray that contains cabling that is to be tested. The 18 flame source is about three inches from the vertical tray, 19 ar,d that is a standard IEEE-383 test.

20 If the flame spread and the fire propagation of 21 the cable does not exceed the top of the ladder which is 22 about eight feet tall, then the cable passes the test.

':d O Modibations to that standard test were made 23 24 like varying the heat source. They increased the intensity 3' of the burner, varied the distance frem the cabling, and 25

i.

t, 6743 '

It 9 I

.vid9 the scoping out of this shored that Tefzel was in all ,

2[ t I

1. cases better than the cabling that was non-tef tel. And 3l1

~S I Tef:el passed the IEEE-333 test even with modifications.

4I Q Could you clarify just a little bit. - think o

that what you said was that it was rather a comparative oV I

test of Tefsel, compared to other 383 cables; ic that j'

l I

true?

S i A That's correct.

9' O And could you give me the results in a ,

10 }

comparative way, Tef:el's quality?

11 A Yes, there were additional tests done beyond 12 the 383 tests. There were some ASTM S4 tests, N L3 J like a Steiner tunnel type test. Tefsel performed superior 14 to the other cabling except for the face that it shorted 15 out earlier than the other cabling. e I

16 But what we were 1 coking at was the flame 17 propagation characteristics and the -- Teftel did perform 18 greatly superior to the other cablings, i l

19 I have some data with me that, if I could refer l 20 l to it, I could give you scme examples of the actual  !

21 ,

results. i 22 That would be helpful.

)

O Fine. ,

+. i 23  :

end 2 24 i

~D .

/ 25 1

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- .__ - . ~ .

6744 Whitlock3 1i A. This is a brochure on flame tests that is put out  !

harbi  !

i 2l by Dupont. It is available to the general public. It is i 1

J . t 3 titled " Flame Tects," and it is a report en tests conducted i i

l 4 by Underwritors Laboratories, Incorporated at North Brock  ;

I 5" Illinois, September 27, 28, 29, 1976.

6 MR. FARRIS: I don't believe the material that 7 the witness is referring to has been identified as an e::-

8 hibit to be offered. I would cbject to his reading frem 9 any exhibit that has not been so identified.

10 If we got a chance to lock at it, we may have no  !

11 objection. I don't think we can make that decision without 12 some time to look at that doc.anent.

t MX. NELSON: Mr. Chairman, as I recall, the q 13 14 witness said that he would refresh his recollection as a 1

15 basis for giving some examples. )

16 I don't believe his use of the document is ob-17 jectionable.

18 MR. FARRIS : But if he reads from the document jg and quotes frczn the document, it would be.  ?

20 CHAIRMAN WOLFE: Do you want time to review the 21 document, Mr. Farris?

22 MR. FARRIS: I think we would like to look at it.

$ 23 CHAIRMAN WOLFE: All right, Mr. Earris, you may 24 borrow it.

3 -

4

6745 1 (Pause. )

s 2 CHAIRMAN WOLFE: Mr. Farris has returned the doc-

.) '

3 unent to the witness.

O 4 De v m heve any c - ene, M=. rer= w 5 MR. FARRIS : I have no cbjection to the witness P

6 using that to refresh his recollection. But I do object 7 to the witness reading from the document, reading it into a evidence, it not be off ered as an exhibit, and I don't think 9 there is anyone here today who could properly identify that 10 document for that purpose, since it is prepared by UL.

11 For the purposes of refreshing recollection, I d

12 hwe no cbjection.

CHAIRMAN WOLFE Do you have any objection to

]> 13 14 the testimony to date?

15 MR. FARRIS: No. j 16 BY MS. WOODHEAD:

17 0 My cuestion asked if you could give some canpari- l 18 son between Tafzal and the other cables tested at UL tests jg in Chicago, September of '76, in a quantitative manner, in i

20 terms of fire retardant properties.

]

21 A. (Witness Johnson) In all ofthe tests, the Tefzel

- 22 performed better from a fire retardant point of view because 23 there were, like I said earlier, a series of modifications y to the IEEE 383 test, and the 70,000 btu the standard tast, the length burned was substantially less than the other calbe, 25 I

- . , , .m. ..- . . . .m.. , , , . , . - 4. ,, . . . . _ _ _ m.- _ _ _ . _ - _ , , ....,_.,m_,.,..m . . , _ . . . - _ . - ..,.3 m

st 674.6 1 which is. cross link polyethylene cable.

s 2 At the 210,00 and 410,000 btus with varying the i

)

^

3 { distance ofthe flame to the cable tray, the length of prepa-u +

gation for Tefzel tras on the order of three to rour rest,

({) 4 5 in the vicinity of the flame, whereas the other cabla prepa- l 6 gated beyond the -- that distance, and in some cases, it was 7 like four and five feet, and in othereases, exceeded the  !

I g eight foot length of the tray.

9 ,

10 11 End3 12 13

-)

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)

21 22 '

N

.) 23 -

24 25

BU- arl 6747 !

g You're sure the Tefzel cable burned slinificantly I .:

54 s 2 less than the other cables tested at this time?

i  !

3 A That's correct.

.m j 4 0 Could you explain the difference in the objective f the test in California for PGCC,i:o. 1 and tio. 2, the UL 5

6

.ests on Tefzel, and how thev might he related?

A At the UC-Berkeley test on FCCC fire sections, 7

g those tests were conducted after having discussed the g

licensability of the PGCC design with the IMC.

General Electric had developed a test after 10 9y the Browns Ferry fire to investigate what would be needed g in our power generation control complex in light of the Browns Ferry fire, and in light of the imC's requirements .

13

}.. resulting from that fire.

g We had several meetings with the imC and we 15 hired some consultants and employed a task force, and out 6

of that we developed scrae criterion by which pr-CC could be licensed.

• One of the objectives of the test at Berkeley was to ensure that fire in one division in one tray of a

/ g floor section would not propagate and would not affect 21 the cables in an' adjacent division.

All of the tests that were done at Berkeley

$m poved that point, that it would indeed not propacate beyond the fire source, and it did not affect the cabling in an ,

] 25 I

1 I

,, e

4 ar2 6748 1

l

? ,

adjacent division. l s 2y The results a:e again rencrted in a 1 30 that lI l 2 the Staff has reviewed and approved.

m 1 4 ,I! The tests of the Undervriters Laheratorf were 1

4 5[e. more of a stopping. test to find out if indeed 2222 393 not l

Gi modified, that is the standard treatment half inch spacing g 7- and 70,000 Dtu fire source were still adecuate to cualify a,. cabling for its fire retardant properties. And so they i l1 9

modified tne test to determine or scope out, and I don't 10 , believe that there were any conclusive things ns a rescit g; of those tests, but they did learn that the Tef el did 12 : pertorm much better.

l g3 0 Do you recall in the Chicago UL test that during

-s

..)

14 t a certain test sequence, the groups of Tef:el cables did I

burn quite readily? Do you remember that?

l A Yes. Tefsel will burn. The fire spread or 1G pr pagation, if you will, is what we were looking efter, 17 and a fire retardancy of the cable is measured by that. It la ,

19 ir one way to measure it, the fire retardant properties of this cable, and the fact that Teftel did not burn past the 20 fire source, or at the most about one foot.beyond the fire 21 source is evidence that it is a very good cable.

22

) 3 0 on page 7, you point out, page 7 of your 24 testimony, you point out that a prior Staff position I

reccmmended against underficor cables in the control room

.25

l ar3 6749 l and Ebat this prior position has been sunerseded by a 3

- 2 m re recent revision. ,

' l Can you explain why NECO 10465, Revision 2 3

quotes the old Branch position?

']) 4 A As I recall, the Revision 2 -- I hava a copy of 5

t ere -- s dated March of '7R. At the time of the 6

writing of that report, the Revisio2. 2, the Branch position

, 7 had not been in our possession. Uc didn't address it. He 8

addressed the current requirements at the time of the writing of the report.

, O Thank you.

s MS. WOOLI:EAD : The Staff has no further ques-tions.

MR. WOLFE: fir. Fcrris?

14 MR. FARRIS: Thank you.

BY MR. FARRIS:

16 0 tar. Johnson, you testified that you were the 17 author of Revisions 1 and 2 to ITEDO 19456; is that correct?

18 A (Witness Johnson) No, sir. I testified that 19 I directed and coordinated the writing of that report, 20 specifically those revisions.

21 0 ' Do you know who was the author er co-author of 22 Sh the revision zero of NEDO 10466?

"' 23 A Yes, sir; Mr. Gregory Minor.

24 Q Is that the man sitting to my right?

} 25

I ar4 6750 1 A I have never met Mr. :linor, but I am told that

- 2 is who that is.

3 q Thank you.

) 4 Mr. Johnson, why is fire protection especially 5 important to nuclear plants?

5 A The importance of safety in nuclear plants is --

well, it is just a very important aspect of buildinc a 7

nuclear power plant. You have to design safety systems a

9 such as they will not be affected by occurrences of things like a fire, would not be able to shut the plant down or 10[

operate it safely. Just as any other natural or unnatural ,

13 i

12 type of element, you have to design'it against hazards.

Q In other words, a -- a fire could result in 13

.'.) being unable to centrol the reactor to tell what is going 34 i

33 I on in the reactor?

A Not necessarily, no. As in the case of Browns 16 Ferry, the reactor was controlled. The situation that 37 we would not want to have is to have any adverse affects 18l 39 on any scfety-related pieces of equipment in the plant.

There are redundant divisions, and redundant pieces of 20 equipment to accommodate failures.

21 14e don't want to design a plant such that it g

h g can accommodate or that it cannot accommodate failures. So we have this redundancy, and we have protection against g

) g fires involved.

- - - , - . , ,,.,m.,- --,

l ar5 6751 i

1 O Is it your understanding at the Browns Ferry' l i

2 fire that at all times the reactor operator had all of 3

\) .

3 the necessary input he needed from the reactor to safely 4 operate that reactor?

3 A I can only offer an observation, or a personal 6 opinion on that.

7 0 Your understanding is what I asked for, sir. l l

8 A From reading the reports of the fire, I believe g he did the right thing and did have information that he l  !

l 10 really needed.

11 Q Can you identify the type of cable that was tested l 12 against Tefzel in the UL tests in Chicago?

A It was a cross link polyethvlene cable insulation.

13 Q Isn't it a fact, tr. Johnson, that is one of 14 the worst cables as far as fire retardinc capabilities?

15 A No, sir. In my opinion, that is not true. It 16 g also passes IEEE 383, which is the standard for fire 18

1. • * ""W

• g Q Let me ask it this way, then:

e ca es M passed F.E 383, is it one 20 g of the worst?

A I dcn'e believe I can cerment on whether it is one

) of the worst or whether there is one worse. In my opinion, 23 it is not the worst because it does pass.

) Q Did it pass with the smallest margin?

I ar6 6752 t

I A I am not (7ualified to an.swer that type of 3 2 question.

.) I I

3 0 You don't know what its margin was?

d A That's right.

5 MR. FARRIS: May I approach the witness, Mr.

6 Chairman?

7 CHAIR'WT WOLFE: Yes.

I 3 BY MR. FARRIS:

end'4 9 0 I will hand you a document and see if you can to identify having seen that document before.

11 A (Witness Johnson) I believe I have read this.

12 , Q Can you identify that document? -

t u A For the record?

f u j. Q Yes.

I A Fire Protection Research for Research Application 15 16 Branch, Water Reactor Safety Research, Nuculear Regulatory 17 Commission. It is a quick-lock report on some tests done 18 in Sandia Laboratories.

gg Q I ask you to turn to page 3 of that document, if 20 you would, sir.

21 A Okay.

22 Q In particular, I would ask you to look at the 23 sentence preceding the itemised portions of 1, 2, 3, 4, 5, y and 6.uave you read that particular portion before on this

/ 25 document?

. . ~ . _ . _ , _ . , . . _ _ . _ . - _ . . . - . , . . , - , . _ . -_

k ar7 5753 1 A Yes.

2 O And does that refresh your recollection about 3 the fire propagation capabilities of the XL-3E 4 insulation cable?

5 A Does it refresh my memory about the 6 capabilities of cross link polyethylene cable? No.  ;

i 7 This is the definition of the scope of hcw to set a severe 8 fire.

9 Q How to set a severe fire? And was one of the 10 items itemized there the use of XL-EE insulation cablas?

11 A That's what it said, yes.

12 l I might add that the tests performed at Berkeley i

13 were even worse than the Sandia test that you just showed me c l'

14 ; report of, as far as the fire being set in a cable tray, 15 that is not normally configured in the centrol room as

' I 16 l the floor sections, the cover plates are removed, and j i l JP-4 fuel put in milk cartons. That is not the normal J 37

g configuration of the control room. ]

19 We mutually with the NRC agreed to a worst-case 20 fire condition, and without disconfiguring the design, we could not start a fire. Once we did start a fire after the 21 22 design was disconfigured, the cabling performed extremely f

well and did not propagate beyond the fire scurce. So I 23 I 24 don't see how these other tests are related to the PGCC design.

3 L

i i i

i l

ar8  !)

5734 j i

1 1, ?tR. SHOM: Cut of curicsity , how dcas the gacmetry 1

2 of a test you performed, the disccnfigured das;, cc= para vita j

't ,

3j the gecmetry in the Sandia test; do ycu kno;F

-s 4 {i' UIT !I:SS JCIC750N: I would have et r rti w tne l i  !

4 5i -actual Sandia configuration again, but I can describe the i i i

at tect that we performed the PGCC units, and I don't bolinve 7 that they are similar, but I could describe that for you.

8 MR. SHON: Could you do that for us, please? I i

1 9:i would like to know roughly what the configuration was in e

l' i

10 ' the test that you made .

It i WIT:IESS JOHUSON: As you may know, the flcer 12 sections, as they are installed in the centrol rocm, have t3 floor coverings or metal plates on them. That makes up i

t 14 . the control room floor. l t

15 The cabling that is run through these trays, if h

16 l' you will, under the floor sections,under the floor plates, i

7 ! rather, is routed in divisions that are separated according i

18 to the plant safety divisions.

19 .

At ch t Berkeley tests, we took one of those fire sections and filled one division with the cabling that 20 '

would be applicable for a particular project. For the cases 21 22 of this hearing, for the Black Fox project, we used the 23 typical Tefzel cable, and one of the conditiens that we had l 24 to modify ivas that we had to remove on each end of the f l floor sect on unit, which is about 8' wide by 20' long,  ;

25 l

?

, , - _ . . _ . , . _ _ _ . .,,,,.,.-.,._.m.,,. ,.m.,_,m. . , . . . , , , , , , . . . . , _ _ ,...,..,.,_,m_,., , , , . , ...

. .- ,_-.,,,,_,or , . . . . . .

= _ .-.

ar9 6755 1 we had te remove the ficor sections to get _nsulation through ,

2 the ducts. i 3 Me had to put a small can of the JP-4 fu21 and 4 seme excelsior covering that underneath the cable and scme 5 milk cartens, approximately 11 or 30 milk carcono, that 6 precisely that -- the bottoms and tops are cut off, so that 7 they would form a surfaca that would burn, and P. hose were 8 chosen because they are typical of what you might find in a 9 trash can.

10 The ignicien of the JP-4 produced the firme 11 that started the wocd burning, and then the cable burning, 12 and we saw temperatures on the crder of 900 degrees C.

t g3 It was a 30-minute cast with no fire suppressicn, and all t

14 l of the tests were satisfactory.

15 In other words, the objectivas of the tests

' l 16 were met.  :

l l

5 If we had the ficer sections in place -- I mean l 37 l

18 the floor coverings in place, we could not start the fire l l

i 39 without the milk cartons intersticed between the cable in a 3 20 very precise manner, so that you had ventilation, and then .

21 we dia" not start a fire.

22 MR. SHON: .ind the matter of passing the test censisted, I trust, although the cables in actual run 23 24 and in the division that you were working with, were damaged I s

J or destroyed, other divisions were net; is that right?

25 t _ . - . . _ _ _ . - _ . _ . _ _ -- -

L ar10 5756 i ,

6 .

, I UITIE5S JOEIi3ON: Yec. Ma monitorsd the I

1 gj ?

function of tha cablas, althcugh the -fire was in about a l

i f

three-fcot long area, we had those mill cartens in, tha: I

~,

' t

,3 } is where the fire took place. It did not go beyend that.

-l It anpelled itself, and the function was lost for these cablet 1,

j !! in that tray, but nod the adjacent tray.

1

}

MR. SHON: Thank you.

J S~l MR. FARRIS:

3 (qu f

i Q Mr. Johnson, you indicated that in the 210,000 9 i Btu test, the Tef::el propagated three or four feet beyond g

the area of fire impingement; is that right?

g I A (Witness Johnson) Yes, I believe that is approxi-12 !

l

, l mately true; yes.

\ $4 9 I

~

O And later in your testimony,you indicated that t,

,m, 4

'4

these tests -- that in the Tef:e1 test, the flame propagated 15 i one foot at the most, weren't you referring to a different 16 ) i l Etu test?

j A When you say propagated beycnd the flame area, 18

4, least it will show that there are other cables besides t e

i

• 17 Ii Tefzel that have the same kind of qualities.

i IO! O How about a silicone? Is Tefzel better than

- I 1~6

! silicone?

t 20 I am not aware of any cable insulatien made out A

a I

21l of silicone.

1  !

22 You indicated before that you have a way to  !

O v ,, e determine which cables you -- will use Tef e1 for and i

~{ ,

t i

T 24l .

which not.

v J,  :

Can you repeat that for me, please?

1 i j 9 ,

It - . - - - - - - _ - . - . _ . - . - - -

l l

6766 l

1 71d7 A Yes. There are certain specialty cables 1

that require a coaxial type of cabling to minimize interference 3

for signal property and what net. So for those cables that

, 1 Tefzel cannot be fabricatad inte that fina of a 5

c0nfiguation and to maintain the same electric properties 6

that are needed for that application.

7 Q Are any of the coaxial cables used to monitor 3

any safety systems?

9 A YEs.

10 Q Can you identify some of the systems where 11 ceaxial cables would be used for safety related systems?

12 I believe the neutron monitoring system would A

I3 be one application where those would be used.

)

I4 I would have to consult with the designer to 15 find out specifically what systams beyond that uses are 16 made for, but I don't believe for purposes of whether II it is safety' related or not, both of those cables, I8 even the ones that are coaxed, passed the IEEE-383; they 19 were also tasted in our Berkeley tests and under severe 20 conditions they passed.

21 The condition that this unit would be installed 22 in the plant would be in a configured condition and not 23 a disconfigured condition as we have done with tests to 24 get a fire going.

"cnd 6 25 BL fis.

l 67G7 7WEL/wal 1

I What constitures a pass under the IEEE 383?

Q o

A My understanding is that if it does not exceed ,

3 the flame test results, the cable passes.

1 4 I O At what temperature?

3 A Well, the standard test, as I explained earlier, 6 is a 70,000 Btu flame source. I guess they went up to 400,000 7 and the cable still passad.

8 The Tefsel cable?

Q

9) A Yes. I 10 But not tha coaxial cable?

Q 11 A That was not tested at the UL tests, but at the 12 test in Berkeley. The only difference there was that there

\

13 was a little bit more smoke given off.

14 MR. SHON: I'd like one point clarified. This 15 IEEE 383 test is a vertical one?

16 WITNESS JOHUSON: Yes, sir, that's correct. It's 17 vertical. And the PGCC configuration was --

18 MR. SHON: Was a horisontal one?

10 WITNESS JOHNSCN: Right.

20 MR. SHON: Thank you.

21 BY fir. FARRIS:

22 Q The insulatica for the ceaxial cables would be the 23 Flamtrol insulation that you referred to earlier, correct?

14 A (Witness Johnson) Thau's correct.

25 Q Do you know who manufactures the Flamtrol cable?

- . --- .. - ~. .. . . _ _

'I i

6768 wal 2 1 A If it's not specified in the NEDO, I don't know 2 I'd have to refer -  ;

offhand.

3 Q Does the Raychem Corporation refresh-your recol-7 ' 4 lection?

5 A Yes, I bel.iare you're correct. That's Raychem ,

6 F3 enstro1.

7 Q Mr. Johnson or Mr. Gang, are you aware of a lawsuit 8 on behalf of the Diablo Canyon plant against Raychem Corpora-9 tion involving Flamtrol, wherein it's alleged that Raychem to falsified their test records?

11 A I'm not familiar with that.

12 A (Witness Gang) No, sir.

13 Q Have you ever heard of any such falsification by

)

14 Raychem Corporation in regards to Flamtrol?

15 MR. NELSON: Objection, Mr. Chairman. I believe 16 this line of questioning about falsification has no bearing 17 on the contentions at hand.

18 Purthermore, the reference by counsel to i

19 allegations made in another lawsuit does not constitute I 20 probative evidence, since those allegations have not been 21 submitted to trial, even if the representation were accurate.

22 MR. FARRIS: I agree, those are allegations as far

, 23 as we know at this point, but it seems to me it would be 24 important to GE and, therefore, to us, to know whether or J

's 25 not GE has any concerns about Flamtrol, and if there is a I

r _ , __ _]

i i

6769 i i

wel 3 l 1 ' lawsuit by another utility on the basis of falsification of i

2 test records, I think GE ought to knew about it and ought o 3 be concerned about it. And if we're going to use it in the s

4 Black Fo:: Station, I'm certainly concerned about it.

5 MR. HELSOU: The witnesses have already testified  ;

, 6 that they were unfamiliar with the subject that Mr. Fa,7:is i i

'T was suggesting. Beyond that, I don't see how they could  ;

8 testify. 1 l I

9 MR. FARRIS: They testified they were not familiar ,

l i

10 with the lawsuit. My next question was: Have you heard i

4 11 about the falsification of test records, whether or not it l l l

l 12 involves a lawsuit. l 13 MR. NELSON: I think it was allegation of falsifica-14 tion, not a fact. f i 15 CHAIRMAN WOLFE: You object, then, to the form of i 16 the question in addition?

17 MR. NELSON: And furthermore I object to the l f

1 1B question as irrelevant.

19 CHAIRMAN WOLFE: Ms. Woodhead?

MS. WOODHEAD: I agree that it's. irrelevant.

20g 21 CHAIRMAN WCLFE: Mr. Reporter, may we have the 1

22 , last question back, please?

u l (Whereupon, the Reporter read from the record,  !

23 24 as requested.)

I

's t I s 25 t. CHAIRMAN WOLFE: The objection is overruled,  !

i I 4 I

a

. _ ._ _ . = _ _. _ . _ . __

' 6770 wel 4 I provided the question uses the word " alleged." Have you ever.

l e, 2 heard of alleged falsification? Will you answer that question? ,

'- 3 WITNESS GANG: No, we have not heard of alleged

,On 4 - ft ton, but I might point out that General Electric 5 cc ' ape-L.ct testing for the acceptability of the 6 Flt. ,n in the power generation control complex 7 confi .on, and we independently have determined that this 8 insulat_on is acceptable.

9 BY HR. FARRIS: 1 10 Q Where did you conduct this test?

11 A (Witness Gang) Berkeley.

l 12 Q Have the results of that test been documented?

13 A Yes, sir.

.i 14 Q In what document?

15 A They're in the NEDO report.

16 A (Witness Johnson) It's Appendix F of the NEDO.

17 Q Mr. Johnson, I asked you earlier about different 18 types of cable insulation other than Tefsel which would pass 19 383. Are you aware of any cable insulation on the :narket 20 today that is better than Tefzel, as far as fire retardant 21 capabilities is concerned?

22 A I think I indicated earlier that I did not, but I 23 was aware ol' some tests being conducted on cable that will -

't 24 either be equal to or maybe better than, but we're not at that Y

s 25 point yet.

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6771 wal 5 I Q Could you identify'some of the types of cables that {

I 2 are being tested now, to your knowledge?

s l

3i A Well, General Electric Company itself is investigat-! i l

4' ing a cable that could be used in the floor sections as an 1

5 equivalent to Tafzel. There has been no name pv.t on it yet.

6 It's still in the formulation stages, testing stages. l l

I Q Mr. Gang, are you aware of any insulation materials 8 superior to Tafzel, in your opinion?

9 A (Witness Gang) No, sir.  !

(

10 Q Do you know what this material that General Electric l I

11 is currently testing consists of?

12 A (Witness Johnson) No.

q 13 A (Witness Gang) (Shaking head negatively.)

14 Q If the new material, in your opinion, or in 15 General Electric's opinion, turns out to be superior to 3 16 Tefzel -- scratch that.

17 When do you expect the testing to be complete on 18 this new material?

19 A (Witness Johnson) I have no idea. The Tefzel is 20 totally satisfactory to us, and we're not waiting for any 21 tests to be completed on any other cable.

22 Your question was, was I aware of other cabling.

s 23 And, being under oath, I am aware, and I mentioned this other 24 cabling. But I don't thi:dc it's - we're not looking for a 3/ replacement to the Tefzel. We have great confidence that it 25 i

6772 wel 6 9

will perform satisfactorily under many, many circumstances.

- 2 Q And General Electric is committed to the use of 3 Tefzel, regardless of what other products may emerge on the

~

4 market between now and the time for installation in Black Fox?

A Ue liks it, and we're using it wherever we can.

5 6

If it's practical and the application can be made, we'll use it.

7 8 Q Is GE irreversibly ccmmitted to the use of Tefzel g for the Black Fo: Station?

g A No, sir. That's stipulated as a requirement at the g moment in the topical report, but the words say "Tefrel or equivalent, s we left the door open for any cabling that 12 e uld also be proved to be equal to Tefzel.

13 Q Mr. J hnson or Mr. Gang, en page 3 of your testimony, 14 g the first full paragraph, beginnings g "Where it may be desirable to use..."

you indicate that "other materials," materials - plural.

a er ma er a s, otb.er h Flamtrol, wul 18 g be used which meet 3837 A Well, this is - the case in question here is the 20 coaxial cables that we have in the PGCC floor sections at

,,,, present.

Q When you say "other materials," - plural - you g

l g mean other - you mean Flamtrol is the only other material?

A Specifically for this project, yes, that's true.

- 25  ;

t l

!. l

_o

'l I i

i 6773 j i

wl 7 i

![ Q In the very next sentensa in your testimony you j I l

_ 2" state: >

3by "In addition to GE's use of flame retardant  !

p ,

4[  :

insulation, any cables added to the ?GCC by the l 3I Applicant /A3 must be Tefcel or its equivalent..." i 6 j' Whe'. cables do you anticipate would be added to j i

7 the PGCC, if any, by the Applicant or the architect engineer? j S LI A (Witness Gang) You may add a number of cables.  !

j I s lhaven'tlockedathiscablingdesign. I really can't address

! I 8

10 that, Mr. Farris. i i

1 11 Q There may be seme cables added over which you may i l

10 have no control?

13 A We have control in that we specify the requirement 11 that you just raad in that sentence in both the PGCC topical l i' l 15 report and the General Electric special wiring cable specifica l 15 tion, which is'a requirements documents that the architect-1 l 17 engineer and the Applicant must meet. I l 16 Q And after the PGCC and your other items in your '

i 19 scope of supply are in place in the field, whatever the 10 Applicant does with it is bis business at that point?

A Could you repeat the "i.n-the-field" portion? I 21 [

i .

22 L didn't hear your full question. I 23 Q After the GE scope of supply is installed in the 24 field, what the applicant does with it, as far as hooking up y

s 15 other cables to it, is beyond your con +c.rol, is it not?

a ,

nl l

---,m, ...,,,..m,4- ,

5774 wel 8 1

A We have an interest, but at that point we do not l 2 own the plant and it is, as you say, his business.

l 3l A (Witness Johnson) I'd like to add a clarification 4 to that, if I might .

3 Q Go ahead.

6 A If the Applicant were to install cther than Tefzel 7 or non-Tafzel in a quantity that would surpass the currently 8 approved version of the topical report, the licenselversion, 9 the difference, the distinguishing feature there, is that he'd 10 have to have an automatic halen system, 2her than a manual 11 system.

12 That's the only distinction.

13 It would also be acceptable to us, but it's 14 something that he would have to decide. And it's not needed.

15 If he has the right cabling he can . . .

16 Q All right, Mr. Johnson. In that very same sentence 17 you indicate that any cables added must be Tefzel or its 18 equivalent. Why do you say "must be?"

19 A To substantiate our manually-iniated fire suppressior ,

t 20 system.

21 0 In other words, the "must" is a requirement of the 22 NRC, in your understanding?

l

- 23 A Yes. In order to have a manual system as opposed 24 to an automatic system.

. . - 2.5 Q And it's your understanding it would be the NRC's ym e e - y e -

w w e -- +--- ,,,y e- gg- ,e +r---g g- -

ii 6775 wal 9 I responsibility to check and verify that any cables added

l

, 2  ! would be Tefzel or its equivalent?

I i s

t 3 A yes, sir, m

4 Q Who were the NRC Staff representatives at the l 5 i Berkaley tests? i 6 A We had a number of Staff vitnesses thera.

7 0 Are any of those Staff - were you present, j i

B yourself? l l

9 A Yes, sir.

10 Q Who else from General Electric was there at the 11 tests?

12 L A Many General Electric and many Staff people, and 13 may industry - well, mostly NRC and GE.

)

14 Myself, the authors of the topical report, the 13 designer of the FGCC, the branch chief of the NRC's IS Auxiliary Power Systems Branch, the Assistant Director -- I

17. believe - for . . . I could name some names, but I don't 18: know whether that's of any help.

19' Q Well, let me ask you this:

20 l Are any of the NRC representatives here today in 2L this room who were present at the Berkeley tests?

i ,

22 ' A Yes.

J 23 C Can you identify those people?

24 A Mr. Victor Benaroya cf the NRC Staff witnessed the s I

_/ 25 . test, as well as approved the basis for the test.

.l

6776 i i .

1 wel 10 ,

l Q Is there anyone else here?

l 1

l

- 2 A I don't recognize anvene else at the moment. l I 4 3 CHAIRMAN WOLFE: ?erhaps now would be a good time >

l l

' A for a ten-minute break, Mr. Farris. i 5 (Eecess.)

6 CHAIRMAN WOLFS: All right, Mr. Farris.

7 BY MR. FARRIS:

8 Q Mr. Johnson or Mr. Gang, at the bottcm of page 3 .

l 9 you indicate that the PGCC design contains other features to 10 minimuzo the probability of fires and protect plant personnel.

11 What other features are you referring to?

12 A (Witness Johnson) The very design of the system, 13 where it does not allow air flow. It's constructed in a 14 controlled environment in our factories in San Jose under 15 quality controlled conditions.

16 Once the unit is in place in the control room 17 there's virtually no way than a fire could be started in the 18 floor section.

19 As I indicated earlier, in the test at Berkeley we 20 had to disconfigure the design by removing the floor plates 21 and specifically arranging the cables in a manner that would 22 allow air flow, and fix the milk cartons in there to really 4

O 23 get a fire going.

24 In addition to that, the system as it is currently, N I

_, 25 1 today, has the fire suppressien - fire detection and I -

= , l 11 i 6777 ; I wal 11, j 1 suppressien features in the event that uhere were the -- in 4

2 '

l jl the unlikely event that there were a fire. l 3 0 You indicate that when the floor sections are in j l

' 4 place, very little air can reach the cablas and help support f  !

5 a fire, is that right? j i

6 A That's correct. l l

7 Q But the floor sections are designed to be casily i i

I 9 removable, aren't they?

9 A No. No. The ficor plates that are on top of the i

10 } floor sections -

11 Q Excuse me, the floor plates.

12 A - have a design feature to allou them to be 13 quickly removed in the event that the fire suppressant system, t

14 the fixed system in the ficor sections, if that were unable to i 1

15 i contain the fire or put out the fire, then the operator in  !

16 the control room has the manual extinguishers handy, and he I t

4 17 can remove the floor plates and put the fire cut that way. l j 1B Q Are the floor plates racovable also for maintenance i

19 and repair?

20 A Yes.

21 Q How often would floor plates have to be removed in 22 the course of the operation of a reactor? I

- 23 A If there were any plant desip modifications that 24 ,. required cable pulling, or cable placement, between a control I

s 15 !1- panel and the termir tien cabinet, then they would have to be 1

1

! I

I 6778 wal 12 1 removed to do so.

2 Q Is it conceivable that some of these cable-pulling 3 operations would occur while the reacter is in operation?

m 4 A That's highly unlikely.

5 Q Why?

6 A Generally plant modification would require that i the control room, if it were to be in the control room and 8 affected the control room proper, there would be construction

1. crews o the control room that could interfere with the proper 10 operation of the plant. And I don't think the utility would 11 want that to occur. So I'm sure that they would make other 12 arrangements to perhaps do the modifications during a plant 13 outage, or otherwise. .

14 Q But it'is conceivable, and maybe even likely, is it 15 not, Mr. Johnson, that floor sections - floor plates - will 16 ,

be removed from time to time during the operation of the 17 reactor?

18 A Yes, it is.

tg Q And if the floor plates are not in place, than t

20 air can get down into the raceways and trays where the cables 21 are?

22 A That's correct. But there's also a requirement and

(\ a procedure that once these floor plates are removed, that V 23 24 they be inspected to insure that they're in place again. And s

J 25 the very design of the fasteners would mean that - well, by

- . = -

1 i 6779 wol 13 1 the very design of the fasteners, the floor plates, if they J <

2[ were not intact, would stick up and you would trip over them 3

a liftheywerenotfastenedproperly. And that's part of a

^

4[3 quality assurance review after the particular plant modifica- i 5 tion, or after any work that's being done in the system.

6 0 Is there a fire suppression system beneath the floor l l

7 ,

plates?

S A Yes.

9 Q Io that an automatic fire suppression system?

10 A For Black Fox it's a manually-initiated, fixed  !

11 halor. system.

12 Q Still on the last sentence of your testimony, on 13 page 3, Mr. Johnson, you indicate that the PGCC design 14 contains other features to minimize the probability of fires 15 and protect plant personnel. Don't fire protection features 16 also - aren't they also intended to protect the public as 17 well? That is,,off-site personnel?

12 A Well,, as a - ultimately the public is protected, 10 if the plant personnel are protected and can safety operate 20 ' the plant.

21 Q So ultimately the reason fire protection is I

22 , considered a safety-related issue is because of the public

_ 23 health and safety, is it not?

24 A I don't believe so. If you were to carry it to

[ 25 f the e=treme, censidering that without fire protection features i,

1 6780 I wal 14 1 there may be some instance where the public could be affected, l l

2 that may be true. But that's a very far fetched case.

3 Q Do you think that consideraticn of the public health, m '

4 and safety in relation to fire protection is far fetched?

i 5 A Tt would be a far fetched case to consider that 6 the public is affected if the fire protection didn't function 7 properly.

8 Q Did you see any implications at the Browns Ferry 9 fire for the public health and safety?

10 A No, the public health and safety was not jeopardized 11 during that event. Furthermore, they didn't have the superior 12 design that this plant has. That is an earlier vintage plant.

13 This plant has a very high degree of safety in the mere fact 14 that it's got advancements that Browns Ferry, when it was 15 designed, didn't have.

16 Q Well, would you agree, Mr. Johnson, that Browns 17 Ferry at least had a potential safety implication for the 18 public?

19' A It's possible.

2d Q And isn't it that potential implication for public 21 health and safety that makes fire protection important in 22 these proceedings?

23 A Yes. Ultimately, yes.

24 Q Mr. Johnson, on page 4 of your testimony - and N

25 Mr. Gang -- I'm intanding these questions for either one of you, unless I address it specifically to one or the other -

a il

[ 6781 wal15j 3  ;

1 you indicate that: l i 1

, 2 " Industry codes and standards provide more than I l 31 adequate safety margins. ..

i n .

More than adequate as compared to what? l r i 5 A (Witnkss Gang) I would say that industry codes l

6 an d standards provide scre than adequate cafety margins to .

i, 7 ensure that an ignition from an electrical overload did not l l

B take place. I i

9 Q Well, when you say " margins," though, you mean, I-  !

l 10 assume, the difference between two ratings or two standards.

11 , What are you using as a basis of comparison?

12 A As I recall from the - I believe it's contained ,

i s 13 in the NEDO Report that you would need about five times the 14 design current in order to cause electrical ignition of some 15 insulation fn PGCC.

16 Q And it's your understanding, then, that the ,

17 ; industry codes and st=dards which Black Fox will be built ta in accordance with - correct - provide five times - a is{ factor of five safety margin?

I 20 j. A No, that's not my understanding. We use some 21[/ industry codes and standards for wire selection as a guideline.!

22 7 Our own prudent engineering practices provide additional m

V 23 margin.

I 2.; ' Q Your guidelines exceed the industry ccdes and S l s 25 q standards?

N t

il'

6782 wal 16 I A (Witness Johnson) In some cases they do. The 2 indust: f codes and standards that may be applicable here are 3 such as the National Electric Ccde requirements for cable m l 4! tray fillments. We stick to the generally accepted fill rate f

5f and fill quantity, much like you would in your home where 6 you'd preclude, or possibly design against, a possible 7 overload.

S Q You indicate that these safety margins preclude 9 the possibility of ignition from electrical overload. Do you 10 mean by your language, " precluding the pcssibility," that 11 there is no possibility of an electrical overload? In other 12 words, that it wculd be impossibla for ignition overlead to occur?

13l l 14 ; A (Witness Gang) No, that is not what's meant, Mr.

15 Farris.

16 , Perhaps it would have been better to say " effectively 17 preclude." I believe the meaning is contained in a previous 18 sentence, where it states: I l

j 19 "In addition to the use of flame retardant l

l 20 insulation, the PGCC design contains other features 21 to mdM =dre the probability of fires and protect plant 22 personnel."

s 23 i Q So that really you mean that to =inimize the 24 possibility, mitigate?

25 A Yes, sir.

li .

'i 6783 l

wel 17 5 Q And your statement that the industry codes and j I ('  !

2 standards provide more than adequate safety margins, is that l 0 lyourrespectivepersonalopiniens? ',

4 A (Witness Jchnson) Yes, sir.  !

t 3 I, A (Witness Gang) Yes, sir.  !

i i

G A (Witness Johnson) Those are not the only standards j t

I that are used, though, to meet the NRC's requirements, as I 3' indicated in the NEDO.

l 1

barb fis 9 l 1

10 .

i 11 r  :

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,_,._._.i _ . , . _ _ . . . . , , _ _ . _ . _ . . _ _ _ _ _ ~ . . - , . . _ _ . _ . _ _ . _ _ . _ _ . . _ _ . _ _ , _ . _ _ _ _ _ _ . . , , . , _ _ _ _ . _ _ _ _ . _

6784 i B318 arl i 1l 0 Invariably you meet the IEC requirements?

-- 2 A *les, as covered in tho ?GDO, 1

3 0 In the following sentenco you indicate the PGCC

,m 4

sections are limited, et cetera, by sealing off all penetra-l 5( tiens with semi-permanent fire stops.

6 Now, the floor sections are not airtight, are 7 they?

8 A Not litorally, no, but they limited the amount >

g of air.

10 0 And-the semi-permanent fire stops, could you

3 describe those for me, please?

12 A It is where you would have a requirement for a 3 13 fire stop, you would lay out a mound of sand, and over that i

14 mound of sand pour a mixture of GE silicone material to 1

15 form We boundary.  ;

i 16 That, therefore, would block the passage of air i i

17 as well as fire.

18 0 That would be for horizontal fire stop, would it 39 not?

20 A Yes. This whole configuration is a horizontal I 1

l 2 network of cable trays.

1 t i

22 i 0 There would be no vertical -- there would be no l

,. 1 j 23 vertical openings, then?

y A The only vertical opening would be frem a

) g lateral duct to a longitudinal duct, and in that case the

,.vwr.-,.n- y .-.~,w .e , , . ~ . ~ ,, ,e. . . . e.m.n, _ - - , w ,,. .w-e.--,- +.,,4--%+ . . - - - y-u----,-..-r. , - y .

5785 nr2

material would be laid out in the lower duct, and fill up 2 to the top space of the upper duct.

3 0 The same type of material? j

^' r A Yes.  !

4 5

0 Is that material fla:mnable? l l

A I don't believe so.

6 0 Are you aware of the part the sealant played in 7

the Browns Ferry fire, Mr. Johnsen?

- 8 A Yes.

g r O Do you know what type sealant was used in Brovns g

Ferry?

A I don't recall, but it is not the same material that we are using in the PGCC units.

~

A (Witness Gang) It was a polyurethane, Mr. Farris, I believe.

15 f

O Mr. Gang, isn't it true that the sealant was in fact part of the cause of that fire?

17l A well, the cause, the initiator was a candle 18 flame, but it propagated the fire, yes.

O What effect does an open flame have on the silicone sealant?

21 A May we refresh our recollection by referring to 22

~'l the NEDO Topical Rcport?

23 Q Sure.

24 s

) 25 A (Witness Jchnson) I just checked the NEDO, and it

j' 1 6786  ! ,

ar3  :

1 1

3 is a fire-retardant silicone that is used. There is no j l

u information ab hand on what tests were nerformed on i'c. -

But I am sure that they have pc,ssed scme tests to qualify it 3

- T as a fire-retardant material.

4 Q Enen e:: posed to open flame, would this sselant o

, deteriorate to some extent, either burn or melt?

o A I don't believe so.

7

• Y ** 9' Y # " ^ #" "9 #

8 an open flame would have no effect en the sealant?

g A For the fire barrier purposes, I don't believe it would.

11 O I don't understand that comment, Mr. Johnson.

Could you elaborate a litth bit more?

I l A . When you say no effect, we are talking about whether or not the barrier would be compremised, I assuma, and that is the way we answered the question, and from that I standpoint I don't think it would.

17 .

O The problem with your response, Mr. Johnson, is 18 if an open flame has an effect on it, then, and did cause 19 it to melt or burn, it would be compromised, wouldn't it?

20 MR. NELSON: Objeetion.

21 MR. FARRIS: I will withdraw that. It is a lousy 22

'-~; question.

23 MR. NELSON: Let me state the objection.

24

%. MR. FARRIS: I withdrew the question.

y 4++tr ,+ = -, - we n 't a st we e -w-t-t t w w w -w,- v- w-m +t-m-wee, -c--.mpe- g= ,v -

w w w -e w , 6-~,% ,e u n w aw,-w a e,,*pt---e ewr u -- -m -y t-e -n eve ne , r* y~

6737 1

ar4 l 1 CHAIM1AN WOLFE: Proceed, Mr. Farria.

js 2l i MR.. NELSON: 'I didn't hear the Board's ruling.

3 CHAIRMAN WOLFE: I told 'Ir. Parris to proceed.

4 BY MR. FARRIS:

5 Q How can you say that for purposes of providing a 6iI fire barrier, it would have no effect, if you don't know l-7 what the effect, if any, a flame would have -- nn open flame 8:) would have on the sealant?

l 9i MR. NELSON: Objection, Mr. Chairman. These I

10l witnesses are tendered for the purpose of testifying on gg contention 7 and 8. 7 refers to cable insulation. 8 12 refers to cable separation criteria, and they are testifying 13 only as those contentions relate to the scope of supply of i

14 General Electric Company. The entire line of questioning, 15 l at which they have already testified at considerable 16 length, has been shown not to be rele.vant to either of those two subjects.

37 F r that reason, the line of questioning is 18 39 irrelevant, and we object to it continuing any further.

20 MR. FARRIS: Mr. Chairman, we are talking about GE scope of supply and their design for fire protection, 21 and these contentions have all been lumped together, 7, 8 22 g and 9, and treat'ed as a whole.

Nevertheless, these two witnesses have limited 3

. . . _ .) 25 themselves to Contentions 7 and 8, as indicated by Mr.

. , , . _ _ . . _ . . . _ . . _ . . . _ . , _ . _ _ . _ _ _ . _ . . _ _ _ . _ . _ . _ . ~ _ . . . . _ . . _ _ . . . . _ . _ _ . _ . . _ _ _ . _ . . . .

l 6738 f cr5 1

. Nelson. The silicone sealant we are calking about is a i

2: part, in my opinion, of both fire retardant insulation 3 and separation requirements and fire barriers, m

4{ They have indicated and used the verd separation i

5 barriers in their testimony. I refer you to specifically 6 the bottcm of page 4 of the testimony, the last paragraph.

7 They indicate the separation distance and separation of 8 the barriers.

g I understand the sealant to be such a barrier.

10 (Board conferring.)

tg CHAIRMAN WOLFE: Objection overruled. Certainly 12 the question is directed to the written testimony of 33 these witnesses as pointed out by Mr. Farris appearing at 14 page 4 of your testJ. mony.

15 MR. FARRIS: Would you like the questien read back, Mr. Johnson?

16 WITNESS JOIDTSON: Yes.

37 (The reporter read the record, as requested.)

18 jg WITNESS JOHNSON: I say that because this 20 material is generally used in many applicaf: ions as fire stop material.

21 22 You can also look at the combination of the

) silicone and the sand together as being the barrier in this 3

g case, and as we all know, putting sand on' a fire will j g generally smother the. fire.

6789 ar6 1 With regard to any testing of th'is, I can't

.s 2 speak to the results or affects on the material as a result 3 of tests.ng. But since it is generally used in an applica-4 tion of fire stops, my supposition is that it wculd not 5 compromise the barrier.

6 BY MR. FARRIS:

7 0 Used as a fire stop, you mean as a way to limit 8 the amount of exygen that could reach a fire, or that it e will literally stop the propagation of a fire frem one point to to another?

gg A (Witness Johnson) Its purpose is to stop the 12 fire from propagating beyond that point.

3 13 0 By being nonflammable itself?

)

y A It is resistant to fire, yes.

15 0 Resistant to fire? Do you knew at what 16 temperature it would, if any, it would begin to deteriorate, j7 change form, or burn?

A don't recall.

18 19 0 Then, Mr. Johnsen, you can't say that if, can you, if a fire, an pen flame should begin and should burn 20 1 ng en ugh or burn for a while, -- strike that.

21 g Shon. a flame or a fire initiate in the flocr h section, and should that fire have contact with the sealant, you don't knew whether or not the sealant would be affected 3

> in preventing that fire from propagating to another cable 25

t G790 ar7 g tray, do you, Mr. Johnson?

2 A No. I thought I said that I believed it would 3

prevent it. >

Even though you don't know what effect the 4 Q .

5 flame would have on che saalant?

4 6 A That's what I said, yes. And, furthermore, the fire, as I indicated before, I don't knew where it would 7

g come from.

A (Witness Gang) If you put the sealant in place 9

and pour the RTV silicone on ene er both sides of this 10 sand, it serves as a membrane to hold the-sand in place, so g

even though at some temperature the characteristic of this particular silicone rubber were degraded, the sand would remain in place as a deterrent to the fire.

O What would hold the sand in place, Mr. Gang?

A Well, if the silicone rubber disperses entirely, then nothing could hold the sand in place.

O So the sand would seek its own level, like water?

18 A It may.  !

Q And, therefore,.could allow air to pass between . l 20  ;

the opening?

21 l L I A If you assumed a certain amount of detericration j 22 j v

l of the silicone.

23 0 All right.

24

'nd 8 25[

l i

,- . . _ . . - . . . . . . _ - . , . . . - . . . . . ~ , . _ , - _ . - . . . _ - - - _ - _ . _ . _ _ _ . . . - . _ - _ - . . . . - .

l 1

6791 O In the terination cabirec, there are vertical

'.ps 9 ,,

passages, are there not, for the cabla?

david 1 3 I missed the first couple of A (Witness Johnson)

.n '

4 words of your question.

1 5 0 In the termination cabinets.

6 A They are part of the PGCC.

7 Q Do you install any sort of sealant or firestop 8 in the vertical cabinets?

9 A Yes.

10 0 What sealant do you use?

11 A The smae material we first discussed.

11 Q How do you keep that in place with the sand?

13 A As I indica

• M earlier, on the transition 14 from a lateral duct to a longitundinal duct, you have to 15 go up vertically with the cable, and in the case of the 16 termination cabinets, they fit up against the ends of the 17 longitudinal ducts.

18 And that silicone and sand combinatien would be 19 used at that point to provide a barrier.

20 Q How about where it enters the termination 21 cabinet itself?

22 A That is what I just discussed. At the end of

' 23 the longituidnal duct, there is a rectangular opening in 24 the bottom of ther termination cabinet.

l Maybe we are misuncerstr.nding one another here.

s 25 0

o _

k b 6792 david 2 1 I am talking about vertical entries in the bottem of the 2 termination cabinet, rather the side. Are there any 3 places - 'or the top - where the cables entar into the f^

- I 4 bottom or the top? {

l 5 A To places elsewhere in the plant?

}

S Q Right. In other words,directly perpendicular. g l

7 A I ssume that the applicant or constructor would 8 have the same or equivalent firestop material at appropriate l 9 places.

10 0 Can you tell me how that would be installad 4-33 a purely vertical opening?

11 A No, I cannot. The purpose of the semi-permanent 13 stop in the PGCC floor section is such that you could i

94 actually -- well, first of all, we had a firestop in there 15 that was completely acceptable to GE but not totally acceptable to the NRC, and rather than a permanent firestop 16 where you couldn't lay any future cabling in, we developed 37 to ,,

this semi-permanent firestop which is better than the firestop we had earlier that might get misplaced and not j 39 even get put back in, perhaps if there were a mcdification 20

• • d**

21 Q By " semi-per=anent," you mean temporary?

) A Yes. Because it cannot easily but readily it

- 23 could be removed. The earlier firestop material I an g

) referring to was kacwool which is a blanket that covers s 25 i

the opening.

m y- , , - . , - ,

i 6793 devid3 1 And there was an instance, perhaps, where 2 there was thought to be a chance that during a plant 3lI modification, the plant personnel in putting the unit back r

together in its original configuration might leave cut the 4l ,

kaowool.

5l 6 And so we developed the semi-permanent barriers 7' such that it would require a specific installation 8 procedure and would be insured to be in place before the g unit was put back together.

10 0 Mr. Johnson, you indicated that the applicant 11 may itaif install cable to the termination cabine.ts,. and 12 you would rely on them to install a similar type semi-I g permanent sealant; correct?

14 A That's correct.

i 15 Q How do you assure yourself that the integrity of l

! l 16 l your design in maintained when the applicant does that, I i

37 when he installs cables to the termination cabinent?

A At the point of obtaining an operating license, 18 gg the plant is turned over to the applicant, and he has his 20 quality assurance procedures to follows, his plant perations procedures to follows, and various other precedures 21 that GE is not involved with.

22

) 23 ;

Q Isn't that sort of reliance upon the applicant g the same thing that created the fire at Browns Ferry when

) 15 i the applicant put the wrong sealant in?

I f

. = . . , . .__._ , _ _ _ , , , _ _ _ _ _ . . . . _ _ . , ,. , _ _ _ , _ _ , . _ _ _ . , , _ - . _ . . _ . . . , . . . _ _ . . _ _ . . . _ _ . . , . . _ ,

I G794 1

'*vid4  ;. .A I think we have all laarned a lot about 2i i

! experience that happened at Browns Ferry and the very  ;

3

._, nature of this PGCC design, its defense and depth principal ,

1 4

of preventing firas from occurring to begin trith, and l 5,

along with tha fire stpression systems installad, the l 6 i non-fire -- the fire retardant, fire retardant cabling, all I 7  !

o'f these features, we have great confidence that the 8

utility will not experience a fire.

)

9' O Did your confidence in the utility precede the ,

10 :

Browns Ferry fire- or is that confidence that has been 11 generated since the Browns Ferry fire?

12 A I would say it is since the Browns Ferry fire, m 13 I

We have modfied the PGCC design, as Mr. Minor nay recall, 14 since that fire, and made changes to it that enhance its 15 fire protection features.

16 MR. FARRIS: Mr. Onirman, my ne::t line of inquiry is going to take some time, and I would rather do 18 it all in one lump, since we are almost at lunchtime i 19 anyway, rather than ask two or three questions.

20 l CHAIRMAN WOLFE: We will recess until quarter of 1 l

21 1 2:00. j

.s (Whereupon, the hearing was recessed at 12:22 p.m.

23 to reconvene at 1:45 p.m. that same day.)

and 9

, )

./ 25

1

~

6795

.: tape 10 1i AFTERNOOU SESSION

-david 1 2.

j (1

45 p.m.)

3 Whereupon, 1

s 6

- RICHARD E. JOHNSON 5

and i

6 WILLIAM C. GANG l 7 were called as witnesses, and having been previously duly 8 sworn, were examined and testified as follows:

9 CHAIRMAN WOLFE: All right, Mr. Farris.

10 i MR. FARRIS: Thank you.

11 CROSS EXAMINATION 12 BY MR. FARRIS:

I

, 13 ' Q Mr. Gang, before I get into the next line, a 14 couple of other cuestions occurred to me about Tef::el; how i

15 long has Tefzel been manufactured?

16 A (Witness Gang) I don't know.

17 0 Mr. Johnson, do you know?

18 A (Witness Johnson) I don't know how long; a 10 couple of years at least. It is at least a few years, 20 but I don't know the length of time.

21 Q No more than five years?

22l A Probably not.

3 j

• ) 23 i Q Has any Tefzel been used commercially since it:

l 24 ' has been manufactured, to your knolwedge?

s

) 25 ,: A Yes, we are using it in all of our BWR-6. '

l i

-............-.._..._..m.., - . . . . - . . . , _ . ~ _ . . . . . . . . .,-.-......m._

\

t

!. 6796 1i )

' avid 2 O Is it being literally used in operation?

2 A I believe it is also an outgrowth of the space 3

industry, that they might have used some form of that.

4

! Q Are you aware of any other commercial application 5-1 use for it?

6 A No.

7I '

Mr. Johnson and Mr. Gang, does 3S3 recuire aging i Q

8 as part of its qualification?

91 A Yes.

10 0 Has Tefzel been subjected to any sort of

't testing to qualify for aging?

1 ~'

A I'm'not sure.

O can a product pass 383 tests without meeting 3 ', i the aging qualifications?

l~al could we have a mcment to refresh our memories?

A O

G Sure.

II (Pause.)

I8 A (Witnes's Gang) The statement in IEEE-383 19 says that aging data should be subnitted to establish long-tezr, 20 of the insulation.

21 I do not know persbnally if the manufacturer has submitted that 22 data.

'/

) 23 '

I Does General Electric have any aging data en Q

24 i Tefzel?

T l

~

25[ x z een e xncy.

1.

6797 1

• avid 3 MR. SHON: Excuse me. Just ocu of 2

curiosity, what. sort of aging data would be recuired? Would-3 i you have to conduct accelerated aging testa or real time 4'

, aging tests or what sort of thing; do you know? ,

5 WITNESS JomfSON : No, sir.

6 WITNESS GAMG: The IEEE 383 says data may be 7

evaluated using Arrhenus - technique for a minda.um 8!

of three data points, including 136 degrees centigrade and 9

two or more others 10 degrees centigrade :1part in 10 -

temperature should be used.

11 .

THat would be an accelerated test.

MR. SHON: I trust they mean simply using the slope of the Arrhenus i equation to determine in effect an activation energy or 14 some thing on that order?

15 WITNESS GANGe I am not familiar with the 16 technique, Mr. Shon.

I MR. SHON: Thank you.

18 BY MR. FARRIS:

19 Q Mr. Gang, do you know whether or not Taf zel has 20 been subjected to the sort of testing you have just 21 referred to?

22

- A (Witness Gang) I do not know.

-) 23 Q Are you aware of any ongoing plans for such

'4 testing?

)

> 25 I am not aware of any.

A

. . . . . - - _.- J.- ___ _ _.~.-- . _ . . . . _ _ . - -- . ~ __..__ .-. . ,.._ .. ._..- _ ._. _ __.._._~ -.-_ _ . _. .___-

l f

L 6793

\

l 1

r. nson?

. avid 4 j 2

A (Witness Johnson) No. l 3

MR. SHON: Gentlemen, the board has just

~

been conferring here, and we would very much like to know c'

~

what' kind of aging tests.Tefsel has been subjected to and 6

l what the results were, if possible. 5 i 1 WITNESS JOHUSCN: If the board would allow us, 8.

l we could make ashonecall during the next break and try 9

to find this i'.. formation out for you.

10 MR. NELSON: Mr. Chairman, I think it would be 11 a better procedure to establish that we will obtain this 12 l information and supply it at a later date rather than O make a phone call and taking the chance of catching the 14 person.

15 I"would suggest something like two weeks after I

the close of this session of hearings.

17 PRAIIDTAN WOLFE: All right. Once this information I8 is supplied -- and I don't knew how it will be supplied --

18 but certainly if you wish to pursue cross examination of 20 that, you may. ,

2I MR. FARRIS: Thank you, sir.

22- w . .a , ,92733

..s 23 Mr. Johnson and Mr. Gang, on page 4, the end of Q

24 the paragraph that continued from page 3, the middle of the s 25 page, you say, the last sentence in that paragraph, "the l

1

6799 david 5 1 use of fully enclosed electrical raceways."

2 Are these racewafs air tight or water tight?

3, A (Witness Johnson) They are essentially air 4 tight, and it is a steel constructed box type rectangle, 5 box eight or so inches deen by 12 inches wide, welded 6 ,

design, with the floor plates on top, bolted in place.

7 0 Does the floor plate provide the top surface 8 for the rectangle?

9 A For the longitudinal ducts, yes.

10 0 In other words, the raceway itself, before it is 11 attached to the ficor plate is a U-shpaed metal trough, so 12 to speak?

13 A Yes.

14 0 Do these longituidnal raceways run perpendicular 13 to the floor plates?

16 A Could you rephrase the question, please?

17 q Do these longituidnal raceways cross under the 18 floor plates at a 90 degree angle at any point?

19 A No. THey are parallel to the floor plates '

20 surface. I must ask you again to be more explicit 12.

21 your question.

22 0 The floor plates are 27 feet by eight feet, I 23 believe. -

24 A Yes.

25 0 And the longituidnal raceways then, do they t

i 6300 david 6 1 I:n parallel with the long side, the 27 foot side?

2 A Yes, that's correct.

3l Q Mr. Johnson, if a liquid were spilled on the 4 surface of the floor plates, could that liquid get into the I -j 5 raceways that run underneath the ficor plates? '

S A It is highly unlikely.

7r Q What stops the water from getting in there if g it is spilled at a place where the ficor plates are joined 9 at the seam?

10 A In addition to the floor plates being insballed in the control rcom, there is a floor covering over those, 33 12 and the only place that a liquid could get in there would g be in a crevice between the plates themselves.

14 Since they are secured with a pressure fastener to the transition or the longituidnal ducts, 15 I pers nally don't think there would be much, if any, just 16 g a few drops, maybe, could get in there.

18 0 What sort of ficor covering goes on top of the

g floor plates?

20 --

.A We are specifying as an interface with the ,

l g utilities a vinyl asbestos tile covering.

1 g Q The tile coulrin't overlap the joints or the seams between the abutting floor plates, cou7d it? I g

A It would have to be installed in such a manner 3

f

-) 25 such that the floor pictes are readily removable. ,

1 w n +-e w- -w-e-- aee ee.,- v v , e o --e- -m n e-ee w- , + . ,

6801 david 7 I Q In other words, there will be a visible seam? l 2; A Yes.

3 0 Indicating, in o ther words, a crack between i 4 each floor plate?

l 5 A Yes.

6 0 How much space is there between the floor plates?

7 A I don't know.

8 Q Uell --

i 9 A They butt up against each other.

10 0 They are not water thht, though, when installed, 11 are they?

12 A Not in the literal sense of the word, no.

L3 Q Then is it possible that a liquid spilled on 14 the surface could get into the raceways, the surface o'f the 15 floor plates?

16 A It is highly unlikely.

17 Q But it is possible, isn't it?

18 A ~- Yes.

jg Q What is the difference between a cable tray and 20 a raceway, Mr. Johnson?

21 A Well, in the definition of a raceway, a cable >

22 tray could fall in that category as well as a conduit or any J 23 other desce that would be supporting cable from one point 24 to another.

.- 25 0 Can you distinguish a cable tray, raceway or conduit frcm trenches or culverts when used for the same I

I 6802 i

david 8 1 purpose of holding cables?

2 A Well, normally trenches de not support cables.

3 If there were to be cable -- in the plant yard, for instance, 4 there may be trneches or culverts. There are none in the I

i 5 control room.

6 But if there were to be cable in a tranch or 7 a cu1 Vert. it would no);mally be supported in a conduit'or 8 a raceway of seme sort.. The PGCC design is specifically a g raceway and not a trench or a culvert.

10 0 Mr. Johnson, didn't yqaindica?.e that 7 hen ycu

i take off the floor plate you are 1 coking at the '-shaped 12 trough or trench, so to speak, when you look in the 13 raceway?

14 A I agreed with your interpretation that it is 15 U-shaped, but I didn't say we were looking at a trench.

15 0 What physically distinguishes the raceway frem g7 a trench as far as physical diaracteristics?

18 A A trench would be in a fixed, permanent floor 19 such as the ground or cement slab.

0 wod.d they both be approximately U-shaped?

20 A It is possible.

21 i

22 0 Either with scuared or rounded corners at the m.

23 bottom?

A Yes, that is entirely possible.

3 0 And both would be capable of retaining liquid?

3

4 l

6803 david 9 1 A That's possible.

2 0 And they both would be below the main surface? j i

3 A Yes.

i i

4 O And cables could be run or laid.in tach one of I i

5 them?

. 6 A It is possible, but as I said before, I don't 7 helieve it is the practice to lay cables in the trench or 3 8 :ulvert unless they are supported by a raceway.

9 MR. SECN: Excuse me. Just a moment, Mr. Farris.

10 You asked a question a moment ago that got a reply that 11 seemed to me not in'line with the original direct testimony 12 we have here before us.

13 You asked the distinction, that is, the 14 distinction that is here developing between a culvert or 15 c trench and a raceway, and you asked if both would collect 16 liquids. .

And Mr. Johnson said yes. And yet in his 17 gg testimony, he seems to make a sharp distinction between 19 culverts or trenches on the one hand and raceways on 20 the other, naving that one of the chief reasons for making 21 this distinct 1 & is that the en1 vert will collect water g during a fire, whereas the raceways that you have designed w n't do that and hence won't short out; 1s that correct?

23 WITNESS JOHNSON: That's corrst. But what I 24

.) 25 was really saying is I said it was' highly unlikely that water would get in the raceway, specifically the PGCC

1-6804 david 10 1 raceway.

2 and 10 3 4

5 6 .

7 8

9 10 11  :

la i 13 14 1

15 j 16 l

17 18 19 20 21 22

.s 24 i)

T

.J 25 t

e BW11 arl 6803 1 It is possible it could get in there. I don't i i

t 2, recall answering whether it would collect in there. j 8

IUt. FARRIS: 'Rebain" was the word that I used.  ;

3

,O.

! 4 MR. SHON: Your testimony on page 6, second line ,

i 5 from the bottom, says that the raceways will not collect i 3

6- water. .

7 WITNESS JOHNSON: I still contend that is true.

3 I have to review what was said earlier about col". acting i

9 or retaining.

10 MR. FARRIS: I asked if it would retain water, 11 and you said that it would retain water.

12 MR. SHON: I see the' distinction is simply between g3 ' retain and collect.

g4 MR. FARRIS: If that is the distinction, I 15 would agree with you.

16 MR. SHON: I think it is less of a distinction j7 than I .had understood to be there to begin with.

I 18 MR. PARRIS: We have always contended it was jg designed to hold water. Now we have F.eneral Electric ,

j g agreeing with us.

MR. SHON: He said it would hold water, it 21 t g wouidn't collect.

(Laughter.)

23 g WITNESS GANG: I think a raceway cable tray or

.) g conduit, as opposed to a trench or a culvert, which is t

l

ar2 G806 g generally recessed in a fixed or permanent ficor, I believe, 2 as Mr. iiinor alludes to in his testimony, in fact, there is a 3 distinction in the ability to drain, if you are in a trench 4 or a floor, a trench in a pernanent floor. That would assune 5 that it may be the low point in the floor, and the PG-- and 6 therefore may tend to collect water. In the PGCC we have a 7 false flocr with cable trays, raceways, and conduits, and 8 .then the drain system for the pr:CC is a provision of the architect-engineer.

9 10 BY ?tR. FARRIS:

y3 Q You are relying on the architect-engineer to create a drainage system that would drain not only the i 12 g raceways, but the area underneath the faise floor?

A M tness Gang) Yes, sir.

34 O Are the raceways installed in a level configuration, t o.

aPproximately level?

16 A Yes.

O And how long are they?

g A (Witness Johnson) How long is each raceway?

" "#"**

• E" ## # E*"* ' ** # ** "

• 20 approximately 27 feet long.

O So they could be at least 27 feet long, and being

')

' 23 level, if liquid were to seep frem the water, the false i

floor, down into a raceway, that length raceway could hold '

24

) 25 quite a bit of water that would not drain out by surface

, . _ . . . , _ . _ _ . _ _ - _ . _ , - . _ ~ _ . , - -

6807 ar3 1 tension, couldn't it, on that level surface?

2 Do you understand this term " surface tension"?

3' A (Mitness Gang) Certainly.

7 4 If I,put water on a flat table, a certain amount 0

5 of. water would stay on that table, would it not?

6 A Yes, sir, but I wouldn't identify that amount 7 of water as "quite a bit of water.'

6 0 liow much?

9 A I would have no idea how to cuantify it.

10- 0 Are the raceways perforated or do you have any 11 sort of drainage system built into them?

12 A (Witness Johnson) I don't believe so.

13 0 Going back to page 4 of your testimony, the S

.J 14 statement I earlier referred to, where you used 9.e words 15 " fully enclosed electrical raceways," you ey than is consistent with the requirements of Reg. Guide 1.120, Rev.-1. It is 16 17 your understanding that Rev. 1 is the applicable reg. quide is for the Black Fox Station? ,

. 19 A (Uitness Gang) Regulatory Guide 1.120 is a 20 regulatory guide which the NRC in their acceptance report 21 of the PGCC agrees that we meet, for our coneration control 2g complex.

23 0 so it is your understanding that Rev. 1 is 24 applicable to Diack Fox Station?-

-d T

25 A No, sir, that is not my understanding. ,

g

. - . . . _ - . ~ . - - . . , . . - - , - - . ....-.-..-..-.---.._.:....-......,---

Gr4 6808 1 O But it is your understanding that the NRC 1

2 agrees that 'pu meet that reg. guide, anywav? l l

3 A For our scope of supply in the pcwer generation m

4 ccmplex, that's right.

5 0 Do you knew what the difference betwsen 7ev. 1 6 and Rev. Zero is, as far as the requirement for electrical 4

7 raceways is?

8 A No, I do not.

9 Do you? l 10 A (Witness Johnson) I am trying to recall;what gg particular point about raceways are you asking for the ,

12 difference?

g Q Is there difference between the two revisions 34 as far as the statement that trenches or culverts shculd 15 n t be installed in the floor ~of the control ro:m?

A Between Rev. Zero and Rev. l?

16 37 0 Yes.

A I w uld have to review the reg. guide again. I 18 19 don't remember.

In the context of the reg. guides, the Staff 3

nsiders this to be a concealed floor space, rather than a 21 trench or culvert. We consider it to be the same.

0 Have you personally had centact with the Staff 3

on that point, i.e., the distinction between a trench or a 3

) culvert in the raceways?

_ . . - . _ _ . . . _ . _ . - . . _ - . _ _ . . _ _ _ . . . . _ . . . _ . . . . _ _ . . . _ . _ . . , . . _ _ . . , . ~ , _ . _ - _ . .

! _l

l ar5 6809  !

1 A Never.

2 0 You never have? l 1 1  !

3 A We never had a discussion with them on that. l f

m '

4 0 Itave you been privy to any correspondence 5 between any members of General Electric staf# and imC Staff I 6 on that point?

7 A I have been privy to almost all of the informationl 3 on the fire protection end regarding PGCC, and we have 9 never dealt with that point.

10 0 IIas the NRC d' isagreed with you on that point at t3 any time?

12 A We have never discussed that point.

s j3 N M I WOLFE: Try placing that microphone

)

g4 between you. It may be working now. Please try it and see.

15 SY MR. FARRIS:

0 Mr. Johnson, does GE have any written definition 16 of a culvert?

37 18 A (Witness Johnson) I'm not aware of one.

19 0 Would General Electric have a written definition 20 for trench?

A I am n t aware of one of those, either.

21 0 Is the definition or distinction that you make ,

22 in your testimony your own personal and Mr. Gang's personal 3

3 opinion about the distinction?

) 3 A Yes, and as verified as other representatives of

or6 6810 the General Electric Company.

s 2 0 And you don't know if the Staff shares your 3 opinion, the M7tc Staff?

4 A I have not discuss.3d this with the St.aff, so I 5 don't know.

As I said earlier, both the Staff and GE do agree 6

that this is a conce'aled ficer space.

7 8 0 You indicate that trenches er culverts are recessas in the floor which could collect water; whereas the 9

10 electrical raceway you refer co is not a recess in tho ficor, gg but a similarly configured device that is attached to the bottom of the floor. Is that correct?

12 g A It rests on the CCncrete floor of the Control

4 room, and that floor, as Bill has pointed out, has drainage, w ere at a p ns a ns away he de conhol room to 15 this drain.

16 O Do ' tau know what the purpose of a culvert is on a

,7 s

highway?

MR. NELSON: Mr. Chaiman, I object to the e ntinuation of this line of questioning. I understand 20 that the witnesses have some obligation to claritt and elaborate on their pre-filed testimony.

s

) 23 On the other hand, this has been going on now at extremely long length. I believe it is made irrelevant

] by the testimony that Staff has proffered on pace 7, R, 9-12,

- 25 l

1

6311 ar7 1

they point out that the cabic that the requirement --

2 MR. FARP,IS: Excuse me,Pir. Nelson.

s i

3 i

f tR. NELSON : I am stating an objection, t i

4 MR. FARRIS: I object to your reading testimony 5 into the record that hasn't been admitted. l IIR. HELSON: I an not reading testimony.

6 May I finish the objection, please?

7 3

Mr. tiinor has throughout this proceeding drawn i

g attention to a requirement which is now obsolete insofar 10 as the current regulatory guides and the Branch Technical 99 position don't even contain this provision which apoeared in earlier versions, and this point is clearly brought out 12 on page 12 of the Staff testimony. I am not going to read 3

that testimony, but it is there, and I don't believe the 94 Intervenors have filed anything in this case that any way g

contradicts that testimony. 3 6

Mr. Gang and fir. Johnson did not address in their 7

es&ony Ws c. h ange in de rWaw/ pohon, M I Weve 18 g

if Mr. Farris would j'ust direct himself to a fact that the Provision in the fire provisions is now obsolete, we would 20 establish that the whole line of questioning is irrelevant.

MR. FARRIS: If I can respond to that, Mr. Gang s""

and Mr. Johnson did in fact address themselves to the 23 differences between Branch Technical Position 9.3-1 in the 24

'l first full paragraph on page 6, and the bottom of that

-' 25

ar8 6012 l l

j paragraph says, "In any event, the May '76 issue of  !

2 Dranch Technical Position 9-5 or 9.5-1, et cetera, has 3 been superseded," and they make reference to the new revision,

^

4 CHAIRMAN WOLFE: All right, Mr. Farrin.

1 The objection is overruled. j 5

6

• tR. FARRIS: Could I have the question pending?

(The reporter read the record as requested.)

7 8

WIWESS GANG: The purpose of a culvert on a g highway, as I understand it, is to collect water to provide a certain amount of gradauien so it will drain.

10 g BY MR. FARRIF:

O Do you understand a culvert's purpose to be to collect water?

A (Witness Gang) Certainly.

O You state that the problem with a trench or culvert is that it collects water, and this water can cause an electrical short circuit; if the raceway that GE uses in design of the PGCC can retain water, could that retained water not also cause electrical short circuits?

19 MR. NELSON: Objection. I don't believe that Mr. Johnson testified to that effect at all.

21 MR. FARRIS: I will rephrase that. I think he 22 3 did, but to clear it up,'I will ask it again.

23 BY MR. FARRIS:

24

. O Mr. Johnson, did you testify that the electrical

-- 25

. , . ,--,- ,, . . . , - , - - . . - ~ . , . . . - - . , . . , , , , - - . . , - , -.n--,,,.. --

ar9 6013 I raceways could retain water?

2 A (Witness Johnson) I said it was possible, highly f f

3 unlikely that water could get into the raceway. A few '

-. k 4 drops, perhaps. l

. 5 5 0 And if it did, it could retain that water, cculd 6 it not?

7 A I did not say that it could retain water. If I 8 did, it is erroneous. I did not mean to say that.

9 0 If it gets in there before it gets out, is it to possible it could cause electrical short circuits?

11 A I doubt it. There are no terminal points within 12 the longitud'inal or lateral raceways.to.cause.something t3 to get shorted out. You would have to have two wires touching' 14 each other.

15 Q If some insulation were cut in the prccess of 16 installation or by welding or by some other construction 17 accident, isn't it possible there could be some exposed wire, 18 that if it got wet could cause a short circuit?

19 A If the insulation was removed and if the wire was 20 bare and it, in turn, was in contact with another wire, 21 while its insulation was removed and bare, and' bicth were I 22 energized, they indeed could be shorted together.

]' MR. SHOU: I am going t'o have to clear up one 23 thing. You made a flat statement that -- it would cccur

! 24 l 25 if only tw bare wires touch each other. I understood that l

l

- , , . , _ . . ~ . . . . . , . . . . . , . . - . . . . _ . . - , _ , - - - . . - ~ ,

ar10 691d 1 what we were discussing was shorts through electrolytes 2 like water.

3 WITNESS JOlHISON: If i't could also be in contact --

4 if it was energized, yes, sir, in contact with the metal.

5 @. . SHON: It wouldn't require direct netallic 6 contact for very delicate current such as those that confirm 7 neutron sensor or chambers to in effect short circuit through 8 water, if everything was in water, would it?

9 WITNESS JOIDISON: Mo. I guess water would provide 10 the path.

11 HR. SHON: That's what I mean. Water is an 12 electrolyte and there would be no need for contact.

, 13 WITNESS JolH7SOU: Yes, sir.

412 g4 BY MR. FARRIS:

15 0 Mr. Gang, it has been indicated in your testimony 16 that there is a Revision 1 to Branch Technical Position 9.5-1.

37 I am referring to your testimony on page 6 to pane 7, and you state that, in any event, this new Branch Technical 18 gg Position - in other words, Revision 1 -- has been superseded 20 and does not contain the provision that trenches and culverts --

21 A (Witness Johnson) That's right.

22 0 Is it your testimony that the concern that was expressed in the old revisions about trenches or culverts 3

g collecting water, that that concern was not valid?

I A (Witness Gang) Is that all of your question,

ar11 6815 l 1 Mr. Farris?

2 0 Yes.

3 A. It is my contention that that particular j

4 regulatory requirement has been superseded, does not now l l

5 appear in the current version of that Branch Technical l S Position.

7 0 But whether or not it is required, is' it your-I 8 testimony that that is not a legitimate concern? i l

9 A (Witness Johnson) Not legitimate with regard 10 to this-testimony regarding PGCC, no.

11 0 What I am asking is, as an engineer, do you agree 12 with the proposition that cable should not be installed t3 before trenches or culverts in the control room, insofar as ,

14 fire protection is concerned? i I 1

1 15 A Yes.

I 16 0 'ir. Gang, I note on the first full paragraph at 17 page 7, the first sentence, you put the word "raquirement,"

18 referring to Reg. Guide 1.120, referring to an automatica11'y I

. 19 initiated fire suppression system.

20 However, on page '5, the paragraph that overlaps 21 that last line of that paragraph, you refer to Reg. Guide 22 1.75, and you say " requirements of Reg. Guide 1.75," and 23 that word "requ'irements" is not in quotes. And on page 4, l

,4 the last line of the first paragraph, you refer to 25 requirements of Regulatory Guide 1.120, Rev. 1, the same

ar12 6815 1 document you referred to on page 7, which I first referred 2 to you, and you don't have the word reauiremente in quota- l 3 tion marks in those first two references. t3hy not?

^

4 A (Witness Gang) In using the word requirement 5 in quotations, I was attempting to show that it is acceptable 6 to add an alternate to a position in a reg, guide, and therefc ce 7 make the position acceptable.

8 I did not put the word requirements ir. the other g two areas because I believed that we were consistent in 10 an overall manner.

99 Q We understand that the reg. guides are not 12 law, but why is it that General Electric doesn't put the g word requirements in quotos, when it is consister,t, when it is not -- when it is consistent with the reg. guide, but 14 w en s not consisunt wM de reg. We, it puts de 15 w rd requirement in quotes? As though it is not real.

16 MR. NEI.SCN: Objection, !!r. Chairman. I believe g that is argument 'With the witness at this point.

gg CHAIRt!AN WOLFE: How much further are you going with that?

20 liR. FARRIS: That's the end of it. I would like to get an answer.

s CHAIRMAN WOLFE: We will hear the answer.

23 Overruled.

24

') WITRESS GANG: Can I hear the question again, a 25

i ar13 6817~

1[ please?

2! (The reporter read the record as reque sted.)

3 WIT!TESS GAITG: I disagree thac General Elect-ic

^

. does the practice that you describe. I did it ir. this 5 ll particular instance because I was referring to a specific 6 requirement in quotes that we meet with an al'cernste, whereas 7 in the other two instances, I intended to show that we meet--

g were consistent with the regulatory guide en an everall 9 position.

10 BY MR. FARRIS:

11 O Y u indicate an alternate. Is that an alternate 12 requirement in Reg. Guide 1.120, Revision 17 g A (Witness Johnson) It has been alternately accepted by the tritC as the result of a review on our UEDO.

14 15 0 s dere any language in Reg. Guide 1.120, Rev. 1 ' ,

y u can p int me to that indicates there is any precedure 16 for the NRC accepting an alternate?

97 A I w uld have to lock at this reg. guide. In 18 general the regulatory guide dces this, that it is a guideline 39 20 and they may accept alternates. This one may say that also.

Yes, it is also in that regulatory guide. The statement is 21 n the very cover sheet en the reg. guide. -

22 A (Witness Gang) I will read it if you wish.

3 b a ad, 24 s

y g A " Methods and solutions different from those set

[

orl4 6818 g out in e.e guides will be acceptable if they provide a 2 basis for the findings referenced to the issuance or 3

continuance of a permanent -- licenso,pemit or *.icense 4 by the Commission."

5 0 Did you work with the NRC in obtaining approval I

6 f r this alternate?

A Absolutely.

7 g Q You personally were involved in that?

9 A (Witness Johnson) Yes, sir.

Q And who did you deal with -- whcm did you deal 10 with, with the Staff, as far as obtaining this approval?

g MR. NELSON: Objection, Mr. Chairman. I believe the questioning is going so far afield that it could not be g

of any assistance in determining and resolving the three 15

• 1. ' "* I ** "# * * " * "" "*

16 MR. FARRIS: Mr. Chairman, I think I cm entitled to verify through the Staff witnesses, if available, that these are indeed the men who verked on it, and the reason they gave, and the same reasons they gave the Staff.

CHAIRMAN WOLFE: I see no good objection to tl- 'stion. Objection overruled.

i WITNESS JOmiSON: There were several members 23 of t.. .a liary power systems branch that we held several

, meetings with, and had much correspondence with.

25

1 ar15 5019 4

)

1 The primary person uculd be !!r. 9enarcya of i

I i

2; ) the NRC Staff.

}

l 6 3 3Y ?!R. FARRIS: i 1

4 Q He is here today? l 5 11, A (Wir. ness Johnson) That's correct.

end 1%

7 8

9 10 11 12 13 14 15 i 16 17 18 19 20 21 22

..r#

24 }

3  ;

25 a

6

6820 l

tape 13 1 O In youropinion, Mr. Johnson, would an david 12 automatically initiated area fire suppression sys:em be 3 superior to a manually initiated system?

4 A (Witness Johnson) Quite the contrary. General 5 Electric believes that an automatic system leads :o the 6 possibility of inadvertant actuation through a single 7 component failure that is not necessarily in the best 8 interest of maintaining a habitable control room, g Q In other words, you believe the possibility of 10 mechanical error is greater than human error?

gg A Yes.

12 0 Does General Electric -- has General Electric g ever had to install an automatically initiated area fire g4 protecton system?

15 A We are n t in the fire suppression business. What we supply are products, and if there are to be fire 16 l g suppression features with those products, we only provide the piping or the detectors or the wire for the detectors to 18 a terminal point, not the system. The remainder of the 19 system, the initiation actions are designed by others.

20 g Q So then you would have more confidence in Public Service Company's operators and personnel present than you would in your supplier's products?

3 A I didn't say that, and we don't buy these things 24 D from other suppliers. We fabricate them at our facilities.

25

5821 david 2 1 0 The automatic fire suppression system?

y 2 A No, sir. I think you missed my point. I said f I

3 that we provide the piping, the fired hard piping or rho

) 4 detectors or the wiring. But as ir as a system,'ve do not 5 provide that.

6 What we provide matches up to the balance of 7 plant or AE interface system, and they then must ::cmply a with the regulations or the recuirements of the licensing g requirements of the plant. I 10 0 Would you make the decision from whom to buy

3 such an automatically initiated fire suppression system.

12 A Did we or could we?

g 0 Have you ever?

34 A No.

15 0 Did you rely on the applicant to require such a system?

16 A No. We merely covered this in our topical report 37

g in order to make available to all of our customers a document that they could reference in a licensing 19 pr ceeding that had already been approved by the NRC.

20 and 13 21 wal fis.g 1

.s g3 24 s

/

, - - - , - - a

-r , --,,-,,,,,-mw---, r - ~ ,m.: ,, ,e-, m,., .ne--n..- . . - ~ . . <,-,--,w-,- , . - - , , - . - - a,-r-- -n- .-,-,,,.s..,. ~ .. nas,-o.- . - -

d 14WEL 6822 wel 1 I Q cne of the concerns that you e m essed with the i i

t 2 automatic system is that it could inadvertently be initiated l

3 and create habitability problems for the control room, is l

) 4 J

that right?  !

5* A Yes,. sir.

l 6' Q What sort of problems could be initiated with 7 inadvertent operation of the fire suppression syste=? I i

B A Well, the fire suppressant medium is a halon gas.

9. c At sane concentrations this gas would tend to make the 1

to operator dizzy.

11 Q Would this same type gas be initiated if the 12- system were initiated manually - I mean would it be the same 13 type agent used to suppress the fire?

14 A That's correct.

15 Q Is halon gas toxic, or can it be toxic?

16 A Every extinguisher medium I know of has a toxicity 17 - level. I don't remember what level toxicity this particular

18. gas is, but it's quite a large concentration.

1E Q Is there some sort of a system warning device that 2.0 would measure the halen concentations in order to alert 21 control room personnel to evacuate the premises?

22 A I don't know what the archi+a ct-engineer is N .

4

's 23'1 designing ih the control room. I doubt that he's got those 24 '

kinds of detectors. When you consider that the suppressant 25 is there in the. floor spaces to deuse a fire, it's going to I

wel 2 6823 1 stay down there in the floor sections, unless someone opens

. 2 up one of the panels. The likelihood of this happening is  ;

~

3 very low, but we don't beliese really that it's in the best 4 interest to have automatic systems. If you provida the  ;

l 5 detection and alarm and a manuni actuation, that's adequate,

~

G especially in this manned area.

7' O And you think the likalihood of opening up a floor C plate and looking at the fire - you think that's unlikely?

9 A Well, after a fire I'm sure that would happen.

10 Q How does one tell when the fire is over, then, 11 without opening up the floor plates and taking a look, if 12 your detection systems have gone off?

l 13 A That's the normal practice. You'd have to do that. ,

14 MR. FARRIS: No further questions of these 15 witnesses.  !

I 1G CHAIRMAN WOLFE: Mr. Nelson, redirect?

17 REDIRECT E%AMINATICN 18 BY MR. NZLSON:

19 Q Mr. Gang or Mr. Johnson, in the area above the 20 PGCC floor sections how much water is there, ordinarily, if 21' any?

22 A (Witness Gang) None.

v 23 A (Witness Johnson) I would say there's none, normally, 24 unless there's.a sprinkler system that could sprinkle water 25 on the control room.

I

(

,#-- , - . . - - , - , ,, , , . ~ ., , - ,, ,. ,, .#, . - - _ , - - - , - . , , - - - , - . . . , , - . . . . , - ..--.r e. -,r..-.+. . , - . , . ~

wel 3 6824 I Q How much, if any, of any other liquid which could

' 2 provide an electrolyte would there be?

3 A (Witness Gang) None, normally. Someone making a l d test may have a cup of coffee, or some such thing.

3 Q Mr. Johnson, what is the len'gth of fire propagation  :

. i

• that is tested in IEEE 3837 7 A (Witness Johnson) The length of propagation. Well.

8 as I stated earlier, the vertical tray is eight feet long.

9 MR. NELSON: Thank you. No further quections.

10 MR. FARRIS: I have just a coupla on recross.

I1 RECROSS-EXAMINATION f I

E BY MR. FARRIS: l 13 Q Is there a sprinkler system in the control room?

14 A (Witness Johnson) I don't know.

15 A (Witness Gang) I'm not sure in that par-4"ular 16 instance what the architect-engineer is going to provide. I 17 don't believe there's any water in the control roon.

la Q Does the PSAR call for standpipes to be available 19 to the control recm? '

20 A As I recall, yes.

l 21' Q With connections to water?

22 A Yes, outside the control room.

')

23 , Q Do you know how the vinyl flooring is going to i

1 24' be cleaned, Mr. Johnson?

25- A (Witness Johnson) No, sir, I do not.

I i

. _ . . , _ , . - - , _ . . - . . . - , . . , , . . , . . .,c._.,.,m-_ ., . .._-.,_

I 6825 wal 4 1 Does General Electric have any control over what Q

, 2 plant personnel might bring into the centrol rocm after you've 3 installed the PGCC7

] 4 A No, we do not.

5 MR. FARRIS: Thank you. No further questions.

6~ CHAIRMAN WOLFE Do you have anything, Ms. Woodhead?

7 MS. WOODHEAD Nothing from the Staff.

8 CHAIRMAN WOLFE: Any re-redirect?

9 MR. NELSON: No questions.

10 CHAIRMAN WCLFE: Dr. Purdem?

11 BOARD EXAMINATION 12 BY DR. PURDOM:

3 13 Q I'd like to go back to the question of the sand.

J l 14- Did I understand you to say that this is poured in place?

15 How is it put in place?

16 A (Witness Johnson) Well, you could take a bucket 17 of'sandandpouritintoamoundsuchthat5twou1Ienable 18 you to then take the silicone and drop it over there and 19 fill it up until it covers the opening.

20 Q so that in actuality, the angle of repose of the 21- sand is what it would naturally obtain, so that if you burned 22 off any covering or removed it some way, presu mbly it would 23 stay in that same position; is that correct?

24 A Yes, sir.

• 25 DR. PURDOM: I just wanted to clear tha:. up.

_ . _ . _ _ . . . . _ _ . ~ _ . _ _ _ _ _ _ _ . _ _ _ _ . _ _ _ . _ _ _ . . _ . _ . _ _ _ _ -

i 6826 l wal 5 ,

I BY MR. SHON:

l 2 Q I have a couple of things. This material, Tefzel, ,

3 is a rather new material. I'd like to go back and have a

] 4 word or two about the Browns Ferry plant. It did not use l

5 Tefzel, I suppose?  ;

i 6 A (Witness Johnson) No.

7 0 What was the nature of the insulation there? Was <

8 it polyethylene or one of the organic polymers of that sort?

I 9 A I think it was polyvinyl chloride. We could check  !

I I

10 the reports. But it was not Tefsel.

11'. Q I see.

li One of the things I would like to mention, you seem 13 to me to have'perhaps misconstrued what the Board was driving 14 at in something we said in our ruling en i.he motions for l ,

I is summary disposition.

16 Yotr said 'that the Board appeares to hava concluded I 17 that IZZE 383 and 384 (1974) - this is on page 5 of your i

18 testimony - that these s+=nA=Ms have been invalidated by 19 the occurrence of the Browns Ferry fire.

20 That isn't exactly what we were driving at. We 21 were simply worried that the dates on the standards suggested 22 that they might not have taken account of the Br::nms Ferry

3> 23 fire. j 2.5 Am I correct in assmimg that the rest of your 3

) 25 testimony implies that these stanan ds have been reviewed j j i

i 6827 l wel 6 since then in the light of the Browns Ferry fire, and that nc 2 Is that correct?

revision has been found necessary in them?

3 Yes.

A Yes, that's basically correct.

4 Q I see. ,

A They still remain the valid standards. l i

I 6 I would like you to discuss a little bi:, the Q

7 implications of using a fluoropolymer in a fire si:uation, j 8 l as contrasted to using one of the other organic polymers,  ;

9 polyvinyl or polyethelyne materials. t I

10 Just offhand it seens to me that the presence of Il fluorine could result in the generation of corrosive gases of 12 various kinds, which could affect, say, another division of

' 13 safety cabling or could affect connectors in cabinats that I4 they might leak into.

II To what extent has consideration been given to ,

t 16 that in the change to fluoropolymer?

17 A The tests that were conducted at the Underwriters 18 Laboratories measured the amount of material lost during the 19 fire to get some kind of a grip on the corrosive nature of 20 this cable, and it came through with the same kind of results 21 as the other results - favorable for Tafzel - in that much 22 less of the material did corrode.

) 23 Q Much less of the material did corrode?

M A Than the other type of cable.

3 25 0 Oh, you mean much less of the material did

i ,

l 6828 l 1

wel 7 1

disappear or vaporize in the fire?

Is that what you meant?

2 A It's my understanding that it was less corrosive.

3 Q It was less corrosive to materials placed in smoke 4 from this fire, is that right? }

1 i 5 A That's my understanding of what I read. l 3 Q As I. understand your reasoning cencerning the

-7 fraction of the cables that are materials other than Tefzel, 8 you are saying that since the bulk of the material is Tefsel, 9 i it will not mean a propagation of fire and, therefpre, other g to safety divisiens will not be affected? Is that ascentially 11! the reason that thera will not be any propagation of fire?

1N A Yes, sir.

S 14 Q You mentioned briefly that Tefsel tends to short j ,

14 out cables insulated with it. Would it tend to chcrt out l 15 rather earlier in the fire than other cables?

16 A Thats what the tests have shown.

17 Q What does this suggest as far as its uso in safety 18 circuits is concerned? Do you have any misgivings about it 19 because of that?

20 A No, we don't have any misgivings.' It's a very, 21 very desirable product for fire protection, and if you have 22' that along with your fire suppression systems, there should be s 23 no problem.

24 If one of those were to short out in a fire, you 3 '

25 can always shut the plant down - from a safety consideration, t

. - - - , , - . , ~ _ , . . _ . , ~ . .__.

6829 wel 8 1 you can always shut the plant down into another division.

2 g Yes, I see what you mean.

3 MR. SHON: I think that's all I have.

4 CHAIRMAN WOLFE: Any questions derived from Board l 5 questioning?

6 MR. NELSON: No, Mr. Chairman.

7 FURTHER CROSS-EXAMINATION 8 BY MR. FARRIS:

9 Q Mr. Johnson, you indicated that Tafzel chorts out to earlier than some other materials, is that correct?

11' A (Witness Johnson) That's what the tests have 12 indicated.

13, Q Wouldn't that, in case of a fire, or in case of

)

14 water in the trenches, have the ability or tendancy to short li out earlier and create the same problem by another means that 16 we had at Browns Ferry? That is, the lack of input from the 17 reactor to the operator?

i 18: A Well, as I clarified the last point I made to the i

19 Board member, if you postulate a fire, forgetting about all l 1

20 your fire protection systems, your detection, your suppression, 21 the fact that you can't actually get ventilatiento' keep a fire 22' going, and if you were to have a fire and destroy that whole 1

- l v- 23, division, the one division that that tray contains, you can 24 still shut the plant down with other divisions.

y

/ 25 That's only one lost division, and that's a design

- . - ~ . , . . , - , . . , m,,. ,,. - , ,,, -

4 6830 ,

i wel 9 1 basis.for the plant. You design the plant to accen:modate the E failure of that division.

3 MR. FARRIS: Thank you. No further que.3tions.

4 CHAIRMAN WOLFE: Ms. Woodhead? 1 t

5 '

MS. WOODHEAD: No questions, Mr. Chair:nn.

6 CHAIRMAN WOLFE: All right.

7 The Witnesses are excused. i 8 (Witnesses arm: sed.) l 9 We will have a recess until 3:00 o'cicc~c.

10 (Recess.) .

barb fis 11' 12 x 17 J l 14 ,, a..

15 j l

16 17 18 I

19 i

20 l l

21 i i

1 l s 23  ;

24  !

3-' 25 l l

l

_. . _ . . . , . ,_ ._ - .~.._. . _ . . _ _ _ _ . . . . _ . . . . __ _ _ . ~ . _ - . _ . . . . _ . _

6831 1 CHAIRMAN WOLFE: All right.

upe 14 2 MR. NELSON: I yield to Mr. Gallo.

dsvid 1 3 MR. GALLO: I would lika to call Dr. Cox and m

4 Mr. Bary Engmann to the stand. ,

5 Dr. Cox has been sworn. :4r.. Engmann has nct.

6 Wherenpan, 7 GARY R. ENGMANN e was called as a witness, and having been duly sworn, was 9 exained and testified as follows:

10 and gg E. L. COX 12 was called as a witness, and having been previously duly 33 sworn, was ava=4ned and testified as follows:

)

14 DIRECT EXAMINATION 15 W E. GALLO:

16 Q Dr. Cox, would you state your full name and 37 address for the record?

18 A (Witness Cox) Edwin L. Cox. My address is 19 8209 Linden Drive, Prarie Village, Kansas.

20 Q Dr. Cox -- strike that.

21 Mr. Engmann, would you state your full name and 22 address for the record, please?

qL A (Witness Engzann) My name is Gary Roy Engmann, 23 y 10195 Mackie, Overland Park, Kansas.

) 25 Q Mr. Engmann, did you prepare testimony with

i I

6832 l l l

dasrid2 I respect to contentions seven and eight in this proceeding?

., r A Yes, I did. ',

4 O Did you also prepare a statament of tachnical. '

m l 4 qualifications? 1

' l 5 A Yes, I did. -

}

6 'Q I show you a document entitled, " Testim.cny of  !

l 7 Gary R. Engmann Concerning Contentions Seven and 2ight 3 (Fire Protection) ," and ask if that is the testinbny you

- 9 prepared for this proceeding?

10 A Yes, it is.

11 Q Is.the statement of technical qualifications 12 attached?

)

13 A .Yes, it is.

l.

14 Q Are there any additions or corrections to your 15 testimony, Mr. Engmann?

16 A Yes, there are.

17 .Q Would you make them, please?

18 A- On the cover sheet; the United States of .Lw.rica 19 is misspelled. It should be.D instead of S in United. On 20 the first page I changed my address. The residence'is 21 now 10815 Mackie, Overland Park.

22 on page 3, the fourth line, the sentence that

23 begins, "The' FBF. cable spreading areas" should be corrected 24 to say the 'BFS cable spreading areas."

3 Page 5, the 6 th line down from the top, the

-# 25 1

I

l 4

6G33 dsvid3 I line reads, "Any vertical cable tray and subject to a 2 burning flame." It should read: "In a vertical cable 3 tray, it is subjected to a burner flame."

s 4 The ninth line frem the bottom, the line reads:

5 " Flame impingement, and the test was terminated 40 6 minutes after." It should read: " Flame impingement, 7 and the test was terminated 36 minutes after."

8 Page 6, the eleventh line from the top, the 9 line reads: " cable tray to adjacent cable trays." It to shculd read: " Cable tray on adjacent cable trays."

11 Page 8, the ninth line from the top, the 12 line reads: " Redundant divisionssperrated by five 7 13 feet vertically." It should read: " Redundant divisions 14 separated by five feet vertically co sd not" --

15 And on the same page, fifth line from the 16 bottom, the line reads: " Evidence that the horizontal 17 sperration distance criteria of IEEE." It should read:

18 ' Evidence that the horizontal separation distanco criteria 19 of IEEE.*

20 Q If sperration isn't the word, it should be.

21 A In the attachment one to my qualifications, the l l

22 first line, my title has changed. It is now project 3 That is also true of the 23 engineer, electrical systems.

24 sixth line from the bottcci.

m 25 And that's all. l l

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6834 da971d4 1 Q Mr. Engmann, as corrected, is your testimony 2 and statement of technical qualifications true and correct to the best of your knowledge and belief?

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( 4 A It is. l' i

5 Q Dr. Cox, did you prepare testimony in this  !

6 proceeding with respect to contention nine?

7 A (Witness Cox) Yes, I did.

8 Q Did you also prepare a statement of t:chnical l g ' qualifications with respect to that contention?

to A Yes.

11 Q I show you a document entitled " Testimony of t p, Dr. E. L. Cox Concerning Contention Nine" with an

' 13 attachment one which has technical qualifications set g4 forth therein, and ask you if this was the testimony that f5 you prepared for this proceeding.

16 (Handing document to witness.)

37 A Yes, it is.

gg Q Are there any additions or corrections to tais 39 document?

20 A No.

21 Q Is it accurate and completo to the best of your 22 knotedge and beliaf?

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.._.' 23 A Yes, it is.

Q That includes your statement of technical 3

) g qualifications; is that correct?

A YEs.

i I

6835 l l

i david 6 1 MR. GALLO: At this time I would like to 2 move into evidence the tantimonics of Gary R. Eng nann i 1

i' 3 with respect to contentions seven and eicht and D.:. 3. L. j

.m j 4 Cox with respect to contention nine, into evidenc3 as a .

5 Part of the applicantis direct case.

6 And I have 20 copies of each for the raporter to 7 bind into the transcript as if read.

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8 CHAIRMAN WOLFE: Absent objection, the two j  ;

9 testi:nonies will be incorporated into the record .ns if to read.

11 (Document follows) l 12

)

14 15 16 17 18 19 20 21 22 ,

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=

i UNITES 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) )

N,

/

Testimony of Gary R. Engmann Concerning Contentions 7 and 8 ,

I (Fire Protection) l September 25, 1978 l

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,sg UNITES STATES OF AMERICA j NUCLEAR REGULATORY COMMISSION J BEFORE THE ATOMIC SAFETY AND LICENSING BOARD I i In the Matter of )

)

PUBLIC SERVICE COMPANY OF OKLAHOMA, ) Docket Nos.

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

)

COOPERATIVE, INC. )

)

(Black Fox Station, Units 1 and 2) )

v Testimony of Gary R. Engmann Concerning Contentions 7 and 8 (Fire Protection) l l

1 i

1 September 25, 1978 l

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TESTIMONY OF GARY R. ENGMANN j CONCERNING CONTENTIONS 7 and 8 (FIRE PROTECTION)*

My name is Gary R. Engmann. I reside at 11409 W. 90 Tercace, Lenexa, Kansas. I am Project Engineer-Electrical ,

Systems for the Black Fox Station design project at Black &

veatch, Consulting Engineers in Kansas City, Missouri, engineering >

firm retained by Public Service Company of Oklahoma. A statement of my background and qualification is attached as Attachment I to my testimony. My responsibilities as Project Engineer-Electrical Systems included preparation of Chapter 8 of the PSAR and preparation of the responses to the NRC Questions concerning

,) the information presented in Chapter 8. My responsibilities also

%,,/ included providing technical advice pertaining to the description and analysis of electrical systems, equipment, and components included in the preparation of the PSAR and PSAR Reference Reports.

Contentions 7 and 8 read:

7. Intervenors contend that in order for the Applicant to meet 10 CFR Part 50, Appendix A, Criterion 3, Black Fox, 1 and 2 must utilize cables with fire retardant insulation.

, 8. Intervenors contend that in order to meet 10 CFR Part 50, Appendix A, D "... Criterion 3, the Applicant must separate the cable trays, including those in the cable spreading rooms so as to prevent a recurrence at

.) Black Fox, 1 and 2 of the type of fire which took place in the cable spreading room at Browns Ferry.

- - .. . - - ,~ _ _ . .-

My testimony addresses 10 CFR Part 50, Appendix A, Criterion 3 -- Fire Protection and its applicability to the

~%g electrical cable constructions that will be used at BFS and cable qualification tests that provide adequate assurance that cable will meet the requirements of Criterion 3. My testimony also addresses 10 CFR Part 50, Appendix A, criterion 3 -- Fire Protection and its applicability to the design of the cable tray installation in the BFS cable spreading rooms and the cable tray installation design criteria that provide adequate assurance that the design will meet the requirements of Criterion 3. My testimony addresses cable and cable tray installation design that is within the Black & Veatch scope of design. Messrs. Gang and

• Johnson of the General Electric Company address the Contentions in the context of GE's scope of supply, namely, the Power Genera -

tion Control Complex.

Criterion 3 states in part;

" Structures, systems, and components important to safety shall be designed and located to minimize, consistent with other safety requirement, the probability and effect of fires and exp3osions."

BFS structures, systems, and components important to safety are identified in BFS PSAR Section 3.2, and include cable and cable i

trays designated Class lE,' as defined in IEEE Standard 380 - 1975, 1 ,~

" Definition of Terms used in IEEE Standards on Nuclear Power

( Generating Station." BFS cable designated as Class lE must be insulated with material which meets the requirement of Criterion 3.

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The cable spreading rooms at BFS are labeled " Division 1 and 4 l I

gs Cable Spreading Area" and " Division 2 and 3 Cable Spreading Area,"

and are located at Elevation 575'0" in the Control Building (BFS PSAR Figure 1.2-19) . The FBS Cable Spreading Areas contain Class lE cable and cable trays; and, therefore, the design of the cable tray installation in the BFS Cable Spreading Areas must also meet the requirements of Criterion 3.

Flame retardant properties of Class lE cables can'be adequately demonstrated by type testing in accordance with IEEE Standard 383-1974, "IEEE Standard for Type Test of Class lE Electric Cables, Field Splices, and Connections for Nuclear Power Genera-ting Stations." Cables which meet this test have been accepted as

,, meeting NRC Branch Technical Position APCSB 9.5-1, Appendix A dated May 1976. All BFS cables within the Black & Veatch scope of design, including any cables added to the PGCC, will be specified to meet IEEE 383-1974.

IEEE 383-1974 includes procedures for a flame test of an entire cable construction, including the cable insulation. This test demonstrates that, when the cable is installed in the vertical tray configuration, the cable does not propagate fire even if the cable insulation and outer covering have been destroyed by fire in the area of flame source impingement. Successful completion i

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of the type test of IEEE 383-1974 provides ad' equate assurance that the insulation and jacketing material of cable installed in a tray will not support the spread of a flame within that tray. It therefore provides adequate assurance that the cable constructions used for Class lE cables are designed to minimize the effects of i fire ao swsAEGd by RgfSagfWiLA

Criteria for the design of Class lE cable tray installa-tions are given in IEEE Standard 384-1974, "IEEE Trial-Use Standard Criteria for Separation of Class 1E Equipment and Circuits."

Section 5.1.3 of IEEE Standard 384 states criteria for the separation of Class lE cable trays in Cable Spreading Areas. That Section states in part:

"The minimum separation distance ,

between redundant Class 1E cable trays shall be. .

.1 ft. be tween trays separated horizontally and 3 ft. between trays separated vertically."

Section 5.1.1.3 of IEEE Standard 384-1974 states specific requirements for cable and cable tray construction, cable instal-w lation, and hazard limits that must be met in order that the s-1 ft. horizontal and 3 feet vertical separation distances can be used as criteria for the design of the cable tray installation in Cable Spreading Areas. The BFS Cable Spreading Areas will meet these criteria.

Since the issuance of IEEE 383-1974 several cable fire experiments have been conducted under the authorization of the 1 l

, NRC. The experiments have provided data for evaluation of the l IEEE 383-1974 flame test and its adeque- 'n providing assurance that cable constructions that pass the test will meet the design s

objective of minimizing the spread of a cable fire within a

) cable tray and thereby minimize the effects of fire. In an experiment conducted at Sandia Laboratories, cable of a construction that had passed the IEEE 383-1974 flame test was 1

1

installed in a horizontal run of cable tray, to a fill that

'N appears to exceed the BFS cable-tray-fill design criteria, and ignited using two IEEE 383-1974 flame-test burners. From the reported test results, it appears that flame did not spread significantly beyond the area of burner flame impingement within the cable tray in which the ignited cable was installed.

In a series of six experiments conducted by Underwriters Laboratories, PVC insulated, nylon jacketed cable was installed in a vertical cable tray and subject to a burner flame similar to that of IEEE 383-1974. (This cable construction probably meets IEEE 383-1974, but does not have as good flame retardant properties as the cable materials planned for BFS). In five of

')J the six experiments, separate burners were producing flame impinging on the front and rear surfaces of the packed cable mass for 20 or more minutes before flames had spread significantly beyond the immediate area of flame, impingement. In two of the experiments, fire did not propagate beyond the immediate area of flame impingement, and the test was terminated 40 minutes after burner ignition. The results of these experiments are mixed.

However, these experiments do provide some data that support the adequacy of the IEEE 383-1974 20-minute flame test. That standard is a repeatable flame test that provides assurance that cable g installed in nuclear power plants will meet the design objective

, 4 N- of minimizing cable fire propagation, and therefore minimize the effects of fire. To py knowledge, the IEEE has no plans to

) revise the flame test provisions of this standard. In my opinion,

s successful completion of the flame test of IEEE 383-1974 7 s provides the required assurance that a cable construction is

_. designed to minimize the effects of fire.

Since the issuance of IEEE 384-1974, several experiments have been conducted.by Sandia Laboratories under authorization by the NRC. These experiments have provided data.for evaluation of the tray separation distance criteria of IEEE 384-1974, and the adequacy of these criteria in providing assurance that the cable tray installation will meet the design objective of minimizing the effects of an electrically initiated fire in one cable tray or adjacent cable trays.

These experiments were conducted on cable tray installa-D 1 tions that met the requirements of IEEE Standard 384-1974 for s ./

cable and cable tray construction, cable installation, and hazard limits. The cable tray separation ~ distances used in these experiments were less than the IEEE Standard 384-1974 design criteria for minimum separation distances between cable trays in Cable Spreading Areas. Seven separate full scale experiments were conducted, and the experiments are described in detail in Sandia Laboratories reports. In all of these experiments, electrical ignition of a cable fire was accomplished in an

" ignition" tray, and data was gathered on the effect of such

% a fire on cable in trays below, above, and to the side of the

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ignition tray. As stated on page 32 of the Summary and conclusions of " Cable Tray Fire Tests," Sand 77-1125C,. July 1977:

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. . _ . , . _ . ..~ . _, . - . , . - . - _ . _ . _ . . . . , . . . . , . . . . _ . _ . . .- . _ _ _._ . . _ , . _ . .

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"At no time t'id the cables in trays displaced from the ignition tray begin f

,T to burn. All circuits in-these trays remained functional and elongation-measurements taken of the insulation closest.to the fire showed no major

(<10%) change. "

These experiments provide significant assurance that Cable Spreading Area cable tray installations designed in accordance with the criteria of IEEE Standard 384-1974 will minimize the effects of fire as required by criterion 3.

An additional experiment'was conducted at Sandia Laboratories in July 1977. In this experiment, a cable tray fire was initiated by two burners, each of which satisfied the heat input

. _ , specifications of IEEE 383-1974. In other words, the experiment used an exposure fire. It also employed stacked cable trays I and cable tray separation criteria of IEEE 384-1974. Therefore, this experiment does not constitute a verification of the cable tray separation criteria of IEEE 384-1974 for cable spreading rooms, since the design basis fire for cable spreading rooms . is 1

an electrically induced fire rather than an exposure fire.

Nevertheless, this experiment provided data useful in analyzing cable tray installations that have an exposure fire as a design basis.

The first attempt to ignite the cable with a five minute exposure to the dual burners did not result in a fire in the exposed cable tray. In order to obtain a fire, a steel bar was used to move the cables about at the ignition area to increase

,,,,..m, ,,,wm

s air flow through the trays. Such an air flow is ordinarily ,

precluded by the industry standard practice of specifying

?%

I installation of cable in a parallel, stacked fashion, with no slack. This practice can be an effective means of reducing the probability of cable fire as a result of an exposure fire, and probably ought to be more rigorously enforced.

At least one aspect of the experiment tends to compromise the potential value of the data. The cable trays simulating a redundant division spearated by five feet vertically could not be observed throughout the experiment. Since these cable trays collapsed inte the lower trays, it is not possible to positively conclude that the top trays were set aflame by the fire in the

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lower trays.

On the other hand, the lowest three cable trays separated horizontally from the exposed cable tray by 8 inches, were not affected by the fire and the cable in those trays remained functional. In addition the cable tray simulating the redundant division, and located three feet horizontally from the top of the 14 trays simulating the other division, was not damaged and the cable in that tray remained functional. This provides some evidence that the horizontal spearation distance criteria of IEEE 384-1974 may be more than adequate even if an exposure fire is admitted as a design basis for cable spreading areas.

With the issuance of IEEE 384-1974, the IEEE has established cable tray specific distance criteria for cable tray in cable

) spreading areas.

t Subsequent Sandia Laboratories experiments with electrically ,

,. initiated fire have provided evidence that these specific

, separation distance criteria are adequate. Although the IEEE -

issued a revision to IEEE.384-1974 in 1977, the cable tray separatior dit riteria were not revised; and , . to my knowledge, the a plans to revise these separ.'t'en criteria.

In my opinion, c. ale tray installations in cable spreading rooms designed in accordance with IEEE 384-1974 will provide the required assurance that the cable tray installation will minimize the effects of fire.

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, ATTACHMENT I PROJECT DESIGN ENGINEER-ELECTRICAL: Gary R. Engmann .

~~

) EDUCATION

BS Electrical Engineering, University of Kansas, 1966 MS Electrical Engineering, University of Kansas, 1970 MBA Business Administration, University of Kansas, 1971 Additional Education and Training Westinghouse, PWR Technology Seminar, 1974 I-T-E Imperial Corporation, Electrical Switchgear for Nuclear Power Stations, 1975 Reliance Electric, Qualification of Motors for Class lE Service, 1976

~5 Rotork, Inc. , Valve Motor Operator Design and Application,1976

' /

United Technologies-Essex Cable, Fabrication and Testing of Power Cable, 1974 PROFESSIONAL REGISTRATION:

Professional Engineer, Oklahoma, P.E. 9995, 1975 Professional Engineer, Kansas, License No. 6750, 1973 EXPERIENCE:

As Project Design Engineer-Electrical, I am responsible for the design of the auxiliary electric system including the -

i' preparation of economic analyses, engineering calculations, drawings, and electrical equipment procurement specification for BFS. I am

'S

(}{/ also responsible for the preparation of electrical construction technical specifications and drawings.

) l

. . . . . . . . _ - . . . _ - . . _ . . _. ~ _ . _ . . _ _ . . . . - . - . . _ - . . , . . _ . . . _ . - . . _ . _ , . . . . - . . . - . . . . . . . . , , , ,

~ . . . . . . .

s Since my assignment to BFS in 1974, I have supervised

,, and contributed to the auxiliary electric system design and k

._ analysis, participated in the preparation of the pSAR chapter on the auxiliary electric system, supervised the detailed design of electrical raceway and cabling, contributed to the scheduling of electrical design activities, and coordinated the electrical design effort with other engineering disciplines required for -

station design.

Throughout 1974, I served as the Project Design Engineer-Electrical for a two-unit 960 MW coal-fired generating station and participated in the preparation of studies, analyses, and design criteria for electrical system configuration and equipment

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ratings. I also participated in and supervised the preliminary design of the auxiliary electric system.

From 1972 to 1976, I served as the Project Design Engineer-Electrical for a two-unit 960 MW fossil-fueled generating station.

I participated in and superviced the final design of the atuiliary electric system, preparation of engineering calculations, prepara-tion of equipment and construction specification and drawings, and preparation of the electrical control schematics.

Upon joining Black & Veatch in 1971, I was assigned to a design project for a 480 MW fossil-fueled generating station and performed engineering calculations for auxiliary electric system z.,.

design.

I am presently serving on the Power Generation Committee and the Nuclear Power Subcommittee of the IEEE Power Engineering Society.

. . . ._ . _- - _ _ _ . . . . .~ . _. . . _

3_

Prior to joining Black & Veatch, I was employed by the Center for Research in Engineering Science, and participated in

,. . m the design, fabrication and testing of radar units for remote sensing application.

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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) )

Testimony of Dr. E. L. Cox Concerning Contention.No. 9 (Fire Protection)

September 25, 1978 h

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, _ TESTIMONY OF E. L. COX

• CONCERNING CONTENTION 9 My name is E. L. Cox. I reside at 8209 Linden Drive, i Prairie Village, Kansas. I am a Project Engineer for the Black Fox Station project at Black & Veatch, Consulting Engineers in Kansas City. A statement of my education and experience is

. attached as Attachment I to my testimony. My responsibilities at Black & Veatch include the direct supervision of the detailed Fire Hazards Analysis and the design of the fire protection systems for Black Fox Station within the scope of supply for Public Service Company of Oklahoma (PSO), as the lead Applicant.

My testimony is prepared in response to Intervenor Contention 1

9. / The purpose of my testimony is to demonstrate that the Applicants have designed an in-depth fire protection system for the Black Fox Station which complies with 10 CFR Part 50, Appendix A, Criterion 3.,

The fire protection systems for Black Fox Station are briefly described in Section 9.5.1 of the Black Fox Station Preliminary Safety Analysis Report and, in addition, are more fully described in an extensive Fire Hazards Analysis Report which has been performed and submitted to the NRC Staff on November 28, 1977, as Black Fox Station Reference Report 16.

1/

<- Contention 9 reads: 1 if Intervenors contend that the Applicant has not designed an in-depth fire protection system for Black Fox 1. and 2. which complies with 10 CFR Part 50, Appendix A, Criterion 3. l

PSO addressed the positions of Appendix A to NRC Branch

_ Technical Position 9.5-1 " Guidelines for Fire Protection for

'h Nuclear Power Plants Docketed Prior to July 1, 1976," in particular, those positions specified for applicants whose application has been docketed but whose construction permit had not been received as of July 1, 1976.

The Fire Hazards Analysis designates 15 fire areas associated with safety related equipment and structures in each unit. Many of these areas are further subdivided into fire zones. The Fire Hazards Analysis evaluates the types and quantities of combustibles contained in each area, hypothesizes a design basis fire which can be considered to cause the most damage and evaluates

) / this fire to detcrmine the impact on station safety based upon j

the design of structures and the fire detection and fire suppres-sion systems provided. Inadvertent operation or malfunction of the fire system is also evaluated. Where indicated by the Fire Hazards Analysis, changes to the fire protection systems were made.

The fire protection systems have been designed with an in-depth approach. This approach uses a balance of the following:

a. Design for fire protection.

b. Prompt fire detection.

c. Prompt fire suppression systems.

d. Separation of essential systems to reduce the '

, consequences of a fire.

)

e. Station personnel trained in fire protection methods.

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f. Administrative procedures and controls.

The design of structures, systems and components important to s

safety considers the importance of fire protection and prevention.

Fire walls and fire doors are provided to contain fires depending upon the identified fire hazard. The propagation of fires is minimized by the separation of safety systems, the placement of fire walls and the isolation of combustible materials. Non-combustible materials have been used wherever practical throughout the station, particularly in locations important to nuclear safety. The Fire Hazards Analysis gives 'the location and type of fire detection and suppression systems currently being designed for Black Fox Station.

Safety related equipment is located, or other provisions are made, such that water used to extinguish fires does not af fect their operational status. The design specifications require that fire protection systems be designed for proper capacity.

The systems are designed such that the effects of pipe rupture and inadvertent operation will not impair the safety function of systems, structures and components. The fire protection systems are designed and are to be constructed in accordance with acceptable fire protection codes and standards. The fire wa 3r system at Black Fox Station is dedicated to fire protection only

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and redundancy is provided for the Reactor Building from a safety N' related water supply. Suff!cient fire water stations with hoses are located inside and outside buildings to provide a means for manually fighting any fire if necessary. Portable fire

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1 extinguishers are to be located as needed at the station.

Detectors are located.in areas and ventilation ducts within  !

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j g , structures where any significant fire potential exists. A-sophisticated fire detection system is provided to give prompt

. alarm in the event of a fire and provides detail on fire location.

Fire detection and actuation systems are powered by a reliable power source. The system is designed to minimize the potential for false alarms and yet provide a reliable fire detaction system.

Automatic suppression systems are located in areas where the potential of a fire hazard exists. Charcoal filters are equipped with detectors and manual fire suppression systems.

m

) Areas of high cable concentrations are protected by suppression

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systems, including the cable spreading rooms and the floor of ,

the control room. For the PGCC floor sections, a fire suppression system is provided in accordance with the General Electric criteria accepted by the NRC staff, as described in the testimony of Messrs.

Willian Gang and R. B. Johnson on Contentions 7. and 8.

PSO will provide a trained fire brigade at the station to provide fire fighting capability 24 hours2.777778e-4 days <br />0.00667 hours <br />3.968254e-5 weeks <br />9.132e-6 months <br /> a day. A detailed fire plan is being formulated by the applicant as part of the station procedures; and fire prevention is included as a part of the

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station administrative procedures. PSO has designated a corporate

officer to be responsible for fire protection and has implemented special quality assurance procedures on the procurement of fire

-) protection equipment and construction of fire systems.

The in-depth design of the fire protection system for Black Fox Station considers the experience of other nuclear stations as

N -

reported to the NRC and, in particular, the experience gained from the fire at TVA's Browns Fer.".f nuclear station. Subsequent to the fire at TVA's Browns Ferry nuclear station, I ordered a compilation of all fire related incidents reported to the NRC since 1969. This compilation was sufficiently detailed to permit me to evaluate the capability of the Black Fox Station system to p*_ event or suppress similar occurrences. In addition, I have reviewed the "Hanauer Report" ! on the Browns Ferry fire and have considered this information in the design of the Black Fox fire protection system.

3 During development of the specifications and detailed design

)

_/ for the Black Fox fire prevention system, I am continuing to review and consider NRC reportable occurrence reports relating to fires or fire protection equipment. Therefore, the design criceria for the Black Fox Station fire prevention system is based on the most current information available.

As further evidence of the in-depth measures toward fire 1

protection for Black Fox Station, Black & Veatch, as directed by PSO, transmits drawings and specifications for Black Fox fire protection systems to an independent fire protection consultant for review and comment. The consultant's comments are incorporated i 1

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Hanauer, et al., Recommendations Related to Browns Ferry Fire, Washington, D. C.: U.S. Nuclear Regulatory Commission, 1976.

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s into the' design of Black Fox as directed by PSO.

I conclude that the Applicants have designed an in-depth (D -

fire protection system for Black Fox, 1. and 2., which complies with 10 CFR Part 50, Appendix.A,. Criterion 3.

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OTTACIIMENT I x

POSITION AT BLACK & VEATCH 3 '

Project Engineer - Licens14g - Special Studies for Black Fox Station Project EDUCATION BS Mechanical Engineering, Case Institute of Technology, 1955 MS Nuclear Engineering, University of Missouri, 1967 PhD Nuclear Engineering. University of Missouri, 1970 PROFESSIONAL QUALIFICATIONS Registered Professional Engineer - Missouri and Ohio EXPERIENCE:

At Black & Veatch I have responsibility for licensing activities pertaining to Black Fox Station including the technical

~

review of the content of the Environmental Report and Preliminary Safety Analysis Report, the preparation of the two documents and for coordination of communications between B&V and the NRC, PSO and GE. Two systems in particular fall under my responsi-bility as Project Engineer for Special Studies. These are Fire Proteculon and Security. I supervised the preparation of the Fire Hazards Analysis for BFS and I am responsible for coordinating the review of BFS design with PSO and the PSO fire protection consultant. I am responsible for the security design of Black Fox Station including associated design and procurement specifications.

I directly supervised the technical portions of the BFS Security Plan.

For ten years prior to joining Black & Veatch, I was

) employed by the University of Missouri in Columbia, Missouri. I served in the capacity of Director of the University's 10 MW

2-n.

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Research Reactor Facility, also as Reactor Supervisor and Associate Reactor Supervisor at that facility. I held a senior S

reactor operations license for the f acility.

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From 1959 to 1963, I was employed by General Electric Company and worked at the Vallecitos Atomic Laboratory located near Pleasanton, California. I served in the capacity of Irradiations Engineer, Plant Engineer, Shift Supervisor and Senior Plant Engineer at the General Electric Test Reactor. I held a senior reactor operators license on the General Electric Test Reactor.

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Wid7 BY MR. GALLO:

s 2 Q

Dr. Cox, I show you a document and ask you ,

3 I to identify it for me.

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A (Witness Cox) This is a document prepared in 5

support of the prel.tinary safety analysis and incorporated

- 6 as part of that analysis as reference report 16 and is 7

entitled " Black Fox Station Fire Hazards Analysis.

8 Construction Permit Stage."

9 Q Was that report prepared by you or under to l

your superv'sion?

11 A Yes, it was.

11 MR. GALLO: At this time I would like to mark 13 J for identification the report just identified by Dr. Cox.

14 I will refer to it as reference report 16.

15 I would like to mark it Applicant's Exhibit 16 No. 33. I have three copies for the reporter for that l 17 purpose.

18 CHAIRMAN WOLFE: It will be so marked.

(The above-entitled document was 20 marked Applicant's Exhibit No. 33 21 for identification.)

22 BT MR. GALLO:

23 Q Do you have a copy with you?

24 A (Witness Cox) Yes, I do have, s.-

25 Q Dr. Cox, we established that it was prepared under your general supervision and direction.

+-- --_o, . . .. -, _ - . , ,. 4 ..s -

n. -<-w-- r. . - . v, , - - . . , - - , , , , , - , , , - , .,n..r, ,,m - . ,- , . *,,..-,,,.,,-4

ll 1 4

6837 1

lavid8 Is it accurate and ccmplete to the best of

,. /

( your knowledge and belief? I 3)

, A The document is accurate and complete based .

'i 4 I upon the design of Black Fox station at the time it wad 5

prepared, which was mid to early 1977.

6 The station design is a moving thing, and as 7

a consequence of that, there have been changes in the Blach 8

Fox station design which affect the content of the fire 3

hazards analycis.

10 0 With the exception of these design changes you 11 indicate, is the document accurate and complete to the best 12 of your knowledge?

, 13 A Yes, it is.

14 O Do you have a summary with respect to those 15 changes?

16 A Yes. If I can refer to my notes, I can 17 briefly summarize.

18 MR. GALLO: If there is no objection, Mr. Chairman, 19 I would 6tsk the witness to do that for the benefit of 20 clarity of the record.

21 CHAIRMAN WOLFE: No objection?

22 MS. WOODHEAD: No objection.

u 23 CHAIRMAN WOLFE: All right. Proceed.

24 s WITNESS COX: I have listed those -- a brief a

u 25 description of those things that are affected by amendment

i 6838 devid 9 1 nine to the PSAR, the arrangement for the health physics 2 building, administration building, and rad waste building 3 were changed.

4 These changes have been approved and fire 5 protection measures taken accordingly. We have 6 incorporated design criteria for fire protection to the 7 PGC. The specifications for cable installation icve 8 been established.

9 The design of the water treatment housing and to the fire pump has progressed. The fire protecti:n for 11 the construction facilities has progressed.

12 We have other factors that are less broad, in 13 scope, but nevertheless do affect the fire hazards 14 analysis.

15 These include the wet pipe sprinklers changed 16 to dry pipe sprinkler over the railroad and truck base I to circumvent the poss1bility of freezing. The yet 17 18 pipe spri2Rers changed to deluge spray over the reactor 19 feed pump areas.

20 THe wet pipe sprinklers have been added to the 21 general service building, trash compactor and storage 22 areas.

~ 1 23 Automatic smoke venting has been defined for the l 2j control building, turbine building, diesel generr. tor

./ building and the standby service, water service ptmp 25 i

l

6839 l 2 l vid10 building. 1

)

2:

! The equipment has been upgraded in the fire 3

,, hydrant hose houses. The flame detectors have been 4 '

replaced with ionization or thermal detectors to increase 5

reliability. ,

i 6

Thermal detectors were added to the turbine I 7

bearings and reactor circulation pump bearings.

6 Ionization detectors are added in the areas of the cable 9

penetrations and the containment of dr/well.

10  !

Full electric smoke detectors have been 11 added to the general service building locker rooms. They 12 have a heating, venti 11ating and air conditioning failure

[ alarm in the battery rooms.

14 The door alarms en those fire doors not

~

15 normally closed - I'm sorry. The door alarms on those 16 fire doors not normally locked closed, separate fire 17 alarms to the plant vent charcoal filters has been added.

18 And the details on the emergency lighting have 19 been developed.

20 And that is a summary of the changes that have 21 taken place.

s MR. GALLO: Thank you, Dr. Cox.

t 3 -Mr. Chm 4 man, at this time I would like to move into evidence what has been marked as Applicant's i

./ 25 Exhibit No. 33 as a part of.our case in chief.

6840 1

r vid11 CHAIRMAN WOLFE: Any objection?

2 MR. FARRIS: I don't have any objection to 3

the document, but I would like to see the changes, I 4

think, if they are documented anywhere.

5 Caid we get a copy of --

6 MR. GALLO: Would you like to see a copy of 7

what he read?

8 MR. FARRIS: Yes.

9 MR. GALLO: I will provide that.

10 MR. FARRIS: No objection.

11 MS. WOODHEAD: No objection.

12 CHAIRMAN WOLFE: Applicant's E:thibit 33 is s 13 admitted in evidence.

14 (Applicant's Exhibit No. 33 was 15 received in evidence.)

16 Mr. Chairman, the witnessen are MR. GALLO:

17 available for cross examia t.icn.

I0 CHAIRMAN WOLFE: Ms. Wcodhead.

CROSS EXAMINATION 20 BY MS. WOODHEAD:

21 Q Mr. Engmann, I have some questions fer you first.

s 23 On page 3 of your testimony ycu state that all 24 cables for Black Fox station within Black and Veach's scope

) 25 of design will teet the IEEE-383 standard.

6841 I Are there any cables to be installed at

'9 avid 12 3 Black Fox other than GE or Black and Veach design?

3 A (Witness Engmann) No.

m 4 GE and Black and Veach are responsible for l

5 design of Black Fox.

3 Q You heard the testi9ony of Mr. Gang and Mr.

7 Johnson that GE's supply would be 3S3; so therefore, 8 isn't it true that all Black Fox cables will meet the 333 9 standard whether or not they are classified as 1-E?

10 A That - is correct; all of those cabiss 11- will be specified to meet the IEEE 383. test.

12 Q Thank you. ,

1 13

.]14 14 ,

15 16 17 18 19 20 21

- 23 24 N

> 25 l

n

BW15 arl 6842 1 Q could you explain briefly what the purpose of

~. 2 the IEEE 383 test is, the flame test?

3 A I think by definition of the flame test in that 4 standard, it is fairly clear that the test,is intended 5 to provide assurance that cables installed in tht power 6 generating station will not propagate flame in the raceway 7 in which they were installed, when subjected to a flame er 8 fire.

9 Q Now I assume by what you just said that it is 10 not true that the 383 cables are fireproof?

gg A ch -

12 Q That they will not burn under any circumstances?

g A I think anybody will tell you that any cable 14 will burn, yes.

15 Q on pages 4 and 5, you -- starting at the bottom 16 of page 4, you refer to the SAndia test. It is not clear 37 to me which of the series of Sandia tests this one might be.

18 Can you clarify the date on that one? ,

, gg A The experiment referred to there was conducted, I 20 believe, on July of last year, of 1977.

21 Q Well, you are referring to the top of page 5 of 22 y ur testimony where you state that the flame did not spread

.) 23 beyond the area of the flame impingement? This is the July I

y '77 test?

A As I state in my testimony from the test results, 3

1 1

._ . , _  :, -.. . , - . . . . - _ , ~. -

)

l ar2 6843 I 1 it appears that the flame did not spread significantly s 2 beyond the area of burn or flame impingement witrin the 3 cable tray in which the related cable was installed.

m

+

4 0 Isn't it true.that the July '77 test initiated--

5 the initiated fire burned the entire division?  !

6 A As I interpret the report, the igniti:n cable 7 tray did not -- the e.ble in that did not propagsta down i e that tray, the horizontal tray.

g It is true we have vertical propagatien frem to tray to tray.

11 O I see.

37, You are speaking of propagation along the cables g within the one tray, irregardless of the fact that the

~

flame did spread to the upper trays?

94j t

A es.

15 16 0 I see.

A As I indicated, that is the intent of 383 flame 37 test, is t pr vide assuranco that we do not have propagation 18 i

g 4

within the tray in which that cable is installed.

.Q Purther down on page 5, you discuss a UL 20 g experiment with PVC cables. Does this discussion imply a't g all that Black & Veatch will provide PVC for Black Fox?

.h g A No, it does not. -

Q What is the purpose of your testimony here?

s 3 A I was trying to provide additional material that 25 1

i

Or3 6844 ,

I think tends to support the precept that the 383 flame 9

- 2 test does provide adequate assurance that once tha cable is installed in a power plant, in the normal configucation of 3

4 the 40 percent fill and possibly vertical runs of the trays, that if that tray is subjected to an sxternal -flara, that 5

the cable will not protagate in that tray.

6 7

MR. GALLO: The witness said the cable will not 8

propagate?

WITNESS ENGMANN: Excuse me. The flame will not 9

propagate. ,

10 i BY MS. WOODHEAD:

g ,

Q In ther words, you just explained in more 12 detail what the.383 test is. Your focus on PVC is not ,

-~

g really relevant to Black Fox; is that the way I understand it?

A (Witness Engmann) The construction is not the 4

construction that we used at the Black Fox Statien. IEEE I 8 is conducted with singles that are spaced in a vertical i 17 l tray the UL experiments attempted to fill to a 40 percent I fill, which was a more usual configuration, and then sub-

>- 19 , .

jected that configuration to 70,000 Btu flame scurces.

It is considerably different than the 383 flame test.

MR. SHON: You said it was different. Is it, in 22' your opinion, more rigorous or less so?

23 ,

WITNESS Ef5EANN: One of the conclusiens they N drew from the UL test was that - experiments -- they were V, 25 nonrepeatable.

b w g .. y, , . , ,--m,--g , y + ve- ,w tv 4., r-r , .we---+g -w- ,*+y--ww- ,,.-,w*,r.-vv. --,w-ww-ve-.. w,-. -wme.#----,w~. - , - -. .---.,~w- ++---w-

er4 6845 1 It is difficult to draw any conclusio6s from 2 them. We do have some evidence that perhaps a esble has 3 passed the 383 and is installed in that pack con.~iguration 4 and will not propagate even when subjected to an external 5 flame source.

6 BY MS. WOODEEAD:

7 0 Since we have clarified that Black & 'reatch 8 will not supply or does not intend to supply PVC for Black 9 Fox, could you tell me what other than 383 cables, could to you tell me the materials for the cables?

11 A (Witness Engmann) Ethylene propylene rubber with chlorosulfinated polyethylene jacketing, material for the med-dium voltaae, low voltage singie conduct 6i,?ctoss link N1y-12 ethylene with chlorcatifits.ted polyethylene jackee 13 for multioonductor low voltage powers, cables and control 14 cab Hs, the instrumentation Nables,'the insulaticn constructed 15 for those will be largely dictated by the spec'ial wire 16 cable specifications provided by the Nuclear Energy Division.

37 MR. FARRIS: Can we have that read back by 18 the repo h , please, a little slower, please?

19 (The reporter read the record as requested.)

20 MR. GALLO: I am not sure in reading back, 4

21 that hearing the question read back, that the record has 22 .the last four or five words,provided by the Nuclear Energy,

_ g and that was the last word I-heard.

3 Perhaps just for the sake of prudence, we could

,, get that part repeated again by the witness.

I i

.e 4

ar5 6346 1 WITNESS ENGMANN: The Nuclear Energy Division.

2 BY MS. WCODHEAD:

3 0 On page 6 of your testimony, you referred to

'4 some Sandia tests which were concerned with IEEE 384 ,

5 separation criteria, and in there you referred to a design 6 objective of the electrical fires.

7 Could you clarify what you mean by docign ,

8 objective there?'

9 In other words, do you mean the objective of to the test, or the objective as a design objective for a fire 11 protection program? ,

12 A (Witness Engmann) If I am reading.the correct 13 *91 ace, the testimony said these experiments have provided 3

14 data for evaluation of the tray separation distance criteria 15 of IEEE 384-1974, and the adequacy of these criteria in 16 providing assuance that the cable tray installation will j7 meet the design objective of minimizing the effects of an 18 electrically initiated fire.-

19 Q I understand that, but your term design objective, 20 the'use of your term design objective is not clear to me.

21 Is the design objective related.to the design j 1

l 22 objective of this test, at the Sandia laboratories, or are a

j g you referring to the NRC fire protection design cbjective i

g program?

[ 25 A The design objective that is setting the 1

l

- - - , . - . . n , ,, ..... . .,. , . , . . . . , - _ , , , , , , ._

6847 g distance criteria of IEEE 304.-

-2 Q I see.

The design objective means to test the 384 3

4 criteria; is that what you meant by that?

A I am saying that the design objective is to 5

minimize the effects of an electrically initiated fire.

6 As a result of that rather generic design object!.ve, the 7

specific separation distance criteria have been :.ncorporated 8

* * ** * " * ~~ " *

• 9

• ** #* 9 ** # # # " *** "9

• 10 generic design objective are.

Q Thank you.

On page 7, further discussion of the July '77

)

Sandia test, you indicate that this test of July showed 14 that the IEEE 384 criteria was sufficient, and that'the Sandia test was not significant.

In other words, the results of the Sandia test 17 were not significant since the design basis fire for cable spreading rooms is not an exposure fire.

Do you know what the Staff position for design basis fire is?

21 A With respect to the cable spreading areas?

22 s

i Q Right.

23 A I have been unofficially advised of it, yes. I 24 have read it in no official document that applies to the 25

ar7 6S48 Black Fox Station.

1 Q Are y u familiar with Reg. Guide 1.1207 [

2 A Yes, I am.

3 Q You did not see any e::posure fires as --

4 MR. GALLO: Objection, Mr. Chairman -- I'm o

sorry, I didn't let her finish her question.

BY MS. WOODEZAD:

7 Q You said - I'm sorry. I've forgotun what my question was.

I was asking the witness if he had not seen exposure fire as a design basis in Reg. Guide 1.120.

MR. GALLO: My objection, Mr.-Chairman, is that it is my understanding that there are two versions of the reg.

" gus.de, and we need to know which version counsel is speaking 14 to so that the witness would be able to respond intelligently.

15 MS. WOODHEAD: I would be glad to clarify that, 16 Revision 1, November '77 of Rog. Guide 1.120, in particular.

17 WITNESS ENGMAMN: In Reg. Guide 1.120, Revision i 18 1, I am not certain that I have ever seen an explicit 19 definition that exposure fires of design basis in the 20 cable spreading area - irrespective of that, I am not aware 21 that Revision 1, Reg. Guide 1.120 is applicable to the Black 2?.

c) Fox Station.

1. 23 cnd 15 24 T

'- > 25 6

y

l 6849 1 0 Are you familiar with branch technical position i npa 16 I s 2 951 of May '76 , issuance? i avid 1 )

3 A Yes, I am. '

) 4 0 In your opinion, does that apply to 32.ack Fo::?

1 5 A That is the design basis for the Black Fox )

l 6 station.

7 Q The branch technical position of that 7 ear, 8 19767 9 A Yes, I undershnd that is the design basis 10 for the Black Fox station.

11 MR. SHON: I am confustA. We just had a 12 couple of GE witnesses that assured us that branch 13 *echnical position 9.5-1 and Reg Guide 1.120, revision 14 one, were essentially the same.

13 In fact, I think a footnote in the tesi:imony says 16 essentially that..

17 Now, you just told us that you need ona but 18 net necessarily the other.

gg Is that what you have been telling us?

l 20 WITNESS ENGMANN: I - irrespective of whether 21 I can find that exposure fire postulated in revi6n 22 one of Reg Guide 1.120, I was not aware that Reg Suide 1.120 g was part of the design basis for the Black Fox station.

24 MR. GAIJ 0: Mr. Chairman, may I be heard on

~) 25 this pint to help clarify the situation. I think the

_. _. - _ _ _ . ~ - _ _ . _ _ . _ . ._ ._ .. -

t 6850 dsvid2- g applicable regulations is a legal matter. I shotild be

- 2 permitted to address this point .

3 CHAIRMAN WOLFE: All right.

4 MR. t. ALLO: There are two versions of branch

[  !

5 technical position 9.5-1. The se that is dated May 1, ,

6 1976 is the first version or wh. usually is cal!.ed rev zero.

7l The secon version is branch technical position 9.5-1 dated g November 7th, 1978, and that is revision one; g So tha -- that is a dccument that corresponds go to Reg Guide 1.120, revision one, as opposed to the 3g May version of the branch technical position which was g counsel's,, question.

g I have here a little map.for myself that I

~

g would be glad to furnish to the board, if there z.re no objections.

to 16 MR. SHON: Could you explain why you r.re g using the May 1976 version ,_of-branch technical positon 19 9.5-1. .e

.N*

l

.  : m ega , r. shon. j

', 20 ,....-~'

THe initial branch technical position was 21 -

l issued in 1976 after the Browns Ferrv- fire. data was developed i 22

'E

=

to -- for-dire protection. .

22 l

< 1 l

shortly after the branch issued Appendix A to

~

'- 25 this initial branch technical jictition, which allowed various alternatives according to the docketing Cate of

I '

I 6851

_ devid3 1 plants, so-as to accommodate the various stages of

, 2 plants under review at the time.  ;

3 Since that time, there have been two nore Ei 4 revisions,to the branch technical position. The branch 1

5 technical positions are refiscted more formally in Rag 6 Guide 1.120 and its revision;as the branch technical 7 Position is issued, so is Reg Guide 1.120. 1.123 at 8 the moment is out for comment, and it has not baan s issued officially through the Federal Register procedures 10 as an official Reg Guide.

11 MR. SHCN: 1.120 which you say has not yet 12 officially been sanctioned, but it is still out for a comment - does revision one correspond to the spring 1978 v

14 revision one of branch technical position 9.5-17 15 MS. WCODHEAD: Revision one of 1.120 and 16 revision one of branch technical position, that is your 17 question?

18 MR. SHON: Yes.

19 M8* WCCDHEAD: Yes, that is right. Rag Guide l .

20 1.120 revision one is the same as branch position 9.5-1, l

21 revision one.

22 MR. SHON : That is the way we had undarstood ,

L (q/

23 it on the board. I think we understand it even more clearly 24 now, but new I am still a little confused by Mr.' Engmann 25 making a distinction, not between one revision and

6852.

1

^ david 4 another of a given document, but between the branch 2

technical position and the corresponding regulatory 3

, guide.

4 It was my impression that he had at 13act 5

suggested in his testimony that although he inta;ded to 6

meet the branch technical position as a design basis, 7

he did not feel the regulatory guide of the co rapending I

a revision number applied; is that correct?

9l WITNESS EMG! ANN: No, sir.

10 MR. SHON : Then I misunderstood. What is the 11 situation?

12 WITNESS EMGMANN: The fire hazard analysis

'3 13 addressed 9 - 5.1 -- Appendix A and how we intended 14 to implement that appendix in the design of the fire 15 protection or design of the station. That is the 16 design basis that I am using, branch technical position 17

'9.1-1, Appendix A, May of 1976, 18 MR. SHON: I see. And flat would hava corresponded to the earlier version of Regulatory 20 Guide 1.120; is that right?

21 WITNESS ENGMANN: If I can interpret the road

- map here, it was a subsequent revision to that branch 23 technical position, 9.5-1 that corresponds to an earlier s

revision or earlier issue of regulatory guide 1.120.

.J 25 MR. SHON: Thank you. I am sorry to have

6853 I interrupted your cross examination.

_ david 4 2 MS. WOODHEAD: That's all right. Are we -- we 3 have some understanding now? .

4 MR. SHON: As the board now understanfs it, 5 Mr. Engmann has told us that his design objectivo is 6 to meet the 1976 version of branch technical position 7 9.5-1, which was issued prior to the regulatory ruide 8 1.120, and therefore he is not taking the regulaterf 9 guide as the design basis.

10 Is that essentially it?

11 WITNESS ENGMANN: Yes, sir.

12 MR. FARRIS : Are you all talking about rev zero 13 then of branch technical position 9.5-17 14 MR. GALLO: The answer to that is yes,, sir.

l end 16 15  !

l 16 l 17 18 19 20 21 22, 74 s 23 24

)

-- 2s

.f BW17 Grl 6854 1 BY MS. WCODIIEAD:

. ,s 2 Q Mr. Engmann, I hand you a document. 17ould you 3 read the title, please.

'] 4 A (Witness Engmann) " APCS 3(9 5 1) Power Protection 3 for Nuclear Power P3 ants. "

6 Q Could you read the date on the bottom?

7 A 5-1-76.

8 Q And the 2cman number I?

g A Definitions.

10 Q And could you read this subtitle herc7 11 A It says under definition design basis fires.

12 Q Right.

13 A Those that are considered to cause most damage 34 and Sres that may develop in local areas assuming no 15 manual, automatic or other firefighting acticn has been 16 initiated, and the fire has passed flashover, the temperature at which autoignition of other combustions at the area 37 18 w 11 ocm and hs mached its peak burning rate.

gg Q Thank you.

20 Do you,use this design basis fire in y:ur plans g for Black Fox?

g A We have ackncwledgelthe worst case firo, yes.

'm

'j g Q This is the Branch Position that you use; is that  ;

1 Correct?

~

-) g A Tes.

1 1

4

. - - - .,,,,en., e - , , - - . - . , g n . -. . . e. g. 4, -, ,, , ,,-. n.,,. -. , ., ,-e v . . . . .n . --,,n.--

ar2 6855 1 0 Thank you.

2 A I have read that definition and my interpretation 3

of that definition, I did not read that one had to

' postulate any combustibles in the cable spreading area other 4

than the electrical cable installation in the jadet 5

6 material itself.

7 0 Mr. Engmann, what sort of fire startei the Browns 8

Ferry fire?

A From what I have read, it was a cand15.

9 0 Did you -- would it be correct to term that 10 an exposure fire?

11 A I think that in the -- in a very broaily defined 12 g way, you could say that is an exposure fire. I have tended 14 to relate the term exposure fire because it is jargon that has appeared in the later Sandia tssts to rather intense  !

15 flame sources, namely IEEE 383 70,000 Btu flame tources.

16 I would have difficulty classifying a candle 37

. ame s same categ n a 0,000 Btu k n.

18 O Isn't it true that you consider only two types 19 f fire when you design the fire protection program, that j 20 g

is either exposure or electrical as initiating?

A I am trying to determine what is the cource of I

[' energy that would ignite the combustible materia.~.. It would either have to be the energy present in the cable

.) system itself, or some other equipment in the rcom, or some

-s 25 l

l

ar3 6856

+

1 other source of combustibles.

2 Q I am not clear. Are you saying that there is

'~ t 3 some other category of fire to consider in a fire protection

) 4 program,otherthanelectricalorexposure,orareyousayingl 1

5 that there are different types of exposure fires 7 1 6 A Exposure fires, I guess you could lump in every-7 thing other than electrically initiated fire.

S Q And what part of the plant in Browns Ferry did 9 the fire begin?-

to A As I understand it, it was a wall penetration 11 from the reactor building to the cable spreading room. i i

i 12 Q Isn't it true that it was actually inside the la cable spreading room that it started, the candle, the flame 14 came against the insulation, the sealant, which then spread, l

15 caused the flame to spread on into the cable spreading room?

16 MR. GALLO: Objection. I don't undestand that 17 question. If the witness does, I have no objection.

18 BY MS. WOODHEAD:

19 Q Do you understand the question?

20 A (Witness Engmann) As I understand it, the flame 21 began in a penetration seal in a wall on one side of the 22 wall with the cable spreading arearon the other side was the OO 23 reactor. building.

1 24 Q It began inside the wall without being either in j 25 the reactor building or the cable spreading room?

, , . . - . - _ - . _ . e _ __ _ __. . - . - _ . _ - . _ . _ . . . _ . . _ , _ . - . . . _ , . . , . _ . . . . . . . _ . . _ . _ . . _ . . . . _ . _ _ _ . _ . _ _ . . . . . . _ _ _

ar4 6857 1

MR. GALLO: I am going to object. This line 2 is irrelevant. This is not an investigation of Frowns Ferry.

3 I understood that NRC had already done that. I Eee no a connection between the fire hazard analysis repo2t for 5 Black Fox and the line of questioning counsel is pursuing.

6 CHAIRMAN WOLFE: Yes, Ms. Wcodhead, wrere are 7 you going with this question, or questioning?

8 MS. WOODEEAD: Mr. Engmann has stated that he g did not consider exposure fires in his fire prott:ction design g considerations for the cable spreading room becatse he did not yg consider this to be a reasonable possibility, and I would like to point out that the occurrence at Browns Ferry began at 12 precisely the place he is stating that we needn't look at 13 g such a fire.

15 the question.

MR. GALLO: Mr. Chairman, now that cot.nsel has

" * * "I' * #

18 that if the answers to those questions are for the purposes g

of corroborative comparison to the Black Fox spreading room, then there is no foundation of similarity between the spreading room configuration and design with the spreading v

i 23 room at Black Fox; and until that foundation is laid, the questioning is improper.

.s 25

'l I

ar5 6858 I MS. WOODHEAD: The question- has not bilen related I ,

2 to the configuration of the cable spreading roonti. 'The 3 issue here is exposure versus electrical fires aa a design 3.: . 4 basis.

5 CHAIRMAN WOLFE: Objection overruled.

S

• MS. WOODHEAD: Would you like the question read?

7 WITNESS ENGMANN: Read the question.

8 CHAIRMAN WOLF 3: Read it back, Ms. Reporter, please .

9 (The reporter read the record as requested.)

10 WITNESS ~ENGMANN

I am trying to clari.fy the 11 point. There was a wall that was common between the cable 12 spreading area and the reactor building. There was a

. 13 sealant placed in a penetration through that wal!..

~

14 That sealant, by the way, turned out unfortunately 15 to be a source of combustibles. It was ignited by a candle.

16 Those combustibles burned and subsequently it appears started 17 a fire in the cable tray.

18 The Black Fox Station, we don't intend to use 19 that type of sealant, is therefore not a source of combustibles.

t 20 BY MS. WOODHEAD:

21 Q That is not responsive. My question is really 22 to relate what happened at Browns Ferry to the design criteria

) 23 for fire protection, and my question, I still put to you, is 24 where was the workman standing who had the candle, who N 25 started the fire at Browns Ferry?

.. J l

.._ __._._ _ ._..~.- _ ._ __._ _ _._ _ -._._.~._ _.___

ar6 6859 MR. GALLO: Mr. Chairman, I am going to object 3

2 again. I thought there was supposed to be some tie to a i

desigil basis applicable to Black Fox. I now find that we are '

3 p tal. king about the design basis for the Browns Ferry plant 4

based on counsel's last question. That' certainly has no 5

relevance to this proceeding, and I object that it is irrelevant.

6 In addition, where the man was standing is not 7

particularly pertinent, either.

MS. WOODEFAD: If I said design basis at Browns Ferry, I misspoke. I did not intend to say that. Design

,0 4

basis for fire protection programs is the correct subject matter here, not Browns Ferry, MR. GALLO: I have .to object again. The design 13

~

basis for the fire protection program has not been established on this record. Once that is, whether or not Black Fox 15 complies with it, is a proper line of questioning. We have just spent 10 minutes trying to straighten cut the reg.

17 guides and the Branch Technical positions.

18 The question is vague and without fourdation.

19 In addition, the witness has answered the question 20 three times, that the fire began in the commen we.11 between 21 two rooms. I think it has been asked and answered with 22 3 finality.

~ 23 (Board conferring.)

24 CHAIRMAN WOLFE Objectiort is overrulad.. We will 25 hear the answer.

l Or7 6860 I WITNESS ENGMANN: Could you read the question?

2 (The reporter read the record as requasted.)

3 WITNESS ENGMANN: As I understand, the workman

.m 4 with the lighted' candle was in the area designated as the

_)

5 cable spreading area at Browns 7erry.

6 BY MS. WCODHEAD:

7 Q Thank you, Mr. Engmann.

and 17 8 9

10 11 12 S 13 J

14 15 16 17 18 19 i

l 20 l 21 l

22 m

V 23 24 .

.b 25

+. -r.- r w. - - , - . - r- --ver.,e,- w.,,e1n-g-,. .e.,e e, - -.,.ym.- +n . , - - c --

..c-nw- ., >..e,uw, ,.n,<v a,-ei.-.y,e, , ,..re..., y

l 6861 I

s tapa 18 (Pause.) l 2

'_ david 1 Q Will the fire protection for Black Fox station 1

3 use exposure or electrical fire as its design' basic 1 m

4 criteria?

5 A (Witness Engmann) What we have done in the i 6 fire hazard analysis is identify all of the combustible materials that we could in the cable spreading recm new 3 permanently installed and transient materials based 9 on our current design of cabla constructions, firestops, to and any other equipment that we intended to install.

11 That analysis indicated there was no ecmbustible 12 material in that cable spreading room other than the 13 cable insulation material and possibly the firestop 14 material itself.

15 And we identified that as combustible :naterial.

16 It was natural to assume that the only way one could 17 ignite that is be getting energy in there on the conductors 18 themselves.

19 And so we postulated an electrically initiated 20 fire.

21 Q Well, it is clear from your answer that the i

22 cable spreading room design fire is electrical, but my 3

V question was the entire plant.

23 24 Is this true throughout the plant that you 25 have used an electrical fire as your design basia criteria?

Ii 6862 david 2  ; A I think what we have done in the fire l l l .

2! hazard analysis in each a ea is identify the combustiblec  ! l l '  !

3j present and the energy sources present in those nreac.  !  !

! l l

'S

' 4[d If there are energy sources other than electrica:.ly or j

, 1 3l electrical conductors, I think we have identified those not l l

! 1 5 as exposure fires, but as potential sources of onergy 7 that could raise the temperature to provide the prcpor  ;

i 3 BTU input to set or spread a fire.  ! I l

9 Q Is it your ans'wer -- is it'ccrrect the.t ycur  ;

1 1

10 answer is that the fire protection program for 3rc'.ms 11 Ferry will consider electrical fires -- excuse me. Not 12.

Er was Ferry - Black Fox station will conside electrical la.

fires in some areas and in other areas exposure fires?

3

.)

14 MR. GALLO: Mr. Chairman, refarence rtport 16, the fire hazards analysis report, was synsored by Dr. Cc=,

15 and it was prepared under his supervision and direction, 16 g and perhaps those kinds of questions are best directed to g Dr. Cox.

gg MS. WOODEEAD I would be glad to let the 20 witness decide who is the better qualified to antwer that. I' 21 WITNESS ENGMANN: In areas outside of the

]- 23 cable spreading room, I participated vrary little in the preparation of the fire hazard analysis. I only

, _J. participated to the extent of previding input abcut 25 t

6863 david 3 1 electrical equipment, cabling and wiring in those

~ 2 areas.

3 I believe Dr. Cox is a better witness to n

4 respond to that question.

5 3Y MS. WOODHEAD:

6 Q I would like to hold questics for Dr. Cox 7 for a moment, and I will just repeat your previous 8 testimony.

9 I would ask you if I am correct in saying that to the fire, the only fire that was considered in the fire 11 protection system for the cable spreading rooms vas 12 electrical fire.

S 13 A That was the only way we could see a fire 14 starting, yes.

15 Q Thank you.

16 On pages 7 and 8, beginning at the bottom of 7 17 and going to 8, you discuss the fact that air ficw through 18 the cable trays can propagate a fire more rapidly, and gg that the safest configuration is to have tightly stacked 20 cables.

21 Who has the responsibility for enforet.ng 22 cable installation criteria in the construction of a 23 reactor?

24 A on a power generating station, the conctmetion d 25 specifications will tell the contractor hcw he must

6864

._ david 4 1' install ccbin and tray. The enforcement of thoso I

2 specificatiol at Black Fo:: station I assume wil.'. be done 3 as part of the client's quality assurance progran.

m 4 O Do you happen to know if this is indeed part .

5 of the O/A criteria? 1 6 A I don't know whether it is or not, whether 7 they are going to enforce this particular section of

}

3 this specification. I do knew that as standard niack 9 and Veach construction specifications, these would bc l

10 included with the Black Fox station.

11 Q On page 8 you stato that -- on page U of 12 your testimony you state that in the Sandia July '77 13 fire test it was unknown whether the redundant division

~

14 cables burned.

15 Isn't it true that the etailable data 16 indicate that they did burn, and that indeed the Sandia 37 report says that?

18 A As I read the report, the evidence of burning --

19 and I assume here burning means that chemical process by 20 which some materials can burn into energy -- was limited 21 to temperature sensors inta11ed in or around the upper 22 cable tray.

23 There is a correlation, as I understand from 24 reading.that report, frcm a temperature of a cable

-*) 25 construction and the phenomenon known as burning or flaming, t _ , _ _ _ _ _ ___

6865 1

- davids- material being consumed and releasing energy.

2

, However, I don't know that it establiahes in }

3 I

, that report or anywhere else that there is an ac:ual I 4

physical law that relates temperature to a ecmbuntion 5 4 process. I think a much more positive indication would I, 6 j have been the one that they were attempting, and that >

7 is visual inspection during the test or experiment.

8 Q Do you happen to recall the chapter that was 9

recorded at -- the temperature recorded from thone 10 upper trays.

11 A I think it was 600 or 700 degrees fahrenheit.

12 Q And what is the normal temperature fo::

combustion?

14 A Speaking from memory and what they say in 15 the report is that they have observed ocrrelation between 16 a temperature of 600 and 700 degrees fahrenheit and

' observed combustion. '

1 18 cnd 18 l l

wal fis.

20 l 21 22

~

s.

24 m

i

)

- 25 1

9/EL 6865 wel 1 1 Q So that there's some evidence, although it may not 2 be direct evidence, that these upper trays were?

3 A I agree.

^ l Is.it your testimony or your belief thac IEEE 303

+

4 Q l and 384 alone are sufficient to satisfy Criterion 37 I 5

6 A I think insofar as they address, or inssfar as .

Criterion 3 addresses, design of the cable construction and 7 f I

g the design of the raceway installation at a power couse, I -

g believe that they are adequate. ,

All'right. I 10 Q g; In the Sandia tests of July, 1977 again, isn't it 12 true that all but three of the fourteen cable trays simulating 13 one division burned?

~'

34, A I'm speaking from memory. There were fourteen trays in an array of two stacks of seven. And speaking from 15 16 memory of the upon, ce lower ene uays in de stack 6 l

1 4

which - the stack which was different from the stack in 37 which the tray ignition was started, those three trays  ;

18 I

contained cable that was undamaged by the fire.

39 Q of what significance is that?

20 A Well, to me it says that even those trays that 21 were only eight inches away from the ignition tray, and the 22

)* 23 trays stacked vertically above them, those cables still r ==ined functional, even in that experiment.

24 I

I

] g Q But isn't it true that fire propagates vertically t

.. 1

wal 2 6867 1 rather than horizontally?

2 A That's why I indicated here that I think that ,

3 perhaps the horizontal separation distancee specified in

.s' 4 IEEE 384 are adequate, and perhaps even conservative.

5 0 Is the answer to my question yes?

6 My question was: Isn't it true that fire propagates 1

7 primarily vertically? l 8 A It certainly propagates vertically, yes.

9 Q Wouldn't you characterize the results of the Sandia 10 tests of July of 1977 as total danage as far as having a 11 functioning division?

12 A In the particular configuration in which they 13 conducted the experiment, I think there's r.o doubt that the 14 fourteen trays that they identified or were correlating with 15 a single safety division, were largely damaged. The only 16 exception were the three lower trays that were adjacent to 17 the ignition tray.

la Q Are you aware of what separation criterion was i 19 used at Browns Ferry?

20 A No, I'm not.

21 Q Could you describe the difference between the 22 cable spreading room at Brcwns Ferry and that at Black Fox 23 Station?

24 A No, I could not.

25 MR. GALLO: Objection.

il 1 6868 l 4

wel 3 1 CHAIRMAN WOLFE: The answer was already in.

2 Objection overruled.

3 MR. GALLO: Mr. Chairman, I mcVe that the answer I

4 be stricken and that my objection as to irrelevancy be I

5 sustained. l 6 CHAIRMAN WOLFE: Objection overruled.

7 BY MS. WOODHEAD:

Mr. Engmann, isn't it possible for exposure fires  !

S Q 9 to occur in cable spreading rooms from such things as storage  :

10 of transient flamables? j 11 MR. GALLO: I object to that. There's no 12 foundation that cable spreading rooms are generic in nature, 13 so that whatever cable spreading room you're talking about can 1.; be generalized. In fact, my information is that it's just l'5 the opposite.

16 So.I object to lack of foundation for that question.

17 MS. WOODHEAD: I don't believe my questd.on was 1g based on any sort of generic idea of cable spreading rooms. ,

gg CHAIRMN WOLFE: Would you read the quention back?

20 (Whereupon, the Reporter read from the record, as i L

21 requested.)

i 22 MR. GALLO: Mr. Chairman, the question naid cable l 23 spreading rooms, without any indication of where.

24 CHAIRMAN WOLFE: Do you want to particularize that,

) 25 Ms. Woodhead?

I

I 6869 wel 4 1 MS. WOODHEAD: I suppose I could particularize it 2 by saying: Is it possible that a fire could occur in a cable ,

i 3 spreading room in the event that flammables were suored there  !

I s i 4 temporarily for some purpose at the place where the flammable 5 is stored?

6 MR. GALLO: If the question now is predicated on 7 the proposition that flammable material is stored in the ,

8 spreading room, I have no objection to that question.

9 WITNESS ENGMANN: If there arc flammablos present 10 inthecablespreadingroom,otherthanecmbustiblomaterialofl; i

I 11 the cable insulation jacketing itscif, I think it's possible 12 that there could be ignition source for those flammables.

13 MS. WOODEEAD: Thank you.

14 BY MS. WOODHZAD:

15 Q All right. Mr. Cox - Dr. Cox - excuse me - on  ;

16 page 5 of your testimony you stated that you have obtained a 17 compilation of all fire-related incidents reported to the 1 18 NRC since 1969.

19 Could you give a brief description of the extent of I

i 20 the damage common from those fires? I'm talking a'mut the  !

21 average fire and the average amount of damage.

22 A (Witness Cox) From my review, I recall most of the d fires as being very insignificant.

l

-' 23 24 of course, of outstanding significance was the 3 25 fire at Browns Ferry.

4 wel 5 6870 1

1 But to determine an order of magnitude of signifi-  :

l 2 lcanceisdifficulttodo,butcertainlynotacriticalfire,  !

I I s ,

3 or a fire of major concern.  ;

- i 4 Q Would it be correct to say that in mest casos the {

5 extent of damage was very small?

6 A Yes.  !

l 7 Q And perhaps in some cases none at all?

4 l

s 8 A Yes, that's right.

f 9 Q To the best of your knowledge, can you tell me 10 whether the fire protection program for Black Fox !3tation 11 complies with all the guidelines of Appendix A to Branch i

12 TechnicA1. Position 951? 1 13 A Yes, I can. We have addressed Branch Technical 14 Pcsition A point by point, and there are instan'ces in our I

15 '

response that we have taken an alternative positio:2, rather  ;

1 16' than Appendix A. l l

17 Q Have. you justified the alternative in your submittal?

18 A We have stated our position. We have discussed in 19- Fire Hazards Analysis a discussion of that particular area.

20 -It does not. not necessarily direct itself to a ju:stification.-

21. O All right.

22> Now, I'd like to ask you whether or not exposure

) 23 '. fires have been considered in every area of the plant for

24. the Black. Fox fire protection program, excluding the cable

) 25; spreading rocm which we know about from Mr. Engmann?

J

I wel 6 6871 1 A In Fire Hazards Analysis we hr.ve not specifically 2 identified what started the fire. We've assumed that a fire 3 occurs.

.' 4 For those areas in which we have combustibles or 5 transient materials stored, we would certainly assume an 6 exposure fire.

7 We've done our analysis, and while not specifically 8 so stated as to the source of the fire, we have - well, I'm 9 going back to cable spreading room.

10 The answer to your question is yes, where there are 11 exposure fires at other areas of the plant.

12 Q I'm sorry, Dr. Cox. My question was: In all areas N 13 except the cable spreading room have you used exposure fires a

14 as your design criteria?

15 A We have not postulated the fire as an exposure 16 fire, as opposed to an electrical fire, in all areas.

17 We assume a fire there, not necessarily postulating 18 how it started, in order to arrive at the design basis fire.

1g Perhaps we need to get on a little bit more 20 familiar ground as to what we consider the design basis fire, 21 and the design basis fire as we defined it for purposes of 22 the fire hazards analysis, is that fire which can cause the l

.3 23 most damage. And in most cases we considered that all of the 24 combustibles in ttat particular area are consumed, are burned.

) 25 And that's the heat output, that's the design basis fire.

r 6872 wal 7 1 Now, as far as the source of that design basis fire, Z we don't address that in Fire Hazards Analysis.

t 3 MR. SHON: tis. Woodhead, could I interrupt for one 4 point of clarification from Dr. Cox?

l 3L When you say that in a given area you consider that I <

t 8 all combustibles in the area are consuming to give an 7 exposure fire - if it's an exposure fire -- I think that's D what you said.

I 9 WITNESS COX: In an exposure fire situation we 10 would make that assumption, yes. ,

11 MR. SHON: All combustibles could in sone sense be i

12 rather a variable term. There are things that are stored I

~ 13 there, things that are brought in and out, and indeed there 14 may sometimes be things there that you didn't expect at the 15 design stage would be there.

16 For example, to use our bad example again of 17 Browns Ferry, neither the candle nor the sealing material that '

t 18 were involved in creating that exposure fire - if you call 19 it that - were azthorised to be there, or were the kinds of 20 things that the designer expected to be there.

21 j Bave you taken any account of the possibility that 22 there might be things in an area that don't show on the l

] -' 23 design plans?

1 24 WITNESS COX: Yes, we have taken that into 25 consideration. And in some cases it8 s taken '"to consideration-l N'

i i

ti873 I wel 8 I i

I as a miscellaneous item that was added.  !

2 I mean we can't predict what or when, so we addsd 3 some miscellaneous heat input into some areas based upon the c

4 possibility of a transient. In some areas we knew we were l

t 5 going to have a transient, end we included that i.1 the  !

4 l

6 analysis.

l 7 We can't predict what it's going to be, so we have  !

S introduced a transient in those areas where we hava analyzed l 9 the likelihood of a transient occurring.

4 10 MR. SHON: Thanic you.

11 BY MR. WOODHZAD:

12 Q Dr. Cox, could you give me some idea of what

- 13 percent of the plant where there are safety-relatel areas do

~

1 14 not use exposure fire?

l 15 A (Witness cox) Do not use exposure fire?

16 0 Yes, as a criterion, or have not considtred that 17 as a source of fire.

18 A I would say 10 percent - 5 to 10 perce.it.

! ~

j, 19 Q Between 5 and 10 percent you assume tha: it would l

20 probably be an electrical fire as the source?

l i 21 A Yes.

22 Q All right. Have you visited some opera:.ing reactor 23 plants?

24 A I have visited one. operating power reac:.or. I've

_) 25 been associated with nuclear plants for some years.

_ _ _ , _ . _ . . _ , _ _ _ _ _ . . . , . _ . . _ . . ~ . . . _ , . . . ~ . _ . , . . . _ _ . . _ . - . , _ . , _ _ . _ . . _ . . _ _ _ _ . . . , . . - . .

i 6874

+

wel 9 i MR. GALLO: We can't hear you,'Mr. Witness.

s 2 WITNESS CCX: I'm sorry, should I' repeat the

~

3 answer?

-s

4 MS. WOODHEAD: No, I could hear you.

5 CHAIRMAN WOLFE: Would you read the answer back, 6 please, for Mr. Gallo?

7 (Whereupon, the Reporter read from the record, as 8 requested.) i 1

9 BY MS. WOODHEAD:

10' Q Dr. Cox, do you think it's possible that some 11 welding will be done in the cable spreading room during the 12 40-year life of the plant?

s 13 A (Witness Cox) Yes, I do.

J 14 Q Do you think it's possible that such f:. namable 15 liquids as lubricating oil or acetone, paint solvents - liquids 16- of this sort - could be stored temporarily in thu cable 17 spreading room?

15 A I think it's possible. I think in this particular I

19; case - and I considered Black Fox Station in our analysis

20. in arriving at this decision -- that this was a case, and not 21 a generic station where we considered the likelihood at Black 22' Fox Station.

23 And while I'll have to acknowledge the possibility, 24 I feel in my own mind that the possibility is very, very

., j 3 25 remote.

6875 wal 10 I O Why is that?

2 A Well, I believe it goes primarily to the fact that, 3 number one, we haven't identified any ccmbustibles in the j n

', )

4 material -- I've got a thought process lined out here, I

5 because I kind of figured this was coming, so I'll have to I 6 go through my complete thought process.

7 What I want to establish, (1), is that we have no 8 combustibles planned or designed to be stored in the cable 9 spreading room, other than the cable insulation ituelf. And 10 the cable insulation is not only in the cable sprending room, t1 but we do have to consider that the inverter rooms are in 12 there also.

13 Another item that I considered is the fact that 14 the cable spreading room in this particular instant:e is in an 15 area that is not commonly trafficked by either ope: ators 16 anyone else. It's going to - it will take a spec:.a1 17 purpose in order to get into this room.

18 Not only does it take a special purpose to get 19 into this room, but the door is locked. The cable spreading 20 area - and I don't know how it was at Browns Ferrir, but at 21 Black Fox Station the. cable spreading area is a viu,1 area.

22 This means that the door is locked. It's a door that requires 7)

- 23 particular and special controls in order to enter, and it 24 not only requires that a person be authorized to go in there

) 25 generally, but that he be authorized to go there under specific

6876 I

wol 11 1 conditions.

2 That,'in my mind, with the tight controls on the l 4

3 '

room, preclude what would normally be associated with finding .

I 4! a can of oil, because there's no reason to believe that a l l

i 5 person would takei a can of oil into a cable spreading room. i l l 6 There is no reason to use a can of oil on. cable. j i l

7 So in my mind we disregard a person going into  !

S this area for other than a very spcial reason, and even under i

9' '

the special reason he has to be very tightly controlled throughi i

! I a security system.

16 [ l 11 If we assume that there are conditions under -

1Z maintenance conditions, for instance, the PSO has adopted f i

13 procedures which provide for a fire watch. And I can't in 14 '

my mind justify anyone in a cable spreading room widing or 15 burning with the reactor operating. It has to be imder a 16 shutdown conditien or other maintenance condition.

17 So there will be a special procedure for a fire 18 watch.

19 Now, I think all of those things taken .ogether, 2D in my mind, would make this particular area one where we wouldn't I

21 anticipate a source, at least probably small enough in my l l

22 mind that we wouldn't make it a source. l

, 8 l

'\

_Jarb fis 2$ l 24  :

1 25 I

l 1

J

BW20 arl 6877 Q Are you familiar with a special enforcement rep rt from the Commission which reported that one of the 2

plants under our supervision which had very strict administrad l 3

j tive controls similar in some respects to what you described, 4

5 MR. GALLO: Objection. The question is so vague it is unintelligible. Counsel, if she has a particular report in mind, should identify it and ask the witness with respect to it.

MS. WCODHEAD: I would like to withdraw the questier).

BY MS. WOODHEAD:

11 Q Do you think it is possible that there would be painting dcne in the cable spreading room while the reactor

> is'in operation?

A (Witness Cox)- No.

15 0 Do you think painting would be likely to be done while it is in outage, shut down for some reason?

17 A Yes.

18 MS. WCODREAD: I move that the Applicant be required 19 to consider exposure fires as the basis for his fire 20 protection program, consistent with Appendix A to the Branch 21 Technical Position 9.5-1, to satisfy criterion 3 of Appendix 22 q A, 10 CFR Part 50, and that the Black Fox fire analysis

v 23 he revised to reflect this. basis.

24 3 I also move that the Applicant make commitment

) 25 to meet all NRC fire protection guidelines as interpreted

i E

6878 er2 l

1{:

by the Staff. l 1

2b I have no further questions.  !

3, MR. FARRIS: Mr. Chairman, I would join that -

4 motion and add to it that if the Applicant doesn't, I would i

I 5 move that the construction permit be denied.

S MR. GALLO: Mr. Chairman, it is a strange I p 1 7 procedure with having two motions on the table. I wonder 6 about that. l 9 (Board conferring.)

10 CHAIRMAN WOLFE: We see no problem with joint 11 motions.

12 Howevem we haven't completed our review of this ,

s 13 aspect, and we '#Lil proceed and give consideration to the i

14 !- motion at a subsequent time, j i

Eave you finished, Ms. Woodhead? '

15 16 MS. WCCDHEAD: Yes. I have no further questions.

17 2. GALLO: Mr. Chairman, I hope that my further 33 silence is not construed as acquiescence in the motion. I 19 find the motion' so novel that I would consider and try to 20 remember what was stated in the motion;if the Board seriously 21 is going to consider this, I suggest that counsel submit it i l

22 in writing, providing the bases that such motion should have, i

S O 23 so that it can be responded to in proper fashion.

j 24 As I recall, Staff counsel for the NRC Staff 25 at the last meetings in October, at the last hearings in l

ar3 6879 l

1 October, joined with councel for the Applicants in chiding l l

2 counsel for the Intervenors for oral motions. l 3

It seems to me that a motion of this r:agnitude  !

I 4 and importance should be filed in writing and properly l 5

supported ard the normal response time given, and then we can l l

6 go from there.

MS. WOODHEAD: I have no objection to submitting 7

it in writing. I think it is fairly simple, though.

8 MR. SHON: Ms. Woodhead, I in particur.ar, and I 9

think the other Board members, still have some citestions in to 3;

our m4nds about just what you are proposing.

Y u have said that you proposed to mal:e an 12 g exposure fire the design basis fire for all places in the g plant; but an egesure fire is in some sense a variable l

thing.

15 We have been told Where an exposure fire has been used as the design basis, the exposure fire has, for 17 example, considered burning of all combustible materials presumably over some period of time. Obviously :here are many different kinds of exposure fires ranging. f: rom a l 20 j candle, a few Btus per day or something te < ,et of l 21 holocaust like an airplane tank, JP-4, 22

.7 _

What specific si=os of exposure fires would you

- 23 propose,.for example, for places where there is no combustiblo 24 S material generally expected, where the combustible material

/ 25 would be brought vna.y, say, by a violation of the rules?

I J

, , , r .m a

r 6880 ar4 1

1 How does one determine the size of an exposure i

~

l 2 fire for an arbitrary fire with no definition of materials i i  ;

~

3 present? i h 4 .MS. WOODHEAD: I understand the Staff's pcsition f t

5 to be that they have not defined an exposure fire in terms  !

i 6 of heat, but rather as the worst case, the worst source, becau,se 7 as you recall, when Mr. Engmann was explaining the Sandia l

8 test, th'e electrical fires in the cable trays were of much 1

9 less signficance to the entire safety division than the ,

10 exposure fires.

11 So to that extent the exposure fire in potentially I 12 the more serious fire, although as an absolute it would not '

l 3

13 necessarily be true. l l

14 MR. SHON: h t exposure fire, at least the l l

15 Sandia test, was a very specific fire and involving burning i

16 at certain Btu for certain lengths of time. Would you use j 17 that arbitrarily or would you use some other ones? Would 18 you use the IEEE 383 70,000 Btu per hour fire? 17 hat tmuld 19 you use as a basis? That is all I am asking.

20 MS. WOODHEAD: Just a moment. l l

21 (Pause.)

22 The Staff believes that the source of the fire 23 is not as important as the fact that it should be assumed l

24 that all combustibles burn; that if you have an exposure

) 25 fire, you have something there that is flammable other than --

6881 arS.

1 that would create an exposure fire, and it is that 2 philosophy in designing the plant according to ar. e::posura

~

3 4 fire criteria that is behind this Staff guidance, rather j

4 than the idea of having a certain amount of heat as your j i

3 source. l l

6 MR. SHON: But we are confronted -- perhaps I 7 haven't made myself clear, by some situations, few in number,j i

a which Dr. Cox aays represent areas where there would be i 3 essentially no ccmbustible material present under normal to circumstances.

11 What does one use for an e::posure fire there?

12 Obviously if all that combustible matarial burns, you S 13 wouldn't have any fire, so what do you use? You uust have 14 something arbitrary. What would you use then?

end 2015 16 17 18 19 20 21 l

22

_: D 24

/ 25

6882 1 MS. WOODHI:AD: That is what I was getting in in

- 2 my previous question about the transient flammables

~

typn 21 3 or a candle. It is that kind of thing. In the cabic f

.m avid 1 4 spreading room certainly there is something that should 5 be stored there, and administrative controls are aimed I 6 at keeping anything flammable out of the cable spreading 7 room.

8 And if all of the plants were properly -- an g electrical' fire would be the most you would ever expect.

10 The staff believes that you should expect the worst and it design for the worst for defense in-depth philosophy, and 12 you must expect that administrative controls will on l

me occasions not be called, .and there will be.. .

13

) combustibles and/or serious -- or easily flammable things 14 15 in areas where you wouldn't anticipate.

MR. SHON: But how much? In other words, what 16 do you use as a standard fire in a place where you 37 18 normally expect no combustibles?

19 Do you see that you neod that number, that data in order to make a prediction?

20 MS WOODHEAD: You mean the heat, the amount 21 22 of heat nueds to be defined?

h g MR. SHON: Yes. In othov words, if all that was y assumed at Erowns Ferry was one candle, that wouldn't have

[) happened. It took other material, other unauthorized 3

u l

6883 i.

1

avid 2  ! material. I l

2 Ecw much unauthorized material and of what I 3 l nature would you, for example, is in the cable spreading )

~

4 1 room? A can of paint? 100 gallens of acetene? Tnat?

5 1 Until we have some idea of that, I think the 6

board has no clear idea of what you are asking for, 7 (

nor I believe would the applicant. (*

8 Is that correct?

9 ..

WITNESS ENGMANN: That's right.

10 WITNESS COX: Yes.

11 MR. FARRIS : I think the problem we are having 12 here indicates to us that we need some more work in T 13

/ this area by the applicant, Black and Veach, and the staff 14 to come up with some criteria against which the design 15 can be evaluated. .

16 I see your point. We have to establish some 17 heat source and the amount of that heat for an exposure 18 flame, we all agree or seem to agree that exposure fires 19 should be considered, and I think that the motion should to .

be directed to the parties to make some proposals in that 21 regard in order for you to be able to make an intelligent 22

- evaluation or to be able to determine if it has been

) 2a[ adequately designed for those possibilities.

24

. MR. GALLO: Mr. Chairman?

25 MR. SHON: This seems a good approach to me, at a

l 6884 I least, and I think to the other members of the board. We ,

2 would like to have things in writing.

~

3 MR. GALLO: Mr. Chairman?

n.

4 CHAIRMAN WOLFE: Yes? ,

5 MR. GALLO: I find the suggestion a good on2.

6 Staff has made auch an analysis - I'm sorry. The 7 applicant has made such an analysis and has established 8 criteria that are set forth in reference report 16;that's 9 the fire hazards analysis construction permit stage report.

10 You look to Appendix A, there is a section 11 by section listing of the fire areas and the fira zones 12 within the Black Fox station, based on the Blach Fox

^ . 13 station design within each zone and each area. .

14 The combustibis that are to be anticipated, 15 both transient and normal ccabustibics, they are identified.

16 So the analysis that Mr. Farris is asking for has been 17 made by the applicant.

18 The staff has had this document for ell over 19 a year. Their review has been partially completed, as

20. ' I understand. They are going to continue to review further 21 in what I suppose here to be the post-CP stage.

21. If there is any criteria for design basis 3

d 23 fires, that rests with the NRC. Either they promulgate the 24 criteria as a regulation or as a regulatory guide or a 25 branch technical position.

6385 l

l 1

david 4 1 Ms. Woodhead's problem is that no such critaria j 2l exist in a regulation or a branch technical position or a  !

3 reg guide. That is the reason why if they ever file a j j 4 motion in writing, that is the legal basis for denying 5 the motion. 4 6 (Board conferring.)

7 CHAIRMAN WOLFE: As I indicated before, we 3 will proceed to hear the balance of the testimony on 9 contentions seven, eight, and nine. Uponhearing that 10 evidence, the board will make a determination whether 11 it will act on the oral motion or indeed will, as sugget:ed 12 by applicant, request that the motion be submitted in

~- c writing.

14 At this point we have it before us, and we ,

15 will decide what we are going to do, as I said at 16 the close of the proof-on contentions seven,. eight, and 37 nine.

18 All right.

19 MR. GAIJ.,0: Mr. @miman, I suggest a short

~

20 recess.

21

' CHAIRMAN WOL7E: We are only going until

. 1 22 5:00 o' clock this evening. We have 20 more minutes.

.l MR. GALLO: All right.

23f 1 24 , CHAIRMAN WOLFE: You had completed your 1

-) 25 cross, Ms. Woodhead?

i 1

l

^

l.

6885 da.vid5 1 MS. WOODHEAD: Yes, I have. Thank you.

._ 2: CHAIRMTdi WOLFE: Mr. Farris?

3 MR. FAIURIS: Mr. Chairman, I considered 4 waiving the cross examination of Mr. Engmann -- and I 5 mean that as a compliment on Ms. Wcodhead's thorough 6 job. However, I do have a couple of questions still.

7 BY MR. FARRIS:

s Q Mr. Engmann, have ycu had any experience in g the fire protection area?

3o A (Uitness Engmann) I am an electrical engineer and designer. The design of the electrical facilities 33 12 that I Have participated in have taken into acccunt the

, fire protection criteria. I am not a specialist or 33 an expert in setting. fire protection criteria.

14 Q W uld y u say that any electrical engineer has 15 some experdse in the area of fire protection and 16 fire prevention as far as electrical systems are involved?

37 A I would expect so.

, 18

~

39 Q In your previous experience with the fossil

! fuel and coal-fired generating stations, did you have 20 21 any specific resp nsibilitias as far as fire protection g I design was concerned?

3 WE incorporated in the design of the various

_/ A g

electrical systems featuras that were intended to provide

) a degree of fire protection: redundant cable trays , tha

6l i I

]l 5887 !

t 4

~ avid 5 placement of acuipnent was such that we fait radundant f 2' l equipment could not be destroyed by some fire.

a ,

, 0 on page two of your testimony, ycu talk abeu: l 4  !

~

the Black and Veach scope of design; do you knew uhat  !

5 l percentage of the overall cabling for Black Fox station .

6 I would be within Black and Veach's scope of design?

7  ;

A All of the cabling that will be installed in j 8

the field to connect devices outside of the ?GCC as j 9  :

i within the B L V secpe of design.  !

10 {

Q Do you know what percent that is, the overall .

I 11 cabling within --

l 12 i A overall, ther e is a lot of cabling and s 13 wiring on the site. There is a lot that is internal to

~s 1 14 equipment that is factory installed. Cf the field ,

1 installed equipment or field installed cabling and wiring, 16 the only exception will be the PGCC, and that is a small 17 percentage of the cabling that will be fiela igstalled.

18 and 21 19 20 11 21 Tis ,

1

~' bh l 24  !

\

T

) 25 l l

1

. l 1

1

I BW22 arl 6083 1 Q Will Black & Veatch be responsible for installing 2 any cabling within the PGCC itself? ,

3 A We will not be responsible for installing any 4 cabling. We will be responsible for designing the cabling 5 and raceway outside the PGCC. Designing inside the PGCC 6 is strictly the nuclear energy divisionb responsibility.

7 0 Your responsibility, in other words, stops at 8 the termination cabinets?

g A As the design is currently defined, yes, sir.

10 0 Will Black & Veatch - were you here earlier  ;

11 today for the testi:nony of Mr. Gang and Mr. Johnson?

12 A Yes, I was.

s 13 Q Will Black & vaatch utilize a similar semi-s ,

4 permanent fire stops in the spaces between conduits and g3 raceways?

16 A No, we are not using the same kind of design that was described for the PGCC floor ducts?

37 Q Can you describe the type of cable and conduit?

18 jg A If you were asking about the fire stop design, 20 we have a design at this point in time which is consisting primarily of silic ne f am material that will be installed 21 at penetrations - floor and wall penetrations.

22

) g Q vertical and -

g A vertical anci horizontally, yes.

Q D y u have a generic nama for the silicone foam?

25 I

or2 6889 l 1 A I know that one of the vendors of this foam is i

2 i, Dow Corning. .I 1

t '

3 Q ,Does this sealant meet any IEEE standards that you '

4 are aware of?  :

1 5 A That particular material has been tested in various 6 configurations in accordance with tests that are prezuigated I 7 by ANI. I am sure that the configuratiens as testod are a very similar to the application that we intend at the Black 9 Fox Station.

10 Q You are not aware of any particular rating 11 capa'ity c that it has in relation to the IEEE tests?

12 A As I ur.derstand the ANI testing requirements,

-., 13 they incorporate ASTM 119, and we are going to design for a 14 three-hour rating that would be tested in acecrdance with j i

15 an ASTM s&=M=ed.

16 Q Can you tell me how that would correspond to the 17 test that you just mentioned with the IEEE 383 test?

18 A The IEEE 383 test is a test to provide assurance 39 that the cable material will not support propagati~on of fire 20 on the raceway; the ASTM 119 test is a test of resistance 21 to, or to stop fire from crossing that area. It is a different 22 type of test.

) 23 Q Both tests involve fire propagation capabilities, y don't they?

) 25 A They both can give'you that kind'of information.

1 l

1,

nr3 G890 1 Q Is the material tested to see whether or not 2 it will propagate fire, the sealant?

Is 3 A The ASTM 119 test dcas.

/] 4 -Q Is it exposed to an open flame in the test?

5 A Yes. i 6 Q At what temperature?

7 A It is a variable ten'perature. I am speaking 8 from memory, but the configuration of the test is such 9 that you start at some ambient and rise to some higher 10 degree temperature. I can't recall what it is.

11 Q Are you familiar with the quick look report 12 'from the '77 tests at Sandia?

s 13 A There was a quick look report published by Sandia, v' giving some of the details of the fire test conducted in 14 15 July of 1977. I have read that report, yes.

16 Q And did you testify earlier that Black a veatch 17 intends to use cross link polyethylene insulation cables 18 for Part of the scope of supply?

• d gg A Plame retardant cross link polyethylene, yes.

20 Q Do you know if the type of cross link polyethylene 21 that you are going to use is any different from the cross 22 link polyethylene that was referenced in the report as the h 23 type which is used to produce the severest flanie in the laboratory?

24 ,

A Are you speaking of the test they conducted in

} 3 l

. . . - . - , , _ . . _ _ . ._, . . , _. . , ._ ~ . ,.. ..,- - , . _ _ . . , . . _ _ . _ _ _ . . _ . _ . . _ _ , _ _ _ _ . . . _ _ _ . - . .

i 68@l j ar4 l 1

1 July of '777 i

2I Q Yes. }

5 t

3l A In the exact materials of construction of 4- materials used on the cables that were burned in that test?

i 5 0 Yes.

i 6 ,

A The actual compound was not used in that report.

7 I can't relate --

Ycu can't say it is different er the same?  !

3 Q s A I can't say anything about it, that is correct, i

10 because I don't know what it was.

11 Q Do you have a copy of that report with you?

12 A I do not.

13 Q You say you have seen the report?

S s .

14 A I have seen it.

1 15 l Q I will show you what purports to be the quick l 16 look report, Sandia Lab, '77, and ask if you can identify thati i 17 as a true and correct copy of the report you have previously )

1 18 seen7 l 19 A From the title sheet it appears to be, yes.  !

l I

20 Q Would you look at page 3 of that report?

l A Yes.  !

21 22 Q And under the division on how to produce the  ;

')

i 23 severest flame in a single tray laboratory in reference l 24 to the type ofinsulation cable that was used, can you tell from looking at that whether or not that is the'same

]) 25

6892 ar5 1

material that B&v used in its scope of supply?

2 MR. GALLO: Excuse me.

(

3

~

I assume part of your question means to disrega: 1

( 4 the note.

5 MR. FARRIS: There is no note. There is a circle 6 around No. 6.

WITNESS ENGMANN: The term used is XL-PE ,. which 7

8 is the usual jargon for cross link polyethylene. Cross s link polyethylene can be compoundad many different ways.

10 It is a fairly esoteric chemical design, chemistry design.

11 The usual way in which you specify cross link polyethylene 12 that is capable of passing the 383 flame test, you call it 13 flame retardant crossing polyethylene. They haven't done 14 that, but I have no reason to assume that they did not 15 compound it in the eame way I would.

16 BY MR. FARRIS:

0 You indicated, Mr. Engmann, that the other' 17 18 insulatica you are going to use under cable -- correct me if jg I mispronounce anything, I will probably sound like a 20 deodorant ecamercial - ethylene propylene rubber 21 chloral sulfate?

A (Witness Engmann) It was flame retardant 22 h g ethylene propylene insulation with chloral sulfinated 24 Polyethylene jacketing.

Does that insulation cable meet IEEE 3837

) 25 0

h  ! I C893 i cr6 i

1i A All of the major vendors of that particular i  :

2kI construction havepassed that construction in accordance t i 3 with IEEE 383.  ;

I ,

4 Q Can you tell me what percent of your cabling l 1

5 will be the ethylene propylene et cetera, et cetera, versus 6 the cross link polynthylene?

l 7 A It will be a smaller percentage. I'm going to only!

O use that on my low voltage and medium voltage single I 9 conductor power cable. The number of circuits up at the l  :

1 i 10 medium and low voltage in proportion to the rest of the circuits 1

11 of the plant, it seems to be somewhat small.

, 12 Q Will cross link polyethylene be greater than 80 13 Percent of the overall cabling provided by Black & Veatch?

14 A If I' had to give a judgment, I would say that ,

i 15 flame retardant cross link polyethylene insulated cabling  !

16 will constitute more than half of the cabling that will be 17 installed at Black Fox.

Cad 22 $g 19 20 21 22 m

v

• y 24

%S

6894 tape 23 1 0 on page 4 of your testimony, you indicata  ;

l david 1 2 that Black Fox cable spreading areas will meet these 3

criteria, and I think you were referring to the criteria I- 4 of IEEE-384, are you not?

A That is correct.

5 0 And that states that the minimum separation )

6 .

/

7 distance between redundant clasc 1-E cable trays shall -

8 be one foot between trays separated horizontally and three feet between trays separated vertically.

9 A Thatis correct.

10 y9 Q Is it your testimony that Black Fox spreading 1

I areas will meet those criteria exactly and no more?

f2 A Those are minimum distances. We will not i 13 94 separate less than those distances. In some cases

" * * #"* )

15 Q s he any aMempt to W to get as f6 close to the minimum as possible in your design?

A No attempt whatsoever.

g Q Isn't a normal function of design to try to 39 get as much as possible in one space?

A That is not normal design criteria, no. We have to install the required amount of cable tray in the cable One of the fortunate aspects of the h spreading room. l Black Fox control building design is that there is more than the usual amount of space available in the cable

}

1 j

i -

)

! 6895 '

1 i

1 ,'

david 2 l 3preading ro:m.

- 2d  !

I I

• find that I hatra typically more roca to l 3I f install the required amount of cable tray than I have

.) f

,, 2[

j- in the past.

5i  ;

i 0 You feel no space constrints at all in i

6i the cable spreading room?

7j A There is always a feeling of constraint, but 1

j;, t 8l l I feel much less on Black Fox than in the past.

9I ,

O Mr. Engmann, do you have the fire hazard analysis with you? .

11 A Yes, we have a copy.

12 Q Would you turn to figure B-407 b 13 s'  ;

A B-40?

• 14 i '

Q Yes. -

i 15

,A Yes, sir.

16 Q Would you look at that figure on the lefthand side, i l

17 l detail A, of a typical tray lineup.

18 A Yes, sir.

19 Q And do you see the measurement there right in 20l the center bottom portion. There is a measurement ?aar .

1( j 21

.' , feet, four . inches, and above that a measurement ene foot t

42

- six inches.

.- )  !

What are the first -- the objects separated by q the one foot six inches?

) 5 ti.

A Cable trays of the same division.

4.

. . . . _ . . ~ . , _ . _ _ - . . ~ . .,.. .., - ,__..,,. ,. . . . _ , . , . _ , . . . - _ . _ . . _ _ _ , , , _ _ . - . _ _ . . . . . _ _ . . _ _ _ . . _ _ . . . _ _ _ .

i 6396 1

' avid 3 0 And new if you will lock at a.':ott a 45 degree

_s 2

(  ;

angle up from that particular measurement, you will see 3

another one foot six inch measurement adjacent to a I~h

~'

4 ,

two foot measurement. 1 l

5 A That is correct.

S Q Can you tell me what two objects are separated 7

by the one foot six inch measurement?

S A The one object is identified as metal channel 9

typical. This is intended to be primarily a man-way 10 access for ease of installation of cable in the tray that 11 is identified.next to it.

12 Q How does this particular tray arrangement, that 13 S is, one ffet six inches, compara to Sandia tests of 14 July '777 15 A These five or six trays identified here will 16 all be the same division cabling at the Black Fox station.

17 The Sandia test in July of '77 stacked seven trays of-18 the same division with, I believe, 10 inch spacing 19

^

between the rails, that is, the bottom of the tray varus 20 the top of the tray.

21 Q On the same figure, Mr. Engmann, if you will 22

-s look over to the -- almost immediately to the right, down

\l] 23 a little bit, of the last figure we were talking about, 24 there is what appears to be the main drawing. There is 3/ 25 a statment, possible firewall (if required) .

l. G397 l 1 i cavid4 1 g

can you tell me il that firavail ..s coins to e .

2[ :

be built at this point? }

3 it A THe configurat:.on or the firewall in the j

.1

- 0 f

l 40 cable spreading area is not that whic5 #" 'ndicated hare. ,

i-  :

5!i THe intent of that firewall was to provide caparatien l 6 beteen redundant and cabling divisions. That firavall is i t I

I 7 .

currently designed for the Black Fo:t station, buc it is  !

II I i 11 i l 3L not a straight down shot, j

!  !, l 9;j In order to provide the firewall between j i

, I

(

• 10l the redundant divisions, we could configura it differently,  ! )

I  !

11 , but we have- met the criteria stated in here to provide i

i 12 the three hour rated firewall between redundant end i 1

13 I safety divisions. l a i 14 Q Eces your change of configuration change 15 anything in the fire hazards analysis?

16 ,! A. Certainly it will require revision of this i

17 !' drawing, if nothing else. ,

, i 13 - 0 Will it require.anything else? ,

i  ;

19 A (Witness Cox) YEs, it does require, because '

2c the floor areas for one thing re changed, so it will 21 require other changes, other than the figure. '

22 However, the current layout, although not i

/ identified as a firewall, is currently in the ?SAR, but 23 i ~

24 i

the firewall is not delineated.

3

,2 23 y, l l l

1 a

I .

I 1 1, l I 1

8W 24 arl 6898 1 0 Dr. Ccx or Mr. Engmann, can you identify for

- 2 me, please, the object that runs through the fire wall i  ;

directly above the object running from left to right, 3

4 direct'ly above the line wo were just speaking of?

(Witness Engmann) You mean the cabic tray, the i 5 A 6 thing identified with elevation 585-4 and 586-10?

7 0 Yes. ,

8 A That is a cable tray.

9 Q And that will penetrate the fire wall?

10 A That is correct.

g; Q And will that be connecting redundant systems?

A No. The tray redundant systems are never 12 s

installed in the same tray.

13 J -

Q Are redundant systems on either side of the 34 proposM fhe wall?

15 A There is a redundant safety division on one 16 side and redundant safety division on the other side of 37 the Hre e ll; that is corre d . Ms pardcular way happen 18 e e e sion '5 M1ance of plant ci m it.

19

. smtas y d M sion tray.

20 Q Does that indicate only one tray, or will there 21 be a series of trays beneath that?

l m

,4 A There are two trays there in elevation.

g g Q Ecw many total trays will cross the " ire wall area 7

')/ A As shown in this drawing currently we have 25

6899 ar2 {

I the topmost rung of trays, there are three of them, and 2 below that there is another for a total of four, and then  ;

n 1 3

four more further on down, for a total of eight trays  !

1 4 penetrating that fire wall. l 5 CHAIRMAN WOLFE: Mr. Farris, we will recess now.

3 I would ask that the parties -- tne schedule, I 7 take it, conter.: plated is to conclude all evidence on 3 contentions 7, 8, and 9 by tomorrow?

3 MR. FARRIS: We don't anticipate any problem 10 with that.

11 , CHAIRMAN WOLFE No problem. -

12 MR. GALLO: Mr. Chairman, I will have some redirectf, 13 and my colleagues might have some cross-examination of Mr.

q v ,

14 l Minor.

I 15 MR. PARRIS: Just to help you so we can tell the 16 Board, we cxpect to be through by the end of tomorrow with 17 both these witnesses and the Staff.

IB CHAIRMAN WOLFE: All right.

19 MS. WCODEEAD: I think that is optimistic, but we 20 can try.

) 21 MR. FARRIS: I'll be through; I don't know about you.

22 CHAIRMAN WOLFE: We will resume the hearing at 23 *:30 in the morning.

24 (Whereupon, at 5 :00 p.m. , the hearing

) 25 was adjourned, to reconuene at 9:30 a.m., Friday, December 8, 1978.)

, . ~ - - , - . , . - . , ,