ML19325C885

LER 89-010-00:on 890907,UL Test Results Indicated That Horizontally Mounted Prototype Fire Dampers Failed to Comply W/Requirements of Ul Std 555-1968.Caused by Discrepancies Between as-fabricated & Required specs.W/891009 Ltr

ML19325C885
Person / Time
Site:	Beaver Valley
Issue date:	09/09/1989
From:	Noonan T DUQUESNE LIGHT CO.
To:	NRC OFFICE OF INFORMATION RESOURCES MANAGEMENT (IRM)
References
LER-89-010-01, LER-89-10-1, ND3MNO:1971, NUDOCS 8910180015
Download: ML19325C885 (6)

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i Beaver Valley Power Station, Unit No. 1 Docket-No.-50-334, License No. DPR-66  !

LER 89-010-00 i x.

t United States Nuclear Regulatory Commission *

-Document' Control Desk

'dashington, DC 20555 Gentlemen: .l In accordance with Appendix A, Beaver Valley Technical  !

Specifications, the following Licensee Event Report is submitted j H

LER'89-010-00, 10 CFR 50.73.2.ii.A, " Unqualified Fire L.

Dampers". .

l- Very truly yours,  !

I T. P. Noonan  ;

General Manager -

Nuclear Operations  ;

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m ev. ,o.<, rvo.. , . o, .,> nsI on 9/7/89, Underwriters Laboratories (UL) notified Duquesne Light of the results of the fire testing for horizontally

. mounted prototype fire dampers applicable to Beaver Valley Power ,

Station Unit 1 conducted on 9/6/89. The test results indicated that the-dampers failed to comply with the requirements of UL Standard 555-1968 for a ninety (90) minute fire endurance and hose stream test. The applicable fire dampers were declared inoperable and compensatory actions were taken in the form of fire watches. An analysis was conducted to determine compliance as. outlined in 10CFR50 Appendix R. It was determined that redundant trains of equipment required for safe shutdown were potentially.affected, and therefore reportable in accordance with 10CFR50.73.a.2.ii.A. Fire watches will be maintained until

.the dampers are replaced or analyses performed to support the present configurations. There were no major safety implications due to this event since the installed ductwork and fire dampers, although lacking proper qualifications, would afford some protection to prevent the propagation of fire. Automatic fire

! suppression systems and early warning smoke detection systems are installed on at least one side of all affected barriers to mitigate the effects of a postulated fire event.

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DescriDtion of-Event L

r On September 7, 1989, Underwriters Laboratories (UL) notified

[: -Duquesne Light that the Horizontal Fire Dampers used at Beaver f - Valley Unit 1 did not meet UL Standard 555. Based on this, it was determined that the fire dampers were not qualified for a 90 l L minute fire rating.

g Duquesne Light- had requested the UL analysis after identifying l- 4 discrepancies between the dampers' "as-fabricated" condition and l the SMACNA (Sheet Metal and Air Conditioning Contractors National.

Association) Standards they were to have been built to. Duquesne Light had previously completed a data recovery and inspection l

program to identify the "as-fabricated" condition of the dampers.

Based on the results of this program, typical test models of horizontal and vertical fire dampers were prepared and sent to UL for testing.

On August 15, 1989, UL-testing of the vertical fire damper models was completed. These test models did not meet UL Standard 555 and  !

.;were determined to be unqualified. However, engineering analysis 2 determined that failure of these vertical fire dampers did not compromise more than one train of equipment required for safe shutdown-in accordance with 10 CFR 50 Appendix R. The vertical

' fire dampers were declared inoperable. Fire watches were posted in the areas associated with these dampers. The NRC was notified of the lack of qualification of the vertical fire dampers via a Special-Report dated September 15, 1989.  !

As stated above, on September 7, 1989, UL notified Duquesne Light that the horizontal fire damper models failed their fire endurance and hose stream tests (the tests required under UL Standard 555).

Based on this, the horizontal dampers were determined to be unqualified and subject to potential failure in the event of a fire. The horizontal fire dampers were declared inoperable

-The Nuclear Regulatory Commission was notified of this problem at 1044 hours0.0121 days <br />0.29 hours <br />0.00173 weeks <br />3.97242e-4 months <br />.on 9/8/89 in accordance with 10CFR50.72.b.2.1. The analysis identified that failure of the horizontal fire dampers could potentially affect redundant trains of equipment required for safe shutdown.

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Cause of Event The-Unit 1 Fire Dampers were_ fabricated nn-site during plant construction. -Damper specifications called for them to be constructed in accordance with UL-approved SMACNA specifications.

As stated above, it was subsequently identified'that discrepancies existed between the "as-fabricated" dampers and the SMACNA specifications'. Specifically, the "as-fabricated" dampers were constructed from heavier gauge steel than specified by SMACNA.

The welding used'in damper construction also did not conform to SMACNA specifications. The heavier gauge steel caused the dampers to retain more heat than dampers built to SMACNA specifications.

The various inconsistencies between the SMACNA design and that of the. installed dampers contributed to their failure when fire tested by UL. j j

Previous Similar Events j There has been one previous event (LER 87-017-00) involving Fire Dampers.that were found to be inoperable due to improper installation.

_Qorrective Actions The hourly roving and continuous fire watches will remain in effect until corrective actions are completed or analyses are performed to support the present configurations. Currently the i plans-are to replace all applicable fire dampers in affected areas with combustible loadings exceeding i hour as indicated in the

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10CFR50. Appendix R Fire Hazards Analysis. For areas that do not exceed 1 hour1.157407e-5 days <br />2.777778e-4 hours <br />1.653439e-6 weeks <br />3.805e-7 months <br /> combustible loading, an evaluation is being conducted on a case-by-case basis, to determine the acceptability of the existing sheet metal ductwork. This acceptability is based on' National Fire Protection Association (NFPA) Code 90A and UL Standard 263 " Fire Tests of Building Construction and Materials,"

which indicate that steel ductwork 0.022 inches thick (24 gauge) can withstand a fire for 1 hour1.157407e-5 days <br />2.777778e-4 hours <br />1.653439e-6 weeks <br />3.805e-7 months <br />. This methodology was recently approved at another facility by the NRC. The analysis is being conducted in accordance with the guidance provided in NRC Generic Letter 86-10, regarding unqualified, untested configurations.

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Safety Analysis '

The. inadequate fire rating of'the applicable horizontal fire dampers between the Cable Tray Mezzanine and the DF Emergency Switchgear Room, and the Cable Tray Mezzanine and the. Control Rod  ;

Drive MG Room could,-given a postulated fire in these affected areas, results in.a situation compromising redundant trains of safe shutdown equipment. This inadequacy resulted in an unanalyzed condition reportable under 10CFR50.73.a.2.ii.A. The equipment'potentially affected in these areas are the redundant emergency diesel generator control and power distribution system .

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There were no major safety-implications due to this event since the installed ductwork and fire dampers, although lacking proper qualifications would afford some protection to prevent the propagation of fire betweet,the affected areas. In addition, tne ,

Cable Tray Mezzanine area is provided with automatic fire suppression and an early warning smoke detection system. The DF Emergency Switchgear and Control Rod Drive MG Room are both  ?

provided with an-early warning smoke detection system. These '

systems'would have activated in the incipient stages of any postulated fire event to mitigate the effects of a-fire.

Therefore a fire of sufficient duration to compromise the existing fire barriers is' considered to be extremely improbable.

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