ML20199F460
| ML20199F460 | |
| Person / Time | |
|---|---|
| Site: | North Anna  |
| Issue date: | 03/21/1986 |
| From: | Stewart W VIRGINIA POWER (VIRGINIA ELECTRIC & POWER CO.) |
| To: | Harold Denton, Rubenstein L Office of Nuclear Reactor Regulation |
| Shared Package | |
| ML20199F467 | List: |
| References | |
| 86-065, 86-65, NUDOCS 8603280223 | |
| Download: ML20199F460 (64) | |
Text
.
-e VIHOINIA ELECTHIC ANu PownH COMi*ANY Riennoxn,Vinoix A 2 0 2 0,1 W. I., STEWAltT YICE PRESIDENT Ntctuan Orun4TaoNe March 21, 1986 Mr. Harold R. Denton, Director Serial No.
86'-065 Office of Nuclear Reactor Regulation N0/JDH/vlh Attn: Mr. Lester S. Rubenstein, Director Docket Nos. 50-338 PWR Project Directorate #2 50-339 Division of PWR Licensing-A License Nos. NPF-4 U.S. Nuclear Regulatory Commission NPF-7 Washington, D.C. 20555 Gentlemen:
VIRGINIA ELECTRIC AND POWER COMPANY NORTH ANNA POWER STATION UNITS NO. 1 AND 2 10CFR50 APPENDIX R REPORT - REVISION 3 T
Enclosed is Revision 3 to the North Anna 10CFR50 Appendix R Report.
Revision 3 consists of revised pages to Volumes I and II (originally
' submitted May 1984, and revised October 1984 and August 1985).
Four engineering evaluations are also submitted for review.
Ten copies of the information are being submitted. - At the request of Mr.
J. Stang, NRC, two updated copies are being sent directly to Mr. N.
Ahmed at the Franklin Research Center.
Please update your existing Volumes I and II in accordance with the Table of Changes.
Very truly yours, S'
d W
[#.
L. Stewart Attachments 1.
Revised pages to Volumes I and II~(10 copies) 2.
Engineering Evaluations (10 copies) 1 P
u e
8603280223 860321 PDR ADOCK 05000338 h
F PDR.
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e-t VinoixA Enzctuic Axn Powra CowrAxy To cc:
Dr. J. Nelson Grace Ret.ional Administrator h7C Region II Mr. M. W. Branch NRC Senior Resident Inspector North Anna Power Station Mr.
L.~ B. Engle NRC North Anna Project Manager PWR Project Directorate #2 Division of PWR Licensing-A Mr..T.'E. Conlon h1C Region II Mr. N. Ahmed (2 complete reports updated thru Rev.-3)
Franklin Research' Center:
20th and Race Philadelphia, PA 19103 l
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ri e
' Attachment 2 Engineerina Evaluations
- 2 - Seismic Separation
- 4 - Penetration Seals-
- 7 - Operator Access to Charging Pump Cubicles
- 8 - Operator Access to Motor Driven Auxiliary Feedwater (MDAW) Pump Room O
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- 2. EVALUATION OF TI-E SEISMIC SEPARATION (RATTLESPACE)
BETWEEN VARIOUS CONCRETE WALLS NORTH AP4JA POWER STATION Description of Evoluotion Several buildings, most notably the Auxiliary Building, the Cable Vault / Tunnel, Safeguards, Main Steam Volve Houses, and Quench Spray Pump Houses, have common walls that have o rattlespace (to allow for seismic event movement) between the common wall and a perpendicular wall, primarily containment. In some cases, o combustible material was used as a spacer material during the concrete pour.
This evoluotion will onalyze the potential impact of this configuration on the ability of the barrier to prevent fire spread between fire areas.
Area Description The buildings and fire creas with seismic gaps are listed on Table 2-1.
A description of the crea in terms of boundaries with seismic gaps, combustibles, etc. is provided on the table.
Fire Protection Systems The individual fire protection systems in the fire arcos with seismic gaps are listed on Table 2-1. Most of the areas in this evoluotion have fire detection that annunciates to the Control Room. In general, the areas with larger combustible foodings (over 60 minutes of equivalent fire severity), have fire suppression systems. All areas have manual fire fighting equipment available either within the creo or nearby.
DC-85-31 2-l
Sofe Shutdown Equipment Table 2-1 provides a general listing of the safe shutdown components in each of the fire oreos involved. This list is not all-inclusive and primarily gives major components in order to provide on indication of the function of the area.
Chcpters 3 and 4 in Volume I of the North Anno 10 CFR 50 Appendix R Report provides o detailed description of the components required for safe shutdown and their location.
Evoluotion This evoluotion is divided into several sections.
The first discusses the configuration of the seismic gaps. The second section provides generic justifico-tion for the seismic gaps. The third details previous interaction with NRC concerning the seismic gaps at North Anna. The fourth 'section is Table 2-1 which provides a review, by fire creo, of the seismic gop locations and individual justifications.
l.
Seismic Gap Configuration Seismic gaps, or rattlespaces, are standard in the construction of concrete structures. This is especially true in nuclear power plant due to the number of interconnected concrete structures and the need to minimize the potential effects of a seismic event. The job of the rattlespace is to leave enough space between walls (especially perpendicular walls) to permit rnovement without buckling during a seismic event. In order to create this space, material strong enough to withstand the concrete pour, but flexible enough to give under seismic pressure, is needed. A standard industry practice is to use styrofoam, as was the proctice at North Anna.
The width of the seismic gops are opproximately 2 inches.
A number of the seismic gops at North Anna were reviewed in the field.
The current configuration is shown on Figure 2-1 and con be described as follows:
DC-85-31 2-2
.There is on angle iron opproximately 25" x 25" x k" o.
thick bolted to one wall to cover the gap.
I b.
The some type of ongle iron is used on the ottier side of the barrier.
2.
. Justifications There ore o number of factors that mitigate the potential of fire spread-through the seismic gops.~ These factors, along with a justification, are provided below:
a.
Fire Detection - Most of the oreos involved in the evoluotion have either heat ond/or smoke detectors that 'onnunciate to the Control Room. Detection systems provide early warning of a fire condition to permit prompt station oction. This early notifico-tion provides extra time for the fire brigade to ossemble and attack the fire while it is still in on incipient stage, thereby reducing the potential expo-sure to the seismic gap.
b.
Fire Suppression - In general, fire areas with a combustible looding that results in on equivalent fire severity of over 60 minutes have a fire suppres-sion system. A fire suppression system is designed to extinguish a fire before it con reach flashover or i
the point where the fire grows beyond the general oreo of origin. This will reduce any exposure threat i
to the barrier.
l c.
Combustibles - In the areas reviewed, the vicinity l
of seismic gap was free of combustibles'on both sides of the barrier. This will reduce the amount of direct flame impingement on the seismic gap on the exposed side of _the barrier. This also means that there is little possibility of Ignition on the unexposed side, even if the heat did pass through the
- seismic gap.
In addition, the overall level ~ of
- combustibles in most of the creos when there is no fire suppression where seismic gaps occur is low (on equivalent fire severity of 20 minutes or less). The i
exception is the Cable Vault / Tunnel which hos a j
suppression system. The type of combustibles in the j
vicinity of the seismic gap is also on important l
factor. Although there are few, if any, combusti-l bles in the direct vicinity (up to 5 ft.) of the seismic j
gap, those that were present were primorily cable l
insulation. Cable insulation requires a substantial i
l DC-85-31 2-3 l
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omount of concentroted heat to ignite, and it is unlikely that this would occur via the seismic gops.
Area Configuration - As stated earlier, most of the
- d..
orcos with seismic gops are on the primary side of the plant. These rooms are large concrete struc-t tures with high ceilings that will allow heat to rise and dissipate.
Seismic Cop Configuration - There are several foc-e.
tors in the seismic gaps that will prevent the possage of heat and flame through the gap. First, the seismic gaps are provided.with the barrier described in the first section of the analysis. This barrier is installed on both sides of the gap. This barrier will prevent the possage of heat and flame for most fires in the area.
If the fire is close enough to directly impinge on the barrier, the rubber gasket will fail, but the barrier on the other side shielded by the reinforced concrete wall will prevent possage of heat and flame. The combustible fill within the seismic gap may also octually serve to block the passage of flame if there is insufficient oxygen in the gap to permit total combustion.
Secondly, as mentioned above, the thickness of the walls are on important consideration.
The walls involved are a minimum of I2 in. thick, and some go up to 24 in. This thickness will shield the barrier on the unexposed side and permit the fire gases to cool as they pass through the wall. This will also provide extra time for fire brigade oction.
f.
Safe Shutdown Equipment - There are no major components of the safe shutdown or alternate shut-down systems within the direct vicinity (5 f t.) of the seismic gop. Of the gaps that were field verified, the closest component to a gop are the RHR power feeds where they enter containment in the electri-col penetration oreo of the Cable Voult and Tunnel (CV/T).
These cables were opproximately 8 ft.
oway. The CV/T has detection ond suppression. -
g.
Fire Code Comparison - The possage of limited amounts of gases and even flaming is occeptable for other barrier penetrations. For example, fire door testing as outlined in NFPA-252 parographs 6-l.l.I, 6-l.l.2, and 6-l.l.4 permits flaming of up to six (6) inches along the edges of the door.
I DC-85-3g 2-4 I
- _. _.. ~ -.. -... - - -., _
r 3.
Previous NRC Documentation During the course of the evoluotion, it was determined that this concern had been discussed during the Appendix A evoluotion of the late 1970's.
NRC Ouestion 16, which is answered in Supplement 3 of the North Anna Fire Protection Systems Review (FPSR) dated October I,1978,-specifically addresses the use of styrofoam filler in the rattlespace. The Virginio Electric and Power Company response oppears to odequately cover the NRC concerns, because _no further mention is made of this item in NRC The Fire Protection Safety Evoluotion Report (SER) correspondence.
issued by the NRC in Febrvory of 1979 specifically references the Virginia Electric and Power Company FPSR Supplement 3 as a source document.
The SER in Section lil-A found that North Anna was in compliance with the~
guidelines of Appendix A to BTP-9.5-1 in terms of fire barriers and penetration seats. Therefore, it is Virginia Electric and Power Company's position that this has been settled via the Fire Protection SER for Appendix A.
A copy of the opplicable section of Supplement 3 of the North Anna FPSR is attached ( Attachment II).
4.
See Table 2-1 ottoched at the end of the evoluotion.
Conclusions The seismic gap (rottlespace) configuration will provide odequate separotion between odjacent fire orcos. The technical bases which justify this conclusion con be summarized as follows:
1.
The fire arcos (which contain shutdown components) have fire detection systems that alarm in the Control Room on both sides of fire barriers with seismic gaps.
2.
The fire arcos with the seismic gops in general have combustible loodings that result in on equivalent fire severity of opproximately 20 minutes or less. The notable exception, the Cable Vault and Tunnel, has a fire suppres-
~
sion system.
DC-85-31 2-S
3.
The barrier presently installed over the seismic gops on both sides of the barrier will provide some degree of separation, especially on the unexposed side.
4.
The configuration of the structures involved (primarily heavy concrete with high ceilings and cubicles) will limit exposure to the gaps.
5.
There are few combustibles and safe shutdown compo-nents within the direct vicinity of the seismic gops.
6.
' The possage of limited amounts of heat and even flame is permitted by NFPA codes for such barrier penetrations os fire doors.
7.
This configuration has been previously described to the NRC via the Fire Protection System Review submittal.
The Fire Protection SER issued by the NRC did not raise further concerns.
DC-85-31 2-6
i i
TABLE 7-1 1
Fire Fire Protection Safe Shutdown Location of Proximity of Safe Area Systens Systems Seismic Gop Shutdown Equipment Justification 3-1 Heat and smoke Numerous control, I. CV/T-1 with The power feeds There is detection on both Unit I detection total instrumentation, Auxiliary for the RHR pumps sides of the barrier.
The Cable Vault /
flooding CO2 and power cables Building at are routed opproxi-CV/T has a suppression sys-Tunnel system. Manual for most safe containment.
motely 10 feet tem. The RHR pump power (CV/T-l) open and closed shutdown compo-oway in the CV/T.
feeds are 10 feet away, and i
head sprinkler nents for Unit I there are few combustibles systems oin the Auxiliory Building side.
Equivalent fire severity in excess of 3 hours3.472222e-5 days <br />8.333333e-4 hours <br />4.960317e-6 weeks <br />1.1415e-6 months <br />
- 2. CV/T-l with Safe shutdown There is detection on both j
Auxiliary cables near the sides of the barrier. - The Building at barrier on the CV/T hos a suppression sys-the Service CV/T side.
tem. The only safe shutdown Building.
cables in the Auxiliary Build-inn exposed by the CV/T are those that ore about to enter that CV/T.
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DC45-31 27
TABLE 2-1 (continued)
Fire Fire Protection Sofe Shutdown Location of Proximity of Sofe Area Systems Systems Seismic Gap Shutdown Equipment Justification 3-2 Heat and smoke Numerous control, I. CV/T-2 with The power feeds There is detection on both Unit I detection total instrumentation, Auxiliory for the RHR pumps sides of the barrier.
The Cable Vault /
flooding CO2 and power cables Building at are routed approxi-CV/t hos a suppression sys-Tunnel system.' Manual for most safe containment.
motely 10 feet tem. The RHR purry power (CV/T-2) open and closed shutdown compo-oway in the CV/T.
feeds are 10 feet away, and l
head sprinkler nents for Unit I there are few combustibles on the Auxillory Building l
systems side.
Equivalent fire severity l
In excess of 3 hours3.472222e-5 days <br />8.333333e-4 hours <br />4.960317e-6 weeks <br />1.1415e-6 months <br />
- 2. CV/T-2 with Safe shutdown There is detection on both Auxiliary cables near the sides of the barrier.
The Building at barrier on the CV/T has a suppression sys-l the Service CV/T side.
tem. The only safe shutdown Building.
cables in the Auxiliory Build-ing exposed by the CV/T ore those that are about to enter that CV/T.
DC-85-31 2-8
j TABLE 2-1 i
(continued)
Fire Fire Protection Sofe Shutdown.
Location of Proximity of Safe Area Systems Systems Seismic Gap Shutdown Equipment Justification iI Smoke detection Charging system See I and 2 Most of the seismic gaps in Auxiliary, in most orcos.
CCW system under Cable this fire area communicate Fuel and Partial sprinkler Voult/ Tunnel to arcos within the fire area i
Decontami-system on 244 ft.-
Auxiliary or to the exterior.
notion 6 in. elev. of Monitoring Buildings the Auxiliary Panel Building. Charcool filters have CO2 systems.
Equivalent fire severity i
Auxiliary Building over-all: opproxi-motely 10 minutes.
i The elevations that have conduit penetration ore 10 minutes or less.
4, i
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DC-85-31 2-9 i
TABLE 2-1 (continued)
Fire Fire Protection Safe Shutdown Location of Proximity of Safe Area Systems Systems Seismic Cop Shutdown Equipment Justification 15-l Smoke detection Steam generator
' OPSH-l to No safe shutdown Both fire arcos have detec-Unit i MSVH-l at the equipment within tion, and the equivalent fire Ovench Spray Equivalent fire Pressure trcns-containment 10 feet severity on both sides of the Pumphouse severity mitters wall barrier is 20 minutes or less.
(OSPH-l) 14 minutes There is no safe shutdown (including equipment in the direct Sofeguards vicinity of the seismic gap.
Building) 15-2 Smoke detection Steam generator GPSH-2 to No safe shutdown Roth fire arcos have detec-thit 2 MSVH 2 at the equipment within tion, and the EFS on both Quench Spray Equivalent fire Pressure trens-containment 10 feet sides of the barrier is Pumphouse severity mitters wall 20 minutes or less. There is (GSPH-2) 14 minutes no safe shutdown equipment (including in the direct vicinity of the Safeguards seismic gap.
Building) 17-l Smoke detection Steam generator See the Unit i Unit I Quench Main Steam Equivalent fire PORVs and Sofetys Spray Pump-Volve House severity house Less than 10 minutes DC-85-31 2-10 1
TARLE2-I (continued)
Fire Fire Protection Safe Shutd<mn Location of Proximity of Sofe Area Systems Systems Seismic Gap Shutdown Equipment Justification 17-2 Smoke detection Steam generator See the Unit 2 Guench Uhit 2 Main Steam Equivalent fire PORVs and Sofetys Spray Pump-house Volve House severity Less than 10 minutes l
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DC-85-31 2-11
REINFORCED CONCRETE WALL E" THICK ANGLE IRON BOLTED TO WALL REINFORCED SEISMIC w CONCRETE d GAP WALL FILLER MATERIAL 4
PLAN VIEW (NOT TO SCALE)
FIGURE 2-1 VIRGINIA ELECTRIC AND POWER COMPANY NORTH ANNA POWER STATION
o 16.
It is our position that the styrofoam material used as a filler between the wall and floor slab be replaced to the possible with a noncombustible material such that the extent fire rating is commensurate with the wall / floor fire resistant rating.
Response
The slab in the auxiliary building is wholly within the auxiliary building fire area and is therefor not a fire rated wall.
The filler material has already been added to the inventon of combustables for the auxiliary building.
The slab in the safeguards area is not a partition wall between two fire areas but is a boundary between the safeguards building and the outside.
The joint is covered by a structural steel i
closure angle which covers the filler material.
In addition to the above mentioned items there are walls and slabs listed below wich are fire wall boundaries between separate fire areas.
All walls between two fire areas have closure angles covering the joint filler on both sides, slabs have cover angles on the top only.
Walls which bound a fire area and the outside I
have at least one closure angle.
1.
Safeguards - Quench Spray conunon wall at R.C.
2.
Quench Spray - Main Steam Valve common wall at R.C.
Auxiliary Building common wall at 3.
Main Steam Valve I
R.C.
4.
Main Steam Valve - Cable Tunnel common wall at R.C.
5.
Auxiliary Building - Fuel Building common wall at R.C.
l 6.
Fuel Building - Solid Waste below El 2718-6" at R.C.
7.
Slab El 274'-2" inside Main Steam Valve house at con-tainment wall 8.
Slab El 259'-6" inside cable tunnel at containment wall E
Cabie tunne1 w.11s intersection with north wa11 of
~
auxiliary building 5
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n lli. OlHIR 11tMS ret ATING TO TH! STATION F15f PF'lflCf!ON PROG %'t Ip A.
fire b rriers anft Fire Barrier P.. attations All flonrs, walls and ceilings enclosing fire areas are rated at a minimam of j'
therr h.,ue fire ratings. The licensee has pro.ide d documentation to substantiate the fire rating of the three hosr penetration seals used in the penetrations for j
cabic trays.. conduits and piiing. based on our review, me conclude that the fire b
l barriers anJ barrier penetrations provided, or to be provided, are in accordance r
witte the guiejelines of Appendix A to Branch Technical Position APCSS 9.5-1 and I
are, Lt.erefore, acceptable.
C.
We,DuorsandDapay W-nave reviewed the placement of fire doors and datpers to assure proper fire rating has been provided.
The licensee has stated that about 45 rercent of all fire rated doors are locked -
aint alarmed with the alarm sig.a1 terminating in the control room. All other fire du.rs are kept in the closed position and are controlled by administrative procedores.
The licensee has provided three-hour sentilation fire dampers for most of the 3 hour3.472222e-5 days <br />8.333333e-4 hours <br />4.960317e-6 weeks <br />1.1415e-6 months <br /> wall, ceiling / floor assemblies.- Certain locations have 1\\ hour fire dae ers. These cases were analyred and found acceptable where the fire load was v
small and the estimated fire duration was well below the damper rating; otherwise, daspets will be upgraded to three hour dampers from the esisting 1\\ hoJr fire
[
retirg. Adottionally foi tlntt 2, the air handling duct that is routed through the chiller room will Le f r.vIded with a three hour fire rated barrier.
BastJ on our revien, we conclude that the fire dsors and dampers provided or to be provided, ate in accordance with the guidelines of Appendix A to Branch
. Technical Position APCSB 9.5 1 and arc, therefore, acceptable.
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6
- 4. EVALUATION OF PEPETRATION SEALS NORTH AtelA POWER STATION s;
Description of Evoluotion Penetrations in rated fire barriers are protected by silicone foam sects. The penetration seals are installed in three basic configurations. These configuro -
tions of penetration seals have been tested and determined to have a 3-hour fire resistance roting. This evoluotion describes the documentation of the 3-hour fire resistance rating of the penetration seals. Even though the penetration seal configurations are not listed in the Underwriters Laboratory (U.L.) Building Materials Directory, the seals are occeptable for Appendix R, and no exemption request is necessary.
Evoluotion The following terms are discussed in this evaluation:
1.
NRC Criteria 2.
Foam and Cerofiber Seal 3.
Cable Troy Seal 4.
12-inch Foom Seal j
Each penetration seal configuration is discussed regarding fire resistance test documentation and adequacy of the test.
l.
NRC Criterio Appendix R, Section Ill.G, requires safe shutdown cables and equip-ment to be separated such that one train of safe shutdown compo-nents is " free of fire demoge." One method for eruuring that one train of safe shutdown components is free of fire demoge is to DC-85-3 t 4-1
provide separation "by a fire barrier having a 3-hour rating." Pene-tration seals are port of a fire barrier, so they are also required to i
have o 3-hour rating. Additional guidance on penetration seals is provided in the NRC's proposed Generic Letter 85-01, Section 8.19.I, which states:
J 8.19.1 Penetration Designs Not Laborotory Approved j
OUESTION Where penetration designs have been reviewed and approved by NRC but have not been classified by on approval laboratory, will it be necessory to submit on exemption request?
i
RESPONSE
No.
j This guidance states that the following penetration seals are accept-4
.f oble for Appendix R:
those which have been reviewed and opproved by the i
o.
i NRC, and b.
those which have been classified by on approved l
laboratory.
t i
2.
Foom and Cerofiber Seal This penetration seal configurotron consists of 10 inches of Dow Corning 03-6548 Silicone RTV foam, with l-inch of Johns-Monville Cerafiber or Cerablonket as permanent domming material on each l
end. The total depth of foam and permanent domming material is o minimum of 12 inches.
l Documentation of the seol's fire resistance roting is provided vio o report entitled," Fire Endurance Test of Cable Penetrotron Fire-Stop Seal Systems Utilizing Dow-Corning 03-6548 Silicone RTV Sealing i
f DC-85-31 4-2
Foam," dated February 15,1977. As indicated in the test report, a test was conducted in-house by Virginio Electric and Power Company, based on on early draft of standard IEEE-P634.
The testing was not performed to ASTM E-fl9, nor was it tested by on independent laboratory. However, the testing was based on a similar test procedure, and the acceptance criteria for a 3-hour fire resistance rating was achieved. The test report was then submitted to the NRC and was approved; therefore, based on the proposed for 85-01, this penetrofion seal is acceptable Generic Letter Appendix R.
The referenced report was submitted to the NRC as on appendix to Supplement I dated December 15,1977 to the " Fire Protection Systems Review" Report. The report was reviewed and opproved as indicated by the following statement from the Fire Protection Safety Evoluotion Report dated February,1979:
"The licensee has provided documentation to sub-stantiate the fire rating of the 3-hour penetrotron seals used in the penetrations for cable trays, conduits, and piping.
Based on our review, we concluded that the fire barriers and barrier penetro-tions provided, or to be provided, are in occordonce with the guidelines of Appendix A to Bronch Techn!-
col Position APCSB 9.5-1 and are, therefore, acceptable."
2.
Cable Troy Seal This penetration seal configuration consists of the some combination of foam and cerofiber described in item 2 above, with the addition of a piece of Johns-Monville Marinite XL board permanently attached on each side of the penetration. The board hos a c'ut-out to allow for possage of the troy.
Documentation of the seol's fire resistance roting is provided via the some report, referenced in item 2 above.
This test report was DC-85-31 4-3
submitted to the NRC and was approved as discussed in item 2 obove; therefore, based on the proposed Generic Letter 85-01, this penetro-tion seal is occeptable for Appendix R.
4.
12-inch Foam Seal This penetration seal configuration consists of 12 inches of Dow Corning 03-6548 Silicone RTV foam. Nonpermanent dammina mate-rials are used to form the seol.
These damming materials are removed upon completion of the penetration sealing process.
Documentation of the seal's fire resistance rating is provided via a report entitled," Fire and Hose Steam Tests of Cable Troy Seals -Dow Test No. 4," dated October,1984 (o copy is attached). As indicated in the test report, a full-scale ASTM E-Il9 fire test was conducted by on independent laboratory, Construction Technology Laboratories, of the request of the manufacturer, Dow Corning U.S.A.
The referenced report is equivalent to one condu'cted by Underwriters Laboratories (U.L.) for the following reasons:
The test was conducted by on independent o
testing laboratory; A standardized test (ASTM E-Il9) was used to o
perform the test; o
The occeptance criteric for a 3-hour fire resistance rating was ochieved.
For these reasons, the test report is acceptoble for Appendix R purposes.
Conclusions The penetration seals used at North Anna Power Station are acceptoble for Appendix R. The bases for this conclusion are os follows:
DC-85-31 4-4
l.
The penetration seals have a 3-hour fire resistance rating os required by Appendix R, Section Ill.C.
2.
The foam end cerafiber seo! configuration and the cable troy seal configuration were both tested by Virginia Electric and Power Company.
The test report was submitted to, and was approved by, the NRC.
I.
3.
The 12-inch foam seat configuration was tested in accor-donce with ASTM E-l19 by on independent laboratory.
This is equivalent to being classified by on opproved laboratory.
1 l
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ATTACHMENT TO ENGINEERING EVALUATf0N 4 Report to
(
DOW CORNING U.S.A.
Midland. Michigan 48640
's FIRE AND HOSE STREAM TESTS OF CABLE TRAY SEALS -
DOW TEST NO. 4 by Michael Gillen
(
Submitted by CONSTRI'" TION TECHNOLOGY LABORATORIES A Divis n of Portland Cement Association 5420 Old Orchard Road Skokie, Illinois 60077
'r. t. >b+ r 19 8 4
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CR5502-4374 Doc.
5
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FIRE AND HOSE STREAM TESTS OF PENETRATION SEALS - DOW TEST NO. 4 y
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Michael Gillen*
INTRODUCTION At the request of Dow Corning U.S.A. ( DO*d) and as authorized by Purchase Order No. 17262-N.-Construction Technology Labora-tories (CTL) performed a series of five fire and hose stream
, tests on penetration seal systems.
This report describes results of the fourth test in the program, performed on two cable tray penetration seals.
The penetration seal systems consisted of Dow Corning 3-6548 Silicone RTV Foam.
The 12-in. thick foam seal systems.were cast around two cable tray assemblies installed in a 30x30-in.
~ Cyi.
opening within a 48x48x12-in. concrete slab.
The 30x30-in.
W opening was divided into two 14-1/2x30-in, areas by a 1-in.
thick piece of insulation board, as shown in Fig.
1.
Slabs were constructed by CTL personnel.
Seal systems and cable trays were installed by DOW personnel with-construction assis-tance provided by CTL.
The fire and hose stream tests were performed at the fire research facilities of CTL on October 19, 1984.
The slab con-taining the two cable trays and penetration seals was subjected to a 3-hr fire exposure in accordance with the time temperature
- Senior Research Engineer, Fire Research Section, Construction Technology Laboratories, a Division of the Portland Cement Association, Skokie, IL 60077.
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FIG.I LAYOUT OF CONCRETE SLAB WITH TWO SILICONE FOAM SEALS AND PENETBATING CABLE TRAY ASSEMBLIES l
1
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4 relationship and procedures specified in ASTM Designations:
E119 and E814.
Immediately after the fire test, the
/
specimen was removed from the furnace and subjected to two hose stream tests in accordance with provisions of IEEE 634 3) and ASTM Designation:
E119.
SUMMARY
OF RESULTS The test assembly, consisting of two cable trays and pene-tration seal systems slab, was subjected to a 3-br fire test
'and subsequent hose stream tests Seals were installed in two 14-1/2x30-in. openings penetrating through the 12-in. thick con-crete slab.
The openings were separated by a 1-in. thick piece of insulation board.
The seals consisted of 12-in. thicknesses of Dow Corning 3-6548 Silicone RTV Foam.
The following are significant test results:
C'J2l-1.
No passage of flame occurred through either of the two L
seal systems during the 3-hr fire test.
2.
Limiting end point temperature criterion defined by ASTM Designation:
E814 was not exceeded on the unexposed surface of either of the two seal systems during the 3-hr fire test.
Limiting end point temperature rise defined by ASTM Designation: E814 was exceeded at several measuring points on cables in both Tray Nos. 1 and 2.
Limiting end point temperature
. criterion defined by IEEE 634 was exceeded at one measuring point on a power, cable in Tray No.
1.
- Numbers in parentheses designate References on Page 18..
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3.
No water projected beyond the unexposed surface of either of the_two penetration seals during the 14
/
second IEEE 634 hose stream test.
4.
No water projected beyond the unexposed surface of the penetration seal containing Tray No. 1 during the 24 second ASTM Designation:
E119 hose stream test.
Water did project beyond the unexposed surface of the penetration seal containing Tray No. 2 during the ASTM Designation: E119 hose stream test.
TEST ASSEMBLY A 48x48x12-in. thick concrete slab specimen containing a 30x30-in. square opening was fabricated by CTL personnel.
The opening was located in a nominal 32x32-in. area in the central area of the slab.
The slab was allowed to cure for approxi C:-s, Y S
mately one week following casting and subsequently force-dried at elevated temperature to reduce internal moisture content of the concrete.
Seal materials installed in the slab openings were provided by Dow Corning, U.S.A.
Seal materials consisted of Dow Corning 3-6548 Silicone RTV Foam.
INSTALLATION PROCEDURES i
Installation of cable tray assemblies and seal systems are described in the following sections.
(
. construction technology labornforles
Cable Trays Assemblies Two cable tray assemblies were installed in the concrete
- i test slab, as shown'in Fig. 1.
Cable trays were nominal 18-in, wide x 4-in. high 16 ga. galvanized steel ladder-back trays.
Trays were Model No. PLMS-SS12-1800-4-12 manufactured by U.S.
Gypsum Company.
Certification for trays is provided in Appendix A.
Trays were cut to 5-ft lengths.
Two types of cables were installed in each cable tray:
600v single conductor MCM350. copper power cable with insulation. Type XHHW and 600v AWG10/3C cable with XLP neoprene jacket.
Cables were cut into 5-ft lengths prior to instiillation in the cable trays.
Cable fill in each tray consisted of 14 lengths of MCM350 power cable and 40 lengths of AWGlO/3C cable.
Cables were secured to trays with nylon tie-wraps.
Completed cable tray assemblies were installed so that ends 3
of trays extended 12 in. below the exposed surface of the test slab and 3 ft above the unexposed surface of the test slab.
Trays were bolted at two locations to a steel. angle framework i
on the unexposed side of the concrete slah to provide rigid support and minimize tray movement during seal construction and testing.
Seals Seals were installed in openings in the concrete slab by DOW personnel with construction assistance provided by CTL.
The concrete test assembly was placed in a horizontal position and 1-in. thick pieces of ceramic fiber damming board were attached i
j
) construction technology laboratories
to the unexposed surface of the slab.
The ceramic fiber board
^ '.,
was M-Board manufactured by Johns-Manville. The damming board
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vas cut to fit tightly nround projecting cable tray assemblies.
Small gaps between the ceramic fiber board and cables were filled with pieces of CeraFiber ceramic fiber blanket manufactured by Johns-Manville.
The 30x30-in. opening was subdivided into two 14-1/2x30-in.
openings using a 12-in, wide x 30-in. long piece of 1-in. thick insulation board.
The insulation board was M-Board.
The board was installed in the opening as shown in Fig. 1.
Silicone foam materials were mixed and placed both by hand and machine in approximately 1-1/2 to 2-in. lifts to a thickness of 12 in, in each opening.
Lot numbers, densities.
and snap times of foam materials installed in both penetrations are given fb' in Appendix A.
After foam had set, damming boards were removed from the exposed side of the slab.
The foam in each opening was trimmed flush with the unexposed concrete slab surfaces.
Foam was allowed to cure for approximately 9 days prior to fire testing.
TEST EQUIPMENT & PROCEDURES The following sections briefly describe equipment and pro-cedures used to conduct fire and hose stream tests of the assembly containing the cable tray penetration seal systems.
r Furnace The test assembly containing the two cable tray penetration construcilon technology laboratories
~
seal systems was subjected to a 3-hr fire exposure utilizing the s
small slab furnace at CTL's Fire Research Laboratory.
This
~
furnace provides for testing of small-scale specimens in a hori-
{
zontal position.
Approximate area of fire-exposure is 32x32 in., as shown in Fig.
1.
Furnace atmosphere temperatures were monitored by three Type K, Chromel-Alumel, protected thermocouples located 12 in, below the exposed face of the test assembly.
The fire exposure was
, controlled according to the time-temperature relationship pres-cribed by ASTM Designation:
E119, and is tabulated in Appendix B.
Furnace atmosphere pressure was maintained close to ambient laboratory air pressure or slightly negative (-0.02 to -0.08 inches of water).
For this test, the average draft was -0.08 Ni inches of water.
MS Specimen Instrumentation A total of 30 thermocouples were used for measuring tempera-tures on the unexposed side of the test specimen at locations shown in Fig.
2.
Six thermocouples.were used for measuring temperatures of electrical cables and cable trays at a distance of 1-in, above the unexposed surf ace of the test assembly during the fire test.
Twenty-two thermocouples were used to measure temperatures on seal surfaces, concrete / seal interfaces, cable /
seal and tray / seal interfaces, and concrete surfaces on the unexposed side of the test assembly.
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thermocouples were used to measure foam temperatures at a depth
[f' of 2 in. below the unexposed surface of the seals.
A list of thermocouple locations is provided in Appendix B.
Data Acquisition Furnace atmosphere and specimen thermocouple temperatures were monitored at 5-minute intervals throughout the 3-hr fire test.
The automated data acquisition system' consisted of a Hewlett-Packard HP3455A digital voltmeter and a series of HP3495A data scanners. 'The data acquisition system controller was an HP9845T desktop computer.
Hose Stream Tests Two hose stream tests were conducted after fire testing of the test assembly.
Hose stream test procedures were those des-j cribed in the IEEE 634 and ASTM Designation:
E119 Test Stan-dards.
Equipmenc and procedures for these tests are as follows:
IEEE 634 - A 75 psi hose stream was delivered through a 1-1/2 in. diameter hose equipped with a fog nozzle set at a discharge angle of 30' from a distance of 10 ft.
The spray was delivered over an exposed area of 36x36 in. for a duration of 14 seconds.
ASTM E119-A 30 psi solid _ stream was delivered through a 2-1/2 in. diameter hose equipped with a National
~
Standard Playpipe with a 1-1/8 in, diameter dis-charge tip from a distance of 20 ft.
The stream e-was delivered over an exposed area of 48x48 in.
for a duration of 24 seconds.
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TEST RESULTS
(,
The test assembly containing the.two cable tray penetration seal systems was subjected'to a 3-br fire exposure at the fire research facilities of CTL on October 19, 1984.
A listing of furnace atmosphere temperature measurements and variations from the standard are given in Appendix B.
Variation of the measured. furnace temperatures from the standard was approximately 0.03%, based on comparison of total area under the
, time-temperature curves.
This was well within the 5.00% varia-tion permitted by the Test Standard.I1)
Average furnace draft pressure was -0.08 inches of water.
A listing of measured unexposed concrete, interfaces, cable, and seal temperatures is also given in Appendix B.
The maximum allowable temperature rise of 325'F+ ambient,as defined by ASTM L).,
Designation:
E814 I ) was'not exceeded on the unexposed surface of either penetration seal during the 3-hr fire test.
Limiting end point temperature rise defined by ASTM Designtaion: E814 was exceeded at several measuring points on cables in both seals.
Limiting end point temperture criterion defined by IEEE 634 was exceeded at one measuring point on a power cable in Tray No.
1.
No passage of flame occurred through either penetration seal during the 3-hr fire test.
After the 3-hr fire exposure, the test assembly was removed from the furnace, as shown in Fig.
3, and subjected to the IEEE 634 and ASTM Designation:
E119 hose stream tests.
Views of exposed and unexposed. surfaces of test assembly before hose e
stream testing are shown in Figs. 4 and 5.
Views of hose stream
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No water projected beyond the unexposed surface of either r'
of the two penetration seal during the IEEE 634 hose stream (v
~
No water projected beyond the unexposed surface of the test.
penetration seal containing Tray No. 1 during the ASTM Designation: E119 hose stream test.
Water did project beyond the unexposed surface of the penetration seal containing Tray No. 2 during the ASTM Designation: E119 hose stream test.
Views of exposed and unexposed surfaces of the test assembly after hose stream testing are shown in Figs. 8 and 9.
Following the hose stream tests, measurements were made of the thickness of remaining silicone seal material from each opening, as shown in Fig. 10.
Remaining thicknesses of unburned
materials are listed in Table 1.
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' ~ '
TABLE 1 - THICKNESS OF UNBURNED SILICONE FOAM Thickness, inches Measurement Location
- Tray No. 1 Tray No. 2 West end of seal 6
5 West leg of_ tray 3-3/4 3-3/4 Mid-point of seal 4
3-3/4 East leg of tray 3-1/2 2-3/4 East end of seal 5
5
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B = Tray No. 1 construction technology laboratories
LABORATORY RESPONSIBILITY The Construction Technology Laboratories is a Division of the Portland Cement Association and was not involved in the design of the Penetration Seal System.
Personnel of the Con-struction Technology Laboratories make no judgment of the suit-ability of the materials or seal systems for particular end point uses.
Acceptance of the test results for guidance for field installation is the prerogative of the authority having jurisdiction.
CONCLUDING REMARKS This report described fire and hose stream tests conducted on two silicone penetration seal systems.
Significant test results are presented in the section entitled
SUMMARY
OF RESULTS a
at the.beginning of this report.
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REFERENCES 1.
ASTM Designation:
E119
" Standard Methods of Fire Tests
[
of Building Construction' and Materials," A:nerican Society
\\_ '
for Testing and Materials,. Philadelphia, PA, 1983.
2.
ASTM Designation:
E814
" Standard Method of Fire Tests of Through-Penetration Fire Stops," American Society for Testing and Materials, Philadelphia, PA, 1983.
3.
Standard IEEE 634-1978, "IEEE Standard Cable Penetration Fire-Stop Qualification Test," The Institute of Electrical and Electronic Engineers. Inc., New York, NY.
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- 7. EVALUATION OF OPERATOR ACCESS TO TI-E CHARGING PUMP CUBICLES I
NORTH Al@4A POWER STATION i
l Description of Evoluotion S
The purpose of this evoluotion is to show that station operators will be able to occess charging pump cubicles IC and 2A within 30 minutes of a fire-induced failure of all three of one unit's charging pumps, in order to manually open the isolation volves in the charging pump discharge cross-connection.
Background
There are six charging pumps arranged side by side in individual cubicles on the 244'-6" elevation of the Auxiliary Building. The three.on the east end are for Unit I, and the remaining three are for Unit 2. At least one operable charging pump per unit is required for safe shutdown. In order to assure the availability of at least two charging pumps, Virginia Electric and Power Company has done the following:
1.
A discharge header cross-connect pipe has been installed between the Unit I charging pumps and Unit 2 charging pumps. This cross-connect header is normally closed, and isolation valves in cubicles IC and 2A must be manually opened when the cross-connect is needed. This discharge cross-connection between the two units' charging pumps is in occordance with the Fire Protection Safety Evoluo-tion Report issued by the NRC in February of 1979.
2.
The power cable routing for the charging pumps were reviewed as - part of the Appendix R (to 10 CFR 50) re-onclysis to determine the odequacy of the separation of these power cables. It was found that the separation meets the criteria of Appendix R Section Ill.G.2(b) based on the following:
Separation of the Unit I charging pumps cabling o.
from the Unit 2 charging pumps cobling with no intervening combustible by approximately 22'.
4 DC-85-31 7g
b.
An exemption request (No.1) was submitted for the use of partial creo detection and suppression. How-ever, detection and automatic sprinkler protection are provided for the area where the cables are located.
3.
The individual charging pump cubicles have been sepo-rated from one another by fire rated barriers.
An Exemption Request, (No.7), hos been submitted for the north walls separating the charging pump cubicles and the 244'-6" elevation o'f the Auxiliary Building.
4.
A fire originating in cubicles IC or 2A and exposing other charging pumps or cable is not considered credible because the charging pump cubicles are almost tofolly enclosed.
Therefore, the " worst cose" fire that con be postulated is one that will disable the power cables of all three charging pumps of one unit. To restore charging to the offected unit, the charging discharge header cross-connect must be manually opened via volves in cubicles IC and 2A. Charging to the offected unit needs to be restored within opproximately 30 minutes offer its loss to minimize potential reactor coolont pump seal degradation.
In order to access the manual volves in cubicles IC and 2A, on operator must enter the fire creo (fire area lI which includes the Auxiliary, Fuel, and Decontamination Buildings), potentially on the some elevation where the fire occurred that disabled the one unit's charging pumps.
The 259'-6" elevation of the Auxiliary Building con be divided into fire zones based on the separation of the Unit I and 2 charging pump power cabling. A fire zone is a smaller division of a fire area os defined by Generic Letter 85-01, Section 3.1.1.
Therefore, it con be shown that on operator con occess both cubicles by a route in a different fire zone than the one in which the fire originated.
DC-85-31 7-2
Area Description Fire oreo 11 consists of the Auxiliary, Fuel, and Decontamination Buildings. For the purposes of this evoluotion, only the Auxiliary Building will be considered because of the lock of primary safe shutdown components and a low fuel fooding in the other two buildings. The Auxiliary Building is a four-story structure 244'-6", 259'-6", 274' 0", and 291'-I0" elevations. The CCW ond consisting of the charging pumps are located on the 244'-6" elevation, with the CCW pumps in the main open floor area of this elevation, and each charging pump in a separate cubicle accessed from the 259' 6" elevation. The power feeds for these pumps rise up to the 259'-6" elevation and travel in a northerly direction prior to i
entering each units Cable Voult and Tunnel.
The main occess point into the Auxiliary Building'is through its north wall on the 1
274'-0" elevation vio a 3-hour rated fire door from the Service Build'ing. Access j
is also provided from each unit's Cable Vault and Tunnel at elevation 259'-6.
i t
Evoluotion in order to show that on operator con access charging pump' cubicles IC ond 2A i
within 30 minutes offer the loss of one unit's charging capability, the following items must be onelyzed:
i The division of the 259'-6" elevation of the Auxiliary 1.
Building into two fire ~ zones based on the separation of redundant cable.
2.
The access routes to the charging pump cubicles in terms
.of emergency lighting, distance, potential obstructions, operator familiarity and the need for protective equip-(
ment.
Type, size and duration of a fire to be expecte'd to expose
. 3.
the access routes and cubicles.
4.
Station resources, both possive and octive, that will impoct the fire and the obility of the operator to access the cubicles. This includes fire protection systems, the station fire brigade, and administrative controls.
l DC-85-31 7-3
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This evoluotion is based on the assumption that a fire would disobre the power cables of all three charging pumps of a single unit. This is a conservative j
approach since, os explained in the remainder 'of this evaluation, there is detection and suppression along the power cables routing and a limited amount of -
combustibles in the area.
l.
Fire Zone Divisions i
4 The charging pumps are located on elevation 244'-6" of. the Auxiliary Building. The cubicle walls around each pump extend up to the floor of the next elevation (259'-6"). The charging pump cubicles are occessed through
. hatches on the 259'-6" elevation. The power cables for the charging pumps also exit the cubicles on the 259'-6" elevation. As shown on Figure I, they ochieve on initial 22' separation and remain separated by on excess of 20' 4
through the point where. they exit the Auxiliary Building into their ~
respective units Cable Vault / Tunnel. By virtue of this separation, using the guidance of Generic Letter 85-01, Section 3.l.1, fire zones con be developed for elevation 259'-6". These fire zones are located as follows:
I Zone 11-1, the east side of elev. 259'-6" from the
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o.
l center of the 20' separation to the east wall (see Figure 1).
L b.
Zone i1-2 the west side of elevation 259'-6" from the center of the 20' separation to the west wall j'
(see Figure 1).
Due to the separation and the presence of detection and suppression, based l
l on the Appendix R criteria, the fire will be confined to the zone of origin.
i 1
i However, since no rated barrier is involved, heat and smoke may be present in the unaffected zone.
l l
The charging pump cubicles, although not a separate fire zone or fire oreo 2
will not be involved in a fire in either zones iI-I or i1-2. The cubicles j
a have three (3) hour rated walls and the floor.is on grade. The only openings are at the ceiling of the cubicle which is of the floor of elevation 259'-6" and a fire traveling down and involving the cubicles is not considered credible.
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Access Routes The normal occess path to the charging pumps IC and 2 A is os follows:
Control Room to the Heoith Physics area of the o.
Service Building (elevation 271'-6").
b.
Health Physics oreo to the Auxiliary Building at elevation 274'-0", and then to the enclosed stairwell along the east wall next to the elevator.
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Down the stairwell to the 259'-6" elevation.
c.
d.
Exit the stairwell to charging pump cubicles IC and 2A located approximately 50 and 60 feet away, respectively.
The normal exit path would retrace these steps.
e.
Travel through the 274' elevation of the Auxiliary Building con be virtually eliminated if the outside personnel door to the Auxiliary Building is used.
It is opproximately 10' along the east wall between the outside. personnel door and the enclosed stairwell door.
This path is within fire zone Il-l. Therefore, this access path to cubicles 1C and 2A con be used for a fire offecting the Unit 2 charging pumps.
Emergency lighting for been installed along the path. In addition, this is the normal access route so the operators are familiar with this path. There are no major obstructions from the stairs to the cubicles. The stairwell is enclosed which will provide the operator protection while descending from elevation 274' to 259'-6" and when teoving the area.
The access route to cubicles IC and 2A for a fire that disables the Unit I charging pumps (zone Il-l) is os follows:
Control Room to the electrical penetration area of a.
the Unit 2 Cable Vault / Tunnel at elevation 259'-6".
This is done via the Turbine Building and the Emer-gency Switchgear room.
DC-85-31 7-5
b.
Go through the door in the southeast corner of the electrical penetration oreo directly into the 259' 6" elevation of the Auxiliary Building.
Turn north and proceed to cubicles l C and 2 A.
c.
i This route affords protection in on oreo separated by a 3-hour rated barrier until actually entering the 259'-6" elevation.
Emergency lighting is It is opproximately 100' from the Cable avalloble along this route.
cult / Tunnel door to the cubicle hatches, and there are no major obstruc-tions in this path.
l in both cases, the operator should be prepared to encounter some smoke and heat conditions. Self-contained breathing opporatus (SCBA) should be f
corried to the poi _nt of. entry into the 259'-6" elevation of the Auxiliary Building. The SCBA con be obtained in the Control Room or in the H.P.
area. As a safety precaution, the orerotor should wear the SCBA from the protected arco to the charging pump hatch. The hatch is s.eide enough to permit wearing on SCBA while descending into the cubicle. Operators are trained in the use of SCBA's. Radio communicotton between the operator and the Control Room or Fire Brigade Leoder con be used to get information on the conditions in the Auxiliary Building. As noted above the two cubicles to be entered will not be involved in the fire, so the operator will be protected while performing his actions.
The operator will be in a position to access the cubicle within 15 minutes.
i 3.
Auxiliary Buildino Fires The Auxillory Building is a non-combustible structure (primarily concrete, especially on the lower elevations).
The combustible fooding in the' Auxiliary Building is documented in the 1985 Combustible Loading Analy-sis. The combustible loading in the two elevotions that expose the access paths and the charging pump power cables (244'-6" and 259'-6") is low (I,ess s
than 20,000 BTU /sq. f t.), and the standard durotion is 10 minutes or less.
1 i.
DC-85-31 7-6 t
. _ ~,_
It is important to consider the types of combustible and the contributions they will make in a postulated fire. The following combustibles are taken from those listed in the 1985 Combustible Loading Analysis for the Auxiliary Building.
c.
Cable Insulation - Cable insulation makes up opproximately 60% of the combustible loading on-the lower two elevations.' The cable in the Auxiliary Building is virtually oli IEEE-383 rated.
Cable insulation normally requires a substantial fire for Ignition and to provide sufficient heat input to sustain combustion.
The cabling is located primarily on the 259'-6" elevation at the ceiling level. Therefore, the heat and smoke generated by o cable insuiotion fire
~
would be above the level the operator must travel to the cubicles.
b.
Lube Oil - The charging pumps and CCW pumps both contain lube oil. The majority of the lobe oil is contained in the charging pumps (30 gallons per pump). Since each charging pump is in on individual cubicle (but is considered part of elevation 244'-6" when calculating combustible loading), that portion of the lobe oil is not a factor. Lube oil for the CCW pumps is not under pressure and is in o lesser quantity (12 gallons each) than in the charging pumps. Transient lube oil is only brought in during on oil change for o specific pump.
Class A Combustibles - Step-off pods and protec-c.
tive clothing along with maintenance supplies are' the primary Class A combustible in the Auxiliary Building.
The amount listed in the referenced analysis is during on outoge when the transient combustible loading is at its peak.
d.
Other Combustibles - There are several other combustibles (i.e., grease and hydrogen) in quanti-ties so small (see the 1985 Combustible Loading Analysis), os to not make them on individual factor.
The configuration of the Auxiliary Building will also help reduce the heat exposure to the operator. The Auxiliary Building has several open shafts and high ceilings that will allow heat and smoke to rise to the upper elevations away from the poths that the operator must take to reach the 4
DC-85-31 7-7
cubicles. There are numerous thick concrete shielding floors and walls.
Although these walls may not be specifically fire rated, they are effective barriers to fire spread and will provide protection for the operators as well as the fire brigade. There are several openings to the exterior of the Auxiliary Building on upper elevations where smoke con be exhausted.
4.
Station Resources Detection and Suppression o.
There is a detection system in the Auxiliary Building (although it does The not provide full area coverage, see Exemption Request 1).
detectors are concentrated on the 244'-6" and 259'-6" elevations where the charging and CCW pumps and associated cabling are located. These detectors, ionization type smoke detectors, annunci-ote in the Control Room. Detection will provide on early warning of a fire, normally while it is still in on incipient stage that con be handled with a fire extinguisher. There is normally personnel in the Auxiliary Building. Operators and Health Physics (H.P.)~ technicians as well as Security personnel make periodic rounds of the Auxiliary Building. Personnel in the Auxiliary Building will be able to detect a fire or confirm o detection alarm very quickly. This will enable the personnel in the Auxiliary Building (if trained), or the fire brigade, odditional time to ossemble and extinguish a fire in the first critical moments of the fire.
There is on automatic wet pipe sprinkler system on portions of the 244'-6" and 259'-6" elevations of the Auxiliary Building (see Figures I
7-1 and 7-2). The primary goal of this sprinkler system is to protect the CCW pumps and the associated cabling of the charging and CCW In addition, the sprinkler system will provide the following pumps.
benefits in terms of operator occess to the charging pump cubicles:
DC-85-31 7-8
i i
(1)
Prevent flo' shover - Flashover is defined as the point where all combustibles in the room reach their ignition temperature and is recognized as the threshold between a readily controllable fire and rapid growth fire. Preventing flash-over will almost assure operator occess to the elevation.
(2)
Reduce the fire's output of heat and smoke which improves visibility and occessibility of the area.
(3)
Reduce and control the size of the fire.
The sprinkler system has a flow clarm that provides annunciation in the Control Room.
Hose stations and portable fire extinguishers are provided throughout.
the Auxiliary Building.
b.
Fire Brigade -
North Anna Power Station has a fire brigade that meets the criteria of Branch Technical Position APCSB 9.5-1 Section B 4 (August, 1976).
The brigade has a minimum of five members including a trained brigade leader' who, along with two of the other brigade members, are plant operators. In addition to the assigned brigade members, North Anna has additional brigade members who may be available to fight fires.
l The fire brigade is fully equipped with SCBA's, radios, fire fighting equipment, and detailed pre-fire plans.
The response time of the fire brigade obviously varies with the location of the fire. Response time is recorded _as a critique item during fire drills. Experience hos shown the response time to the Auxiliary Building to be less than 10 minutes. This time includes the arrival, in turnout gear, of a f.ull compliment of brigode members.
Due to the low level of combustible and the detection and suppression systems, the fire brigade should'be able to quickly control o fire.
1 DC-85-31 7-9
Therefore, within 30 minutes the fire brigade will be able to ossem-ble, ottack, and control or completely extinguish a fire.
The fire brigade will be in radio contact with the Control Room and most likely the operator who. will occess the cubicle.
The fire brigode will be able to provide any assistance the operator needs in occessing the cubicle. This may include information on the fire location, quantities of heat and smoke, suggested paths, or even hose stream protection of the path. Although credit cannot be taken under Apperidix R, one of the operators on the fire brigade via instruction from the Control Room could access the cubicles and operate the volves.
This would not jeopardize. the fire fighting activities since the time required to perform the operator action is less than 5 minutes.
c.
Administrative Controls North Anno has a number of station policies and procedures that provide for fire prevention. The ones with the greatest impact are:
(1)
North Anna Fire Protection Program (a)
Flame and Welding permit and procedure system (b)
Limits on storage and use of flammable i
and combustible liquids (c)
Limits on storage and use of transient combustibles (2)
Housekeeping Policy (3)'
O. A. Inspections While these procedures do not assure that fires will be prevented, they will reduce the likelihood and the potential effects should o fire
~
occur.
DC-85-3 l 7-10
Conclusion An operator will be able to access charging pump cubicles IC and 2A within 30 minutes of the loss of charging for one unit due to a fire in the Auxiliary Building.' The bases for this conclusion are as follows:
I 1.
Access pathways to the two cubicles are available for a fire disabling either unit's charging pumps.
2.
Both occess routes have emergency lighting, protected l
stairways, and direct paths to the cubicles.
3.
The operators are familiar with both routes and will be able to communicate with the fire brigade on conditions in the Auxiliary Building.
4.
Breathing opporatus is available to the operator.
The combustible loading in the Auxiliary Building is low, 1
5.
especially on the two lower elevations where the stondord duration of a fire has been calculated to be 10 minutes or less.
6.
The configuration of the combustibles and the construc-tion of the Auxiliary Building will reduce exposure to the i
pathways.
1 7.
lonization smoke detectors are installed on the.244'-6" 1
~
]
and 259'-6" elevations of the Auxiliary Building, in the vicinity of the charging and CCW pumps and power i
J cables. The detection annunciates in the Control Room.
l 8.
An automatic sprinkler system is installed on the some two elevations in the vicinity of the power cables for the charging pumps and CCW pumps, as-well as along most of the access routes.
9.
The station fire brigade will assemble, and control or extinguish a fire in the vicinity of the access paths within 30 minutes and will be able to provide any protection needed for the operator.
\\
Therefore, on operator will be able to restore charging to one unit from the other unit via the charging pump dischorge cross-connect header to allow safe i
shutdown of the plant.
9 i
DC-85-3 I 7-lI
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- 8. EVALUATION OF OPERATOR ACCESS TO TN MOTOR DRIVEN AUXILIARY FEEDWATER PUMP ROOM NORTH AbNA POWER STATION Description of Evaluation The purpose of this evaluation is to show that station operators will be able to access the Motor Driven Auxiliary Feedwater (MDAFW) Pump Room within 30 minutes of a fire-induced failure of both MDAFW pumps in order to manually operate valves to realign the turbine driven auxiliary feedwater pump.
This evaluation opplies to North Anna Power Station Units I and 2.
Background
Each unit at North Anno is equipped with three auxiliary feedwater pumps. Two of these pumps are motor driven, and the third pump is turbine driven. The motor driven pumps are in a ' separate enclosure from the turbine driven pump, and there is a three (3) hour rated fire barrier between the enclosures in occordance with 10 CFR 50, Appendix R, Section Ill.G.2(a).
An Exemption Request (no. 5) from Section Ill.G.3. has been submitted for the lock of fixed fire suppression in the motor driven AFW pump rooms. This_ exemption regards the condensate storage tank level transmitters and does not impact this evaluation.
A fire in the MDAFW pump room could disable both motor driven pumps and require the use of the turbine driven pump to provide auxiliary feedwater. The turbine driven AFW pump is normally aligned to feed one steam generator.
Virginia and Electric Power Company's current onalysis has determined that this will provide odequate heat removed for opproximately 30 minutes.
After 30 minutes, auxiliary feedwater must be realigned for adequate heat removal. In order to realign the auxiliary feedwater flow from the turbine driven AFW pump, valves must be manually operated in the MDAFW pump room. In addition, air or motor operated valves may have to be manually aligned if spurious signals, caused by the fire, affected the volves normal position. These air and motor DC-85-31 8-1
operated volves are also located in the MDAFW pump room.. Therefore, entry into the MDAFW pump room within approximately 30 minutes offer the loss of the motor driven AFW pumps is required.
Area Description Fire creas 148-1 ed 148-2 contain the motor driven auxiliary feedwater pumps for Units I and 2, respective'y, of North Anna Power Station. Each fire area is located in a separate structure which is distinct from all other plant structures and is dedicated solely to the auxiliary feedwater system. Fire arcos 148-l and 148-2 are bounded to the north by Fire arcos 14A-l and 14A-2, which are the turbine-driven AFW pump fire arcos, and to the south by the 110,000 go!!on condensate storoge tanks.
The walls and roof of fire arcos 148-l and 148-2 are constructed of 24" thick reinforced concrete. All penetrations in the north wall are sealed to a 3-hour fire rating with Dow Corning silicone RTV foam. Access to fire areas 148-1 and 14B-2 is through unrated hollow metal exterior doors in the east and west walls for Unit I and Unit 2, respectively.
Evaluation in order to show that on operator con access the motor driven AFW pump rooms within 30 minutes offer the loss of the motor driven AFW pumps, the following must be onelyzed:
c.
The type, size, and duration of a fire expected in the motor driven AFW pump room.
b.
Station resources,. both possive and octive, that will impoet the fire and the ability of the operator to occess the pump room. This includes fire protection systems, the station fire brigade, and administrative controls, c.
Operator occess to the motor driven AFW pump room and to the volves.
DC-85-31 8-2
This evoluotion is based on the cssumption that a fire would disohle both motor driven pumps concurrent with the loss of off-site power. This is o conservative
" worst cose" opprooch since, os explained in the remainder of this evoluotion, there are o number of factors (Iow level of combustibles, smoke detection, enclosed lube oil system, etc.) that will limit a fire in the room.
I.
MDAFW Pump Room Fire The motor driven AFW pump rooms are small (approximately 750 sq.
ft.) concrete rooms that are part of a structure that also houses the turbine driven AFW pump. There is a 3-hour rated barrier between the motor and turbine driven ' AFW pump rooms.
The structural components are non-combustible. The combustible loading in the motor driven AFW pump room is given in the 1985: Combustible Loading Analysis. Lubricating oil is the only listed combustible and the amount results in opproximately 10 minutes..of equivalent fire severity.
The lubrication oil in the room is a high flashpoint oil (in excess of 2000F). The 1985 Combustible Loading Analysis states that there is 12 gallons of lobe oil in each pump.
The additional 12 gallons is considered to be the transient tube oil in the room, while the oil from one MDAFW pump is being changed. Therefore, normally there will be only 24 gallons of tube oil in the room.
Since lobe oil is the only combustible noted by the Combustible Loading ANolycis in the MDAFW pump rooms, it should be considered in any fire scenario for the rooms. Lube oil hos a high flashpoint and is considered a Class ill B combustible liquid (flashpoint in excess of 2000F). The exact flashpoint will vary somewhat with each manufac-turer's oil, but it will be in the Class til B ronge. In order to ignite, lobe oil must be pre-heated or atomized and sprayed onto o heat source. If the pump is not in operation, it is very unlikely that either of these conditions will occur. Even welding sparks folling into o cold DC-85-31 8-3
,n.
,, -, -.,,, ~ -
e
..m.
-e
-lube oil spill normally do not create sufficient heat to ignite the oil, in addition, the lobe oil system for the pump is non-pressurized and is in on enclosed system. Therefore, it must be postulated that the pump is running or has recently been running, and the lobe oil system fails before ignition of the oil con occur. The room has metal gratino at the floor elevation over a trench that extends down opproximately 24". Oil will pool in the trench away from heat sources.
Although hardly credible, as shown above, for the purpose of the evoluotion it is assumed that the lube oil will ignite and include the oil from both pumps.
As shown in the referenced Combustible Loading Analysis, even if all the combustibles in the room were involved, the equivalent fire severity is less than 10 minutes under ideal combustion conditions.
2.
Station Resources o.
Fire Protection Systems There is a smoke detection system in the MDAFW pump room which alarms in the Control Room.
Smoke detectors are designed to detect a fire in its incipient stages before there is heat and smoke build-up that could domoge equipment or prevent entry.
Since the smoke detectors annunicate directly to the Control Room prompt action con be taken, including notification of the fire brigade and starting corrective action. Fire extinguishers are located at the entrance to the MDAFW pump rooms and yard hydrants with hose houses are located nearby.
b.
Fire Brioode North Anre Power Station has o plant fire brigade.
that meets the criteria of Bronch Technical Position APCSB 9.S-l, Section B-4 (August, 1976).
The brigode has a minimum of five trained members including a brigade leader (who receives odditional training) who, along with two other brigade mem-bers, are plant operators. This level of monning is provided for all shifts. In addition to the assigned brigade members, North Anna has odditional brigade members that'may be available to fight fires.
DC-85-31 8-4 l
4 I
The fire brigode is fully equipped with all necessary fire fighting equipment as well os detailed pre-fire plans, including one for the MDAFW pump rooms.
The response time of the fire brigade will obviously vary according to several factors, such as: location, time of day, plant status, etc. ~ However, experience has shown (vio the fire brigade drill critique sheets which records response time) that response time to the motor driven AFW pump rooms is less than 10 minutes. This time includes the arrival, in full turnout geor, of a full complement of brigade mem-bers.
i Due to the low level of combustibles in the room, the brigade will be able to quickly control the fire.
. Lube oil, like most Class Ill B combustible liquids, con be extinguished with fog streams. A fog nozzle l
will be especially effective on o-fire in this room because it is " tight" enough to allow the resulting steam to assist in suppressing the fire by oxygen i
displacement.
Fire extinguishment should be occomplished within 5 to 10 minutes offer the arrival of the fire brigade.
Therefore, the total elapsed time from the fire brigade notification to extinguishment should be. opproximately 20 minutes in the worst cose conditions.
The fire brigade is in radio contact with the Control Room and possibly the operator who will be entering the pump room to align the volves. The brigade will be able to assist the operator if needed.
This assistance may ' include information on fire and smoke conditions. Although credit connot be taken under Appendix ~ R, one of the operators on the fire i
brigade via instructions from the Control Room, could enter the pump room and operate the volves.
c.
Administrative Controls i
North Anna has a number of station policies and proce-dures that provide for fire prevention. The ones with the greatest impact are:
(I)
North Anna Fire Protection Program (o)
Flame and Welding. permit and procedure system (b)
Limits on storage and use of flammable and combustible liquids (c)
Limits on storage and use of transient combus-tibles i
DC-85-31 8-5 4
-c..
....,,. _ _ - -. ~ _ ~ _,... _
(2)
Houskeeping Policy (3) 0.A. Inspections While these procedures do not assure that no fire will occur, they will reduce the likelihood and the potential effects should o' fire occur.
3.
Operator Access In order to access the motor driven AFW pump room, the operator will take the normal route from the Control Room.
Emergency lighting is provided either by 8 hour9.259259e-5 days <br />0.00222 hours <br />1.322751e-5 weeks <br />3.044e-6 months <br /> battery powered lights or by the station security lighting system, which is powered by the security diesel generator.
The MDAFW rooms are small so the path from the door to the valves are direct. Emergency lighting is provided throughout the room, and in the event of its failure, the portable lighting the fire brigade brought to the area con be used. The operator con use self-contained breathing apparatus (SCBA) If conditions require. SCBA's are avall-able in the Control Room, or one brought to the area by the fire brigade can be used. Operators are trained in the use of SCBA's.
It will take less than 30 minutes for an operator to receive instruc-tions from the Control Room, travel to the MDAFW pump room, enter the room, and operate the valves.
I Conclusions An operator will be able to occess the motor driven auxiliary feedwater pump room within 30 minutes in order to manually operate valves. The bases for this conclusion are as follows:
1.
The combustible loading in the room is very low and ha~s-an equivalent fire severity of less than 10 minutes.
DC-85-31 8-6
e 2.
It is very unlikely that a firo could occur in the MDAFW pump room since lobe oil ( o Class lil B combustible liquid) is the primary combustible, and the lobe oil is not pressurized and is in on enclosed system.
3.
The rmm has a smoke detection system annunciating to the Control Room.
4.
Portable fire extinouishers and yard hydronts with hose houses are located nearby.
5.
The station has a fully equipped and trained fire brigode capable of ossembling and responding to o fire within 10 i
minutes.
6.
The type of combustibles and room configuration are such that extinguishment should be occompli,hed within 10 minutes of the fire attack.
7.
The fire brigade will be able to provide assistance to the operator if necessary.
8.
SCBA's are available for use by the operators if needed for entering the room. Operators are trained in the use of SCBA's.
j i
t DC-85-31 8-7 i
TABLE OF CHANGES
)
Please remove and insert the pages and' tables listed below in your copy of the North Anna 10_CFR 50 Appendix R Report, Volumes I and II:
VOLUME I 1.
Insert entire volume (Table of. Contents, Executive Summary,-
Chapters 1-5 and Appendixes A and B).
VOLUME II Table of Contents-1.
Remove.the. Table of Contents.
Insert new Table of Contents.
~
Chapter 6 1.
Remove Chapter 6.
Insert new Chapter 6 (Pages I-1.through III-6).
g Chapter 7 b
1.
Remove Preface to Exemptions.
Insert new Preface to Exemptions.
2.
With the exception of Summary Evaluation Tables, photo-graphs, and figures, remove the text from the following exemption requests and insert new text:
1, 2, 3, 4,
5, 7,
14, 15, 17, 19, 20 21, 22, 23, 24,-25, 26, 27, 28, 31, 32 3.
Remove' Exemption Requests 6, 8, 10, and 11.
' Insert new Pages 6-1, 8-1, 10-1, and 11-1.
4.
Remove text and table for Exemption Request 16 and replace with new text and table.
5.
Insert new Exemption Requests 33, 34, and 35.
1 e
l