ML20195F216

Forwards Detailed Info Re Fire Damper Installation Deviations,Test Program Conducted at Ul & Evaluation of Test Results.Fire Dampers Will Provide Required Level of Fire Protection Safety

ML20195F216
Person / Time
Site:	Vogtle
Issue date:	05/16/1986
From:	Bailey J GEORGIA POWER CO.
To:	Youngblood B Office of Nuclear Reactor Regulation
Shared Package
ML20195F221	List: ML20195F216 ML20195F223 ML20195F230
References
GN-910, NUDOCS 8606110194
Download: ML20195F216 (17)

Text

e Georg a Power Company Route 2. Box 2n9A Waynasboro. Georgia 30830 Telephone 404 554 9361 404 724 8114 Southern Compar.y Services N Post Of tice Box 2625 B,rmingham, Alabama 35202 I Telephone 205 870 6011 Vogtle Project t

May 16, 1986 Director of Nuclear Reactor Regulation File: X6BB06 Attention: Mr. B. J. Youngblood X6BA01 PWR Project Directorate #4 Log: GN-910 Division of PWR Licensing A U. S. Nuclear Regulatory Commission Washington, D.C. 20555 NRC DOCKET NUMBERS 50-424 AND 50-425 CONSTRUCTION PERMIT NUMBERS CPPR-108 AND CPPR-109 V0GTLE ELECTRIC GENERATING PIANT - UNITS 1 AND 2 FIRE DAMPER INSTALLATION DEVIATIONS

Dear Mr. Denton:

The purpose of this letter is to forward to you the detailed information pertaining to the fire damper installation deviations at the Vogtle Electric Generating Plant (VEGP), the test program conducted at Underwriters Laboratories (UL) and the evaluation of test results. Final test reports from UL are sica attached. Illustraticas 19 and 20 of the March 13, 1986 report will be submitted later. These details were discussed with members of your staff at a meeting in Bethesda on April 8, 1986.

Based on the results of the tests and our evaluation of site specific application of fire dampers at VEGP, we have concluded that the fire damper installations at VEGP provide the required level of fire protection safety and the installation deviations will not affect the ability of the dampers to perform their intended functions during a fire event.

Should you have any additional questions, please inquire.

Sincerely, J. A. Bailey S Project Licensing Manager ,1 3^"a =

M ;A.;>

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b 8606110194 860516 \

PDR ADOCK 05000424 i F PDR

Director of Nuclear Reactor Regulation File: X6BB06 May 16, 1986 X6BA01 Page 2 Log: GN-910 xc: R. E. Conway R. A. Thomas J. E. Joiner, Esquire B. W. Churchill, Esquire M. A. Miller (2)

B. Jones, Esquire G. Bockhold, Jr.

D. C. Teper W. C. Ramsey NRC Resident Inspector L. T. Gucwa Vogtle Project File 0479V l

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Attachment 1 Evaluation of Fire Damper Installation Deviations

1. Description of Deviations In accordance with CMEB 9.5-1, fire dampers have been installed at VEGP in fire area boundaries which are penetrated by HVAC ducts. For some 3 hour3.472222e-5 days <br />8.333333e-4 hours <br />4.960317e-6 weeks <br />1.1415e-6 months <br /> rated dampers, the installation method is not in strict conformance with the manufacturer's installation instructions. These deviating installation features fall in three general categories.

The first category is the use of spacers to facilitate damper installation by centering the damper in the oversized openings in concrete walls and floors. The spacers are depicted in Figure 1. The spacers are 1/4 inch plates, 3 inches in length and are cut to fit the oversized opening and are welded to the damper sleeve. The damper manufacturer, Air Balance Incorporated (ABI), recommends that 1/8 inch per foot of damper dimension be provided for expansion. Some spacers are installed such that they meet this requirement while in some instances spacers do not provide the recommended space for thermal expansion of the damper.

The second category affecting damper thermal growth involves the design of the closure angles which are used to span the space between the damper sleeve and the concrete opening. To simplify the design of the seismic support of the adjoining HVAC duct, the closure angle function was integrated into the design of the duct support. ABI's instructions utilize a 1/8" thick angle welded to the sleeve and overlapping the penetration opening by 1 inch. The corners of the angles are not welded and are not anchored to the penetration opening.

The closure angle / support designs used at VEGP are shown in Figures 2 and 3.

The Type 84 support (Figure 2) uses a minimum 1/4" inch thick angle which is welded to the sleeve and to an embedded corner angle in the penetration opening. The Type 93 support (Figure 3) uses a similar concept but is used when no embedded corner angle has been provided in the penetration opening. In this case, a plate is bolted to the 2 sides of the penetration opening and the closure angle is welded to the plate as well as to the sleeve. For both the Type 84 and 93 supports, the closure angles are welded together at the corners. Other variations of these types of support include welding the closure angles to the embeds in the penetration opening on 3 sides or two adjacent sides. In many cases, the extent of welding to the embeds is less than that shown in Figures 2 and 3. Type 84 and 93 supports therefore represent the most rigid configurations from thermal growth standpoint.

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The third category involves substitution of a 10 gauge cover plate with welded corners in place of the 1/8" thick closure angles.

All of the above deviations (except for the third category) were considered to have the potential for restricting the

, thermal growth of the damper and thereby possibly affect its performance. The only concern with the deviations in the third category was the lack of prior test data.

When the significance of these installation features was identified, their use on new installatio".s was discontinued.

An evaluation was initiated to assess the acceptability of the installed dampers which included performance of a fire test to determine the effects these deviations may have on damper performance. The test plan was formulated in consultation with Underwriters Laboratories (UL) and an outside consultant (a registered fire protection engineer with special experience with fire dampers).

II. Test Program A survey of dampers was performed to identify the type and sizes of dampers which were installed using deviating design features. Through consultation with Underwriters Laboratory, a set of test samples was selected which enveloped the range of damper sizes (length and width) including the multiple section dampers. The sizes selected envelope dampers installed in round as well as rectangular ducts. Table 1 summarizes the damper installation configurations and sizes

enveloped by each of the types tested.

As reflected in Table 1, the multiple section dampers tested envelope the maximum length and width dimensions of the multiple section dampers. The single section dampers tested envelope the largest single damper size. Following the test, an additional walkdown identified a small number of floor mounted dampers which do not separate redundant safe shutdown j trains which are 10% larger in the limiting dimension (blade width) than the tested dampers. These dampers are not of particular concern because they do not separate redundant safe shutdown trains, the 10% larger width is judged not to be significant and the tested dampers are considered to be representative of these dampers as well.

The test was comprised of two wall test assemblies (Wall A and Wall B) and one floor test assembly. Wall A contained two damper assemblies utilizing spacers and the 10 gauge cover plate. Wall A also contained one single section damper assembly employing a Type 93 support with spacers.

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Wall B contained a multiple section damper with a Type 93 support and spacers, a single section damper with Type 84 supports and spacers and a multiple section damper with Type 84 supports and spacers.

Tne floor test assembly contained a single section damper with a Type 84 support and spacers and a single section damper with a cover plate and spacers.

All specimens were subjected to fire endurance and hose stream tests as specified in UL Standard for Safety, Fire Dampers and Ceiling Dampers, UL 555.

III. Test Results 3 Hour Fire Endurance Tests:

Throughout the 3 hour3.472222e-5 days <br />8.333333e-4 hours <br />4.960317e-6 weeks <br />1.1415e-6 months <br /> fire endurance test, all dampers in all 3 test assemblies remained securely closed to protect the openings. No significant distortions were observed, no

} visible openings developed and dampers remained structurally intact.

Hose Stream Tests Wall A:

Some warpage of the damper sleeve was observed between the locations of damper to sleeve stitch velds resulting in openings of approximately 1/8" maximum. However, there were no visible openings when viewed at an angle perpendicular to I the plane of the damper. Only minimal warping of the damper frame, the cover plate or the Type 93 support was experienced.

Wall B:

Some warpage of the damper sleeve was observed between the locations of damper to sleeve stitch welds resulting in openings of approximately 1/4 inch. Some openings were visible when viewed at an angle perpendicular to the plane of the damper. In one spot a 3/8 inch opening developed. Only minimal warping of the damper frame, the Type 84 or Type 93 support was experienced.

Floor Assembly:

The damper blades became dislodged from the blade locks and partially opened about 1-1/2 to 2 inches. One blade lock on one damper assembly was bent out of its normal plane. Only minimal warping of the damper frame, the cover plate or the Type 84 support was experienced.

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Figures 4 and 5 are pnotographs of the wall B test assembly immediately after the 3 hour3.472222e-5 days <br />8.333333e-4 hours <br />4.960317e-6 weeks <br />1.1415e-6 months <br /> fire exposure and immediately after application of the hose stream test. I Figures 6 and 7 are photographs of the largest damper assembly in wall B and tne larger of the two dampers in the i floor assembly after the hose stream tests.

IV. Evaluation of Test Results The criteria for acceptance contained in UL 555 require that a damper remain closed during the fire endurance phase of the teest and during the hose stream test. Clearances between parts of a damper may not exceed 1/8 inch during or after the fire endurance test and 1/4 inch during and after the hose stream test. The criteria allow occurrence of openings within the above dimensional limits as long as they are not visible through openings when viewed in a plane perpendicular to the mounting plane of the damper.

The damper assemblies in wall A met all of the above acceptance criteria. While the damper assemblies in wall B and the floor assembly met all the acceptance criteria for the 3 hour3.472222e-5 days <br />8.333333e-4 hours <br />4.960317e-6 weeks <br />1.1415e-6 months <br /> fire endurance portion of the test, the occurrence of visibility through openings is not in complete conformance with the UL 555 acceptance criteria. The following evaluation demonstrates why such an occurrence is not significant nor credible for VEGP specific applications.

Wall B Dampers:

The results of the tests were reviewed by a registered fire protection engineer who concluded that the warping after the hose stream test was due to the cooling effect of the water and was not associated with physical stress which might be applied to the damper as a result of a fire. Application of water on a hot fire would occur during fire suppression.

Under these conditions, damper warpage does not present a threat of spread of fire. Additionally, the single 3/8" opening is not a significant deviation from the 1/4" criteria in UL 555. The condition where some openings were visible when viewed in a plane perpendicular to the damper does not diminish the damper's ability to carry out its function of fire containment.

4

An evaluation has been performed to address the possible consequences of damage by water spray through the developed openings should they occur. A significant quantity of water would not be expected to pass through such spaces. Where a duct is connected to the damper sleeve on at least one side, water spray passing through openings would be contained by the duct and would be shielded from safe shutdown equipment.

Evaluation of dampers with no duct on either side (i.e.

transfer grills) has determined that the location of the dampers with respect to equipment which is susceptible to water damage (e.g. electrical cabinets), is such that the water spray would not reasonably be expected to impinge upon the safe shutdown equipment.

Floor Dampers:

Based on the observations of the dampers following the hose stream test, it is postulated that the combination of stress resulting from the rigid installation in combination with the horizontal force component of the hose stream caused the damper to open. The dampers at VEGP are not likely to be subjected to the conditions as severe as those in UL 555 for the following reasons:

1. Instead of being exposed to the 1925 F temperature of the test furnace at UL, the VEGP dampers are more likely to be subjected to a temperature not exceeding 1400 F due to the likelihood of the fire being ventilation controlled.

This will reduce thermal expansion stresses by approximately 28%.

2. Fire suppression and detection capabilities in all plant locations will further reduce the maximum anticipated temperature as well as the length of exposure.

3. The VEGP reinforced concrete construction with fire proofing of structural steel members and the substantial seismic supports of duct, cable trays and piping greatly reduce the possibility of structural collapse and i

consequent mechanical loading on the fire dampers.

1 i

4. The mechanical load application to the dampers by a hose stream is not possible at VEGP because water spray (fog) nozzles are used throughout the plant as opposed to the straight stream nozzles used in the UL 555 test.

In addition to the above, we have conducted further evaluations which indicate that should a floor damper open in a fashion similar to that experienced in the hose stream test, the probability of spreading a fire is very low and the ability to safely shut the plant down will not be jeopardized for the following reasons:

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1. On the floor above, dampers are connected to a minimum of i 18 gauge duct. Presence of this duct represents a substantial enclosure whose construction is closer to that of a metal smoke pipe (chimney) than to typical HVAC ducting. The ability of a substantial steel enclosure to contain hot gases and thermal radiation is recognized by NFPA 90A. Thic standard does not require fire dampers in ducts that penetrate a fire rated floor if the area of the duct is less than 20 square inches and the duct terminates in a substantial steel air handling unit.

2. Out of the 58 horizontal dampers evaluated in Unit 1, 53 are located in fire rated walls which do not separate redundant safe shutdown trains. The 5 dampers that do separate redundant safe shutdown trains have substantial ducting both above and below the floor with no register, grills or other openings within 8 feet of the top of the floor. It is the assessment of the consultant that this duct configuration will be effective in preventing the spread of fire from the area below. All areas have detection and automatic suppression. Independent sprinkler system are provided above and below the dampers. None of these 5 dampers are as large as the those tested (the widest of the 5 is 30 inches compared to the tested dampers with 35 and 48 inch widths).

V. Conclusion Based on the results of the tests conducted at UL, evaluation of the test results by a registered fire protection engineer and evaluation of site specific application at VEGP we have concluded that the damper installations at VEGP provide an adequate level of fire protection safety and the instalation deviations will not affect the ability of the dampers to perform their intended functions during a fire event.

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TABLE 1 VEGP BASIS FOR TEST DAMPER SELECTION MAXIMUM TEST INSTALLATION INSTALLED DAMPER TYPE METH00 SIZES SIZE SELECTION BASIS VERTICAL SPACERS WITH 60 x 30 66 x 30 e COVERS MAXIMUM HEIGHT OF A TWO SECTION COVERPLATES 66 x 20 DAMPER ASSEMBLY (SECTIONS INSTALLED SIDE BY SIDE).

24 x 60 36 x 60 o COVERS MAXIMUM HEIGHT OF A TM0 SECTION 36 x 36 DAMPER ASSEMBLY (ONE SECTION INSTALLED ON TOP OF OTHER)

SPACERS WITH 60 x 26 60 x 30 e COVERS MAXIMUM NIDTH AND HEIGHT OF A TH0 TYPE 93 SUPPORTS 44 x 30 SECTION DAMPER ASSEMBLY (SECTIONS INSTALLED SIDE BY SIDE) 36 x 36 36 x 36 o COVERS UP TO 36" 0F BLADE WIDTH.

SPACERS WITH 72 x 20 72 x 50 e 00 VERS MAXIMUM WIDTH AND HEIGHT OF A '

TYPE 84 SUPPORTS 70 x 50 FOUR SECTION DAMPER ASSEMBLY. (ALSO -

ENVELOPES TWO SECTION ASSEMBLY INSTALLED SIDE BY SIDE).

e 00 VERS UP TO 3S" 0F BLADE WIDTH.

l 36 x 36 36 x 36 e COVERS UP TO 36" 0F BLADE HIDTH.

HORIZONTAL SPACERS WITH 44 x 36 44 x 48 e 00 VERS MAXIMUM HIDTH OF A SINGLE COVERPLATE 38 x 48 SECTION ASSEMBLY SPACERS WITH 35 x 35 35 x 35 e COVERS THE LARGEST SIZE DAMPER (WIDTH TYPE 84 SUPPORTS AND HEIGHT) IN THIS CONFIGURATION

, SPACERS r 1/4" THICK x 3" LONG SPACERS CUT TO FIT OPENING (TYP) m t .

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