ML20147D998
| ML20147D998 | |
| Person / Time | |
|---|---|
| Site: | Black Fox |
| Issue date: | 12/12/1978 |
| From: | Purdom P, Shon F, Wolfe S Atomic Safety and Licensing Board Panel |
| To: | |
| References | |
| NUDOCS 7812200320 | |
| Download: ML20147D998 (202) | |
Text
.
"5 PUDLIC DOCUENT R0051 NUCLE AR REGUL ATORY COMMISSION 1
l IN THE MATTER OF: 1
?tD1ic Servico Ccmpany of Oklahcr.c, at al-I (Black Fcx Station, Units 1 and 2) l 1
l
, Docket Mos. 50-556 t 50-557 Tulsa, Oklahcma Place -
13 ~ 'r , ; -
Date - Friday, Docenbar 3, 197G p
'3 -
THIS DOCUt#ENT CONTAINS '
POOR QUALITY PAGES, cry *,- T.i. phon.:
(202)347 3700 ACE - FEDERAL REPORTERS,INC.
OfficialReporters u 781220D330 444 nor,s capitoi s,,..,
Woshington, D.C. 20001 NATIONWIDE COVERAGE . DAILY
1 l
Whitlock:
WEL 6900 ar I UNITED STATES OF AMERICA l
,e 2 NUCLEAR REGULATORY COMMISSION !.,
t 3 ----------------x
'4 In the matter of: : !
f g PUBLIC SERVICE COMPANY OP :
OrJ.AHOMA ASSOCIATED ELECTRIC :
O COOPETATIVE, Inc., and : Docket Nos.
I WESTERN FAPJ4ERS ELECTPJC :
7 COOPERATIVE : 50-556 ;
- 50-557 ;
G (Black Tor Station, Units 1 and 2) :
g - - - - - - - - - - - - - - - - - -y.
i l '. i United States Courthouse
! Courtroom No. 3 ! j 11 333 W. 4th Street '
Tulsa, Oklahome .
12
, Friday, December S, 1978 :
I 15 i
( The hearing in the abov'e5 entitled matter wcs ;
I t. !
reconvened, pursuant to adjournment, at 9:30 a.m. l lE pl ,
j BEFORE:
15 t i SHELDON J. WOLFE, ESO., Chairman,
[ Atomic Safety & Licensing Docrd.
l g g! ,
! l tE r
DR. PisUL W. PURDOM, Member.
i Ic I FREDERICK J. SHON, Member. !
20 APPEART>.NCES :
at (As heretofora noted.)
(. 23 -o0o- f i
1 i 25
.i 1
l
,- i i :
I 1
l
i.
6901 ,'
Gr l
' I 1 COMTENTS !
t 7-2 Witness: Direct Cross _ Redir._ Recr. Scard _
( .
3 (Applicant) ;
e 4 ,
GARY ENGMANN )_ 1
)' 6902 6942 6962 7005 j 5 E. L. COX- ) 7011 (
ll ,
6' (Staff) !
)
7 l ROBERT GIARDINA )
7012 7016 7081 7007 709d e )
JAMES D. BEini ) :
? l 1G l 1 11 i.
12 I
1 ~*
'( Identified: Received:
I t, ,
EXHIBITS: .
I I
- g i Intervonors' 11 - a four-page .
mmo dated Sept. 30, 1977, i 7077 13 igned by Mr. Cohn l i
<m I 1/ '
i I -
ic i
19 ;
I. I t
l 21 ! l i' ;
22 !
( i A.. h[-
1 ,
2A i
( 25 ! j 1 .
.l i
J 1
,,.y-w,- y y -- w. -- v -,e .-e y y -
}
j 6902 :
lWEL i wel 1 l I
1 l _P _R _O _C _E _E _D _I _N _G _S i ;
s 1
f- E CHAIR!GN WOLFE: The hearing is resuraed. l (s ; l 3 Mr. Gallo, will you recall your witnesses?
t, j Whereupon, L
l 5 GARY R. ENGlRNN ,
G and I 7 E. L. COX l !
6 l resumed the stand as witnesses on behalf of the Applicants, C and, having been previously duly sworn, were examined and testified further as follows:
10 [i 11 CROSS *SYJJIINATION (Continued) 12 ,
BY MR. FARRIS:
I ts O Mr. Engmann, yesterday you told me that Black & !
Veatch intends to use cross link polyethylene for something 14 15 ; greater than 50 percent of its scope of supply, is that iGj correct? i
't ,
p ; A (Witness Engmann) I anticipate that the nu aber of ,
13 cables that.would be insulated with cross link polyethylene I
- g would exceed 50 percent. i 20 0 And yoc identified the type of cross link poly- i s ,
21 .I ethylene as fire retardant? i l l
gg ). A That's the usual jargon that's used, or flame f g3 retardant. i 1
l 2,.; j Q Flame retardant. In that usually indicated by ,
i I
gg the initials FR, following XLPE7 t
I !
5 h
l l
,_ _ 7-6903' wel 2 . )
1 A Usually it's PR-ZLPE, flame retardant cross link l '
1 I
g- 2 polyethylene. i e
3 Q Are you familiar, Mr. Engmann, with the Under- ,
- r. !
4 writers Laboratories tests that were conducted at Northbrook,'
5 Illinois on September 27, 28 and 29, 19767 l l
6 A I've read'a report that was issued by UL. I'm 7 not sure that that's the time framo. l l i I B Do you have a copy of that report with you that l Q
D you read?
10 A Yes, I have a report that indicates the develop-11 ment and verification of fire tests for cable systems and )
12 systems components, reports 2 and 3, September 1, 1977 13 through February 1978.
( l 14 Q Do,you have one that indicates tests of September 15 27 through the 29 of 1976?
16 A Of what date?
17 Q September 27, 28 and 29, 1976. :
18 A No, I'm not familiar with those tests. l t
19 0 Were you here yesterday when Mr. Gang and Mr.
20 Johnson were on the stand? l i I
21 A Yes. ,
1 22 Q Mr. Johnson, I believe, produced a document that
(.' was identified as Underwriters Laboratory tests?
t E3 i
24 A I was present yesterday, and I was aware that he' k- , 25 i Lhad a, document. .
i t
L
.In.
i ._ _- _ -. . . , . , . . _ . .
6904 i a !
'wel 3 [ ;
t' O And he used that document to refresh his recci-
! {
- lection about some parts of that test when we were discussing
{~ .
S Tefzel?
- i ;
4 l A I recall that, yes. !
1 <
l ;
5 Q Allright. ;
{
3 6 I Did you see that particular document? l i
)
7 I A No, I have not. ;
t E j Q You've never seen it before' -
i E- A I don't know if I've seen it before or not. I li 10 ',! didn't know what the docer.ent looked like. ,
l I
it , O Let me show you what I'll represent to you as a i
IE ,j copy of that document that Mr. Nelson prepared for me
( 10 i I
yesterday. ;
14 l MR. GALLO: Could I see it first?
5[ ,;
(Document handed to Mr. Gallo.)
I' l 10 . (Pause.) l a 1 I
17 l:l (Document handed to Witnesc Engmann.)
1 13 BY MR. PARRIS: l 19 0 'Let me ask you to look through this document, if [
t !
20 I you would, please, j l
. i 2! h (Pause.) -
e i 22 A (Witness Engmann) I don't recall ever seeing !
b' this before.
13 g a
i E6 1 Q. If I could ash you, cir, if this document.which
, I L .t3 .: we discussed yesterday deals with a test of Tefsel, which n ,
a l- s Y i F i
. 1; ;
6905 wel 4 l 1 is.the cable insulation that Pe. Johnson testified will be 1
-(e 2 used in the PGCC7 Do you recall that testimony?-
s l .
3 A I recall it, yes.
4 Q Could you identify from this test what bype of 5 cabling material was tested against Tefzel?
6 MR. GALLO: Objection. The witness has testified ;
I 7 thEc he hasn't read the document, he is not familiar with 1
1 6 the document, and that the first time he's scen-it was, I D guess, today, f i
10 To ask a question from a document on that basis
?
11 is unfair and prejudicial, and I object on that basis.
I 11 MR. FARRIS: I'll withdraw the question. I I l
( 13 EY MR. FARRIS:
14 0 Are you aware of any tests involving cross lirk i I 15 polyethylene fire retardsnt inculation, Mr. Engmann?
l I
16 i A (Witness Engmann) Wall, there've been:a numb *er 17l of tests. I assume that you're referring to fire tests.
l<
15 !j Obviously insulating materials are subjecte6 to a number of IP different types of tests.
20 '
Q Yes, fire tests.
I 21 A All the major vendors of cable who use that as 1 an insulating material have told me that they have tested i
02 !j l
(
s_
ho ~
25 9 their ecmpound to IEEE 383.
L4; O -Q Have you personally reviewed the resnits of any l 2rli- -of those tests?
t
- 1 b
li i l
-. _ . - . , _ __,..,a..
i 6906 :
Wel 5 I l
, a 8
i A I haven't personally reviewed the results. I E personally witnessed one.
{
O Where did you personally witnecs one?
t 4
~
A Essex Power Conductor's test facility in Paducah, I , I believe it is. Either Paducah, Kentucky or Marion, Ohio.
6 ; Q Was any other material testod at that time?
7 j, A They also burned some ethylene propylene rubber P
P j'. insulation,
'! i 1
9 O Have you ever seen any comparison of the tests
$ between crose link polyethylene fire retardant and Tafcel?
u l.
- I[ A I don't recall that I've seen tect results,
- t. !
i O Arc you aware of hou they comparadras far as the
(
II .: fire retardant capabilities? ,
~
n 14 !I A I have been told, and I think I concur in the i
)
if .i. opinion, that Tcfcel has superior fire retardant capabilities i i;
- 'D L to cross link polyethylene.
D Q Do you know how they compare, an far ac the aucunt
^
I
': e i.
- of smoke-that's produced? .
f-
'4 : A I have been told, and I think I believe, that the +
n F
2Dp s amount of 'moke produced by burning cross link polyethylene <
i: >
l N[ ,
c::cceds the amount of smoke produccd by burning Tcfcel.
1 6
. 6 11 ; O Do you know by how much it exceeds it? ,
c ,
("
Il A I couldn't give you any quantification. I Et h 0 Are you aware of any ocuparison in the e. mount of
, L k-
.'.E gases that are given off as a byproduct of combustion of
.u ,
v .
]
6907 l w@l 6 !
1 Tefzel as compared to cross link polyethylene? ;
l
- 2 A No, I'm net. I 3 Q Are you. aware of how cross link polyethylene ecm-4 pares to Tefzel as far as susceptibility to shorting in l l
l 5 flame tests?
6 A One of the things I would like to have you l
7 clarify a little bit is, flame retardant cross link poly-8 ethylene can be compounded in many different ways. It can 9 he halogenated with any one of the halogen family. Depending 10 on which one you use you're going to get different properties I ,
- 1 Flame retardant cross link polyethylene is a l
!S generic name, and when you say you're going to use that it's j like saying you're going to use a Chevrolet. You've-going I
{ 12 I M to have everything from a Chevette to a !!onte Carlo.
15 t Q Well, your -- Black & Veatch, I should say -- your ,
l !
' I 15 cross link polyethylene, are you going to have all the 17 options, or a stripped-down model?
18 A We're going to buy it so it'll pass IEEE 383.
19 The advantage of the standard is to set criteria for flame 20 retardant properties.
- 1 o Do you consider a product that merely passes 353
'a J ,
to be adequate fo.r purposes of Black For Station?
k- Es A Certainly.
- 4 0 Did you hear the question?
k 25 A You said a produ-t that merely passes 383 to be i
i i
- i. i
p_
I, i
ll 6908 o
wel 7 i,.
V INo acceptable for the Black Fox Station? '
,4
- '-p O Yes.
e i'
S ;j A Certainly.
- 3 4 Q Even if other products pass it by c grceter o
a ,
- 1 5 l'l margin you still think it's saticfactory just tc moet the l h !
3 3i minimum? l 7 l A When you're trying to select a cable conctruction l I
E i you do it on the basis of many different criteric. Dven 41 EU the flame retardant criteria has many ftcets to it, j it n
!C} Cable construction has to be colected primarily li 11 fi based on its electrical characteristics of that construction. l I'
1 12I che dielectric croperties, resistance te ground properticc
!I I Y the leakage capacities. All of these tre prinary criteric 7
il j lii it !i f for selecting the cable construction. The insulation il material is there to provide your electricci insult. tion.
t, t
M, Included with the critoria in moct power gencrat-ing stctionr c and a certcin amount of nuclear p rer gencrating S stations, are the flame retardant criteria alco, and hov 19 ;l that particular cable construction performs with a flanc M i[
! applied to it. The retardancy can be cdequately demonstratsi-i I,
l '. ' .
by pascing IEEE 383.
I L2 i There are some other properties of the insulating
- ;1 I 1.
material that are relevant in c ticme tect. I think it 1
& ! wcs notod ycstotday by it. Shon that in the uccticony it
- k. ,0,0 l was mentioned that Tcftel has a tendancy to short out faster i
6909 :
wel 8 :
1 in a flame test thLn other types of insulating materic1. l l
,e 2 Certainly this is a property that could be desirchie in a ;
i 1 3 cable conss 4ction. l 4 So as far as maintaining the criceric of ficme !
l t
5 retardancy, I think that passing 363 is an accepttble i
6 demonstration that flame retardant properties cre adequate. !
7 Q Is cost a critarion nsed in selecting a cable? ) ;
6 A Cost is a criterior. in.all of the system. l
\
\
S Q You stated that you saw a test batween cross link i
10 polyethylene and EVR?
- l 11 A I sau them burn crocs link polyethylene and EVR.
12 0 !!ow did EVR compare with the crose link poly-13 ethylene?
(" ,
i 14 A My recollection of the test wcs thnt they 1oth $
l I
15 j passed the 383 test. Hou far the flama propsycuci up the l
16 8-foot tray, I don't recall exactly. I believe they ware 17 comparable.
18 Q Do you know whether or not creas linh polyethylene l i
19 would pass the IEEE 383 modified or extended test?
I 20 A The information that I have from all the major j 21 vendors of that cabic construction have told me that'it j i
Ei would pass the 210,000 Btu test. !
! I '
' 21 ; O Do you know if cross link polyethyleno vill pass l
~24 i the 400,000 Btu test? .
. j Im A I have not inquired about that. I have no 25 h: !
5 e
g e-, , , , .
r I .
l 6910 ;
wal 9 I information from the vendors. I l
': l
~ E In your observation of the test of cross lith ,
i 0 1
1 l polyethylene and EVR, which one of the two crcates the most ,
I ;
4 j smoke? ,
0 l4 A I couldn't give you a quantifying annwer. Both of them smoked.
7 Q Mr. Engmann, I remember asking what percent of !
l 6 ,
your scope of supply would be crosc link polyethylene and, ;
l cortcet me if I'm wrong, you said something grenter than
!' [
R' 50 percent?
II. i A Yoc. :
12 f Q Did I ask you what percent of the total amount i
13 l of cabling would be within Black & Veatch's scope of supply ,
6 14 ! of the total cabling within Black Fo:: Station? !
$[ A Yes, you did. And, in fact, if I recall my ,
b '
d response, I pointed out that the cabling that I was going
(
l ~ i-' to cpack about was the cabling that was installed in the h .3 W . field versus factory inctalled cabling insido panels. l i
T[C of the cabling installed in the field, we had ;
I t 0 !! two categories: That which would be installed i.. '.he PGOC il i and that which would be installed in the rest of the plant.
II
[ ,
f- i Li h And I believe I told you that the PGCC-installed cabling i
/ ;
(-- El L was a very, very small portion of the total cabling that U
24 ' would be inctalled.
.i k LEI .O Your quantification of the amount of cabling, is
, i I
i is
1 6911 wel 10' I that by. link?
n r'-
- A Yes.
\ E!
3 O Dr. Cox, do you have your Fire Hazardc Analysis 4'l with you? '
}
E' (Witness'Cox) Yes, I do. l A
6 Turn to page 1.6-3, please.
-Q I MR. GALLO: May I have that page again, please?
O MR. FARRIS: 1.6-3. j 9 MR. SHON: . Mr. Farris, I wondsr if the Bocrd {
"' ' could be supplied with a copy of that? We don't have our !
II copies with us.
l I 12 l (Decuments handed to the Board.)
l Barb fisl3 1 l
14 i i
15 ,
16 i.
6 17 I fI 1 E. q 15 20 21 22 !
' 23 24 1
k 25 !
l!- t s
l 1
i
. I 1 ,:
w scs., .-.- 6 SF': crl '
t Ih CD.ITCIAI: FOLPD: Your reference?
" 2 r.R . FARRIF: 1.6-3.
f i.
51 DY 'tR. FARRIS : -
1 s
1 4 l O Dr. Cox, vould vou looi: at the V:ry last sentence i 4 j
- 1
- 1 5 j on that page. I l
l 3 A (Uitness Cox) Yes. I i
7 l 0 Phat, in your opinion, sir, is the impact of ,
I 81Il having combustibles uithin the subfloor of the control !
C j! room, cs far as fire protection is c>ncerntd?
r
'l 10 A tiell , the basis for this suetement W.s u.e sub-I o flooring would contein cable. It doesn' u in piv uht conta:t '
1 a I i .,
11 ll of the fire heenrd analysis, thtte there will be othar tynes l
,, ; 1 i l g 11 )j of combustibles there. i l i 14 It acknowledries the fact that there is cz.ble i
in the subfloor, 15 f, ic: 0 ':' hon you have indicated, sir , tha t other concer..'.c,
'l so.eces vill be devoid of combuctibles. Pnv. is that, sir?
1E ,i A Ue are talking about the ceiling, the c.uspendef ;
I ty ceiling, and we are proposing that there will he no ,
t combustibles up in the ceiling. It is not going to be I 20 l '
21 j used cs a storage space for comhuntible mcterial.
I '
22 > 0 Generally isn't it a acod idea net to nave any I
i k 23 j combustibles in concealed' spaces?
9
~4: i A Yes, it in.
1
( 2:; a >
f) And ts.y is that? '
,I
>A
6913 ar2 1 A Because we want to avoid any probability of t
- E i a fire in the area.
7 0 Dut in the subfloorine , there,is goini to be 4 concealed, end you rimpiv can't get arounn it then?
I 5 : A Iio, because we acknowledge the f act th t there is going to be cable there. "e don't acknowledge the fact s
7 that there is going to be other combuntihle ncterials stored.
j e O And this is a critical area, subflooring , for fire;? l
- I l ,
a' ,
A Yes.
I L
0 At the top of pace 1. 6-5, Iir. Co):, the VEry r l 10 y. ; ,
! I g; first sentence, is thtt ser.tence still valid, i.e., that i
g3 ,
halogenated plastics will bc used only when a practiccl ,
l 1;3 substitute is not available?
A That is correct. ! l 14 O Yo L' don't have any intention of using halogenated l gg j 1
i plastics ct this tinc? I 16 g A 1:ot to nv'nowledge, f ..
/ i i
tir. Engnann has in#crned me that there is a 18
- g possibility.
, A (t?itness Engnann) As we have talked before, s.O croca link polyethylene, flame retardant cross linh
-i
,i polyethylene is a he.logenated connound. There is no
- u. l f practical substitute for cable constructions that are not 23 :' i I i halocenated compounds, if you want the flame retardant properties.
.t i
n i 6514 i, ar3 lb}
11 l
i,
!i l r
O Let ne ash you this:
p 2i,/ Mill polyvinyl chloride he used in the Black Fox 4'
t
- 14) Station ammharc.?
- i
_ o .
4[ A PVC v'ill non he used in any of the cabling j U
material at the Black Fox Station. I can testify to ':. hat.
F['t i 6 1 O It may be used elsewhere? !
i i
- / A I am not able to make that statement. Perhaps l 8 : Dr. Cox can. >
l p A (Uitness Cox) For the crea, the critical areas --
si g j wall, I can sev it is a matter of tne specification and a
- 'i matter of policy that ue will not specify polyvinyl chloride.,
- i 32 There is a possibility and we recognize that I
p~ hi possibility, that a practical substitute can be obtained.
.i
}
jg I have no specific e):amples where it is being used, but i
te i! there is certainly the possibility that it might be.
ir ,
u+ (!
O The possibility that it might be used contrary n
t 1
3 i; to specifications? ,
t< l.
l- .
r
,~ d A No.
LC l i
ll1 Still on this same nage, Dr. Cox, if you would :
<i s. ;
0 - - ,
!i
- 9. ,,
!i refer to the third paragraph from the bottom, the last f, t i j sentonce of that paragraph, beginning with "The maximum 't
- t. t
,. I extent practical." !
- . v
(_ .. I A (Mitness 2ngmann) Since we are talking about i 1: (
., cabling, would you prefer to direct the quection to nc?
x ., ,
t-
.. ,, O To either one of you.
I !
l t; .
._ .; _.=
t ar4 6915 I
- A 'lon. The lact sentence of thet paragraph?
O Would you read that centence, please?
. A "To the maximum extent practicable, cable 4
constructions -- cable construction that does not qive off
. corresive gases while burning should be used."
u 0 -!sn't it'a fact, Mr. Engnann, that cross linh S <
polyethylene gives off quite a bit of corrosive gases?
, A I would say that is a vaJue judgment. "
Ouite a o
i v i bit isn't a thing you can cuantify. It gives off corrosive j i
i gases like any other cable construction does when it burns.
O Let's compare it to Tefsel. Does it give off I 11 I I
quite a bit as compared to Tef=el?
A I already answered that question: I don't know, i
0 If you had the results of tests that indicated .
14 ',
that it did give off 10 times as much corrosive gases as if Tefzel, would you still be inclined to use cross link poly-I ethylene as your major cabling? l 17 ( l MR. GALLO: Objection. Mothing in this record 18 19 would substantiate that test exists which indicates that Tof zel is.10 times superior to the other types of insulation.
20 Therefore,'the question is based on facts not in evidence.
- 21 lin. TARRIS: I will withdraw the question,-tir.
^2.
, Chairman.
23 BY itR. PARRIS:
14 0 Isn't it a fact, Sir. Engmann, that the cross link ,
'i -25 l
polyethylena does in fact. give off corrosive gases while a
N n
., 9 . - - . - -_ 9 y _.m 9--. 9 ,,a..%- gg,, w
l'
- i 0 c-4p-ars .
I
- f burninc?
A (Mitness Fngmann) v os.
/~ u ,
Is it your testinony that it is not prccticable
~
O pe.
- F I- to use any other cable for Blach r Vectch's scope of supply f
.n for the Blach Tox Station? I A The halogenated compounds are used in cable j 6
construction for flame retardant properties. They are 7 1 C
additions to materials that are desirable for electrical l l
1 l
insulation. You don't select cable conctructions only on t
the basis of thcir flamz retardant properties.
.g As I said before, you coloct cable ccnctructions
. l :.l.,
i
! primarily or in conjunction with electrical properties and .
i 14 i I
l performance under flame situations.
13 ,
Cross link polvethylene is an exec 11ent electrical It insulation material.
15 P O Isn't it aloo a prolific producer of corrosive it r
[ gasec when burned?
A " Prolific producer" is a value judgment. I can't T5 cuite define what you said. ,
i 1E i G Uell, in making your recommendations for the '
20 I material to be used at the Black Fox Station, do you feel .
%; i6- !.
li h
it is your obligation to beccme familiar with all reputable 4
'3 t i
i tests involving cross link polyethylene as far as its '
L I a amount of corrosive qacen it produces?
.e lt
~+.
?in GALLO: Objectior.. 'dr . Farris has tried ,
n r. > *
.m ,
'! (
) .
66
i 1
6917 '
arG t three timec to get this witness to characteriz 3 the anount
- f2 of corrocion effect from this particular type of insulation.
-(
3: The witnest has three times answered the question. It I ' < . .i han been' asked and answered. I think we should move on to i
5 somothing else.
6 ftR. PARRIS: I haven't asked that cuestion at all.
7- I realize that he hasn't seen the particular tes: that I i
gi have in mind, but I'm asking in his opinion whether or not 1
I he thinks it importe.nt to find out those kinds of things.
9 ,
I !
10 ? I didn't. quantify it or give him any sort of figure.
gj .,
CHAIR' TAN WOLFE: Objection overruled.
1 12 UITNESS EliGMAICI: In selecting a ccble construc-l
, g3 tion for the Black Fcx Station, I familiarized myself with I
(
14 what I think to be the relevant properties for cable conctrue-g- tion for the Black Fox Station.
I g I am.awcro that cross linh polyethylene is c i
g compound that gives off corrosive gesec while burned. !
f t
g However, you can he.logennte it with any of one cf the j halogen families.
39 I have been -told by vendors that if you halogenate 20 it with chlorine, you are going to get considerably more 2,
gg corrosive gns than if you.halogenate it uith the bronides.
(- 23
- * *"" " " "" E Y* Y #"
appears to give off -- I am told gives off much loss in the
, way of corrosive gases. The superior electrical insulation s 2a.. . 4 I I
.p
- f .
4 '
H
- c. .o-.s e ,
ur7 I
l I
propert:..cc c: the cross 1:. .nh polycu. ry.;.ena reconcended as : I
.f -
2 ,.
i ccmpound or as a contturuction to be used at 9.e Black For 3 Sta !.cn. I do not kr ow cf any othIr coNitr%ction Either 4I than ethylene prooylene ruboer the.t would meet more of I <
in '
5[ the criterit of both electricrl and flame retardant that we .
,5 I are using in the selection of cable construcsion for Llach .
t
- j 7 Fox. l i
1 e lI BY ?!R. F1.RF IS : ,
1j i
.e [, O Is it your testimonv. that crocs link pciv_ e-ivlene _
t h
je l of the type that ic going to be used at the 31ach T'c:: Stz. tion - - -
I si
- h strike that. 4 There is a belancing test between the elect"icci l 12 1 4 t
f I
t,3 conductive capabilities of the cable and the ure renaracncy l 1
3,; l1 Of the insulation? j l
i 1
(Mitnces Engtann) In scme car.es it ic much more f: !! i
/.
l come of the constructions that meet t sovere than bclencin
- 3. :. t
, h.
i .f cil of the cricoric. "herefers, they can't b0 t'.se6.
cnd 2 te, d- t I
IP '
I I
. r. .! ',
I i
..< j
=Ie 4 I t,i A ?lt .
/ I l C <r.
'~
! i P l e
il e.c.
- =
- h s i
' }
l' L 4
il u
_ _ . . ,_.. i I
6919 I l
david 1 1 O Have you determined whether or not Tzfzel
. tape 3 '2 inculcted cable would have the electrical properties 3 that you taink were'used? ,
1 e
4' A Tcfzel insulated cables will not have all of 5 tne neccesary properties for the cable at Black Fox. ,
1 6 O Won't the cable that you are using be ultinctsly 7 connected with Teftel insulated cable within GE's scope 8 l of supply?
)
! A I am not sure I understand your word ' connected.
10 O Going into the termination cabinet that you 11 j determine to be ultimctely the current that will travel 11 f.' through your cables will be fed into cables insulated i.
e 12 by Tefzel within GE's scope of supply, will it not?
(
14 A It will be a continuous circuit.
15 O Do you think GE has colected the wrong type of 16 ; ctrble for their scope of supply?
17 A The necesscry properties of the cable to be 10 installed in the PGOC arc different than the properties 19 required when you are installing it in tray in the field.
20 MR. SHON: Mr. Engmann, could you give us an 21 example of some of those differences of what the properties 22 'it are that Tef e1 doecn't have that you need in the field 1
'* /
,so - 25 and that they don't need in the PGCC.
h
- 24. lj ITITNESS ENG E N: Installatien of Tefzel in tray
, I Es in the field is a vigorous procerc. Cabling han to have 1.
u il
- 3. .
w P
- , - - - W - r,,_- ep. +,. ,-p, ,y.,-y- r wy y -- r-
6921 david 3 I A cutting is what I tnouaht you ucre talking about '
2 r
by just resting the pressure of the cabic itself on a 3
sharp projection. Yes, over a period of tims it ecn indent 4
and perhaps cut the jacket and insulation material.
5 0 Are you aware of any tests that cross link 6
polyethylene has been cubjected to as far as its 7 resistance to cutting?
U A I am cuare of some tests, yes.
9 G And who performed those tests?
10 A The test data chat I reviewed had been summarined 11 by someone who was working for me, so I am not sure whc 12 performed the tects.
12 0 Were those tests satisfactory to you?
14 A You have to start talking about what the 15 construction of c cable is. The out covering of the cable 10 construction to be ussd at the Blaic Fox station, the 17 jachoting materiel is chlorosufinnted polyethylene, net 18 cross' linked. The insulation acterial inside the jachot ic 10 crosc link polyethylene; cable resting on some sharp 20 projection will be resting, obviously, on its jacket 21 meterial which is chlorosulfinated polyethylene for 22 Black Fox. -
23 0 And the outer jacketing mateial is the material 24 that would need to be tested for its susceptibility to J
I i 25 cutting?
i l
- a. - - -
i, n..e m_. .l, F &
1 t
i david 4 'l A I think- when yet: ety ' no d to N neca: *
- i f 2 don't necessarily believe it necir to ha testad. ~
3 3 think we-havo' to be 2.asured that it is caticfcetery in
(-
4 its performance in that particular typc of rituation, '
~5 0 sd how cre you assured of its performenec in !
6 that cituation? I i
4 7 A one of the principal ways that I am asrured j i
8 is by werking with thtt construction and ins s tion in the !
i 9 field. :
i 4
to Q licve you observcd that pcrticular product ;
i i
11 in the field ever c long pcried of time? l l
t 12 A I think that the inste.llation of ecb]e and i I (m 13 cable trcys subjects that jacketing material to much i
o 14 more severe cutting duty, if you will',.than recting on i l'
iS some object over a long period of tirae. I ,
16 The presscron nnd ansion existinF on ::.bic ,
i 17- when you pull it' fnr c::ceed the weight of the cab'e itcolf f.
18 an6 invariably,.no matter how well you design the raceway 19 system, there are projections, sharp edges en which that !
}
20 cable will be pulled against, pressured against in any one of 2 a number of ways.
22: My observation is that chlorosulfinated {
/
I
-C polyethylene is an ac.
g3- material for that l
,g kind of inctt i 25 O Do o Teftel in that I t I
1 y l~ L l
r
=-w -
=ese ene ,
l oraa david 5 A Fr:n recollection, I halieve that there it
'~
2 in the specific auantified tests in uhich such varichlos ,
i as pressure of the projection, . depth of cut, using what 4 I think are reasonable criteria, Tefzel as a material had 5 - better, if you will, resistance to cutting than chloro-1 0
sulfinated polyethylene.
7 Mr. Engmann, when chlorosulfinated polyethylene
.O 0 is burned, what byproducts are produced?
9 A It is a halogenated compound. I am not 10 krowledgeable enough about the specifics of any particulcr 11 vendor's ccmpcund or in general vendor's compounds to 12 know enactly what products are produced. ,
1 13 0 Do you know if it produced hydrochloric ceid?
14 A I have no information at hand that indicctes i 15 that it produces hydrochloric acid. l 1
end 3 16 j 17 18 19 20.
21 22
~
23 24
' 25
e i i 6924 DtT4 crl o l
Mr. Engr.Enn, the remins, tion cubir,etc , is the ,
1 , 4, O i
(' 3 primary point of interface between the GE ccope of supply ,
t 5 ..l and B1cci: & Ventch'c scope cf supply, it f.t Sci:?
le For ccblinq. i 4, ! A o For ccbling, yes. !
5 '
i S
101o is responsible for deciqr.ing the fire {
y stops and the cable construction in the terminction cabinet? :
d- "ha floor E
' A Fire ctops, that will be inste.lle* f i
b..
e openings underneath the terminction cabinetc, will be ;
i'l 1 '
m designed by Eleck & Vectch. We have c1racdy discucsce l .
't
- 5. .
the cable constructions in the PGCC and the rest of the f; eld 3 .,
c 7,3 .!.
cabling, and who hco recponsibility fer those, obtiously o
- ., y ti in the termination ccbincts is a point of ', unction where I
h
- ,, y you have both types of cables, ca you pointed out earlier. ,
n g ; O And who designe the fire stops leading from the !
, j o'
hy 1
termination cabineta in the FGCC?
L l'
A Thct ic vithin the GE scope cf derien.
.,h O And who handles fire protection for the PGCC?
Ic i.
i m
A (17itncsc Co2:) On the fire protection -- may I 8
.o )
. i answar the question?
.c.0 y 1 0 Yec.
-. a
'l t A On the fire protection for the PGCC, it is the j 3 [
b
. s ..0. l! cc:t.binction of CE and Fic.ch G Vcctch responsibili ty. ,
.s ,
- i. ,
H
,1 O Firo protection to the termination cchinctc is A, . :: i, ti
,i uhose responcibility? i l c, ; s;e i 1
.E I Ih I I
h '
i c
.o 4
6925 ar2 g A ~ General Electric Company.
, 3 0 Even though you will have some input as far as N- t 3
y ur cabling? l 1
A Mr. Engmann can correct me if I am wrong. Our !
4 g
i input is up to the termination cabinet.
Q Didn't Mr. Engmann tell me that half of the cable 6
in the termination cabinets will be supplied by you?
7 A (Witnese Engmann) The field cabling coming ir, 3 l from the field and landing in the termination cabineta, g f f
those constructions will be the responsibility of Black &
g {
i Veatch.
On the other side of every termination nodule there is cablinct~ that now entere the PGCC from the termina-13 tion cabinets, the floor modules. That cabling construction it selected by General Electric Company.
I o,,
O Is there en automatic fire suppression rystem within the termination cabinet? l 17 A (Witness Cox) No, there isn't.
18 0 What sort of fire protection system do you have?
A I think when speaking within the termination cabinets, it is probably more appropriately addressed to General Electric. It.is their responsibility within the 22 termination cabinet.
23 MR. GALLO: -Mr. Chairman, may I give the uitness 20 come water?
2S l
9 - - -n.-w p
o 1
- 6) '
l' ars ;; ggig h
- CHAIDIAI; WOL!'E: Yer.
{I
~ 3 (Pause.)
! I
.- , EY 7 tR . F7.RRIS :
~ sl
, l!
4 ; O Mr. Er.gmann and Dr. Con, if you would turn to l
3 l Figure B-40.
'I n-i
. Dr. Cox, we discussed yesterdcy the marked ;
y location of the fire wall, that it is not exactly correct, ,
. i 3
but it will be roughly in that sane configuration, uon t t it?
, i A (Uieness Cor) Yec -- ve"l, ce fcr at tha n
g- i inverter rooms, it is correct, but there are some chcngee
.s j l'
,l 9 i
in that crea also, and the firo Ucil continues cc. t it i i, .
y, j indicated in this drawing. t h; i
.. y To a point slightly past this center of the page, '
a . ,
i from that point the fire wall deviates through what is 14 .l !
l irdicceed there. ',
.c
.-; ,. c D,
!! O And on either side of the fire wc11 are the
.Gi i
li
., ; different divisione.? ',
i.
,i G.
l A (Witness Engmann) That is correct. The fire wall as it is located in the current design, separates e
the redundant divisions. !
d
'0
{
O And where is the cabling that would go to the ,
- d. ! ,
1 remote control roo:a7 l' 2E b!!
A You mean the remote shutdown pancl?
55 0.t ,
l O- Remote shutdown.
Z4 ;
i <
! h The remote shutdown panel cable could bt on either t ?
kI i 4 i
!) !
' -~ -. -.... . _ . _
6927 ,
ar4 g I side of the fire w:ll, depending upon uhat' redundant division s
- 2 it was in. l i
s 3 O' It is not on either side? :. .
1
- r' 4 A It could be on either or both, depending on 5 the divisienci assigrnent of the instrumentation an6 controi e i
i of ths. remote shutdown.
7 Primarily the instrumentation control remote .;
l 8 shutdown panel'is Division 1. Therefore, the cabling thtt 9 vould run betwcon the PGCC and remote chutdown pans'ing .
10 would be on the Divizion l'and far side of that fire wall.
11 j O So, in other vords, if wa have a fire in the 12 i Division 1 or far side, it would not only toke out the -- !
l, 13 that division as far as the main control room is concernod, 14 ' but it would'clso take out or could conceirchly take out l
15 I
the remote shutdown room? ;
I
'A No, it could not. Currently within the GE scope
!G l
)
17 f of supply, and they are the best ones to addrert.this ques-18 tion, there is a transfer switch located on remote shutdown 19 panels. . That transfer switch is the normal position in 20 which all'of the wiring runs to the control room from that ,
21 ramote shutdown panel is disconnected.
22 0 I think my questior is, does the ramote shut-13 down room have separate divisions?
- 14. A LThe control and indication instrumentation 15 mounted on the remote shutdown panel is primarily Division 1. ,
i i
i
!)
~
ar5 l{ 5523 -
r i
- 3 The functionc thct are performed from that rcmote shutdown i il
,_ <3hk panel can be performed through either the control room or 5 i
v the remete chutdoun pancl. ?Tithin the control deriga, 3j i
(
~
g' i electrieni control dorign of General Electric Ccapany, they }'
't
'- i e.
- have located at the remote shutdown panel a transfer switch. !
t 6
The normal position of the trcasfer cwitch dis- j 5
I connects any t iring between the remote shutdown panel and l 7 .'
g the control room, ao even if you dectroy all of the viring from the reacte shutdown panel to the contro2 recr. vith a e,
i t
10 positive fire in the Division 1 and floor cable spreading room, y u cc= promise none of the functions that can uc pcrforme-.
If h
y by thct remote chutdevn panel. f t
b 0 How is that accomplished? Is there a direct l
%*~
0 d
cabling from the remote shutdown room to the reactor enfety l 4.;
I j' systems? !
E i! -
A There is hard wiring from the transfer suiten en I. . I "B !
<! to uhe. control room. Thero ic hard wiring from the c hcr
.. m ,
., i i
N cide of the trancfer switch to the control indicction .i la >
instrumentation mounted on the remote shutdown panel. The f it signalling circuits necescary to perform the function of .
j 20 y>i c controlling the process, the process drives,the emergency j 1
i ;
j core cooling spray systens, is hard wired from the rs=ote ,
ao
~~ . s 3
- chutdown panel to the actuators for that procece equipasnt. i
~
E3 ,
I d
u O What route does the hard wire take from the l
~* .- l } .
O remote shutdown rocm to the actuctors?
25 i! !.
I O !
il i
't i
.L s
ar6 ! l
- i
' l A Primarily the control function the.t is located ;
' I on the remoto chutdown pt.nel in Division 1. Division 1
,t types of devices, safety related, and most of the iring a '
would be routed in Division 1 tray, obviously, or Division 1 5l raceway. i l
5 end 4 i l
7 i 8 l' t
' I 9 .l l
i l 10 i j i i u '
l, 12 l' l 13 l
14 w
l
.16= . l l 0 l' 18 r
19 20 t 21 Ii 22 i
'~
23 24 !
25 ,
I
.f
GE20 I
tape 5 1 l 0 Cnn yac indicate in the drowires which pa tica
- david . 2 1
of the drawing is the division one in Figure b-/.0? -
A The 1cfthand sida of the firewall is the division 4 j one and four cable spreading aret. .
l-5 0 Now, is the hard wire cabling from the remote 6
chutdown room to the reactor within that cabling indicated 7
on that side of the figure?
8 A THe hard wiring between the rorete shuudoun '
t 9
panel and the procesc drive actuctor: and inctrernentation ,
10 i
"" indication, that hard uiring is not in this cable ;
11 .. i; 5 .cing area.
12 .
Q None of that wiring? ;
g *, .
A None of it. I I
14 1 0 Mr. Engmann, could you direct us to a figuro, i 15 '
either in this document or in the PSAR that would indiccte {,
16 the route that the hnrd viring tchet from the reac;ur I !
II actuctors to the remote chutdown? !
6 IO A Well, the divicion one tray system as described l 1
s 19 e in the series of B-drawingc, if you will look on B-22, :
20 there is a complex of rooms near the zero degree line of 21 I the reactor.
'2 One of those is the rentote shutecun room. If !
23 i you look out in the corridor, ycu vill notica tht? there is i i
1 24 a number of trayc' identified as divicion one; some of the 25 wiring that would go from the remote shutdown panel to the L .
6921 david 2 1 process drive cctuatorc, instrumentation indication would
(' 2 be in that t. ray as well as other division one trays 3 located wherevor it would be necesscry to route those 4 circuits.
In addition to the division one tray, there will 5
6 be conduit also which is not indicated in this series of 7 drawings.
8 0 Thank you, Mr. Engmann.
Dr. Cox, this firewall indicated on figure B-40, 9
10 is that supposed to be c 3 hour3.472222e-5 days <br />8.333333e-4 hours <br />4.960317e-6 weeks <br />1.1415e-6 months <br /> rated firewall?
A (Witnces Cox) I assume you mean the firewall 11 12 down through the center of the cable spreading rocr.?
ll 13 0 Y*8' 14 A Y*U' it is a 3 hour3.472222e-5 days <br />8.333333e-4 hours <br />4.960317e-6 weeks <br />1.1415e-6 months <br /> rated firewall.
l 0 Are you f tmiliar, sir, with the firm of 15 16 Gag -Babcock Associates?
A I knou chem by name. I knew that they are a g7 consultant to the NRC on fire protection.
yg 0 liave you ever seen any correspondence between 99 Gage-Babcock Associates and the NRC?
20 h Yes, I have seen some.
21 G Hav y u ever seen a mem randum dated 22
~ op em er 1, m r. .n, senior vice president 23 ,
ef Gage and Babcock to Messrs. Phil Matthews -- Phil 4 24 Mattheus , Bob Ferguson, and Gene Imbre -- I-m-b-r-0? i
i
' ," c en l, I
david 3 1' A I cannot identify it, whethe.r :' ht"c renn in or
^^
2 nc t - from the inforetticr. you have given : 4.
3 .O I hand you what purparts to be a r.amorandum !
l 4 to thethreegentlemonIjustmentioneidatedSeptember30th)
I l t
5 1977, from.Mr. Bert Cohn, and ack if you have ever cean that l
6 particular memorandum before.
y i
A No, I haven't. I haven't seen thin memorands:
8 before. f g 0 !! ave you -ever seen any documents thet cre !
10 critical of cny weahnesser in a 3 hour3.472222e-5 days <br />8.333333e-4 hours <br />4.960317e-6 weeks <br />1.1415e-6 months <br /> firewc11 Le an jt effective fire protection barrier when it is penit.need l 4
12 by cable' trays?
g3 A I havo not.
14 0 Do'you have any concerne about the efficacy of ,
i thic firewell to perform its fire protection functions? l 15 i A No, I do not hcvs.
1G s Q Do you recognize Gege-Babcoch cnf.Aosoni.ctes En ;
97 ,
a firm having considerable a::pertise in the arce cf fire 18 gg protection and fire safety?
A I would recognice them, I believe, yec.
20 l
Not knowing a lot 'about them, but recogrhing 21 the name;with come degree of reputation, I would recognize 22 I
E
'- that.
23 0 'N "10 you be surprised to lecrn, sir, that 24 -
25 Gnae-Bebcoch and Associates has informed the UnC that if c l
u i
< _-- , 1 l
6933 david 4 firewall'hes penetration for ductc, cable trcyr, conduits,
- c. 2 l et cetera, that the probability of failure can be fairly high, despita -- can be fairly high despite the fire rated 4
protection on the penetrations?
5 A I have --
6 Objection. The gestion assumes MR. GALLO:
7 facts not in evidence; therefore improper. There is 8 nothing in this record to indicate what Gege and Labcock o
thinks about 3 hour3.472222e-5 days <br />8.333333e-4 hours <br />4.960317e-6 weeks <br />1.1415e-6 months <br /> fire wal:.s.
I MR. FARRIS: I didn't accume any facts. I II asked him if he would be r.urpri:cd to learn if that were 12 the case.
I3 MR. GALLO: I will object on the grounds that 14 it is irrolevant. Dr. Con's surprise is not probitive 15 evidence and not pertinent to this record.
16 MR. PhKRI S Dr. Con indicated that he had 17 absolute confidence in che ability of the fire walls to 18 parform their function. I a:ked him what he thought of 19 Gage and Babcock. He indicated that he thought he knew 20 wh'at they were doing.
21 I think hic surprise would be relevant to 1
22 this botrd to know that Gage and Babcock have been critical 23 of the ratings given firewalls.
24 CEh2RMAN WOLPE: Ob:,ection overruled.
~
25 WITNESS ENGMANN: If you are addressing the
I 6934 1
de.vid5 firevtlls, it it penetrated not only by ctile rcys,
~
2 then parhcps I would be better able to answer vot. ;
3 i question, j 4 1 EY MR. FAP.RIS:
5 O Either one, both of you. l 6
A (Witness Cox) Before he docs, let me repond to 7
my confidence with regard to firewc113, and that night 8
answer -- and that my answer remains the same because the ,
9 l firewcll itself, I hcva confidence in.
10 When you talk about the penatrations to the !
l 11 walls, I have confidence in that and that we have cpecified l
12 i as far as the rating is concerned, the chility of the f 13 firewell penetrations or the penetrationc for the 14 firewall to be jeopardiced would be news to me and probably 15 I would be more -- and probably would be more offectively ;
i 16 ;
answered by Mr. Entmann. l 17 l A (Witness Engmann) YEcterday we diccessed the ,
18 design of cable tray penetrations in floors and walls.
19 At that time I indicated to you that our design was going to 20 be baced on the application of silicona foam material 21 and that those cable tray penetratienc would be tertcd in 22 accordance uith ANI requiremente which included an ASTME-119 23
- test.
24 - i Based on that testing, I would hcVe full confidence j that the integrity of the 3 hour3.472222e-5 days <br />8.333333e-4 hours <br />4.960317e-6 weeks <br />1.1415e-6 months <br /> barriar would be maintained t
. ._ -. ~ _ . _ .
6935 Cavid6 1 with those cable tray penetrations.
c 2 BY MR. FARRIS:
3 O Then you hcVe some concerns about tho 4 penetratienc in the firewall?
5 A (Witness Engmann) I think the.t you have to be 6 very careful that you raaintain the integrity of that i i
7 barrier and you do that by testing the application that !
i 8 you intend to use in accordance vith accepted tectc.
9 -Q The integrity of the firewall wculd be no 10 better than the sealant that you use in the area of the 1
11 penetrations?
12 A In this particular case, the vall itself 13 probably has a rating that much exceeds three hours.
end 5 14 15 16 17 18 19 20 21 22 23 24
'*M
! -[
i C936 j i DW6 arl ,; . ;
E i i
.1 l .The cpplication that we have in mind for a i
4 ,
e- 2 .
cable tray penetration of that wire will be designed for a !
t i
5 !
.three-hour rating. It nay achiave something greater than ;
P
',~ 4 that, but that is ' ths criteria to which we arc designing. !
- 5 Q Who will be doing that testing? ,
i l
4 C A The testing of the configuration of the cable trcyl
! 7 penetrations that will be used at the Black Fox Station has
.6 been accomplished on very similar types of installetions I 9 ! already.
t >
l '
to { Q By whom?
I S : t j gt A ANI has. sponsored several tests that I have seen ',
1 l3 i
jz summary information on. I don't know who the actual testing f 4
4
]i !
j3 i laboratory was. l
. t i 0 Dr. Cox, will you turn to page 3.1-33 of the g4 {
4 l' g g ;; fire hazards analycic, Appendir A.
1 j j,3 A Would you scy the page egain?- j
! O It is page 3.1-33. -
I 7' :
i t gg 1 A (Mitness Cox) Yes, I have that page. j i
gg- 0 At the top of the page, your response to the i
- _y .
. NRC positions on the halon supproscion system. [
1
- u A Yes'. ;
j l ,, *-
O You indicate that Blach Fox Station fire protection' I 4 L. ,,,
" system will not use halon supprocci.on- accociated with any -
safety-related'syctems. Why not? ,
A :We at that time hcd not identified'halon as i
,g 's i
p ,
k
.- . . - - . . . ~ - .-.. . . -- .-
--.- - . ~ . - '
69L7
.cr21 I suppression agent for the PGCC. As I indiccted yesterday, r- 2 'there'have been. changes that were not known at the time 2 this analysis was prepared, which affects the answer to this, r
4 and it has been changed.
5 We now recognize that halon systems as being 6 utilized at the Black Fox- Station in suppression for the 7 P3CC.
8 0 Why did you not originally decide to use a halon 9 fire protection system?
10- A In this particular area?
f i
i 11 O Yes. j 12 A Because we could not decide, Black & Vaatch 13 .could not decide what to use in this area, because whatever .
1 1
14 was used had to be compatible with the PGCC, and the PGCC l i
is was a cubject being addressed by General Electric Ccmpany I l
15 with the liRC, and tim tests were being made at that time 17 1 to recolve fire suppression for the PGCC. So ve could not ,
IS commit to a sugression agent until we knew the conclusion of 10 the negotiations between General Electric and HRC.
20 0 Had you made the. decision not to use a halon 21 suppresrion system even outside of the PGCC?
22 A Yes, wr vi.
23 O Did you havs.any reservations about the use of' -- >
24 ; any reservations about the use of the halon supprescion systemj 4 l
2, personally? !
N i
._ y
<,w ,
m _.._. . _ . . _ . _ _-__. . . ._ - % . . - c _._. _
3
.. j- 6938 l-ar3' l. ,.
c 1" 'A The main reservation that ~ have is that other
-- 'Z- l cuppression systems are much more effective, and -this. ic -j.
1 3
5 the reason why this suppression systems on the outside of 4 this aren primarily are water systems. i i
5 0 on page ?.1-3.7, Dr. Cox, in response to -- in j e
6 your response at the top of the page to the NRC position, l 7 you qualified your answer to som extent to the Staff's !
I e concern about the separation of the computer from other t.reas ,!
t gi of the plan. .
I 10 A Yes.
tg 0 Why did you do that, sir? ;
23 A Because the most opt'inistic performancc, optimum 13 performance of the control room incorporates the computer, y and co the communication between the computer and the I control room is essential, and it is our feeling that we gI i l t
3,:; j did not wcnt to divorce that function between the co:rputer 2
- 7 and the control room. l
- g Q Does the computer create some exposure fire f I
gg hazards? l i
I 20 MR..GALLO: I would object to that question on
.n the grounds that it is var 2ue, on his definition.of exposure t fire hazard. '
e
- l l
eo-MR. FARRIS: I will ctrike that. !
I l i
/4 TaY MR. FARRIS: -I t
. %. O Does the ccmputer producc a product that is a !
d i
i
)l <
r' :
-h ;
.. . i T' -
-v tag ei -- m-6-ed.,9++e --wo---r- .-twt--a ,wn, g w e ..-rs"3-.-=
=s_ - - ,
4--
6939 ara g
potential 9ource of exposure fire 7 A (Witness Cox) Yes, it does.
s 2 0 What prcduct is that?
3 A (Witness.Engmann) If I can interjoct, I think 4
5 best that you address that question to General Electric.
O Can you respond to that cuestion, Dr. Cox?
A (Witness Cox) I don't mind responding to it.
The cnswer is obvicts. 7cs. It produces paper r anc paper
]
is a product.
O Dr. Ccx, on page 3 of your testimony, the second ;
11 l' ,
paragraph, the second centence beginning, "The design ,
s te t
) specifications."
A Page 37 ,
i
! O Page 3, second paragrt.ph.
15 A Yes.
16 0 Design spacifications requiro the fire protection 17 system would be designed to the proper capecity.
18 A Yes.
19 0 How did you determine what the proper capacity is 20 for the fire' protection system?
21' A This is determined by the number of -- take, for 22
- j. example, the nuuber of cprinklers that are required or are ES.N ' to be utilized, the length of ' pipe, the size of the pipe ,
24.
and the desired capacity, the required capacity.
PS 4
. _ - . . . , - , , v - ,--
t- a
-l 694C l
ar5 j.
I' O Ic that onic specific crec, the.nnount of- !
l
>^- 2 combustibles that might be present? 3 i
3 A Che sprinkler system that in specified for the j e ,
i 4 area is selected on the basic of the job that it hco to do. ;
i ;
'S .The calculations confirm. that it can do the job that'it has I f.
i 6 to do. t l
7 Q IIow do you design the syctoms to prevent inadvsrteny f
D operction from impairing the safety functionc? 1 I i 1 g A I wonder if you would 'repcct that for me, ; l 1
10 0 How do you design the fire protection syntens j i
t ji such that inadvertent operation will not ir.pcir the ccfsty e i 1 i ;
12 function of the syctem ctructures and the comacnentc7 l
- i. i
, 33 A It is.many-faceted. Sema of the fcetors are thct +
14 the scfety equipment must be such that the uater doesn't 15 impair its function. If we portulate a brech in the fire 16 uyctem, for inctance, and we 6Lcign to oncure that ar a 37 result of that brech, the rccultant pipe would in no ucy gg ondanger the safety-related equipment.
l i
99 Q And you have to get the water er the other -- ;
i 20 whatever the cuppression is, close to the possible nourcs !
. I 21 , of the fire, don't you? j ,
A Yac, shr.-
22 i
-Q And at the sene tima, docen't that prcxicity givs -i 23 you prcbicms with,-ospecinlly in the crea of clectricci f 34 4 4
equipment in the .. event of inadvortent operation or pipe l 25 l
f n 4
, >- . ,, . , . - . , . . , , _ - - - . , _ . . _ _ . . . . , , _ . , - -. - . ~ .
-ar6 6941 1 . rupture?
" 2 ' Is It presents that possibility. !!auever, the fire 3- protection system as applicable to safety-related structurec e
4 is desig,ed against pipe break, and also it is designed 5 against -- to withstand an earthquake, the safe shutdewn 6 earthquake.
end 6 7 8
9 10 11 12
, 13 14 15 16 l 17 18 19 20 21 22 23 24
'25
- 6. .: 1 I
6 a
It is important to point out als the.t should l' david 1 }
- n s tne fire crotection
~ svste:a f ail chcre is a redunis.nc tape 7 e
a cystem to take its place and. perfora that function. ;
s~ e MR. PARR~S: Mr. Chairman, I have no further 4
c*aestions of Mr.EncTaann or Dr. Cox. 2 5 - -
i g Cura.ina woLrB: nedirect, Mr. Gallov r I
MR. GALLO: Yes, Mr. Chairman. i-7 i
REDIRECT EXAMINATION 8 i BY MR. G.ELO :
D s 1
1 0 Dr. Cox, turning your attention to the fire ha. cards analysis report, page 3.1-3 3 -
+
A (Witness Cox) Yes. l
- m. ,
i
.- Q I en not there vet. - ,
ah I believe ansuer to one of Mr. Fr.rris's !
quection, you ind.icated thtt you thcught water or other suppression systems other thtn he.len were sup=:rior; ie t o,,
r 17 l thLt what"ou said?
^
t A He were talkinc about creac outside.
~
We weren't i 18 t talking about this area, and in thatparticular crse, they !
19 l i are supera.or. ,
20
, O Let me try again: in answer to Mr. Parris'c ;
21 i Jctem -~ I'm 22 l question, did you indicate that the halo: ,
r I
23 l scrry --that suppression rysteT.c cther chan halon were t i~
- suncrior?
24 l ,
! A Yes, I did.
I'5
' t i
G Now, when you made uhnt ctttement, did rou mean >
I
5943 1
david 2 to indicate that a water suppression system should be
- 2 used in the PGCC?
3
- A No, I didn't because the question was not 4
being addressed to the PGCC.
5 .
O Is it your opinion that a water suppression system 6
should be used in the PGCC7 7
A No , it isn' t.
8 Q Can you explain why?
9 A I believe in this particular case a halon 10 system applied in the area that we are concerned with, 11 the subflooring is a perfectly adequate suppression system.
12 Q Does that opinion rest upon the type of fire 13 you might expect in that aren?
14 '
A No. It isn't dependent upon the type of fire.
15 O Can you give me the basis, then?
16 A Mell, the halon has been shown to be an eff ective 17 fire suppressant for all fires except deep seated fires.
18 The halon concentration, effective halon concentration that 19 we are introducing here of 20 percent is an extremely 20 eff ective concentration and so it will be an eff ective 21 fire suppressant for a fire in this area.
22 Q You don't expect a deep seated fire inthat 23 area, is that it?
24 A No.
25 Q I believe you testified to one of Mr. Farris's
- =. . .z_.. . .: :: . -- -
z-- . .- .
... .:z2:= - , ._
84 1-david 3 questionc that there was no plan to use PCV in the Blach <
, ,- .2
. Fox station?
3
. , k - PVC.
4 0 - I'm sorry, PVC.
~
Did you testify that there was ;
5 l no plan at present to use PVC? ;
6 A That's correct.
t 7
0 You said that it was possible that it might 8
inthe future?
9 A It is peccible that under certain circumstances 10 the required cabling, the -- the required instrument 11 cable cannot be obt:ained in material other than PVC. )
l
' A' (Witness Engmann) If I could interject here.
13 In that particular case of cabling, there is no plan to use 1A PVC now, and I don't anticipate that we will need to use PVC in the future for any cable insulation or jacketing 16 material.
j
'7 G Dr. Con, is it clear that whatever f i
1 18 and wiring is used at the Black Fox station, it will meet l 19 specifications as described by P507 20' A (Witness Ccx) Thore is no doubt about it.
O Mr. Engmann, what is NED?
22 A. It is a General Electric ccer.pany.
23 GL In answer to any - ctrike that.
g l In answer to questions , if tou used the on
~
{ phrase NED,you mean the General Electric Company?
I
- - _ s-l l
J 6945 1
1 david 4 A Yes,'that is correct.
- 2 I Q Dr. Cox, can you tell me what the objective l 3 l l . is, the purpose for your development of the fire hazards l 4
analysis report? I 5 .
A (Witness Cox) The objective of the fire hazards l
6 analysis is to show that postulating a fire we can 7
safely shut down the reactor.
8 0 Is this a comprehensive and systematic 9
analysis? l 10 A Yes, it is very cor.prehensive, 11 i, Q For the Black Fox station?
12 A Yes.
. O Can you e:: plain how you conducted this analysis 14 starting with the first step?
15 A Well, the first step in the analysis was 16 identifying fire areas by going to drawings, referring no 17 drawings of the facility, identifying on those dreuings 16 areas which are more commonly bounded, that can be 19 classified as fire areas, and this is identified 20 by a rating of a wall' and the primary reading of the 21 wall that'we initiated was the 3 hour3.472222e-5 days <br />8.333333e-4 hours <br />4.960317e-6 weeks <br />1.1415e-6 months <br /> fire wall.
22 So we identified areas within the facility on 23 each drawing and in every crea on the basis of a 3 hour3.472222e-5 days <br />8.333333e-4 hours <br />4.960317e-6 weeks <br />1.1415e-6 months <br /> 24 firewall.
25 After the firewall inthe area was idantified --
I n .
I l 1 I E946 fdevid5- .1' C' Can you tell me-how many fire areas thars are?
e' 2 A- 23 fire' areas, approrimately. That enocmpasses }
i
~
.3 the entire plant. ;
4 .G And are they reflected -- are these fire g 5 areas identified in the report? t 6 A Yes, they are. l
}
7 0: Can you tell me where?
A The fire areas are identified in section. D, i e I i
g Appendix B, which identifies each area by drawing. !
1 10 Each is identified and discussed also in f 11 section two of the report.
I 12 Q Is drawing B-40 that you were questioned on, :
i is that one of those drawings that identifies fire creas? $
( 13 14' A Yes. ,
15 O The first step, as I understand is to identify ;
16 these fire anas uithin the entire plant.
f
- 7 A Yes. .
gg Q Then what do you do?
jg A Af ter tr.e fire areas are identified an analysis of what is in thefire area is made. Safety 20
+
21 related equipment is identified. Assurance is made that- {
p2 there is. proper separction of safety related equipment-
- I
' combustible material is identified; combustible material l 23 f
is also spelled out for each fire area, and in ttb.la A-1 '
g4 ;
_ gg. of the' analysis --
1
'+-*. W
.. ~'...L.- . .
'" -~ ' ' ~ ^ - -
i 1
l 6947 l david 6 1 O You.sey table'A-l?
- 2 1. Table 1.
3 O This is entitled Appendix A, combustible Mctoricls?.
e
~ .4 A Yes. Appandix A, Table 1.
i 5 Q And you have ihntified the combustibles in 6 this appendix?
7 A Yes, we have.
e O Can you explain how you did that? l l
g A By exulysis of what -- J 10 0 Just a minute.
11 CEAIK1AN WOLFE: Off the record. !
l 12 (Discussion off the record.)
g3 CHAIRMAN KOLFE: On the record.
14 MR. FARRIS: I am going to object to this 15 line of questioning. It is not reclly in response to 10 anything that was brought out on cross examinction. The 17 document pretty much speaks for itself and I also object 18 to the witness going through and reading portions of the 19 document. It is in evidence, I think. It has taken up 20 time needlessly.
21 I raised some points on cross examination, an?.
22 Mr.Gallo should be limited to addressing thoss points, if 23 he wants to, but I object to -just going through in this 24 self-servi.ng narrative about what this document is all about.
25
}
.c. -.. :,- I, l
1 1 david 7 b., a_.a@ --
o hair: nan , yee' "A
- y un :
- Mole !
2 i question of the analysis of the Elack Fox stction fror- .
s 1
- a fire protection standpoint was questioned by tht. 1EC 4 1
4- I staff. This line serves tha purposes of de.cnctrating that ,
5 l \
in on -- on redirect thct analysis has been made. { l 6
I might also point out that Mr. Parric suggested l l l :
7 i !
with Mr. Shon's agree 2.cnt that the applicants conduct 5 1
8 1 an cnclysis in citing from c. fire protection stcndecint l 4 I g i 1 for the Elech For station;the purpose of the redircot l 10 is to point out th t the ane. lysis has been made, and it i i
i 1
11 l l explains how it har been me.de. >
12 . .
4 I think the question is entirely port'.~nent on
}
ac i redirect. .:
14 M2. FARRIE : 1ir. Chairman, the point thatwas 15 j in iccuo yesterday it whether it has been annlyned from -- ,
1C ,
for possible rtraifientions of an a::porure fire, .n/ T i
a n. f ti think if Er. Ga'.lo vnnts to get into that, I have no !
18 objection to that. That certainly was a point on 19 cross eneT.ination. .
20 l I think it ought to be limited to that rather I
than the rezbling narrative, going through the fire hasards 22 analysis, some of which hac no reicvance to the points in s
2a l
- contention. -
24 i i MR. G;.LLO: Mr. Chairman, I was indaci doing 25 l
- thr.t. Th firct cuep is what the witness has clready '
I l
., i U
~.. ._ _ _
6949
'datid8 1' testified t6.
X 2 I will tie this to this line'of questioning, 3 to this witness's concept of thetype of design bacis 4 fire he used for the Black Fox station. I l
5 - MR. FARRIS : I withdraw my objection in that ]
6 case then.
~
7 BY MR. GALLO:
1 8 Q Dr. Cox, we were at the point when you said 9 that in this analysis it was important to identify the 1
10 combustible material.
11 A That is. correct.
12 0 And I believe you had indicated that such an 13 identificatbn was in Appendix A of thnfire protections 14 analysis.
15 A Yes.
16 0 can you explain to ne by giving me an exexple 17 how you identified the ccmbustiblec within these 18 fire areas?
19 A By example, I can pick, for instance, the example 20 of the standby gas treatment room. These rooms are located 21 in the redundant rooms, the fuel rooms. The design for 22 the standby gas treatment system has been completed.
K 23 The preliminary design, based upon the preliminary g design,.the combustibles.in that particular area can bc c
25 identified.
.--wymw +--9t* y -e M Yu-T=- T- *T -#77
6950 david 9 1 They are identified in the fire h:.:trd:
2 analysis.
3 0 Can you show rae that. t
, .i 4 A In the fire ha::crds anc.lvsis. \
5 0 Yes. ,
Gnd 7 6 7
8 I
9 4
10 11 1
1 12 !
t i
13 14 i.
?
15 t 16 O
i 17 l
18 19 20 21 22
' i b $
24 1 25 i
f i
BU8 erl 6951 1 A Tnis is fire zone 4 on page A-4 oi Tabls 1, and
2 in Tabis 1 the combustibic materici is identified as 3 2000 pounds of chercoal cable insulation, electrical equip-4 ment.
5 0 Can you give an example of the fire where you 6 concluded that transient combustible material"was introduced?
7 A There is an example of that in the railcar 8
area, the fuel car, and which we accepted as a transient in g that arca, the possibility of a boxccr in the aree..
10 0 Can you show me where that is?
A Fire cone 1-E on page 63 of Tahic 1. Uc identified gg 12 a railroad car.
I O That is fire zone 1-B where you assumed that a 13 14 railr, cad car would be a type of tansient of combustible 15 material?
A Yes, the railroad car and the combustibles are 16 37 transient matericis.
Q How did you determine as you went from firc cono 18 to fire zone what combustibles might be in that area?
19
.A Primarily the determination was made based 20 21 upon an opinion as to whether it was possible that a transient might be left inadvertently there, or whether 22 the posibility wa: good that it wouldn't, or thct the 23 o casi n could possibly arise, it might be left there.
24 O S y u made a judgment as to whether or not a 25 I
l ar2 6952 1 combustible transient, combustible metericl, r.ight be in r.
6 l
(
' 2 particular fire arac?
f 3 1 That is correct.
And how did you obtain c decign bacis fir; for 4 C f
5 thct pcrticulcr -- let's say fire cone 1-B. l 6 A The design basis fire, and there may b3 somo l
l 7 confusion here - the design basis fire is postulstod with E c.v.ceptiens that have been noted in the fire hczard analycin, l
D l. that ocsenticily all combustible material in the c.rez is !,
I 10 i
consumad, is burning, and sac get de peak fire cr a racult of j l 1 (
t i
11 l that, 4 i 1
l 12 G When you say all combustibic mancrici, is a j l
13 combinction of the materici that ic normally there pluc cav 14 trancient mttarial you think chould be there?
i I
A Fluc any transient materic.l. Uc don't pontulate :
15 !
16 i hov it rtarted or anything else. Ws postulate that in is
- 7 there and burning. >
l i 18 0 Ho's are you able to calculcte the heat rcte from f I
I 19 such a fire?
20 A The 1ect rate is determined based upon the hect t
21 generation for ecch material and for each materici there 22 cre tablec uhich cre used in order to determine what the g heat rate is as a result of com? particular product burning. i i
l, P y 0 And this heat rcte then becomeo a design basis ;
q
.:n
" 4 for a ccrticulcr fire; is that correct? '{
- 1
- i u I
6953 sr3 I -A Yes, it it.
2 O Let's go to the cable spreading room for the 3 Black Fox Station.
i 4 First of all, how many cable npreading recms are 5 there?
6 A For two units, there are four; two cable apreading 7 rooms in -- let's say there is one cable spreading room, 2
8 they are separated by a fire barrier, so you might call it 9 two cable spreading rooms.
10 0 Can you identify the safety divisions that run 11 through -- striho that.
12 What are the fire area designations for thess?
13 A 24 and 25. ,
14 Q What safety divisions run through fire crea 24?
15 A You make sure that 24 is on one side and 25 is 16 on the other.. Fire area 24, which is on the left side, is -
17 indicated by Mr. -- Mr. Engmann's Division -- by Mr.
10 Engmann as Divisio'n's 1 and 4.
19 0 What divisions are in the other fire area?
20 A 2 and 3.
21 O What type of fire suppression systam= are included' 22 in 'this cable spreading room?
i 23 First of all, with respect to a fire wall?
24 -A Well, the fire vall is a barrior that separater.
25 It is not a suppression cystem. The suppression system is "-
t P ? - t 7 *--P
- ~
._~.;..;~.~._.~.-_-- - . . - - -- - . -.
I ar4 6954
}
we have incorporated a water sprinkler rystem,nn automatic t
e- '2 sprinkler cystem, . in each of the two cable crEas.
{
l 3 G. A sprinkler cyctcm in each of the tuo cable areac? ; ,
' I 4 A That is correct.
f 5 O The cable areas are divided by a fire vall? i 6
A Dy a three-hour rated fire barrier, yes.
-Q Does this separate redundant safety divicions?
7 A Yes, it does. '
8 g O Are there any fire clarms or detectors thru indicate the -- !
10 +
l A There are also detectors. i 11 i i
O Can you tell me what kind they are, or how th 9y j 12 i
function? i la.
A Yes. The ddactors are ionization detectors.
14 ,
l They function as a recult of detecting the products o# -
15 ;
16 combustion that may result to a result of a fire in the f cable rooms. $
17 3 Q As I understand your testimony yesterdcy, you i 18 i t
indicated in answer to counsel's question that you did not 19 assume any transient combustibles in t$.c cable screadine - -
f i
20 roem; is that correct?
21 *l t
A No. We did not make that assumption. .
i 22 i
But let me say.yes, we did make that assumption.
23 0 As I understand your testimony -- well, I won't 24 I
charceterize it. Would you stato acain the basis for thct i 25 .
i I
- 4
-yw,- 4 m., m.,ee-. sa w. ,*wr
ar5 6955 1 assumption?
e 2' A Well, possibly two years ago, I could not have --
3 I wouldn't make that assumption. I wouldn't c:re to that con-I think it is e::tremely important in this particular 4 clusion.
5 area to recognize the changes that have taken place in control 6 and access control. This is primarily as a result of the y security systems.
8 I have been associated with reactor operations 9 enough to know that under very ctrict controls, you can 10 expect about anything to happen.
I think that in this particular case of the 11 12 cable spreading room, where we again have barricrs to prevent the access, where we have insignificant or unc=pected -- it is, 13 i
14 not a pathway for traffic, it is not c trafficwey here, l t
15 with the loched doors, with the controlled accert, and the l accase is controlled not only -- you have to have a key ct.rd, 16 I
- 7 you have te have permist.icn to go into the crea r you have to.have a need to go into the area.
18 0 Dr. Cox, you mean to tell me that a new 79 20 empicyee at the Black Fox Station just couldn't wcik into the cabic cpreading room?
21
!!R. FARRIS: Objection; leading question.
22
's ! R. GIII/J : Strike that question.
23 U #'U 24 0 Could a nov employec walk into the cable 25
_. f ,
s>
ar6- 6956 '
j spreading room?
A (Witness Cox) No.
~
2 t
3 0 Eny not?
A Because he would not be authori=ed to get into 4
a m. e n uols M cP, I have a h ad to 5
w uld prevent him from doing so. The secured system will 6
prevent him from getting on the site, and in this crea r 7
un s e s g ne ug a 8 a ning session c M -- un d he )
has been scraened. Uc hac to be screened. l 9
3 g O Wouldn't c hey get him into the ccble eprcading room?
A No, c key wouldn't open the door. In order to 1
opan the door, you hcva to have essenticily two things, as far as the employee is concerned:
He would have to have a key card, and he vill also have te have a knowledge of cn individus.1 code whien l 16 :
is not written ocun'cnywhere. This ic a code identification !
17 code. Until ho has completed -- until he satisfies the 18 security system's needs, in order to open that access door, 19 he icn't going to get into that area. I 20 l O Want are those security syctem's needc? :
21 h The security systems, the cecess control', and --
22 ,
the rcccon I hocitcte here about talking.chout the security }
23 !
syctem is becauce there is to some extent propriety informa-24 tion, and the information that:I am going to talk chout, I , ,
25 l
[ , 4 a t !
1
- - , , . _ . , - . , m m 4
1 l
ar7 6957.
1 :believe, is common knowledge as a result of information ;
l
- '2 that has been published on'the record, and I am just a littic 6
1 3 ' bit hesitant about tr.lking about the computer cystem.
MR. GALLO: I will strike the question.
4 99 5 BY MR.'GALLO:
G- What criteria exists for getting a key to the 6
7 door to the cable spreading room?
A The criteria is that an employee would be 8
9 personally screened. IIis background will be screened. IIe 10 will have to be' assigned a responsibility in that particular area. IIe will have to receive his supervisor's approval to 11 be in the area, and this is primarily the reason that he 12 would get a key to this particular arca.
13 14 0 It is my understanding that he -- did you 15 testify just now that he would havo to have an assignment in the cable spreading room?
16 A Yes, he would have to have an t.saignment there.
97 Q Mr. Engmann, can you tell me what systems are 18 in Se cable apreading room?
19 A (Witness Engmann) Most of the cable spreading 20 ro m is dedicated to the tray system that supports the 21 wiring t the control room. There are several inverter rooms 22 as part of the fire creas 24 and 25, but the overwhelming 23 g amount of equipment in there is electrical, and it is g primarily cable tray and cabling.
l>
l - , ,- -- . . - _ - .- ,_
2 ~.. .- a _ r.m-m-. . m -_ . _ _g m . ._ m l
- arS 6958 g
O Based on your experienec, what type of trained
" 2 person might be required to go into that cable cpreading l room as a part of his normal dutics et the Black FC:: Ecction?l 3 t A The cable spreading aron itccif, the trcy 4 ,
, system,.and the cabling is essentially static. Once in ,
G place, there is no reason to displace it for any maintentnce I or surveillance testing purposes. Based on my cxperience, I 7
wouldn't anticipate any need to go in there in the next 40 .
6 I years, quite frankly. There are coveral inverter ronmo in 9 1 those two areas. Thoso inverter rooms are -- the ce;uipment 10 l in those invarter rooms ic safety relcted.
,t.
i Eowever, it tende to be fairiv reliable, fairiv --
' ~
f 12 it is capable of unattended operation, obviously it is equipment that does not need to be accessed on a dcily bacio.
It has monitoring deviccc so that if thero was a probism, in 15 would be brought to the attention, to the operator. It is ,
15 j not sub j ect to those hinds of problems on a frequent bacir, 17 I outside of some surveillance tecting interval, which ons 18
'could cpproximate monthly, I wouldn't see any reason to be in thoso inverter rooms execpt on some kind of maintenance 20 check every cin months or a year.
21 So, all in all, I would not anticipats that you 22 would cce personnel in thooe two fire areas any more 23 frequently then perhaps monthly.
24 nf 9 wel 25 ii fcle .
-+ -- -,
-..,, , , - .--.y- -
---,y
' ~ ~' -
-, L -
.. J.: : TJ L ;.- ;
6959 10WEL we1 1 I Would you see any need to do any welding in the 0
(~
cable spreading room of Black Fon?
A Well, the only pince - the only type of equipment
- ' -where I could see welding being done after the initial 5 installation would be accomplished on cable tray supports.
6 After the initial installation, because of the 7 design of the station, the fact that we design with cable 6 trays is so that m:)difications in cabling can be made in an S existing cabling tray, and because of that design concept I 10 can see no reason they would be doing welding in that room.
1 II O Is it your testimony that all the welding would 1 12 take place prior to operation, is that correct?
, 12 MR. FARRIS: Objection.
14 MR. GALLO: Striko the question. I'll ask a IU different question. -
l 16 BY MR. GALLO: l II 0 You indicated that welding would occur during the i
16 installation of the cable spreading room. When is that? l IO A (Witness Engmann) The. installation of the cable i i 2"" I tray and supports in the cable spreading room will be 1 21 l' accompliched much in advance of any preoperational testing, j ,
l 22
.! which, of course, is in advance of fuel loading and generating!
l li '
" 23 station operation. ;
{
\
24 i Q Dr. Cox, let's assume that one of Mr. Engre.nn's ,
11
- 25 monthly Ae.intenance inspections in required in tne cablo i .
)
i i i 1 !
- ~ - - . . - . - . . . . . . - - . . . -- - - - .. -
l 6960 ,
wel 2 i I spreading room. .Do you have any special procedures for
^ 2 maintenance in the cable spreading room?'
3 i A (Witness Cox) Yes. There would be spccial .
,. l 4 procedures, i W Q Describe them.
6 A I can't be specific, because they have not been !
t 7 fully developed. But there certainly ic a special procedurc ;
i G ,
for access into it. That is that he will have to be cleared }
i i 9 for acceos, he will have to obtain permicsion for that entry.;
10 He will be monitored by a guard force, meaning the security i* 9 system will monitor his entry into this arca. !
i 13 In addition to that, we're concerned about a ,
,e 13 '
transient material. There is no reason to belicve that a !
l1l i 14 person entering the area for that specific purpose is geing 15 to carry a material that can be concidered of a combuctitic -
16 5 nature of sufficient strength'to cause a problem in that ;
i 17 .
i area. .
I m O Will combustibics be controllad, generally, for ;
10 the Black Fox Station?
20 A Yes, they will be.
21 Q. Can you explain how that rt.ight happen? l 22 j A Well, there would be -- prire.arily through j
, )
25 ,i administrative controls. Administrative controls arc f
i b: effective. And in particular instances not only administra- j t I 25 ' ;l tive controls, but security controls. I 6}
+;
i
- . i
6961 I
wel 3 I I night point out thct this opinion.is shared by
_ 2 otherc in the industry.
3 Q Can you identify who the others in the industry
. i A are?
5 A I have read numerous reports to this effect, 6 the latest being a report that was submitted to the NRC in 7 October by a group from the Institute of Electrical and 6 Electronic Engineers.
I D Q Do you recall what they said about the efficacy 10 of administrative controle with respect to cable spreading i I1 rooms?
12 A It was .their feeling, as c):precsed in this }
l 13 report, that administrative controls are effective, can be -
14 effective, in controlling combustibles. 7md I believe they 15 were talking particularly about this area.
I I
16 Q Dr. Cox, do you know whether or not the cablo 17 spreading room at Browns Ferry was separated -- ctrike that. l 18 Do you know whether or not the redundant systems, 19 safety divisions, in the cabic spreading room at Erowns 20 Ferry were separated by a firewall, a three-hour firewall?
21 A Yes, I recall that they were not.
22 0 They were not so separated?
23 A That's correct. l M '
Q Do you recall whether or not the spacing 25 requirements for cable t.rcys, cs provided for and required l
l l
l l
l !
J 6962 l wel '4 i I by IEEE 384 were met? i
)
- 2 1 A I'm not sure about that. I don't think that they i
? i,. were.
- \ )
4 I Q Can you help us, Mr. Engmann?
t 5
3 A (Witness Engmann) The information that I've ;
5 recently reviewed indicated that the vertical separation 7 distance as required b" 384 was not met at the Browns Ferry l l i l i
8 I cable spreading roon P Q Mr. Eng' " ;an you tell me whether or not the ;
W requirements of TEEN 383 concerning flame test requirements t1 i on insulation were met in the cable spreading room at I
l I
12 ; Browns Ferry? ,
l l 13 'l A A little while ago, a short time ago, I looked i i '
I 14 e at some of the materials that were used in the cable i h
1D i! construction at Browns Ferry. Soue of those materie.ls I i b !
M, am confident could not pass the IEEE 383 firme test.
- 7 n The one that comes to mind most readily ic 1Ep,,)'ipolyethylene. I know of no cable insulated or jacketed with Wh just plain polyethylene that's capable of passing IEEE 383 20 flame tests. !
. i 2; d MR. GALLO: That's all I have, Mr. Chairman.
a ,
L al! CHAIRMAN WOLFE: Any recross? ,
t PJ 3 MS. HOODHEAD: Yes, I have a few questions. ;
I PJ - RECROSS-EXNCNATIOli I. t .
21 !< BY MS. WOODHEAD: ,
! 2 O Dr. Cox, you said that in.your analysis of the {
{k i
. .- . . . . ~ . . . . _
5963 ,
wol 5 ,
1 i different fire areas for'the Black Fox Station you assumsd ;
}
. 2 lt that all the combustibles in the area burned. I
( ,
3 i In the cable spreading room did you assume thtt i
4 all the cahic in the particular spreading room that you were S considering burned in full flame along the entire tray?
6 A (Witness Cox) No, we did not. And this brings up .
l I
i l 7 a point that's extremely important. That is, I'm not sure { l 1
i 0 who has read the Hazards Analysis and who hasn't, but the f; Hazards Analysis very specifically identifics what the 10 criteria was that was used to design Black Fox Station. And ti i the particular criteria for the cable sprending room is i
i 12 specific'. in the Fire Hazards Analysis, and it's cpecified
- 13 in Section 3 of our response to the Branch Technical Position.
u a From the very beginning it has been our concern ,
tg that -- and our intention -- that the design criteria for ;
1s ;
the cable spreading room be in accordance with neg. Guide '
i 17 3 1.75 and IEEE 384.
I 10 I This was submitted in November, the uholo ha::arde
- 9 i analysis, and produces a firm foundction on which the i .
t design of the Station is based. ,I have identified that we 20 j t
l have taken exception or deviated from the Eranch Technical 21 \
]i.t Position. We didn't flag that with a big red flag, saying 22 l.I 21 "Here's a deviation." But we specified what we were doing, ,
{
p :
and in the cable spreading room, in the discussion in Fire j 24{J i' w.
-. ! Area 24 and 25, we identify what the design basis fire is, ,
! i l 5 !
O i
, - - - . ~ . ~ . - .- . . , _ _ . - - _ . _ .-
6964 I wel 6 j
.1 In that design basis fire we take credit for a 2 separation, and that has been the design basis for the
' I i r 3
plant. -And we postulate complete consumption of one division) 1 8 i 4 not everything in the cable room.
I 5 -Q Is'it true that a full-fledged fire which would i 1
-G ! consume all the cable in the cable tray would be induced l 7 only from an exposure fire, and not from an electrical fire? 1
, 1 Sl A To the best of my kncreledge, and I haven't !
1 studied this. ca a great extent, but to my knowl' edge it does )
9 l
to require an exposure fire for a complete combustion in the 11 cable area, yes.
I l
12 0. All right. , :
I i i 13 You say that in the Fire Hazards Analysis you -
i 14 took exception with the Staff's position in several areas, i i
15 and that you stated so within some sections of the Fire 16 Hazards Analysis.
8 17 As I recall, you made no effert to justify you-i to exceptions to the Staff positions, is that correct?
t 19 A Maybe some background information is necessary 20 here, if I may.
21 We were asked by the Staff, or by Pso, who 22 received a letter from the Staff, that we should prepare 4 23 ,
a conprehensive Fire Hazards Analysis for Black Fox Station.
24 And the guidelines for that were Revision 0 of the Standard 35 Review Plan - or Branch Technical Position 9.5-1, Appendix 1
.a .. . -.
i f
l 6965 !
i wol 7 !
I f A. j L
c E That's what we did. We addressed each specific i .
i
? position. ;
i 4 Now, it isn't customary to go'into a lot of 5 detail of,why you did it at that particular point, so we i
G~ .didn't feel that justification was necessary. l 7 We were asked what our position was. We told j i
8 them what our position was. t O 'O You said you were told to use the Rei-ision 0 of ,
10 y{ the Branch Technical Pocition 9.5-1. Who told you to tre 1.
11fI, this?
t if. ' Public Service of Ok1choma told us, and it was f A l l
l IF l in a letter that they had received from the Nuclear I !
1A t. Regulatory Commission.
(!
15 " Q All right.
h 4 h
16 ;! Are you familiar at all with the procedures of .
J [, presenting information to the Staff which will be incorpor-1C 'j ated or would be part of the e5AR for the utility? -
t t
6 10 E', '
A I'm quite familiar with PSAR material, and I'm !
i i 20 .l, also familiar that, by request.of the Staff when we {
t h I E! !! submitted deviations in that particular case, they said i
[
1.2 ll we would like justification. And we presented justification ;
i ll
'i 1.3 [ uhen'they acked for it. ,
e E- They didn't ask for it here. Perhaps in ;
- 2 ,
hindsight it would have been nice and better and everything 1
(
l[ -
i i; i
. . . - . m. ._ . _ . . . . _ . _ _ _ _ _ . . . . _ _ _ _ . . _ . . _ . .
6966 wel 8 1 else if we had. But we didn't. We had no reason to believe l 2 they wanted justification. They acked for our position, and l 3 that's what we gave them.
4 0 Your understanding is that the Staff will accept 5 any deviation from Branch positions unicas they ask for ,
6 justification?
7 A No. We weren't asking for - we were presenting 6 what we were doing. It is customary for the Staff, upon 2 review of this material, if they don't agree with it they 10 will ask questions.
11 Well, we presented this material in Novamber of 12 1977. We have not received yet the results of any review. ;
13 He don't know if the Staff has a question.
14 And so wo presented the material, and absent anything else, for us it's acceptable. j 15[ t 15 Q You assumed, uithout any communication with the l
17 Staff, that your deviations which you have set out in your t i
1 18 Fire Hazards Analysis, were acceptable, had been approved, 19 or would be approved unless notified?
20 tiR. GALLO: Objection. The witness didn't 21 testify to that at all. He said that they subrdtted the 22 '
Fire Har.ards Analysis Report in November of 1977. It j.
22 ij represented an acceptable position from the standpoint of
- I 24 j PSO and Black & Ventch. And after more than a year, they
{
I i
_ 2r- { haven't heard word one from the NRC Staff. !
l 1
i 3
$ I
a 6967 f )
wal 9 I If there's any incumbency here, it's incumbent ;
,- E upon the Staff to do comething. That's the uitness' point.
3j .
He assumed no approval or any reaction by the KRC Staff,*one 4 way or another. ,
5 That was his testimony. The qu stion mischc.rac-6 terizes the witness' testimony. j 7 MS. WOODEEAD: Mr. Chairman, I did ask es:actly {
C the question as to what he assumed when he wrote thic Fire .
F i Hazards Analysis without justification. That was my question.
10 4 MR. GALLO: That's a different question.
11 l CILLIRMAN WOLFE: May we have the question read tE . l back, please, Mr. Reporter?
i3 i (Whereupon, the Reporter read from the record, r!
12E! as requested.) -
15 THE WITtTESS: No, we didn't -
ll CHAIRMAN WOLFE: Wait a minute.
70 a[
17 . MR. GALLO: Mr. Chairman, my objection is based i
d SE il on the point that the question mischaracterizes the witness' v
19 J testimony.
- i He's answered two or three timec now what he 20 o
M f, e
assumed for purposes of'his presentation. He did not ,
it EE I testify with respect to any presunption of what he understood *
- \
i
'- 2.5 to be the state of the mind of the Staff, tihich i~c what the U [6, question asks. . j l'
nr{ CHAIRMAN WOLFE: The question was: What did he
. t c '
- t .-. - .. ._ -. .. .. . - - . . -.
l l
6968 wel 10 i
1 assume, beyond what he's already stated.
2 I think this is a fair question to plumb this l
\,
3 further. l 1
4 Objection overruled.
5 WITNESS COX: No, I did not assume approval. And 6 I didn't point out in justification of what we -- what we 7 .did present in the Fire Hazards Analysis may have been a l 0 deviation from what was asked in the Branch Technical 9 Position, but is not a deviation from what we considered, by j t
10 I Staff guidance in R3gulatory Guide 1.75 and IEEE 384, as l 1
11 recognized by the Staff as acceptchle criteria. I l
i l
12 And so what we presented was what we felt, as i l
}
13 accepted by the Staff, was acceptable criteria. l j 14 It was not in accordance with the Tranch ,
t i
15 Technical Position, but it was, in our opinion, from the 16 information that we received, acceptabic- critoria to the i
17 Staff. [
16 BY MS. WOODHEAD:
f 19 0 Isn't it true that Reg. Guide 1.75 and IEEE 383 20 and'384 are focused on electrical subjects, rather than 21 fire protection systems?
i 22 A No, i
23 0 No? l 24 A They are focused on electrical subjects, but the t
- 25- object of the focus is fire prevention. Why do you separate i
u
f
< t'
! 6969 !
wel 11 I l
I cable to a certain - l i
- 2 Q My question, Dr. Cox - !
- i. i 3- I MR.'GALLO: I'd like to have the witness conplete i e
4 his answer.
5 , MS. WOODEEAD: Sorry. ;
i 3
6 CHAIRIOLN WOLFE Go ahead, Dr. Cox. !
l 7- WITNESS COX: And the reason I wcs trying to got I i
in is that because of the whole idea of separation is fire i 6
Sq prevention.
q .,
10 l And while it may not say that in c particciar I
t 1 *: ti case, I believe that 1.75 and 384 are geared for separation 10 f to prevent fire; spread.
i ;
if !! BY MS. WOODHEAD: -
i o
16 h.i Q My question, Dr. Cox, was whether or not these '
l' 15 II,, IEEE standards and this R3g. Guide 1.75 are concerned with l.
d !
~. 6 fire protect. ion, rathar than fire prevantion. .
t
'?_f A No. Well, possibly so. It's both. 'It's i
<> , i
'F
. fire protection, but it's also fire prevention, becausc you j i
if' ! want'to prevent that fire from spreading to another area. t 5
i 21 -li So it's both.
, j 21 Q Quite true. But icn't it correct: to cay that l i
Cf' the words, fire protection" is a much more comprchensive {
I;3, term? "It would include cuch thingc as fire protection ,as ,
?.c I well as fire suppression. Would that be correct?
._ 2F L MR. GALLO: Object. The cucation is unintelligibl2.
- i i
[N 5' e
.e
- - ,. ,------,a,
2 -. . -
6970 wel 12 1 ::t uses fira protection in two contexts.
- 2 CHAIRMAN WOLFE: Rephrace your question, please, 3 Ms. Woodhead.
4 MS. WOODEEAD: All right.
I o '
DY MS. WOODHEAD:
3 0 Dr. Cox, is there a difference between fire 7 protection and fire prevention? t 9 A (Witness Cox) I'm not sure. In the way I think 1
I e or it, fire prevention is a part of fire protection. l 10 0 True. Would a fire brigade system, or water l'
f sprinklers, or anything in a plant system designed to put ,
\
t !
12 0 out fires be included in fire prevention?
I .
13 ( L That would be primary fire pre :ection or !
14 j suppression.
15 j Q Pight. Do is it correct that the words fire i
if p protection would include various designs, activities, el 17
~'
et cetere, concerned with the possibility of fire?
19 l A I'm sorraj. Would you repeat that?
19 (Whereupon, the Reporter read from the record, 20 as requested.)
21 THE WITNESS: Yes, I would say so.
22 CHAIRMAN WOLFE: We'll have a ten-minti recess
. 23 l at this time. ;
!l '
. Barb fis 2/. (Racess.) f EI[
i, a
i- ,
6971 I
tape 11 1 CID.IFJG2 WOIEL : All right. Ms. Ecodhead?
'~ david.i 2 BY Hs. WooDIEAD: }
I L
Dr. Cox,~before the break, we were discuscine 3 g i
- l 4 the difference in terminology in the use of the terms 5 " fire prevention" and-" fire protection." l 6 You mentioned that you had used Reg Guide 1.75 l J
I
'7 and IEEE criteria. l l
8 Continuing on that line, can I ash you: is ;
9 it true ths.t criterion three of Part 50 of 10 CFR is i
i 10 concerned with fire protection rather than only fire li prevention?
i 12 A (Witness Co::) Yes, that's true. !,
13 0 Ic it true that in your fire hazards analycis 14 by the use of -- by relianco en Reg Guide 1.75 an6 the IEEE 3
?
15 standardo your analysis emphasized fire prevention and did i 16 not cor.77.etely analy::o uith the Eea cf fire protection as ;
i cor out in the branch technical pocition? I 17 18 h Fire prevention is a part of fire protection. - You 19 seen to be cpeaking of them as two different terms, but ;
fire prevention is a part of fire protection, so while 21 one is r.ot all inclusive, one is certainly a part of the 22 other one.
23 And in further response to your question, while- i 1
24 we used 1.75 0.nd 383, we didn't stop there. That was the !
1 35 design criteria,. but. we continued as in depth meccuros, l
}
,l-- . - - - - ,- , ,- , , , - , .w--, , - - , , ,
. . . _ _ _ _ _ . _ . - . . _ _ _ . - ~ . . . - .
6972 david?. 1 which is part of fire protection, to instcil the r" 2 suareccion system in there and to put the fire barrier 3 in there so that we went beyond the criteria chich we 4 established in the fire hacards analysis for fire 5 protection in that area.
6 Q Do I understand you to say that installation 7 of a fire suppression system such as water sprinklers or 8 some similcr suppression cystem would be beyond the 9 criteria of the branch technical position?
10 A It is beyond the sepcration criteric.
11 Q True. Let me ash it c different way.
12 Is it correct to say that in your understanding 13 the branch technical position which gives guidance in a 14 possible way to acceptably moet criterion three includec 15 various means of preventing firas as well as suppressing 16 fires that might occur in spite of prevention systems?
17 A Yes, that's true. Amd when we addressed the gg branch technical position point by point we said, we will 19 comply -- comply. We will provide cuppression systems.
20 So, we, have met that particular aspect of the 21 branch technical position. We didn't daviate from the 22 branch technical position except in the major area of
\-
23 defining this ' design criteria.
24 If you go through all of our positions, you 25 will read page after page where this requirement will be
t 1 6f71 I
david 3 met, and thtt is consistent til through it. i 1
2 THere tre places -- 2.nd thir .'.s c mnjer placc -- k 3 that we hcvc deviated. And we have ccid there that this 4 is a deviction. We complied with the branch technical I i
5 Position as far as suipression systems.
1 s
6 0' I think from your previous answers to Mr. Gallo 1 1
1 7 that you. indicated that in those areas where ycu did nor 8 consider e decign basis fire, you baced that analyric of ! '
1 I
that hind of analysis on your opinion that there would j 9
i 10 be no possibility of an ca:posure fire.
t
.s jg A We analycod based upon our cnalysis. We arrived i j l
12 at the conclusion that it not being a picco for ctorage of ,
i i
~ combustibles and with the possibility being se remote of i 13 i l
14 trancients being there, it was our conclusion that it ;
15 would not be an expecure fire in that aren. {s 0 Dr. Cox, cre your adminir.trative controlc 16 which you cxplained in detail at Mr. Gallo's cucstioning 37 i
different then those administrative and security controic !
18 I
gg ' enforced in operating plantt today? {
l A
I am' afraid I haven't seen any.
20 0 you don't know if there is a difference? !
21 i i
- 22 A I would not know. I do know that the administrative; 1
ntols - enforced today at operating plants becauce of l 23 9 security mecaures cre certcinly different then they nighu {
24 l
have been si:: months ago or a year ago.
25 ;
)
. .i
6974 6 avid 4 1 O In those areas where you did not une a
~
2 design basis firc for your taclysis, did you imposs any ,
3 extraordinary procedural or administrative controls?
4 MR. GALLO: Objection, the question was: in 5 those areas where the witness did not use design basis G fires.
7 The witness testitied he used design basis 8 fires as determined by him in his report analysis.
9 MS. WCODHEAD: I withdraw the quertion. That 10 is correct.
It EY MS. WoODHEAD:
12 0 In those creas where you did not use an
, 13 exposure fire as your design basis fire, did you impose 14 or describe more stringent administrative procedures?
15 A (Witness Cox) No, we did not.
16 0 Dr. Con, are electrical engineers fire protection 17 experts?
18 A They cocid be. .
19 O HOW Go?
20 A I consider Gary Engmann,an ciectrical engineer, 21 a fire protection expert in the. areas of . cable.
22 0 Hou does one become a fire protection expert?
i
A one becomes a fire protection c:: pert by 23 24 experience, trcining,or both.
25 0 True. Are you a fire protection expert?
._. .. --. . .-. = _. - _ . - - - - . - _ _ - .. -
-._.. ;... .:-.-.--~,--.,.- '
E*15 1
david 5 g A By what definition?
2 C Ey experience or training? j 1
,i 3 A. I feel that I an an expert in some areas of j
.i 4 fire protoculon by experience.
5 0- You have had extensive experience in designing fire protection systems?.
6 l A~ I have had - extensive -- I cm cfraid that I 7
g has me lost.
Q Well, significcnt, more than one plant, I would j 9 .
i assume would be comething that would occur over several l 10 l
}
years. .
11 I 1 I A Yoc, i 12 1 g O Over several years you have had significant e pcrience in fire protection design?
14 l
A I have been associated with fire protection 5
" * -" u Y* '
16 one plant, end 11 18 19 20-21 i
22 s
23 i a4-a ll l
6976 BW12 arl g
Q Could you' identify the plants for us?
A Yes. The plants are Black Fox Station, and
.- 2 th University of Missouri Research Reactor Facility.
3 Q Also in two plants then that -- one constructed 4
plant and --
5 A You mentioned design experience.
0 Right.
7 nsider fire protection experience considerably 8 1 more than design, and I think operating experience associnted g
with the responsibility for fire protection and supervision certainly weighs heavily on thtt, and that goes back over 1 l
- 11. ,
the course of 18 and 19 years to my experience back at the 1 12 General Electric Vallecitos General Electric test reactors, in
? G which I was responsible for shift operation, and part of that responsibility uss fire protection in which I received training 15 from the General Electric Company on fire protection, and 16 also I guess one of the ways to learn a subject is you have 1 17 l to teach it, and even though I wasn't experienced at that '
18' time, I gave lecturcs to my shifts on fire protection.
And I tHnk that all contributes in experience to a point 20 where -- and it contributes to the point where I felt that 21 I could accept responsibility for firo protection.
22 0 Could you compare the size of your research reacto:
' 23 to tho'aize of Black Fox Station, when it will be built 24 and constracted? i 25
t b 6977 1 !
ar2. l 1 A The physical size or -- well, the size in what 2 !
context?
I i
3 0 The area. !
- l 4 A All right. The area for Black Fo:: Station ice !
t 5 I think, 2206 acres. The area for the University of f
6 Missouri research reactor was, for example, 10 acres. That l l
7 doesn't necessarily -- I don't consider the University of 8 Missouri research reactor facility in 'he c same context as one 9 might concider a research reactor facility, because ths 10 University of Missouri research reactor is a 10 ruegavatt.
11 That is not big compared with 1300 or so magaratts of q l
12 electrical power put out by the big power plante; but the l
- 6 13 same principles apply. It is a 10 megawatt reactor. It hac 14 maintenance, it hac fire protection, it has a cooling ,
15 system, everything applies to the big reactor is there- at the University of Missouri reactor. Sice isn't nacericl, in 16 17 my cetimation.
18 0 Size of the plant ac well as the power output 19 makes no difference in the fire protection cystem necesse.ry?
LO A Fire protection is just ac imp'ortant at the 21 research reactor facility as in the power reactor, and vice 22 versa.
23 0 My question.was, is there any difference betwoon the considerations involved between a small 10 megawatt 24 25 plant and a 1300 megawatt plant?
l l
ar3 - 6978 !
l 1
l 7
A No.
Q No difference?
2 A No.
3 0 Dr. Cox, you previously stated that you used 4
Eranch Technical Position 151, Rev. Zero as a guidance.
5 Do you happan to have a copy of that with you?
6 A I don't have it here with me. I do have --
7 MR. GALLO: I will furnish the witness a copy.
8 (Counsel handing document to witness.) l 9
MR. GALLO: Will he need Appendi:: A?
10 MS, WOODIZAD: No.
11 l BY MS. WOODiIEAD: l 12 l
Q Could I ask you to turn to page 951-14.
13 MR. GALLO: Can I look over the witness' shoulder 14 at the book? I gave hire ninc.
15 WITNESS COX: Let me clarify that the revision l
16 )
I have is dated May int.
17 DY MS. WOODITEAD:
18 I O That is correct.
19 A (Witnces Co::) The pages aren't numbered that way.
20 0 That is what I wan afraid of. The page numbering 21 is different. l 22 MR. GALLO: Why don't you use this ccpy, if that
' 23 is acceptabic?
MS. WOODEEAD: Well --
25 (Panee.)
_ _. . . . ~ , - _ . -
I 6979 ar4 g 3Y MS . WOODIIEAD:
1 2 O On page 14 of the Dranch Technical position, which j I
i 3
you have in handr Dr. Con, there is c footnote at the I bottom, footnote 1.
4 5
A (Witness-cox) Yes, I see that.
6 O Could you read that footnote for me?
A " Designs or methods different from the guidelines 7
set ut in this document may be e.eceptable if they provide 8
fire protection canparable to that reco=menfed in the guide-g
. lines. Suitable basis and justification must be provided ,
10 for alternate approaches to establish acceptabic inplemente-11 tion of design critorion 3."
Q Dr. Co%, I believe you Stated previonCly that although you were well aware that in the fire hazarde j 14 1
analysin you differed with the Branch Technical Position in l l 15 1
some areas, you made no attempt to justify it or enplain it, becausc.veu had not heard'from the Staff, you had had no 11 l
questions from the Staff, and that your understanding was that if the Staff disapproved of your design, they would notify you.
Isn't this a contradiction of your underctanding, .
I 21 given the fact you are familiar with uc?
22-A Let me EE.y. this :
23
~
Wa did not say justification and give justifica-24 tion. I believe that if you read the firo hazards annlysis, h 25 .
[
i 1
, 1 i
l l
ar5 69S0 5 l l i
1 there is considerable discussion there, 'and I don't know 2 what defines jueification. I have not said that there in }
3 juctification outlined. I believe it is possible to inter- l 4 pret juctification as a thorough discussion, . and that is !
]
5 L what we did. He made a thorough discussion of what we.did 1
l 6 in the fire hazards analysis, and I believa that I can 7 call that justification.
8 I didn't think of it in terms of saying here is 9 justification, but I do believe that the discuccion that ; )
i l 10 we outlined in that particular crea could very well constituto gg juctification. i l 12 O Are you changing your previous testimony whera 13 you caid that you had stated a different position without 1 1 14 justification? l i
No. I believe I caid that ue did not provine 15 A
16 justification, and by that I mean we did not say as us huva often dono in the pSAR, whsre we take exception, hers ic 37 gg the exception, underneath it here are the words justification and outlined, and so we did not provide juaification in 19 i
20 that context.
l 21 I do believe that we can consider the discuscion l
f the fire hazard analysis a type of justification. ;
21 1
' Whethar-it is adequato justification, I don't know; but I l 23 g think we can consider that.
O So your testimony today is that although you did ,
25
+
l l
, - - - - ,. . . _ _ , . 7 #,
6981 ar6 1 not previde a formal justification such as you might have l
)
~
e 2 provided in the past in some other document, you did subir.it 3 some discuscion with.your --
4 A We submitted considerable discussion about what 5 we were doing in. that particular area in the f'.re ha=ards 6 analysis, and while we did not call it justification, I y 'believe that it can constitute this justification.
cnd 12 8 9
10 11 12 13 14 15 16 17 18 19 20 21 22 23 24 25
- r -- w - M -- 4 3. j Tr f F7
. - - - . . . . - . - . - - . . . . . - . . . - - . - - - . . . . . . , - - - - . - ~ ~ - - - - - - -
,-- - - 1 l
i 6922 l 9
O Do you r call that in your discussion of your tape 15 e 2 deviations from the branch; position that you discusced ;
. avid 1 !
3 whether or not your deviation would give protection j comparable to that set out in the branch technical i 4
p siti n? { l 5
l l A .We did not, j G
Q Could I direct you once again to page 14 of 7
the branch technical position: I believe when you read it j 8 t 1 i i g
previously we stated the first sentence where it stated deviations could be accepttble if they providad fire j to g protection comparable to that recommended in the guidelinos. l 3 MR. GALLO: Objection. I 12 DY MS. WOODHEIS:
0 You juct stated that your explanation -- your 34 s i "
discussion in the fire hacards analysis of the deviationc 15 I
did not attempt to explain whether or not your deviationc i 16 :
I uould previde' comparable fire protection. .
17 - .
t MR. GALLO: Objection. Mr. Chairman, thin I
line of questioning is really immaterial to the question i 19 j .
, i of'whethdr or not a satisfactory fire analysis exicts for 9 l l
Black Fox station. t !
21 l I have been patient while we went through the exercise of determining what the term " justification" means }
23 l and how it can be relected.
24 'f I think further cross alnn this line serves no 25 L
6983 david 2 1 uttful purpose for the ree:rd and should be stopped 2 at this point.
3 MS. WOODHEAD: Mr. Chairman, I believe that 4 Dr. Cox upon questioning by Mr. Gallo attempted to ascert i
5 that the deviations in the fire protection -- fire hazards
]
6 analysis gave protection entirely adequate. I am 7 attempting to find out why they deviatedron what grounds, 8 and whether or not there is a justifiable basic for 9 characterizing it as an adequate fire protection program 10 in these areas.
11 MR. GALLO: I thought the line cf questioning 12 was whether or not this witness has complied with the 13 format guidelines of the branch technical position, and 14 in particular the definition that unc read int:- the record.
15 Tnat is what the whole line pursued, and that is what I 16 am objecting to.
37 MS. WOODH51.D: I dicarree with Mr. Ghllo'r characterization on the line of questicning.
18 gg (Board conferring.)
CHAIRMAN WOLFE: Ihe objection is overruled, but 20 Ms. Woodhead, we are giving you c. little leeway here. I 21 think that you better get to the nuts and bolts of this, 22
~ ultimately, the specifics.
23 MR. SliON : If as you ctated what you are driving 24 a wa e deviations are, whether in this witness 25
~
w
y-- -
6984' david 3 1 opinion they give equirclent pr tecticn and if 20, why, 2 1:. might be e good idec. to cck thosc three s >acific
.s 3 questions; do you think?
4 MS. WOODHEAD: M: . Shon, I think we crc clear
-5 to seme extent on what the devictions c.re.
6 MR. HON: They are not very cles.: in the 7 board's mind yet.
8 -MS. WOODREAD: Then I WOuld be glad to ark thht 9 question.
10 Si~ HS. WOODHEPID:
.1 11 0 Dr. Co::, could you tell us precisely what the 1
12 deviations from the branch technical position are in your 13 fire hazards analycia? ;
- l .
14 A I ccn't enumertte them all. We have other 15 deviations. The most significant deviation, and the j l
deviezion ve arc concerned s.-ith right now here is the !
1G J t,
- 7 deviction with the definition of the design basis fire. And } ,
t !
we have indicated in the fire ht:Erdr' analysis a design gg f jg basis fire which does not meet that definition about, 20 in particular, the fire being propagated to other 1
21 combustibice'in the reon. ]
1 And that is not an enz.ct definition, but that t 22 L is'in enconee.what ue cre tc.1hing about that we hcvc
,3 i
1
.g set c.s our criterit septrntion, and say that ue rre not
.g going. to get propagation to another division as indicated I
, , . .__ _- . . . . - . _ ~ . .
6985 3-david 4 , by the= design basis fire.
2' MR. SHON: ~n point of fact, you have done only 3
the insulating material covering part of.the cables in L 4
the room; is thc.t right?.
5 WITNESS COX: When we postulated the design 6
basis fire, we postulated that the fire would consume 7
all of one division.
8 Dy test we know'that it won't do all of that, 9
but we postulated all of one division buring, but only 10 that division.
11 MR. SHON: And the normal branch technical 12-penition requirement would be to burn all of the ..
13 comburtibles in the room; is that right?
14 WITNESS COX: Yes.
15 By definition, the design basis fire indicates 16 that the fire has reached flachover, which meanc eccentially 17 overything in.the room will be ignited.,
18 MR. SHON: I think that is much clearer now 19
-to all of us...
20 LTTI:0S COX: May I add something elso?
21 DY MS, WOODHEAD:
0- Sure.
23: -A We have been talking about this (Witnecc Co2:)
24 pcrbicular footnote and whether wo apply -- I mean -- I
' don't.know'that it makes any difference whether we did or
.------ -~._- - ~ ~~ -
6986 1
david 5 1 didn't. He have submitted the fire ha::ards cnalycie.
2 The Co:crisrion has nct bun reluctant in the part to cay, 3 look, we asked you for something. Ee didn't got it.. Plotre j 4 give it tc us. If it.doecn't' matter, I would curpect that 5 if we had not given you what you felt you needed, you 6 would have let us know, and we haven't heard anything.
'7 MR. SHON: I guess we want to find out why ;
& it is equivalent or whether it does. ,
t 9 5'l MS. WOODHEAD: ;
10 0 Can you explain why in your opinion c design i
j; be. sic electrical fire in 5 to 10 percent of the plant g 12 gives fire protection equivalent to the criteria of the I
93 branch technical pocition, which is an exposure fire.
g A (Witness Cox) Socauce we know electriccl 15 ignitions fires, the firec will not propagate across the ,
I l separation distance. That har been choun by the test, and i 16 I am not ce familic: With the test cc Mr. Engmann, but I 17 gg am familiar enough to know that if we have an ignition fire, the fire is limited to that particular arca, and 39 1
it does not propagate over to other areac,of the 20 21 cable spreading room, and on the basic of that and the cabic 1
we are ucing, we have adequate protection.
22 i
cnd 13 23 !- !
\ l 24 s
I 25 I s- j l.
- l l
= --- - - .- - . - . ~ . .
EN14 arl 63G7 1 .O You had e.dequate protection for an electrical fire?
2 A Ycs.
3 0 I don't understand having adequate protection
+
1 4 for an exposure fire.
5 A Wo did not postulate an exposure fire for that 6 area. j 1
7 Q Then your discussion of the analysis or any f 8 justification you might send in to the Staff on this point 4
9 could not explain the difference betueen protection for an 10 exposure fire and one for an electrical fire to justify, to 11 show that there ic . comparable protec. tion; is that right? 4 12 MR.GALLO: objection. The question is compound, 13 argumentive, and we are back on the format agt.in for submittinT 14 fire analysis reports. It is irrelevant as well.
!!S. Wo0DHnAD: Can I rentate the questien and 15 16 simplify it?
jy DY MS. WOODlIEAD:
18 G Dr. Coxi how can you explain your fire protection 1g cystem as comparable to the one required by the Staff in 20 those places where you deviate?
MR. GALLO: Objection. There is no -- thore 21 22 has been no predicate established for some deviation in the fire protection system. The question assumes some 23 sort of fact not in evidence. I thought that we were talking 24 25 about how we postulate a design basis fire, not about fire protection systems.
6965 MS. M00D11FJtD: Mr. Chairman, e deci.:n basis fire is a basis for a fire protaction cyctem. A deviation ,
2 ,
, from'a Staff pocition in a design basis fire chould be 3 :
i' c::plained on the bacis of a firo suppression, a fire 4 ,
protection systen, to show comparubic safety. l D 1 (Board conferring.)
1 liR. S110N: Mr. Gallo, you object on the basic 7 '
1 that there has been no showing that there are deviationc in the design; is that right? 4 9 ,
1 MR. GTLLO: Yos.
10
.MR. S! ION: I think --
11 MR. GALLO: In terms of the fin protectioncystm.}
12 i 1 1 MR. SHON: In te me of the firo protection cvote . I is 1 I think the point thet Mr. Uoodhecd cchec, thz.t it is clear that the fire protection rystem design and, ! ,
15 : l i l indeed, dhe desigr c f the plant in goncrr.1 nay dopind upon ;
16 thc poctulated decign bccis firc. l 17 .
We have spol:en about different design basic 18 fires that have been postulated, but I thinh, Ms. Wood. head, ) ,
19 ;
you:had not indicated or had not gotton the witnesecc to 20 indicate excetly what the consequencec to the deci;n of the l 21 fire protection cycten would be for accepting the Staff'c 22
( _
. design bacis fire, rather than theirn.
a ce 4.w And, indeed, it scu.z that we de not have an 24 indication of. exactly what the difforences would be ir. he ,
25 }
- .- . . . . ~ _ - -- . - . - , .--
- a. I I or3 '6909 j y fire 1 protection cyctem's design itself. Could you crplore i
~
2 shat first?' '
f
]
6
- 3 MS. WOOOZELD
- Surely. I 4 4 MR. GALLO: Mr. Shon, mnv I'repiv te vour point, and Mr. Chaiman, it seems to me that the issua here it whoss 5
4 6
postulated design basic fire is rocconable, the Branch F
i Technical Position _ postulates throughout the plant somethin-7 -
g they had been cherceterizing as an es: posers fire.
4 3
The Applicant's fire entlycic report identifice !
9 i
- " "* " 9 * " " " Y
- 10 Dr. Ocx. Sonc of those firec could be chcracecrirad - cote i 11 l
. 12 of those decian basic fires desond.ina en the fire croc "
l i a <
l J I
' could be characterited as an exposure fire. i
, 13 l
Sona of those firec could be chnracterized cc 14 i
i an electricci fire, g
t
~
Now, whether -- it errihcr ms tha the necessary fire pr vantion cni fire cupprescic: tystem:, protection .
17 2
cyctemc necoccary, are a function of whoac 6ecign basic 18 fire is-correct.
19 1
The Branch Technical position 10 nce e regulation, 20 more_ly a position. It isn't even a rag. guide. We have
, staked out our poci- on based on our restin:ny. Cocncel s~
fer the Sttff is entitled to probe with respect to our 23
}
pocition, but the Branch Technict1 Pocition cannot 're hild I up ca a firm requiromant in terms of'it being c ecgulation. j E5 1 4
l
""Wh ..
6990 ar4 y
If they d'isagree, they have to justify their 2 design basis fire themselves.
So I submit the quarrel is there, ce to whcce 3
design basis fire is correct, not what the nature of the 4
Suppression systems would be.
5 g (Board conferring.)
CELIRIEN WOTEE: In light of this lengthy dialogus, 7
- 8 e .p an 's je n s su a ned.
9 E.. M : W are M ain W W o @ M on a g the ground dat you had asked something,e question involving changes in design, when in point of fact we.had not shown g
f that there vero any real changer in _he decign as a result
- of thic.
What we would like to havo you pursue, whethcr or not there are such changes, despite what Mr. Gallo said c chcrt while aco, and find out what t*ne diff'ertnce may bc in 16 design, and then we vill further ezplore which one of the t
two ac. sign bases appear to be* easonable. All right?-
MS. WOODHEAD: Al' -
19 BY MS. NOODHEAD:
20 0 - Dr. Co::, what differe. :es are there in the design of a fira suppression system between taking an exposure on t an electrical fire as the Ipanis c;iteria?
23 -
A -(Witness 24:) I don't knov if I can ansvar your
, question in that particular way. Let me apply it specifically 25
- ._._ .._ . _ ... .. _ _. - . _ . _ . _ . . . _ _ . _ ~ _ .
t c5Pi i ars 1 to the Black For Station, and with regard to the design of j i
2 Black Fox Station, if we ascume an e:rposure fire in tha f, i
3 cable spreading ro me it will require no desigt chanpec. j p
4 C How cbout the -- l i
8 5 MR. GALLO: I ~ a.m having a hard tims hearing ] .
6 the witness. Can you cpeak into the :nicrophone?
)
BY MS. WOODEEAD: !
7.
How-about the-other areac that cro included in 8 0 ,
t 9 'your 5 to 10' percent, where you use the c h '~' cal fire !
t 10 basic? l 1
i l In the~arec of the 5 -- in the other part -- I 1 -I 11 .A ' i i
12 cannot m:.ke the same statement there thtt I hnvc nia before l
with regard to the cable cpreading roomc. I -- I thir.h L':
13-u l 14 is importent to note the bachground here, and th:3 the finc 1 i
15 hccards Entlysic prenice doesn't scy enpenurc fire er
- ctrincl fire.
??n do an anclycic baced ca the ancDfsic we ,
)
18 Postulate the fire, and this is what va have donc, and I i t ,
1 \
19 think it is important to note that we firch became involvec '
in the issue of whether it is an ignition firo~or whether 20 21 it ic 'an c::posure fire really in the tactincny of tir. Sn nann j l
- 22 when.he pointed out that we have postulcted an ignition, ;
23 c?.ectrical ignition design bacis fire, and while I might g e.rgue with that characigarication, cnd we had not mentionad in the fire hactrds analvsic, and uc had no restirements by PA i
a e- J
-,a- ,, , , ,. - -.e. , + . , , -
0 ar6 1 the Staff to say you postulate an exposure fire, and I thir.k
^
2 in my own mind, it is a little bit unfair to be adviced a 3 couple of days before the hearings that the Staff feels n
4 that Mr. Engmann's testimony is in error. And it caused us 5 to reconsider, do we have a problem, and we have reconsidered, 6 and we are in the process of reconsidering.
He do not feel that we have a problem in the 7
8 cable spreading area. We do feel because -- I guess I am g the culprit -- I can't feel as confident in the other arocc that we can control combustibles and rule out an exposure fire 10 gg out thare, and so we haven't heard by documentation, to my knowledge, that it would require an exposure fire, 12
, g3 We have been informed by the Staff that an exposure fire is required.
14 end 1/15 16 17 18 19 20 21 22 N
24 i
ES I
" M
1
,1 6993 tape 15 -I In anreer to your. question, we hava ar_ arer s I
b 2Vid'l- 2- thtt is und? r review that I can't rube-entiatt in my 3 own r.ind;- meets the requirements, F.nd I think we will l. I 4 require a chcrge, and.I don't know what that change is yet.
5 The design is not final until it is approvei 6 by PSO, and I can't ache a co:aitment for two recsons: I 7 can't commit for PSO, and the other reason is that we B are'nct completed.on our revimf. ;
i 1
9 Eut we have another crea that we have a problem 10 with.
11 Q All right, Dr. Con, two things: origins.lly la we were trying to investigate the difference bettroen !
I
~
13 fire protection programs or systems, which would bc 14 designed cecording to one e::posure fire or the other e t
i 15 whetner or not there wcc a significant difference.
16 You stcted that in the cable spreading roc = there 17 ie no difference because you have c fire suppression, !
l 18 a fire protection cyctem in there that would accommodate; 19 am I correct, it would accorcoacte an exposure fire?
20 A Yes, it will.
.21 Q. But could you explain it a little bit, the 22 difference between a system that would be adequata in 23 these other creas that you are reviewing now with the ,
fire protection systemt vould it be significantly :
24 I t
25 different if you decide to.uce an exposure fire as c bacic? l t
l ?
)
y a a.- -- 1 , , - -n- ~ -- +w,-, ..,a.-n , ,, ,.-,,'n,.,,- , . . , . , , -
~ ~
~~
. . . . _ . - ~.. ZZL ,.. . .._ _ . _ _ _ .._ f .1, .__ :.
6994 david 2 I A. I can't answer that question specifically 2 because we' haven't completed our review. I can I believe
'3 say that it is going to involve a change. Whether it is f-4 going'to be a change in the fire protection system 5 has not been determined.
6 THe guidelines permit alternatives, and I 7 can't rule out the possibility that there is an alternative l l
8 sdlution to a change in the fire protection system. '
9 MR. SHON: Ms. Woodhead, you have consistently 1
10 used the words " suppression system design" rather 1
11 than " fire protection design," which is much broader. l l
12 A question still unclear in my own mind is --
l l
13 the' fire suppression system assumed to operate in the i
14 design basis fire? )
1 15 WITNESS COX: No, it is not. l 16 MR. SHON: That's what I thought. I would then-17 anticipate that the iportant question would be what 18 change would be required in the overall fire protection 19 design, perhaps firewalls or something like that.
20 If you made the' assumption the staff wants 21 you to make, which is that all provisions of all cable 22 insulation. burn.
23 WITNESS COX: That's the issue, but we don't
'24 know the solution. i 25 MR. SHON: Isn't it also true that there would
- - - = . - - - - . , - - . . . . ..
6995 dsvid3 1 he no change required in the cable spreading room from J
^
2 that standpoint? ,
4.
WITNESS COX: That's true, i 3
4 MR. SHON: But you don't know about the rest of (
l S it?
6 WITNESS COX: Yes.
7 MR. SHON: When you gave your. answer, you were 8 not limiting yourself solely to the fire supprer4 ion g system because that doesn't even work in the design basie 10 accident?
i t
WITNESS COK: That's right. j jt f l 12 MR. SHON: Thank you. Teat was uncicar to me. } l l
BY MS. WOODHEAD:
13
(
0 I would like to clarify another point you just 14 15 made sout your unh d hse am wh M MM I from the staff's position. i 16 l 1 You do definitely intend to review these !
97 ,
amas aga n?
18 19 A (Witness Cox) Yes , we do.
0 With what purpose in mind?
20 A Justifying in our own mind that a fire in 21 that area will not heopardize the safe shutdown of the t 22 k g plant.
0 And in the event or -- correction -- when you y
g come to a point that you can justify in your own mind l
i ;
i e
6996 david 4 1 that a fire in that area will not heopardize the plant, r' 2 do you intend to take any steps beyond just your personal satisfaction?
A I am having some difficulty in determining
' 4 what steps. I think logically what might occur in that --
that we will reanalyze this area and draw a conc lusion --
6 and I don't make this individually -- I mean -- well, I 7
have a certain input and responsibility. This is not 8
my decision in its entirety to nake, but I can certainly l 9
envision that collectively, Black and Vecch will 10 recommend to PSO and PSO cortainly will have input into 11 the decision that if a change is required, a change in 12 design will be ude and the fire hazards analysis in the 13 future will reficct this change. i 14 O So, at this point you are unable to say whether 15 or not you together with PSO might decide to comply with 16 the branch technical posiuion by either incorporating 17 design guidance or by spelling out a justification for 1
18 deviations; is that correct?
19 A No, we are not in a position right now to 20 say just exactly what we will do.
21 0- One more question, Dr. Cox. You previously 22 discussed welding with Mr. Gallo and explained that the 23 welding would be donc before the plant goes into operation.
24 Is it possible that modifications could be 25 made in the cable spreading room during the life of the
.. ,.. ~ u w a . . . _ . . . . . . . ._
. , ~ _ . . . , __
6997 I I
! 1 1
I Savid5. plant?- ,
m.
-2 '
A I believe that was Mr. Engmann's tactimony.
8 l O I'm sorry. l i
4 A Gary, do you want the mike? !
5 0 Mr. Engmann, should I repeat the question?
6 No, I think I can answer-it.
A (Witness Engmann) 7 By the nature of the raceway system that is designed for B.
the.cabic spreading room, I think I ccn say with full l 9
confidence that it will not be modified in the next 40 TO years.
U Q All right. Mr. Engmann, are you ft:niliar ,
f i
12 with the report on the Browns Ferry fire entitled NUREG 0050? -
I3 A I have read selected sections of it. I haven.
I# read it in its entirety, though. l 15 end 15
+
1 16 i,
17 18 19.
to 21 22
'M 24 25
~.
6W16:erl 6998 1 Q Do you hcppen to recall comparison of the Browns i
r- 2 . Ferry design with Reg. Guide 1.757 3 A I have only ceen that recently, just in passing..
e.
4 That was not in the selected sections that I have read. j i
5 O But you have seen it before?
-l I
6 A I have seen it in passing, yes.
.y Q I believe your testimony previously was that l
8 the separation criteria of 384 was not fellowed in Browns g Terry in the cable spreading room?
1 to A 11 hat I saw was a description of vertical separatio:1 11 between divisions of some 16, IS inchos at Browns Ferry 12 versus the vertical separation distance of three foot 13 required under IEEE.384 on Reg. Guide 1.75. That is what I 14 wne basing my testimony on, yes. ;
15 MR. GALLO: I might point out that that is stated 16 n pcge 39 of ImREG-0050.
37 (Pause.)
18 MS. WOODHEAD: I withdraw the question.
19 That's all. That's all questions for both 20 witnesses.
MR. SHON: Ms.11oodhead, if indeed as these 21 22 witnesses seem to have seen telling us, at least for the
(' cablo spreading room, it doesn't matter which of the two 23 pr poned fires one uses cs the design basis, as.far ce the 24 a tual phycical design of the plant is concerned, then why is 25
~._,
h.
6999 ara 1
it important to -- for either you or the Applicant to enforce
^ one or the other design? i 2
l I mean if it coecn't make any difference in the i 3 !
4 hardware, why is it so important to have the design bceis .
1 5 fire of one kind or ancther?
g MS. WOODHEAD: I don't believe that was the l testimony, Mr. Shon. I believe Dr. Cox said that the present j 7 l 8
fire pr tection design that he has postulated in his fire j l
g hazards analysis would acccmmodate either type fire, and I 10 believe the Staff has verified thct the hardware or uhatever yg the design is, vould accomnodate either kind of fire. But 12 I don't believe Dr. Cox naid that there would be no difference 1
in what might be necessary for an electrical fire versus to.
"" **E 8"#* #"* )
14 1
^ * " 8' " " "*'# """ Y" U ,
15 ,
- #" * #E#"" "9 # "' * "U E # * " #"" ##
16 protection over that you would provide for in electrice.1 fire 18 MR. SHON: I guess.that's the point. If the g
able arroading room is decigned to take what you have been 20 terraing an exposure fire, anyway, then what is the essence 21 f what you wich with respect to thase cEble spr2ading rocmc?
22 23 the plant?
l MS. WOODHEAD: Mr. Shen, I am sure vou are aware l 25 l
- l. I i-1 1
ar3 7000 1 . that the technical specifications and the design and e '2 commitments of the Applicant are enforced by the Staff, 3 and thic commitment is an important part of that ability r
- 4 to enforce these things, these designs and the criteria 5 which they commit themselves to, i 1
6 In the event they are not committed to accommodate 7 an exposure fire in the cable spreading room, it would be 8 permissible in the future for them to remove those fire I i
9~ protection systems in the cable spreading room which would l l
10 be excessive over the electrical fire.
11 MR. GALU3: Mr. Chairman, I would like to respond l l
12 to that.
i 13 I don't know where counsel gets the notion that l
14 once a fire protection system has been reviewed and approved 15 by the NRC Staff, that certain fire protection systems 16 wit 511n the overall cystem can be removed at olr caprica 17 o,ce that system has been reviewed and approved as a require-18 ment of the applicable license, and the changes can only be 19 made in accordance with NRC approval under the technical 20 specifications of the operating license.
!G. SHON: Mr. Gallo, on the other hand, if indeed 21 y your present design,for example, for t'.ie cable spre'ading
' room will accommodate an exposure fire as well as an 23 electrically-ignited fire, why not simply say so? I'hy 24 15 should there be any resistance on the part of the Applicant
t <
l ar4 '7001 l 1
1 to perforr.ing this.analysic, stating it in ALA?J., the .
2_ -design basis fire to be an exposure fire?
3 MR. GhLLO: 3ecause the. experts on my side of j e
4 the table say it is not logical to talk about a design l
?
t 1 basis fire in terms of exposure fires, because ycu can't I 5 i define an exposure fire: That follows the line that you 6
y pursued yesterday with Ms. Woodhead, how many -- how large 1
an. exposure. fire? What is a combustible? Gaeolins, wood, ;
8 I
e paper? And how much, what quantitv? I, ,
\
l 10 So it is more logical to do what the witness said I
~1 gg he did in this case, which is to identify the conbustibles. ,
i Look at it from the standpoint of transient 12 t combustibles, and then use that as a design basis fire.
93 14 Thtt ir the logical basis that we have used in the cable spreading r Om. It is true we have the suppression systems 15 l and the other firc protection systems that would accommodato I 16 the complete type of fire which they characterica as an 37 10
- E 8"r" fir"*
4 gg MR. SHON: The design bacis fire abant whi.ch we are talking assumes that the suppression system does work, 20 s y u v ul n't have any change in that?
2f MR. GALLO: -That's right. There was no credit 22 23.
MR.-SHON: Now, ac I ces'it, and perhaps it is 4
still a little unclear in my mind, what we appear to be i*
25 ol s i
i er5 7002 1 . talking.cbout is twoiquite well-defintd firca in thic-2 r.pecific' case: l 3 One'ic.where part of the insulation in ths room
,~
4 burns,-and'one is where all of the insult ion in the room 5 burns.
6 .I think unlecs I am mistaken, tha staff, in y defining their "crposure firs" has not required that any 8 additional combustibic naterici is ccsumed to be in the room
, g it that correct? Other than sinpiy the Ocmbustible insulation.
10 on the wires?
11 MR. GALLO: Chat's right, and in that inctancc,.
12 Mr. Shon, the fire analycis report for Blach For for ths 13
- cable spreading room takes credit for the spacing benefit 14 tchieved by IEEE 384, and the judgme.nt that you need not assume that all of the Ochle incide tha Ochle spreadina - room 15 will burn ic breci on the fact $ ct thers is that ccpa atien
,6 i
and, t.hertfore, the fire from cne enble Civision vill not
$7 18 E 09"9" " *U 'UOO*#
- M n. SIIO N : Sinca your design is capable of gg 20 accommodating a design bnais fire which assumes combustion cf:the ccble insulction, why uould you object to saying.
g s and giving that as the design basic? It doesn't coct you 22 anything,.it doesn't de anything to the decign of the plant, g
M t . G.I.L L O : It is a nrtter of, I guess, y
philosophy, dicagreement of:the crpartc. That ic how they
. So i;
i, i
. . _ .. .. c ;_
ar6- 7003 l l
l 1 got to where they were. We have yet to hear the logical l 2 basis for the Staff for their position.
3 In this instanca it is true that the -- if you 4 are going to use the tenu exposure fire, that the apparatus 5 there are sufficient, the fire wall is there, the three-6 hour fire wall.
7 MS. WOODHEAD: Could I explain one nere thing, !
1 8 Mr. Shon, about our view of the nececsity of the commitment l
9 at this point?
10 We have not completed our in-depth review of i 1
3g the fire hazards analysis. We have as a quick look, looked 12 at the part which deals with the cable spreading room, and l
13 it appears at this point to be able to accommodate any kind of fira, so that in that respech Lhe design basis 14 fire w uld be irrelevant. But since we have not completed 15 nr ntire review, and an adequate fire protection system 16 g7 ic a comprehensive whole, we feel the necescity now to hcve a mmitment to thic kind of fire in the event that we find 18 something amiss further on in our more in-depth review.
19 If we are limited at this point, we are in a 20 quandary later on if we do find some serious omission or 21
. err r in the analysic.
22 MR. SHON: Yes, I realize that we are speaking g ;
g only to the cable spreading room at this point, and we have been assured that there are some other places where
7002 es:7
, .. s , ,.. - .
r.. 4 w >a
- o. -e a e..e..c..,,. e ,.sc e ,
. ...s
,. ~. 2 2, 2 3.... m. mc. ,.,, ~-,...
w - - ,e.. . , p .: n .
. ~ . - .
1 ,
l, 2 ti.a 0;.ble .3 Pref dine roon L a 2. pr.rtcigr of what .:111 narO = n i
{'
3 1c.ter, ;
I e
4 i think uhat we we.nt to 60 now is 0 r.xinus- trd I 5 hear the Staff witnecces and r. heir side of it. j I
6 Mn. WOIEE: We will recess itntil 2:00 o'cloch. ;
f (Whereupon, at 12:50 p.m., the hearing g vas rececssd, to reconvene at 2:00 p.m., n'"
i g sn rc icy. )
t 10 i l i
1 12 :
1
- -_ _ _ l r 13 1 14 i
15 s 16 17 18 1
i 19 i
20 :
6 1
mj !
h 23 <
l i
24 i
?,
t b h l
I e
N BW17 arl. 7005 1 ATTERSOON SESSION 2 (2:00 p.m.)
3 CHAIR'&N WOLFE: The witnesses will resume the 4 stand.
5 Whereupon, 6 GARY R. ENGMANN and.
7 E. L. COX 8
resumed the stand as witnesses and, having been previously 9
duly sworn, were excmined and tectified further as follovs:
10 EXTtMINATION BY THE BOARD 11 BY 11R. SHON:
12 -
Q I think it was Mr. Engmann that mentioned that in 13 having these plastics for insulation purposes, various halo-14 gens could be used for fireproofing plastics and that 15 bromine and chlorine were often used, and that the amount 16 of corrosive gas given off by the brominated plcstic was 17 rcther less than thct by the chlorinated plastic. Is thE.t 18 correct?
19 A (Witness Engmann) That is the information I 20 received from several of the cable vendors.
21 Q Are you specifying brominated plastice for all of 22 these, or do the manufacturers simply get their choice?
23 A I feel that the specification of IEEE 383 is sufficient specification construction from a fitme retardant 25 point of view; compoundic.g of cable insulation is a vcry i
.-_-..7-..
1 I
ar2 7006 l
. - . , i 1
eseteric sciance, cnd is constantly in a cente c: _=.
- I
. e. .,. .
n m.. , w. . , 4 2 -
. > . , , 1 x. in.. .q-._,-_.._.:_c,,~.4_....
,w - .; ,
i.
3 cc:t. pound for inrulation, but rather an acceptable test by 4 which you can crove the function vill be achieved. ;
i 5 O Does IEEE 303 address itself in c quantitative }
t 6 fashion to the evolution of corrosive gcses? i 1
7 A It does not. t I
g 0 It would seen that this would be entirely ctart
{e i from ICI.: 1E3, as far c.c the kind of prec.ution ycu migh: ;
g ,i.
I I
g v+.nt to rche in that, .cculdn't it? l l i
gj A What I read thout the evolution of corrosivc gc.sec cur].nc tne burninct of. cabla construct:..on nas ne:
.L c . ml i 1o - - ,
e i
to '.he opinion that it is a scvarc Oroblem. It is often i 13 .
f g touted as such in the industry when opinions arc cffered. i g 0:- who.t evidence I've oi:cmined, I do not concu" in thcz I U"' I 16 i
0 I cce.
37 t
While us were tulking over t.hc lunch hour -- !
g I g the bocrd -- a matter enne up that I think Dr. Cox will {.
carha.ps have to addresc.
20 -
y.
'?here une cone doubt cc to our understanding of :
s l;
cn ctiv hc7 the spacing betwoon cr.ble trays affected the 22 -
g design bacio firc an6 uhether or not spacing betwoon cahic treec wac an impc,rtant paratneter if one took the aanroace --
24 i that tha design basis fire cou1C be orierincted be an ~ "
2a !
I h
i a
1 I I d I
7007 ar3-1 exposure fire, and that all of the cable -- is spacing 2 between cable trays important if in the design basis 3 fire assumption all of the cable burns?
n 4 A The course of action led us to where we 5 got was to loch at the combustibles present. If the 6 combustibles present were confined only to cable insulation 7 material itself, then the only source of energy that could )
8 ignite a fire would be electrical ignition. Within I 9 electrical ignition of the cable insulating material itself to we have evidence at hand that supports Reg. Guide 1.75 11 that says that separation is important, and one can conclude 12 the propagation of fire from one division to another.
13 I think that answers the first part of your question.
14 If you would restate the second part, I might address that )
l 15 one.
16 0 In the caso of the design basis fire, where an 17 expocure fire is assumed and all the cable is assumed to 18 burn, is spacing between the cable trays of any importance?
19 A If one would choose to use spacing instead of 20 barriers, then you would have to increase the spacing over 21 those explicit criteria offered in Reg. Guide 1.75 to assure g2 that the multiple divisions did not btrn, given en exposure
' 23 fire.
24 At least that appears to be the results of the 25' experiments at Sandia, that the vertical separation dictance
i 700P i ar4 I Eut as I understand uha precepts cf !
1 would r.ot be adequa te . !
2 the Branch technical position, if you do have divisicns 1 3 that you have identified as redundant for certain critical I 4 safety f actions, then you shculd put barriers in there. !
t 5 If you put barriers in there, then the argument >
I 6 about how much .cpace or separation is sufficient beccmes t 7 academic.
8 0 The particular civisions that we were talking. I S a'.>out thic morning, heuever, are not specified ac redundant, l t,
10 were they? .
I 11 A The primary rodundancy is achieved in the safety j 12 cystems between Divicions 1 and 4 and 2 and 3. Additional .,
I i j;3 redundancy for both safety purposes and.for availability i 1
34 of the plant is achieved between Divisions 2 and 5 and 1 and 4; IS ,
but the redunde.ncy that is achieved primarily bet'. teen 1 and 4 16 and 2 a id 1 is more than sufficient for the cLfc. shutdown cf {
the plant, 1/ -
18 O It was mentioned this mornina rather as un cside i
39 that the cabling to the ramote shutdown panel board was
.0 largely Division 1. Does that maan that there is not 2,a in Division 3 redundancv there?
- {
22 A The design of the remote shutdown nanel or
'- that system that is called the remote shutde.:n svstem is i 23 - ,
4 largely within the scope of design of the General Electric l i
25 company, and I think the cuestion more proceriv may be
'{
i f
, i i I
-ar5 7009 g' addressed to them.
Uhat I'hnov of that design is that it ir 2
.3 Primarily Division 1. There is little or no division to r
4 2 or 3 or 4 instrumentation control or indication on that i 1
board.
5 0 And can you say in any way how a proper redundancy 6
is achieved with a single division? It just doesn't seen 7
8 r asonable offhand. l nk you have to address the functicr. of the 9
rem te shutdown panel. I believe that currently we are now 0
positing single failure and/or-accident in conjunction with t'.ne necessity to abandon the control room.
0 I see.
13 You are arsuning in effect that a single failure 14 wouldn't. occur at the sane time in Division 1 as a requirement l 15 to abandon the control roon? !
16 A Ac I interpret curren design objectivest it F7 i does not include the necessity of assuning a single failure I or an accident in conjunction with abandoning the control room. l l
20 0 Thank you.
21 CIIAIRMAN UOLFE: Dr. Purdom.
22 ]
SY DR. PURDC:i: \
23 ;
'O- Dr. Cox, is there cry control of smoking of 24 employees while on duty at the nuclear plant, er in arens l R
25 in which they are not permitted to emoke?
i 1
. - . . . . - . - - -. . - . _ - - ~ - . . - . . . . .
I .
1 ar6- 7010 ;
1 A- -(Mitness Ccx) : think that has to be determined-2 as pcr: of the evaluation Of the hazardc cssocictsf. I
(~
3 -would certainly expect PSO'to hava."U Smoking" signs'in ;
4 an area where there is combustible materials to make sure 5 there isn't a fire, but-I can't speak of that until thoca i
6 procedures are formulated. ,
1 7 0 In the cable separation room, for example, would g that have "No Smoking"?
I' I don't think cmoking would be n problem. Hov:sycr ,
9 .
it would certainly bs our recommendation to PSO that it be 10 I ,s a "No Smoking" sign. ;
Q But you didn't take this into account in any of l 12 Y'** ""' Y***I f 13_
g , A We did not postulate c cigarette being in thero.
O I might ask either on+ of you, it was stated thtt l 15 ;
in the cable spreading room, thct there would be no wclding I I
16 o I
in the future It there any possibility the.re uceld ; - i 17 i
""Y " ""Y " * "9 18 g
A (Mitness Engmann) The primary components in the '. cable spreading room are the cable tray supports and 20 the cable. The' cable is continuous from the terminal points to the termination cabinets above the cable spreading room to the field devices. I woul6' anticipate no coldering in 23 l
that-cable snreading room.
^
24 DR. PURDOM: That's Lll I have.
125 are .---- C - p g- @ -e ;e $1g rwx P -T y
^_:._...__ :'" ^ ~
l ar7 7011 1 IHA!?l".AU WOLPE: Any questions derived from the 1
2 . Board quenciens? l 3 Ms. WOODIEAD: No questions, e
4 MR. GALLO: No questions.
5 MR. FARRIS: I have just one question, maybe uwo.
6 FURTHER RECROSS EXAMINATION I
l 7 BY MR. FARRIS:
8 0 You indicated that you didn't think there would g be any changes mcde in that cable spreading room over the 10 40-year life of the plant, jg Have you ever observed a cable spreading room that 2 has been around for 40 years? !
1
,. j3 A (Witness Engn. ann) No, sir. I'm only 36 years old.
14 0 I didn't mean that you had lived for 40 years.
15 I meant have you cycr been in a cable spreading room that 16 has oeen around 40 years? -
g A hava been in a number of cable spreading creas the vintage of which I .m unaware of. They were cider.
18 gg I can't tell you that they were 40 years; probably not.
20 There' arc not too many power plants around operating that are over 40 years.
21 O In fa t, they are closer to 20 years, aren't they?
22
' A That would be a better approximation, yes.
3 O How can you say with a fair degree of assurar.ce 4
- that there would be no changes in the nes:t 4G years in a
't cr8 7012 j power picre that ic on.y 2: feart old?
i i
(.
2 -2 61 nL"n run cnr.aagn a ser:.ng c: rac ont e ::.ct n.r; ;
I e
e co like this:
Ue have a control building of a certain fixed 4 -{
4 i
5 dimencien. The centrol room that occupies that control ;
6 building is currently occupying most of the space avnilable {' l 1
in it. The control panels that are in that control room at i 7 1 the time of design finclication will be largelv filled -
- 6 i I l
g by the control devices that one F.ight vant tc put on thca. ;
4 With that limitction, thers is a limit on the {
$g i g amount of ciring one may want to add to that cable sprecdin; !
l 1
room to get into the control sprending room. i i
12 .
i If one looks st the cpace er value provided in .
1.,3 4
i decignina the initial inctEllation of the ccble trcv, when I
14
- g !
one can f cirly encily believe that any cable that has to bc ,
I i
.i added vill be added in existinc cable trcy.
If Enictina -
1c w I n,
c tb2 c trev. n t, or the initiel ins:cilation of cchic trayr is ,
i sufficient, I ccn't posit that one would want te go in therc :
e 4, .
I p* i and ndd anvthing, and certainiv. vould not need tc cupnort t
I anythine that you would have to add in the way of cable tray.
20 end 17 ,
mi s
wi 23 i
' f 14 i
e5
- l E
I' 4 i
- 7012 -A tape 18 1 Q Your cnswer assumes that the present design
'*e.vid 1 2 for cable spreading rooms, at least the Black Fox design, 3 will not be improved upon for the next 40 years?
g-4 A No, my assumption is that if you have to add 5 anything in the way of control indication or monitoring, you can't do it in the existing control building. You 6
7 are going to have to make it bigger.
8 MR. FARRIS: No further questions, g CIIAIRMAN WOLFE: The witnesses are excused.
10 (Witnesses excused.)
11 CEAIRMAM WOLFE: Ms. Woodhead?
MS. WOODHEAD: Yes, at this time, Mr. Chairman, 12 the staff's witnesses on -- I would like to present the 13 staff's witnecscs for contentions seven, eight, and nine.
14 15 They are Mr. Robert Giardina and Mr.* James Behn.
Mr. Giardinc hcs been sworn previously, but 16 37 Mr. Behn has not.
Whereupon, 18 gg ROBERT J. GIARDINA was called as a witness, and having been previously duly 20 sworn, was cxamined and testified as follows:
21 and 22 g JAMES D. BEEN y was called as a witness, and having been duly sworn, was 3 examined and testified as follows:
M w
7013 i
david 2 .1 DIRECT EXAMINATION t
' 2 BY MS. WOODHEAD: I s
-3 0 Mr. Giardina, vould you ctate your name for the !
r 4 record?
I 5 A (Witness Giardina) Robert J. Giardina. l 1
6 .G-i-a-r-d-i-n-a.
7 0 By whom.are you employed? ;
8 .A -U. S. Nuclear Regulatory Commission.
s 0 What is your position at the NRC?
10 A A reactor enginear. !
Mr. Behn, would i I 11 3 0 you state your full name for tha l
12 record? >
l
! l
( 13 A (Witness Behn) James D. Behn. i i
14 0 Mr. Behn, by whom are you employed? !
35 A Gage-Babcock cnd Acsociates. ,
i 16 O What is your association with the Nuclear Ree;ulatory' 17 C C*iSSiCh?
gg A I am the fire protection consultant to the NRC.
I 19 O Mr. Giardinc and Mr. Bahn, have you both prepnred }
20 written testimony for presentation in this proceeding?
21 A- (Witness Giardine) Yes.
22 A (Witness Behn) Yec.
E' 23 0 Does thic testimony concern contentions seven, cight.,
i 2/p and nine? !!
A (Witness Gicrdiana) Yec, it doca. !
25 l !
l
] t' 1 :
_ ~.-
7014 david 3 I Q Uave you prepared statements of your professional
~
2 qualifications?
3 A (Witness Giardiana) Yes.
e 4 A (Witness Behn) Yes.
5 0 I will now show you a document and ask you to 6 identify it.
7 (nanding document to witnesses.)
6 Was this document prepared by you, Mr. Giardis 9 and Mr. Behn?
10 A (Witness Giardiana) Yes, it was.
11 A (Witness Behn) Yes, it was.
12 0 Was any part prepared separately by cither of
(~ 13 you?
14 A (Witnoss Giardiana) No, it was a joint effort.
15 0 Are there any corrections or additions that you 16 wish to make to this testimony?
17 A (Witness Giardina) Yes, we would.
18 on page 7, the seventh line from the bottom 19 where it says, "for nuclear generating stations flame 20 tests," it should be: quote, period, and capital T for 21 these tests are used."
22 on the fourth line from the bottom, the last t
23 word in the line should be "severc1" instead of " general."
24 On page 12 under item B, third line down, it 25 sayc IEEE standard 284. It should be IEEE standard 354 t
-- - - - - - - ~ ~ ' ~ ~ ~ ~ ' - - - - ~ ~ ~ ~ ~ '
, ~ . _ - __
r -
7015 david 4 And on the fourth line from the bottom where it says, THe current edition," it should be an N af ter the 3-0 in " addition."
4 Q Arc there any further' corrections you wish to 5
make?
6 A No, there are not.
7 Q Mr. Giardina and Mr. Behn, is this testimony 8
of 25 pages which consists of 18 pages of testimony and 9
2 pages of professional qualifications for Robert C.
to Gicrdia , two pages of professional qualifications for 11 James D. Behn, and an NRC memorandum entitled " Memorandum I R.' Strike from B. Benaroya," true and correct to the for 13 best of your knowledge?
I4 A (Witness Giardina) It ic.
15
A (Witness Behn) It is.
N ME. WOODEEAD: Mr. Chairman, thic testinony having 17 been previously distributed to the board and partiec 18 on September 25th, I now move to be bound into the record I9 as if read.
20 CHAIRMAN WOLFE: Without objection, said 21 -documents are incorporated into the record as if read.
M (Documents follow.)
- v. . gg 24 .
I 2a
}
i i l'
w-_ . . . . _ .
. . . -.m_ ._ _,,_ _ .
i, l [ -
I UNITED STATES OF AMERICA l
- s. NUCLEAR REGULATORY COW 11SSION BEFORE THE ATO'11C SAFETY AND LICENSING BOARD l In the Matter of' Public Service Company of ) Docket Nos.: 50-556 ,
Oklahoma ) 50-567 l
) i (Diack Fox Station, )
Unit Nos. 1 & 2) )
TESTIMONY OF ROBERT J. GIARDINA AND JAMES D. BEHN ON CONTENTIONS 7, 8, AND 9
- 1. My name is Robert J. Giardina. I am employed by the Nuclear Regulatory Cemission as a Reactor Engineer in the Auxiliary f
I have been employed in this position since
( Systems Cranch.
September,1974, and I am responsible for coordinating the ;
- overall fire protection review and the safety review of the fire protecticn system.
- 2. My name is James D. Behn. I am employed by Gage-Babcock &
Associates, Inc., as a fire protection and safety consultant.
I have been employed in this field for the past eight years.
I am presently providing fire protection consulting to the Auxiliary Systems Branch of the NRC and am responsible for the review of the fire protection system and the fire hazards analysis.
][w 7.8.9-1:
+
/ c'.-
< a , sa i .ema ,.% , ,4b .a _pm,. ,,,,,~.
e y * , , , +. ,,7, --
y --y, , . _ . . . . , - - , . --c, e y --we..w-.,,yn,. y - - . , +-
. . . . .-. ,. ~ . . . . . - . . . .. . . - . - - . - . - -. . -
/
/
- 3. The purpose of our testimony is to address the Intervenor l
. Contentions Numbers 7, 8, and 9 regarding the fire protection ;
I program for cables, cabit tray separation, and' for the plant, respec^!vesy. These contentions relate .to the compliance of the Black Fox Fire Protection Program with the requirements
~
in Appendix A Criterion 3 to 10 CFR Part 50. Our testimony will shmt that the Black Fox Fire Protection Progrtm is cc-ceptable and will meet the requirements of 10 CFR Part 50 Criterion 3.
Contention 7 4- 4. Intervenors contend that in order for the Applicant to mact 10 CFR Part 50, Appendix A, Criterion 3, Black Fox. Unit Nos.
1 and 2 must utili:e cables with fire retardant insulation.
Contention 8
- 5. Intervenors contend that in order to meet 10 CFR Part 50, Ap-pendix 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, Unit Nos.1 and 2 of the type of fire.which took place.in the cable spreading room at
/. . Browns Ferry.
(.
8 7,8, 3- 2 a
.k.s
, . . - - . . , . . . . - . . ,,. . , ,,,,..n. _ _ . - .
' ~
~:.-. . .. ~~- . .. . ; ::==z=.=:=~ ~ ~ ~
}~C. :a :: ".
- i s
v
' Contention 9
- 6. Intervenors contend that the Applicant has not designed an in-depth fire protection system for Black Fox, Unit Nos.1 and 2, which complies with 10 CFR Part 50, Appendix A, Criterion 3.
Introduction !-
- 7. The fire that occurred at the Browns Ferry Nuclear facility in Alcbama in fiarch,1975, mainly- affected electrical cabling and equiprent. After this event, the NRC undertcok a substantial upgrading of fire protection provisions at nuclear power plants.
The staff made a thorough study of the Browns Ferry fire; dcycloped licensing requirements for both new and operating plants; and comenced systematic fire protection review of all licensed nuclear power facilities. The results of the study, mentioned above, were published in NUREG-0050, "Reconuendations Related to the Browns Ferry Fire," February,1976. Based on the conclusions of the study, the staff developed an extensive set of guidelines for fire protection considerations in new plants during 1976. These guideline: were issued in the Stand-ard Review Plan as Branch Technical Position (BTP) ASB 9.5-1 i and later as Regulatory Guide 1.120 for use by the industry.
In addition, the.following NRC Fire Protection Guidance Documents have been issued:
([
x 7,8,9-3 r . a-we w 8< ,9.- -u . . . _ . , , .. , _ , _ _
, - -,.,.,,n- ,-- - +.w.-
_-...,.;.__._._,_c.,_._.__,_.._. .r,y .
- a. BTP 9.5-1. Appendix A: " Guidelines For the Fire Protection I of liuclear ' Plants Docketed Prior to June 1,1976." l l
l
- b. Standard Technical Specifications, llovember,1977.
l l
- c. "Ituclear Plant Fire Protection Functional Responsibilities, '
Administrative Controls, and Quality Assurance," June 14, 1977.
- d. "I',anpower Requirements for Operating Reactors," May,1978.
{
These guidclines incorporate applicable recomendetions of the j factory Mutuci Systems, fluelear Energy Liability Property ;
- 1 Insurance Asscciation (liELPIA), and professional fire protection
\.
engineers with whom the staff consulted. The staff's goal in the fire protection guidelines is to assure that a sufficient fire protection system is provided for safe shutdcwn systems so that at least one division of safety equipment necessary for safe plant shutdown will be operable to perform its safety function in adequate time if a fire occurs anywhere in the plant.
Licensing Recuirements
- 8. General Design Criterion 3, " Fire Protection," of Appendix A to 10 CFR Part' 50 states that:
\ ,.
7,8,9-4
- - . . - . ..m. . . - . . _ _ . _ . . _ _ . _. . _ ._ _ . _ , ._. _ ,_ __
I 4
1
" Structures, systems, and components important to li safety shall be designed end located to minimize consistent with other safety requirenents, the ,!
probability and effect of fires and explosions. ! ,
fionecabustibic and heat resistant materials shall !
be used.wherever practical throughout the unit, ,
particularly in locations such as the containment i and control room. Fire detection and fighting i systems of appropriate ~ capacity and capability I shall be provided and designed to minimize the adverse effects of fires on structures, systems, ,
and components important to safety. Firefighting systems shall be designed to assure that their rupture or inadvertent operation does not signif-icantly. impair the safety ctpability of these structures, systems, and components."
For the Black Fcx facility, guidance for meeting the requirements of GDC-3 is set forth in BTP ASB 9.5-1, Appendix A " Guidelines
- s. for the Fire Protection of lluclear Plants Docketed Prior to July 1, 1976," and Regulatory Guide 1.120, " Fire Protection Guidelines for Nuclear Power Plants."
Although the guidelines of the Branch Technical Position provide preferred guidance for fire protection programs, alternative
~
fire protection guidelines are identified in Appendix A. The alternatives apply to areas where, depending on the construction or operational status of a given plant, application of the guide-lines could have significant impact, e.g., where the building and 7,8,9-5 E
.--w; m.__________m_______ _ _ _ _ . _ . _ _ _
_ .-. ~
w -
rs- e
. _m. . .. e. o . ., 4 . . . . - 2..,,__...._,_ ._. ....___.._m.. . .. . . __ ._ _. _ _ _
l
- b. i.
system designs are already complete and construction is in prog- ;
ress, or where the plant is in operation. These alternative !
1 guidelines provide adequate and acceptable fire protection i J
consistent with safe plant shutdown requirtments.
Section 50.35(a) of 10 CFR states that for a construction pemit, it is sufficient for Applicants to provide infomation concerning the principt.1 architectural and engineering design criteria.
The complete design is required when application is made for en operating license.
- 9. The stcff's review of the Black Fox Stction's Fire Protection Progrcm has been performed in accordance with the guidelinec of i .
- Regulatory Guide 1.120 and Branch Technical Position ASB 9.5-1, ;
Appendix A. .The Applicant ccmmitted by letter dated May 26, 1977, to provide a fire hazards analysis and a comparison of his fire protection program to the guidelines of Appendix A to Branch Technical Position ASB 9.5-1. The Applicant submitted on November 30, 1977, a report entitled, " Black Fox Station Fire Hazards Analysis, Construction Pemit Stage, Reference Report
- 16. " This report includes a Fire Hazards Analysis and the ;
comparison to the guidelines of Appendix A to Branch Technical Position ASB 9.5-1, to demonstrate Black Fox's compliance with the guide. Our preliminary review of the report revealed that t
t 7,8,9-6 t
~~
- . ' . .,; T..'
- :;. - : ' : ~ .:
~~
~~~~~~T~" - ~ ~ ,
i, l
p r
! l j all of the applicable positions in the guidelines had been ,
i i addressed and that the report was acceptable for staff review.
i A detailed fire protection system revie.1 will be performed and further requirements may be imposed to further improve f
the capability of the fire protection system. This review l
will be done on a timely basis and prior to the issuance of {
the oport. ting license so that the Applicant can effectively incorporate any design changes in the final design.
Contention 7
- 10. The staff position, kuted in Regulatory Guide 1.120 and Branch
- Technical Position ASS 9.5-1, Appendix A, on fire ret.irdent insulation for cables used in nuclear plants is
- " Electric cable constructions [in safety-related crees] should, es a minimum, pass the current [1974 editien) IEEE Standard 383, [IEEE Standard for Type Test of Class 1E Electric Cables, Field and Connections for Nuclear Generating Stations) flame test"; these tests are used to screen cable insulation for fire propagation properties. The l
IEEE Standard 383 specifies 70,000 Btu fire tests. The staff retained the Standards of IEEE 383-1974 based on tests by general , l laboratories which confirmed its adequacy. The Black' Fox commit- -
1 p
ment test uses the 210,000 Btu (NELPIA) fire test which exceeds !
q.. NRC requirements. ;
l 7,8,9-7 ;
1
- ~. . , , . . . .
. - , . - . - . . - - , - . - = - . -
~ _ _. -..
, ..-.._.._._.7 ,
I 4
l
- n. t
' k.
c' The' IEEE-383 St:ndard. specified in the guidelinas is used to
't '
- determine the receptability of cable insulation for certain fire propagction properties, and the testing is donc under l
\ \
laboratory conditions. l l 1
s During 1975-1977, several' tests were perforad at Sandia i Laboratories in New Mexico. Sandia conducted a cable fire j test with a cable tray configuration consisting of two sticked columns of seven cable trays each to simulate one safety di- !
1 vision. Other cable trays were previded to represent a second safety division. These cable tray divisions were separated r based upcn the guidelines of Regulatory Guide 1.75 for open
('
plant areas; i.e., five feet vertical and three feet horizontal spacing betrecn divisions. The tests were initiated by two different means; one type used internal electrical heating to initiate the fires, while the othar type used propane burners to produce a sustained fire (expusure fire). The tests were performed without a fire suppresrion system. Fire propagstion did not occur .for electrically initated fires; however, an exposure fire initiated in one of the bottom cable trays resulted in fire propagation from one division to the other. j The tests demonstrated that a fully. developed cable tray fire can propagate to adjacent cable-trays. The results also show
(
' that a fully developed fire in 14 trays can propagate across the five foot' vertical separation between divisions.
(
7,8,9-8 7 _ -
w , . - ,,-i, w-- ---
, . ,s.
- .3 9-.. . . _
i j
y-
-t i
I i
. g.
l The staff position accounts for the possibility of IEEE-383 cables '
propagating a fire in a cabic tray, Cable separation' guidelines and fire retardant cables are not E intended to be sufficient alone to protect against exposure ,
l fires. Additional fire protection measures are required by ?!RC.
These additicial fire prttaction measures include fire barriers between redundant safety division cable trays, autcmatic fire t-
. detection systcms; automatic fire cxtirguishing system.s, such as sprinklers in plant areas of high cable density; bcckup fire sup?re:sion capability (fire hoses and portable extinguishers), ;
-administrative procedures and controls to minimize fire hazard:
due to poor' housekeeping or to plant maintenance activities; and fire brigcde training and drills to assure adcquate respenst .
i to fire cmergco:ies. The additional fire protection measure.. :
3 contained in Branch Technical Position ASB 9.5-1 and its Appendix A, and in Regult. tory Guide 1.120 do not infer that complete protection is afforded by use of the IEEE-383 and Regulatory .
t Guide 1.75 guidance. Rather, they serve to supplement and di-
~
- I versify protection against exposure fires, and to provide ample
- margin _for assuring'a.high degree of fire protection safety at ;
t nuclear plants by means' of 'a defense-in-depth fire protection .
I program. i i
7,8,9-9 4 e
7 _._ _._ _ _ _l-
,.n<- m e ews,
. . . . . . . . . . . - - - - -- - - . - - ~ - .
f' i.
The applicant in his PSAR Section 3.11 states that all Class 1E
~
J' cabics will meet IEEE-383. The applicant has committed in his :
" Fire Hszard Analysis Construction Permit Stage Reference Report !
6 i 16," dated NovemberL17,1977, to use cable insulation that passes .[ l as a minimum the flame test in IEEE-383 Standard as modified by I, Nucicar Energy Liability Property Insurance' Association's (NELPIA) l 210,000 Btu' fire test. This document is part of the Black Fox b i
Docketand was submitted as an amendment to the PSAP,. i
~ '
The ' applicant in thc Fire Hazards Analysis Reference Report 16 has committed to a Quality Assurance (QA) Program for the fire protec-
~
-tion system for safety related creas. The Applictnt in the PSAR 1
g Section 17 provida: a Quality Assurance (QA) Progrce that ecmplies I i
with the provisionc of 10 CFR Part 50, Appendix D, " Quality l
i Assurance-Criteria for Nuclece Plants." This program will ensure l
that cables are installed properly in accordance with the. drawings, I instructions, and procedures.. It will also provide a means for l t
tracing cable charactoristics during construction es required by i 10 CFR Part 50, Appendix B Sections VII, " Control of Purchased l'aterial, Equipc?nt, and Services," and VIII, " Identification and Control of Materials, Parts, anf Components."
t i
f i
N; P
7,8,9-10 t
s t
b .y up e , e v w . - % g we.=v--+, - o y e tw r - gr .v
,- 1 Contention 8 7
- 11. The NRC design criteria for cable '.rcy separation for Black Fox, including the two cable spreading rooms in cach unit of BFS is stated in Regulatory Guide 1.75, " Physical Independence I' of Electric Systems." This guide endorses IEEE Standard l
}
3S4-1974, " Criteria for Separation of Class lE Equipment and Circuits."'which is adequate for electrically induced cable ,
tray fires. Regulatory Guide 1.120, and Branch Technical Position ASB c.5-1, Appendix A, address both exposure and elcetrically indu:ed fires. The Applicant has cenmitted in his:" Fire Haz6rds Antlysis Construction Penr.it Stage
( Reference Report 16," to the following, for ecch of the l Black Fox Units,.which are totally independent of each .
other:
a.- In the cable spreading rooms, the cable tray separation distances, both. vertical and horizcntal, will be in accordance with Regulatory Guide 1.75 and IEEE Standard 384. Safety divisions 1 and 4 in one cable spreading room will be separated from redundant safety divisions 2 and 3 in the other cable spreading room by a 3-hour fire barrier. in .accordance with Regulatory Guide 1.120,
- Position C.4 and C.6 and Branch Technical Position ASB N~ 9.5-1, Appendix A, Sections D.3 and F.3. Thus, a fire ,
in one cable spreading room will.not prevent safe shut-down of the plant, since the redundant cable spreading 7,8,9-11 ,
1 4 ..9. ,$., ae. -,e-.. .r e .n.# ,e isw e W
- _ ---. 3 ,,
i
,- l
( room will be intact. In addition, a fixed auton tic deluge system will be installed with manual hand hose bact.up in
( accordance with the guidelines of Regulatory Guide 1.120, !
Position C.2.c and C.6.c and BTF 9.5-1, Appendix A. l Sections D.3(c) and F.3.
- b. In the balance of the plant, the cabic tray separation distances will be in accordance with Regulatory Guide 1.75 and IEEE Standard 284. In addition, hose stations and l
portable extinguishers will be provided in areas of low cable concentration (six cable trays or lesc) and automatically activated water deluge system (fixed) will will be providcd for areas of high cable concentration in accordance with Regulatcry Guide 1.120, Position C.4.c.(2) ,
1 and BTP ASB 9.5-1, Appendix A. Section D.3(c). I
- c. Fire barriers in the cable trays will be provided in accordance with BTP ASG 9.5-1, Appendix A, Section D.3(e).
Revision 1 of BTP ASB 9.5-1 and the current editio: (1977) of Regulatory Guide 1.120 presents guidarce for underfloor cables.
There is no prohibition of in-floor cable trenches provided adequate fire prc tection is available.
C 7,8,9-12 y 3 ,-w .w. - +,e e w= . . ,.. e- . ~ - ~ we .- =
b
f The Power Generation Control Complex was reviewed as a topical
( report in conjunction with the GESSAR ' docket. Attachod is the Staff evaluction of the fire protection review of "GE Licensing Topict1 Report, NEDO-10466, Power Generation Control Ccmplex
- Design Criteria and Safety Evaluation (TAC-4599)" memorandum l
. from V. Benaroya to R. Stright, dated July 7,1978, which we I incorporate as part of our testincny. The tests were per-fcmed for General' Electric at the University. of California research facilities. These tests consisted of using the l EWR-6 cable configuratien and Tef:e1 cebles representctive of the Black Fox design er,d inst:11ation to show that a fire in one of the esbie trains will not damage the adj: cent trains
'( cnd prevent a safe (ccid) shutdo in. These tests and the results are documented in Licensing Topical Report NEDD-lC466,
" Power Generation Control Compicx Design Criteria and Ssfety Evaluction," Revision 2, V, arch 1978. Even though the tests showed that for the Bicek Fox type configuration, a fire l would not propagate horizontally along the test cable and, therefore, could not affect adjacent cable tecys, to ccmply with tha defense-in-depth philosophy, GE will install a fixed manual halon fire protection system. with a concentra-tion of 20% and thennal and smoke automatic detectors in
, each floor section of the PGCC. Black. Fox will be provided
... with all the GE commitments and the applicant is responsible for the installation' of the commitments.
7,8,9-13
-4 ..
3.- , .- ,,-.-,,..-w- r r.w,, ,, , , ,,..e.: e .- m. w..e,-.
For fire protection evaluation purposes, the tervinttien cabinets for the PGCC design are similar to cabinets in other piant designs and were not te:ted. We required, as part of the TGCC, a mear.s for datec-ting fires in those termin?, tion cabinets which contain redundant safety divisions. The applicant is responsible for providing product )
of combustion detectors at the top of each cabinet which contains redun-dant safety cable divisions to detect a fire in any bay. Each cable division vill also be separated by c cett.1 fire barrier within the tcitination cabinets. The detectors will alt.rm locally for thare l cabin:.ts loc.ted in the control room. If the ccbinets are loc:ted l outside the cor. trol room, then the dctectors will be connected to
the rain control room fire protection panol . I is The teruination cabinets will also be readily acccssible for n'nnual fire fignting by means of hinced d: ors on front of each cabinnt that will be kept unlocked for quick access. l In-the Fira Protettien Evaluction to be performed it the FSAP. stage of review as discus cd below, the PCCC area vill be revic,ied for the Black Fox Plant. In this review, all panels , consoles , cabinets ,
including the termination cabinets and the halon systcm, will be
/"
(
w 7,8,9-14
-g
-[' evaluated for fire protection. Also included in this review
,~ will be an evaluation .to determine that the commitments made at the construction permit stage and interfaces for the PGCC fire
. protection system have. b een installed and integrated with the ,
Black Fox Fire Protection System. ,
l It is.our opinion, as well as our consultants', Gage-Babcock and Associates, Ix., that the PGCC design is an acceptable alternative to the guidelines of Regulatory Guide 1.120, specifically, Section-C.6.b in regard to fire protection in the floor sections of the PGCC area in the control room complex, tnd Section C.4.a in rest.rd to cable tray fire barrier design, construction, and separation and, l's' therefore, is consistent with 10 CFR Part 50, Appendix A Criterion 3.
These comitments by the applicant will materially reduce the proba-Hlity anc consequences of the type of fire which took place at Browns Ferry. Therefore, the staff found the design to be acceptable 1
and meets the intent of General Design Criterion 3.
(~...
7,8,9-15 i I
,f m
-m ~ ..i . ... , , , , , ,, _ _ _ . . ,
4 -, ,, - - - < , , . . . - . . .c-.,- - . - , , . . . ~ , - - , , , .,n,
Contention 9 ,
- 12. The Applicant has submitted extensive inferration in its " Fire liazards Analysis Report" concerning its proposed fire protection program. The analysis covers all safety-related areas of the plant and fire protection systees for these areas. The staff presented its evaluation and conclusions with respect to the fire protection system for Black Fox Station, Unit Hos.1 and j 2 in Section 9.6.1 of the Safety Evaluation Report (SER) dated !
June, 1977. The Safety Evaluatian Report states that there is sufficient design flexibility in the plant to alleu future design changes if required and that "the design (of the fire protection system) as presently proposed, maets ' General Design Criterion 3, e ' Fire Prctection,' end applicable guidelines in effect prior to N issuance of Branch Technical position ASB 9.5-1, and Appandix A, thereto, and for the construction pemit stage, we find it accept-able." Therefore, we could defer the detailed fire protection system revier until after issuance of the construction permits.
Our review was based on the infomation and comitments submitted in the PSAR, including all amendments and letters, which wet e sufficient to pennit us to make a finding pursuant to 10 CFR 50.35(a), thct the fire protection system design is adequate for the level of review necessary at the construction pemit stage. The basis for this
/"
conclusion is as follows:
7,8,9-16
1
- a. The applicant has described the princip:.1 architectural and engineering design criteria (plant structures, and system I design parameters) with respect to plant fire protection, and has identified the major features or ex.ponents incor-porated therein with respect to the plant fire protection systems for the protection of the health and safety of the
. f public.
1
- b. The presently designed facility has sufficient design flexi- l bility in _the area of the detection and extinguishing systems to alicu implerentation of cny design changes that may be' necessary to assure com^11ance of Black Fox Station, Unit flos.1 and 2 with Appendix A to the Branch Technical Position l ASS 9.5-1, and Regulatory Guide 1.120 and which may renscnably N
be lef t for later consideration.
- c. There are no safety questions associated with the features of the fire protection system that requires cny research and developme.nt.
The fire protection rescerch being perforced for f4RC is confirma-tory in nature. -
d.
On the basis of the above, there is reasonable assurance that:
(i) any additional protection requirements regarding the fire protectio'n system will be satisfactorily resolved at or, before the latest date stated in the application for completion of construction of Black Fox, Unit Nos.
1 and 2.
s 7,8,9-17
~ . - . - :.- , -. _ _ _ _
tw y e -- , V , y ye r m + c w rr
pe.
(ii) with respect to the fire protection system, and tahing t
inte consideration the site criteria contained in 10 CFR Part 100, the proposed facilities cen be censtructed ,
and operated at the proposed lo:Etion without undue risk to the health cnd safety of the public.
As part of thc cperating license review, we will perform an evaluation of the plant fire prote: tion syst.m which usually involves a site visit to reviev the in:tallation of the fire detection and extinguishing systems, thL cable tray configurations with their respective fire l l
protection sys: cms, and the plant's administrative controls for fire prevention cr.d fire fighting. There will also be a revicv: of the updated fire hazards an: lysis rcport to deterair.e the compliancc of j l
the plant with the applicable URC guidelines. l 1.c
' have read the foregoing testim:nj and swear that it is true and accur;te to the t'est of our knowledge. l
./
l
- 77) v .:'
Robert J, Giardina a-h / % i James D. Behn (s. V 7,8,9-18
- . .-. --. - - ~ .._ ._ . . _
Rcbert J. Giardina Prof 2 icnal Qut.lificatiens .
l Auxiliary Sytt: : Branch .
/' .
Divirien cf Sy':ce: Safety Office of liu:1 car R:cct:r Regulatien .
I an a Reactor Enginear in the Auxiliary Sy: tams Branch in th: Office of - !
!!ucitar Rtt.ctor f.egulatica, U. 5. Nuclecr Regulatory Comicrfen. In thi: }
f positten I perfer technical reviews, analyses, and evaluations of rateter r
plant fc:turt.: purcuant to the construction and opar: tion of ra c:crs.
Fduention I received a Ccchelor of Scian:t Degree in H::hanical Engin cring fm Dr:: 1 Univer::ity in 1971. In 1974 I rc:cived frc Drexc1 Univer:ity a Mart:c cf Science Degree,in Mschanical Engineering with spt:iali:t. tion in ,
ths crea of Them:1 and Fluid Scicn:er crd. a M::ter of Scian::. Degren in i Engine 2 ring Mana p nn: with speciali:atien in the area of Rcecccch and l Develo;nant and Enginccrin; Mancgement (Cor;cra e i.avel). The.resecr h paper for the Engineering Manage.mant Ds:fgn war entitled, "Tcchnoloc ;
/.cs t-::r tn :. " Since 1974 I have taken a number of cour cs en FT. and EE L Sy:te a Oper:tien, Rea:ter Saf ety, Systra T.e11 ability, Fault Tree Analysis, anci Fire Prctection. 3 Excerf ence - i ttr experience includes eight years of Engineering in the design, manufacture, e i
and tuting of Shipboard Mechanical Systes and Components at the philiadelphia :
i
( Naval Shipyard. These systems and cc=ponents included cooling water systers, ,
I propulsion systems, fire protection systems, hydraulic system, and ventila- j
. tion. systems.
i
+
.7,8. 9-19 ie
' ' ' ' ~ ' - , . - .
V %.--,,-,, _
b ' *. . . .A. . .% .2 e ~ -2
- i
^
/' I joited the Auxilicry Syste.s tran:h of th: Commin icn in 157.'. ,
+
i Since joining the Co=r.ission,'I have performed safcty evalu tions on '
l rpent fuel pool cxptnrien: for five planti as well e.s provided input I to or revised the Division of Oparating Reactors pe:ition on spen,. .
~
l 1 fuel peci expansien, The Enviren=2nt:1 Impact Stattmant o.n Spent ! l l'
Feel Storr.pt, the Regulations en Independent Spent Fuc1 Stor:gc l Facilitics (10 CFF. Part 72) cnd P.cgulatcry Guide ind Ettndard i:eview . i Plan: en Spent Fuel St: rage (en and off-site). I havn been c:tively involved in the investigatien cf the stc:. ptnerator feed wtter hc=sr I pr0b1cm and was e mader cf the Commission's Ec.:er H: ant Ttsk for:e. ]
~
I am prestatly revicwing er have revic'.>td cnd evtlutted the cur.iliary 1 l
L systc= cf five nu:1:ar poutr plants t: well ts cc rdintred f. ire pro- I tcction reviews for three nuclear power pit.nts.
I hav: recce:sfully passed the test fer End w:.s cw:r:'ed the certi-ficate of Engineering-In-Trtining. .
Oreni trion.31 !MS*:hi t:
I tm e. ranber of Pi Tau Sign. - National Honorary Machanical Engineer-ing Frticmity and of the American Management Associations. I am 1
an Asse:iate Member of the Am:rican Society of Machtnical Engineers. t i
I am an active Tnerber in the Boy Scouts of America and a Brotherhood Member in the Order of the Arrow, of that organi:ation.
7,8,9-20 e
1
Prefer fens 1 Oualifications !
t ,
" '. Otrar D. Sehn t Ccg2-C:Accch & A ::ciater, Inc. -
(
i P.y r.:c: ris Jamar D. Ed. I t:n caplorcd ts t It:ff cnsinuer at E:Go--
B:10 :t ced A ::::ict22, Inc.,125 /ddis:n Avenue, Elr.iurst, Illiccia. t l
i C:.;2-N.S:::k t.nd /r.:::itter is ender c:ntract ):ith Sandia Labortt:rie [
to pr: vide fire prett: tion cer.: ult tion to the Aur.ility Synti?.s Ertn:h' l
cf t.M U.S. I m teticting ths Au::ilitry Sy: rs tranch in Mvicwing '
tM fire pretc: tie:: prergru. cf nucic .r pwar plant: cf t.tich tic.ch Fc::, ,
I Unit kr.1 c.nd 2 fc cnc. Tha Auxilic y Syst m. Eranch in rerper.:ibic for revic ting rect r licen:t tppli ;ti;ns c..d cyclu.tix hc cenign of cc::ilitr/ ryv.tes, faciuding. the firt. pr::ttett:n ry::: r, of the nu:1ctr ,
s pc.ter picn: dth renc:: t: nu:1ctr raicty.
I att:r.:-d I11taoi Institute of T:.cha:1c;y in Chicap, Illin:in, z.nd re: ived a B.S. Degras in Fir: Prc:cetien Engincerirein 1970. I have airo at rnded varicus ir.de:tri:1 etminars dealing c:::1y with fire rafety.
I'htvo a t0:11 cight yscrt of work expericnce with mjor projtets as st.ted below.
I was first employed at Underwriters Labortt:ry in Chicsgo du-ing the st:trars of my junior and senior years at I!T, tasting fire resistanca f'
I
(_ ratings of various walls, doors, colu=ns, etc.
' Fram 1970 to 1771, I was empicyed at Marsh' and McLennan, in Chicago doing:-
t I
basically fire prettetion inspection of various indu: trial sitas in the
~ Chicago area, including factories, offices, hospitals, foss.il fucted 7,8,9-21
. . .._, . # - <= - . . - , aw.,, .
w v + - , -
. s - .-.-. . . - - . - . . . . . , -
i
. g-
/
e >
t i
( a b, y, .
i t
p w:.r plent::.::nd ts1c.; hone c:=unication cutcr , end terting their j; 1
in.~ ..,.aiu
.. 1.i.. .a......-,..... 4. .y . .. .
Fr:: 1571 to 1572, I wori:d fer CTE Aute:ctic Ele:t-fe, a :::r. Tunic:. tion
- i r.nd r ie:rtphic c:.nufacturar, as a Fire f'retcetien and 5:fety Enginsar. l l'y &th: includcd til try.:ts cf ft : pr: t::'cn and 5:fcty te they P,.lat:
m , , .. , 1 n,:.. .. . .. t
.a, .
t Erring c :br? p;: Tod cf th: in 1572, I c.s ti::. er.;.leyed ct P.rta El e.. ~. . 4 .. " .. . .. ,, r . i r.~- p.',t.$- v * ".i +. a. e.'. - - - - d-#~ -
r- v
~,
E '4 i < ..u'i r ' . - * ' 6
- a b " # c4- 'a 1 }* r-
. .a pNvice: c ;1cFant, l
?
In 'i .t ~e '.). . I +^ . . "~~d
- r. . . 4;i r. , f o r G.' e. .~~.a._ ~
.'. .~. '..2. .d. r%. c .-i c *.". ." * *. r 4 p:'otecti:n t.r.d r:fety cen:uittnf. f t.( c .jor t.::ivitte.2 hav ber.n in th2 rc:, of (1) surv::ying :nd ev:1ucting cxt:: ting fire pret.ntica :.y.:t .c for varien: indu:trh.1 facilitic.: ta dretrr,ine their nd::,cacy and ra:=::nd ticc=7:ry igrove.'nants cnd (2) design cf fire de.:scrien and suppr=:icn .
- yst=s as=ctated with (1) abete. l 2
1 I tc presently providing fire pretcetten centuiting to the Auxiliary !
t l Syst== Branch of the NRC.
l 7,8,9-22 4
3 4
h 1
,n -,
, e.
,p.+- +- ~ , - - , , -, - , , - ---.-w n
.-._r_.-- ._-_
f'(.. % vtnTED :i;. :c ' ,Q ,(,4 $./ *
.. '.t ...,./
%n f!UCLEAn REGULATCRY CCJ.".Micc!OTJ .
j, Y. A;HtidGYO's, D. C. 205.55
. n gl
. . v', /. -3 1 1
r s.t..v,,llt.:
%. ,'l' $ JUL 7 1973 :
, fCiDPIND'J" FOR: R. Stright, Project Manager, Light h'cter f.eactors Eranch 3, DPM l
( ! l FROM: V. Benarcya, Chief, Auxiliary Systms Branch, DSS , l l 1
SU5 JECT: GE LICEiiSING TODICAL REPORT - NEDO 10465, "PO' DER GEriEPJTIC" l
CONTROL CO?'. PLEX DESI2N CRITERI A AND S AFETY EVALUAi!0N (TAC- ;
4699) l Report I: umber: NEDD-10466 Report iith: Power Cencration Control Complex Design Criteria ar.d ,
Safc ty Evalur. tion l Responsible Branch: LURl'o 0 . <
l P&;uestid Completion Dtte: De ccaber 12, 1977 l Revie.. Statu;: Ccap h .e 1 The encMed Topict.1 Report Sciety Evaluetion covers the fire protection I evalu:J.mn of the Pc.ar Generacien Control Complex (PGCC), for which the l Auxii- '" Sys ter:7 Br? ,ch t n rc . iew re:y:nsibili ty. Gur revicw was based on the E:. Topical f.eporL NEDO-lG466 up to and includinc Rcvision 2 and the series cf full scale fire tocc: perforr;:' on the ficor sections of PGCC. __
l
[.- The NR'.. ccust,ltants , Gege-E Lbccck & As:,0ciates of Chicego participated in I
( ;he revie.v of the Topicci Rt. port and the fire barrier tests and results .
I and they are in agrecir.ent with our evaluatico and conclusions. } l l
l Based en the revised Tepical Re> .et and the results of the fire tests, we conclude thct the dcrien bases and criteria for the fire protection of the GE-lTCC are accectable. Tht bases for our conclusions are includcd in the encicceo evaluaticn. ,
\ \[5 w V. Scnaroya, Chief ,
Auxiliary Systems Brar ch ;
Division of Systems Safety '.
i cc: S. Hanauer i R. Mattson l R. Tedesco J. Glynn C. Long
( 0. Parr
( D. Vassallo ;
P. Matthews D. Fischer C. Miller M. Srinivasan W. Le Fave D. Thatcher 7,8,9-23
'~
FIRE PF.0TECTION 5AFETY EVALUATION GE TOPIC /.L P.EPORT, NEDD-10456, itEV. 2 POWER GENEP.ATION CONTROL COMPLEX p..
I
% /
FGCC Fi e T rot etion The Powar Gent: ration Control Compicx (PGCC) is a prefabrication con- --
cept for routing and installing cabling for the control room of boil- '
ing wt.ter reactors. PGCC consists of three major assembles: (1) a set of steel floor seccions, (2) a set of termination cabinets, one for c:ch floor section, and (3) a set of interpanel cables. The steel floor sections contsin raceways to provide routing tnd sepa-ritior; n' All interpanel cabling. The coerator panels and the the signsi caan ticning panels will be nounted on the ficar sections.
These ptncit arc not cor.siderec a pcrt of PGCC and will be reviewed on a plan:-by-plant b; sir. The tereinttien cabinets provide the intef6ce N .een tne field installed cabling and the factcry in-sttilcd cibl:: in tf e floor sectiere. The fire protection system fer thc ~7JC rill consist of fire detection ar.d suppression for the ficer scctians and fire detection for the termination cabinets -
4 The "R: corcultints, Gans-Etbock and Associates, Inc. cf Chicago par-N- ticipcted in the review cf the PCCC Tcpical Report and of the fire bcrrier t:sts (described below). This evaluatien includes the rec-comme ndi ti c n: of the consul tar.ts. Gtpe-Bibock and Associates Inc.
con.: . with our evciuation and conciations.
Gene rl Electric has performed fire barrier tests for the ficor sec-tions of PGCC at the University of Califorr.ia lacoratcries in order to de~cnstrate th3t a fire in ene ccble safety division wruld not prrpa; ate or cause un:.cceptable damage to a redundant cable safety disision in an adjac;nt raceway. The test fire and acceptance cri-teria were tgrced to by GE and the sccff before the tests. The tests were perform?d to deconstrate that PGCC had acceptable fire barriers between cat.le divisiens. A description of the fire tests and their results are contained in the PGCC Topical Report. Conservative fire tests were cond"cted by placing conbustible material within one ca-ble division raceway and removing floor plates from each cnd 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 cable resulted in a fire which propagated partially in one raceway and produced consider-l able smoke; and (b) Tefzel in:ulated cable resulted in little or no
\s. fire propagation in the raceway and considerably less smoke genera-7,8,9-24
- D' . l
~
\,
tion throughout the test. t i
At our request, General Electric has included provisions for a ges ;
' fire suppression system (Halon 1301) in the floor sections for all l I. PGCC configurations. iThese systems will be automatic for non-Tefrel ,
insultted cable be:.ed plants and manually initicted for Tef:e1 insu-lated cable based plants.l The Halon su; ply system external to the ficor sections will be the responsibility of applicant referencing l PGCC. GE has provided acceptable interfaces for the design of the Halon system. GE has also provided quici. opening covers on the ~'
floor sections for manuti fire fighting purposes. i Fire detection for the ficor sections will consis t of two thermal and one product of combustion detector in each lon;itudinal raceway.
Tnese detectors will be cor.nected in a zoned configuration to indi-cetc locttion of a fire by floor sectior. Appliccnts referencing PGCC will be re.ponsible for the zoned system external to the PGCC.
Ter fire protection evaluation purport , the termindtion cabinets for the PGCC design cre sim.iiar to cabinets in other picnt designs and were not te;:cd. We rcquired GE to provide a means 'er detect-ing fires in th:se termination cabincts which contair re andan: stfety divi:d e- GE prov.ided product of ccmbustion detectcr3 a+ th2 top of
,_ cach car. net which contains redund r.t safety cable divisions te e.t:ct a fire in any b y Each cable division will also be scr-
{ crt.p d by a metti fire barrier within the terminatico cabinces. M detc: tors will a l ; r.T locally for those olants where the cabinets are loc:;ti an ti centesi road. If the cabinets arc located outM e2 tne I contral roon , ch c :ne catectors rilil be connectea to the main centrol C'~~4 rc. : .a,,_ D r *. *m' ' ' '.'. '. t'..*. .9ET I..
T!.a termination cabinets will also be readily accessible for manuel fire fichting by means of hinged doors on the front of each cabinet that will be kept unlocked for quick ccccss.
All panels, consoles, and cabinets other than the termination cabi-nets will be evaluated for fire protection on a plant-by-plant basis since they are not included in PGCC Topical Report.
Based on our review of the design basis and criteria for fire protec-tion, interface information and the fire tests, we conclude that the '
proposed design is in accordance with Regulatory Guide 1.20 and General Design Criterion 3 and is, therefore, acceptable. ,
7,8,9-25
. _ . _ . . -a,-.n.. -- , . . - . - ~ .~n- - ~ ~ ~ . .
I 7016 ;
4 david 5- MS. WooDHEAD: These witnesses are available 2
for board c2: amination and cross examination.
CROSS EXAMINATION j
~
4 .
BY MR. GAIlo: .
O MI . Giardina, looking at your testimony, I am 6-a little confused as to what'the applicable Reg Guides tre 7
and regulations. I wonder if you would bear with mc {
I B
and explain to me which ones you think are applicable. ;
O Would you agree with me that if we start .
10 with criterion three of 10 CFR Part 50 -- i II A (Witness Giardina) Yes.
l I
O I cm talking specifically with respect to the [
l' C I'3 Black For station; it is my undersinnding that the s i
I4 branch technical pocition 9.5-1 dated May 1, 1976 and 15 Appendix A are applimble to the Black Fox station.
16 Would ,su agres with that? j 17 A res, they are applicable to Black Fox.
18 They are used by their staff in review of the !
O i
I9 fire protection analysis of the Black Fox station; ic {
20 !
that correct?
i 21 A They'are one of the documente, yes.
22 I understand there is a revision one of the
,. Q l
~
U bnanch technical position. ,
M A There is. ,
25 l Q 9.5-1; is that correct?
l 7017 david 6 I A There it, t 1
! l
^
2 O Do you romenbar offhand what the dato of that i j i
2 is? .
( 4 A No, not of fhand. !
5 0 Is that document used by the staf4when' applicable, i lG to the review of the Black Fox station?
7 A The applicant can use that document in the G evduction of the fire hazards analysis. The attff would ,
9 use that docurcat in its review. ;
i 10 If the applicant had used that document or if l It he felt that document was more applicabic to the criteric --
t 12 0 I'm sorry, have you finished? ; l i l
. 13 A Yos.
14 O So that if I undcrctand it, the cpplicant has 15 hic choice as to whether to use the May 1976 brcnch technical i .
l 1
I l
'16 position Appendi:: A or the revision one to that technicci i l 1
17 position or both?
18 A That is correct.
end 18 19 1
l wel . fis. 20 1
21 l
22 '
+.
1 24 1 1
25 1
t i l
4 .egy - , p.go heip., y
,g* 4 gg 19WEL
""1 7018 1
Q Am I also correct that Regulatory Guide 1.120, 2 Revision 1, is not considered by the Staff to be applicable 3 to this review in connection with the Black Fox Station?
4 A The Applicant may use that Guide as a reference, i l i
U and we would review their application in accordance with G that Guide, if they use.it, or sections of it. Excuse me. l 7 'O Have you finished your answer? l 8 A Yes, I have, f j i
9 ! So, once again, it's the choice of the Applicant?
O l 10 A That is correct.
I i li 0 Now, in your testimony, I believe on page 5, you t
12 indicate that for.the Black Fox facility that guidance is l i
~
12 '
set forth in the Branch Technical Positio- dated July, 1976, ! j l
14- ,
as well as Appendix A to Branch Technical Position and f i i 15 Regulatory Guide 1.120. l 16 In what connection did you need the application l 17 of Regulatory Guide 1.1207 16 I lA I'm sorry. I don't understand what you're asking, f 19 or the meaning of your question.
20 Q It's my understanding that Dr. Cox, in his Fire ;
i 21 Hazards' report, addressed himself to the Branch Technical !
i 1 22 Position of Appendix A dated May, 1976, and not to Regulatory l l
E 23 Guide 1.120, Revision 1.
I 24 !- Is that your understanding?
l 25 A Basically, yes. i l
i A
,(
-- _~ - . - . .- . . . -- .-. . . .- - -
I 1 7019 1 1
- ! I wel 2 1 j Q All right. Then when I look at your testimony j 2 i)i I see that you also are -- strike that.
S Do you also agree Nith me that it was appropriate .
- t 4 ,! I for an Applicant to make that choice in this instance? i
! i 5' A Correct. i 6 ,
Q Then I look at your testimony and I cee that I l I 7 l Regulatory Guide 1.120 is being indicated as a review basis ,
l B11 document by the Staff. !
't Sb '
A That in true.
it <
c ,
10 .h O Was that in connection with the PGCC? .
l r.
Ith A It would be in connection with both the PGCC and i D
12 S the Black Fox Station.
jl
~
13 (! O It would be in connection with the PGCC.
9 it 14 it Now, with respect to the Eleck Fo:: Station, if the t
t' :
- g g' Fire Hazards Analysis report was predicated on just the l
g ,] Branch Technical Position, why would the Staff use the i!
g .a Reg. Guido nonethelesc?
a y,
- n y - A Well, the Rog. Guide in its later revicions and g
tg {! revision 1 10 a little bit different than the original ;
j! i I
20 il Branch Technical Position.
21 4 The revision sort of incorporated more realistic II
. ::, [ items into it, and some of these realistic items loosened [ i n
ny.l some of the requirements of Appendix A and the original
\
i,; - Branch Technical Position. ;
33 : Therefore, we would review the plant under the 1 4
i e 1N l
~ -. . - . - ~ . - . . . _ . .. . - - . . . _ _ _
7020 wel 3 I less stringent requirements of the Reg. Guide, rather than
- 2 under the more stringent requirements of the Brcnch Technical 3 Position.
P 4 O I see. Where you feel that in some areas the {
I P Branch Technical Position may be over conservative, you 6 apply the more realistic guidelines of the Reg. Guide?
7 A That is correct. ;
i 8 0 I see. !
i 9 CHAIRMAN WOLFE: Would the witnesses use the I l
10 hand microphone, please? l t
11 BY MR. GALLO:- l 12 O Now, the Regulatory Guide 1.120, Revision 1, as !
- 13 I understand it, has been out for comment for over a year, 14 is that correct? j 15 A (Witness Giardina) I think so. This is Revision f I
t 16 1? Yes, it's been out for about a year. j l
17 G Are you familiar with a memorandum written by 18 Mr. Robert Minogue dated November 7, 1977 with respect to 19 the distribution of that draft, Revision 1, Reg. Guide 1.120?
20 A I haven't read it, but I've seen it.
21 0 Then you are familiar with it?
22 A .Yes. ,
23- 0 Do you recall that in that me'orandum it was 24 indicated that the review period would be appror.imately a 25 fyear?
i 1
1 J --
. .s . . ~ . , _ . . . _ . . . ~ _ . . . _ . .._. _
_c-t 7021 i
wel 4 i MR. FARRIS: Objection. He indicated he hadn't
) read it. He said he had soon it, not tha*: he could recall i
l'whatwasinit. !
i 4 I' t MR. GALLO:The witness said he was familiar with ;
i l 5 I it. l
! 1 6 I'11'ask this question:
7 EY MR. GALLO: i 5 Did you read the memorandum?
Q l ,
) i 1 e4
- :'p- A (Witness Giardina) No, I hcyo not read the '
U memorandum. ,
i '
er Q In what respect are you familiar with it?
l 1
IEq A It was the cover sheet, when thc Regulatory Guide j D revision came out, and it was right on top. I've looked at h
M $r it. I saw it, saw who signed it. But that was about it. ,
...- e 5; Do you review Regulatory Guides in your normal Q
J II h review practice? ,
M1 A Yes, we do.
i i 15 0 Did you review the cover memorandum from Mr. ,
t.
29 Minogue? f l
20 (j A That is correct. l t
i E ! O Do you know, of your own knowledge, whether the i
22 review period for the Revision 1 to Reg. Guide 1.120 was for I '
- E3 i approximately a year, beginning November 7, 1977?
24 l A It was my understanding that tha Reg. Guide wac ,
af f supposed to be out for comment, and I think it was supposed {
4 I
-- - - . . - _ - - . . - . . . - . - - - . ~ \
7022' I wel 5 I to'be out for comment for a year.
i 2
~
4 O Do you know what the present status is'of that l I
. ( ,_
3 Reg. Guide within the Staff?
!,., - 4 A Other than that it was out for comment, that's ,
1 I
5 about all. I have no idea whether it's been approved or not.
6 Q Looking at page 5 of your testimony, I believe at 7 the top of the page you have a quote. That's a quote from 8 Appendix A, General Design criterion 3, is that right? ;
9 A That's a direct quote, yes, sir.
10 MR. SHON: Mr. Gallo, it might help us all if you II made certain to identify the Appendix A you're talking about 12- directly. There are two Appendices, both called A, involved ; .
I
- 13 in this particular subject. One is Appendix A to Part 50, 14 - - and is a regulation, and the other is Appendix A to the }
! l 15 Branch Technical Position. j 16 ' tm. GhLLO: - Certainly, Mr. Shon. l 1
1 i
i .: 1 17 BY MR. GALLO: I !
18 0 Let me state the question again:
-l 19 At the top of the page you have a direct quote 20 from Appendix A to 10 CFR Part 50, Criterion 3, is that 21 correct?
i 22 }
A (Witness Giardina) That is correct.
'(+
23 : O Is there a definition of an exposure fire in that l l
24 wording? !
25 A I would interpret "effect of fires" as exposure firci.
i
- i I i
- -w ..* * . A 4 W M hehe$ AmGres.i.hada.w, -%
7023 wel 6 I )I. I think Mr.-Behn would be better able to interpret that, since
,, 1
' he's a fire protection engineer. I am not.
]
3 '; .Q~ Well, let's stick with your interpretation first. >
4 Where in there do you see the words that define [
- 1 1
5 exposure fire? .
l I
G A It's roughly the fourth line, where it says, 7 I "the probability and effect of fires and explosions." l I .
O j .Q Probability and effect of fires and explosions.
9i And you construe the words " fires and explosions" to bs an b
W 4 . exposure fire? :
i H I A I construe the effect of fires as being an i
12 I e::posure fire. Explosions are an entirely different thing. ,
- 13 i O Well, it's my understanding that -- as I understandi I l-i 14 ; the term, is that an exposure fire deals with the source or ignitor of the fire. Is that your understanding?
Eh ,
? .
14 ,; A MR. FARRIS: Objection. He's already given his I!
U understanding of what this languago meanc.
t IF , CHAIR!ULN WOLFE: I'm corry, Mr. Farris. I didn't .
1 i f
19 1 hear you.
10 MR. FARRIS: He's already told counsel what his f I \
21 understanding of these words moan. He's arguing with the !
22 i witness. ;
',}
'- MR. GALLO: -I asked him a different question, Mr. )
21 f. >
l; i.s ,
Chairman..
25 p CHAIRMAN WOLFE: It appears it is a different t,
((
' r e t w -
t , > , -e
. . .. _ . m . .- _ . . - _
7024 wel 7 I question.. Objection overruleL
. 2 WITNESS GIARDINA: I think Mr. Behn wotild be much 1
3 better_ qualified to answer that question than I am.
4 BY MR. M M:
5 Q You don't have an opinion on that point?
6 A (Witness Giardina) As I said, Mr. Behn is the 7 expert. 'I am not. My opinion would bear no relation to the 8 caso. The Guides were developed by a fire protection engineer, 9 and an interpretation of what an exposure fire is should be 10 left to the fire protection engineers.
11 O I see. Are these fire protection engineers at the 12 HRC or at a non-governmental organination?
- 13 A The guides were developed by a fire protection 14 engineer at NRC, but we do use consultants to review the 15 Fire Hazards Analysis, and their interpretation is just as 16 good as the NRC interpretation.
17 Q All right, Mr. Behn, let me ask you:
la Do you see the term " exposure fire" defined in 19 Criterion 3?
20 A (Witness Behn) No, I don't, but I think the design El basis fire is an exposure fire.
22 0 But at least it's not here in this section, is 25 that correct? l 24 A Correct.
~ P.5 I Q I didn't hear your answer. l l
t
- ~ ~ .c . _ -. - .
! i 7025 wal 8p) 4 h
1 5 A- Yes.
I All right. Thank you. I
- Q 3 We'll turn now to the Branch Technicci Position !
4
> f
- - 4 '
9.5-1 dated May 1, 1976.
t F MR. SHON: If we're going to talk about this .
6 Branch Technical Position at some length, could the Board +
1 7 get a copy of it? j 0 MR. GALLO: Yes. Do you have one, Ms. Woodhead?
g i MS. WOODEEAD: Yes, I think so.
(
10 ! (Document handed to the Board.)
\
ii j BY MR. GALLO:
1; i Q Do you have the document there, Messrs. Giardina k ?
13 i and Behn? l l
it g A (Witness Giardina) Yes, we do.
I tr O I'm looking at the section that has the caption, je t
" Definition," and I wonder if -- Mr. Giardina, first -- you, ,
, ;. unless you want to pass to Mr. Behn, could tell ma whether .
g y'l or not there's a definition of an exposure fire contained
't ip under the category " Definition?" i l :
e ao ') A (Witness Giardina) I will pass to Mr. Behn. :
' i '
A (Witness Behn) Yes, I interpret that as saying ',
- 3
]
,. 3; j the fire that causes the most severe condition to be an l
- t. 21 i- exposure fire. ,
l'
- g ' [ Q Could you point me to the place where you got t
that conclusion from?
arL!
l.
I r
h
[ i
7026 wel 9 I A The first sentence, are those that are considered 2 to cause the most damage.
S O Well, are you reading from the definition of the f i
4 term design basis fire?
5 A Yes, I am.
6 Q Do you consider that as being an exposure fire?
1 7 A Yes, sir. ,
C Q Now, how large an exposure fire do you believe 9 this definition contains?
l 10 A An exposure fire is a concentrated source of fuel j 11 that can be moved around the fire area and result in the most 12 damage to the area.
l 13 0 Well, how much fuel do we need?
l t
14 A Again, it depends on the fire area and the cable j l 1
15 tray configuration. A corridor that may have redundant trainsi 16 in it may have four or five soiled laundry carts in it, whereae l
t? a small room that has redundant trains, the possibility of 10 i using these in the small room is remote, because they won't 19 fit. So we consider another exposure fire, such as the 20 flammable liquid.
21 Q So am I correct that a person would have to look
,1 22 j at the reactor configuration and determine the so-called fire
- areas, do you agree with that?
21 }
24 A~ Yes.
EC l O Would you then identify the combustibles in the i!
l 0 i
_ . _.- .___._..___u.. __
d '7027 ,
wol 10
{* i t
I area in order to come up with your exposure fire? i e f i A I would identify what's reasonable that can bc ;
l '
, i
~
j brought into the area as a transient means, transient ,
/' combustibles, j I
n ,
Q Would you disregard combustibles that were there I
6 37,o7 i
7 A No, I wouldn't. {
l l
0 You would not?
Q ,
E ,
A No.
IO Q In your analysis would you assume that transient ;
Il
}' combustibles could be carried throughout the reactor as a i
C general proposition? 4
^ IS A Ifthereactorisaccessibleduringoperation,yes.;
I#-
{ Q You would not look to see what hind of cituation ,
i i 10 existed in a particular fire area to determine whether or not ,
i o
KN it was ronconable to conclude that combustibles would be l lI I 'i , located -- I'm sorry -- transient combustibles would be j i
I6 flocatedinthatroom?
I9 i A As I said, if the fire area room is accessible EO during operation, I would consider it likely that transient t
21 :! combustibles can be introduced into it. '
1 2E O Uhat do you mean by accessibility?
! f 1 1
'2 4 4 A In other words, when a person can go in thero i E4 j! without'protectivo clothing. The radiation level b such i U
that no clothing is required.
2f h {
L :
b .
.14w. .m. , .g.w w J.e.e e 4 2-- %_
wel 11 7028 1
Q Run that by me one more time,please.
2 3 recs accessible without protective clothing.
3 O Do you consider a cable spreading room as l
4 accessible during plant operation?
5 A Yes, I do. l l
6 O Did you hear the testimony of Mr. Engmann, who l 7 indicated that there was very lbmited reason to go into the C cable spreading romm?
l 9 A Yes, I did. I to O Do you have any reason to disagree with that i
11 statement? ?
12 A Yes, because I've been at plants where there have i i
13 been combustibles in operating cable spreading rooms.
l l
14 0 Was it a plant that had a lock on the fire door, ;
15 and was a vital area from a security standpoint?
16 ,
A Yes, it was, i
17 I Q What is the name of this plant?
18 A (Witness Giardina) I think for the plants that 19 are still under review in which this condition was found, I 20 don't know if we have the right to divulge that information.
21 For the plant that we have completed the review in which we 22 ,
originally found this to be true, I think we probably could 23 ; divulge that information. But I am not positive. That would 24 be a management decision.
25 [ MR. GALLO: Well, it seems to me that's a matter ll 1
i l-
- m.. . b + i ewans[a -- .n -..%,-.a4-7029 wal 12'
'l for counsel to determine, Mr. Chairman. The witness can't !
2 ,
arbitrarily decide whether or not he can disclose something. ;
i .
-3 [
i.
CHAIRMAN WOLFE: Unless there's some objection, f 4 answer the question. !
5 MR. FARRIS: Mr. Chairman, I hate to protect the }
6- plant, but I think it's probably irrelevant to Black Fox 7 Station. He says he's observed it in a plant. I don't know I L what point the identity of the plant has. The point in that E .fitcangetinthere,inthiswitness' opinion.
I i 10 MR. GALLO: Mr. Gallo, it goes to credibility of l l
11 j the witness' statement. !
t i l i
12 r He said with respect to the plant that ho looked 12 ,
at that it had some of the same administratd.ve controls as i f
ic n Black Fox, and in answer to my question about the name of the 15 : plant there appears to be some concern.
I t I .
16 , I'm not clear what it is.
-i i
p 17 e MR. FARRIS: As an aciidemic proposition, Mr.
h'I 18 l Chairman, I agree with Mr. Gallo, that it would go to the i i !
19 .
witness' credibility. But Mr. Gallo, you recall, has stated j l
20 i; to this Board that credibility is not'an issue here. ,
j !
.f (Laughter.) !
21 [ .
p El f. MR. GALLO: Mr. Farris will recall that I !
f l 13 [; im:nediately corrected myself that the demeanor of the witness ;;
i i y [ was'not important in the proceeding. I
- 1 t 1
, 25 [ MR. FARRIS: I'll withdraw my objection. e j l
h I L t :
I I l
I
- e -u.n.-~.a.- s - -.
I 7030 I
wel 13
! 1 CliAIRMAN WOLFE Ms. Woodhead?
e 2 MS. WOODUEAD: I have no objection to the l1 3 question, Mr. Chairman. I 1
4 CHAIRMAN WOLPE: Objection overruled.
5 WITNESS BERN: There are two plants. One plant 6 was Salem, in which they had a gas welding outfit and 7 combustibles stored in the cable spreading room.
8 The other was Davis Besse, which had flammable 9 liquids in the cable spreading room.
10 BY MR. GALLO l t
1i Q Both of those plants had computer controlled locked l l'
12 doors, like Black Fox?
13 A (Witness Behn) I don't recall.
14 Q Both of these plants had limited access of i
15 personnel to the cable spreading room? l i
16 A That is correct. l l
17 0 Did both of these plants require supervisory 18 control in terms of permitting access by other employees 19 into the cable spreading room?
20 A Yes.
21 0 Were both of these plants considered secure areas 22 '
from the standpoint of compliance with security regulatione
~ 25
- l. of the Commission?
14 pl A I don't know the security regulations of the F5 .
Commission.
I b
. e t-7031 I j.
I.
wel 14 :
, i.
Q Do you know whether or not both of these plants !
i
'~ "
j were considered secured areac? >
.t
'I r
A Yes.
<~ , , I Barb fis l 1 1
5 l I ; I
& : l 6 l r
l
~
l l
1 0 .
i,
(
\ s O
s
[
10 l l
11 i .
I
! . l t
O
'L s. t t
ib '
O 8 s e.-
1 l
sg ,
s' i
- k. . ,
E 16 :,
i i
"n .C j i
i 20 l i
,t i m.
m ,
6 b
_2. C ,
5
' ,.* t
%- 41 0 .g I J
[w * $,
e !
ar ,
?
l Is .
I f 1, ,'
I.
-,,e ivs_
DW20 arl l l
0 You i.'dicctc6 when you 7,ppl_ed t'. '.s desi.:ition 1
3 in 9.5-1 concernine nnt decign bacic firc, ycu votid assume ,
1 that with combuctibice or the transient corbustibles, they I 3
4 would get into the various fire arans of the reactor- is l 5 that correct?
6 A That's true.
/
Q How do vou determine how much transient d
corbuctible getc into the fire?
8 ,
I g A I think you have to use enginatring judgment on l l
this, and what I have seen ic -- can go frcr a half a pint l 10 11 f flammada liquid all the way up to 300,400 pounds of Clsos Aj I.
combustible material.
12 l g3 0 It can be anywhere from a smc11 cc:abuctible item that can be inflammable te something largs; is that 34 correct?
15 l A Thct'c true. I i
16 ,i O And you don't - do you hcve cnr part wcarc and g
engineering judgment as to your standard average trancient combustible?
A Agci I w uld rely on engineering judgment and O
what the utility thinks is in their judgment is realistic, that the transient material can be b cught into the crec.
G You rely on utility judgment as well as what 2a, is realistic to bring a trancient ccaburtibic matarial into a particular fire z.rea; is that correct? l l
1
~
ar2 7033 1 A Yes.
2 Q Mr. Giardina, am I correct that in your --
3 strike that.
4 What are your normal duties'at the NRC?
5 A (Witness Giardina) My normal dutiec at the NRC 6 are to review the safety systems -- auxiliary systems in 7 the reactor plant which is the balance of systems outside 8 containment.
g Q Does that include the control room?
10 A That includes the control room.
O And you reviewed these systems from a fire 11 12 protection standpoint?
A We reviewed the systems from the systems stand-13 point and fire protection systems is one of the systems we 14
- "i*"*
15 O D you use, in the ordinary course of your 16 g business -- strike that.
Do'you use, in the ordinary course of discharging 93 your duties, Branch Technical Position 9.5-1, dated May 1, 39 1976?
20 A Yes, we do.
21 g 0 So, then, you are familiar with the term design
'I t.
g basis fire as it is included in that document?
A Yes.
0 Did you rely on Mr. Behn to indicate application?
25
_ _ - -. . , . - - -.--.a ,
1 70x
-ar3 1 -Is that.right?
I
.- 2 A. That is correct. Hc does the r0 View, c.nd we 3 evaluatp his. review, e 1 4 Q. You have no independent opinion vith respect to .
l
.5 what that term means?
l 6 A Yes,'but as I said before, I am not a qualified {
3 1
7 fire protection engineer.
8 Q Now in the areas of your responsibility, Mr.
9 Giardina, do you apply it as adefinition for a design 10 basis fire uniformly?
11 A Yes, sir. It is applied uniformly throughout 12 the review procedure.
i
^
13 .Q. Throughout the review procedure?
14 If I understand this definition, I will switch 15 t Mr. Behn for this question. .
16 You correct me on this, Mr. Behn, becauss you are !
ths expert.
$7 As I understand this definition, it is a fire 18 jg which.in of sufficient intensity to essentially burn up all 20 f the; combustibles in a particular fire area? .In that 21 corrac't?
22 A (Witness Behn) Yes, that is correct.
- k. 23 ..Q Is there any other interpretation of this defini-i g tion?
t
-. _ __., _ _. _= o__.._. _. . _ . _ .._. _.
Gr4 7035 l' O You can Tive the microphone back to Mr.
2 Giardina.
3 As defined by Mr. Behn, do you apply that e l 4 definition to the control room?
5 A (Witness Giardinal Yes, that would be applied !
l 6 to the control room.
7 0 Do you presume that in connection with the control 8 room, that the design basis fire will burn every combustible l 9 wire or the insulation of every combustible -- I'm sorry, 10 let's try again -- that the fire will burn the insulation 11 on every wire, and also burn every other combustible within 12 the control room?
13 A It will be assumed that -- in the evaluation 14 that the combustibles in the room would burn.
15 0 Is that what you -- is that what was assumed 16 for purposes of the review, the general electric control 17 room, called the PGCC?
18 A I did not conduct a review of the PGCC. It 19 was reviewed by one of the other reviewers, and it is my 20 understanding that they conducted a test to justify their 21 procedure, to show that under the operating condition that 22 they would have in the plant, that the system would not 23 propagate a fire within the PGCC complex.
24 0 Then you don't know whether or not these other E5 reviewers applied the definition of design basis fire as
--q-
[ 7036' !
ar5 [
1- defined by Mr.' Behn,.do you? h f
-. .2 <
A A Gage-Babcock reviewer reviewed the complex. -
s 1 s
0 I'm asking what you know. Do you know whether er -,
8-4 I not the reviewers in connection with the PGOG used a 5 definition of design basis fire as defined by Mr. Bohn? I 1
' I c A I would assume they did.
I !
j Q You would assume they did? All right. ;
g Mr. Behn, can you tell us whether or not the -
3 design basis fire as defined by you, was applied to the PGC0 10 control room? ,
- $ f A (Witness Echn) I don't know.
12 O You don't know?
l g Were both of you in the courtroom when Mr. .
l g . Johnson and Mr. Gang testified?
g A (Witness Giardino) Yes, we were.
16 i
A (Witnces Behn) Yes, we were.
g Q Did you hear cither Mr. Gang or Mr. Johnson --
g I believe it was Mr. Gang -- describo the nature of the gg erposure firo that was used for the design basis for that l
, 1 l
facility?
20 3g A Yes, I did.
g f A (Witness Giardina) Yes, I did.
23 0 Did it have something to do with ogg cartonc?
- t 3 ;[
Do you recall that?
A (Witness Bohn) Yes, that's true. ,
- a. . ,
. l
- l t
l 1
d i
1 1
7037 I ar6 l
t O Do you recall any other aspects of the design
_ 2 basis fire from the testimony? j t
3 A (Witness Giardina) I think there wac some kind 4 of a liquid plus that the conditions of the fire were not i i
5 the conditions that you would see in the control room. !
6 Q That was still used as a design basis for the 7 plant; is that correcti 0 A That was considered the worst fire, correct. ! ;
9 O Did that fire consume every combuctible within 1
10 the control room? ,
3g_
A It did not. That fire bnly consumed the one 12 division in the PGCC. The test was performed to show that
" t 13 a fire w uld not propagate from one division to the other. ;
~
g Q Something like -- ctrike that.
15 S then the definition of design basic fire i 16 in 9.5-1 as defined by Mr. Behn, itwasn'tatotalassumptionj of all combustibles as a design basis fire; is that correct? i 37 gg A I would guess so, yes.
39 Q so that is kind of an exception to the definition 20 as set forth in the Branch Technical Position; would you l
agree with that?
21 g A It was an exception, but it was justified by a test ,
' O All right. Was justified. So it is not unusual,
- ao.
g then, to present exceptions to this definition for design 25 l
~
l l
t
il 7038 i ar7 ] f !
I i l 1
A Applicant is allowed to present exceptions, but I i
2 he must have cubstantial justifications.
I' i
3 O In that connection, are you responsible for
[
4 l reviewing the Safety Analysis Report for the Black Fox i I i 1 i 5 Station? 4 I i
G o A I am one of the people responsible, yes. ,
I 7 -Q You are one of the people.
- I l .
i 8 j Do you review just certain portions, or do you i t ;
O1 have the cdministrative reopensibility to explain it? I l
!O . A The revieu of the fire hazards analysis involves l l
i 1
- i
. j Jim Behn, the firo protection engineer from Gage & Babcock. l 11 It involves me. The electrical people get into it in connec 1 I 1
15 ,
tion with electrical circuits and what-not, and there ic ,
i4 -
some Q/A involved, which the Q/A people get into, and I thinh
!5 ii there are a few other people like the project manager might U .
M1 get involved in the review of the fire protection analysis; Ia auxilicry cystems coordinctes the revieu.
17 q ,
I m 3 0 That is a different organization than yours? '
t 19 l A No, I am the one who would coordinate the review. ,
'i !
20 I Q I see. l l !
2; j Now is it true that the report was filed in ;
O {
0; I i
November of 1977? l i '
2? { A That is correct.
i :
3; .j 0 Since then have you had occasion to review the et
. document? f I
.If h !
,a egga .-a ma.g s- Emn.-MLe%*** *4-m-*-t*8we-1'==+ ^ " ' ' * + = + + - -Wi cr8 7039 A When the report came in November, we gave it a 9
. 2 - quick look review. At that time we checked it to see that 1
there were no changes from what was given in the PSAR that 3
l would affect our original evaluation. At that time we found 4
n hanges. i 5
The interpretation I got from looking at the 6
review, because I gave it a quick look review, was that they 7
g did use an exposure fire in all areas, which was part of our i
requirements. The review of the fire hazard analycic wac ;
i 9
""" #9 " ' "" * * "" " "9 "
to it. We have, since Mr. Engmann's submittal of the testinony, i 11 ,
found out that the exposure fire was not considered in certain areas, and a more detailed review of those areas f
was conducted, and that was conducted by Mr. Gang.
ond 20 15 16 17 ;
18 19 20 21 22
( 23 24 25
}-
I
7040 )
l
' I think you said you assumed an exposure fire taps IE 21 Q
.- p d id 1 was used as a. design basis fire?.
A No, it was an interpretction I got frcm reading 4
the fire hazards analysis, that an exposure fire.had been 5
used in the analysis.
6 0 Isn't it your normal practice to assume that to 7 determine whether or not the branch technical position 8
design basis fire is used as a basic point for analysis? l 1
l 9 A When we gave it the quick look review, we reviewed i
10 it for meeting the requirements of the branch technicci t
.I position or Appendix A. I 12' No checked to see that they addressed certain I
I3 areas. l 14 As I said, in looking at the review, my reading 15 of it, my interpretation of it was that they had used an 16 exposure fire.
17 Now, you must remember that this was back in I6 November of 1977. Since that time we found out that 10 my interpretation was incorrect.
20 0 Looking at this definition that is in 9.1 - I'm 21 sorry, S.5-1, isn't it unimportant as to whether or not
.22 e particular fire is called an exposure fire or an electrical
(.'" !
23 fire?^
24 Perhaps I ought to address that to Mr. Behn?
25- A I think you better.
1
l l
7041 david 2 I A (Witness Behn) I don't think it isn't important l 2
because I believe you can do more damage with an 3
exposure' fire than an electrical fire.
- But you don't know how much more damage? !
Q A No, there is'no way to --
6 Q If you are going to presume as this definition 7 does, that every combustible on its own"le going to burn, 8 what difference does the intensity of the fire make?
i 8 A All of the tables as well as equipment in the 10 area is lost.
11 0 Then what difference does it r.ako whether wo 12 call it en exposure fire, an electrical fire or a A water melt fire?
~
13 water fire?
14- A Could I have the question read back, please?
15 MR. GALLO: I will repeat it.
16 BY MR. GALLO:
17 Q I guess first -- well .my question is: if 18 you are going to assume that everything, every combustible 19 within a certain fire area is burned and consumed by fire, 20 what difference does it make if you call it an electrical 21 fire or an enposure fire or some other type of fire?
22 A Just that the' initiating device -- I don't believ5
23 . Black Fox .has considered an exposure fire if there
- j. 24L was no transient load on the floor.
25 .g. Then apparently the disagreement isn't over
7042 l
l 1 l david 3 terminology; it is whether or not it is proper to 2
consider transient materials in a particular fire cone. l 3
Would you agree with that?
4 A .Yes, that's true.
5 Q So that perhaps we can abandone this semantic 6 1 disagreement over whether it is an exposure fire or an 7
electrical fire and focus on whether or not transient 8
materials, transient co=bustible materials are appropriately ;
9 l located in the room or in the fire area.
10 A We have no gucrantee whether about the location l
11 !
of transient combustibles in the fire area.
12 i O Isn't it true in the fire safety analysis !
l 13 report that a fire area by fire area analysic is mcds to deter
- 1 14 mine what combustibles are to be expected to be 19cated in (
15 [
that particular fire aroa?
10 A Inctalled cc:tbustibics, yes; trancient combustibleu, l 17 l (
no. -
0 Hasn't the applicant done %at in this' case?
10 A He has considered the installed c n % % 1E 20 J in his analysis, I believe. 1 21 0 Did he not in some inctances identify 22 .
transient combustibles also in connection with particular 23 fire areac?
24 A He may have, but again an crposure fire has a 25 ~
strong concentrated source of fuel, and I believe in his
_. l
- w_ - _ _ _ ___
7043 1
devid4 analysis he spread the exposure fire out throughout the 2
area of the fire ~ zone.
3 O I thought you agreed with me that we don't 4
have to worry about labeling the fire; what we have 5 l to worry about is whether all of the combustibles in the 6 l area were consumed. )
7 l A Right. I believe that Black Fox, when they 8
did not consider an exposure fire, it was not credible 9 i for them to lose the cabling in the area.
10 0 cabling where?
11 A Wherever it is installed.
12 O Have you read the Black Fox fire safety 13 analysis report?
14 A Yes, I have.
15 0 You have? Have you heard the tectimony today 16 with respect to the cable spreading room concerning the 17 3 hour3.472222e-5 days <br />8.333333e-4 hours <br />4.960317e-6 weeks <br />1.1415e-6 months <br /> firewall that separates redundant safety divisions?
18 A Yes.
19 Q Do you still believe that it is important to 20 talk in terms of an exposure fire rather than trying to 21 determine whether or not combustibles, transient combustibles 22 should appropriately be included in each fire area?
23 A Well, they have redundant cable spreading rooms, 24 so it is possible to lose the cable spreading room and 25 still shut down the plant safely with the redundant
7044 david 5 1 system.
2 .Elsewhere out in the plant, I believe there are j 3 places where there are redundant trainc.
r 4- 0 But you did agree with rae that the applicant t
5 should review the various fire creas in their determination j 6 of the combustibles that should be reasonably in the 7 fire area; is that correct?
8 A Yes.
9 0 Once he does that, includes that judgment in i
10 the fire analysis report and submits it to the NRC, I 11 ascun.: a review is rade by the NRC; correct?
12 A That is correct.
e 13 O And if you disagree with the judgment on the 14 number of combustibles or the amount or type of corobustibles j i
- g in a particular fire area, I would expect tha.t you would j i
16 cend back a contnent indicating that? f 17 A That is correct. {
18 0 You haven't done that yet for the Black Fox 19 ctation, have you?
20 A Review the fire hazard analysis?
0 No, I asked whether or not you have sent back 21-22 a particular cercuent to the utility indicating that in certain fire areas the combustibles were not properly 23 ;
}
identified in your judgmsnt.
24 25-A (Witness Giardina) That is true. We did not i
4
__ : c. . _ ,
7045
~
.1 david 6- send back a - comment, ' mainly because we reali::ed that 2
- the construction.of the' plant is a continuing process, and 5_
the amount of combustibles in a particular area at 7..
i' 4 any particular time during a construction phase will 5 l changer and therefore, the identification of the '
6
, combustibles in a particular area, in a particular 7
transient will change during the construction of the 8
plant.
9 i' So, for enample, they might hcVe only pectulated l
10 at this point in time a very small transient load or e, 11 small cable load in a particular aron; but by the 12 time the final plant is completed it might have e very ;
~
13 large load in that area. I I
14 Q Are you suggesting, Mr. Giardina, that th'is l 1 i particular icouc is one that could be properly postponea
)
f 1G to the post-construction permit ettge?
17 A If you are talking about the exposure fire --
18 Q I am talking about the quoction of idenifying 10 combustibles and determining what action should be taken 20 with respect to them.
E '
A No. . We would like the identification of
- cortbustibles in the area co we have a comparison of what k.
23 is going.in and-what'is coming out.
i 9M
.O I think that you just told me that since that l
3 would change during the construction period -
.l.
-.m.. - o . - , - . . - , . , - - ,m .
^ ~ - ~ ~ ~
._. ,___. . 1. _ . . . . _ . _ . _ ~ __
704.6 s
david 7 1 A Agreed --
2 0 -- the information would have no value right 3 now.
4 A It does have a value in the evaluation.
5 0 And it has been presented in the form of our 6 analysis report, correct?
7 A That is correct for the fixed fire combustibles.
8 0 Is your testimony still the same on this point?
9 Let me turn to it. Pago 17, paragraph B, you indicato, 10 "The presently designed facility,' meaning the Black 11 Fox statim - "hac sufficient. design flexibility in 12 the area of detection and extinguishing systems to allow 13 implementation of any design changes that may be necessary 14 to ascure compliance of Black Fox station with Appendix 15 A to branch technical pocition 9.5-1."
16 And you indicate Reg Guide 1.120.
17 Is that still your view?
18 A That'is still our view.
19 0 So that during this period, if you see something, 20 what I would call during the post-construction permit period -- -
21 strike that term.
22 During the construction period; you understand 23 that?
A Yes.
24
'- 25 0 . During the construction. period, if. che NRC and +
V
l 7047 l
david 8 1 you in particular identify some aspect of the fire l
l l 2 protection program that you believe to be inadequate, l
3 you will take action with the applicant in that review ;
I 4 period; is that correct?
5 A We would probably, yes. It would depend on i
G when we reviewed it. l I
7 0 Wouldn't you handle the matter more 8 cppropriately in connection with the FSAR review?
' The detciled fire hasards analysis will be 9 A 10 mado at the FSAR stage, and at that time we would take a j visit to the site when it was'almost completed in 11 f
la conctruction to review the site to determine whether
{
IS additional fire protection would be necessary.
14 O And if you determined that in a cartain arca ;
l 15 ,
a certain fire protection system might be needed, what !
16 would be -- how would you implement that judgment? l
- 7 A We vould require the applicant to put' something l ~
I in there.
gg l gg l Q This would be prior to issuing the operating 20 license? l l
1 l g; A That is correct. l l
}
and 21 22 l 23 i
i ,
24 i i i 1 1
25 l 1 !
i o
I i
a k.
l 7048 l
l- tape 22 1 Q If in your walk through of tin plant you s ^* avid 1 2 determined that more combustibles than you had 3 contemplated was in a particular fire area and you felt 4 that additional fire protection was needed, what action .
l 5 would you take on that observation? l 6 r A We would require the applicant to put in l 7 additional fire protection. I 1
This would all be during what I call the FSAR l 8 0 g review; is that correct?
10 A That is correct.
11 Q Turning back to you, Mr. Behn; on this 12 definition of design basis fires -- I will start with 13 MR. Giardina.
14 ,
Are you familiar with the term called
- design 15 basis accident"?
A I am familiar with the tern, yes.
16 37 0 Ic it your understanding that there are certain 18 accidents postulated for reactor design that have to be gg designed against?
20 A Yes, sir.
21 O Is one of those accidente loss of collant 22 accident?
" A I understand it is, yes.
23 24 0 Is the cause of the accidnt ever a consideration 25 in de> ermining whether or not the accident has to be
7049 david 2 1 designed against?
f~ 2 A In some cases it is, yes.
3 0 Let's take the double-ended pipe break for the
\' 4 loss of coolant accident; does the NRC staff look to 5 see if the accident can be caused in the facility, or do 6 they just assume that it will be and go from there?
y MS. WOODHEAD: I object. It is outside the 8 scope of the testimony.
9 CHAIRMAN WOLFE I'm corry. I can't hear you.
4 10 MS. WOODHEAD: This line of questioning g; concerns design basic accidents; that is not within the 12 scope of the testimony.
' MR. GALLO: Mr. Chairman, I will try to connect t 13 14 it up. If I can get some basic ground rules with the 15 witness on what the design basic accident means --
4 16 MS. WOODHEAD: Mr. Chairman, fireprotection is 17 net a decign basis accident; it is irrelevant. ,
gg (Board conferring.)
19 CHAIRMAN WOLFE LEt me cee where Mr. Gallo is 4
20 g ing. Let's see if he can make his goal.
Objection. overruled.
21 22 BY MR. GALLO:
- 23-Q Do you remember the question?
24 h (Witness Giardina) I do not, s 0 I asked you whether or not it wasn't accurate 25 a.
3
_ , m , . _ _ . . . - _ . _ . - _ . .
f 7050 david 3 1 that the type of loss of coolant accident called a
, 2 ' double-ended pipe break was just assu aed to occur, rather l
~
3 than the staff looking to see under what circumstances
~
4 or how it might occur?
5 A I don't review the loss of coolant accident.
6 O Do you know the answer to my question?
7 A It is my opinion that on that condition where a pipe break occurs, we do not consider what causec it, 8
i Isn't that the analogous siuuation with 4 g O 10 rctpect to the design basis fire? You acsume that the ,
1
- fire is going to wipe out all of the combustibles in the area; therefore, we don't need to know how the fire !
12 C 13 started.
A No, I do not think that is analogous.
14 O Mr. Behn, what about you? j l 15 l
A (Witness Behn) No, I don't.
16 0 one last shot, Mr. Behn. j 37 l
gg We assume that all of the combustibles in a
- g particular fire area ignite and are consumed and are burned; won't that in effect cotopletely destroy all of the cabling 20 i
in that area? l 21 \
g A- That's true. l 23 0 And won't that occur even if we assume that the co:tbustible is the insulation from the cabling? l 2/,
i A es, but in reality it would be difficult for ,
25 i
l
_ . . . . , . . . . - . .- - - . ~ - , 1 1
7051 david 4 1 an electrically initiated fire to cause the most severe 1
2 damage in this fire area as an exposure fire can cause l 3 more damage.
4 O Do you believe that reality is part of 1
I 5 this definition of the design basis fire?
6 A It is the criteria that we used.
7 Q Do you believe it is realistic? :
8 A Yes, I do. l 9 O Do you think it is realistic to not take 10 credit for the automatic suppression system that might be i 1
- g in a particular area?
12 A The suppression cystems have been known to fail.
e n Q Do you think it is realistic to not take j y, credit. fire brigade, and fire extinguishing action 15 that might be takon?
16 A We provide a defense in depth for this analysis 97 and it has appropriate backup with the fire brigade, fire protection and early detection, so we can lose one 18 99 -
and still have appropriate backups.
Q Let; me ask: do you think then that it is 20 realistic to lose all of these systems for purposes 21 y of this fire definition?
(
g A No, I don't.
g Q You do not?
- " 0: May I have a moment, e. Cha b an?
s5
..7 7052 david 5 1 CHAIRMAN WOLFE: Yes.
r 2 (Pause.)
3 BY MR. GALLO:
( 4 Q Mr. Behn,withrespecttothecablespreadingroom,f 5 I believe it is your judgment int a fire analysis should 6 include transient combustible material; is that correct?
7 A (Witness Behn) That is correct.
8 0 How much transient combustible material?
9 A I would say that is a five can of fla:snable 10 liquid.
t <, O Would pu consider that a design basis for a l
ig fire in the cable spreading room? j r 13 h Yes.
t w
g '
O For all cable spreading rooms. ;
i 15 A Yes, I would
~
16 0 Would you repeat again what - . five gallon }
37 can of what?
jg A Flammable liquid. ,
CHAIRMAN WOLFE: What did you say 1t was? l 19 ,
20 A can of what?
WITNESSIEHN: Flammable liquid.
21 22 BY MR. GALLO:
0 So it is your feeling because you observed 23 I
a y this one instance which had this five gallon can of flan:mable g :; liquid, that that is a sufficient basis to now determine
,i l1
~
7053 1
david 6 that that is representative of what you might find in 2
a cable spreading room generally; is that correct?
A (Witness Behn) There is a variety of materials
- As I said before, you can find in a cable spreading room.
5 I found a gas welding outfit, class A material, wood motsrial, 1 6 boxes. And I considered a variety of materials.
l 7 Q I am trying to find out which one you would 8 select as a design basis for the cable spreading l 8 room; I think you told me it was a five gallon can.
10 A I believe that is the figure I would use. l l
II O And that is a five gallon can? I l
12 A Yes. One of them. l
' 13 And in all of your observations, you only found O
14 the five gallon can once; is that correct?
15 A That is correct.
16 0 Mr. Giardina, are you familiar with the so-called 17 Hanauer report NUREG 00507 18 A (Witness Giardina) I have read it.
19 0 Bave you made any comparisons between the 20 findings of that report concerning the Browns Ferry cable 21 spreading room and the one that would be designed and 22 constructed at Black Fox?
23 A I have personally not made any co:nparison between 24 %e two .
25 0 Let me ask you this, are you aware of whether
1 7054 )
I, 1
david 7 or not Browns Ferry had a firewall separating redundant f 2 i j
systems? l 3 j A To my understanding,they did not. !
4 l Q Is it your understanding that Black Fox docs? , j 5 l A Yes.
6 But only in the cable spreading room. l 7
Q That is what I am talking about.
8 !
Mr. Giardina, have you identified other i t !
9 s areas within the -- strike that. l f 10 j I take it that as a reviewer, do you find that l 11 the fire design protection system for the cable spreading 12 l room would be sufficient based on what you have heard in ,
i 13 the testimony and your review of the fire ha=ard analycic 14 report?
15 i A For Black Fox? t ;
16 i G Yes. l l
17 A I have not reviewed the cabic spreading roon. ; i i !
- 4 18 fire suppression systems in detail. j i
19 Mr. Behn has. l 20 It is my understanding in talking to him that !
21 it may or may not be sufficient for the design bacis fire. i 4
. O Mr. Behn, can you tell uc what your concern ic? l
' 23 I l A (Witness Behn) My detailed analysic of the ! <
24 fire hazard analysis has revealed that it wac -- was !
I I
sufficient. j
. 1
~
i
7055 ,
1 1
david 8 1 0 so, you take it -- does that cause you, l 2 Mr. Giardina, to change your statement? i l
3 A (Witness Giardina) Well, I originally said 4 may or may not.
5 O But you will stand by Mr. Bbn's statement?
6 A Yes r I will.
cnd 22 7 l 8
9 10 l 11 12 13 14 15 16 17 18 19 20 21 22 t
g 2-4 23
U. . 7056 !
arl 623 -lg! .
h
, 1 ;
O Mr. Giardina, have you ascertained that any or. hor {
i area in the Black. Fox Station from a fire protection standpoin:
r 2l[ :
l! )
l' ' is unsatisfactory?
As I said before, I did not conduct a' detailed A l 4l s i
E 1 review. Mr. Behn has. ;
I G
O Fine. I will pass the quection to him.
i A (Witness Behn) I havo determined _other areas !
7 i C l that may be problem areas.
i 5'[ O Can you indicate one? ,
t to I A I don't have my analysis with me. l l
0 Mr. Giardina, would these be problem areas -
.1 h ,
- g. j are you familiar with the problem areas that Mr. Behn had
,3 M. talked about?
9 (Witneso Giardina) I am familiar with the problem u j; A D f
.rj of the problem areas. I am not'familicr with the areas i ,
themselves.
1g Q If we were to apply the design basis fire ,
- 3. [
tg definition found in Branch Technical Position 9.5-1 i 1
- g uniformly throughout the reactor with the exception, of
)I courso, of the PGCC, would that satisfy the concerns that 3 -
gf you have indicated, Mr. Giardina?
c Yes, I think it would.
A 3[
0 Mr. Behn?
( n $
Yes, it would. ;
.>. J A (Witness Behn) w ;t y7 Q Mr. Giandina, can you toll ne whether Mr. Behn is -
96 9 d f
l ;
l
[1 t1 i.t .
cr2 7057 1 going to be the reviewer for this document called the 2 Firs. Hazard Analysis Report?
l 3 A (Witness Giardina) He is the present reviewer.
J 4 I cannot forecast what it will be in two or three years from i
5 now. i 6 Q Is his opinion going to be controlling with 7 respect to the NRC position?
6 A At this point in time, yes.
9 0 Mr. Behn, if I give you a copy of the fire ,
10 safety analysis report, do you think you can identify for me 11 the concerns that you have?
12 A (Witness Behn) I will try.
13 (Handing document to witness.)
14 (Pause.)
15 On page 2.5-4. l l
15 0 2.5-4.
17 A Yes. Section 2.5.6, electrical. My concern here I a
ja would be all four divisions being in one area.
19 Q How do you get tnat interpretation? f k
20 A The second to the last sentence, cables divisions l 21 1 and 2'will be routed in cable tray conduit and cables 22 for. divisions 3 and 4 will be routed in conduit. I am 23 under the understanding that one division is cable trays
- 4 1 and 3, or trays 1 and 3, and divisions 2 and 4.
25 Q I believe the testimony was that the redundant a
1 4
I ar3 7058 {
l l
. divisions were 1 and 4 as compared to 2 and 3. Do you I 1
l recall that? j 2
, A No, I don't. t l
Q Pardon me? ,
4 i
gj !
A No, I don't.
f' Q Mr. Giardina, do you recall that? !
A (Witness Giardina) Yes, I do.
l l
Q Does that cause you to change your judgment on g
this point, Mr. Behn? f g
I l A (Witness Dchn) No, it doesn't.
10 t
! Q Do you have concern that all of the safety divicient it ;
! may be, based on what is stated here, that all of the safety ;
2
{ ,
j divisions may be routed in one conduit; is that right? ;
13 i
MS. WooDHEAD: I would like to object at this I 14 i time. Mr. Behn is being asked to give a review, a Staff ,
,i c_ ;
unalysic hero on the witness stand uithout his notes, )
16 ;
{
l without warning, and Uithout the complete documents that he i U l !
1 uses to review a fire hazards analysis. ;
18 ! i I think it is entirely inappropriate to conduct
- 10.
- this sort of Staff review extemporaneoucly at this time.
20-
-MR. GALLO: Mr. Chairman, the witness testified 21 -
l that he has some concern with respect based on his review 22 .
- of the document called the Fire Hazards Analysis Report, !
- 7.3 .
I and I handed him the document and ackod him if he could point 24 I
.I ther out to ns. He said he would try.
li I :
I !
l I d 1 Ir :
1 7059 I ar4 I
I He has not complained of any incumberance. ;
He 1
2 has pointed me to one right now.
I don't see any unfairness.
1 3 I think it is very helpful that we are clarifying the record j 4 as to what the Staff concerns are.
5 I have no objection to some MS. WOODh'EADl:
C explanation by Mr. Behn of some of the types of problems l
7 that be has encountered to give the Applicant an idea of 4 1
8 what the problems are, but to hold him to a commitment on i the record of his written analysis which is back in the !
i 10 office, which is subject to Staff review and consultation, is j 11 highly inappropriate and objectionable.
12 CHAIRMAN WOIEE: I think not. The objection is
(
)
g 13 overruled. However, the witnese, if he feels that he needs l l l
14 his documentation,his own papers, he may so state on the 15 record and not answer the question because he does not have l
76 his papers before him. To the extent he can, he vill answer l i ,
17 the quection. '
l l
12 BY MR. GALLO: l l
1e Q Mr. Behn, with respect to the sentence you have 23 identified under Section 2.5.6, I just feel that I don't 21 understand your point. I em just asking you to clarify 1 1
- I E2 your concern. Would you state it again, please? !
\
- l
. 23 A (Witness Behn) Yes, the concern here, if you have I I
n4 l rodundant divisions in one fire area that the exposure fire ;
1 2G can jeopardize both the redundant divisions.
l l j
l 7060 )
ar5 j l I a MR. GALLO: Can we have the answer read back? l g 2 (The reporter read the record as requested.) !
3llif BY MR. GALLO:
~
4 )- 0 Mr. Behn, can you toll me another a:ea of your ,
I :
5 concern? -
G- L A (Witness Behn) On page 2.6-3, paragraph 7 P-C-6-B, I would have er.ception to the -- I would question i
13 '
the separation under the subheading, a separation of cable j i
i 0 ; trays in accordance with IEEE 384 and Reg. Guide 1.75 as IC being insufficient for redundant trains. ;
11 ,
O Can you tell whnt more night bs necessary?
1 12I A In regards to Vnct?
O
'l
,f. 11 j O Uhtt would be sufficient?
( j '
14 l A That an analysis be done concerning an e::posure Wl fire for this area.
It! O An c:'posure fire or o design basis fire cet .
gh forth in 9.5-17
. i jn ,! A Yec. -
19 Q The latter? i 20 A Yes, gi O Are there any other areas that you can identify f 2 Q(,for me? !
. p
( ns j! ?
A Also on page 2.G-5, under the heading 2.6-6, ,
34.] clectrical, on the first sentence. !
?
y,g O Give me that page number again.
4
- j. I I '
t ,
,. +
e ,. .m..
r---- r
7061 ar6 1 A 2.6-5.
l 2 o -97 l 3 A -5. f 1
4 0 Go ahead.
5 A Under the paragraph entitled " Electrical," the 6 first sentence.
7 Q What is the concern here? (
8 A Again redundant trains within one fire area.
9 0 You don't feel this meets the definition for c to decign basis fire? f l
Not when it jeopardizes redundant trains. l 11 A l
12 0 Can you give me another one? l 13 A on page 2.8-3, again on the paragraph electrical. l l 14 0 The first sentence?
I l 15 A Yes, it is. )
l 16 0 What do you conclude from that sentence?
17 A That rodundant trains are one fire area. l 18 Q Again it doesn't meet the definition of design 19 basis fires is that correct, as set forth in the Branch 20 Technical Position?
21 A That's correct.
R2 0 nr. Behn, if you are able -- I preface that, if 4
'3 you are able -- with respect to these areas, these four g4 areas you have identified, would a fire wall separating i the redundant systems satisfy your concern?
25 I !
s
~
i j 7062 or7 i l
l A Yes, it would. i 1
2 O Mr. Bahn, let me be a little more specific, based { ,
t' 1:
3 1 on the last question. I used the term fire wall. Would a (
l l l 4 three-hour fire barrier be sufficient? ,
I 5; A Yes. ;
1 G O Are there any other areas that you are able to i t
l 7 determine at this time that might not be adequate from your f 6 point of view?
\
t g
l A In my preliminary review of the analycis I had , l 1
10 questions on numerous areas in which I thought there uns j
~
not sufficient information to determine if there were or '
I jg l were not redundant trains in the area.
.i 93
' Q So you have other questions? j t
g q A Yes, I did. f i
l At some point you are' going to transmit those
- g .! O ,
- g. (d to the Applicant; is that correct? {
' A I transmit my responses to the NRO. l i
i
- g
- A (Witness Giardina) At some point th y would g probably be submitted to the Applicant, yes. I l
33 O Mr. Bohn, I would like to get clarification on one ;
t
.j p,; !l Point.
11 -
~~
- You indicated that -- and correct me if I am i I l y J wrong -- that you did not ha'ic to consider or hypothesice !,
t transient combustible materialc in an inaccccsible arca; is t
[ 1 i that correct?
25 i ,
l !
g , , , - - -
7063 ar8 1 A (Witness Behn) Correct.
2 O What do you mean by inaccessible?
A Where the radiation level is such that personnel 3
4 cannot enter the area under plant operation, j 5 0 What is the difference between that situation 6
and a situation where a -- in the cable spreading room where 7 you have this designated vinyl area and under security a conditions?
g A The likelihood of having a transient material 10 is significantly greater there than in the radiation area.
1 O Is the containment area an area that you have in l 11 12 mind as a nonaccessible area?
A Yes, it is.
33 g O Aren't certain portions of the containment area g accessible during operation?
g A I don't know.
g O Do you know, !!r. Giardina?
A (Witness Giardina) No, I do not. It is my gg gg understanding, though, that containment is completely isolated during operation. During operation --
20 O I am sorry?
21 A It is my understanding that containment is i mpletely isolated and no one is allowed in during operation.
23 O You don't know whether there might be certain pornions of the containment that access might be permitted 1
~ , . -
I !
7064 }
ar9 t 11 during operation? ;
A That is correct.
7.-
'a .
I f
, Q' Mr. Behn, with respect to these other questions ;
7 that you have, if you will, is it your. judgment that those j l
matters could be handled on what I am calling a post-5 construction permit basis? !
G l A (Witness Behn) Yes. !
O I didn't hear you.
8 . ,,
A Yes. i i i
! Q Do you have any judgment with respect to the 10 ,
four areas that you have identified as to whether'or not f li j i
they could be handled on a post-contruction permit basis?. j
- u. ,
A Again I would have to make a detailed analysic i
- 13 i !
b of the area. Just by going through it briefly, I can' t' 14 f,
{ answer that. !
15 ;
l 0 Do you have anything, Mr. Giardina? .
16 i '
I A (Witneso Giardina) My opinion is that-the plant ;
i 17 !
! has sufficient flexibility cuch that any design changes ;
IC }
that are made. in the essence of putting in fire barriers i
je or extra sprinkler systems, this can be done during the post-20 conetruction period and during the OL review stage.
21 0 So if Mr. Bahn, after he' completas his _ analysis, '
22 ;
- confirme in his preliminary judgment that a'three-hour fire i k., 23 : !
' barrier is needed in ene or more of the four areas he i 24 identified,youfeelthatthe-docignissufficientlyficxible{
2S :
1 i
s
- 1. l
.- - - - , , - . v- w-ne -
--ww- - ,-g - t ye-, , - . =
t.r10 7065 g
for the Black Fox Station that that could be included in the p st-CP period; is that correct?
2
^ '
3 1
MR. GALLO: Mr. Chairman, I have no more questions 4
l at thiS time.
l CHAIRMAN WOLFE: We will have a 10-minute recess.
7 g
(Recess.)
end 23 9
10 l
li 12 ,
l 15
- 4-15 16 l
17 l 10 19 20 21 l 22
, 25 24 25 j' 1 l l i
l $
l.
7066
~I You had finished, Mr. Gallo?
tape 24 CHAIRMAN WOLFE:
I
lavid 1 MR. GALLO: Yes, I have, Mr. Chairman.
CHAIRMAN WOLFE: Mr. Parris?
?
MR. FARRIS: Thank you, sir.
5 BY MR. FARRIS:
0 Mr. Behn, did hhe applicant in its fire ha::ard 0
7 analysis consider any transient combustibles at all in 8 the cable spreading room?
9 'A (Witness Behn) No. j 10 Do you find that realistic?
0 II A No, I don't.
12 O Mr. Bohn, you or Mr. Giardina, one or both 13 of you, indicated that you would be satisfied if the 14 design basis ' fire was applied throughout the Black For c'tation;I 15 is that correct? I 10 A That ic correct.
17 0 Wouldn't it be more accurate to any that you 1E would be satisfied depending upon the outcome of the 19 application of the design basis firo?
20 A (Witness Giardina) Would you repeat that, please?
21 O Is not the mere paper exercise of the planning, 22 the design basis fire, you would have to be satisfied that I
23 the results of that application and the analysis of that 24 application, wouldn't you?
l 25 A Yes, I thin 1: that would be correct. :
I l
. _ , =
7067 david 2 I O Mr. Behn, you also indicated, did you not, 2 that you have a more detailed analysis you want to conduct 3 into the fire hazards analysic?
4 A (Rhness Behn) I believe I was referring to -- !
5 I cannot conduct a detailed analysis here.
6 0 Would you repeat that, please? )
l 7 A I cannot conduct a detailed analysis here. l 1
8 Q Based on the information that you have? )
l 9 A Yes.
10 0 Is it possible, Mr. Dohn, that after a more 11 detailed analysis, and after you have more information 12 that you would be able to identify changes that would not 13 be readily adapted into the Black Fox station, and 14 therefore would be inappropriate for a post-cT consideration?
15 A I believe that all of my concerns can be 10 corrected prior to the operating lice '2e.
17 O At this point, the concerns you have identified 18 at this point?
19 A Yes.
20 0 Is it possible after you receive more information 11 that you will be abic to identify changes that should 22 be addressed before the construction permit is granted?
23 A It is possible.
24 O Mr. Behn, you have been here all day today 25 and you heard Mr. Engmann and Dr. Cox testify, did you not?
I -
7068 1
devid3 .A Yec.
f 2 O You heard the table they described that they are 3
- going to use for the Black and Voach scope of supply?
. '4 A Yes, I did.
~5 Q What is your personal opinion of the cross link 6
polyethylene as an insulation cable for use in a nuclear 7 !
power plant? j 0
A I am not an e:: pert on cable insulation. l l
1 C
O nave you reviewed any tests of crocs link
- 10 polyethylonc, fire protection tests? j 11 A No, I haven't. !
12 0 ft. Giardina, what is your opinion of cross 13
-linked polyethylono?
14
! A (Witness Giardine) I cra not an e>: pert in I
10 I clectrical cable I
16 O Mr. Dohn and Mr. Gicrdina, did you not in fact ;
I 17 file testimony in this proceeding rogarding intervenor'c le concention seven? f A (Nitness Giardina) Yes, we did.
20 0 Did you not in your testimony indicate that you !
i i 21 + '
- j. thought insulated' cable that met the require: tents of IEEE 19~
e 383 was catisfactory no far as the staff is concerned?
F j.
23 i
. A That is correct. 1 I i 24
-0 Ac far as the cabic itself is concerned? i
- G As far as the cable itself, yes, sir. l
-l A ,
' I i
- . - . . , . ~
7069 devid4 Q You did not indicate that cabling itself was 2
sufficient-to meet your fire protection requirements, though, did you?' !
l
'4 A Could you rephrase that?
5 Well, I will refer you to page 9 of your Q
6 testimony, three lines from the top of the page.
7 A Yes, I see that.
8 It reads, Cable separation guidelines and 0
8 fire retardant cables are not intended to be sufficient 10 alone to protect against exposure fires." '
II A That is correct.
i 12 Who on the staff - did you consult with anyone O
^
13 on the staff regarding appropriate fire retardant cables?.
14 A I am not sure I understand what you mean.
15 Q How did you determine what cables.have passed 16 IEEE 383?
17 A We relied on the applicant's commitment that 18 the cables will pass IEEE 383.
19 Q Does the staff verify on its own that the 20 . cables so identified and so committed to by the applicant I 21 will in' fact meet IEEE 383?
22' A I would assume it would be part of the Q/A.
23 I really would not know.
24 0- Mr. Behn, who is Mr. Bert Cohn?
25 A -(Witness Behn) He is the senior vice president
~
1 l
, - , , , . . - . ~ - .
_7
7070 1
david 5 of Gage-Babcock Associates ;
2 i o I, he a fireprotection expert? li 3
1 A Yes, he is.
A I O Is lue your superviser? i i
5 ;
A Yes, he is.
6 Q Mr. Behn, have you ever read Mr. cohn's i 7
memorandum dated September 30, 1977 to Phil Matthews, l' 8 (
Bub Ferguncon, and Gene Imbro, subject comments on l I nuclear power plant fire protection? '
j i
10 A YEs, I have.
- i 11 Q Did you acsist in the preparation of that l l 12 {
j memorandum? ,
'_ l' 13 A No, I did not.
j 14 Q Did you rc cive a copy of that memorandum? +
t ll 15 A No, I did not. l i
16 i 0 When did you read thic particular memorandum?
17 A Approrimately two months ago. ,
18 0 In preparation for these hearings?
19 A That's correct.
20 Q Is that the first time you have seen this 21 document?
22
- A That's correct.
23 0 Do you hcVe a copy of thic document with you ,
24 at the stand?
A No, I don't.
1 -
i
i 7071 1 david 6 1 Q Do you know if your counsel has c copy? f
- 2 MS. WOODEEAD: I will provide one. ;
3 (Handing document to witness.) l i
C 4 BY MR. FARRIS: I.
i S Q Have you been provided with a copy by your i t
l 6 counsel now, MR. Behn?
l 7 A (Witness Behn) YEs, I have one.
f f 8 Q Would you look through that copy and see if it cppears
?
l g to be an accurate and complete copy of the memorandum? t 10 A YEs, it is. ;
11 Q Have you ever talked with Mr. Cohn concerning ;
I f
12 this memorandum? ;
i 13 A No, I haven't.
I 14 0 Isn't it true, lir. Behn, that in thic menaarandum !
15 Mr. Cohn expresses como reluctance about the efficacy I
16 of the firewall?
17 I refer you specifically to page 2, paragraph 18 three, the middle of that paragraph.
gg A Yes, that's correct. j 20 Q Do you know why MR. Cohn expresses that i I
21 reluctance?
21 A No, I don't. ,
k- 23 Q Isn't that reluctdaco baced upon the fact that pj if the firewall hac penetrations for doors, ducts, 25 cable trays, piping conduite,et cetern, he believes that the failure rato can be high?
i I i 1
7072 1
david 7 MR. GAIlo: Objection. The witness stated 2
he dion't know what was the basis for it.
3
,- MR. FARRIS: I will uithdraw the quastien.
4 BY MR. PARRIS:
5 0 Mr. Bchn, do you see thc. sentence in the middle 6
of that paragraph that begins, "An unpierced 3 hour3.472222e-5 days <br />8.333333e-4 hours <br />4.960317e-6 weeks <br />1.1415e-6 months <br /> 7
concrete wall"?
8 A Yes, I do.
9 0 Would you read that -- I don't mean read it 10 out loud. Road it yourself.
11 end 24 12
( 13 s
14 15 16 17 18 19 20 21 22
('
23 24
a 625arl 7073 ;
1 l-' A Yes, I have read it. ,
2 ., O Now can you express an opinion about why Mr.
g ,
Cohn is concerned about the efficacy of three-hour
_ i
( ,
4g concrete walls and fire barr?.crs? ,
5 MS , WOODIID.D : The quection runs to the mental l 6 processes of Mr. Cohn.
7 CHAIPJfAN WOLFE: What was the objection again?
6 j MS. WOODEEAD: The question asks about the E [; mental processes of Mr. Cohn. Mr. Behn has not indicated i l
1 ,
w j that he has discussed this at all, so he would have no 4
11 !! knowledge.
i l '
12 MR. FARRIS: It cartainly does, but we hava tho i
e i words of Mr. Cohn here in front of us and in front of the i p 'jb '
witness, and --
g, MR. GALLO: Mr. Chn!.i? man, I don't believe the u
g, ' ' mamorandum has been authenticated.
i!
II CHAIRMAN WOLFD: I have been concerm d tbout p
h 3g ii this portion of the hearing. A lot of things have been i:
19 6
swirling around the Board, without the Board being provided ;
2' ! with the documentation, the documentation being marked i d !
i m
- t. ,
i, as an c:hibit and admitted in evidence.
.m.
t I morely note our concern. I don't know at some !
q l
(- g ! future time whether we can base any of our findings on i 1
, nomething out here, and I have waved my hand, that is toward -
Ii the ceiling, and perhaps toward the heavenc, without ;
,.e iI I s
.! j
ar2 7074 1 having something concrete on which to bottom a finding, and I
^
,r 2 I am not telling theparties how to handle their conduct 3 of proceeding with eviden:::e before this court.
4 MR. GALLO: I am concerned by the Chairman's l
. i statement that all of the exhibits that Applicant have '
5 6 put in are in fact in the possession of the Board. Thsy 7 were sent to the Board in accordance with the filing require-J 8 ments set forth in the Board's order.
I I P I have also made the assumption -- perhaps this 10 assumption is invalid -- that the Board has acceso to the {*
1 11 reg. guides and the Dranch Technical Positions that we have l 1
12 been referring to throughout the day, i
( 13 If not, I certainly will provide copies of those t
i t.
for the Board.
i I
CHAIRMAN WOLFE I am not referring to that in gg l t
je particular. I am referring to the documents we are talking {
i 37 about now. For example, interne.1 memoranda or memoranda ;
18 between the vendor and the Applicant. We haven't been 19 furnished with those documents. They are not in evidence.
20 There have been references to them, but I will let the 21 parties govern themselvea.
1; gg We do have this outstanding objection.
( 3 MR. FARRIS Mr. Chairman, I think the witness has testified that he has seen this before, and it e.ppears 24 {
l' I to be a true and accurate copy. If it would be helpful to 3
. i 3- i e
{
..-.-.-.,,..7 4
l+
ar3 f 7075' !.
.the Board, I would move.for its admission into evidence. f
( ,
,_.. ;; . ; CliAIRMAN WOLFE:- We still have an outstanding +
( .i objection.
7] -
- t 4 i Is argument completed now? ! l
'. I (Board conferring.) ;
e 1 p ,
I CHAIR!OJ1 WOLFE: The objection.is overruled. f 6
1 I
., As I say, I don't know what is'in the document.
l gj If it is there, the witness can say yes; and if it is not i 4
',ij there, the witness can'say no. :
I! . 1
.gy Answer the question, Mr. Mitness. , I n
,,! WITNESS BEEN: The three-hour wall is testod with no penetrations --
l.e H :
, p. CHAIRMAN WOLFE: Are you answering the question
, 1
, thon?
l ,
y WITIESS BEHN: Yoc.
1 :.
(
I CHAIRMAN WOLFE: All right.
_b
,]
4 ,'
UITNESS DEIET: We provide a defence in depth
! approach to this area where there are'three bach-ups to TC i i
the fire wall. We have an early warning detection system.
i
, We-have a delugo system,.and we have a fire brigade in .
40 ;
the unlikely event that there is a penetration of this e o
!o! three-hour firo barrier. !
22-f !
U -
BY MR. FARRIS:
-(.- ;3.y r
l' O In the unlikely event that there is a penetration.
24 (lt ,
U Aren't you aware, Mr. Behn, that there are in fact soms. ',
- 15 i i I: }
L t it i
l
- jf .
. . ~ . . _ . -. _ __ _ . _ _ _ . . _ . _ _ ._
'l are 7076 1' ,
penetrations through.the' fire wall in the design?
2 A (Witness Behn) Yes. They will have a three-hour f
=
f,. ;
3 fire rating..
4 MR. SHON: I am sorry, Mr. Behn. I perhaps
({
4 misunderstood Mr. Farris' questian. I t1:2ght he had asked 5
G you whether, after having read what Mr. Cohn said in his
- 7. memo, you came to the conclusion that it was -- you could not g tell us what reservations he had about the integrity of the i i
g three-hour fire wall. Is that not what you as1:ed? ;
i 10 MR. FARRIS: Yes, it was, but --
' i
,l MR. SHON: That doesn't see:n to bc what you i }
q answered. Can you not tell us what reservations he had j i
about the integrity of the three-hour fire walls? j e 13 l I
! WITNESS BE3N: All I can cay is what I said i 1,
t
! previously, that the fire well was tested without penetrations,
,a_
l
! and thic fire wall, the more penetrations you put in there, 1,. >
i i
the wenker the fire rating of the wall becomes, even though l
,i _/ j the assembly is tested for three hours. I think that was g
his thinking when he wrote this down.
g MR. SHON: The three-hour fire wall with a three-hour penetration in it is not necessarily a real three-hour. fire wall? Is that the idea?
! WITNESS BEEN: Both the fire wall and the
( g3 i
j assembly are rated for three hotra.
.4 ,
25 ! !-
t
.I'
\
i 7077 j ers j j i !
I BY MR. FARRIS: >
1 '
-?, jj 0 would you look at page 4, Mr. Behn.
)
i Have you ever had the opportunity to observe 3 ,
4 Mr. Cohn sign his name or to initir.1 any documents?
g A (Witness Behn) Yes, I have.
6 4 0' Do those appear to be Mr. Cohn's initials on page i 7 , 4.above his name?
l
, A Yec, it is.
I e
' ! MR. FARRIS: Mr. Chairman, at this time I I
g would move for admicsion of this document into evidence.
3)
I am not sure what exhibit number of Inter-renorc would be i
,3 d appropriate at this time. I will have to nahe copios for q
gj the Board, but I would do no and see that you r.ad them i
I
,.
- e, before we adjourn today.
g It CIMIPJRU WOLFE: We will have it marked firet.
.W ;
,m_
!l That would be Intervenors' Exhibit 11.
L, ,
1i (The document referred to was ,
g ! marked Intervenors' Exhibit No.
h..
11 for identification.) {,
e '
l CHAIPMAN WOLFE: Would you identify for the f 20 ;
J' 21
, reporter, please? It is the Cohn memorandum? !
g
.i y Kh. FARRIS: Yes, this is a memorandum for ,
22 ,
i.
t
,,,d phil Mathews, Bob Ferguson and Gene Imbro, subject, coments l
.a ,
!{ I
_ !; 'on nuclear power plant fire protection, dated September 30,
-^
h l
- x. ae ,
y' 1977, ' a four-page document; purports to be cigned by Mr. l
- )
Nli i,
f.!
.c
6 nas ep -% a+m-0.4 ..
ar6 7078 1 Burt N.'Cohn, C-o-h-n, Senior Vice President, Gage,
, 2 Babcock & Associates, Inc. As indicated down at the lower 3 left-hand corner of each corner.
CHAIRMAN WOLFE: Would you make the offer?
(' 4 5 MR. FARRIS: At this time Intervenors would G
move for admission into evidence of Intervenors' E:&ibit 11, 7 heretofore identified.
3 CHAIRMAN WOLFE: Any objection?
9 MR. GALLO: Objection, Mr. Chairman, to Intervenors!'
10 E:iibit No. 11, on the groundo that there is not a proper g3 sponsoring witness for this document.
Mr. Cohn is not here, he will not be subject to 12 cr as-examination. Admission of his views, if indeed they 13 ja are his views, is highly prejudicial without the opportunity g for cross-examination. !
g liR . FARRIS : Mr. Chairman --
CHAIRMAN WOLFE: May we hear from the Staff?
97 g MS. WOODHEAD: The Staff has no objection to the g admission.
MR. FARRIS: Mr. Chairman, technically this 20 would,,Mr. Cohn not being here, constitute hoarsay. As we g
, all know, hearsay is admissible in trece proceedings. We c2 have let these witnesses, these expert witnesses, rely g3 pretty freely upon hearsay testimony in reference to reports !
l
. I that they have read about, heard about, talked chout in the i 22
'I l
l j- ,
l V
~ *'N - . e ..
h 7079 '.
~
ar7 t
industry, and I think this Board is well aware of that fact.
l i We have'been in these hearings, open to technical objections, !
_. 2
( ;
3 ,
the witness has identified this as a true and accurate Ha has seen it before,
(~ 4 copy; prepared by his supervisor.
- e read it before. The parties were aware of its existence, 6
at least the Staff was. I They had a copy today when I offerec to hand out 7
> i C pies. I don't see we can be prejudiced by -- I don't l 6 .
[ l see how anyone can be prejudiced by the admission of this ,
g l l
} i gg l document. I MR. GALLO: Mr. Chairman, there is a vast !
difference between hearsay offered a witness who can be i
r I.n ;
f i probed with respect to the basis of that hearsay, and ,
,3 6
! asked quections about his knowledge with respect to that g
i
? hearsay, so the.t it can be given proper weight. ,
,u_
. l There is no such opportunity with respect to this ,
16 I Written documOnt.
17 -
I and 25 .
16 i
19 i I
20 1 i
'l-1 1 i
E2
, l I
(i 23 l \
l :
24- !
- d. i
(
' I 25 I
. :It L !! i
.-. --, - -_- . ~
1 1
70E0 1 (Board conferring.)
("aps 26 2 CHAIRfiMi WOLFE: While to some extent the david 1 3 board is more relaxod toward admission of documents and 4 testimony of witnesses and relevancy and et cetera, we 5 think that applicant's objection is well taken.
6 The writer of this document is not before the 7 board. Whatever might be contained in that document --
a because the writer thereof is not before this board and 9 not subject to cross examinetion; nececsarily we have 10 to deny the admissibility of the document.
11 I take it then thic is not to cay that you 12 may not use it for your cross examination, since you have g3 been doing so and there has been no objection
{
That'c all I can scy at thic point.
14 15 All right. Let me comment that as I stated 16 carlier, these types of mcmos and so forth have been cd-verted to and if they -- if they are never o"fered into 17 evidence and there isn't objection thereto even after 18 gg they.have been offered, this leaves the board in sort of 20 a suspended vacuum.
'21 It raises a prob 1$m, hit it can make findingc on 22 that document. There has been objection. We custeined it.
g So proceed with your cross examination, Mr. Farris.
end 26 24 wel fis 25
t I
7081 e 27/tEL !
I wel.1--
3 BY MR. FARPlS: 1 i .
4
.- E
! O Mr. Behn, in lir. Cohn's memo, does he indicate in l I { ,
S there, particularly in paragraph 8, that he thinks autonatic j
[ 4 ,
- fire detectors are just pacifiers?
5~
MR. GALLO: Was that a question? I C MR. PARRIS: Yes.
7 1 !IR. GALLO: May I hcvc the question read bach, ,
i E
-l please? ,
1 i E j MR. FARRIS: Let ma rephrnes the question. ;
70 '
BY MR. FAPIIS:
II ! 0 It. Behn, does re. Cohn have acme reserv tionc ,
i <
12 about the use of automatic fire detectors? .
13 A (Mitness Behn) I' don't know. I never talked to .
C.
14 him about the cubject. I 3
t 15 j Q Do you have any re servations chout the e:: tensive '
16 i! use of automatic fire deteccorc as an offective fire b
D !! protection device? 3 10 t A !!o, I don' t. -
t i-
.i 19 i MR. FARPlS: We have no further questions of these 20 .
witnesses, Mr. Chairman. i
'l '
21 {- CHAIRMAN WOLFE: Redirect, Ms. Woodhead? !
p !
El h) REDIRECT ETJh1INATION l 0 ;
(C .23 0 BY MS. WOODHEAD:
y, i f4 y Q Mr. Dehn, ic the' amount of transient combustibles ,
h !
to 25 of particular significe.nce in a fire hacerds analysic? -
l!
O o ,
l-
. L- i
~ ^ '~ ~' ~ "
^ . ~_; - -. . . . . . .
7002 l
wel 2 _
1 A (Winness Behn) Basically, no. A quart of a 2 flamtable liquid can have the same effect as.300 pounds of ,
- i. ;
3 a certain material. It's the configuration of the room and j r 4 the cable tray arrangement, and wherever the exposure fire is [
(
5 that affects the redundant trains. l 6 Q All right.
7 In the Applicants' fire hazards analysis has it I 1 B been assumed that fire consumes all combustibles in every !
9 fire area there? ,
i 10 A That's correct. l 11 O' In every fire area it's assumed that all 12 combustibles'are completely burned?
13 A That's correct. I must say we have not consideredj
(
14 an exposure fire for all of these areas. l I
15 Q I believe you stated the type of fire - !
l 16 A I believe the Applicant took in h'ic analysic that I,
17 an exposure fire is not critical in a certain area, so he i 16 does not poctulate an ignition source for this area.
19 0 I believe you stated previously when it is assumed 20 that all combustibles totally harned in a particular fire 21 area,'the design basis fire is not important, is that 22 correct?
. 23 A No. The design basis fire is important.
24 1 Q Why?
25 A The design basis fire is an exposure fire which i
i I
7033' !
wel 3 I can'effect total burnup of the fire area.
- 2 , O I'm sorry. I -- ,
i 3 A If you just consider an electrically-initiated fire,'
'( 4 the probability of having an entire burnup in the fire area 1
5 is remote. In an exposure fire it is poscible to completely l j 6 consume the contents of the fire area. f I l 7 O But didn't you previously say that the Applicant l l t 1 0 had considered --
O i A The Applicant had concidered a design basis fire 10 , for a fire area where there were combustible contents on the 4 j
i 11 .: floor. Not transient materials, such as pumps, some kinf'of
.)
12 ) equipment on the floor.
1 13 I'm sorry. I think my question must not be cicar.
.- Q .
14 I thought that you had previoinsly steted that in ;
15 the Applicants' fire hazards analysis that in every fire area j i.
16 I he had assumed a total consumption of all combustibles in the t l
I q : l M i area.
1B A That is correct. l ,
! l 1B Q If everything in the fire area considered is i 20 assumed to be completely burned, then what difference does !
i
21 the design basis fire mahe? .
d t i
F 22]j A' Because in some areas he did not consider an ;
e
(~ '
'- 23 ; exposure fire.
i 24[ Q But the difference in the fire -- what was the i
25 ij differenco?
I a
r s v- -
7084 wal'4 1
A You still -- just the initiating. source. The 2 combustible contents of the room is still burned.
I 3 MR. SHON: Mr. I',ehn, I think we've run around again l
(- 4 on the same rock as we did earlier, in this examination by 5' Ms. Woodhead.
i 6 If you burn all of the combustible substance in a 7 given area -- and I specifically mean the term combustible 8 substance to include all insulation on all cables in the i
entire fire zone - then what difference does it make what 9 l to the origin of this burning was, as far as its effect on the f i
i 11 cabling and safety systems is concerned? l I
12 That's what you're driving at, isn't it, Ms. !
13 Woodhead?
14 MS. WOODHEAD: Right. ; l l
15 MR. SHON: I can see no difference. l ,
I I j
IG WITNESS BEHN: There's no difference. I agreo.
17 MR. SHO:: But I trust that there are certain i
10 areas.-- 5, 6 and 8 are among them ~~ in which the Applicant I l
I 19 didn't really consider that all cables burned completely.
4 20 Is that correct?
4 21- WITNESS BEHN That's correct. l 22 MR SHON: Does that get us off dead center?
(- 23 MS. WOODHEAD: Yes. Thank you very much. f s
24- BY MS. WOODHEAD: I 25 Q Mr. Behn, in your position as a fire protection 7 r r w w
l 1 7035 wel 5 l 1
{
8 consultant to NRC do you make the final decision as to i {
t l 2 approval or disapproval of an Applicant's fire protection I i I ,
3 program? {
4 A (Witness Behn) No, I don't. I give my preliminary 5 ' commentstoMr.Giardina,andtheyarereviewedbytheStaff.'!
I !
C Q Mr. Giardina, is the definition of a design basis l 7 fire a part of the principal design criteria referenced in l i
6 50.35 of 10 CFR? i t
i l
E A (Witness Giardina) Would you repeat that, please? f 10 Q Is tne design basis fire in a fire hasards analysis,'
l 11 or fire protection program, part of the principal. design ,
12 criteria which is mentioned in Section 50.35 of 10 CFR? ;
i 13 A Yes, it is. {
14 i MR. GALLO: Objection.
15 '
MS.WOODECAD: pardon me? : i t 4 i
!6 l MR. GALLO: May I have a moment, please, Mr.
- 3 17 Chairman?
10 CHAIRMAN WOLFE: Well, the witness said, "Yec, 1
19 it is." :
1 I
20 MR. GALLO: The question calls for a legal 21 conclusion. There's no foundation -
1 i
21 i CHAIRMAN WOLFE: The witness already said, "Yes, {
i? l f " it is."
~
f i .
24 ; MR. GALLO: Thank you, Mr. Chairman. I move to
~
l 25 ; strike-the answer, so that I can mrke the objection. Aside (
.l .
l .1
. m - _ _ . _ _ _ . . . - . . . _ . . _ _ _ _ _ . .
7086 !
(
wel 6' ,
I from the fact that it appears to call for a legal conclusion, o
- which this witness ic not competent to make, there's no !
7' 3 foundation. And I was just going to establish wise.lf, f 4 i rather than put counsel through the rigors, as to whct E 50.35 provides with respect to design criteria. !
6 I assume by 5035, we're talking about 10 CFR Part i
7 50, Section 50.35. .
C MR. GALLO: I previously stated, Mr. Gallo, it '
l E l was in 10 CFR..
l IE - Mr. Chairman, the Staff makes the engineering I l
I 11 I judgments ac to what the principal architecture and design G
i
' is in relation to the requirements for a construction permit. ,
l 15 It's an engineering judgment. It's not a legal s ,
14 .- judgment. ,
15 MR. GALLO: Mr. Chairman, I've looked ut the i
l 15; ! section. I don't see any criteria listed in 50.35. I th ' thought the design criteria were in Appendix A.
7 18, : I will object to the question. It's just not 16' intelligible. )
20- MR. SHON: The word is used, at least,tir. Gallo. ,
I f l
T1 50.35 . .. [
l
'l 22 j MR. GALLO: It's true. It's one of the findings f t
?3 ll that havc to be made, Mr. Chairman, but I thought the cense i
i :
h Is fire protection, or come such thing, 24ll of the question was .
I, e H I
.o t-I3 y required by the architectural engineering desicrn criteria of i I l I
t- :
- _ - . --_._~, _s. - __...._ _ ..
7067 1
wel.7 1 50.35, and there are none.
- 2 MS. WOODHEAD: No, that was not my question, Mr.
3 Gallo. My question was - ,
i 4 CHAIRMAN WOLFE: Well, let's back up and get the
-( l 5 question, Mr. Reporter. ;
6 (Whereupon, the Reporter read from the record, as 7 requested.)-
B MR. GALLO: Mr. Chairman, I'll make it easy. I'll l 9 withdraw the objection. i 1
10 MS. WOODHEAD: Thank you, Mr. Gallo. l l
11 BY MS. WOODHEAD:
12 Q Mr. Giardina, I believe your testimeny stated j t
,.. 13 you reviewed all the principal architural and engineering i !
., 14 design criteria for the Black Fox fire protection program?
15 A (Witness Giardina) That is correct. l 16 j 0 3xcept for the design basis fire, are there any t
17 outstanding items in the principal architecturc1 . and l
18 engineering design criteria.
19 A No, there are not.
20 MS. WOODHEAD: Thank you. No more questions. (
21 CHAIRMAN WOLFE: Any recross?
l 22 MR. FARRIS: No.
23 RECROSS-EXAICNATION l
BY MR. GALLO: 1 24 <
E 25 Q Mr. Giardina, did you hear Mr. Behn with rospect I
> y 04O siati. L -pme- e-* -
f '
7003 i wal 8. :
i I 1 to-the four areas he identified for me as being inadequacies .
i
' ,! in the-Applicants' Fire Hazards Analysis? Did you hear him :
i I- : i 3 .j indicate that he would be satisfied with a 3-hour fire barrier ' ,
i
- f: 4 inserted between the systems?
5j -A' (Witness Giardina) I heard his answer, yes.
s ,
6 Q Do you agree with. his judgment? I t
7 A No, I do not. .
E j Q Would you explain why not?
F ! A A three-hour barrier would only be part of the I .
TC NRC's philosophy of a defense in depth. We would still 11 ! require fire extinguishing systems in the area, and detection.
12 O Do you .know whether or not those systems arc l
, 12 provided in the areas that Mr. Behn testified to?
M ,
A I-understand there are some systems in there. I i
in don't know the details of that system, i' ,! O So'you don't know that they're not there?
I
- ? A That is c0rrect .
is f Q Mr. Behn, how do we keep people from going into i Is I the containment crea during operation?
l (Witness Behn) Presuming the containment is j
20 t A.
II 21 h accessible during operation?
I '
Q Yes.
in .i4
[: .
A That.would be up to the plant personnel.
23 l:. !
p Q ' Based on your e::parience in plants you've been in, '
r Y .
15 h do you have some iden of what controls might be used? l ii n .
I Id
- i w e- -
,31 9 7089 l
l I A I don't know. ,
1 2 j 'l MR. FARRISr Objection. I don't think any other g
l*
3 plant's controls are relevant to Black Fox Station.
I 4 CHAIRMAN WOLFE: I'm sorry, I don't hear your l 5 objecti:n, Mr. Farris. ,
1 6 MR. FARRIS: I don't think that what other personnel 7 controls are applicable in other plants has any necessax,/
relevance to Black Fox Station.
8 9 We'renottalkingcboutfiresincontainmentareas,I i
I 10 I don't believe, anyuay.
il MR. GALLO: Mr. Chairman, I don't know if the II Reporter caught it, but an answer was given: To wit: "I I l
13 don't know." And that probably disposes of the problem.
14 CHAIRMAN WOLFE: Was there an answer, Mr. j i
15 Reporter?
16 MR. FARRIS : I'll withdraw the question in light ,
17 of the answer, not in light of Mr. Gallo's cormacnts . ,
i 18 There is a remedy, as you know, but I'n'catisfied !
19 with the answer.
20 CHAIRMAN WOLFE: Was there an answer to the l
21 .,
question? -
22 (Whereupon, the Reporter read from the record,
. 23' as requested.)
24 MR. GALLO: I have no further questions, Fr.
25 Chairman.
r- t F
.41 10 :
. 3 7090 l F i i
I MR. FARRIS: No further questions. j Ho further questions. '
.- ' 2 -j M3 WOODHEAD:
i 11
- 1. ;
- ' BOARD EXAMINATION l
- BY MR. SHON: >
? i i
Bb Q I have a couple of short questions, particularly <
l
- 1 6 directed to Mr. Behn.
7 I -)ust want to clear up in my own mind the O differenco that you and the Staff's other experts see between F l the situation in'the cable spreading room on the one hand, 1
if and in areas, fire arens 5, 6, 3 and the ones you pointed out 0
l iF in the hczards analycis on the other hand.
I:
3[a Ic it true that your reason for being satisfied
'd with the area in the cable spreading room is that the i n :
14 y three-hour fire wall exists between the redundant cyctcms? !
H ,
] A (Witness Behn) That's correct.
Tl 0 And in'the other case where it does not, and the i,
g p protection relied upon cimply the ceparction specified in l
- E . ;i IEEE 384, Reg. Guide 1.75, you feel that in not adequate ,
. t if ! if almost any kind of an exposure-fire occurs, is that i
, ?
i right?
20 o:
,. . t ,,,
[.
O i. .
j' 5 t
7.1 ,,
- p 2 0 . ..
y a f. i T 6 l
e na 9
.. . .. - = ,
1
- 7091
- 28 arl i A (Witness Behn) That is correct.
i
- 2 O You have mentioned seeing things liko five !
)
3 gallons of flammatie liquid. We have heard of some tests I :
4 run, I believe, at Sandia wherein the criteria of IEEE 384 1,
5 i I
for separations were met, but an exposure fire was simulated i i
6 l by two burns, each approximately double the capacity of --
7 each approximately of the capacity of that specified in j t
B IEEE 383 and in which cables in vertically separated i f !
9 ! cabic trcys we'e r simultaneously affected; is that right? ]
to l A That is correct.
I 11- Q Is fivo gr.llons of a flammable liquid in any l
12 ! way comparable to two such burners as an ignition source? j 13 A I would have to consider the Btu output of l l
1 t, ,
the flammable liquid.
I l Do you have any idea how many Btus is 75 j Q I t 16 i represented by five gallons of flanmtable liquid?
1 A Ho, I don't.
37 3g Q You don't?
l A No, I don't. I don't think it is an arbitrary 10 ,
20 figure of five gallons. As I montioned previously, a half gallon or a pint can have just an devastating an effect 21 as a five gallon can can, given the right situation. It is 22 l
\
hard to put a quantitative number on the exposure fire. i
- 3 l I
l g 0 Because you nean the liquid could be splashed j l !
t 9
ver, say, several redundant cable trays or something like l
~5 i
1 i
-. 2 _ - . . .- ._.___;.__...,.
1 t e
i 7092- l ar2 I i
t 1 ! that?
s 2 A Yes.
(-
5 ll 0 I see, i
I s.
4dn Thank you, t
?
5 CHAIRMAN WOLFE: Any questions based on Board l t .
6 questions? !,
7 MR. GALLO: No questions.
E ,1 MS. WOODHEAD: No questions. i 3 i 9 MR. FARRIS: Mr. Chairman, I would like to refer l 10 .
Mr. Shon to the fire ha::ards analysis, page A-18, in fire ,
), .
11 area 26, there is reference --
11 i
i MR. GALLO:: I am going to object to this procedure.I t
33 , The time for findings of facts and conclusions of lau l
/ ! i la
)
is after the record is closed. ,
yjf i,t MR. SHON: Are,you about to tell me how to calculate the Etus in five gallons? I already knou.
is
- - MR. PARRIS
- I was going to show you it is there, 79 it has been calculated. !
l gg MR. SHON: I looked it up in the fire hazards ,
20 l analysis, but the witness said he did not know and I didn't
.f think it worth pursuing. j 21 MR.. PARRIS: All right, sir. j m.
a L, MR. SHON: Thank you very much. ;
(
~, i CHAIRMAN WOLFE: All right, the witnecsas.
are excused.
D l
.c.
.~<. p
< p
, _F (Witnesses e::cused.)
a it O t 4 !
n-
-u 2
3 1 7093 ar3 1 CHAIPJ4AN UOLFE: We are proceeding to 5:00 l
2 o' clock this evening. Is there some reason uc can't l 5 proceed with your uitness, Mr. Farris?
4 MR. FARRIS: Yes, I would say a very good reason. l l
5 We have decided to withdraw Mr. Minor's testimony. We i
6 feel like we were had in fourth quarter, and we are going !
7 to sit on the ball, so we are withdrawing Mr. Minor's 8 tectimony, and that will be the end of it. :
9 CHAIRMAN UOLFE: All right.
10 (Board conferring.)
11 CHAIPJmH.10LFE: This concludes the testimony, ,
11 then, on Contentione 7, 8 and 9; is that correct? ;
i
- 13 MR. GALLO: Subject to review of the record 5 14 and filing of possible rebuttal testimony, Mr. Chr.irman, l
15 that is correct. .
i 16 MS. WOODEEAD: That is correct.
17 MR. FAFJdS : In that regcrd, Mr. Chairman, we ;
I '
ta may have some rebuttel testimony, that may in f act be filed '-
ig i by Mr. Minor, and I don't want to indicate that by withdrawal; 20 of our direct testimony, we would not be filing any rebuttal I I 21 testimony. ;
! l l .end 20 22 (Board conferring.) ,
l .-
i 23 ! !*
l I
24 i
. , l
, i 25 .
I f,
. . . . , ~ . .
i 7094 I
i david 1 ' CHAIRMAN WOLFE: We still have outstanding a t
1 2
tape 29 staff orcl motion cupported by the intervenors. In I i
3 i light of advice from the parties that they mcy vich !
( e
?
\- '
to file rebuttal testimony, obviously we cannot rule on 5
the oral motion or make a determination whether we vant c 6
written motion from the staff.
I So pending advice from the parties whether 8
they are or are not going to file rebuttal tcctimony, l 9 we will not rule on staftc motion which was orclly 10 presented yesterday.
II MR. GALLO: Mr. Chairne.n, beforc Ve recess --
12 - CHAIRIMN UOLFE: Yes.
13 MR. GALLO: I want to make it clear on the j u ,
14
- record that I view the status of the staff's motion in !
15 this light: that an oral motion was made, cnd I move 16- that it be denied without prejudico. I don't believo I !
t 17 used thoso exact words, but that is the thrust. I move IB that it be denied without prejudice and filed in writing. ,
t 10 If that motion is denied, applicants request j 20 the opportunity to then address intervenor's motion and 21 advance legcl crguments in opposition orally.
22 MS. WOODHEAD: I am corry. I don't understand 23 you, Mr. Gallo. You wish to --
24 MR. SHON: I think Mr. Gallo acid 25 intervenorc when he rant staff's motion.
. _ . - __ _ -...m_.a.__... ,
l 7095 1
d2Vid2 MR. GALLO: I misstated it, and I correct myself. What I am saying, Mr. Chairman, that as a 4
3 '
preliminary attack on the motin, I thought it was i:nproper to file it and the vehicle should be filed in writing 5
with response times.
6 If that is denied by the board,I would like 1 7 l to address myself to the motion on the merits. I haven't 8
had that opportunity.
9 '
CIIAIRMAN WOLFE: We understand that. Yes?
10 MR. GALLO: Thank you. l I
11 MS. WOODHEAD: It was my understanding, 12 Mr. Chairman, after I made the motion that the board 13 suspend a decision on whether or not they felt that 14 4
they caid answer it orally or they wonid need a written 15 motion with legal argument.
16 I indicated then, and I would urge you now, to 17 make a decision on the oral motion, given the assumption 18 that MR. Gallo would have the right to orally argue 19 his viewpoint and also intervenors would be able to 20 argue theirs.
21 We will are arguing also CHAIRMAN WOLFE:
about a third option left to the board on what to do with 23 your-oral motion, so we will reserve ruling between'our
,. options'until, as I say, the parties have indicated 25 whether they are going to submit rebuttal testimony.
7096 i
l 1
david 3 MS. WOODgEAD: Did you want a statament now?
,-- 2 ,
CIIAIMIAN WOLFE: I'm sorry? !
3 i MS. WOODHEAD: Are you asking the parties noir {
r 4 I i
whether they intend to do so, or is this to be decided --
5 'l CHAIRMAN WOLFE: I assume that they had reserved the 6
right to do so. I assume at sometime before we conclude ,
7 this portion of our hearing that we will be advised 8
whether or not they do wish to proceed with rebuttal 9
testinony.
10 And you had left that open as well, had you not?
11 ,
MS. WOODHEAD: The ataff is prepc cd to state 12 1 now that we do not intend to provide rebuttal testimony )
.l l 13 w on this -- we don't intend at this time to present 14 l robuttal testimony unless this is establiched as e r l 15 ! l
- procedure by the other partiec. l l 16 j j (Board conferring.) ;
CHAIDIAN UOLFE The board has boon conferring. f end 29 18 MR. SHON: Ms. Woodheade I would like one 19 matter clarified at least.
20 At page 6877 of yecterday'c transcript where
. 1 21 you actually made the motion that is precently beforo uc, l 22
- you caid, "I move that the applicant be required to consider 1 3
23 -
e::posure fires as the basic for his fire protection l
. program, consistent with Appendi:: A to branch technical {
^
U position S.5-1.*
l i \ ,
I 1
}
7097 david 4 1 Could you site us the exact section of that 2 Appendix A to which you refer?
3 MS. WOODHEAD: Yes. Just a moment.
( 4 '(Pause.)
5 The section I referred to is on page 9.5.1-9.
6 MR. SHON: Okay.
MS. WOODHEAD: Under Roman numeral I, definitions.
7 8 THe particular part referred to is that design basis firos; 9 this is a section that was read into the record 10 previously. ,
1 11 MR. SHOM: In the first place, that isn't in 1
12 Appendix A to the document; it is in the bottem of the r document itself; is that not correct?
13 14 MS. WOODEEAD: I believe you seu in Appendix A on the first page or taro it says, preliminary definitions 15 16 are referred to in the BTP.
g7 MR. SHON: It is in the bottom of the document gg that these definitions appear.
MS. WOODEEAD: Right.
19 20 MR. SHON: Secondly, perhaps I haven't looked 21 quite enough, although we massaged the section quite.
thoroughly eazlier on; I don't see the words " exposure fire" 22 23 assuchmentionedinthatdefinhon.
MS. WOODEEAD: That's right, Mr. Shon. The 24 explicit words are not there. If you recall Mr. Behn's 25 1
1
l 7098 J
david 5 'l testimony, his interpretation of that for fire protection 2 purposes is an exposure fire; the worst case would be 7
3 an exposure fire.
4 In later revisions of the branch technical 5 position it is explained much more clearly. The word 6 " exposure fire" is used, but this was the original design y basis definition which has been clarified since t
8 then and is readily available to applicants for use. j 9 MR. SHCN: If indeed later Versionc of thic l
to branch technical position make this more clear, why did you l tt not cite these later versions to us in making the motion?
12 MS. WOODEAD: Eecause applicant has accepted 13 this particular branch technical position for its use, v
g and I thought it would be simpler to use his choi;e to 15 refer you to rather than some other Reg Guido or branch l i
16 technical position to avoid the confusion that no have l 17 had about which applies.
MR. SHON: He might voll not have chosen exactly gg {
19 that for just some such reason.as avoiding the term 20 8Kposure fires. -
MS . WOODEAD : I think that would be unlikely, 21 -
22 although I can't testify as to the applicant's mental 23 pr cesses. N l i~
1 I think the staff han testified that the 24 g original branch technical position is more stringent than q l l i- l 1
, .i l t
^
1
.u____.._.-_., __
7099 l l
l l
1 david 6 later revisions, and we review on the more lenient l
. 2 I revisions.
3 MR. SHON: I guess what still troubics me is I
( 4 the fact that your motion makes reference to exposure 5
fires consistant with Appendix A, and then we found 6
that Appendix A references a definition in the body of 7 i the document and that that definition then doesn't use 1
8 ,
the word exposure fires, but you tell us that that is the j 9 i staff's interpretation of the definition. ;
10 $
Perhaps your motion should simply have said I 11 "concistent with the staff's interpretation of design l
12 basis fires."
{ la' MS. WOODEEAD: That's fine. I would be glad I
t to change it.
15 I withdraw, and to cicrify it or refer to a i t
16 different definition., l 17 MR. SHON: I think it has been clarified for me l l
i 18 '
now, but I was concerned about the fact that the l
19 - 1 real worde used in your motion don't appear in the document i that you mentioned in the motion, and that bothered me.
i 21 Thank you.
22 l end 30 , .,
i l
23 l j 24 >
- l 3
-25 ,
' )
i l
, i i
. ~ . _ . - . . . _ . . _ . . . . _ ., . . . , _ , _ _ , _ _ . _ _ , _ _ _ _
7100 !
- 31 arl l i
I MS. WOODHEAD: 'Thank you. l i
.- 2 CHAIRMAN WOLFE: We are considering it, Ms. I 7 <
3 Woodhead, and we are considering scheduling oral argument ;
/ 4 Did you wish to, other than merely state for Monday. '
1 t 1 5 your motion, did you wish to reserve time to in support of 1 l
6 your motion, or are you just stating your motion, period? l 7 I intend to ash Mr. Gallo and Mr. Farris how l O much time they will need to respond to your motion as stated t l
9l on the transcript. i 10 My question is did you wish to reserve any .
l 11 opening time to supplement your motion? ,
i 12 MS. WOODHEAD: I think in the event that the 1
- 13 Board decides to handle this as oral argument, I would l 14 certainly like time to clarify my motion. Could I alternatively '
if Ij cuggest that rather than delay the hearings further, which ,
i if
! are scheduled for next wech, wo either decide -- the i
17 Board decido the motion today upon oral argument or upon ,
18 written argument, written pleadings, to be submitted to j 19 the Board within the Board's time.
I 20 CHAIRMAN WOLFE: Well, we have 10 minutes to make 21 up our mind on it, it being nearly 5:00 o' clock. I don't ,
l i
22 I think we can hold oral argument this evening. ,
' t'
- g 23 ! It has all along becn Mr. Gallo's suggestion that l i 24 i i
we proceed via written motion, co under the circumstances, ;
? !
25 i- do.you wish to withdraw your oral motion and request leave j
) i J i d 1
7101 ar2 1 to file a written motion within -- how many days would you I
- '2 need after the beginning -- what are the dates -- with 7
3 your time beginning to run as of -- with your time beginning I 4 to run to file your written motion as of December 16th?
5 !!S. WOODHEAD: The question is how much time do I l l
6 need?
7 CHAIRMAN WOLFE: Yes.
8 MS. WOODHEAD: I believe 10 days. Let me see 4
9 what day that falls on.
't 10 CHAIRMAN WOLFE: Friday is the 15th, is it?
11 !!S. WOODHEAD: That's correct.
12 ' CHLIRMAN WOLFE: All right. Then 10 days,
- 13 would that be sufficient?
14 MS. WOODHEAD: 10 days. That happens to 95 be Christmas. I withdraw that suggestion.
16 (Laughter.)
How about the 15, the usual 15 days for a motion?
17 10 CHAIRMAN WOLFE: That would begin when, then?
You are right on top of New Year's then. It's your motion, 39 20 however, you do what you wish.
MS. WOODHEAD: It would be due on January the 2nd, 21 22 given the intervening holidays.
CHAIRMAN WOLFE: It's your motion.
23 ,
MS. WOODHEAD: That's true. I anticipate having 24 it in significantly before that, but I would like to allow 25 I
c- -
1
- m. .m . . _ .
c_. _., . _ . . . _ _ . . . . _ . _ . . _ __ _ _
7102 ar3 i
t' myself a little extra.
3 j
- CHAIRMAN WOLFE: You are withdrawing your oral ,
' s, 2
motion of yesterday; is that correct? I 1
(~ MS. WOODHEAD: Yes. I wish to withdraw.
4 i CHAIRMAN WOLFE: Thank you. Well, then, file l 5 i l 6 your written motion on or before January 2, 1979.
MR. NELSON: Applicants have no objection to 7
I 6
Staff having a floating deadline; however, we would like to ;
g have a firm deadlino to respond, and I would suggest 15 days )
after the 2nd of January.
,_ 39 CHAIRMAN WOLFE: For your response? <
11 MR. NILSON: Yes.
12 CHAIRMAN WOLFE: All right.
'd
- 13 f
k Mr. Farris?
MR. FARRIS: We will respond within 15 days after I
the Staff's motion is filed. i 16 CHAIRMAN WOLFE: All right. Very good.
17 ;
All right. Now we will recesc until 9:30 Monday morning.
19 (Whereupon, at 5:02 p.m., the hearing was 20 I
adjourned, to reconvene at 9:30 a.m., Monday, December 11, 1978.) !
22 23 t .
24 i he I
- -_-__-_- __ _ _ - -