ML19308D562
| ML19308D562 | |
| Person / Time | |
|---|---|
| Site: | Brunswick  |
| Issue date: | 02/25/1980 |
| From: | Utley E CAROLINA POWER & LIGHT CO. |
| To: | Ippolito T Office of Nuclear Reactor Regulation |
| References | |
| NO-80-292, NUDOCS 8002290373 | |
| Download: ML19308D562 (5) | |
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Carolina Power & Light Company February 25, 1980 FILE: NG-3514(B)
SERIAL NO.: NO-80-292 Office of Nuclear Reactor Regulation ATIENTION:
Mr. T. A. Ippolito, Chief Operating Reactors Branch No. 3 United States Nuclear Regulatory Commission Washington, D.C.
20555 BRUNSWICK STEAM ELECTRIC PLANT, UNIT NOS. 1 AND 2 DOCKET NOS. 50-325 AND 50-324 LICENSE NOS. DPR-71 AND DPR-62 FIRE PROTECTION
Dear Mr. Ippolito:
During March,1979, Carolina Power & Light Company (CP&L) and NRC were working toward resolution of fire protection issues for Brunswick Steam Electric Plant (BSEP) Unit Nos. 1 and 2.
CP&L met with NRC and made several submittals to NRC requesting revisions to your November 22, 1977 SER.
In our discussions with NRC, labeling of fire door frames was one item recognized as needing resolution from the November 22, 1977 SER.
The SER required that fire door frames be labeled. While some existing frames at BSEP are still not labeled, we believe they are equivalent to a labeled frame. CP&L planned to submit justification to NRC demonstrating the adequacy of the existing frames in order to have the SER requirement revised. Apparently, since this was not a physical plant modification to be monitored, it was inadvertently overlooked during the Spring, 1979 refueling outages.
Brunswick Plant personnel discovered this omission in January, 1980 and promptly established appropriate compensatory measures at these doors in accordance with the " ACTION" statement of Technical Specification 3/4.7.8.
The equivalency of BSEP's existing door frames to labeled three-hour rated frames has been discussed with representatives of our insurance carrier and is satisfactory to them.
As an attachment to this letter, CP&L is transmitting our technical evaluation to justify that the existing, non-labeled fire door frames at BSEP are satisfactory for three-hour fire-rated service. We would appreciate an early review of this information and an appropriate approval from NRC accepting the existing BSEP fire door frames in lieu of labeled fire door frames as presently required in the SER.
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- P. O. Box 1551
- Raleigh. N C. 27602
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4 Please call my staff if you have questions,'or if you need any additional information.
Yours very truly, l/'h, E. E. Utley Executive Vice President Power Supply & Customer Services JAM /je (5793)
Attachment 5
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i CAROLINA POWER & LIGHT COMPANY BRUNSWICK STEAM ELECTRIC PLANT UNIT NOS. 1 AND 2 FIRE DOOR FRAMES
Background:
Section 5.8.3 of the BSEP Fire Protection Safety Evaluation Report (SER) points out that fire door frames in the Diesel Generator Building fire barriers are not labeled to indicate a three-hour rating.
Section 5.8.6(2) of the SER states that BSEP will replace these frames with labeled frames.
Request:
Af ter reviewing the existing fire door frame construction and installation details and comparing them with commercially available labeled frames, CP&L believes that the existing frames are equivalent or superior. Accordingly, CP&L requests that NRC approve the use of the existing BSEP fire door frames (described herein) in lieu of labeled three-hour fire rated door frames.
Justification:
The above request is considered justified based on CP&L's analysis of the frame design and installation details.
Further, an independent evaluation conducted by a registered professional engineer who serves as a fire protection consultant to the plant's insurance carrier has also found the frames satisfactory for the intended purpose. CP&L's analysis is attached.
Evaluation:
A description of the construction details is given below.
Additionally, two drawings are. included which show the details of the installation. Drawing 9527-F-1694 shows details of the original channel frames and Drawing 7000-DG-2 shows the details of the adaptor frames including modification of the channel frames to allow their installation. Any additicnal data you may require will be forwarded on request.
Construction Details:
The frames in question are adaptor type frames fabricated and installed to design documents provided by the Sonicbar Door Division of Rysdon Products Company.
Frame material is 1/4 inch structural steel meeting the specifications of ASTM A36.
The adaptor frames are welded to existing channel frames with bar spacers between the two to permit proper frame alignment and permit anchoring of the adaptor-frame. The space between the two frames is. filled with grout.
4 CAROLINA POWER & LIGHT COMPANY BRUNSWICK STEAM ELECTRIC PLANT UNIT NOS. 1 AND 2 FIRE DOOR FRAME ANALYSIS The ability ot a fire barrier or a fire barrier penetration sealing component to perform its intended function is dependent on three factors.
These are the continued structural integrity of the barrier or component, its thermal con-ductivity (i.e. - the ability of the component to prevent the occurrence of " hot spots" on the non-exposed side), and the completeness of the barrier (i.e. - the number and size of holes in the barrier). The existing BSEP frames have been analyzed with regard to each of these three factors. The results of this analysis are as follows:
1.
Structural Integrity - The factors affecting the ability of the frame to withstand a three-hour fire test are the combustibility of the frame material, the ability of the frame components to withstand compression loadings without buckling, the resistance of the frame components to assymetrical stresses (bending stresses) resulting from the temperature gradient across the frame, the thermal expansion characteristics of the frame material (this is the mechanism which produces the various loadings experienced by the frame during c fire), the ability of the anchoring system to prevent dis-tortion, and the change in structural properties of the material with changing temperatures. These topics are discussed individually.
Combustibility: The frames are constructed of non-combustible materials.
Compression (Buckling): Ability of a structural shape to withstand axial loading is dependent on the characteristics of the material, the nature of support and end fastenings, and moment of inertia of the shape's cross-section. Comparison with commercially available labeled frames indicates that the existing frame is equal or superior in all respects.
Thermal Expansion:
The thermal expansion of the structural material is the prime factor in establishing the compressive and bending stresses on the frame members during a fire exposure. A comparison of the materials in the existing frame and those in the commercially available labeled frame are es-sentially identical.
O Assymetrical Stresses: During a fire exposure asymmetrical stresses (b,end-ing stresses) are applied to the frame members due to the temperature gradient across the frame in concert with the frame material's thermal expansion characteristics.
In comparing the existing frames with commercially available labeled frames, it can be seen that the cross-sectional area of the heat transfer path from the inner face to the outer face of the installed frame is much larger. Thus, the bending stresses developed on the members of the existing frame would be less as a result of the reduced temperature gradient developed.
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h Anchoring Design: The design of the anchoring system is vital to minimizing frame distortion during a fire. The design of the anchors for the existing frame are equivalent or superior to those provided for commercially available frames with respect to size, number, configuration and placement.
Structuraf Properties:
The change in the structural properties of steel with changes in temperature are of concern in the design of fire rated structures. The properties exhibited by the installed frames are equivalent to those of commercially availabic frames.
2.
Thermal Conductivity - The thermal conductivity of the material used in the existing _ frames is the same as that for commercially availabic frames.
Thus, exterior (non-exposed) surface temperatures of the existing frame will react identically to an exposure fire as would a labeled frame except for response t ime. The difference in response tine would be affected primarily by the cross-sectional area of the thermal conduction path. Thus, the non-exposed surface temperature of the existing frame would not exceed that for a labeled frame for a three-hour fire.
3.
Completeness - The cc pleteness of a barrier refers to the size of any un-sealed openings in e 'aarrier.
In the case of the door / frame units con-cerned, the amount of unsealed opening is dictated by the provisions of NFPA 80, Standard for Fire Doors and Windows. The same requirements apply to a labeled frame assembly. Additionally, considering the superior structural design of the installed frames, any increase in the unsealed opening area due to frame distortion in a fire would be less than with a labeled frame.
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