ML20196H588
| ML20196H588 | |
| Person / Time | |
|---|---|
| Issue date: | 09/20/1994 |
| From: | NRC OFFICE OF INVESTIGATIONS (OI) |
| To: | |
| Shared Package | |
| ML20150F728 | List:
|
| References | |
| FOIA-97-180 NUDOCS 9707300264 | |
| Download: ML20196H588 (53) | |
Text
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I r
1 UNITED STATES OF AMERICA 2
NUCLEAR REGULATORY COMMISSION 3
l 4
OFFICE OF INVESTIGATIONS 5
X 6
In the Matter of:
7 INVESTIGATIVE INTERVIEW l
8 Clayton W.
Brown (CLOSED) 9
-X 10 Nuclear Regulatory Commission i
11 Executive Conference Room i
12 801 Warrenville Road l
12 Lisle, Illinois l
1.:
14 Tuesday, September 20, 1994 15 16 The above-entitled matter commenced at 9:50 a.m.,
17 when were present:
18 RICHARD C.
PAUL, Senior Investigator i
19 JOSEPH M. ULIE, Investigator 20 Nuclear Regulatory Commission 21 Office of Investigation 22 Region III 23 801 Warrenville Road 24 Lisle, Illinois 60532-4351 l
l 25 1
3 ANN RILEY & ASSOCIATES, LTD.
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1 PROCEEDINGS f
i 2
[9 : 50 - a.m. ]
3 MR. ULIE:
Today's date is September 20th, 1994 4
at approximately 9:50 a.m.
For the record this is.an 5
. interview of Clayton W. Brown, spelled B-r-o-w-n, who is i
i 6
currently a technical consultant to Brand Fire Protection 7
Services.
The location of this interview is The Executive 8
Conference Room of the United States Nuclear Regulatory 9
Commission's Region III Headquarters Office, located at 801 1
10-Warrenville Road, Suite 255, in Lisle, Illinois.
i 11 Present at this interview are Richard C.
- Paul, 12 spelled P-a-u-1, Senior Investigator, and Joseph M. Ulie, 13 spelled U-1-i-e, Investigator, both with the United States.
y 14 Nuclear Regulatory. Commission, Office of Investigations.
15 As agreed, this interview is being tape recorded 16 by court reporter Ronald N. LeGrand.
17 The subject matter of this interview regards a 18 fire barrier material known as Dow rorning Number 3-6548, 19 Silicone RTV Foam which is used 2.n the nuclear industry.in 20 part as a fire resistive barrier t.o seal penetration 21 openings, so as to separate fire areas.
This interview will 22 also allow Mr. Brown time to provide any additional 23 information pertinent to the subject matter of the interview 24 for which Mr. Brown may wish to make a part of this record 25 of proceeding.
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)
1 Whereupon, 2
CLAYTON W. BROWN 3
was called for examination by an investigator for the NRC 4
and, having been first duly sworn, was examined and l
5 testified as follows:
6 EXAMINATION 7
BY MR. ULIE:
8 O
Please be seated.
t 9
For the record please provide your full name?
10 A
Clayton W.
Brown.
i 11 Q
Due to the number of name and/or organizational 12 changes that have-occurred since you were the company f
13 President of Brand Industrial Services Company, more
{
24
- commonly known as BISCO, could you provide an overview of l
15 the organizational changes BISCO and its successor Brand 16 went through and your position when these changes occurred, 17 as best that you can recall?
i 18 A
Approximatel; five years ago, the controlling 19 interest in our parent company, Brand Insulations, or the 20 Brand Companies, was acquired by Waste Management Company.
21 At that time the Brand Companies were involved in many 22
. specialized forms of contracting, like industrial 33 scaffolding, asbestos abatement, et cetera.
I was also 24 president of about five different asbestos abatement 25 companies and,;when-Waste Management acquired control, they 1
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1 restructured the company and over the period of five years 2
continued to restructure the company to where BISCO's name
[
3 was changed to Brand Utility Services as part of Brand 4
Marine Services and it was at one time Brand Nuclear 5
Services and currently it is Brand Fire Protection Services.
6 I had, even though I retired three years ago and 7
became a consultant at their request, constantly argued not 8
to lose the name of Brand.
We were the only company left in 9
the entire organization that retained a Brand name for its 10 marketing purposes.
Other than that, about a year ago the 11-entire group of companies were integrated into Rust i
12 International.
As of September 1, our group for the nuclear 13 fire service was acquired by a John Giangi who was President 14 of the Brand Marine Group.
Now he is sole owner and has 15 separated himself from the Rust group and we are continuing 16 to do business as Brand Fire Protection Services.
17 MR. ULIE:
For this interview, the names Brand and i
i 18 BISCO will be used interchangeably.
19 BY MR. ULIE:
20 0
Does the fire barrier penetration seal used by 21 BISCO and used in the past at nuclear plants have the 22 specific name and number designation of Dow Corning 3-6548 23 Silicone RTV Foam?
24 A
That is the product, one of the products we use.
25 Q
For purposes of this interview, this is the i
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particular type of foam that we would like to have addressed 2
when you respond to our questions.
We are just going to 3
refer to it as silicone foam.
4 A
Okay.
5 Q
How many years have you been involved in,the 6
penetration fire barrier seal business?
1 7
A About 17.
I 8
Q And how many of those years have you been 9
specifically involved in installing seals at nuclear power 10 facilities?
11 A
Seventeen.
12 O
Approximately how many nuclear power plant units 13 did BISCO have a contract to install penetration seals?
14 A
Fifty-five in the United States and six more in 15 countries.
16 Q
Did BISCO co-develop the silicone foam material 17 with Dow Corning?
18 A
Yes.
19 Q
Could you provide background details in a summary 20 form regarding the development of the silicone foam?
21 A
Before my coming with the company, the research 22 and development group of Brand Industrial Services was
.13 looking for a better product for nuclear fire seals.
They l
2' had worked with urethanes and cellular concretes, et cetera, 21 but as they saw the nuclear industry developing they ANN RILEY & ASSOCIATES, LTD.
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1 realized there had to be a better, more versatile material i
2 with a longer life.
Knowing the durabilities of silicones, 3
they contacted Dow Corning and together created a foam, a
4 foaming which is 3-6548.
5 0
Would you please read over this November 12th, 6
1984, letter from Dow Corning to its power applicators which 7
identifies a silicone foam formulation change.
I had a 8
question with respect to that document.
9 A
Yes.
10 Q
Do you recall receiving this letter?
t 11 A
Yes.
12 Q
The letter specifies fire endurance testing was i
13 conducted that showed the modified formulation met or s
14 exceeded to properties of the existing silicone foam.
Did 15 BISCO's review of these tests concur with Dow Corning's 16 statement, do you recall?
17 A
Well, our subsequent testing showed that the j
18 material passed three-hour fire tests.
19 Q
So BISCO performed additional tests on their own 20 that showed acceptable results?
21 A
Not just because of the reformulation, but in our 22 regular business we are conducting many tests.
23 BY MR. PAUL:
24 0
Were these tests conducted after the formula 25 change similar or in the exact configuration as the tests ANN RILEY & ASSOCIATES, LTD.
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performed before the formulation change, do'you know?
2 A
Both.
3 Q
Both?
4 A
BISCO has hundreds of fire tests of many 5
configurations and I couldn't put a general answer on it.
6 It was -- some of the configurations may have been more 7
complex than the originals.
8 O
Did you ever have any discussions with Dow Corning 9
regarding this formulation change?
10 A
Yes, I was interested in the reasoning for it.
11 They were broadening -- actually, we had received, I 12 believe, two notices.
One, they had found a different 13 source for one or two of the components and also they were 14 broadening their tolerances of the formula for manufacturing 15 reasons that had no effect on the finished product.
16 BY MR. ULIE:
l 17 Q
What is of specific concern to us today is whether 18 you are aware of any problems with the silicone foam that 19 were nonexistent prior to this formula change that took 20 place around the '84 timeframe,but that began to occur 21 subsequent to the formula change?
23 A
Problems, no, I am not aware of any.
l 23 Q
Nothing, based on your experience?
{
34 A
No.
l 25 O
Are you aware of seal tests that were conducted on i
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the same seal configurations that passed fire endurance 2
testing prior to the formula modification change, but failed 3
the ASTME-119 conditions of acceptance after the formula 4
modification change?
5 A
By BISCO or others?
i 6
Q I will leave it open to anyone?
7 A
No, not for that reason.
l 8
O Specifically related to Dow Corning?
9 A
No.
10 0
And this particular product that we are talking 11 ab'out?
12 A
Correct.
13 MR. ULIE:
Rich, do you have any questions on the 14 formula modification change, at this point?
i 15 MR. PAUL:
Not as to the specific event, but I 16 would go back to it in general.
j 17 THE INTERVIEWEE:
If I can just add something?
18 MR. ULIE:
Please?
19 THE INTERVIEWEE:
If you talk to a testing lab, 20 most of the testing used to be done by Construction 21 Technology Laboratories.
22 BY MR. ULIE:
l 23 Q
Such as Portland Cement Association?
i 24 A
Portland Cement Association, that is where all of 25 our testing was done.
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run the same test identical, let's say, ten times and you 2
might experience a couple of failures.
It was just a fact 3
of probabilities in the testing business.
4 BY MR. PAUL:
5 0
As far as testing, generally, what is,the role of 6
the testing laboratory in the tests conducted for BISCO as 7
far as CTL's role, as far as oversight and writing the 8
report?
What were the procedures?
9 A
Well, we constructed the test, the configuration 10 and took it to them and then they took the test from there.
11 They did all the monitoring, providing all the results, all 12 the observations, et cetera.
13 Q
Did the testing lab do any quality control over 14 the construction and test article?
15 A
No, we did the quality control of the construction 16 of the test.
17 Q
So the testing facility actually constructed or 18 used the furnace?
What was their role as far as --
19 A
We mounted the test slab on their furnace and they 20 configured the furnace to the appropriate test star.dards and 21 then they had a control room where all of the thermocouples 22 and readings were fed to and they monitored the test through 23 the full three hours.
Then they did the hose stream test 24 and provided the results.
25 BY MR. ULIE:
l l
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Q Did they actually write the report?
2 A
Not always.
Not always, but the reports were the 3
result of -- we have always had people present and the 4
reports were the result of -- maybe for expeditious reasons, 5
we would write the report as a result of the tests that w'ere 6
given to us, send it to them for'their review.
They would i
7 review and make any corrections or modifications and sign 8
off on the tests then.
l 9
Q So there were times when BISCO personnel would 10 actually write the test report and submit it to the test lab 11 for review?
l l
12 A
As a result of their findings and the information 13 provided to us, like charts of thermocouple readings, et F
14 cetera, those things, or if there was a leakage or a failure 15 or whatever.
16 BY MR. PAUL:
17 Q
In those cases that BISCO wrote the report would 18 it be on BISCO letterhead or would it be on test laboratory I
19 letterhead?
20 MR. ULIE:
When the report was actually issued.
21 THE INTERVIEWEE:
We gave them the report and the 22 report --
I am not 100 percent sure, but I believe the i
23 reports were always on their letterheads, the summary page i
24 and the attesting to the results of the test.
25 BY MR. ULIE:
s
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1 0
The next series of questions is generally related 2
to the nine-inch seals that I know NRC personnel talked to 3
us in the past.
4 Did BISCO conduct a testing program to qualify i
5-various design configurations for generic use at nuclear J
6 power plants?
I think we have been talking along the
]
7 line -- th'e answer is yes?
8 A
Yes.
9 Q
Were these tests provided to nuclear utilities for 10 their use in demonstrating the qualifications of particular 11 seal designs?
12 A
Yes.
i 13 Q
Are you aware of the nine-inch seal, nine-inch l
14 fire barrier seal, that had the damming boards removed after I
15 installation that was successfully qualified for a three-j 16 hour1.851852e-4 days <br />0.00444 hours <br />2.645503e-5 weeks <br />6.088e-6 months <br /> rating using the ASTME-119 conditions of acceptance?
l 17 A
Yes.
l i
18 Q
Can you identify what the test report number is?
19 A
I don't know.
20 0
Would that be in the file'at Brand offices or 21 where would that be?
22 A
Well, the fire test is, but the problem was, there 23 was no subsequent or.we cannot find the subsequent hose 24 stream test report because BISCO had a fire in their l'
25 facility and we lost a lot of documents and all we can i
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assume is that that hose stream test report was lost in that 2
fire.
-3' BY MR. PAUL:
4 Q
Do you know in what timeframe that particular fire 5
qualification test was conducted?
6 A
It was before I came with the company.
It was 7
early '70s.
8 0
Who was the president of the company at that point 9
in time, before you came in?
10 A
Before me was a Stanley Mandeltort.
11 0
Could you spell his last name, to the best you 12 recall?
13 A
M-a-n-d-e-1-t-o-r-t.
If I knew the year of the 14 test, I could tell you if he was present at the time.
It 15 may not have been under his administration.
He was not 16
.there for a long time.
Prior to him the president was 17 William O'Brien.
-)
18 O
O'Ryan?
19 A
O'Brien.
20 Q
O'Brien.
21 BY MR. ULIE:
22 Q
Would it have been subsequent to that -- going 23 back to the time the vendor branch of the NRC did an 24 inspection of BISCO, I believe it was 1987, and they looked l
25' into this area.
I reviewed the inspection report.
It i
B a
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13 l*
1 talked about an October 1976, Portland Cement Association l
2 test and talked about a subsequent hose stream test that had 3
been performed.
So do you believe that test you are l
4 referring to was that subsequent hose stream test that would l
5 have been some time after October of '76?
6 A
It sounds like it.
If it was conducted in '76, I
7 should say that it was under Mandeltort.
8 Q
After installation of a penetration fire seal, 9
what was BISCO's recommendation regarding final inspection?
10 In other words, what I am really looking after is the 11 damming board material, whether one or both -- if there were 12 two damming boards put in place, was it common practice or
)
13 policy at BISCO to remove one or both of those or did it i
14 depend on a particular configuration?
l 15 A
Our technology, unlike all other contractors in 16 the business, is the seal, the finished seal, is without 17 damming boards left in place, except for floor seals where 18 there is a damming board on the bottom only, to support the 19 material as it is being applied and that particular board we 20 always made it of fire-rated material so it wouldn't have to al-be removed for labor reasons, labor costs.
22 All of Brand's technology is based on no damming 23 board left in place so that you could do a complete visual 24 inspection of the silicone.
25 Q
So after the installation -- and actually the 1
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BISCO installers walk away to turn it over to the utility?
l 2
Do you recall the policy being that there would be no 3
damming board?
4 A
Correct.
5 Q
Put back?
6 A
Correct.
There may be some very rare occasions on 7
a special' design where there had to be a damming board.
For 8
instance, there was one plant where we were directed to use 9>
a specific design that left damming board in place and we 10 were hesitant to use it because any system that leaves 11
' damming board in place has failures in it because the foam 12~
forms gas pockets, like underneath a cable tray.
In this 13 specific plant we did a number of seals at a direction to do 14 it and we were using a specific design with damming board in i
l 15
' place and even cautioning our applicators aus to the.
16 potential problems of installing the foam.
Later it was
(
17 discovered there were voids in the foam and we went back, 18 under warranty, repaired those voids.
19 O
That is'what I am trying to make a distinction 20 with the installers removing the damming boards, but then 21 putting back one or both boards.
You know, what the policy 22 was of BISCO.
It was not to put back either of the damming 23 boards?
['
24 A
Our damming board was an inexpensive ethefoam, 25 like styrofoam, and it was removed and discarded.
It was I
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not fire-rated so it could not be left in place and that was a
the basis of our technology except for floor seals.
3 Q
Okay, except for floor sealt and times when the 4
.. customer would require that damming boards be left'in place?
5 A
Or if there was a special design, because often we 6
ran into conditions where we had to construct a special 7
design which naturally was supported by fire testing of some 8
sort.
9 Q
Okay.
So, generally speaking, three occasions 10 that a damming board could be put back?
11 A
Yes.
I 12' MR. ULIE:
Rich, do you have any further questions i
13 in this area?
14 BY MR. PAUL:
1 15 O
In regards to the nine-inch seal, in 1985, I l
16 believe, ANI, American Nuclear Insurers, withdrew their j
17 approval for insurance purposes of the BISCO nine-inch 18 undammed seal; do you recall that?
19 A
Yes.
20 0
Could you tell us a little bit about or tell us 21 about the circumstances surrounding that action by ANI, the 22 best that you recall?
23 A
The way it was done -- you have to realize our 24 files have hundreds of tests and the way we discovered the 25 hose stream test was lost in some manner was ANI couldn't ANN RILEY & ASSOCIATES, LTD.
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find it in their files and they asked us for a copy.
So our 2
engineering manager went through the files and couldn't find 3
it which caused a dilemma, not having a supporting hose 4
stream test.
So ANI put out a notice to that effect, as I 5
recall, and then asked if we would retest that particular 6
design.
7 In fact, if I remember, on the first test, they 8
even shared in the cost of it, but they changed the 9
configuration that made it more restrictive than the 10 original test that we were -- the whole subject was about.
11 when we ran the test it failed.
So we ran it a second time, 12 as I recall, and it ran for, I think, two hours-and-45, and 13 ANI approved it then and sent out notices that they approved 14 the design for insurance purposes only.
15 Naturally, when the first notice went out to the 16 various utilities where the design was used, there was a 17 concern, but there is a conflict in our industry of 18 overlapping and conflicting test standards.
We did have a 19 successful test of a nine-inch seal without damming board 20 with a hose stream that met the NRC standards.
So I put out 21 a notice to everyone giving them a copy and informing them, 22 they should not be concerned because we have a test that met 23 the NRC standards, but did not meet ANI standards.
That 24 dif ference was ANI requires testing to be done with PVC-25 jacketed cables which is very severe and the NRC didn't.
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don't remember what the jacketing was on the cables in the 2
successful test.
3 Q
Do you recall the date of the successful test?
4 Q
, The 2-hour-and-45-minute?
5 Q
No, the 2-hour-and-45-minute was the ANI test, 6
right?
In 1985 is the date I have.
The test that you 7
mailed out that met the NRC requirements, which test was 8
that?
i 9
A I don't know.
I would have to look it up.
10 0
Was that before this test or contemporaneous, do
)
11 you know?
12 A
I can't remember.
13 BY MR. ULIE:
14 0
would you be able to identify or find that test l
i 15 and provide a copy to either Rich Paul or myself?
16 A
Sure.
l 17 BY MR. PAUL:
l 18 0
In regards to that failure, well, the ANI termed 19 it failure.
In regards to that specific test, did you have 20 any reason to believe that there was any difference in the 21
. performance of the foam material, the Dow Corning foam 22 material, from the previous test?
23 A
No.
If anything, the only change we observed in 24 the Dow product, I can't tell you at what point in time, is i
L25 that it had a higher density which makes it more fire i
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18
~
1 resistant.
It used to be that foam was in'the range of 16, 2
I think 16 to 20 pounds or 16 to 18 pounds, and suddenly'it
{
i 3
started running 20 to 23 pounds.
Well, this was of concern 4
to us because, commercially, we are paying,by the pound for 5
materials.
When we are quoting a job, if we are using that 6
lighter number we are losing money.
So we monitored.
Our 7
quality assurance manager, through our quality control 8
program, constantly monitored densities and, anyway, from 9
coast to coast on every project we were on and we saw the i
10 density rise.
We just compensated for it commercially and l
11 it paid a better sale.
12 O
In regards to the relationship that BISCO had with i
13 Dow Corning, did you rely on their -- any training or i
14 installation techniques developed by Dow as far as what 15 BISCO would do when they worked in a nuclear plant as far as 16 installing these seals of this material?
l l
17 A
No.
We relied on Dow for technical advise about l
18 materials.
We communicated with them on a regular basis 19 because we were always running into odd applications and we 20 would take their input, but if a test had to be constructed 21 to support a unique design it was based on our knowledge.
)
I 22 O
As far as installation methods, were those BISCO 23 initiated or were they Dow Corning initiated?
24 A
We extracted information from their knowledge 25 naturally, but all installation was based on our procedures.
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'Some of it is extrapolated from their experience with their i
2
. material.
l l
3 Q
One other area, as far as inspection techniques, 4
inspection of the completed product, were those Dow Corning
{
5 adopted procedure or were those BISCO initiated procedures?
6 A
BISCO procedures.
7 BY MR. ULIE:
8 Q
Are you familiar with seal deficiencies such as 9
cracking, splitting or gaps, lack of fill and voids that wereidentified--beingidentifiedwithasinstalleds"2h5h, b
10 11 which was the subject of an NRC information notice back in
{
12 1988?
13 A
Yes.
14 O
Based on your experience what do you believe the r
15 problem was a result of?
16 A
Poor application.
Was that Wolf Creek i
17 or Calloway?
i 18 0
Wolf Creek was the subject of that.
19 A
I was very disturbed at the report'because the 20 contractor was trying to blame the material, but again that 21 was damming left in place and I remember there was a very
~
22 high -- because I talked to Calloway about it.
There was a 1
23-very high percentage of voids as they started to inspect, l
I 24 taking damming off, and that is the flaw of damming left in 25 place.
'It was an application problem, not a material i
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problem.
2 O
Can you describe any settlements or other legal 3
actions that involved BISCO and Dow Corning against each 4
other relative to the silicone foam that you are aware of?
5 A
Well, there was some legal action, lit-igation, 6
before I came to Brand, but it was strictly commercial.
it 7
wasn't over the materials.
It had to do with sharing the 8
royalty over the co-development of the material, but it was 9
resolved out of court and I don't even know what the terms 10 were of the resolution.
There has never been any other 11 litigation between Brand and Dow.
12 BY MR. PAUL:
13-0 What about the settlement over -- any type of 14 settlement where BISCO contended there was something with I
i 15 the product, meaning the silicone foam?
Did they ever give 16 you a credit or anything for product?
17 A
There was something at one time.
It was nothing 18 big, but, yes, they compensated us through additional 19 material, but I don't even remember the details of it.
20 0
Can you recall if the details had anything to do L
21 with the product performance, the Dow Corning product?
22 A
No, it was quality.
You see a very important 23 factor of this business is an extensive quality control 24 program with various stages of inspection including raw i
- 5 materials and samplings, et cetera.
None of the other 2
4 ANN RILEY & ASSOCIATES, LTD.
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contractors in the business have the same extensive quality 2
control program that we have.
They have, in my judgment, 3
very borderline inspection and that is why you get a 4
Calloway or,a Wolf Creek.
5 Somewhere, I can't even remember the project, the 6
initial inspection of the raw material brought something to 7
the attention to our quality control group.
I don't even 8
remember the details of it, but I can recall that part of 1
9 it.
Therefore, some of the material I think had been used, 10 a little of it, but, again, through our system we knew where 11 every lot number was installed and whatever happened from 12 there.
I just remember Dow compensated us in some way with 13 some materials but, as I said, it wasn't a big issue.
14 0
In regards to that situation, did you have any 15 concerns regarding the Dow Corning product being deficient?
l l
16 A
No, never.
17 Q
Just as an overview, over the years, including 18 through the formula change, has the product performed 19 consistently in your experience?
20 A
To the best of my knowledge, yes.
We have never l
21 had a warranty call back in the 17 years I have been with l
l 22 the company except that one design I told you about where we 23 were told to put in that design.
24 MR. ULIE:
Do you have any other questions or 25 topics that you want to go over?
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MR. PAUL:
I have a couple.
2 BY MR. PAUL:
3 Q
It is my understanding that BISCO installed the 4
silicone foams used in WNP2, Wolf's 2 and also in San 5
Onofre?
6 A
Not all of them.
7 Q
Not all o[ them?
8 A
And not all of them at Wolf's 2.
9 Q
Are you aware of the recent licensee event report 13 filed by WNP2 regarding the seals where they declared them 11 inoperable?
12 A
Not all of them.
13 0
Well, declared a certain amount -- a certain 14 number of them.
15 A
In fact, I talked to the -- who wrote the report 16 from the NRC about it because I was amazed.
17 Q
What information do you have on this particular 18 event, and I would like to discuss some things about it?
t 19 A
Sure.
I was surprised when I saw that notice and i
20 I saw it quite some time after the fact.
That is, during my 21 consulting period, and I am not in the office a lot.
When I 22 called the gentleman who wrote the report and he asked if he 23 could call me back in 15 minutes.
The reason for that was 24 he got a few other people in the room and we were on a 25 conference call.
I asked him what this was all about ANN RILEY & ASSOCIATES, LTD.
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because I wasn't aware of any deficiencies out there and he 2
told me.
He kept referring it to BISCO's seal material.
I 3
said it is not a BISCO material, it is Dow Corning.
We use 4
a product with our own product number.
We call it SF20 in 5
our system.
6 They said, what do you mean, it isn't all BISCO 7
material?
I said, no.
I said, furthermore, Bechtel 8
installed a lot of seals after we left that project.
These 9
are Bechtel's seals, which didn't surprise me.
I said, 10 well, that is what the situation is.
So we had a long 11 general conversation about the seals and I offered our full 12 assistance in any way, providing information.
13 He said, well, what do you know about San Onofre?
14 I said Bechtel installed the seals.
He said, BISCO's seal 15 was used there.
I said, don't say that.
We have never 16 worked at San Onofre installing fire seals.
I said, Bechtel 17 installed them at San Onofre, too.
18 I am sorry, that was Diablo Canyon.
He asked me 19 about Diablo Canyon and your incident at San Onofre, if 20 there was an incident, the same thing occurred there where 21 Bechtel wanted us to leave the job before all the work was 22 completed.
There was still some to be done and they did 23 that work.
So whenever these issues come up, I suggest to f
24 our people, identify the seal and see if they are our seals 25 or Bechtel's seals.
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BY MR. ULIE:
1 2
O So, if I understand correctly, both the Diablo Canyon and at h h, Bechtel purchased the Dow Corning 3
4 material or,their installer or contractor, and the seal is 5
installed and BISCO was not related to those two' incidents.
6 A
Absolutely, that is exactly what the inspector 7
told me.
He said, no, these were Bechtel installed.
8 BY MR. PAUL:
9 Q
So in this particular case BISCO didn't provide 10 any qualification tests, it was totally separated from the 11 seals in question?
12 A
One of the flaws of our industry is people who 13 take a BISCO test, Bechtel or whomever, naturally Bechtel 14 was our largest client and we did a lot of plants and in 15 doing so we had to submit our designs and technology to 16 them -- through them for approval which they obviously l
17 copied for their own files.
They have done work using our l
18 technology without our knowledge.
j 19 I had all of our documents copyrighted some years j
20 back to protect ourselves from this because we suddenly saw l
21 this was becoming flagrant around the country for l
22 unauthorized people.
Even though every single document of 23 ours had a proprietary statement and cannot be used without l
24 approval, people have been using them.
That is an issue I 25 will expand on when I get my own free time.
It is critical.
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1 25
~
1 Q
For our information, we are aware that there are 2
certain issues as far as the silicone foam seal, such as 3
delamination, voids, things like cracking, has BISCO ever 4
experienced any of these problems with their seals?
5 A
I would have to say we probably have seen some 6
cracks which were caught by quality control, but a lot of 7
people are installing this product without full knowledge of 8
how to do it.
It is a very sensitive product that requires 9
explicit procedures on how to install it, how much liquid 10 you put in because it expands 300 percent.
If you put in 11 too much liquid, it won't expand as much and it will react 12 strangely.
Some people think that, well, I am going to get 13 it done faster where --
14 I Korea they installed liquid in one-third of the 15 entire opening when you are not supposed to put more than 16 maybe an inch, inch-and-a-half, thinking it would all 17 expand.
They had all sorts of splits, cracks and problems, 18 but they thought they would save time by doing that.
19 Well, you don't save time, you get the flawed seal 20 because so much of this was filtering out from sources --
21 whatever it is, this goes back some years -- Dow ran a fire 22 test deliberately creating delaminations by putting in lifts 23 of silicone foam, letting it cure and I think they spread 24 vaseline on it so the next lift wculdn't bond.
They did all 25 these things.
We experienced what we call edge curl.
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Silicone foam is subject to thermal expansion and 2
contraction and, if you install silicone foam on a very hot 3
day, like we had a lot of problems in a Philippines and in 4
Mexico where we had,to refrigerate the material before we 5
installed it -- a lot of people don't know this.
So the 6
people installing in hot climates are probably causing 7
trouble for themselves because if you install on a hot day 8
and that silicone foam is up against concrete and the lower 9
level of a nuclear plant is much cooler, that silicone foam i
10 will contract.
11 We call it edge curl and we have observed its
.12 size.
We have measured it.
We have had people check it and 13 we found the same thing Dow Corning found in their testing 14 of delaminations or splits.
That is because it is subject 15 to thermal expansion and contraction, once the fire hits it, 16 it expands and seals up.
So there is not problem.
17 I know of a plant that just last year tore out all 18 their seal without talking to anybody because they had edge 19 curl and they thought they were all flawed.
I later talked 20 to them when it was all over with and said, why didn't you 21 call us, we have a test to show that is no problem.
What we 32 do, because aesthetically, looking at it, people get 23 concerned, we will in areas and certain applications run a 24 bead of silicone caulk around that perimeter so that edge 25 curl is out of sight.
But our testing deliberately causing ANN RILEY & ASSOCIATES, LTD.
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4 27 1
that showed no problem and Dow had run a test showing.
2 delamination is no problem.
Once the heat hits it in a 3
fire, it closes up, but the splitting is usually a poor 4
application, 5
Q Do you know if Dow published any notices or 6
anything on edge curl?
7 A
I don't know about edge curl, but they made the --
8 I think they made the test available on the delamination in 9
order to put this whole issue to bed, that there was 10 something wrong with the materials.
11 0
So, as far as the application of the material in 12 fire seals in nuclear plants, what I understand you to say 13 is, it is very installation dependent?
14 A
Absolutely, absolutely.
15 0
And there is a certain amount of technique 16 required for the applications?
17 A
Absolutely.
At one point the woman that wrote 18 that letter you showed me wrote a letter to the NRC on that 19 issue, saying that they should be concerned that properly 30 trained people are installing this material.
The President 21 of the International Brotherhood of Insulators wrote a 22 letter to the NRC on the same issue becauce they knew, 23 working with the material because it is on union assignment, i
24 those insulators, they knew the sensitivity of it.
They had 25 a local in South Bend, Indiana, called Local 75B where the ANN RILEY & ASSOCIATES, LTD.
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1 members of that local were the sole technicians that 2
installed these materials.
They had written a letter years 3
ago to the NRC, too, cautioning them about who installs this 4
material.
They must be trained and knowledgeable in the use 5
of it.
So the NRC was notified by both Dow Corning and the 6
union on this issue.
7 Q
Does BISCO have a training program for installers?
8 A
Absolutely.
j 1
9 O
What does it consist of?
10 A
Going through our procedures.
It is not so much 13 a -- well, it is a training program, yes.
But we have 12 written procedures for every single step in the construction 13 of a seal, including how to mix the material, sampling of 14 the material, the lifts of the material that I explained 15 earlier.
I have been talking to the NRC for 12 years on 16 this issue because the problem lies with the fact, the NRC 17 took the position that as long as a test report exists that 18 is all they care about, and that was told to me by Dave 19 Notley, and I have cautioned the NRC up until even this year 20 that without the explicit written procedures, that test is 21 meaningless.
It is a picture, and that is all it is.
32 It has been prevalent throughout our industry, the 23 nuclear industry, people have been installing seals using 24 pictures without knowing how to work the material.
l 25 Q
Does BISCO have a QC program?
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. -. - _ = _
_ - _ _ _ -. - - - ~.-
2P 1
A Absolutely, very extensive.
2 0
In your nuclear contracts do you normally provide 3
the QC services along with the installation service?
4 A
We insist upon it.
I wouldn't take a contract if 5
we didn't have the quality control'because we would be
~
l 6
liable to criticism if someone else was inspecting our work.
7 O
Are you familiar with the term "Part 21"?
8 A
Somewhat, yes.
9 O
It is an NRC requirement that if the product is j
1 l
10 defective that you are required to notify the NRC.
Are you 11 aware of any Part 21s filed by Dow Corning in regards to the l
i 12 silicone foam?
i 13 A
Not that I am aware of.
j 14 O
Has BISCO ever filed a Part 21 in regards to the 15 Dow Corning product?
16 A
I don't believe so.
17 0
There is one issue you mentioned initially in 18 regards to the test reports where BISCO would write them and 19 they were possibly issued by CTL?
20 A
They were reviewed and critiqued by CTL.
The only 21 reason we wrote them was for expeditious reasons, no other.
I
(
22 CTL has written test reports also.
i I
23 0
Was that particular report that was written by 24 BISCO issued as a BISCO report or issued as a CTL report?
25 A
Well, CTL would have a cover letter confirming i
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what is in the report, the success or failure, and we would
)
2 put that in a BISCO test report.
3 Q
Did you identified that BISCO actually wrote the 1
4 report?
i 5
A I have seen the' signature of our engineering 6
managers on some of these reports.
Now, in what context, I j
7 can't tell you.
1 8
BY MR. ULIE:
9 O
Did one or more utility ever require contractually
)
10 that BISCO apply Part 21 to BISCO services?
11 A
I think they all do.
12 Q
If you want at this time to open up the interview, 13 you can add any information you would like to on the record.
14 A
Some of it I touched on because it has been a 15 concern of mine for probably 14 years.
One, I had very high 16 level meetings with the NRC back in '82,
'84 with Jim 17 Taylor, Leon Whitney, John Crieg, n
first telling 18 them of the biggest problem in the NRC -- in our industry 19 was the conflicting test reports, as I mentioned -- I mean-l 20 the conflicting test standards.
J 21 As I mentioned to you earlier about this nine-22 inch seal where we had an NRC -- we passed the NRC 23 standards, but it didn't meet ANI.
Now we put this together 24 years ago to show the difference in the test reports, the 25 test standards, ANI, NRC, ASTM, IEEE and NML.
It was i.
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interesting to note, after having done many plants, when we 2
went to do San Onofre, they were insured by Nuclear Mutual l
3 Limited who used different test standards and said none of l
l 4
our designs were acceptable.
I said, what you are talking
)
l 5
about?
They are in plants all over the country.
i 6
So through negotiation they accepted all of our 7
tests, but I had been after the NRC going back into '82, at 8
least, maybe even before that.
They should look into coming l
9 up with one test standard because of this problem, and the 10 best example is that nine-inch seal.
It passed the NRC 11 standards.
l 12 MR. ULIE:
For the record, let me just put on the 13 record that Mr. Brown passed out a document that is undated i
14 and untitled, but that lists approximately five test 15 standards and has the various criteria for penetration fire 16 seals.
17 THE INTERVIEWEE:
It was an internal document for l
18 our own knowledge.
If anyone got exposed to one of these 19 standards, he could look at this and see what the 20 differences were.
21 I talked to Dave Notley, it is a letter, December 22 of
'82, about my concern -- you can have these things -- of 23 the do-it-yourself concept that was starting to become 24 prevalent in the industry where people without the 35 sophisticated knowledge of designs and the use of materials l
i
)
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1
_ were actually sealing nuclear plants.
I pointed -- I 2
described to him what was happening.
This says, my call to 3
you was in desperation seeking a course to pursue to help I
4 prevent further problems from occurring similar to Zimmer.
)
1 5
Coincidentally, the penetration seals at Zimmer were
(
i 6
installed as a do-it-yourself project.
I will appreciate 7
any further information.
8 BY MR. ULIE:
9 Q
The date on that letter is December 22, 1982, and that was from Mr. Brown to Mr. Dave Notley.
10 l
l 11 A
This is just a confirmation letter back to Jim i
12 Taylor with some of our catalogues.
I don't know if it is 13 any help, but I will hand it to'you.
.14 BY MR. PAUL:
)
15 Q
Yes, we would like that.
16 A
Then the use of the people -- Ben Arroyo is not on 17 that list, but he was there also.
18 Then as the date -- the industry -- first of all, 19 there are a lot of plants out there that are sealed by 20 contractors who are not what are known as power applicators.
i l
21 Dow Corning established four power applicator agreements l
22-that we have, and our business is concentrated on the power 23 industry and no one else can do it, as far as Dow was then 24 providing materials to those people.
But contractors like 25 Daniel, Bechtel, Catalytic, on and on, Vasco, have or did i
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1 and are continuing to install seals without the l
2 sophisticated knowledge necessary.
3 Now what is the sophisticated knowledge?
We 4
encountered a problem -- not a problem, something. unique at E
Shoreham where, because of the length of time it took to 6
construct that plant, they had epoxy-coated all the concrete 7
walls and all the sleeves before any of the seals were put 8
in.
Well, the silicones had never been fire tested against 9
epoxies because the other problem is that epoxies leech 10 amines and amides which neutralize the catalyst, or maybe if 11 it doesn't neutralize it, it seriously affects the catalyst 12 that is in the silicone foam.
So, first of all, we had to 13 request an analysis of the epoxy and we ran an extensive 14 serious of tests to show that the designs we were going to 15 use in that plant were compatible in epoxied openings.
16 Nobody else knows that.
Bechtel, Daniel, they don't know 17 that.
They put it in the opening and something happens.
18 We also encountered it at Wolf Creek and Fort 19 Shuntley, we can use the same technology and we have a 20 chemical analysis of that epoxy that didn't leech any 21 contaminants.
22 Sulfurs, pulling compounds on cables are sulfur-23 based often.
That prevents the silicone from shee,ing in 24 contact with the cables.
Our procedures require the wiping 25 down and cleaning of pipes to get any sort of contaminant t
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I 34 1
off before you install the silicone foam.
Most of the 2
people that were doing this work didn't know that, so they 3
went on the material.
It is a sensitive material and you 4
have to know what you are working with.
5
.There are many examples like this that our people 6
are trained to be alert to, and our procedures cover these 7
things of what you should and shouldn't do.
i 8
BY MR. ULIE:
9 Q
A question I had, with respect to Bechtel, 10 Daniels, and some of the other companies that you mentioned I
11 that were not approved power applicators from Dow Corning, 12 how was it that Dow Corning -- how were they able to get the j
i 13 material, were they purchasing it directly from Dow Corning?
14 A
No, not without a settlement.
Some of our power 15 applicators, in order to get half a load, would joint 16 venture with them.
Now a training program -- I fought for 17 years not to train utilities to do their own maintenance 18 for, again, the fear of these things going wrong, but we 19 were back to the wall.
Even ANI set standards for training, 1
20 if we trained anyone else, ANI also says, but the ultimate l
21 liability lies with BISCO.
So we created a very i
l 22 comprehensive exculpatory agreement that we required a 23 utility to sign before we trained them.
24 The training -- our training program would run 25 anywhere from eight to ten days.
Whereas, you know, the TSI l
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1 program, they have maybe two days of training on the TSI 2
system, which is foolish, that should be much longer.
Other 3
people aren't training eight to ten days, and this agreement 4
a.lso required they~could not retrain.
5 Our concern was like the old party game where you i
6 whisper something in someone's ear and when it is repeated i
7 five times it comes out entirely different.
However, we did t
8 concede to one utility who videotaped our entire training 9
program because they wanted to retrain, and we said, based j
10 on that, if that is your training program, that we would 11 concede.
But we wouldn't even allow retraining for our fear 12 of all of the proper information not being passed on.
13 So back in '88, a lot of utilities were being 14 abused the power applicators.
They were concerned, 15 rightfully so.
So in '88, EPRI hired IMPELL to create a i
16 computer database of all testing of fire seals, and we saw l
l 17 through it immediately.
They came to us first because we 18 have the largest test library in the.world, and we saw i
19 through it right away.
We said, no, we won't cooperate, 20 because someone was going to take pictures and do their own 21 work or unqualified people.
22 I know there is a plant in the Midwest that did 23 some retrofit. modifications by two guys on a pickup truck l
l l
24 who used to be in the union and said, we can do it.
Tom
'25 Gilmore, if you remember, he was my vice president.
He got t
i i
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a hold of the utility right away and warned them of what 2
they could be exposed to here.
The utility didn't care.
We 3
feel they are qualified.
Two guys in a pickup truck with no 4
technology of any sort of their own.
5 So we told EPRI a'll our documents were 6
copyrighted, and I sent this letter to the fellow who was 7
the program manager of this database concept'and warned them 8
that BISCO will monitor any unauthorized use, copying or 9
exchange of our fire tests, and we will take appropriate 10 action to protect their rights.
11 This concept, because of our lack of involvement, 12 met with very limited success because, again, our argument 13 is, without the procedures this information is useless and 14 we can see people -- well, we know the utilities where we 15 have worked trade our tests.
They are not supposed to and 1
16 some honor our confidentiality and will call us and say, so-i i
17 and-so is looking for Fire Test Number Such-and-such, would 18 you talk with them, provide them a copy.
However, these 19 consultants who are out there now, I think trashing the 20 whole damn industry, they will call around when they are 21 consulting for some utility trying to get copies of our 22 tests and utilities will call us and say, so-and-so is l
l 23 trying to get a copy of this test of yours, and we have told 1
24 them to go directly to you to get it, but they don't.
25 This is a big hole out there.
Even the NRC now ANN RILEY & ASSOCIATES, LTD.
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1 will accept tests conducted that are in the UL catalogue.
2 It is on your report.
It doesn't tell you how to construct 3
it.
It doesn't give you detailed procedures of how to use 4
the materials, et cetera.
5 Here is a letter I wrote to Pat Madden in December 6
of last year.
I quoted Dave Notley, he said the NRC didn't l
7 care who conducted or owned a fire test to support a fire 8
seal design as long as the test existed.
I was telling Pat 9
Madden the trouble with not having these procedures,'all you 10 have is a picture when you have a test and the test report.
11 I have since talked to Jeff Holmes on the subject, 12 too, because he was involved in the audit of these three 13 plants, which really I don't know how -- if this is 14 coordinated with those audits, but I think you are on the 15 same subject.
I think it is extremely important.
There is 16 no problem with Dow selling the foam.
There is a problem of i
17 people who are using it and putting it in without the 18 knowledge of how to work with it.
l l
19 To give you an example, here'is a couple of 20 typical Brand or BISCO details.
To help our clients, we 21 have innovated what we call parameters, and this particular 22 picture is a flexible bootig fires.
We created this concept.
23 Is it good for a floor?
Yes, there is the test report.
Is 24 it good for a wall?
Yes, there is the test report.
25 Concrete or block, there is the test report.
Metal-lined, i
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38 f.
I there is the test report, and on and on and on.
Nine-inch i
i 2
annular gaps, there is radiation resistance in the 3
materials, what the pressure resistance is, what the 4
corresponding test reports, temperature limitation'on the 5
use of the material.
6 People would -- well, do you remember the report 7
that came out of the silicone foam burning up at Diablo 8
Canyon on the diesel exhaust pipes?
9 Q
High temperature over a prolonged time.
10 A
You don't put silicone; foam on a pipe like that 11 that is over 600 degrees.
Those exhaust pipes go to a 12 thousand.
Right away people wanted to blame silicone foam 13 again.
It is the lack of knowledge of what you are working 14 with.
We do this to show the consulting -- not the 15 consulting, the design engineers and our clients what the 16 parameters are.
There are limiting parameters.
Here is 17 silicone foam on a pipe penetration, all of the supporting 18 test reports and what the limitations are.
The limitation 19 on the pressure.
Pressure is a big issue on these seals now 20 that developed some years ago, aside from fire.
- Bechtel, 21 Catalytic, Vasco, Daniels, they don't know this.
They don't 22 understand it.
23 Here is another thing we did.
This was on a slide 24 projection when we would give a presentation of the 25 importance of the contractor having extensive engineering ANN RILEY & ASSOCIATES, LTD.
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knowledge of seals.
Here are 39 design parameters for 2
different seals.
Electrical seals depending whether it'is 3
fire, air, hydrostatic pressure, tornado pressures, et 4
cetera, tell you what materials or combination of materials 5
must be used, and here are the test reports that support 6
that information.
These inexperienced people don't know 7
this and don't understand it.
8 Here is mechanical penetrations, all the 9
different -- here, as long as there isn't major movement, 10 you can use silicone foam, but the minute there is thermal 11 movement or high pressures, you have to go to flexible 12 boots.
If there is radiation, you have to go to the higher 13 density materials.
If there is movement, you have to use a 14 bond with the higher density materials.
These are the 15 design parameters that, unless you are in the business, you l
16 don't know.
17 What you are pursuing right now I was very, very 18 interested in because I have no problems with silicone foam.
19 We have had no problems with silicone foam.
The problem is 20 the people who are using it and the lack of understanding by 21 the utilities, by many of the design engineers, and my 22 disappointment that the NRC didn't listen to me 14 years ago 23 when I was trying to tell them this was going to happen.
I 24 That is the problem with the industry right now.
25 Utilities, after they go into -- our feet are held
't
)
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1 to the fire when we are constructing these plants by ANI, 2
NRC, whomever.
After they are turned over into operationi 3
that is when the whole damned thing falls apart.
ANI has no 4
further involvement, and they usually hire either a general 5
maintenance contractor or a local contractor in'their user 6
district -- they try to always use people in their user 7
district -- to maintain the fire seals who doesn't know a j
8 damn thing about it.
9 Davis Besse some years ago was some disaster 10 because of that and we were brought back in to correct it 11 all, but that continues to exist in the business and it is l
l 12 prevalent out there of people who don't understand this.
l 13 BY MR. PAUL:
14 0
What type of maintenance is required on the seals?
l 15 A
They are constantly pulling cables, punching new l
16 pipes or conduits through, or somebody swings a scaffolding 17 support and cuts a flexible boot or gouges the material out.
18 There are utilities that will repair silicone foam with 19 other materials for which there is no supporting fire test 20 usually.
It is unfortunate.
j 21 Part of what is driving it is, utilities trying to 22 save money.
They thinking bringing in a contractor like 23 ourselves is going to cost them a lot of money.
We have 24 been at Susquehanna I think 12 years now.
I think it is the l
25 smartest utility in the business.
When we finished the 1
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plant, they had us stay to do the maintenance and 2
modification work, and working together set up a program 3
that interfaces with all other contractors.
4 A lot of utilities don't kno,w when a seal is
~
5 violated.
I have walked through plants and seen holes all 6
over the place.
But at Susquehanna, there is a form an 7
electrician fills out when he is going to pull'the cables, 8
. violate a seal, it comes to our project manager, whether it i
9 is a pipe or whether damage has been done, whatever it is.
10 I have tried to sell this concept to other utilities, that 11 looks like a waste of money, that is foolish, it is cheaper l
12 than hell.
It is very cheap.
But, unfortunately, some of 13 these utilities have had some bad experiences with other 14 companies.
15 I think there are some major, major problems out 16 there in my own opinion, but we have been unable to bring it 17 to the attention of anyone who would really take action.
i 18 O
The major problems being the repairs, et cetera, those are 19 performed by the utilities that you elaborated on, 20 the major problems?
21 A
And contractors doing the work and putting in new L
22 seals, too, because they modify plants.
I 23 BY MR. ULIE:
24 Q
Untrained contractors?
25 A
Untrained contractors.
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BY MR. PAUL:
2 O
. Would this, the WP2 thing, be an example of that?
1 3
A Bechtel.
4 Q
With Bechtel performing the work without~the 5
proper experience?
6 A
Sure.
I will tell you an interesting story.
7 Lance Sims was at Diablo Canyon for us when we were 8
installing high pressure seals.
We were hired only to 9
install high pressure seals in certain areas.
It wasn't a j
10 big contract.
Our quality control inspector observed a man 11 installing cilicone foam seals, and he watched them, and 12 most of them were pipe mechanical penetrations.
The fellow 13 would fill the wall with silicone foam.
It didn't matter if 14 the wall was three feet thick, he filled it with silicone 15
-foam.
But on one occasion he saw him do it in an eight-16 inch block wall, and he went over to the fellow and he said, j
17 where is the technology that supports that seal because you l
18 can't put silicone foam in an eight-inch block wall and get l
19 a three-hour fire rating?
He showed him a picture in a Dow 20 catalogue that shows the wall filled with silicone foam.
al That was our promotional brochure.
It had nothing to do 22 with technology.
33 So Lance called me and said that our inspector 24 found this was something he had to report, what should we J
as do?
I said, we never interfere with the conscience of one i
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of our people who wants to report whatever.
He reported it 2
to the client.
The work was being done by Bechtel, and they 3
called our Lance in with Bechtel people, supervision, there, l
4 and chewed him out royally and threw us off the job.
5 Later the NRC was brought into it.
What 6
transpired, we don't know, but we were given a letter of 7
some sort that the matter had been resolved, period.
8 Now I am not saying that we don't continue to 9
support or that BISCO didn't always support the concept of 10 reporting things like this, but that is what happens to you i
11 when you report things.
Lance was told to be off the job 12 that day at the end of work, all of us were to pull our 13 stuff out and be gone.
14 But they were using a picture out of a catalogue, 15 not even a picture out of a test report, that you are is supposed to fill the wall with silicone foam.
All right, 17 now you do that with an electrical seal, you so insulate the 18 cables, you derate the cables, you cause the temperatures to 19 rise.
But there are a lot of cases out there like this.
l l
20 Q
BISCO performed a capacity a derating test on the l
al material, things like that?
t l
22 A
Yes, we have.
We have four or five capacity 23 tests, not only on ours but others.
Dow conducted the most l
24 comprehensive many years ago to put the whole issue to bed.
25 They contracted with Westinghouse and let Westinghouse even 4
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' construct it, configure it, et cetera.
The results became 2
documented with IEEE. 3 Q
In regards to the Dow product, you mentioned your 4-experience.at Diablo Canyon.
Did you ever not report any 5
deficiency with the product because of fears of' losing a
- 6.
job, as far as the Dow product was concerned?
7 A
I have lost jobs because of my refusal to do 8
things.
I lost Sharon Harris and I lost Vogel.
Both 9
utilities wanted us to train Daniel to do the work and I 10 said no.
I said, the least I wi,ll do is, it will be my 11 management group, my installers running the machines and my 12 quality control.
Daniel can support that they want to.
13 They wouldn't take it, they wouldn't accept it.
Eventually 14 Vogel got into trouble and called for our help.
They wanted 15 to buy a fire test because a seal was installed that didn't i
16 have a supporting fire test and they found out we had the 17 only one in the country.
So I had long talks with those i-18 people telling them, I warned you about this, you know, and 19 I charged them an arm and a leg for that damned fire test.
j 20 0
would that test have been valid based on l
21 installation technique?
l 22 A
Yes.
I didn't give them procedures, they only l
l 23 wanted the fire test.
i 24 O
So it would have been up to whoever reviewed it to 1
25 determine if they used the same installation techniques as i
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1-BISCO did?
2 A
Absolutely.
]
3 Q
You are saying, based on your previous 4
conversation, the installation techniques, a critical 5
factor, is where this test is r'epresentative of'this 6'
installed configuration; am I understanding you right on 7
that?
8 A
That's right.
ANI's policy was that the 9
procedures you wrote in constructing a prototype test became i
10 the construction procedures.
I think their words were 11 variations or something will not be tolerated.
ANI do a 12 tremendous job.
When they stepped out of the picture, they 13 left a big void.
They really policed them.
Even they 1
14 weren't able to control them all, but they were a real good 1
15 organization for policing the business, and they gave a 16 tremendous knowledge of what worked or didn't work with 8
17 silicone foam and naturally other materials, I am sure.
'18 Q
I am a little concerned now, has BISCO sold a 19 number of these tests, is this fairly common,'the situation 20 you mentioned with Vogel, have you done that often, selling 21
.the tests, or could you identify to us in the future on what 22 tests you sold to which utilities that BISCO didn't install?
23 A
No, it is not a big thing with us.
Maybe for 24 selfish reasons, as contractors, that is where we aren't 25 engineering, we are contractors.
We try to convince the ANN RILEY & ASSOCIATES, LTD.
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46 1
client or whoever is requesting it the importance of 2
installing it ourselves, being the installer.
For whatever 3
their reasons are, certain utilities say no, we only want 4
.the information or we only want to buy the material.
We 5
sell a lot of materials to utilities, and who is putting it 6
in, I haven't the faintest idea, and we certify it because 7
we have a QA program that certifies the material.
The 8
selling of tests has not been a big thing.
i 9
O So in addition to also -- you act as a wholesaler 10 for the Dow Corning material, say, to Bechtel?
11 A
Yes, recently.
Yes.
Recently.
The brings up a 12 very interesting issue, as the nuclear industry came down 13 and business dropped off, Dow Corning decided they would --
14 to utilize their manufacturing facility, decided to package 15 the material for the commercial market, and they came out 16 with what is known as fire stop foam.
Unfortunately, their 17 promotional literature referred to it as 3-6548, as being 3-18 6548, but they wouldn't certify it, there is no 19 traceability, nothing.
i i
20 So some utilities started buying it because it was 21 cheaper because Dow didn't have to control it the way they 22 controlled 3-6548.
They didn't have to provide paperwork, 23 traceability, any of those things.
That material has been 24 used in some plants and some contractors have bought it who 25 are doing work in plants.
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1 I raised a lot of hell with Dow about it when we i
2 started to find this stuff surfacing in places, and as of' l
3 the first of this year -- also, as part and parcel of this, 4
6548 was a'vailable to Dow commercial distributors in smaller 5
containers, and we buy the big 55-gallon-drums because there i
6 were commercial uses for 6548 even before they created fire
{
7 stop foam.
We found some uti3ities were dumb enough to buy l
8 it from commercial distributcrs at a much higher price than 9
what they could buy it from us because it was in their user 10' district.
Why that is so important, I don't know, and they 11 were buying material without any traceability.
12 I raised lots of hell with Dow about this.
First 13 of all, those commercial distributors are not supposed to 14 sell to utilities by your own agreements with them, only 15 power applicators got it.
As of the first of this year, Dow 1
16 finally closed that door completely.
In their own words, l
17 6548 is no longer available for utilities from -- well, it 18 is no longer available under that nomenclature from anyone 19 other than power applicators.
They closed the door.
The 20 turned the fire stop foam over to 3M.
They formed a 21 marketing, joint marketing arrangement with them, and 3M is 22 going to market the fire stop foam, according to their 23 agreement, for commercial purposes only, but you are going l
l 24 to find people using it in nuclear plants because they are 25 going to go through this whole commercial dedication 4
1 j
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1 business which is a big mistake.
\\
2 Q
Was it common for the utilities that imposed 3
Appendix B, the Quality Assurance Requirements, and Part 21 4
on you when you obtained the contracts?
5 A
Absolutely, every contract.
~
O And those --
1 6
7 A
Every contract.
l 8
0 So now I think what you are saying is, they are 9
dedicating the commercial Dow Corning as a nuclear product, 10 upgrading or whatever they do?
11 A
And Dow has asked us and others, if they identify 1
12 any breaches of this that we are to notify t, hem and they 13 will take action because Dow understands the difference.
14 How their products are being used, they can't control, and 15 rather than some of these unauthorized installers coming to 16 a power applicator contractor to buy the material or a 17 utility who is doing it themselves, they are going to i
I 18 commercial distributors trying to buy it.
It is not even 19 available to the commercial distributors any more.
i 20 That is why I say, our feet were held to the fire 21 when we constructed these plants, but after they went into 22 operation everything all went to hell.
l 23 O
By that you mean maintenance by untrained people 24 and where you went into detail and explained further?
25 A
I once asked ANI, aren't they policing the t
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1 maintenance, and they said, no, it is not our responsibility 2
after the plant is constructed.
They don't even get 3
cooperation from the utilities to do it.
4 MR. PAUL:
I don't have anything further.
i 5
BY MR. ULIE:
6 Q
Did you want to add anything else?
7 A
I will probably think about it tonight.
8 0
Not at this time?
9 A
No, I can't think of anything.
I think I have 10 painted the picture.
11 0
You certainly did.
l 12 A
The reason I wanted to be here is, I have been 13 trying to bring this subject up for 14 years.
There is 14 nothing wrong with the material, there really isn't, or we 15 wouldn't be using it.
Every manufacturer in the world that 16 came up with a new fire stop material brought it to us 17 first, whether from Germany or GE or whatever the case was, i
18 and we did work on it.
We did our own investigations into 19 it, and we found nothing that could do the job like silicone j
20 foam, that had the flexibility and all the other features of 21 it.
32 But maybe, as a parting shot, I think some years l
l 23 back the NRC retained Sandia to run some fire testing and l
l l
24 they wanted to fire test under positive pressure in the 25 furnace.
I want to say the NRC paid a lot of money.
I 4
- l
}
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50 I
wanted to say $500,000, but I may be wrong, and a big report 2
came out of Sandia and I got a copy of it.
I sent off a 3
scathing letter to Sandia and the NRC about it because this 4
test was run to represent the situation of fire seals in 5
nuclear plants." They used GE* foam that nobody 'ever used.
6 It had different characteristics, different densities.
That 7
material shrank and cracked because Dow had the patent.
GE 8
got as close to it-as they could and didn't come out with a 9
good product, and here this whole thing was tested not even 10 knowing what was used in the indnatry.
But I got an answer 11 back from Sandia saying, well, we accomplished the results 12 we were trying for.
But I never saw anything with that l
13 report again.
j 14 BY MR. PAUL:
l l
15 O
What year timeframe was that?
I 16 A
Early '80s.
At one time the NRC was talking about l
17 positive pressure in the furnaces for fire tests, but it met l
18
'with a lot of opposition.
In fact, most places couldn't do l
19 it and meet ETA standards.
20 BY MR. ULIE:
i i
21 O
In your overseas projects, do they require that?
i 22 I understand it is part of a European type fire testing.
23 A
No.
Europe is shutdown.
They are in a moratorium 24 because of Chernobyl.
We were just entering the market over 25 there in Italy when that occurred.
Our activity is 4
i 1
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1 primarily Asia, Japan, Korea, Taiwan, and the minute you l
2 fellows up out a notice or information on anything, they i
3 have it.
It has been a running battle trying to correct 4
some of the things said in these 1,nformation notices.
Like
. i 1
5 one of.them closed saying that silicone foam was suspect, or 6
something, and I had gotten some nice cooperation out of the l
7 NRC in Washington with corrective letters, but this thing l
8 hits the fan worldwide, and I have to say that in Asia they
\\
\\
9 follow NRC and American technology to the letter, very 10 closely.
11 Q
If the NRC staff wishes to follow up any of these 12 issues that you have raised today, you can be reached at i
13 this Addison address or phone number on your business card?
14 A
Or my home, I am usually at home.
15 MR. ULIE:
Do you have anything else, Rich?
16 MR. PAUL:
No.
J l
i 17 BY MR. ULIE:
18 O
Mr. Brown, have I or any other NRC representative 19 here threatened you in any manner or offered you any rewards 20 in return for this statement?
21 A
No, but I thought I would get doughnuts and l
22 coffee.
23 0
Have you given this statement freely and 24 voluntarily?
25 A
Yes.
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52 1
Q Is there anything further you would care to add l
2-for the record?
3-A, Not that I can recall at this time.
~
4~
MR. ULIE:
Then this interview is concluded.
5*
Thank you.
(whereupon, at 11:10 a.m.,
the interview was 6:
7 concluded.)
8 9
10 11 12 l
- 13 14 i
15 l
16 17-l 18 l
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'24 35 l
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53 4
REPORTER'S CERTIFICATE This is to certify thit the attached' proceed-ings before the United Statis Nuclear Regulatory Commission in the matter of:
HAME OF PROCEEDING:
Interview of Brown DOCKET NUMBER:
PLACE OF PROCEEDING: Lisle, IL
~
were held as herein appears, and that this is the original transcript thereof for the file of the United States Nuclear Regulatory Commission taken by me and thereafter reduced to typewriting by me or under the direction of the court report-ing company, and that the transcript is a true and accurate record of the foregoing proceedings.
/ A fL A
e2 ik,/
Official Reporter Ann Riley & Associates, Ltd.
~
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EXHIBIT 6 4
)
- ASE NO.
3-94-068
,1,1,1,,
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.. ~
e g7M-M.c2554 1 voa hvoenAT1m c4 FIRE TEST CONFIGURATION FOR -
BISCO THREE HOUR RATED SEAL SYSTEM BISCO TEST REPORT NUMBER 748-32 UTILIZING
- 1 - BISCO SF-150L
- 2 - BISCO SF-100
- 3 - BISCO SE-Foam
- 4 - Kaowool "M" Board and Quelpyre 703 FS
- 5 - BISCO Boot and Sleeve Extension TEST DATE
. APRIL 15, 1980 BECHTEC D
$[h b
OCT 209
'L A. H. Zima Test Director 10B.NO.12501
~
3: 94- 06
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C@@dgDCQ0@@
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%Ch2@[@gl3 a 4b@G@Q@GD@9
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80meien of the PORTLAND CEMENT ASSOCIATION l
i l
. April 21, 1980 j
A. H. Zima Test Director Bisco Brand Industrial Services, Inc.
- i 1420 Renaissance Drive l
Park Ridge, Illinois 60068
Dear Mr. Zima:
i I have reviewed'the report ent'itled, " Fire Test Configura-
{
r tion for Bisco Three-Hour Rated Seal System - Bisco Test i
Report Number 748-32."
The test was conducted on April 15, 1980, in the Fire Research Laboratory, Construction Tech-nology Laboratories, of the Portland Cement Association.
l l
The report accurately describes details of specimen fabri-i cation,. test procedures, observations during test, and test results.
Sincerely yours,
& & J.ca % w Director
~~
Fire Research Department Melvin S. Abrams rk Copy to-W. G. Corley Central Files CR-CR-4601 i
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E 110. 3-94-068 EIBIBIT 13
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