ML20196H594
| ML20196H594 | |
| Person / Time | |
|---|---|
| Issue date: | 08/18/1994 |
| From: | NRC OFFICE OF INVESTIGATIONS (OI) |
| To: | |
| Shared Package | |
| ML20150F728 | List:
|
| References | |
| FOIA-97-180 NUDOCS 9707300268 | |
| Download: ML20196H594 (57) | |
Text
-
ORGL\\'AL i
OFFICIAL TRANSCRIPT OF PROCEEDINGS l
1 Agency:
Nuclear Regulatory Commission Investigative Interview of
Title:
- a. Lance simms (cLosEo) i Docket No.
l LOCATION:
Lisle, Illinois DATE:
Thursday, Augus t 18, 1994 PAGES: 1 - 44 i
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(202) 842 0034 EXHIBIT 9707300268 970724 PDR FOIA PAGE l OF Nb PAGE(S)
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1 UNITED STATES OF AMERICA 2
NUCLEAR REGULATORY COMMISSION 3
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-- - - - - - - - - - - - - - -x 1
l 5
In the Matter of:
6 Investigative Interview of 7
J. LANCE SIMMS (CLOSED) 8 1
. _ _. _ _x i
l 9
10 Nuclear Regulatory Commission l
11 Region III Headquarters l
12 801 Warrenville Road 1
13 Suite 255 14 Lisle, Illinois 60532-4351 l
15 Thursday, August 18, 1994 16 17 The above-entitled interview commenced at 9:58 18 a.m.,
pursuant to notice.
l 19 20 21 l
1 22-l l
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APPEARANCES:
2 f
3 RICHARD C.
PAUL, Investigator i
4 Nuclear Regulatory Commission 5
JOSEPH M. ULIE, Investigator
'6 Nuclear Regulatory Commission 7
i 8
ROSLYN BURBANK, ESQUIRE, Attorney for Interviewee 9
Senior Counsel 10 Rust Industrial Service 11~
12 l
13 i
1 14 l
15 16 I
J 17 18 19 20 21 22 l
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24 j
25 ANN RILEY & ASSOCIATES, LTD.
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P R O C E E D I N G S' 2
[9:58 a.m.]
3 MR. PAUL:
For the record, this is an interview of 4
J. Lance Simms.
Last name is spelled S-i-m-m-s, who is a 5
manager with the Brand Fire Protection Servic'es, Inc.,
6 located in Addison, Illinois.
The location of this 7
interview is the Region III NRC offices in Lisle, Illinois.
8 Present at this interview in addition to Mr. Simms 9
are Richard C.
- Paul, P-a-u-1, and Joseph M. Ulie, U-1-i-e, 10 Investigators with the U.S. Nuclear Regulatory Commission, 11 Office of Investigation.
12 Additionally, Mr. Simms is represented by Roslyn -
13 MS. BURBANK:
Burbank.
14 MR. PAUL:
B-u-r-b-a-n-k?
15 MS. BURBANK:
Yes.
16 MR. PAUL:
And you're with who?
17 MS. BURBANK:
Rust Industrial Services.
I'm 18 Senior Counsel.
19 MR. PAUL:
Okay.
It's agreed this interview is 20 being transcribed by Court Reporter, Ronald N.
LeGrand, Jr.
t 21 The subject matter of this. interview concerns the 22 Dow Corning Silicon RTV Foam.
It's identified by the number 23 3-6548.
24 Mr. Simms, please stand and raise your right hand.
25 Whereupon, j
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4 F
1 J.
LANCE SIMMS 2
was called for Interview and,'having been first duly sworn, 3
was examined and testifi,ed as follows:
4 MR. PAUL:
Please be seated.
5 EXAMINATION 6
BY MR. PAUL:
7 0
Mr. Simms, as a little background, could you 8
please tell us -- could you identify the company you work 9
for and what the relationship is with Rust International.
10 I believe that the company uses -- has used in the 11 past the acronym BISCO.
12 Could you just give us a little corporate identity 13 of your company?
14 A
In 1980, I was hired by Brand Industrial Services, 15 Inc., commonly known as BISCO.
I was hired on as a field 16 engineer at the San Onofre nuclear generating station.
17 In the late eighties, approximately 1988, Brand 18 Industrial Services was acquired by a division of Waste 19 Management, Incorporated.
It was actually Chemical Waste.
20 Management that purchased us.
They purchased all of the 21 Brand companies.
{
22 We were headquartered in Park Ridge, Illinois at 1
23 that time.
Since the acquisition, we moved to Westchester, 24 Illinois, where all of the Brand companies were l
25 headquartered.
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They were -- approximately two years ago another 2
reorganization took place where the Brand companies, Wheeler 3
Brader Technologies, SEC Donahue -- anybody else?
4 MS. BURBANK:
Net that I can think of.
5 THE INTERVIEWEE:
There were -- and' Rust 6
International out of Birmingham, Alabama.
They put all 7
those companies together to create the new Rust Company.
8
.There are six separate divisions of that.
9 We are operating under Rust Industrial Services.
10 We retained our name.
Our name is changed from BISCO to 11 Brand Utility Services to today's name of Brand Fire 12 Protection Services.
13 During this time, we've conducted fire tests with 14 this product in question, with the Dow Corning 3-6548.
And 15 all of those records are in my office right now.
16 BY MR, PAUL:
17 Q
In regards to the nuclear power. industry, you 18 briefly mentioned that you came to work in 1980 for Brand.
i 19 We'll identify it as Brand, even though it may be-20
- it's gone through so many name changes.
21 Is that all right?
22 A
That's fine.
23 MR. PAUL:
Let's stop one minute here.
I just 24 want to make it clear for the record.
l 25 Mr. Simms, you are appearing here under response ANN RILEY & ASSOCIATES, LTD.
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1 to a subpoena issued by the NRC; is that correct?
I 2'
MS. BURBANK:
Yes.
-3
.Yes.
4' BY MR. PAUL:
.5 y
Just then going back to will you id'entify your i
6 exper'ience.and what type experience you've had in regards to i
7' the nuclear power industry?
I 8
A As I! mentioned, I began working at the San Onofre
.9 nuclear generating station in 1980.
I began as lead 1
10 engineer for the Unit II completion of construction; and i
11 then for the Unit III completion of the-installation of i
12 penetration seals I was project manager.
13 From there, I moved to Clinton, Illinois station, r
14 involved in installing penetration seals.
j 15 And then, in 1553 -- no, 1984 -- I moved to the r
16 Park Ridge corporate. offices,- where I was brought on board
)
17 as. contracts manager.
We were doing quite a lot of business j
i 18 at that. time, approximately $25 million a year in-1 11 9 installation of penetration seals.
20 During the next several years, the business grew h
i 21 to a high of $57 million a year installing penetration j
22 seals.
I f.
23 I became then the engineering manager and oversaw 24 the engineering take place.
My typical duties would entail 25-reviewing design. specifications for plants during the bid ANN RILEY & ASSOCIATES, LTD.
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stage, and then assembling the documentation package 2
necessary to justify the installation of our designs.
3 I've continued doing that up until today.
- But, i
4 the number of bid proposals is very, very small.
A lot of l
5 my time is spent in just answering phene questions from 6
utilities calling with penetration seal questions, and 7
sending them up updated test reports, or things like that.
8 Q
In regards to Dow Corning 3-6548 silicon RTV foam, 9
does your company use that product?
10 A
Yes, we do.
11 Q
And in what application?
12 A
As a penetration seal fire barrier.
Typically, if
{
13 there's a hole in the wall or hole in the floor, this 14 product can be used to seal it.
15 We have called that product SF-20, being the brand I
16 designation for the identical product.
To give you some 17 history, the 3-6548 was developed in the 1970s.
- And, 18 initially, Brand and Dow Corning developed the silicon foam.
19 And it was a four-part foam.
20 Dow Corning's lawyers got to the patent office 21 before we did, and we paid them a royalty for using this 22 product for 17 years.
i 23 The four-part foam, Dow Corning in the late 1
24 seventies informed us that they were not going to supply two 25 of the components..
So they basically forced us to buy this J
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silicon foam, the 3-6548.
2 So we began a testing program to qualify that 3
design to be used in nuclear power stations.
4 BY MR. ULIE:
5 Q
And that was a two-part product?
An F29 6
A That was a two-part product.
That's a continued 7
product that we've used.
That same designation has been 8
used all along.
9 BY MR. PAUL:
10 Q
The two-part product has the 3-C548 product as 11 opposed the four-part had a different identifier?
12 A
Yes, tota 31y different.
13 BY MR. ULIE:
14 Q
So, for purposes of this interview, we'll be 15 referring to the Dow Corning 3-6548 silicon RTV foam as just 16 silicon foam.
17 A
Yes.
18 Q
Okay.
So we understand there's other silicon 19 foams and we want to focus in on this one particular foam.
20 Okay.
21 BY MR. PAUL:
22 Q
In your experience in 1980 at San Onofre, were 23 they using that particular foam?
i 24 A
Yes, they were.
This foam was used in San Onofre.
25 Q
Did you have any infield experience with the l
l i
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application of the foam?
2 Or was yours more of an office review?
What was 3
your experience with the foam?
4 A
Well, I would write the paperwork that would J
5 direct the people on what design to install.
It's called an 6
IWR, internal work release, which would direct the people 7
what design to put-in what hole.
8 I was in charge of the field survey where we'd 9
send our personnel out in the field.
They would survey the 10 penetrations, find the location, identification of what it 11 is, and then number of the item.
12 We would then come back and say, okay, item one, l
13 two, _three, four, five, we're going to install this design l
14 in that.
15 And we'd put the paperwork package together to 16 give to the production personnel, who would then install it, 17 and the quality assurance personnel, who would monitor the 18 installation.
19 0
But, did you receive feedback from all these 20 people as to the progress of the actual infield application 21 of the product?
j 22 A
Yes.
Out at San Onofre, there was a -- I want to 4
23 call it the discovery of the phenomenon of etch curl.
The l
l 24 blockouts at San Onofre were quite unique in the industry.
l 25 The four blockouts were over 50 square feet --
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1 Q
Could you identify for the record what a blockout 2
is?
i 3
A A blockout opening is when you're building a l
4 nuclear power plant, these walls are typically several feet 5
thick of reinforced concrete.
The floor slabs could be from i
l 6
six to 12 inches thick of reinforced concrete.
7 And where a hole is where you're going to run a 8
commodity through, be it a pipe or a cable tray or a f
9 conduit, when they're casting the concrete, they would put a 10 blockout in there.
11 Typically, a plywood box that would prevent the 12 concrete from filling up this area.
13 So, when the concrete cured, you would remove the 14 blockout box, and you~would end up with just an opening, a 15 void into which the penetration seal would subsequently be 16 installed.
17 Q
And going to finish your answer --
18 A
Okay.
The large blockout openings at San Onofre, 19 when we identified them being so large, they were beyond the i
20 scope of our in-house testing at that time.
21 We tested several different configurations that 22 failed to pass -- these were two-hour rated floors -- to i
23 pass a two-hour ASTM E-119 fire and hose stream exposure.
24 We subsequently came up with a design that 25 consisted of a one and a half inch ceramic board with a six-ANN RILEY & ASSOCIATES, LTD.
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inch depth of RTV 3-6548 silicon foam on top of it.
1-2 And there was eight inches of foam in the actual l
l 3
cable trays.
So the cable trays were compartmentalized 4
separately, and then the large 50 square foot area of 5
unsupported silicon foam just had six inches of foam in it.
6 So we successfully fire-tested that design, and 7
that's what we installed.
8 But what physically occurred in the plant is after j
9 we installed it, sometime later, the foam had a phenomenon I
10 called edge-curl where around the perimeter of the opening, 11 the foam peeled back a little bit.
And it had a little gap 12 around the perimeter.
13 That gap was not qualified in our fire-testing at 14 that time.
So the ::epair was to go through again, trim out 15 these perimeters and install some new silicon foam that 16 sealed that gap.
17 And I believe that we did that retrofit to all the 18 floor blockouts at San Onofre.
19 Q
Now, these were floor blockouts?
20 A
Those were floor blockouts.
21 Q
The 50-foot ones?
22 A
Yes.
23 O
Was a design -- did you put a lattice work within 24 the seal, or the blockout to make the hole smaller, so that 25 you wouldn't have just 50 foot of foam?
You'd l
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1 compartmentalize the area by a certain dimension.
2 Do you understand what I'm --
l 3
A Yes.
I don't know if we compartmentalized the 4
floors or not.
I think we tested the largest floor blockout 5
so that the 50 square foot was qualified.
And I think that i
6 was the largest that the floors weren't compartmentalized, 1
7 based on my memory.
B Q
Did Brand do the qualification testing, or was 9
that contracted out somewhere else?
10 A
That was -- the test was conducted at Instruction 11 Technologies Laboratories in Skokie, Illinois.
12-Q And who supervised the qualification test?
13 A
That -- Russ Hall would probably have been the 14 person that physically ran the test.
He was hired then.
15 Q
From CTL?
16 A
From CTL.
But, typically, we would go over there.
17 They would supply the slab.
We would write a test procedure 18 that would tell personnel how to construct the seal.
19 You'd use that procedure to build the seal on the 20 floor of the test lab.
And then, when it was done, they 21 would burn -- burn the specimen.
22 O
And who wrote the test report?
23 A
In some cases, CTL did.
In some cases, we did.
24-Q So you were the sponsor for the test?
Or. was the 25 utility, or was Dow Corning?
{
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1 Do you recall?
2 A
I don't recall the specifics.
We've had instances 3
where all three have taken place.
i 4
Typically, what we would do is we would attempt to 5
get the utility to pay for the test, and then~have them come 6
and witness the test.
And so they would pay for our labor 7
to construct the specimen.
They would buy the materials.
8 They would pay for the -- pay the invoice to the test lab l
9 for conducting the test.
10 Q
Did you rely on Dow Corning to provide any 11 specific qualification test for you to use at San Onofre?
12 A
Offhand, I can't recall.
We've used some of the 13 Dow Corning tests in the past.
I do have some of them in my 14 library.
But, Dow Corning has told us that they prefer us 15 not to use their tests for the qualification, and that we 16 were to use our own testing to qualify the designs.
17 BY MR. ULIE:
18 Q
Did they provide an explanation as to why that was 19 the case?
20 A
I think they wanted to limit their liability.
But 21 there's some cases that we have submitted Dow Corning tests 22 to justify certain applications.
23' O
The six-inch application or configuration that you 24 mentioned earlier that was qualified, what was the fire 25 rating, for what period of time?
i l
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1 A
That was a two-hour rating.
2 O
About a two-hour rating.
3 A
Yes.
4 BY MR PAUL:
5 Q
Did that have damming on it?
6 A
Yes, it did.
Left in place damming of inch and a 7
half board held in place with Unistrut.
The Unistrut was on 8
the inside, so it was the cap slated by the silicon foam.
9-Q Was it dammed on both sides, or one side?
10 A
No, just the bottom side.
11 BY MR. ULIE:
12 Q
Are you aware of a nine-inch fire barrier that did I
13 not use damming that was successfully qualified using the 14 ASTM E-119 --
15 A
Yes.
16 Q
-- conditions of acceptance?
17 Could you identify that by report number, or in 18 some other manner?
19 A
off the top of my head, no.
We do have some tests 20 of successful designs with the nine inches of silicon foam.
21 Q
Okay.
And would this test report be on file with 22 the Brand Fire Protection Services?
23 A
Yes.
24 BY MR. PAUL:
25 0
Okay, just to put a couple of things in focus l
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where we're going here, I'll ask you if you're familiar with 2
on August 4th of 1988, the NRC ever issued an information 3
notice 88-56, potential problems with silicon foam fire 4
barrier penetration seals.
5 And it concerned experience from
'8'6 and '87 of 6
B&B Promatech in regards to certain conditions and 7
deficiencies found with the use of silicon foam.
8 I have a copy here.
9 A
I'm familiar with the document, yes.
10 Q
Okay.
It identifies certain deficiencies, and 11 whether they identify them as nonconforming conditions--
12 void, shrinkage and lack of fill.
13 Are you familiar with that general statement that 14 you've --
15 A
Uh-huh.
16 0
-- that you've read this and are familiar with 17 what they're talking about here?
18 A
Yes, I have.
19 0
Okay.
In regards to your experience with the 20 product, did you ever cbserve the conditions while 21 installing seals using the Dow Corning foam?
22 A
Yes.
23 Q
And could you just tell us what experiences Brand 24 has had with them?
25 A
Well, the notice you're talking about refers to a j
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I site where it was -- the seal was analogous to an Oriole 2
cookie.
You've got a damming board, a fill and then a 3
damming board.
4 And so, in a wall configuration, the installation 5
technique used was to put the damming board in place with a 6
hole in the top of it -- maybe you'd put the first one in.
7 You'd work from one side.
You'd slide one in to the 8
required depth.
9 And then the second one, on the face of the seal, i
10 would be the one you're going to install from.
And that i
11 would have a hole on the top of it.
12 The installation technician would then stick the 13 hose in from the foam machine and pull the trigger.
And if 14 any foam came out the hole, he assumed it was filled.
And 15 then he'd walk away from it.
16 The -- I think that this information notice missed 17 their mark.
This is an installation problem.
It isn't a 18 foam problem.
19 The -- I've spoken with technicians who physically 20 did the work out there.
And they -- Homatech did not have a 21 100 percent inspection program at the time.
They had an 22 approximate 10 percent inspection program.
23 So, the people signing this off would have been l
24 the technician; whereas, Brand has always had a 100 percent 25 inspection where, when we installed something, a second ANN RILEY & ASSOCIATES, LTD.
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person came and looked at it.
2 We've had personal experience with a design like 3
this at the Limmerick generating station where Bechtel Power 4
asked us to install a design that had board in place on both l
5 sides.
This was a Bechtel fire test.
It was'not a Brand 6
fire test.
7 But they directed us to install this configuration 8
using this silicon foam.
I believe it was 12 inches in 9
depth, with aluminum cable trays present.
i 10 So, we put this -- these seals in and were called 11 back under the warranty provisions -- it cost us $100,000 to 1
12 fix these right.
We discovered -- or they disccvered after 13 they removed the board that there was an incomplete fill.
14 So it's an installation problem here that you have i
15 to visually look at the silicon foam to see that it's 16 actually filling completely.
17 The characteristic of the foam as it goes in in a 18 liquid state, in approximately four minutes, it has arisen 19 up to a mountain / valley configuration.
It doesn't just rise 20 like water.
21 And then, as you pour the next layer in, you can 22 sometime run into an obstruction as you're coming up to a 23 cable tray or something.
That obstruction becomes a dam and t
24 prevents the liquid from flowing to the opposite side.
25
.And then you just end up with some voids as part 4
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of the installation.
And I believe those are the types of 2
voids and problems that were discovered out at Wolf Creek.
3 BY MR. ULIE:
4 0
After a final installation, after it solidified, 5
what was BISCO's recommendation as far as final inspection?
6 Were the dams removed?
7 A
What we see now is that four penetrations where 8
you have a left in place to hand in place, you can view the 9
installation of the foam as you're going up.
10 So you get to see that you're getting complete 11 encapsulation.
And you just bring it up to the minimum 12 required thickness.
And then that continuous inspection is 13 assurance that the floor is adequately sealed.
14 In walls, we allow the installation of a permanent i
15 dam on the back side and installation of temporary dam up 1
16 front, so you're at least viewing the front side and the top l
17 as you stage this penetration.
So you're ensuring that 1
l 18 you're getting full encapsulation as you install the 19 product.
i 20 Without it, it's a guess.
In our experience, it 21 is that you have no guaranty unless you've pulled off one of 22 the dams that you had complete encapsulation.
23 And that's why we use the temporary damming, so 24 that we can view the product going in.
i 25 Q
And is the final configuration then with the one J
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dam in place on a wall configuration, is that truly 2
representative then of what the test report would reflect?
3 A
Can you run that by me again, please?
4 0.
I'm just trying to compare the as built 5
installation after you walk away from it and after your 6
final inspection and saying you believe that's an acceptable 1
7 seal that's in place at a particular plant.
1 8
When it's in its final installation -- and if I 9
understand correctly, on a wall configuration, there'd be 10 one damming board, the initial' damming board that's put in 11 place, and then the silicon foam that's filled in afterwards 12
-- th?at's the final installation if we were to look at it 13 visually, cross-section.
14 And what I'm trying to compare is would that be 15 truly representative if we went back and looked at a test 16 report?
Is that how the test was completed?
17 Was there a temporary damming board that was l
18 removed and only one damming board that was left in place?
19 A
Yes.
Our typical detail, if it shows, let's say, 20 nine inches of foam, the test would be just nine inches of 21 foam.
22 We would have removed any damming board.
We have 23 tests that have damming board left in place, and tests that 24 don't.
25 Q
And would this be for three hours or --
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A Yes.
2 O
For three hours?
3 A
For three hours.
4 It's been -- when we became aware of this problem, 5
we developed a second silicon foam, which we 'all SEFOAM.
c 6
We use the 3-6548, and then we put an additive in it to make 7
it more fire-resistant.
8 But it is primarily 3-6548.
In appearance, our 9
product is just a little grayer.
That's really the only 10 difference.
And it's a little denser.
The density range 11 can go up to, let's say, 26 pounds per cubic foot versus a 12 22-pound per cubic foot for comparable density of the 13 straight foam.
14 BY MR. PAUL:
15 0
What year did you institute that change?
16 A
Well, we had the product as far as 1980, but we 17 really started selling it in probably '84 -- is when people 18 started to buy it and install it in the plants.
19 But that one was designed specifically with no 20 board left in place because we knew the problems adherent in 21 installing the designs, that you need to see the foam go in.
22 So we wanted a design that didn't require a board 23 as part of the design.
24 Q
Now, we talked about voids.
There is also a l
25 condition identified with the silicon foam as to gaps and l
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1
- splits, i
l 2
Are you familiar with those terms?
l 3
A Gaps and splits are problems that have come along i
4 over the years.
We haven't pinpointed a root cause to them.
5 It appears as if the temperature differential's might have 6
something to do with it.
l 7
We've heard reports that it's in air-conditioned 8
rooms where these are being discovered more often than not.
9 This product has a -- I want to say a high coefficient of 10 thermal expansion and contraction, meaning for approximately 11 every 20 degree drop in temperature, there could be a 1 12 percent contraction of the material.
13 So that could be causing this.
But, it appears 14 that if we install it during construction and it's 90 15 degrees out, the drop in temperature when it's finally the 16 plant is in service and it's 65 degrees in the room, that i
17 there's a little bit of this shrinkage that potentially 18 could cause these cracks.
19 It appears that once those have been filled, they 20 do not reoccur.
21 BY MR. ULIE:
22 0
one distinction you made, and I'm asking you for 23 clarification if I understood you correctly -- one i
24 difference I understood you to make between the 25 installations that were in place at Wolf Creek that the l
l l
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~
1 information notice v as derived from problems that occurred 2
there, there were damming boards on both sides that were not i
3 removed or inspected; whereas, it's always been BISCO's 4
policy to only allow for left in place dams on one side of 5
the penetration.
6 Is that correct?
i 7
A Yes.
If we were going to use a dam, I mean, a 8
design that had left in place boards, we would put permanent 9
board on one side and temporary on the other so that we 10 would be able to view at least one side of configuration as 11 it was being installed.
12 O
Okay.
And then, subsequent to its installation t
13 after it. solidified, you would remove one of the two sides?
14 A
We would remove the temporary board --
l 15 Q
The temporary damming.
j 16 A
And view the penetration so QC could sign off.
17 MR. ULIE:
Okay.
That's fine.
That answers my 18 question.
19 BY MR. PAUL:
l 20 Q
So as to gaps and splits, just so I understand l
21 what you said, they're more related to the product than the 22 application?
23 I believe you said there were some environmental 24 factors as to the gaps, which is the pulling away the j
l 25 material from the sides?
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A Yes.
2 Q
And they identified a third nonconforming 3
condition of splitting, cracking of solidified material.
4 Have you ever had any experience with that 5
happening on your --
6 A
Cracking would be the case of a larger free area 7
where, instead of the -- I want to call it shrinkage --
8 instead of the edge curl that's going to occur around the
)
9 perimeter, maybe the tension is relieved by a crack that 10 appears in the face of the sealed material.
11 Q
Have you experienced that in your application of 12 the silicon foam, Dow Corning?
13 A
I have heard reports that they're discovering it 14 right now out at the Sussquehanna nuclear station dur. g 15 thei r walk-down.
They're talking with our personnel about 16 tha t., the discovery of that.
17 Q
Did Brand install those?
18 A
Yes, we did.
19 O
Okay.
What I'm trying to see here is I have a Dow 20 Corning memo from November 12, 1984.
It's addressed to All 21 Dow Corning Power Applicators, which I believe Brand is one 22 of those.
23 A
Yes.
24 Q
And at this point, I'd just like to show it + o you 25 and ask you if you ever have seen that particular ANN RILEY & ASSOCIATES, LTD.
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1 memorandum.
2
[ Handing documents. ]
3 The first paragraph is the relevant one.
It 4
applies to the 3-6548.
5 A
Yes.
That's one of those documents'I brought with 6
me today to show you.
I've seen that document.
7 Q
Did Brand receive this document contemporaneous 8
with the date on it in the 1984 time frame?
9 A
Yes.
November 12th.
We received it November-10 19th.
We have a date stamp of when we received it.
11 0
Did you ever have any discussions with Dow Corning 12 as to what changed as far as the formulation?
13 A
Yes, we did.
1 14 Q
And could you tell me who you had the conversation i
15 with and what you recall was said?
16 A
Okay.
Back in that period of time -- I don't 17 recall.
I wasn't a participant in the conversation of Dow
{
a 18 as it was explained to us just then --
l 19 Two weeks ago I called up the person, Takahashi of i
20 Dow Corning who was their technical man at the time and got l
21 his input on what occurred based on this letter.
It is his l
22 recollection that the specific change in formulation, he 23 gave me an analogy of saying there are approximately six l
24 items that go into the formulation of this type of foam.
l i
25 It's a big kettle.
I have seen their mixing l
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process It's a giant kettle.
They've got these overhead 2
lines that are fixed for pumping product into the kettle 3
where they mix it together.
4 And his analogy is that component A maybe is 30 5
percent, component B is 40 percent and component C is 5 6
percent.
And the change that took place was in the 7
tolerance, the allowable tolerance of this 40 percent might 8
have been plus or minus.05 percent and they widened the 9
spectrum to, let's say,
.1 percent plus or minus,
.1.
10 It's his recollection it was one of the minor 11 components, one of the smaller iteme in this formula, not 12 the large ones.
The A, B, C numbers that were always the 13 percentage for the formulation, those never changed.
The 14 only thing that changed was the spectrum of acceptable plus 15 and minuses on this.
16 I took that -- this coincided with Dow Corning was i
17 bringing out a commercial-grade product, fire-stop foam at 18 the same time And it is my assumption that they are 19 loosening the -- those tolerances a bit so they could s' ell a 20 product that's commercial grade and not have to look at it 21 with a microscope each time they ran the vat.
22 BY MR. PAUL:
23 Q
In the memo it references test reports Dow Corning I
24 had.
Did you ever review those test reports?
25 A
Yes, we did.
We received them later.
I have a i
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letter dated January 8, 1984, which I assume they mean 1985.
2 It's the beginning of the year and I think --
3 BY MR. ULIE:
4 Q
A typo.
5 A
-- their secretary made a typo in the beginning of 6
the year.
And it talks about the test -- you know, the 7
first letter is saying we have these test reports.
So the 8
following year, we are requesting -- we requested the tests 9
and here is the letter of transmittal that they gave to us:
10 At the request of your sales representative, I am 11 enclosing two Portland cement association tests.
In order 12 for you to interpret the data, you need to know that the lot 13 numbers represented the old formula and the old formula.
14 So this letter gave us the lot numbers to show the 15 old formula and the new formula and they gave us the test 16 reports that documented -- this was side-by-side testing of 17 the old formula and the new formula.
According to 18 Takahashi, this was blind testing.
He physically installed 19 the configurations at Portland Cement Association but he l
20 didn't know what was the old and what was the new.
He just 21 put the stuff in and recorded the document -- the lot 22 numbers and what areas they went into.
And even these test 23 reports do not reference old formula and new formula.
J 24 If you just read these reports, it's -- you're 25 just looking at 3-6548 foam.
It's the lot numbers with this ANN RILEY & ASSOCIATES, LTD.
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letter that's telling you which is the old formula, which is 2
the new formula.
3 Q
And for these tects did they use the ASTM E-119 4
conditions of acceptance test criteria?
5 A
Yes, they did.
6 O
And can you tell us what those test results were 7
then for each of the old and the new configurations?
8 BY MR. PAUL:
9 Q
Are you going to provide these to us?
10 A
Yes, yes.
I've got a letter of transmittal to 11 give you all these documents.
12 O
Okay, fine.
13 A
Off the top of my head, I don't have -- I can read 14 the test results to you, the concluding remarks, summary 15 results.
16 BY MR. ULIE:
37 0
I was just wondering if you know what -- did they 18 pass the E-119 criteria?
19 A
Yes, they basically passed.
In one test, two of 20 them failed the E119 hose stream, two of the six.
But these 21 tests showed -- and I think one test had an 814 thermal 22 coupling to it.
23 So we accepted these at that time that, hey, the 24 product is the same product.
25 Q
With respect to the two tests that failed the hose ANN RILEY & ASSOCIATES, LTD.
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stream, do you know, was that the new product, new formula 2
change, or was that of the old?
3 A
It was one of each.
I think it was one of the old 4
and what they did, they had one penetration that was old A, 5
old B, and one penetration that was old A, new B.
They 6
broke it up so you could use the new stuff and prove that it 7
would combine with the old and still vulcanize and create 8
silicon foam.
And that's why they used six of the items.
9 Q
The two that failed, can you provide an 10 explanation on why Brand or BISCO accepted those then as 11 being acceptable if they failed the hose stream test?
12 A
The two of the six -- the E-119 hose stream is 3
13 very subjective.
The -- although it specifies what the 14 water pressure is and the distance from the specimen, it's 15 still the operator of moving this thing back and forth in a 16 specific amount of time.
And it's just that one hits the 17 edge and squirts through the edge of the interface of the 1
18 concrete opening in the silicon foam and sometimes it does l
19 and sometimes it doesn't.
i l
t 20 These were 9-inch specimens and four of them did 21 pass and we took that as being, well, that's --
22 Q
All six of these configurations, they were 23 duplicate in every way with the exception of the mixture of 24 the old formula and new formula and new and old formula i
25 combined?
l i
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A No, four of them were I think 10-inch sleeves and 2
two of them were smaller diameter sleeve.
3 0
I see.
So the two that did fail, to the best of 4
your recollection, BISCO didn't go back and retest those 1
5 configurations to get the pass for the hose stream in 6
addition to the fire test?
7 A
No.
8 BY MR. PAUL:
9 Q
In addition to this test, which I haven't seen 10 those, but it. 1985 there was testing I know conducted by 11 Transco for. Mill Stone.
Are you familiar at all with that 12 testing that involves the Dow Corning silicon foam?
13 A
No, not unless it was a Dow Corning test.
Or was 14 it a --
15 O
It was a Transco test for Mill Stone.
16 A
No, I've never seen a test.
17 O
And then in 1985 also, ANI, American Nuclear 18 Insurers, withdrew their certification regarding a BISCO 19 seal or a Brand seal.
Are you familiar with that?
l l
20 A
Yes.
21 Q
And that was based on some testing they had 22 conducted?
23 A
Yes, in conjunction with us.
24 0
You participated in it?
l 25 A
Yes, we did.
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0 It was specific as to the 9-inch seal; is that 2-correct?
3 A
Yes.
4 O
Could you tell us what testing took place and, you 5
know, what precipitated that particular test?'
6 A
The -- this was the time frame when we were 7
beginning to understand the importance of parameters in the 8
qualification of penetrations.
The previous testing had 9
been reviewed and some people thought that it was -- it was 10 missing, in one of the cases, I believe it was the PCA-76 11 test was what the foundation of this -- is that the one 12 that's referenced there?
.3 Q
Here, you can take a look at the document.
14 A
Yes, that's the PCAA, a 1976 fire test.
And the l
l 15 background is that there was no hose stream test attached to 16 that configuration.
The people reviewed the files at that 17 time and determined that there had been a test but nobody 18 had a copy of it.
19 So ANI said, hey, let's run another test.
The 20 test that we conducted with ANI I believe it was two 21 tests -- they were more severe than this 1976 test, meaning 22 the parameters were larger or different than this first 23 test.
And those tests, I believe there were two of them l
24 conducted and they both failed approximately two-and-a-half l
25 hours2.893519e-4 days <br />0.00694 hours <br />4.133598e-5 weeks <br />9.5125e-6 months <br /> and that's at the point that ANI issued their -- their i.
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1 31 1
letter stating that they will accept it for insurance 2
purposes only.
3-0 Do you recall when those tests were run?
4 A
You mentioned 1985 so I take it it's in that time 5
frame.
6 Q
That's what I'm trying to establish.
The letter t
t 7
itself, the notification, I believe they sent a copy to 8
Brand, to Mr. Clay Brown.
9 The letter itself is dated August 20, 1985, but 10
.these forms for the acceptance are dated 1983.
11 A
Okay, those are the American Nuclear Insurers 12 acceptance forms.
During the power plant construction 13 phase, many of the specifications for jobs would include, 14 you know, shall be qualified pursuant to ASTM E-119 or IEEE-15 634 and/or ANI.
So the ANI, their hose streams were 16 different.
They allowed th'e use of a fog-style hose stream
]
17 exposure versus the E-119 hose stream exposure.
So many 18 sites were not requiring that the seals be qualified E-119.
19 you could get by with just an ANI acceptance.
So this form 20 that you're showing me here is an ANI acceptance.
They were 21 valid for a two-year duration and they were issued after ANI 22 reviewed the fire tests and they would write down, saying, 23
.okay, you can use this configuration.
24 And then when ANI, as I told earlier, discovered i
that there was no hose stream test, we attempted to retest 25 l
4 4
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1 the design but it was in a larger configuration and it did 2
not pass the three-hour exposure.
3 Q
Do you believe.it was the performance of the 4
material or what do you attribute -- previously'you had a 5
test that was from 1976 that showed that this'nine-inch seal 6
was qualified.
And then, somewhere, contemporaneous with 7
the latter, there was additional testing, where you just 8
mentioned we're not positive as to the date.
But there, 9
there was this failure that led to the issuance of the 10 letter.
11 A
That would have been in August
.t 12 Q
Of '85?
13 A
Of that year when that testimony was conducted.
14 Q
Based on your knowledge of, you know, the 15 circumstances and review of the test, do you know, was there l
16 any change in the performance of the material, the Dow r
17 Corning foam material?
i 18 A
The -- I believe the root cause is design 1
19 parameters.
And not particular material type.
l 20 Q
Specifically, which design parameter?
21 A
Well, I have been asking that question for quite a 22 while.
And ANI in 1987 issued a listing of design i
23 parameters.
The NRC attempted to issue one in 1987, it was 24 87-XX, but no one would sign it.
And those -- both those 25 documents referenced design parameters.
i d
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Q So your belief is it's the design parameters led 2
to these different results as opposed to the performance of 3
the Dow Corning?
4 A
Correct.
5 Q
Did you notice any difference during installation 6
once Dow changed their formulation in 1984?
Did you have 7
any different experiences with the installation of the foam 8
in your sites?
9 A
We had reports of people complaining. -We brought j
Dow into our facilities to try to duplicate it and they 10 I
11 looked at it and they said, well, it's no different.
And we 12 couldn't duplicate some of the stuff.
l 13 It's a temperamental product; that is, temperature 14 and humidity change the ability to react identically each 15 time.
l 16 BY MR. ULIE:
17 Q
Can you identify what those problems were that j
l 18 were -- that you're mentioning occurred subsequent to the 19 formula modification change that were not brought to your 20 attention or that you weren't aware of prior to this formula 21 modification change?
What were those problems?
22 A
I don't think these problems were a result of the 23 formulation change.
I think that these things that were 24 being discovered were there all along.
And that's when you i
25 talk about a splitting or an edge curl that takes place.
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Q And the voids and lack of fill that are talked 2
about in that information notice, you think that's all --
3 A
I think that's always been a part of it.
4 Q
But Mr. Paul's question was, are you aware of 5
problems that occurred subsequent to the form 61a 6
modification change and so rather than give your opinion 7
that's what you think it is, can you identify though new --
B problems that weren't existing prior to the formula 9
modificaticn change that have come out since the formula r
10 modification change?
I appreciate your opinion but --
11 A
No, no, not really that I'm aware of.
I think it 12 has always been that the procedures on how to put this stuff 13 in is important to follow.
So if you don't have the j
14 installation procedures telling you how to put it in and i
15 make the lifts the same way we do when we build a test 16 specimen, I think that could lead to problems.
l 17 When you do work, people that don't know what l
18 they're doing, they can install the product and get the 19 stuff to come out horrendously.
They'll pour it in two much i
20 liquid, it will rise up too quick and it splits apart like a 21 loaf of bread does as it rises out of the oven and the top 22 splits.
23 And so if that's the sort of splitting that they 24 identified at Wolf Creek, that could be caused by putting j
25 too much liquid in, which is an improper installation ANN RILEY & ASSOCIATES, LTD.
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method, instead of putting in in small lifts the way we do.
2 We build our test specimen for the fire test.
That way, we 3
instruct our personnel to instal it in the plant.
4 Q
So the variety of examples that were pointed out, 5
such as the Information Notice 88-56, type of deficiencies 6
and others that Mr. Paul mentioned, you were aware of those 7
kinds of problems prior to November of '84 when the formula 8
modification change occurred?
9 A
Correct.
And that's really what made me say it's 10 an installation problem and not a material problem.
11 MR. ULIE:
Okay.
12 BY MR. PAUL:
13 Q
Do you know if Brand has been involved with any 14 lawsuits or legal actions with Dow Corning in regards to the 15 silicon foam?
16 A
There -- something occurred in the '80s where we l
17 received a credit from them, but I don't know if it was l
18 silicon foam or silicon elastomer.
19 So something happened with some material that 20 wasn't good that we received compensation for by additional 21 material.
I don't have the specifics.
22 O
Who would have the specifics of it?
23 A
I think Clay Brown could remember that.
24 Q
Has Brand filed any Part 21 notifications -- are 25 you familiar with what the Part 21 --
a s
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A Yes.
2 0
-- with the NRC in regard to silicon foam?
3 A
I don't believe so.
I think it was addressed at i
4 the time that this ANI withdrew their acceptance.
We had a 5
lot of correspondence that went out and notifled people of 6
that at the time.
People being those utilities.
But I 7
can't recall a Part 21 being issued at that time.
8 Q
Other than that incidence, has Brand ever filed 9
Part 21 with the NRC?
10 A
I don't think so.
i 11 Q
Are you aware of any other, either Dow Corning or 12 other applicators filing Part 21s concerning silicon foam 13 that's manufactured by Dow Corning?
14 A
Well, I think didn't Promatech issue one in i
15 response to this Wolf Creek?
I believe they did.
16 Q
Other than that, are you aware of any more?
17 A
They might have issued two.
I think that's -- are 18 there others out there?
19 Q
No, I was -- that's what I'm trying to determine.
20 They did file Part 21 at Wolf Creek and then they 21 were involved, I believe, at Calloway.
But I don't know if 22 a Part 21 was issued.
23 Just as an overview, as you're probably aware, in 24 addition to the information notice 88-56, there were several 25 other information notices in that time frame, 88-04, ANN RILEY & ASSOCIATES, LTD.
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supplement to 88-04, 88-60, in regards to Dow Corning seals.
2 Are you aware of those events?
3 A
Yes.
4 O
And as you said, some of them are installation 5
problems, various specific problems as 88-60, water 6
tightness of seals at Vogtle.
7 Did you, anywhere in your opinion, professional 8
opinion, feel that it was a result of the performance of the 9
Dow Corning material?
10 A
No, I think the Vogtle one had a drawing that 11 showed it was an access problem, where they installed the 12 foam there was a metal plate at the bottom of the cabinet 13 that prevented the foam from going in and filling the 14 opening.
And that -- the QC should have found that.
15 Q
The point I am trying to make is in '88 we have i
16 identification of quite a few problems with silicon foam j
i 17 seals and I'm just wondering if you associated it at all 18 with this change in formulation?
19 A
No.
20 BY MR. ULIE:
l 21 Q
Do you know if any nuclear utilities were notified 22 of the Dow Corning formula modification change?
23 A
I don't know.
I don't think we notified them.
If 24 Dow did direct, I don't know.
25 Q
That's fine.
This next question, indirectly we ANN RILEY & ASSOCIATES, LTD.
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l 38
!l*
1 talked about it but I would like to ask you direct and see i
2 if you can answer in a direct manner.
3 Are you aware of fire barrier penetration seal 4
tests conducted on the same seal system configuration that l
l 5
passed the fire test prior to the formula modification 6
change but failed the E-119 conditions of acceptance test i
7 criteria after the formula modification change?
l 8
If you would like me to ask it again --
9 MS. BURBANK:
Yes, could you?
10
[ Laughter.)
11 THE INTERVIEWEE:
No, I understand.
This would be l
12 an example of it right here that I talked about earlier that 13 the six specimens in Dow Corning Test 1 that was testing 14 side-by-side testing to show the old formula and the new 15 formula, they all passed the fire portion and then two of 16 them failed the E-119 hose stream.
17 BY MR. ULIE:
18 Q
Can you identify what test report it is we are 19 referring to?
20 A
That is Dow Corning test 1CR5465-4324 Document ID 21 1191E.
22 Q
And it's dated?
23 A
October 1984.
24 Q
And it was a test report that was written or 25 issued by --
l ANN RILEY & ASSOCIATES, LTD.
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A Dow Corning Corporation.
2 Q
By Dow Corning.
3 A
Conducted at Construction Technologies 4
Laboratories.
5 0
And would you be able to identify by number or 6
whatever the identifier is of those -- we talked about six 7
configurations, which are the two that are in question with 8
respect to the hose stream test?
5 9
And take a couple minutes if you need to.
We can 10 go off the record if you need more time.
11
[ Pause.]
1 12 THE INTERVIEWEE:
Yes, I have got the ones.
1 13 BY MR. ULIE:
14 Q
Okay, go ahead.
15 A
Okay, the summary section states that water did 16 project through penetration seals A-1 and A-2 during the 17 hose stream testing but did not penetrate A-3, 4,
5 and 6.
18 Q
Very good.
19 And to the best of your knowledge, those are the.
1 20 only failures of the series of tests that are discussed in 21 that test report?
22 A
Yes.
I haven't really scrutinized these.
I am 23 leaving them for you so you can.
24 Q
Okay.
And we thank you for that.
25 My last question.
Are you aware of any fire ANN RILEY & ASSOCIATES, LTD.
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barrier penetration fire seals at a nuclear facility that is 2
currently not qualified by the E-119 conditions of 3
acceptance test criteria?
4 A
Say that again?
5 Q
Sure.
6 Are you aware of any fire barrier penetration fire 7
seal system at a nuclear facility that is currently not 8
qualified by passing the E-119 conditions of acceptance test 9
criteria?
10 A
There could be a lot, yes.
Specifically, the 11 reason would be because the job specification allowed the 12 use of ANI acceptance criteria so you didn't have to pass E-4 13 119.
That the ANI acceptance criteria with the use of a 1
14 hose stream that is a fog nozzle, all the designs passed the l
l 15 fog nozzle.
There are three different types of fog nozzle l
16 exposures, one the IEEE and two others listed in the ANI.
i l
17 ANI gave you a choice of three different exposures.
18 When we typically fire test something, we would 19 first pick up a fog nozzle spray.
That would pass.
And 20 then we would hit it with the E-119 and then that was the 21 crap shoot if it was going to pass the solid hose stream 22 exposure.
1
[
23 Q
With the exception of the hose stream test and the 24 fog nozzle versus the straight stream or some other type of 25 stream, was there any other conditions of acceptance that ANN RILEY & ASSOCIATES, LTD.
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would not be met in responding to this question, being 2
either the temperature criteria or the passage of flame l
3 through the barrier?
l l
4 A
Well, yes.
Some of the criteria by allowing 634, 5
IEEE-634 as being a test standard, if you've got penetrant 6
temperatures, they are typically higher than the allowable 7
cold face surface temperatures allowed by E-119.
So in some I
8 cases, when the cold face surface temperature limitations 9
exceeded on the penetrating objects, we go to the 700-degree 10 Fahrenheit penetrant limitation.
11 So because we had choices of fire test standards 12 to use for qualification, we would look at our test reports 13 and in some cases we put a matrix in the back of the newer 14 ones showing which test standards this thing actually 15 passed.
4 16 So some of our tests do not pass E-119 but they 17 are used to qualify the designs that have been installed.
18 MR. ULIE:
Okay.
I think you clarified it very 19 clearly.
So I have no further questions.
20 BY MR. PAUL:
21 Q
Just one other question on your background.
22 Prior to Brand, did you have any other experience 23 in fire protection?
24 A
None.
25 0
And what is youi educational background?
I ANN RILEY & ASSOCIATES, LTD.
Court Reporters i
1250 I Street, N.W.,
Suite 300 Washington, D.C.
20005 (202) 842-0034
42 1
A I graduated from California Po'lytechnic State 2
University in San Luis Obispo in 1972.in political science.
3 And then I went to work for an architect and built custom 4
homes for about five years and then worked for a land 5
nurveyor for several years before I came to work for Brand.
6 Q
So that was your first experience with fire 7
protection and the nuclear industry then?
8 A
Correct.
9 Q
Okay.
10 You mentioned earlier you have documents to i
11 present to us?
I 12 A
Yes.
I've got a letter of transmittal dated 13 August 18 that lists everything.
We've talked about the 14 first bundle pretty much.
Those are the Dow Corning tests.
h 15 But there is another change to Dow Corning that you people i
16 didn't talk about and that is outlined in the March 7,
- 1989, 17 letter from Dow Corning where they changed the specific 18 gravity and viscosity readings an their specification 19 sheets.
20 So I have given you that letter.
I have given you 21 that letter again with some notes where we have looked at 22 that and we document the change in specific gravity.
23 Previously, their spec sheet had called out a specific 24 gravity of 1.05 as just being a fixed number.
And I think 25 after years of producing the item they discovered, wait a ANN RILEY & ASSOCIATES, LTD.
Court Reporters l.
1250 I Street, N.W.,
Suite 300 Washington, D.C.
20005 (202) 842-0034
-=.
43 1
minute, you can't just hold at a fixed number, this is a 2
chemical so you need an acceptable range.
So what they were 3
doing is instituting an acceptable range here and having it 4
shift.
5 It is only a couple hundredths of a' percent that 6
physically changed.
But that's documented there.
7 I've given you a copy of the 1982 Dow Corning 8
information sheet on 36548 that shows those original values, 9
the 1993 version that's in effect today.
I have given you 10 the Dow Corning corporate test method that shows how -- what 11 steps they go through to determine specific gravity.
I 12 believe it even references the ASTM designation number of 13 the test that it's modeled after.
The same for viscosity.
14 Then I have given you a test of a BISCO report, 15 748255, which uses a nine-inch thickness of this material 16 with one-inch damming board which is left in place.
And this shows that the performance of this product is still --
17 18 still working today.
19 So these documents are transmitted for your use.
20 BY MR. ULIE:
21 Q
And based on our questions today -- we appreciate 22 all these documents -- is there anything else that either we 23 haven't asked or that you would like to provide at this time 24 to us?
You mentioned that there were a number of documents i
25 there and we appreciate additionally that we addressed.
2 ANN RILEY & ASSOCIATES, LTD.
Court Reporters 1250 I Street, N.W.,
Suite 300 Washington, D.C.
20005 (202) 842-0034
r, 44 1
A No.
Go and review the documents now.
Then, if 2
you've got some further questions, you can call me up.
3 You've got my phone number here; it's on the letter of 4
transmittal.
5 MR. ULIE:
Okay, thank you.
6 BY MR. PAUL:
7 Q
Mr. Simms, have I or any other NRC representative 8
here threatened you in any manner, offered you any rewards 9
in return for the statement?
10 A
No.
11 Q
Have you given the statement freely and 12 voluntarily?
13 A
Yes.
14 Q
Is there anything further you care to add for the 15 record?
16 A
Not at this time.
17 MR. PAUL:
The interview is concluded.
18
[Whereupon, at 11:04 a.m.,
the interview was i
19 concluded.]
20 21 22 23 i
24 l
l 25 ANN RILEY & ASSOCIATES, LTD.
Court Reporters i
1250 I Street, N.W.,
Suite 300 Washington, D.C.
20005 (202) 842-0034
i g
i REPORTER'S CERTIFICATE t
This is to certify that the attached proceedings before the United States Nuclear Regulatory Commission In the Matter of NAME OF PROCEEDING:
Interview of Simms 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 reporting company, and that the transcript is a true and accurate record of the foregoing proceedings.
WarwAANMnAA (\\A
\\
,p -
Official Reporter Ann Riley & Associates, Ltd.
t e
=
N U REG-0300 IFormerly NUREG-75/o871 pa atc,y u
y
?
- e, U.S. NUCLEAR REGULATORY COMMISSION
(%3 j STAN DARD REVEWe PLAN
\\
/
OFFICE OF NUCLEAR REACTOR REGULATION j
eee-j 9.5.1 FIRE PROTECTION PROGRAM i
j REVIEW RESPONSIBILITIES Primary - Chemical Engineering Branch (CMEB)
Secondary - None I.
AREAS OF REVIEW The purpose of the fire protection progrdm (FPP) is to provide assurance, through a' defense-in-depth design, that a fire will not prevent the performance of necessary safe plant shutdown functions and will not significantly increase the risk of radioactive releases to the environment in accordance with General Design Criteria 3 and 5.
The fire protection program consists of fire detection and extinguishing systems and equipment, administrative controls and procedures, and trained personnel.
The CMEB review of the fire protection program includes a review of the evaluation of potential fire hazards described in the applicant's Safety Analysis Report (SAR),andareviewofthedescriptionofthefireprotectionsystemdesign showing the system characteristics and layout which define the ' fire prevention" and " fire protection" portions of the program.
I The CMEB reviews the total fire arotection pr6 gram described in the applicant's
}
Safety Analysis Report (SAR) wit 1 respect to the criteria of Branch Technical Position CMEB 9.5-1 attached to this SRP section, specifically with respect to the following:
1.
Overall fire protection program requirements, including the degree of involvement and. assigned responsibility of management; fire protection administrative controls and quality assurance program; fire brigade training activities and coordination with offsite fire fighting organizations, including their capability in assisting in the extinguishment of plant fires.
e
+2.,, Evaluation of potential fire hazards for safety related areas throughout the plant and the effect of postulated fires relative to maintaining the ability e
I'XHIBIT M
3M 2b PAGF /
OF 5 PAGFI ev. 3 - July 1981
~
USNRC STANDARD REVIEW PLAN Stendsed review plans are prepared for the guidance of the Office of Nuclear Reacter Regulation staff responsible fee the review of soolications to construct and operate nuclear power plants. These documents are made eveilable to the public as poet of the Commission's policy to infeem the nuclear industry and the general public of regulatory procedures and policies. Stenderf review plane are not substitutes for regulatory guides ce the Commission's regulations and compliance with them 6s not wi'ed.The eenn Ined sowiew plan sections are keyed to the Standard Formet and Content of Safety Analysis Reports for Nuclear-r Plants.
Not all sect 6ons of the Standard Formet have e corresponding review plan.
l Published stendeed review plans will be revised periodically, as appropriate, to accommodate commente and to refied
, m rme.
tien and esperience.
Comments and suggestione for improvement will be considered and should be sont to the U.$. Nuclose Regulatory Commission.
Office of Nuclear Reactor Regulation. Washington. D C 20566.
[
Y 8
4 to perform safe shutdown functions, and minimizing radioactive releases to the environment.
Plant layout, egress routes, facility arrangements, and8ttructurri design 3.
features which control separation or isolation of redundant safety systems and selection of the methods for fire detection, control and extinguishing;
~
use of noncombustible control of fire hazards; fire barriers and walls;ighting and communication materials; floor drains, ventilation, emergency l systems.
The functional performance of the fire fighting systems, extinguishing 4.
agents, including the detection, alarm, suppression, control, and extin-guishing systems described in the SAR to verify the adequacy of the FPP to protect safety-related equipment.
The fire protection system piping and instrumentation diagrams (P& ids);
5.
including redundancy of equipment; the FPP design criteria and failure modes and effects analysis (impairment).
On multiple unit applications, the additional fire protection and control 6.
provisions during construction of the remaining units will be reviewed to verify that the integrity and operability of the fire protection system is maintained.
The CMEB will coordinate other branches' activities related to fire protection as follows:
The Auxiliary Systems Branch (ASB)* reviews the applicant's list of systems and components needed to provide safe shutdown capability r.nd reviews the appiicant's program for identification of the locations where redundant trains or divisions The results of of safe shutdown systems are separated by less than 20 feet.
these reviews are provided to CMEB.
CHEB notifies the applicant of results as appropriate and reviews the applicant's fire protection measures to deal with If such measures involve modifications of original separation deficiencies.
)
system (includingemergencylightingandcommunication)orcircuitdesigns,or will review upon request from ~HC.B.
The changes in layout of equipment, ASB designs will be reviewed against the criteria for shutdown system'; gisen in BTP CMEB 9.5-1, Positions C.5.b and C.S.c.
The review of these modifications will be documented in SER sections dealing with the systems involved.
The Emergency Preparedness Licensing Branch (EPLB) will evaluate the adequacy of the offsite emergency planning as part of its primary review responsibility The Licensing Qualification Branch (LQB) will evaluate for SRF Section 13.3.
the fire protection brigade training programs and will evaluate the organiza-tinual arrangements as part of its primary review responsibilities for SRP The Procedures and Test Review Branch Sections 13.2.2 and 13.1, respectively.
(PTRB) will evaluate the fire protection plant procedures as part of its primary The Quality Assurance Br:nch (QAB) will 4
responsibility for SRP Section 13.5.-evaluate the adequacy of the QA Pro
-.~
The Licensing Guidance Branch will review the bility for SRP Section 17.0. technical specifications prepared by the appifca The Structural of its primary review responsibility for SRP Section 16.0.
Engineering Branch (SEB) will, upon requast, verify the acceptability of the "with assistance from other PS branches (RSB, ICSB, PSB) as required.
Rev. 3 - July 1981 9.5.1-2
d design analyses, procedures, and criteria used for seismic Category I sepperting structures for the FPP, and for externally imposed system loads resulting from less severe natural phenomena.
The Mechanical Engineering Branch (MEB) will, review that portion of the hose standpipe system which should upon request}onal following a postulated SSE, and confirm that sye.tems compo-remain funct nents, piping, and structures are designed in accordance with applicable seismic design criteria.
The Instrumentation and Control Systems Branch (IC58) verifies, on request, the adequacy of the fire protection instrumentation and controls.
For those areas of review identified above as being reviewed as part.of the primary responsibility of other branches, the acceptance criteria necessary for the review and their methods of application are contained in the referenced SRP section of the corresponding primary branch.
II.
ACCEPTANCE CRITERIA The applicant's fira protection program is acceptable if it is in accordance with the following criteria:
1.
10 CFR Part 50 650.48, and General Design Criterion 3, as related tc fire prevention, the design and operation of fire detection and protection systems, and administrative controls provided to protect safety-related structures, systems, and components of the reactor facility.
2.
General Design Criterion 5, as related to fire protection for shared safety-related structures, systems, and components to assure the ability to perform their intended safety function.
The following specific criteria provide information, recommendations, and guidance and in general describe a basis acceptable to the staff that may be used to meet the requirements of 550.48, GDC 3 and 5:
a.
Branch Technical Position (BTP) CHED 9.5-1 as it relates to the design provisions given to implement the fire protection program.
b.
Regulatory Guide 1.78 as it relates to habitable areas such as the control room and to the use of specific fire extinguishing agents.
c.
Regulatory Guide 1.101, as it relates to fire protection emergency planning.
III. REVIEW PROCEDURES The secondary and coordinated review branches will provide input for the areas l
of review stated in subsection I of this SRP section. The primary reviewer obtains and uses such input as required to assure that this review procedure jsfomplete.
ThdreviewerwillselectandemphasizematerialfromthisSRPsectionasmay be. appropriate for a particular case.
- 1. ' CMEB reviews the SAR to determine that the appropriate levels of management and trained experienced personnel are responsible for the design and implementatIonofthefireprotectionprograminaccordancewithBTP CHEB 9.5-1.
9.5.1-3 Rev. 3 - July 1981
i t
CMEB reviews the analysis in the SAR of the fire potential in safety-related plant areas and the hazard of fires to these areas to determine that the proposed fire protection program is able to maintain the ability to perform safe shutdown functions and to minimize radioactive releases to the environment.
3.
CMEB reviews the FPP P& ids and plant layout drawings to verify that facility _
arrangement, buildings, and structural and compartmentation features which affect the methods used for fire protection, fire control, and control of
-~-
hazards are acceptable for the protection of safety-related equipment.
4.
CMEB determines that design criteria and bases for the detection and suppression systems for smoke, heat and flame control are in accordance
~
with the BTP guidelines and provide adequate protection for safety-related structures, systems, and components.
The reviewer determines that fire protection support systems, such as emergency lighting and communication systems, floor drain systems, and ventilation and exhaust systems are designed to operate consistent with this objective.
CMEB reviews the results of an FPP failure modes and effect analysis (impairment) to assure that the entire fire protection system for one safety-related area cannot be impaired by a single failure.
5.
For multiple unit sites, CMEB determines that protection is provided to operating units during concurrent construction of other units. This includes an evaluation of the total fire protectiori program for each plant, the overall program for the site, including division of responsibility on fire protection matters.
3.
CHEB reviews the technical specifications proposed by the applicant for fire protection (OL). The reviewer will determine that the limiting conditions for operation and surveillance requirements of the technical specifications are in agreement with the requirements developed as a result of the staff's review.
l IV.
EVALUATION FINDINGS CMEB verifies that sufficient information has besa provided and that the review is adequate to support conclusions of the following type, to be included in the staf f's safety evaluation report:
The staff concludes that the fire protection program's design criteria and bases are acceptable and meet the requirements of 10 CFR Part 50, 650.48 and General Design Criteria 3 and 5.
This conclusion is based on the applicant meeting the ouidelines of Branch Technical Position CMEB 9.5-1, and Regulatory Guides 1.78 and 1.101 as well as applicable industry standards.
In meeting these guidelines the applicant has provided an acceptable basis for the design and location of safety-related structures and systems to minimize the probability and effect of fires and explosions; has used noncombustible and heat resistant materials whenever practical; has provided of fire detection and fire fighting systems of appropriate capacity and capability to minimize adverse effects of fire on safety-related systems.
In addition, the applicant has demonstrated that shared structures, systems anh temponents of the fire protection systems will not g
prevent their ability to perform their intended safety functions.
9.5.1-4 Rev. 3 - July 1981 I
i d
~
V.
IMPLEMENTATION The following is. intended to provide guidance to applicants and licensees regarding the NRC staff's plans for using this SRP section.
- t Except in those cases in which the applicant proposes an acceptable alternative method for complying with specified portions of the Commission's regulations,
. %e method described herein will be used by the staff in its evaluation of "conformance with Commission regulations ~.
Implement'ation schedules fo'r conformance to parts of the method discussed herein are contained in the referenced regulatory guides.
3 l
VI.
REFERENCES i
1 1.
10 CFR Part 50, Appendix A, General Design Criterion 3, " Fire. Protection."-
i 2.
10 CFR Part 50, Appendix A, General Design Criterion 5, " Sharing of Structures, Systems, and Components."
- 3.
- Regulatory Guide 1.78, " Assumptions for Evaluating the Habitability of a '
l Nuclear Power Plant Control Room During a Postulated Hazardous Chemical Release."
4.
Regulatory Guide 1.101, " Emergency Planning for Nuclear Power Plants."
i i
5.
Branch Technical Position CHEB 9.5-1, " Guidelines for Fire Protection for l
Nuclear Power Plants."
6.
10 CFR Part 50, g 50.48, " Fire Protection."
7.
Appendix R to 10 CFR Part 50, " Fire Protection Program for Nuclear Power Fccilities Operating Prior to January 1,1979."
i L
l l
i i
u.
i i
fa i
i 9.5.1-5 Rev. 3'- July 1981 i
i 1
we.
a c
Standard Methods of FIRE TESTS OF BUILDING CONSTRUCTION AND MATERIALS' d
1ha saadard u issued moder the (med des.gmainom E 119 the number 4
vear of onpaal adopison or, sa the case of revassoa the year of t unmediaieiy folloaing the deugnauon endwases the
*PProvat e
asa revisaoa A numtier un parentheses indscates the year ofless I
t g apagwuema.esaaaedsThese sneesheds here been appreeedfor as:a by agencaos of the Depa f
soment of Defense andfor JLat. sg an she DoD lodea of 1
INTRODUCIlON i
l g
j The performance of walls, columns, Doors, and other building memb exposure condations is an item of major imponance in secunng constructio ers under fire
.u safe, and that are not a menace to neighbonng structures nor to the public R ns that are of this is registered in the mdes of many authonties, municipal and other It is im
{
{
. ecognition to secure balance of the many units in a single building portant s
vanous authonties throughout the country. To do this it is necessarcharacter and use in a 4
. and of buildings of like u rements of resistive properties of materials and assemblies be measured and specified a y that the fire-a common standard expressed in terms that are applicable ahke to a wid i
ccording to materials, situations, and conditions of exposure.
{
e variety of i
Such a standard is found in the methods that follow i
j exposing fire of controlled extent and severity. Performance is denned as the. They prescribe a standard observed. Results are reported in units in which field exposures can b j dresistance to period of I
e avior is expressed.
?
e u ged and The methods may be cited as the " Standard Fire Tests" and the perf exposure shall be expressed as "2-h," "6-h." "%-h." etc.
ormance or When a factor of safety exceeding that inherent in the test cond ti proportionalincrease should be made in the specified time-classification period.
5 i ons is desired, a i
- 1. Scope l.1 These methods'are applicable to assem.
anddescribe thepropertnes ofmaserials, products, 1ses of masonry units and to composite assem.or assembhes an response to heat andflame under 6
hes oi structural matenals for buildmgs, in-controlled laboratory condations and shondd not b
~
iudmg beanng and other walls and partitions. -be used so describe or appraise thejire hazard or c
olumns, girders. beams, slabs, and composite c
'These metbMs are under ne prudacuon of ASTM
}
slab and beata assemblies for floors and roofs.
communee u on hre standards i
S hey are also applicable to other assemblies T
i9st onpaan, pubt.shed as C ioCurnas edessoa approved March 2.1981. Pubbsbed June
{
nd structural units that constitute permanent a
ed.non E sit so 917 T tasi prev.ous tegral parts of a fimshed building.
gn These methods.of which ne present standard represeass
{
l.2 It is the intent that classifications shall a nvision. =cre prepased tn Sectsonal Commsnee A2 on 9
g re5tster performance dunng the period og ex-Fire Tens of Ma.cnals and Construcuan. undes the joina Fire rrosecersponsorskapof the Nauomal Bureau of Standards.the ANSI s
@ idetermmed suitabthty for use after fire expo-posure and shall not be construed as havmg and Malenals.luac% see Amerua&setMesssag
- I 5(**d*'d$ 1=*u'"**upamg under the procedure of the Ar2r-1 v*
huse.
hau
- Supp"ornag data on repeat nss suostdard should be u. sed so measure....;,,,,,,,, _ mm, m e,abditw and reproducibelsew are maawnm me ruaseerph.a.r* WM4FTRR *o*-mm I9ue st.
f 93-02 6 M.
PAGE I
1
-- OF _. __ P AGE (S) 3
~
'3 W
. -. -- - - - ~
,n,~~-.~-~#'"
" ~' '
@ E 119
[wr nsk af nsasenals. products. or assembhes 2.3.I.2 Mc s:rement of the traumnssion of under actualfare conduons #1werc.. remhs of hot gases through the assembly, sufficient to perature curve, see Appendix XI mg these ume conuani remmement m.n he, tam.
this test may be used as elements of sfire risk igrute cotton w"ste.
Host 2-Becornnsendsnuuns for Recordung f uel fj jg afg a ef ema e
i assessuscat w/uch sakes anto account all of she 2 3.13 For load beanng elemenu, measure-Ik-88 f"'"'" 8""Mh' I II *"I P"'udes porcekn msulators and msenmg the assembly so the
[$
f[ f1 ofNt factors w/uch are perimens so an assessment of ment of the load carrymg abihty of the fest I"'I' the'muc UP c bead as b m from the scaled end of a l
me Iurn shefire hasard of a partscidar end asse.
specamen during the test exposure.
*"d*'d * *'8
' """'"* 3 h * "#"' "' " 3""'"*l h
n Fuel flow data may be useful for a furnace NOTE l-A method of fire bazard classifacauon 2 3 2 For individualload bearing assembhes beat balana analysis, for measunng the effect of
- f,j"
""*""'I I'
g,,
based on rate of flame spread as mvered in ASTM such as beams and columns: Measurement of furnace or can'.rol changes, and for companng the time constant may also be calculated from knomtedge j
"aface Bang hactens-the load carrying ability under the test exposure PSPemes in of its phyncal and thermal propernes See Research u:
Repon RR. ED5-1001. nailable from AST M licad-with some rnnsideration for the end support Reard the integrated Icumulative) flow of gas (or i
1.4 The results of these tests are one factor conditions (that is. restrained or not restrainedl.
other fuel) to the furnace burners at to min. 20 min.
l in assessing fire performance of buildmg mn-2.4 The test standard does not provide the 81**stly Total gas consumed dunng m"e total tem4.2 he temperatures shall be read at inter.
t 30 SS *"d *"7 30"'"**'****'
"C'
- I'e-I struction and assemblies. These methods pre-follownE:
vals not exceeding 5 min dunng the first 2 h, penod as also to be determaned A recordang fle scnbe a standard fire caposure for comparing 2.4.1 Full information as to perforinna" of mener has advantages over penodic readsgs on an and thereafter the intervals may be mcreased
[,
the performance of building construction as-assembbes constructed with components or
--- or totahnng flow meter Select a mea.
to not more than 10 mm.
sembhes. Apphcation of these test results to lengths other than those tested.
surag and recadmg synem to provide 11o= rate 4.3 The accuracy of the furnace control shall Predact the performance of actual buildiag con-2.4.2 Evaluation of the degret. by wbkh the readmEs accurate to wiman i R be such that the area under the time-tempera-
~
P"t
'E struction requires careful evaluation of test con-assembly contributes to the fire hazard by gen-
, and the w c t Q ture curve, obtained by averaging the results dations.
erstion of smoke, toxic gases, or other products dauons of 60*F (16*C) and 30 0 in. lig) as an funcuon from the pyrometer readmgs, as within 10 per-ofMe of ume.
cent of the corresponding area under the stand-
- 2. Signmeance 2.4.3 Measurement of the degree of control ard time-temperature curve shown in Fig. I for 4 Famace Temperawes fire tests of I h or less duration, withm 7.5 4 j
2.1 Dis standard is intended to evaluate the or limitation of thepassage of smoke or prod-duratzon for which the types of assemblies ucts of combustion through the assembly.
4.1 De temperature fixed by the curve shall for those over I h and not more than 2 h. and noted in 1.1 will contain a fire, or retain their 2.4.4 Simulation of the fire behavior ofjoints be deemed to be the average temperature ob-within 5 % for tests exceedang 2 h in duration.
structural integnty or exhibit both propertaes between biuldmg elements such as floor-wall tained from the readtags of not less than nine dependent upon the type of assembly involved or wall-wall, etc, connecsions.
thermocouples for a floor, roof wit, or parti-
- 5. Temperatures of Unesposed Surfaces of dunng a predetermined test caposure.
2.4.5 Measurement of flame spread over su,.
tion and not less than c. sin thermocouples for Fluors, Roofs, Walls, and Partitions 2.2 The test caposes a specimen to a ssmadard face of tested element.
a structural column symmetrically disposed 5.1 Temperatures of unexposed surfaces fire exposure controlled to achieve specif3ed 2.4.6 De effect of fire endurance of conven.
and distributed to show the temperature near shall be measured with thermocouples or ther-temperatures throughotti2 specified timey~-
tional openings in the assembly, that is, electri-a!! parts of the sample, the thermocouples bemg mometers plaad'under flexible, dry, felted as-nop. In some inmam thefire exposure may cal receptacle outlets, plumbing pipe, etc, un_
enclosed in protection tubes of such matenals bestos pads (Note 5) The propesties of these be followed by the application of a speepied less specifically provided for in the construction and dimensions that the time constant of the pads shall meet the requirements hsted in Ap srandard fire hose stream. The exposure, how-tested.
Protected thermocouple assembly hes withm pendix X2. The wire leads of the thermocouple ever, may not be representative of all fire con.
the range from 5.0 to 7.2 mm (Note 31 The or the stem of the thermometer shall have an dauons which may vary with changes in the CONTitOL OF FIRF TESTS exposed length of the pyrometer tube and ther.
immersion under the pad and be in contact amount, nature and distribution of fare loadmg, mocouple in the furnace chamber shall be not with the uncaposed surface for not less than 3b Temperswe Cane ventilation, compartment size and configura-less than 12 in. (305 mm) Other types of pro-in (89 mmi The hot junction of the thermo-taon, and heat sink charactenstics of the com-3.1 The conduct of fire tests of materials and tecting tubes or pyrometers may be used that, couple or the bulb of the the'nnometer shall be partment. It does, however, provide a relauve c nstruction shall be controlled by the standard under test conditions, give the same indic.ations placed approximately under the center of the measure of fire performance of comparable time-temperature curve shown in Fig.1. De as the above standard within the hmit of ac-pad The outside diameter of protecting or assembhes under these specified fire caposure Points on the curve that determine its character curacy that apphes for furnaccumperature insulatmg tubes. and of thermometer stems, conditsons. Any vanation from the construction measurements. For floors and columns, the shall be not more than b in p mmi The pad are-or conditions (that is, size, method of assembly.
1000*F (538'C) at 5 min ljunction of the thermocouples shal! be placed shat! be held firmly agamst the surface, and and matenals) that are tested may substantially 1300*F (704*C) at 10 min 12 m. away from the exposed face of the sample shall fit closely about the thermocouples or change the performance characteristics of the 1550*F (843*C) at 30 nun at the beginning of the test and, dunng the test.
thermometer stems Thermometers shall be of assembly.
3700*p(927'C) at I h shall not touch the sample as a result of its the partial-tmmersion type. with a length of 2.3 The test standard provides for the fol-1850*F (1010*C) at 2 h sie!!ection in the case of walls and partitions, stem. between the end of the bulb and the towag:
2000*F (1093*C) at 4 h the thermocouples shall be placed 6 m (152 211 In walls, partstions, and floor or roof 1300*F (1260*C) at 8 h or over mm) away from the exposed face of the sample
- Harm.un T z oeuen or n,c leu 8 arn.-ec I-c assembhes:
at the begmning of the test, and shall not touch M**"8 ' " i
- 1 "" N * * * * '
2.3.1.1 Measurement of the transmission of 3.2 For a closer delbition of the time-tem-the sample dunng the test, in the event of buik"E$$
MrNddYAa$
f heat.
- a is a asru ssa.anas. r n :
deflecton.
Temar Mam Wo. pp "* *ad 011*+ " stash:
B *ad Bwhanaa.A H. "A Heat Basence AaMwm td the 48,1 Non 3-A typical thermacouple auernbly meeb hre t odurante leu *'
40 M HIBIT 41 I PAGE(S)
- ^ 1 OF m
m
.m.
m.
w g g;339 tmmeruon mnk. Of 3 m (76 mm). The wirts determined by the avsrage of the musurement' sanilarly decrmed for fire exposure below CONDLICT OF FIRF TESTS for the thermocouple in the length covered by Likin ca mdniduit points, except that af a standard.
- 8. Fire Nurance Test the pad shall be not beaner than No.18 B & trmper aure nse 30 % ia excess of the specified a bThe wrecten can be ww h m S gage (0.04 in.)(1.02 mm) and shall be elec-Itmit oa:urs at any one of these points. the m squauon:
8.1 Contmue the fire endurance test on the tncally insulated with heat-resistant and mois-remainder shall be ignored and the fire endur-specimen with its applied load, if any, until C" D
- W* + 4 ture-resistant coatings.
ance period judged as ended.
failure occurs, or until the specunen has with-Nort 4-For the of testing roof assem-CLASStFICATION AS DETERMINED BY correcuan in the same units as I,
- E' "9 "*' '
bhes, the unexposed s am shall be dermed as the TEST f - indicaud hm W that herem specified in the conditions of ac-N TE 5-taas it maI be un-
- 6. Report of Resuks A " "'** "*d*' 'b' """ *' '"d'**'*d *** f e CcPtance fw the given type of constmction.
'*'* "' "*PracucaNe to use thermometers furnace temperature for the first three fourths 8.2 For the purpose of obtaining additional 6.1 Resuhs shall be reported in accordance of the indicated period, performance data, the test may be continued 5.2 Temperature readings shall be taken at with the performance in the tests prescribed in A. - area under the standard furnace curve for the beyond the time the fire endurance classifica-same the a
not less th us nine points on the surface. Five of these methods. They shall be expressed in time tion is determmed.
g, hF-b or 30*C b f3240*F-mun or 1800"C-dA these shall be symmetrically disposed, one to periods of resistance, to the nearest integral t
be approximately at the center of the specimen, minute. Reports shall include observations of mun)y
- 9. Iluse Stream Test and four at approxunately the center of its significant details of the behavior of the mate-9.1 Where required by the conditmns of ac-
- "*7 quarter sections. The other four shall be located rsal or construction during the test and after the g.
ceptance, subject a dupbcate specimen to a fire at the discretion of the testing authority to furnace fire is cut off, including information on obtain representative information on the per-deformation, spalling, cracking, burning of the the report shall indicate the side so enposed e2Posure test fw a penod equa ndes W k td W & y g that indicated as the resistance period in the formaace of the construction under test. None specunen or its component parts, continuance shall so indicate the fire endurance classifica-fire endurance test, but not for more than I h.
of the thermocouples shall be located nearer to of ihmmg, and production of smoke.
immediately after 3idth subsect the mectmen la 8 8PPucable to each side.
the edges of the test specunen than one and 6.2 Reports of tests involving wall, floor, to the unpact, erosion, and cooling eficcts of a one-half tunes the thickneas of the construction, beam, or miling constructions in which re-b'Ee stream directed first at the middle and TEST SPECIMEN or 12 in. 00$ mmL An exception can be made straint is provided against expansion, contrac-then at 111 parts of the esposed face, changes in in those cases where there is an element of the tion, or rotation of the construction shall de-
- 7. Test Spechnen direction being made slowly.
construction that is not otherwise represented scribe the method used to provide this restraint-9.2 Exempima-The hose stream test shall in the remainder of the test specunen. None of 6.3 Reports of tests which other than maxi-7.I The test specimen shall be truly repre-not be required in the case of constructions the thermocouples shall be located opposite or mum load conditions are imposed shall fully scatative of the construction for which classi-having a reststance period, indicated in the fire on top of beams, girders, pilasters, or other define the conditions ofloading used in the test fication is desired, as to materials, workman-endurance test. ofless than I h.
i structural members if temperatures at such and shall be designated in the tstle of the report ship, and details such as dimensions of parts, 9.3 Optional Program-The submitter may points will obviously be lower than at more of the test as a restricted load condition.
and shall be built under conditions represent-elect, with the a3vice and consent of the tesitag e representative locations. None of the thermo-6.4 When the indicated resistance period is ative,of those obummg as practically apphed body, to have the hose stream test made on the couples shall be located opposite or on top of % h or ovur, determined by the average or inTulding construction and operation. The specunen subjected to the fire endurance test fasteners such as screws, nails, or staples that maximum temperature rise on the unexposed Pitysical properties of the materials and ingre-and immediately following the expiration of will be obviously higher or lower in tempera-surface or within the test sample, or by failure dients used in the test specunen shall be deter-the fire endurance test.
ture than at more representative locations if the under load, a correction shall be applied for mined and recorded.
9.4 Stream Equipment and Dermis-1he aggregate area of any part of such fasteners variation of the furnace exposure from that, 7 2 The size and dimensions of the test spec-stream shall be delivered through a 2 bin. (64-projected to the unexposed surface is less than prescribed, where it will affect the chuirication, ames specified herein are intended to apply for mm) hose discharging through a National 0.8 percent of the area wtthin any 5-in. (127-by multiplyicg the indicated period by two rating constructions of dimensions within the Standard Playpipe of correspondtog size mm) square. Such fasteners shall not extend thirds of the difference in area between the usual general range employed in buildags. If equipped with a 14-in. (29-mm) discharge tip through the assembly, curve of averaSe furnace temperature and the the conditions of use hmit the construction to of the standard-taper smooth-bore pattern 5.3 Temperature readmgs shall be taken at standard curve for the first three fourths of the smaller dimensions, a proportionate reduction without shoulder at the orifice. The water pres-intervals not exceeding 15 min until a reading period and dividing the product by the area may be made in the dunensions of the speci-sure and duration of application shall be as exceeding 212*F (100*C) has been obtained at between the standard curve and a base line of mens for a test qualifying them for such re-prescribed in Table 1.
any one point. Thereafter the readings may be 68*F (20*C) for the same part of the indicated stricted use.
9.5 Nonle Disrance-The nozzle ortlice i
taken more frequently at the discretion of the period, the latter area increased by 54*F.h or 7.3 When it is desired to include a buih-up shall be 20 ft (6 m) from the center of the testing body, but the intervals need not be less 30*C h (3240*F min or 1800*C min) to com-roof covering, the test specunen shall have a exposed surface of the test specimen if the i
than 5 min.
pecsate for the thermal tag of the furnace ther. mof covering of 3-ply,15-lb (6.8-kg) type felt nozzle is so located that when directed at the j
54 Where the conditions of acceptance mocouples during the first part of the test. For ap m excess of 120 lb (54 kg) per square (100 water its axis as normal to the surface of the i
place a hmnation on the rise of temperature of fire exposure in the test higher than standard. A (9 m')) of hot mopping asphah without test specunen. If otherwise located. its distance the unesposed surface. the temperature end the indicated resistance period shall be in gravel surfacing Tests of assembbes with thts from the center shall be less than 20 ft by an point of the fire endurance period shall be creased by the amount of the correction and be covering do not preclude the field use of other amount equal to I ft (305 mmi for each to deg i
buih-up roof coverings.
of deviation from the normal.
N 42 EXHIBIT c
j PAGE O OF M PAGES i
l I
v -
,10. Protecties and Conditioning of Test Spec-10.1.2 If. durinE the condit?**"E of 6' Amen specunen it rppears destrtble or is necessary to deugn crueria. The tests may also be conducted
- 1ES1N OF NOMAltING w A1.1.$ ANie l' AR111 RON$
10.1 Protect the test spectmen dunng and use accelerated (rying techniques, it is the re.
by aPplyi;g to the specimen a load less than rfter fabrication to assure normality ofits qual. sponsibihty of the laboratory conducting the the pmm M m M k hM m ity and condition at the time of test. It shall not test to avoid procedure's which will significanti the a e as hng Mn MM &
- 14. Size of Sample be tested until a larI* Portaon of its final alter the structural or fire endurance character'**
2 strength has been attained, and, ifit contains istics of the specimen or both from those and the apphed load expressed as a percentage less than 100 ft (9 m ), with neither dimension r
f
'8" P
moisture, natil the excess has been removed to duced as the result ofdrying in accordance th achieve an air-dry condition in accordance with Procedures given in 10.1.1.
beincluM M the repoa A Me wau assend on an h Mges.
the requirements given in 10.1.1 through 10.13.
10.1.3 Within 72 h prior to the fire test in-ns.
e her e o ed
- 15. Conditicas of Acceptance Protect the testtag equipment and sample un.
formatmn on the actual moisture contect and dergoing the fire test from any condition of distnbution within the specunen shall be ob-tely or both sides together (Note 9). The 15.1 Regard the test as successful if the fol.
wind or =cather, that might lead to abnormal tained. Include this information in the test re-method used shall be re ried' lowing conditions are met'-
resula. The ambient air temPaature at the Port (Note 8).
Non 9-The choice depends on the amended use, 15.1.1 The wall or partition shall have with.
.ad whether the load on the exposed sade, after u has stood the fire endurance test without passage bestaning of the test shaB be within the range. Non 7-A recommended method for detem failed, will be transferred to the unexposed side If.
of flame or gases hot enough to ignite cotton of 50 to 90 F (10 to 32*C). The velocity of air ma the relauve hay withm a hardened concreu in the unended use.the load from the structure atme across the unexposed surface of the sample' sp-=*a with electnc se ' elements is descnbed is supported by both wa!!s as a urut and would be or waste, for a E' nod '9ual to that for wluch la APPendax I of the pn Menzel, C. A., "A is sansferred to the unes d side m case of collapse classification is desired.
measured just before the test begins, shall Method for Determaning the Moisture Condition of of the exposed sade, walls should be loaded in 15.1.2 The wall or partition shall have with-exceed 4 4 ft (13 mVS, as dettmuned by an llaniemed Concsete sa Terms of R#ative Humiday,-
the test by a single unn. If, in the miended use the stood the fire and hose stream test as specified anemometer placed at right angles to the unex-Proce=dngs, Am. Soc. Tesung As., ASTEA. ~vol load froen the structure above cach wall is supported in $cction 9, without passage of flame, of gases posed surface. If mad =At ventilation is em-55,1955. p.1085. A==itar proc =4are wuh electnc by each wall separately, the walls should be loaded plcyed during the test, an air stream shah not 8enmag elements can be used to detco mine the relative separately in the test by separate load sources. If the hot enough to ignite cotton w.aste, or of the be directed across the surface of b specamen-humaday withra fire test sym,a= made with other intended use of the construction system bemg tested hose stream. The assembly shall be ' considered matenals-410.1.1 Prior to fire test, condition construc-Wah wood construcuans, the s.oisture meter scnbed above, the walls should be loaded separately sievelops that permits a projection of water involved situations of both loadang condunons de-to have failed the hose stream test if an opentng tions with the objective of providing, within a based on the electrical raa'a= method can be used, an the test by separate load sources. la tests conducted when approprute, as an ahernauve to the relauwe wah the walls loaded separately the conduson of from the stream beIand the unexposed surface reasonable time, a moisture condition within-the specunen approaisnately representative of humuhty method to Ma'* whcc wood has atra-t ace uinn the walls to maintain the ap-during the time of the hose stream test-the proper moisture content. Electncal methods an load s be on the tune at which the 15.1.3 Transmission of heat through the wall that hkelv to exsst inymdar w wiim ug descnbed on 320 and 321 of the 1955 ediuos fast cf enher of the walls faal to sustaan the load or partition dunng the fire endurance test shall
_buildags. For purposes of mndardization, &is of the Wood medbeek @ forest % w conditaon as to bg consadered as that whg essary,U.S.DepansecatofAgncuhure.Therelation-13, ramations of Acceptsace ggg,ggg 5 established al equal Onurn,nsuhang 5 a i ph[tn 3 ~
13.1 Regard the test as successful if the foi-v ts ini ial m ratu e 39*C) a mnpa an ambient atmosMicrg.pfjp %
we. that too a moisture comens of l) % a'sI wing condition; are met:
min relatsve humadaty at_lh INote 7). Howevd, a reative humiday of 70 g for a temperato,e of 70 13.1.1 Th wall or partition shall have sus-with some constructions, it'may be difficult or to 30*F f21 to 27*CL tained the apphed load dunng the fire endur-IF.STS OF COLUMNS smpossible to achieve such unifonnity within a Norr 8-If the moisture condnen of the fire test ance test without passage of flame or gases bot E*
reasonable period of time. Accordangly, where ely to change draussaHy froEn the 72-enough to ignite Cotton waste, for a penod assem s
this is the case, specimens may be tested when Ythan l
8' P ing should be h pnor equal to that for which classification ts desired.
I6 i The length of the column exposed to the dampest portion of the structure, the por-13.1.2 The wall or partition shall have sus-fire shall, when practicable. approximate the tion at 6-in. (152-mm) depth below the surface MD M KARING WALLS AND tained the apphed load during the fire and hose maximum clear length contemplated by the I
of massive constructions, has achieved a mois.
PARTTTIONS stream test as specified in Section 9, without design, and for buildmg columns shall be not ture content corresponding to drying to equilib-II. Sise of Sample Passage of flame, of gases hot enough to ignite less than 9 ft (2.7 mi Apply the contemplated rium with air in the range of 50 to 75 % relative cotton waste, or of the hose stream. The assem-details of connections, and their protectioc if humidity at 73 2 5'F (2313*C). In the event area ex7 sed to Em shall be not bly shall be considered to have failed the hose any, according to the methods of acceptable that specimens dried in a heated building fait less than 100 ft (9 m ), with neither ditr,casion stream test if an opening develops that permits field practice.
to meet these requirements after a 12-month 8:58 8Pecamen shall a projection of water from the stream beyond ai ed on its vertical edges-the unexposed surface dunng the time of the
- 17. Imading e
conditioning period, or in the event that the nature of the construction is such that it is 12.14ading hose stream test.
17.I Throughout the fire endurance test ex-evident that drying of the specimen interior will 12.I Throughout the fi d
13.1.3 Transmission of heat through the wall pose the column to fire on all sides and load it be prevented by hermetic scahng, these require-and hose stream tests a 8f Partition during the fire endurance test shall in a manner calculated to develop theoretically, as super" spents may be waived, except as to attainment imposed load to simul not have been such as to raise the temperature as nearly as practicabic, the working stresses i d of a large porten of final strength, and the condition. The ap lied load sb I be on its unexposed surface more than 250*F contemplated by the design Make prmiston specimen tested in the condition in which it as practicable the maximum load all d (130*C) above its initial temperature.
for transmitting the load to the emptned portion design under nationally recognized structural
//
r XHit4IT 44 e~
OF [ PAGE(S) n, e r'
y r
[\\)'
APPENDIX A* TO BRANCH TECHNICAL POSITION 'PCSB 9.S-1 i
A
" GUIDELINES FOR FIRE PROTECTION FOR NUCLEAR POWER PLANTS DOCKETED PRIOR TO JULY 1,1976" (AUGUST 23,1976) l This Appendix A provides guidance on the preferred and, where applicable acceptable alternatives to fire protection design for those nuclear power plants for which applications for construction permits were docketed prior to July 1,1976.
The provisions of this appendix will apply to the following categories of nuclear power plants:
(1) Plants for which application for construction permits were docketed prior to July 1, 1976, but have not received a construction permit; (2) Plants for which construction permits were issued prior to July 1, 1976, and operating plants.
This appendix modifies, as deemed appropriate, the guidelines in Branch Technical Position (BTP) APCSB 9.S-1, " Fire Protection for Nuclear Power Plants" which are intended for plants whose application for construction permit is docketed after July 1, 1976.
'Ihe guidelines of the above cited BTP were adopted for this appendix and are preferred in all instances.
D Alternative acceptable fire protection guidelines are identified in this appendix for areas where, depending on the construction or operation status of a given plant, application of the guidelines per se could have signi-ficant impact, e.g., where the building and system designs are already finalized and construction is in progress, or where the plant is in operation.
These alternative guidelines are intended to provide adequate and accep-table fire protection consistent with safe plant shutdown requirements without a significant impact on plant design, construction, and operation.
Particular sections that are intended to apply only to plants under review, under construction or operating are identified under the appropriate column.
Although this appendix provides specific guidance, alternatives may be proposed by applicants and licensees.
These alternatives will be evaluated by the NRC staff on a case-by-case basis where ruch departures are suitabl y justified.
Among the alternatives that should be considered is the provision of a " dedicated" system for assuring continued safe shutdown of the plant.
This dedicated system should be completely independent of other
-+
plant systems, including the power source; however, for fire protection, it is not necessary for the system to be designed to seismic Category I criteria or meet single failure criteria.
the other safety related systems would still be required.. Manual fire fighting capabil I
(
1
- This document includes the changes listed in the Errata Sheet dated
~
l Hovember 18, 1976, as indicated by a vertical line in the margin.
[
i 3.9s,-026 9.5.1-55 2/24/77 nm 1:1.
DAGE
/
OF 1 PAGE(S)
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i;
.i g.
18
.\\PPLICATION'DOCrETED EUI CONSTRUCTION
)
PLANTS UNDER C055TRUCTION AND PERMIT NOT RECEIVED AS OF 7/1/76 OPERATING PLANTS
\\
3.
_ Electric Cable Construction, Cable Trays and Cable Penetrations 3.
E3ectric Cable Construction.
_ Cable Trats and Cable Penftrations (a) Only non-combustible materials should be used for cable tray (a) SAME construction.
l l
(b) See Section E.3 for fire pro-l taction guidelines for cable (b) SAME l
spreading rooms, I
(c) Automatic water sprinkler systems i,c)
SAME. When safety should be provided for cable related cables do not trays outside the cable spreading Cables should be designed satisfy the provisions room.
to allow wetting down with of Regulatory cuide 1.75 all exposed cables shoul l
deluge water without electrical I
be covered with an
. faulting. Manual hose stations and portable hand extinguishers l
approved fire retardant should be provided as backup.
coating and a fixed Safety related equipment in che automatic water fire vicinity of such cable trays, suppression syste:n that does not itself require water should be provided.
~
fire protection, but is subject t
to unacceptable damage from sprinkler water discharge, should be protected from sprinkler system operation of malfunction.
(d) Cable and cable tray penetration of (d) SAME. Where installed fire barriers (vertical and bori-sontsi) should be sealed to give penetration _ seals are protection at least equivalent to deficient with respect
{
'that fire barrier. The design to fi're resistance, thes l
of fire barriers for horizontal seals t:ay be protected and vertical
- cable traye should, by covering both sides i
as a minimum, meet the tequire-with an approved fire ments of ASTM E-119. " Fire Test retardant material.
of Building Construction and The adequacy of using Haterials," including the hose such raterial should be stream test.
demomstrated by suitcble j
testang.
i (e) Fire breaks should be provided as
['.
deemed necessary by the fire (e) SAME hazards analysis. Flame or flame
~
retardant coatings may be used as a fire break for grouped elec-trical cables to limit spread of fire in cable ventings.
(possible cable derating owing to use of such i
4 l,
9.541-83 2/24/77 EXHIBIT IA PAGE 1 OF 1 PAGE(S)
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