ML20011D771
| ML20011D771 | |
| Person / Time | |
|---|---|
| Site: | Beaver Valley |
| Issue date: | 12/19/1989 |
| From: | Sieber J DUQUESNE LIGHT CO. |
| To: | NRC OFFICE OF INFORMATION RESOURCES MANAGEMENT (IRM) |
| References | |
| TAC-56566, NUDOCS 8912280387 | |
| Download: ML20011D771 (60) | |
Text
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aver Vahey Power Station SNppingport PA 15077A)D4 f
h JOHN D.SIEB.IR
- v. p..
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a m 5o 6755 December 19, 1989 U.
S.
Nuclear Regulatory Commission Attn Document Control Desk Washington, DC 20555-L
Reference:
Beaver Valley Power Station, Unit No. 1
~
Docket No. 50-334,. License No. DPR-66 (TAC 56566)
Gentlemen:
By NRC letter dated December 4, 1986, Duquesne Light Company
' (DLC) was requested to provide fire test results'for the: subject fire dampers demonstrating fire resistance ratings equivalent to those required - of the barriers.
A submittal was filed on September 29,
- 1987, outlining DLC's program for qualifying the j
existing fire dampers.
To keep NRC apprised of the status, a report was provided on November 30, 1988 which summarized our efforts and provided a projected schedule for completion.
On August 15,
- 1989, DLC received the results of the fire testing for the vertically mounted prototype fire dampers from Underwriter's Laboratories (UL).
The failure. of. the fire endurance and hose stream testing (per UL Standard-555) prompted-the issushc6 6f & 9966181 fdp6ft t6 the Commission ~ dated September 15, 1989.
On September 7,
1989, UL notified DLC of. the failed test results for the horizontally mounted prototype-fire dampers, and a
License Event Report (LER 89-010) was submitted on October 9,
1989.
In each case, compensatory measures were taken in the form of fire watches or tours for.the affected areas.
As outlined in LER 89-010, the fire watch patrols:will remain in effect until corrective actions.have been completed:
1.
For fire areas with combustible loading exceeding 1 hour1.157407e-5 days <br />2.777778e-4 hours <br />1.653439e-6 weeks <br />3.805e-7 months <br /> (i.e.
the cable vaults-and cable tray mezzanine), our plans i
are to replace all fire dampers affected by the UL fire test results (a total of 17 fire dampers).
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Banvar Valley Pow 3r Station, Unit No. 1 Docket No. 50-334,-License No. DPR-66 TAC 56566 Page 2 2.
For fire areas with combustible loading less than one (1)
- hour, an evaluation will be conducted, on a case-by-case
- basis, to determine the acceptability of the existing sheet metal ductwork.
Item 1,
under corrective action noted above (replacement of the fire dampers) is in progress.
An engineering specification has been established and proposals are being received from vendors.
The replacement and installation of the fire dampers in these vital plant areas is unfeasible during power operation due to the cutting and welding of ductwork, isolating ventilation systems supplying vital areas, de-energizing the fire suppression CO systems and the scope ~ o f-work in the cable vaults and the 2
cable tray mezzanine (located directly below the-control room).
Engineering,
- design, procurement and pre-fabrication activities that can be accomplished outside the affected areas will be pursued.
Actual installation work will be performed during the next refueling outage at Unit 1.
In the interim, compensatory measures in the form of fire watch patrols will remain in effect.
Item 2,
associated with the evaluation of'the ductwork in areas where the combustible loading is less than 1 hour1.157407e-5 days <br />2.777778e-4 hours <br />1.653439e-6 weeks <br />3.805e-7 months <br />, has been completed, and the summary results are enclosed as Attachment 1.
The analysis supports the present configurations 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 satisfactorily 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 by the NRC for another facility.
The analysis was conducted in accordance with the guidance provided in Generic Letter 86-10 for unqualified,. untested configurations.
The attached evaluations and detailed sketches provide'the basis for our position and address each ventilation duct. penetration on a case-by-case basis.
Parameters such as location of fire dampers, i
HVAC system and ductwork, direction of air flow, location of duct
- openings, and amounts of combustibles (both fixed and transient) l have been examined for each area.
Based on the satisfactory results of the
- analysis, we have determined that compensatory measures in the form of fire watches for these affected areas are no longer necessary.
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Beaver Valley Power Station, Unit Nos. 1 Docket No. 50-334, License No. DPR-66 TAC 56566 Page 3 Since the existing fire
- dampers, although lacking proper qualifications and
- labeling, would afford some protection in preventing the propagation of
- fire, we have decided to leave the dampers in place.
They will be maintained and tested with all other fire-rated dampers based on good fire protection practices.
I t' there are any questions or clarifications, please contact my staff.
Very truly yours, D. Sieber Vj.ce President Nuclear Group cc:
Mr. J.
Beall, Sr. Resident Inspector Mr. W. T. Russell, NRC Region I Administrator Mr.
P. Tam, Sr. Project Manager Mr. R. Saunders (VEPCO)
Mr. Cliff Anderson, NRC Region 1
r i
ATTACHMENT 1 EHQINEERING EVALUATIONS Index:
EV-1:
FIRE DAMPERS IN THE EMERGENCY SWITCHGEAR ROOMS EV-2:
FIRE DAMPERS IN THE MAIN STEAM VALVE AREA EV-3:
FIRE DAMPERS IN THE-MOTOR CONTROL CENTER ROOM EV-4:
FIRE DAMPERS IN THE CABLE VAULT AREA VENTILATION ROOM EV-5:
FIRE DAMPERS IN THE BLOWDOWN TANK AREA EV-6:
FIRE DAMPERS IN THE AUXILIARY' BUILDING AND SERVICE BUILDING l
EV-7:
FIRE DAMPERS IN THE AUXILIARY BUILDING AND FUEL BUILDING' EV-8:
FIRE DAMPER IN THE AUXILIARY FEEDWATER PUMP ROOM 4
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ENGINEERING EVALUATION, EV1 FIRE DAPFERS IN THE EERGENCY SWITCHGEAR ROOMS BEAVER VALLEY POWER STATION - UNIT 1 i
1.0 PURPOSE The purpose of this engineering evaluation is to document the 5
4 acceptability of the fire barrier duct penetrations between the redundant Emergency Switchgear Rooms, protected by unqualified fire dampers.
This evaluation is performed in accordance with the provisions of Generic Letter _ 86-10.
Criteria for evaluating-the fire area boundaries are based on Section D.1(j) of Appendix A to BTP APCSB 9.5-1 guidelines.
2.0 BACKGROUND
On Agust 29, 1989, Duquesne Light Company _ (DLC) issued a special report to the NRC regarding the failure of prototype fire dampers to pass the Underwriter's Laboratories-(UL) tests as required by l
Standard 555-1968.
The subject dampers in this evaluation, VS-D-263 and VS-D-266 are similar to the aforementioned prototype.
These dampers are installed in the exhaust air duct penetrating ' the fire rated barrier wall between the two Emergency Switchgear Rooms, Orange (Fire Area ES-1) and Purple (Fire Area ES-2).
These dampers have been field fabricated by Schneider Sheet Metal in accordance with Sheet Metal and Air Conditioning Contractors National. Association (SMACNA) specifications for a fire rating of 1 1/2 hour.
The contractor did not obtain the UL fire rating label for the dampers.
This necessitated a request for exemption from. NRC guidelines by L
DLC in October 1986.
Following the staff's safety evaluation, the NRC concluded that-the fire damper design was not an acceptable deviation, 'and recommended that fire tests be performed to demonstrate that the fire resistance rating of the dampers was equivalent to that required of the' barriers in which they were installed.
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2 i
e Complying with the NRC's recommendation. DLC fabricated prototypes of all dam;;er configurations subject to the deviation and submitted them to UL for testing in accordance with Standard 555-1968.
The i
subject prototypes failed the fire endurance and hose stream tests, Upon receiving the UL failed test report, DLC has declared the applicable dampers inoperable.
Hourly roving fire watches have been implemented for the affected areas and will remain in effect until an evaluation demonstrates the acceptability of the present l
configuration or corrective actions, if necessary, are completed.
3.0 REFERENCES
i 3.1 NRC Generic. Letter 86-10
}
3.2 ' Beaver Valley Unit 1 Appendix R Review
.l 3.3 Fire Protection Handbook,16th Edition 3.4 Underwriter's Laboratories (UL) - Fact Finding Report on " Air Duct Penetrations Through One Hour Fire Resistive Wall Assembly" dated April 17, 1985.
l 3.5 Sandia Fire Protection Research Program Corner Effects Tests
- and 79-0966.
3.6 Calculation 8700-DMC-2341-0 4.0. ANALYSIS
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4.1 CONFIGURATION
'?
i The boundary walls of' the Emergency Switchgear Rooms (ES-1 and.ES-2) j are reinforced concrete of a minimum 12 in, thickness.
The ceiling is a minimum 4 in. concrete slab on steel decking.
The ~ supporting structural steel is fire proofed for 3 hour3.472222e-5 days <br />8.333333e-4 hours <br />4.960317e-6 weeks <br />1.1415e-6 months <br /> fire rating.
The two-l 1
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L areas are separated by a 12 inch, reinforced concrete wall provided with a 3 hour3.472222e-5 days <br />8.333333e-4 hours <br />4.960317e-6 weeks <br />1.1415e-6 months <br /> rated door.
All perimeter doors are 3 hour3.472222e-5 days <br />8.333333e-4 hours <br />4.960317e-6 weeks <br />1.1415e-6 months <br /> fire rated.
Penetrations of walls and ceiling have been sealed to ensure the integrity of the barrier.
Two station emergency battery rooms are located within each of the emergency switchgear rooms.
The battery rooms associated with one of the' safety-related trains are located within the perimeter - of the respective emergency switchgear area.
Each battery room is constructed of 12 inch - concrete block walls with a 5 inch concrete ceiling slab on steel decking.
The battery room doors are not fire ated since they - have fixed open louvers to allow for make-up air to be drawn in from the respective emergency
_l switchgear room.
One of the two redundant emergency powered fans j
exhausts air from all four battery. rooms to maintain the hydrogen j
concentration at less than one percent by volume in each room.
The common exhaust duct is located above the battery room ceiling and penetrates the wall separating the two emergency switchgear rooms.
l The duct penetration is protected -by the unqua'11fied fire damper i
VS-D-263.
A -second branch of the main common air exhaust duct, exhausts air from the emergency switchgear rooms. This branch, located close and in parallel with the battery room exhaust branch, begins with an opening in the wall separating the' two emergency switchgear j
rooms.
The opening which constitutes the exhaust air intake for the emergency switchgear room corresponding to the Purple train (ES-2) l is protected by the unqualified fire damper VS-D-266.
(See attached Sketches No. SK-14760-1. Sheet 1 & 2).
All ductwork_ is seismically supported.
Ductwork penetrations are adequately sealed with fire resistant material.
i 4.2 EQUIPENT Redundant safety-related 4KV switchgears, 480 V substations, 480 V motor control centers, 125 V de batteries, battery chargers, DC switchboards, inverters, vital bus, 120 V ac distribution panels are located in each of the emergency switchgear areas and supply power to Class 1E circuits required for safe shutdown.
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4.3 C0leUST!BLES Combustibles concentration in both emergency switchgear rooms is limited to cable insulation.
The calculated fire loading based on the cable insulation heat of combustion of 11,000 BTV/LB is 37,770 BTV/sq.
ft, for ES-1 area and 26,545 BTU /sq.
ft.
for ES-2, corresponding to a fire severity of approximately 28 minutes and 20 minutes respectively (Ref. 3.2).
4.4 OTHER CONSIDERATIONS
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Fire detection consisting of area ionization coverage is provided in both emergency switchgear rooms with control room and local elam.
The availability of portable extinguishers, in the emergency switchgear rooms, of hose racks at the access stairwells and 150 lb wheeled dry chemical extinguisher located at the same elevation in the Service Building ensure auequate fire protection capability in accordance with the recommendations of Appendix "A" to BTP APCSP 9.5-1 Section F.5.
b To preclude hydrogen concentration buildup, each of the battery rooms is provided with an air flow switch installed in the ventilation duct to annunciate the control room when low flow condition occurs.
Electric sensor detection wired to the control room alarm circuit for flow trip is also provided for remote indication of a fire damper closure.
4.5 SUISWtY OF ANALYSIS A calculation has been performed to demonstrate the impact on one of the Emergency Switchgear rooms of a fire occurring in the adjacent Emergency Switchgear room (Ref. 3.6).
The calculation uses input from the Sandia Test Report (Ref. 3.5).
No credit is taken for the unqualified fire dampers VS-D-263 and VS-D-266.
5 When the exhaust air system is operating, air is flowing from ES-2 into the ES-1 area through the ventilation ductwork.
The calculated fire loading in ES-2 area is equivalent to a fire severity of 20 minutes (Ref. 3.2).
UL tests (Ref. 3.4) were performed on a galvanized duct assembly fabricated from 0.022 in, sheet metal.
Material subjected to a maximum temperature of 1700'F corresponding to a one
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hour duration test on the ASTM E 119 time-temperature curve showed the specimen to maintain its integrity. The ductwork installed in the Emergency Switchgear rooms ES-1 and ES-2 at Beaver Valley Power i
i Station. Unit 1 is galvanized 20 gauge with a minimum thickness of I
0.036 in, and therefore, the air exhaust ductwork can be assumed to maintain its integrity.
j The calculation investigates four cases performing a heat balance for each case.
i The methodology used is to determine a peak temperature for the postulated fire room by modeling the room as a furnace, taking credit
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for heat sinks attributed to the major room components.
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The following cases have been examined:
Case A:
Heat from a corner type cable tray fire including j
only cables in ES-2 area within a 20 foot distance i
surrounding VS-D-266, and additional heat generated by transient combustion one gallon of Heptane.
The resulting peak temperature of air flowing into ES-1 was calculated to be 182'F.
Case B:
In this case air temperature in the Battery Room
+
No. 4 was calculated based on the heat generated by the combustion of one gallon of Heptane.
Considering the exhaust air system operating, air from the Battery Room No.
4 will mix with air exhausted from the adjacent Battery Room at the i
ambient temperature of 104*F.
The resulting air l
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6 temperature flowing into the ES-1 area through the damper YS-D-263 was calculated to be 152'F.
Case C: The peak temperature was calculated using as combustible value all the cables installed in the ES-1 area and the additional heat generated by the combustion of one gallon of Heptane.
In this case the exhaust air system is assumed to be shutdown, consequently heat may be partially transferred into
)
ES-2 area by natural convection.
The resulting room air temperature in ES-1, considering the major heat sinks is 210'F.
Case D: Using the same approach as in Case C the resulting i
room air temperature in ES-2 area is 212'F.
In all four cases investigated the resulting tentperature in the assumed
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fire room is below the 325'F maximum accepted temperature on the
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cold side of a fire rated barrier wall and well below the critical temperature of 450'F at which cables begin to degrade.
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A supplementary analysis has been performed to gain an appreciation i
of the duct wall temperature behavior under a hypothetical condition, j
For this analysis an arbitrary value of 300'F v;as selected for the I
damper VS-D-26C inlet air temperature.
Considering this entering.
I air temperature, an average duct wall temperature of 265'F has resulted for the first 10 feet of duct inside the ES-1 area.
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5.0 CONCLUSION
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Based on the following:
o Low combustible loading in both Emergency Switchgear Rooms and particularly in the vicinity of the ductwork, o Steel construction of the ductwork heavier gauge than that tested by UL for one hour resistance.
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7 o Resulting insignificant effects of the heat transmitted through the unprotected ducts on safe shutdown components in the adjacent a rea,
o Fire detection system and r adily available fire suppression I
means.
replacing the existing fire dampers VS-D-263 and VS-D-266 with UL i
qualified dampers would not significantly increase the level of plant i
fire safety.
]
Consequently a fire in one of the switchgear rooms will not prevent equipment and cables in the adjacent area to perform their safe shutdown functions.
In addition the adverse affect of inadvertent operation of the fire suppression system is not considered since neither Emergency Switchgear room is provided with an automatic fire suppression system.
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@ WEST EMERGENCY SWITcHGEAR Room (E s.- 2.)
( E. 5. - 1)
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SECTION 1-1 FROM SHT t DuoutsME uGHT cof1PANY UNIT 1 E.rMt#JEE1ttrJG EVALU ATiotJ A R E/\\
E V-l E MER GENCY SW I TC M GE A SC ARCA FOR VS-D- 2G5 5 ZGG SK-147G C -l SNTI
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ENGINEERING EVALUATION, EV2 FIRE DAMPERS IN TE MAIN STEAN VALVE AREA BEAVER VALLEY POWER STATION - UNIT 1 1.0 PURPOSE The purpose of this engineering evaluation is to document the j
acceptability of the fire barrier duct penetrations in the Main Steam Valve Area (MS-1), protected by unqualified fire dampers.
This
]
evaluation is performed in accordance with the provisions of Generic Letter 86-10.
Criteria for evaluating the fire area boundaries are based on Section D.1(j) of Appendix A to BTP APCSB 9.5-1 guidelines.
I
2.0 BACKGROUND
1 On August 29, 1989. Duquesne Light Company (DLC) issued a special report to the NRC regarding the failure of rototype fire dampers to pass the Underwriter's Laboratories (UL) tests as required by l
Standard 555-1968.
The subject dampers in this evaluation VS-D-162 f
and VS-D-163 are similar to the aforementioned prototype.
These dampers are installed in the air ducts penetrating the fire rated barrier wall between the Ventilation Equipment Room and the space west of the protective wall in the Main Steam Valve area. El. 756'-0".
These dampers have been field fabricated by Schneider Sheet Metal in accordance with Sheet Metal and Air Conditioning Contractors National Association (SMACNA) specifications for a fire rating of 1 1/2 hour.
The contractor did not obtain the UL fire rating label for the dampers.
This necessitated a request for exemption from NRC guidelines by DLC in October 1986.
Following the staff's safety evaluation, the NRC concluded that the fire damper design was - not an acceptable deviation, and recomended that fire tests be performed i
to demonstrate that the fire resistance rating of the dampers was equivalent to that required of the barriers in which they were installed.
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2 Complying with the NRC's recomendation. DLC fabricated prototypes i
of all damper configurations subject to the deviation and submitted them to UL for testing in accordance with Standard $55-1968.
The subject prototypes failed the fire endurance and hose stream tests.
Upon receiving the UL failed test report, Duquesne Light has declared the applicable dampers inoperable.
Hourly roving fire watches have been implemented for the affected areas and will remain in effect until an evaluation demonstrates the acceptability of the present configuration or corrective actions, if necessary, are completed, i
3.0 REFERENCES
3.1 NRC Generic Letter 86-10 j
3.2 Beaver Valley Unit 1 Appendix R Review 3.3 Fire Protection Handbook, 16th Edition i
1 3.4 Underwriter's Laboratories (UL) - Fact Finding Report on "Ai r Duct Penetrations Through One Hour Fire Resistive Wall Assembly" dated April 17, 1985, t
3.5 Calculation No. 8700-DMC-2341-0 4.0 ANALYSIS 4.1 CONFIGURATION The Ventilation Equipment room, part of the fire area PT-1, is separated from the adjacent fire area MS-1 Main Steam Valve area by a 24 inch. reinforced concrete wall provided with a 3 hour3.472222e-5 days <br />8.333333e-4 hours <br />4.960317e-6 weeks <br />1.1415e-6 months <br /> fire l
rated door.
Non fire rated-partitions in the Main Steam Valve area l
create personnel refuge spaces on the East and West sides of the main steam valves and piping.
The wall between the Ventilation I
Equipment room and the personnel refuge space en the west side -of i
1
3 the Main Steam Yalve area is penetrated by two air conditioning system ducts (supply air and return air from and to the air conditioning unitVS-AC-6).
The ducts are protected by unqualified dampers VS-D-162 and VS-D-163, installed at bottom elevation 757'-6",
6 '- 6" above the finished floor (See attached Sketch No. SK-14760-2, Sh. 1).
The air conditioning ducts are constructed of galvanized 20 gauge sheet metal with a minimum thickness of 0.036 inch.
This is of a heavier gauge than that tested by UL for one hour fire resistance when subjected to a furnace temperature of 1700*F. equivalent to one hour duration based on ASTM E 119 time-temperature curve.
The ductwork is seismically supported.
All duct penetrations through fire walls are adequately sealed with fire resistant material.
4.2 EQUIP 9ENT The Mechanical Equipment room houses the non safety related air conditioning unit VS-AC-6 which serves the Main Steam Yalve area El. 751'-0" and the - Steam Generator Blowdown room. El. 767'-10".
Cables in the Mechanical Equipment room are installed in conduits.
There is no equipment or cables located in the personnel refuge space.
The Main Steam Valve area El. 751'-0" houses the main steam trip valves, atmospheric steam dump valves, residual heat release valve, main steam safety valves, MSIV bypass valves and steam supply valves for the turbine driven auxiliary feedwater. pump.
4.3 COBOUSTIBLES There are no pennanent combustibles in either the Mechanical Equipment room or the personnel refuge area.
4.4 OTHER CONSIDERATIONS Hose' reel station located the Mechanical Equipment room backed up by portable extinguishers provide adequate means of fire protection.
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5 4.5 10MutY OF ANALYSIS With the lack of pemanent combustibles on both sides of the wall incorporating the fire dampers VS-D-162 and VS-D-163 only one gallon of Heptane as transient combustible has been considered to determine the impact on the fire barrier of a fire occurring on either side of the wall.
This evaluation is bounded by the air temperature calculated for Evaluation EV-1 of 200'F. (Ref. 3.5)
This is a conservative approach since the building components acting as heat sink in the Mechanical Equipment room as well as in the Main Steam valve area of the MS-1 fire area are larger than those considered for the Battery Room calculation.
Consequently, it is reasonable to consider that the heat generated by combustion of one gallon of Heptane will neither jeopardize the integrity of the air conditioning ductwork based on the UL test results (Ref. 3.4) nor will result in the temperature on the cold side of the fire barrier higher than the 325'F maximum accepted criterion for a fire rated barrier wall.
5.0 CONCLUSION
S Based on the following:
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l o Lack of permanent combustibles in both the Mechanical Equipment room and the personnel refuge area, o No equipment required for plant safe shutdown in case of fire located in the Mechanical Equipment room or in the personnel refuge area, o Steel construction of the ductwork heavier gauge than that tested by UL for one hour resistance, c
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o Resulting low heat generated by the potential transient combustible, which are administratively controlled, Manual fire suppression means readily available, o
replacing the existing fire dampers VS-D-162 and VS-D-163 with UL qualified dampers would not significantly increase the level of plant fire safety.
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ENGINEERING EVALUATION, EY3 i
FIRE DAMPERS IN THE MOTOR CONTROL CENTER ROOM BEAVER VALLEY POWER STATION - UNIT 1 1.0 PURPOSE The purpose of th's engineering evaluation is to document the f
acceptability of the fire barrier duct penetrations between the Motor Control Center (MCC) room in fire area MS-1 and the Purge / Exhaust duct This area on elevation 756'-0", protected by unqualified fire dampers.
evaluation is performed in accordance with the provisions of Generic i
Criteria for evaluating the fire area boundaries are Letter 86-10.
l based on Section D.1(j) of Appendix A to BT.P APCSB 9.51 guidelines.
2.0 BACKGROUND
On August 29, 1989, Duquesne Light Company (DLC) issued a special report to the NRC regarding the failure of prototype fire dampers to pass the Underwriter's Laboratories (UL) tests as required by Standard 555-1968.
The subject dampers in this evaluation, VS-D'-165, VS-D-166, and VS-D-167, are similar to the aforementioned prototype.
These dampers are installed in exhaust ductwork located at the south wall of the MCC room at elevation 756'-0".
This exhaust ductwork services the MCC room and the mainsteam valve area and penetrates the wall through to the adjacent Purge / Exhaust duct area.
These dampers were field fabricated by Schneider Sheet Metal in accordance with Sheet Metal and Air Conditioning Contractors National Association (SMACNA) specifications for a fire rating of i 1/2 hour.
The contractor did not obtain the UL fire rating lebel for the dampers.
This necessitated a request for l
exemption from NRC guidelines by DLC in October 1986.
Following the staff's safety evaluation, the NRC concluded that the fire damper design was not an acceptable deviation, and recommended that fire tests be performed to demonstrate that the fire resistance rating of the j
dampers was equivalent to that required of the barriers in which they l
were installed.
Complying with the NRC's recommendation, DLC fabricated prototypes of all damper configurations subject to the deviation and submitted them to UL for testing in accordance with Standard 555-1968.
The subject prototypes failed the fire endurance and hose stream tests.
I Upon receipt of the UL failed test report, DLC has declared the Hourly roving fire watches have been applicable dampers inoperable.
instituted for the affected areas and will remain in effect until an evaluation demonstrates the acceptability of the present configuration or corrective actions, if necessary, are completed.
l l
1 l
71160-1778119-B3
[
a
3.0 REFERENCES
3.1 NRC Ceneric Letter 86-10 3.2-Beaver valley Unit 1 Appendix R Review 3.3 Fire Protection Handbook, 16th Edition Fact Finding Report on " Air 3.4 Underwriter's Laboratories (UL)
Duet Penetrations Through One Hour Fire Resistive Wall Assembly" dated April 17, 1985.
3.5 Duquesne Light Company Design Analysis No. 8700-DMC-2341-0 4.0 ANALYSIS 4.1 CONFIGURATION The areas of concern in this evaluation are shown on sketches SK-19760-3 Sheets 1 and 2.
The three subject dampers, VS.J-165, 166, and 167, are located in ductwork which penetrates the sout's wall of the Motor Control Center portion of fire area MS-1.
This 24-inch reinforced concrete wall and the stairwell separate the MCC Room from the Purge / Exhaust duct area within the Safeguards. Area structure.
The ductwork supplies and exhausts air to and from the MCC room and main steam valve area.
The Safeguards building including the MCC room and Purge / Exhaust duct area is a reinforced concrcte structure.
Ductwork is adequately supported with penetrations sealed with fire resistant material.
4.2 EQUIPMENT The MCC room houses MCC cabinets and associated conduit and cables, junction boxes, and wall mounted panels.
The majority of cables enter the cabinets directly through floor sleeves and through' conduit from above.
These MCC cabinets are not required for safe shut down of the plant. The room also houses ductwork and associated supports.
The adjacent Purge / Exhaust duct area contains ductwork,
- piping, supports and conduit as well as Purge Supply and Exhaust system containment isolation butterfly valves. These valves are closed during normal operation of the plant.
4.3 COMUSTIBLES The MCC room contains control cabinetry and two vertical cable trays located in the northeast corner approximately 20 feet from the subject fire dampers.
The contents of these trays in conjunction with the loading of a postulated transient combustible flammable liquid (1 gallon of heptane) are considered in.this evaluation.
There are administrative controls in place to limit transportation of flammable liquids to a quantity of one gallon.
71160-1778119-B3 2
_-____-______-_a
The Purge / Exhaust duct area on the south side of the subject fire wall contains no permanent combustibles.
Only the loading of a transient combustible source (1 gallon of heptane) will be considered in this evaluation.
4.4 OTHER CONSIDERATIONS Fire suppression is accomplished in these areas with a local hose station located on the west wall of the MCC rooms and with locally mounted portable existinguishers.
4.5 SLM4ARY OF ANALYSIS:
The MCC room contains control cabinetry and cable trays.
The combustable loading of two full cable trays coupled with a postulated 1 gallon of heptane combustible loading would not result in a temperature rise high enough to challenge the integrity of ductwork at the penetration. This conclusion is based on review of the calculation (Ref: 3.5) for evaluation EV-1.
In this calculation, the combustible contents of the emergency switchgear room consisted of a larger number of cable trays and the postulated 1 gallon of flammable liquid, and resulted in a peak area temperature of 182*F.
This evaluation (EV-3) is considered to be bounded by the results of the EV-1 evaluation, since there is a lower level of combustibles and proportionately higher quantity of heat sinks in these areas.
Therefore, the temperature in these areas due to a fire will be well below the 325'F acceptance criterion for fire barrier cold side temperature.
It should be noted that 0.022 inch thick (24 guage) sheetmetal duct has been successfully tested in accordance with ASTM E117 to withstand 1700'F for a duration of one hour (Ref: 3.4).
The ductwork installed in the MCC Room / Purge duct area is of heavier material (20 gauge, 0.036 thick) and therefore is assumed to maintain its integrity.
5.0 CONCLUSION
S Based on the following:
Minimal combustible loading in both the MCC room (MS-1) and the Purge / Exhaust duct area on elevation 756 ft - 0 in The steel construction of the ductwork with heavier gauge than that tested by UL for one hour resistance The resulting low heat generated by potential transient combustibles, which are administratively controlled Readily available fire suppression means 71160-1778119-B3 3
_j
Replacing the existing fire dampers VS-D-165, 166, and 167 with UL qualified dampers would not significantly increase the level of plant fire safety.
4 I
71160-1778119-B3 4
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4 EMINEERING EVALUATION, EV4 FIRE DAWERS IN THE CABLE VAULT AREA VENTILATION ROOM BEAVER VALLEY P0lR:R STATION - UNIT 1 1.0 PURPOSE The purpose of this engineering evaluation is to document the acceptability of the fire barrier duct penetration between the Cable Vault Area Ventilation Equipment room, elevation 735'-6" and the Upper Ventilation room, elevation 756'-0" protected by unqualified i
horizontal fire damper.
This evaluation is performed in accordance with the provisions of Generic Letter 86-10.
Criteria for evaluating j
the fire area boundaries are based on Section D.1(j) of Appendix A to BTP APCSB 9.5-1 guidelines.
3 I
2.0 BACKGROUND
j The fire dampers at Beaver Valley Power Station Unit I have been field fabricated by Schneider Sheet Metal in accordance with Sheet Metal and Air Conditioning Contractors National Association (SMACNA) specifications for a fire rating of 1 1/2 hour.
The contractor did not obtain the UL fire rating label for the dampers. This necessitated a request for exemption from NRC guidelines by Duquesne Light Company (DLC) in October 1986.
Following the staff's safety evaluation, the NRC concluded that the fire damper design was not an acceptable deviation, and recommended that fire tests be performed to demonstrate that the fire resistance rating of the dampers was equivalent to that required of the barriers in which they were installed, i
Complying with the NRC's recommendation. DLC fabricated prototypes of all damper configurations subject to the deviation and submitted them to UL for testing in accordance with Standard 55-1968.
The subject prototype for the horizontal damper failed the fire endurance and hose stream tests as reported by UL (letter dated September 7, i
1989).
One of the fire dampers installed in a similar configuration is YS-D-179 protecting the slab duct penetration between the Cable I
i l
l
2 Vault Area Ventilation Equipment room (El. 735"-6") and the Upper i
Ventilation room (El. 756'-0").
Subsequently. DLC submitted a License Event Report LER 89-010 on October 9,1989.
Upon receiving the UL failed test report. DLC has declared the applicable dampers inoperable.
Hourly roving fire watches have been
)
implemented for the affected areas and will remain in effect until
{
an evaluation demonstrates the acceptability of the present configuration or corrective actions, if necessary, are completed.
i
3.0 REFERENCES
3.1 NRC Generic Letter 86-10 1
3.2 Beaver Valley Unit 1 Appendix R Review 3.3 Fire Protection Handbook.16th Edition 3.4 Underwriter's Laboratories (UL) - Fact Finding Report on " Air Duct Penetrations Through One Hour Fire Resistive Wall Assembly" dated April 17, 1985.
3.5 Calculation No. 8700-DMC-2341-0 4.0 ANALYSIS 4.1 CONFIGURATION The Cable Vault Area Ventilation Equipment room, elevation 735'-6" is adjacent to the Reactor Building on one side and is enclosed by reinforced concrete walls. 2 feet thick, on the other sides.
All the boundary walls are qualified for 3 hour3.472222e-5 days <br />8.333333e-4 hours <br />4.960317e-6 weeks <br />1.1415e-6 months <br /> fire rating.
The door in the north wall is also qualified for 3 hour3.472222e-5 days <br />8.333333e-4 hours <br />4.960317e-6 weeks <br />1.1415e-6 months <br /> fire rating.
The 18 inch reinforced concrete ceiling slab is penetrated by a 15 x 20 inch air conditioning supply ductwork protected by the unqualified horizontal fire damper VS-D-179.
The seismically supported duct
= _ _ -
3 is constructed of galvanized 20 gaage sheet raetal with a minimum thickness of 0.036 inch.
This is of a heavier gauge than that tested by UL for one hour fire resistance when subjected to a furnace i
temperature of 1700*F, equivalent to one hour duration based on ASTM E119 time, temperature curve (Reference 3.4).
The ductwork penetration is adequately sealed with fire resistant material.
1 4.2 EQUIPDENT The Cable Vault Area Ventilation Equipment room, elevation 735"-6",
houses the nonsafety-related air conditioning unit VS-AC-8.
This i
unit supplies air to the East Cable Vault Area, elevation 735'-6" and to the Motor Control Center in the Main Steam Valve Area elevation 7 56 '- 0".
There is no equipment located in the Upper Ventilation room, elevation 756'-0" (attached sketches SK-14760-4 sheet 1 and 2).
4.3 CopWUSTIBLES There are minimal combustibles (belts, etc.) associated with the ventilation equipment in the Cable Vault area Ventilation room.
4.4 OTHER CONSIDERATIONS Portable extinguishers located in the adjacent East Cable Vault area, elevation 735'-6" and a hose reel station located in the stairwell I
between cable vault rooms, provide adequate means of fire protection.
i 4.5 SulORRY OF ANALYSIS With the minimal amount of combustibles located below and above the slab incorporating the fire damper VS-D-179 only one gallon of Heptane (as transient combustible) has been considered to get an appreciation of the impact on the. fire barrier of a fire event occurring in the Cable Vault Area Ventilation Equipment room (elevation 735'-6").
l
4 This evaluation is bounded by the air temperature of 200'F calculated for Evaluation EV-1 (Ref. 3.5).
This is a conservative approach since the building components acting as heat sink in the area analyzed i
in this evaluation are larger than those considered for the Battery Room calculation (EV-1).
Consequently, it is reasonable to consider that the heat generated by combustion of one gallon of Heptane will neither jeopardize the integri t,,
of the air conditioning ductwork based on the VL test results (Ref. 3.4) nor will result in the temperature on the cold side of the fire barrier higher than the 325'F maximum accepted criterion for a fire rated barrier wall.
5.0 CONCLUSION
S Based on the following:
l 4
o Lack of permanent combustibles in the ventilation equipment
- rooms, o
No equipment required for plant safe shutdown in case of fire located in the ventilation equipment rooms, i
i o
Steel construction of the ductwork heavier gauge than that tested by VL for one hour resistance, o
Resulting low heat generated by the potential transient combustible, which are administratively controlled, o
Manual fire suppression means readily available, e
replacing the existing fire damper VS-D-179 with UL qualified damper would not significantly increase the level of plant fire safety.
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i ENGINEERING EVALUATION, EV5
)
FIRE DAMPERS IN THE BLOWDOWN TANK AREA j
BEAVER VALLEY POWER STATION - UNIT 1 1.0 PURPOSE The purpose of this engineering evaluation is to document the accept-ability of the fire barrier duct penetrations between the Blowdown Tank i
Area, the Personnel Hatch area, and Auxiliary Building on elevation 767'-10".
These penetrations are protected by unqualified fire damp-ers. This evaluation is performed in accordance with the provisions of Generic Letter 86-10.
Criteria for evaluating the fire area boundaries I
are based on Section D.1(j) of Appendix A to BTP APCSB 9.5-1 i
guidelines.
2.0 BACKGROUNO On August 29, 1989, Duquesne Light Company (DLC) issued a special report to the NRC regarding the failure of prototype fire dampers to pass the Underwriter's Laboratories (UL) tests as required by Standard 555-1968.
The subject dampers in this evaluation; VS-D-170, VS-D-171, VS-D-172, VS-D-173, VS-D-174, VS-D-175, VS-D-176,_ and VS-D-178 are similar to the aforementioned prototype.
These dampers are installed in containment purge supply and exhaust ducts, safeguards exhaust ducts, and fuel building exhaust ducts which penetrate the reinforced concrete wall between the Blowdown Tank Area, the Personnel Hatch area, and the Auxiliary Building on elevation 767'-10".
These dampers were field fabricated by Schneider Sheet Metal in accor-dance with Sheet Metal and Air Conditioning Contractors National Association (SMACNA) specifications for a fire rating of li hour.
The contractor did not obtain the UL fire rating label for the dampers.
This necessitated a request for exemption from NRC guidelines by DLC in October 1986.
Following the staff's safety evaluation, the NRC con-cluded that the fire damper design was not an acceptable deviation, and reconnended that fire tests be performed to demonstrate that the fire resistance rating of the dampers was equivalent to that required of the barriers in which they were installed.
Complying with the NRC's recommendation, DLC fabricated prototypes of all damper configurations subject to the deviation and submitted them to UL for testing in accordance with Standard 555-1968.
The subject prototypes failed the fire endurance and hose stream tests.
Upon receipt of the UL failed test report, DLC declared the applicable dampers inoperable. - Hourly roving fire watches have been instituted for the affected areas and will remain in effect until an evaluation demonstrates the acceptability of the present configuration or correc-tive actions, if necessary, are completed.
7115B-1778119-B3 1
i
o o
3.0 REFERENCES
3.1 NRC Generic Letter 86-10 3.2, Beaver Valley Unit 1 Appendix R Review 3.3 Fire Protection Handbook, 16th Edition 3.4 Underwriter's Laboratories (UL) - Fact Finding Report on " Air Duet Penetrations Through One Hour Fire Resistive Wall Assembly" dated April 17, 1985.
3.5 Design Analysis No. 8700-DMC-2341-0 4.0 ANALYSIS 4.1 CONFIGURATION The areas of concern in this evaluation are shown on attached sketches SK-14760-5 SH 1 and 2.
The eight fire dampers VS-D-170, 171, 172, 173, 174, 175, 176, and 178 are mounted in ducts that penetrate concrete fire walls of 24 inch thickness within the safeguards area structure.
A shake space separates the Auxiliary Building from the safeguards area structure. The concret6 valls are three hour rated barriers.
Ductwork connects the primary containment and safeguards a'reas with filter and ventilation equipment located in the Auxiliary Building.
The Safeguards Building, including the Blowdown Tank Area and Personnel Hatch area is a reinforced concrete structure.
The adjacent area on the Auxiliary Building elevation 768'-7" has walls constructed of structural steel framing, siding, and a corrugated metal deck with built-up roof system.
The area of the Auxiliary Building surrounding the subject fire dampers is open to the general area on elevation 768'-7".
Interior walls of the Auxiliary Building are concrete or concrete block construction.
The ductwork is adequately supported and the penetrations are sealed with fire resistant material.
4.2 EQUIPENT The safeguards _ Blowdown Tank Area contains ductwork, piping, conduit, and the blowdown tank and associated heat exchangers and pumps.
There are no systems or components in this area which are required for safe shutdown of the plant.
The Personnel Hatch area contains the hatch itself and associated conduit and small bore piping.
The area of the Auxiliary Building surrounding fire dampers VS-D-170 through 174 contains gaseous waste filters and fans, ductworks, piping, and conduit.
l 71158-1778119-B3 2
i l
4.3 COMUSTIBLES The areas involved with this engineering evaluation contain minimal amounts of permanent combustibles during normal operation of the plant.
Thete are administrative controls in place to limit transportation of flammable liquids to a quantity of one gallon.
This transient combus-l tible loading of one gallon of heptane is considered in this evalua-i tion.
Protective clothing is sometimes stored temporarily on the Auxiliary Building elevation 768'-7" during an outage.
- However, appropriate administrative measures are taken during these periods to ensure the control of these transient combustible materials. There are no open cable trays located in the vicinity of the associated ductwork j
with this evaluation.
)
4.4 OTHER CONSIDERATIONS Area fire detection consisting of area ionization coverage'is provided j
in portions of the Primary Auxiliary Building (PAB) elevation 768'-7" with control room and local alarms.
The area of the PAB used for temporary storage of protective clothing during an outage is provided with local wet pipe sprinkler protection.
4.5 $UMARY OF ANALYSIS The only viable fire loading to consider in this evaluation is that of a transient combustible, (one gallon of heptane), The methodology used is to determine the peak area temperature for the postulated fire area i
by modeling the room as a furnace, credit for heat sinks of major room structures and components.
In the calculation for EV-1, a peak temperature of 200'F was reached.
The areas associated with this evaluation (EV-5) are much larger and contain many more heat sinks.
Therefore, the temperature caused by a transient fire in either the Blowdown Tank Area of the Auxiliary Building, is expected to be substantially less than 200'F.
Localized conditions caused by a transient combustible fire may actuate sprinklers in the PAB area.
This, however, would not constitute an inadvertent system actuation or jeopardize safe shut down for a fire event in the PAB 767 area. The temperature of the transient fire would not in ar.y case be substantial enough to challenge the integrity of the 20 gauge sheet metal ductwork.
It should be noted that 0.022. inch thick (24 gauge) sheet metal has been successfully tested in accordance with ASTM E119 to withstand 1700'F for a duration of one hour.
(Ref..
3.4) The ductwork installed is of heavier material (20 gauge 0,036 in.
thick) and therefore is assumed to maintain its integrity.
5.0 CONCLUSION
S Based on the following:
Minimal combustible loading in both the Blowdown Tank Area, the personnel hatch area, and Auxiliary Building elevation 71158-1778119-B3 3
4 768'-7" and particularly in the vicinity of the ductwork, during normal plant operation, No equipment required for plant saft shutdown in the event of fire located in the analyzed areas, Steel construction of the ductwork with heavier gauge than o
that tested by UL for one hour resistance, Resulting low heat generated by potential transient combusti-bles which are administratively controlled, Readily available fire suppression means, Replacing the existing fire dampers VS-D-170, VS-D-171 VS-D-172, VS-D-173, VS-D-174, VS-D-175, VS-D-176, and VS-D-178 with UL qualified dampers would not significantly increase the level of plant fire safety.
1 71158-1778119-B3 4
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2.0 BACKGROUND
On August 29, 1989. Duquesne Light Company (DLC) issued a special-report to the NRC regarding the failure of prototype fire dampers to pass the Underwriter's Laboratories (UL) tests as required by Standard 555-1968.
The subject damper 'in this evaluation VS-D-194
^
is similar to the aforementioned prototype.
This damper is installed in the exhaust air duct penetrating the fire rated barrier wall between the Auxiliary Building and the Service Building.
The dampers -were I
field fabricated by Schneider Sheet Metal in accordance with Sheet l
Metal and Air Conditioning Contractors National Association (SMACNA) specifications for a fire rating of 1 1/2 hour.
The contractor did.
not obtain the UL fire rating label for the dampers. This necessitated a request for exemption from NRC guidelines by DLC in October 1986.
Following the staff's safety evaluation, the NRC concluded that the fire damper design was not an acceptable deviation, and recommended that fire tests be performed to demonstrate that the fire resistance rating of_ the dampers was equivalent to that required of the barriers l
in which they were installed.
Complying with the NRC's recommendation, DLC fabricated prototypes of all damper configurations subject to the deviation and submitted
I r
t 2
J
-1 subject prototypes failed the fire endurance and hose stream tests.
Upon receiving the UL failed test report, DLC has declared the applicable dampers inoperable.
Hourly roving fire watches have been implemented for the affected areas and will remain in effect until an evaluation demonstrates the acceptability of the present.
configuration or corrective actions, if necessary, are completed.
3.0 REFERENCES
3.1 NRC Generic Letter 86-10 3.2 Beaver Valley Unit 1 Appendix R Review 3.3 Fire Protection Handbook,16th Edition 3.4 Underwriter's Laboratories (UL) - Fact Einding Report on " Air Duct Penetrations Through One Hour Fire Resistive -Wall Assembly" c
dated April 17, 1985.
3.5 Sandia Fire Protection Research Program Corner Effects Tests
- and 79-0966.
3.6 Calculation 8700-DMC-2341-0 4.0 ANALYSIS 4.1 CONFIGURATION The air exhaust duct from the filtration unit VS-F-39 located in the Service Building penetrates the 3 hour3.472222e-5 days <br />8.333333e-4 hours <br />4.960317e-6 weeks <br />1.1415e-6 months <br /> fire _ rated wall between the Service Building and the Auxiliary Building at elevation 764'-0" (bottom of duct).
The 20 X 20 inch duct penetration is protected -
by 'the unqualified fire damper VS-D-194 (See attached sketches SK-14760-6 sheets 1 and 2).
The penetration is adequately sealed with grout material.
- ~
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The seismically supported duct is constructed of galvanized 20 gauge sheet metal with a minimum thickness of 0.036 inch.
This is of a
]
heavier gauge than that tested by UL for one hour fire resistance j
when subjected to a furnace temperature of 1700'F equivalent to. one
.]
hour duration based on ASTM E119 time-temperature curve.- (Ref. 3.4) 4.2 EQUIPfENT There is no equipment located in the vicinity of the fire damper on the Service Building side of the separating wall.
The Auxiliary Building, elevation 752'-6" houses the boric acid tanks, volume control tank, boric acid transfer pumps, each individually installed in a separate concrete block wall cubicle.
None of' the abovementioned equipment is required for plant safe shutdown in case of fire.
9 4.3 C0080STIBLES There are no permanent combustible 3 in the Service Building in the vicinity of-the duct wall penetration.
In the Auxiliary Building three cable trays are located in the proximity-- of -the ductwork penetration.
4.4 OTHER CONSIDERATIONS Area fire detection consisting of area' ionization coverage -is' provided in portions of the 752' level of the Auxiliary Building with Control
.)
room and local alams.
Manual fire extinguishing-equipment strategically located in the Service Building. and the Auxiliary Building is provided to suppress a fire in either area.
4.5 SUISERY Or ANALYSIC With the lack of pemanent combustibles in the Service Building, one gallon of Heptane has been considered as transient combustible l
i -
1 1
4
)
to detennine the impact on the barrier of a fire event occurring in the Service Building side of the damper. This evaluation is bounded by the air temperature of 200'F calculated for Evaluation EV-1 (Ref.
3.,6 ). -This is a conservative approach since the Service Building area is larger than the Battery Room for which the calculation has been perfonned, and consequently provides for larger volume for heat sink.
The analysis for the Auxiliary Building side of the fire damper involves the existing cable trays coupled with one gallon of Heptane.
as transient combustible.
This analysis is also bounded by the results of the Evaluation EV-1 where the resulting room air temperature was calculated to be 182'F.
The room air temperature determined on either side of the barrier is well below the 325'F acceptance criterion for the fi re barrier cold side temperature - and cannot jeopardize the integrity of the ductwork, based on the UL test results (Ref.
3.4).
5.0 CONCLUSION
S Based on the following:
d o Lack of permanent combustibles in the Service Building, elevation 752'-6" in the vicinity of the duct. wall penetration, o Low combustible loading in the Auxiliary Building, elevation 752'-6" and particularly in the vicinity of the ductwork,
'l o No equipment required for. plant safe shutdown in case of fire located in the areas of-concern, o Steel construction of the ductwork heavier gauge than that tested by UL for one hour resistance, o Resulting insignificant effects'of the heat transmitted through-the unprotected ducts on safe shutdown components in the adjacent area, l
e-
5 o Manual fire suppression readily available means, replacing the existing fire damper VS-D-194 with UL qualified dampers would not -significantly increase the level of plant.
fire safety, i
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ENGINEERING EVALUATION, EV7 FIRE DAlfERS IN TE AUXILIARY BUILDING AND FUEL BUILDING BEAVER VALLEY POWER STATION - UNIT 1 1.0 PURPOSE The purpose of this engineering evaluation is to. document the acceptability of the fire barrier duct penetrations between the A~uxiliary Building and. the' Fuel Building, protected by unqualified fire dampers; This evaluation is performed in accordance with the provisions of - Generic Letter 86-10.
Criteria for evaluating the fire ' area boundaries are based on.Section D.1(j) of Appendix A to BTP APCSB 9.5-1 guidelines.
2.0 BACKGROUND
On August 29, 1989 Duquesne Light (DLC) issued a 'special report to the NRC regarding the failure of prototype fire dampers to pass j
the Underwriter's Laboratories (UL). tests as required by Standard 555-1968.
The subject dampers in the evaluation, VS-D-188, VS-D-189,.
VS-D-190 and VS-D-191 are similar to the aforementioned prototype.
These dampers are installed in 'the supply and exhaust air ducts penetrating the fire rated barrier wall between the Auxiliary Building, i
elevation 768'-7"' and the Fuel Building.
These dampers were field.
fabricated by Schneider Sheet Metal in accordance with Sh'eet Meta.1 and Air Conditioning Contractors National ' Association '(SMACNA) specifications for a fire rating of 1 1/2 hour.
The contractor did not obtain the UL fire rating label for the dampers. This necessitated a request for exemption from NRC guidelines by DLC in October 1986.
Following the staff's safety evaluation, the NRC concluded that the fire damper design was not an acceptable' deviation, and recommended that fire tests be performed to demonstrate that the fire resistance rating of the dampers was equivalent to that required of the barriers in which they were installed, i
u
2 Complying with the NRC's' reconnendation. DLC fabricated prototypes of all damper configurations subject to the deviation and submitted them to UL for testing in accordance with Standard 555-1968.
The subject prototypes failed the fire endurance and hose stream tests.
Upon receiving the UL failed test report, DLC has declared the-applicable dampers inoperable.- Hourly roving fire watches have been implemented for the affected areas and will remain in effect until i
an evaluation demonstrates the acceptability of the present configuration or corrective actions, if necessary, are completed.
3.0 REFERENCES
3.1 NRC Generic Letter 85-10 3.2 Beaver Valley Unit 1 Appendix R Review
'3.3 Fire Protection Handbook,16th Edition 3.4 Underwriter's Laboratories (UL) - Fact Finding Report on " Air Duct Penetrations Through One Hour Fire Resistive Wall Assembly" dated April 17, 1985.
3.5 Calculation 8700-DMC-2341-0 1
3.6 Calculation 8700-DMC-2345-0 4.0 ANALYSIS 4.1 CONFIGURATION
- The three hour fire' rated barrier wall between the Auxiliary Building, elevation 768'-7" and the Fuel. Building is penetrated by: four ventilation ducts supplying 'and exhausting-air to and from - the Fuel Building.
Each duct is provided with an unqualified fire damper.
The four fire dampers installed in wall penetrations are worked with L
l
g 3
J the following numbers: VS-D-188 VS-D-189, VS-D-190 and VS-D-191.
See attached Sketches, Nos. 14760-7 Sheets 1, 2 and 3.
The ductwork j
penetrations are adequately sealed with fire resistant material.
')
The seismically' supported ducts are constructed of galvanized 20 j
gauge sheet metal with a minimum thickness of 0.036 inch.
This is.
of a heavier gauge than that tested by UL for one hour fire resistance when subjected to a furnace temperature of 1700'F equivalent to one hour duration based on ASTM E119 time-temperature; curve (Ref. 3.4).
In the Auxiliary Building, adjacent to the staircase S-3 and' to the south wall there is a-snubber repair shop followed by an office space.
The snubber repair shop is' enclosed by wire mesh partitions..
4.2 EQUIPIENT The-Fuel Building houses the fuel pool heat exchangers, the' fuel-pool cooling pumps, and spent fuel pool all located along the north wall separating from the Auxiliary Building.- The fuel pool crane rail is_. installed parallel to the North Wall at elevation 768'-7".
The top of the crane is at elevation 792'-2" The Auxiliary Building elevation 768'-7" (Fire Area PA-1A) houses the gaseous waste filters and the component cooling water. surge tank, all located in the proximity of the south wall.
Approximately 28-ft, away from this wall the main exhaust filter banks are located within 2 f t. thick concrete block walls.
Neither of the abovementioned equipment is required for safe shutdown in the event of a fire.
4.3 C0feUSTIBLES
-There are minimal amounts of permanent combustibles in the Fuel Building and Auxiliary Building in the proximity of the wall separating the two buildings.
The snubber repair shop occasionally stores-
- m
4 approximately 5 gallons of lubricating oil and 5 gallons of hydraulic fluid for immediate use.
4.4 OTHER CONSIDERATIONS Area fire detection consisting of area ionization coverage. and automatic suppression capability consisting of a water sprinkler 4
system are provided in' portions of the Auxiliary Building, elevation l
. 768'-7" with Control room and local alarms.
Portable extinguishers and hose stations.. strategically located in both fire areas, provide for reliable fire suppression means.
4.5 SLNMARY OF ANALYSIS With the lack of permanent combustibles in the Fuel Building, one gallon of flammable liquid as transient combustible has been considered to get an appreciation of the impact on the ' fire barrier of a fire occurring in this area.
This evaluation is bounded by the air temperature calculated for Evaluation EV-1 of 200"F (Ref. 3.5)
This is a conservative approach since the Fuel Building area is larger i
than the Battery Room for which the calculation has been performed, and consequently provides for larger volume for heat sink.
A calculation has been performed for the Auxiliary. Building to determine the-space air temperature increase due to the heat generated by the combustion of the lubricating oil and hydraulic fluid occasionally - stored in the snubber repair shop and - considers the heat sinks ' provided by the building components..in the - vicinity--of the fire barrier.
The peak temperature was calculated to be 248*F (Ref.
3.6).
The peak room eic :emperature calculated on both sides of the fire rated wall is cell below the 325*F ' acceptance criterion for the cold side temperature of a fire rated barrier wall and cannot jeopardize the integrity of the ductwork, based on UL test results (Ref. 3.4).
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5.0 CONCLUSION
S Ba, sed on the following:
o Minimal combustible loading in the Auxiliary Building and Fuel
o Manual fire suppression means readily available, replacing the existing fire dampers VS-D-188 VS-D-189.. VS-D-190 and VS-D-191 with UL qualified fire dampers would not significantly increase the level of plant fire safety.
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ENGINEERING EVALUATION. EV8 FIRE DAWER IN THE AUXILIARY FEEDWATER PUMP ROOM BEAVER VALLEY POWER STATION - UNIT 1 1.0 PURPOSE The purpose of this engineering evaluation is to document the acceptability of the fire barrier duct penetration between the Auxiliary Feedwater Pump room, elevation 735'-6" and the Main Steam Valve area, elevation 751'-0" protected by unqualified horizontal fire damper.
This evaluation -is performed in accordance with the provisions of Generic Letter 86-10.
Criteria 'for evaluating the fire area boundaries are based on Section D.1(j) of Appendix A to BTP APCSB 9.5-1 guidelines.
1
2.0 BACKGROUND
The fire dampers at Beaver Valley Power Station Unit I have been i
field fabricated by Schneider Sheet Metal in - accordance with Sheet l
Metal and Air Conditioning Contractors National Association (SMACNA) i specifications for a fire rating of 1 1/2 hour.
The contractor did not obtain the UL fire rating label for the dampers. This necessitated a request for exemption from NRC guidelines-by Duquesne Light Company (DLC) in October 1986.
Following the staff's safety evaluation, the NRC concluded that the fire -damper design was not an acceptable deviation, and recommended that fire tests be performed to demonstrate that the fire resistance rating of the ' dampers was equivalent to that required of the barriers in which they were installed.
j Complying with the NRC's recomendation, DLC fabricated prototypes of all damper configurations subject to the deviation and submitted them to UL for testing in accordance with Standard 555-1968.
The subject prototype for the horizontal damper failed the fire endurance and hose stream tests as reported by UL (letter' dated September 7, 1989).
One of the fire dampers installed in a similar configuration is VS-D-154 protecting the slab duct penetration between the Auxiliary
4
'8 2
l Feedwater Pump room =(El. 735"-6") and the personnel refuge space 1
east of the Main Steam Valve area _(E1. 751'-0").
Subsequently, DLC
)
submitted a License Event Report LER 89-010 on October 9,1989.
[
l Upon receiving the UL failed test report, DLC has declared the l
applicable dampers inoperable.
Hourly roving fire watches have been implemented for the affected areas and will remain in effect until an evaluation demonstrates the acceptability of the present l
configuration or corrective actions,-if necessary, are completed.
3.0 REFERENCES
1 3.1 NRC Generic Letter 86-10 3.2 Beaver Valley Unit 1 Appendix R Review 3.3 Fire Protection Handbook, 16th Edition 3.4 Underwriter's Laboratories (UL) - Fact Finding Report on " Air Duct Penetrations through One Hour Fire Resistance Wall Assembly",
dated April 17, 1985.-
4.0 ANALYSIS 4.1 CONFIGURATION The Auxiliary Feedwater Pump room, part of the Pipe Tunnel area (PT-1) is located at elevation 735'-6" adjacent to the Reactor Containment building.
It. is separated on the east side by _ a 3 hour3.472222e-5 days <br />8.333333e-4 hours <br />4.960317e-6 weeks <br />1.1415e-6 months <br /> fire rated barrier wall from the west cable vault. A reinforced concrete ceiling slab 18 in, thick, separates the Auxiliary Feedwater Pump room from' j
the Main Steam Valve area.
A 4 inch concrete curb ~ is installed around each auxiliary feedwater pump to contain an oil spill from the pumps, and water flow from the fire suppression system.
ot 3
Each curbed area is provided with a drain which allows for the transfer of liquids through a loop seal to a safe location.
4 The Auxiliary Feedwater Pump room exhaust air duct penetrates the ceiling slab in the east personnel refuge space of the Main Steam Valve area.
The duct penetration is protected by the unqualified fire damper US-D-154 (attached sketches SK-14760-8 sheet 1, 2 and j
3). The' penetration is adequately sealed with grout material.
4.2 EQUIPIENT The Auxiliary Feedwater Pump room houses three safety related auxiliary feedwater pumps and safety related cable trays.
The Main Steam Valve area el. 751'-0" houses the main steam trip valves, atmospheric steam dump valves, residual heat release' valves, main steam safety valves, MSIV bypass valves, steam supply valves for the turbine auxiliary feedwater pump and cables in conduits.
The requirement for all the abovementioned equipment for plant safe shutdown is discussed in the Appendix "R" Report (Ref 3.2)..
There is no equipment or cable trays in the personnel refuge space area.
4.3 C0080STIBLES Lube oil and cable ins _ulation are the permanent combustibles present in the Auxiliary Feedwater Pumps room.
l The fire loading for the - Auxiliary Feedwater Pump room area is equivalent to a fire duration of 54 minutes as documented in the Appendix "R'.' Report, Table 3.4-1 (Ref.
3.2).
4 4.4 OTHER CONSIDERATIONS The Auxiliary Feedwater Pump room is protected by an automatic preaction fire suppression system designed and installed in accordance 1
with - NFPA No. 13 The preaction valve - will be actuated by heat detectors installed in the area, i
Ionization smoke detectors are provided for early warning indication locally to the Control Room.
I Portable extinguishers are available in the Auxiliary Feedwater Pump room and adjacent areas.
4.5 St# MARY OF ANALYSIS Due to the specific configuration of the area under evaluation, a fire in the Auxiliary Feedwater pump area h'as been considered in detail, for potential impact on the fire barrier.
In this particular case credit is taken for the existing preaction fire suppression system.
It is expected that the room peak temperature.
will not reach critical values since the water suppression-systems will extinguish a fire generated by the combustion of cables and/or lube oil present in the area.
It should be mentioned that all the cables located in the room are qualified to IEEE 383.
1 In addition, concrete curbs are provided around each auxiliary -
feedwater pump to limit the spread of oil to' adjacent equipment, i
A drain within each curbed area is provided. to limit buildup of water and oil and transfer the mixture to a safe-location.
These features afford a reasonable level of confidence that the amount of potential burning combustibles will be adequately controlled.
The ductwork installed in the Auxiliary Feedwater Pump - room and the Main Steam Valve area -is seismically supported.. galvanized 20 gauge steel with a minimum thickness of 0.36 inches.
Therefore the air
5 v <. s exhaust ductwork can be assumed-to maintain its integrity.
The ductwork penetration ir. adequately sealed with fire resistant material.
5.0 CONCLUSION
S Based on the following:
o Dedicated early warning detection system.
i o Automatic water suppression system, o Provisions for limiting the spread of oil spills, o Provisions for collecting. the spilled oil and allowing for -
transfer to safe location, o Construction of the ductwork heavier gauge than that tested by UL for one hour resistance, replacing the existing fire dampers US-D-154 with an UL qualified damper would not significantly increase the level of plant fire safety.
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