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NUREG/CR-4112US 75-2Vol. 2
Investigation of Cable and
Cable System Fire Test Parameters
Task B: Firestop Test Method
Underwriters Laboratories Inc.
Prepared forU.S. Nuclear RegulatoryCommission
NUREG/CR-4112US 75-2Vol. 2RP
Investigation of Cable andCable System Fire Test Parameters
Task B: Firestop Test Method
Manuscript Completed: December 1984Date Published: January 1985
Underwriters Laboratories Inc.333 Pfingsten RoadNorthbrook, IL 60062
Prepared forDivision of Engineering TechnologyOffice of Nuclear Regulatory ResearchU.S. Nuclear Regulatory CommissionWashington, D.C. 20555NRC FIN B6197
NOTTCE
This report was prepared as an account of work sponsored by anagency of the United States Government. Neither the UnitedStates Government nor Underwriters Laboratories Inc. nor any oftheir employees nor any of their contractors, subcontractors, ortheir employees make any warranty, express or implied, or assumeany legal liability or responsibility for damages arising out ofor in connection with the interpretation, application or use ofor inability to use any information, apparatus, product, orprocesses disclosed, or represents that its use would notinfringe on privately owned rights. This report may not be usedin any way to infer or to indicate acceptability for Listing,Classification, Recognition or Certificate Service byUnderwriters Laboratories Inc. for any product or system.
ABSTPACT
An experimental investigation was conducted to provide dataconcerning the effects that changes in pressure differential,fire exposure and sample construction have on firestopperformance when exposed to a standard fire test. Fifty-one firetest experiments were conducted using pressure differentialsbetween -12 to +120 Pa, different sample constructions and twofire exposure conditions. Findings were that small changes inpressure differential did not have a significant effect onfirestop materials that did not have cracks or through openingsto allow passage of gases during fire exposure. if the materialsallowed passage for gases through cracks or holes, such as thoseleft open after pulling a cable, changing the pressuredifferential affected the firestop performance. Also, it wasdemonstrated that changing the size of the opening; size,location and type of the penetrating items installed through theopening; and severity of fire exposure affected the performanceof the firestop.
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TABLE OF CONTENTS
Abstract . . . . . . . . . . . . . . . . . . . . . . . . . .. ei11List of Figures. . . . . . . . . . . . . . . . . . . . . . . .viiList of Tables . . . . . . . . . . . . . . . . . . . . . . . . ixAcknowledgements . . . . . . . . . . . . . . . . . . . . . . . xi
1. .introduction . . . . . . . . . . . . . . . . . . . . . . . . 11.1 Background . . . . . . . . . . . . . . . . . . . . . .1
1.2 Objectives, Scope and Plan. . . . . . . . . . . . . .2
2. Experimental Procedure ...... . . . . . . . . . . . . .52.1 Samples . . . . . . . .. . . . . . . . . . . . .. . . 52.2 Firestop Sample Construction . . . . . . . . . . . . .62.3 Equipment. . . . . . . . . . . . . . . . . . . . . . .62.4 Instrumentation. . . . . . . . . . . . . . . . . . . .72.5 Method . . . . . . . . . . . . . . . . . . . . . . . . 8
3. Results and Discussion. . . . . . . . . . . . . . . . . . .93. oenera ..3.2 Pressure Differential Experiments.. . . . . . . . . .93.3 Fire Exposure Experiments. . . . . . . . . . . . . .113.4 Sample Construction Fxperiments. . . . . . . . . . . 12
4. Findings . . . . .. . .. . . . . . . . . . . . . . . . . . .154.1 Differential Pressure. . . . . . .... ................ 154.2 Fire Exposure. . . . . . . . . . . . . . . . . . . . 154.3 Sample Construction. . . . . . . . . . . . . . . . . 16
5. References . . . . . . . . . . . . . .. . 0 . 0 . 0 . 18
LIST OF FIGURES
Figure Description Page
1 Floor Slabs 422 Small-Scale Furnace 433 Enclosure 444 Pressure Probe Locations 455 Furnace Temperature Curves 466 Unexposed Surface Temperatures; Exps. 1, 47
3, 5, 7 and 97 Unexposed Surface Temperatures; Exps. 2, 48
4, 6, 8 and 108 Unexposed Surface Temperatures; Exps. 23 49
and 249 Unexposed Surface Temperatures; Exps 23 50
and 2410 Unexposed Surface Temperatures; Exps. 23 51
and 2511 Unexposed Surface Temperatures; Exps. 23 52
and 2512 Unexposed Surface Temperatures; Exps. 26, 53
and 4913 Unexposed Surface Temperatures; Exps. 35 54
39 and 4114 Unexposed Surface Temperatures; Exps 38, 55
40 and 4215 Unexposed Surface Temperatures; Exps. 35 56
and 3716 Unexposed Surface Temperatures; Exps. 36 57
and 3817 Conductor Temperatures; Exps. 31, 32 33, 58
34 and 3918 Unexposed Surface Temperatures; Exps. 43 59
and 4419 Unexposed Surface Temperatures; Exps. 45 60
and 4820 Unexposed Surface Temperatures; Exps. 49 61
and 50
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LIS T OF TABLES
Table Description Page
1 Pressure Differential Experiments 192 Pressure Differential Experiments - Cracks 20
and Holes3 Fire Exposure Experiments 214 Sample Experiments - Conductor & Size 225 Sample Experiments - Cable Construction 236 Sample Experiments - Conduit or Pipe Type 24
and Size7 Sample Experiments - Cable Loading 258 Sample Experiments - Size 269 Cable Constructions 27
10 Conduit and Pipes 2811 Pressure Differential Samples 2912 Pressure Differential Samples - Cracks 30
and Holes13 Fire Exposure Samples 3114 Samples Constructions - Conductor Type 32
and Size15 Sample Constructions - Conduit or Pipe 3316 Sample Constructions - Cable Loading 3417 Sample Constructions - Opening Sizes 3518 Slab Humidities 3619 Thermocouple Locations 3720 Pressure Experiments - Flame Occurrence 38
Times21 Flame Occurrence Times and Pressures - 39
Exp. 5122 Time to Flaming - Exps. 24, 25 and 26 4023 Time to Flaming 41
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I
ACKNOWLEDGEMENTS
The US Nuclear Regulatory Commission through its office ofNuclear Regulatory Research maintains an ongoing fire protectionresearch program. The program is intended to obtain data insupport of current regulatory guides and standards for fireprotection and control in light water reactor power plants and toestablish an improved technical basis for modifying these guidesand standards where appropriate. The investigation described inthis Report is one task of an element of this program.
This investigation was conducted at Underwriters Laboratories'facility in Northbrook, IL. The authors wish to thank thetechnical and engineering staff members, especially Tom Plens,Chris Johnson, Stan Lesiak and Sandi Hansen, for their effort inconducting the experiments and preparing the data.
Respectfully submitted:
Underwriters Laboratories Inc.
L. J. PRZYBYLAEngineering Group LeaderFire Protection Department
Reviewed by:
J. R. BEYREISManaging EngineerFire Protection Department
W. J. CHRISTIANManagerResearch and Technology Development
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1. INTRODUCTION
1.1 BACKGROUND:
The US Nuclear Regulatory Commission (NRC), through its Office ofNuclear Regulatojy Research (RES), initiated fire protectionresearch in 1975f with an investigation of a limited cable trayseparation verification program to obtaig data for evaluatingsome guidelines of Regulatory Guide 1.75 . After the BrownsFerry fire and following recommendations made by the SpecialReview Group, RES established an expanded fire protectionresearch program to augment the cable separation studies and toinvestigate other fire protection concerns.
One fire protection concern is the qualification of penetrationfirestops. Materials and devices are installed to fill openingsin fire resistive floors and walls that are provided for thepassage of items, such as cables and pipes. These materials anddevices are installed in the openings to retard the spread offirer between compartments. A firestop is the specificconstruction consisting of the materials that fill the openingtogether with the penetrating items such as cables, cable traysand pipes.
Some of the NRC guidelines for qualification testing of firestopsare containeg in App. A to Branch Technical PositionAPCSB 9.5-1. . These guidelines recommend that firestops shouldgive protection at least equivalent to that of the fire resistivefloor or wall and that fi estops at least comply with therequirements of ASTM E119 which is the standard used to evaluatefire resistive assemblies.
Within the past few years, test methods have been developedspecifically for investigating firestops. One test that has beenused to evaluate the performance of firestops 7 installed innuclear power plants is described in IEEE 634 . This standarddescribes the test procedure and criteria for acceptance. Thetest procedure consists of subjecting the sample firestop to afire exposure in accordance with ASTM E119. Tmmediately afterfire exposure, the sample is subjected to a water spray (hosestream test). The firestop is acceptable if it withstands thefire test without passage of flame or gases hot enought to ignitecable on the nonfire side, and if it limits the temperature onthe nonfire side to less than 700 0 F. Also, the sample mustwithstand the hose stream test without developing an openingwhich allows the passage of a water stream. This test methodprovides a means of determining the ability of a particularfirestop design to resist the passage of flame when exposed to a"standard" fire. Accordingly, fire stop designs can be ratedaccording to their duration of fire exposure as expressed inhours or fractions of hours. However, the ratings are notabsolute values. It is intended that the test method obtain
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results that provide a degree of correlation to the fireperformance of firestops in a nuclear power plant during a fire.The test method was not intended to obtain the performance offirestops under all possible fire conditions that could beencountered.
However, there has been some concern about the effects onperformance of the test specimen when certain test parameters arechanged. These are 1) the pressure differential (the pressure atone side of the firestop with respect to the other side), 2)firestop construction and 3) fire exposure.
Pressure Differentials - Pressure differentials exist in theplant under normal operation. These pressure differentials aredynamic, changing with the ventilation system operation. Also,they may change during a fire. IEEE 634 discusses this problemand recommends that it be studied as a future task, but does notrequire that one specific differential be applied during thetest.
Firestop Construction - Sample selection for testing is tobe representative of the firestop installed in the plant. Tofacilitate selection, suggested guidelines are provided inIEEE 634 for size of opening and types and sizes of cables, butdata substantiating the selection are not referenced. Theeffects of varying the sample construction could be significant,and a method to determine quantitatively the effect of changes insample construction would be advantageous.
Fire Exposure - The fire exposure for the sample is thestandard time-temperature curve cdescribed in ASTMHE119. However,the heat released during a real fire in a plant may have asignificantly different temperature-time relationship. Data onthe effects of different temperature-time exposures could beuseful.
1.2 OBJECTIVES, SCOPE AND PLAN:
The objective of this investigation was to develop data to beused in evaluating the effects of changes in 1) pressuredifferential, 2) fire exposure and 3) firestop construction.
In connection with this overall objective, specific objeptiveswere
1. To develop data on the following when the pressuredifferential is changed:
A. Unexposed surface temperatures
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P. Time at which flaming occurs on the unexposed sideC. Formation of cracks in the firestop materialD. Structural failure of the firestop materials
2. To explore changes in pressure differential regardingflaming on the unexposed side when there are holes inthe firestop material or concrete floor slab.
3. To develop data on the following when the fire exposureis changed:
A. The time when flaming occurs on the unexposed sideB. Unexposed side temperature.
4. To explore the affect that changes in firestopconstruction parameters have on the following:
A. The surrounding material temperature on theunexposed side when the cable conductor size ischanged
B. The temperature of the surrounding firestopmaterial when aluminum conductors are used insteadof copper
C. The conductor temperatures and the observedperformance when cables are used with differentjacket/insulation materials
D. The interface temperature between the pipe and theunexposed surface of the firestop material whenthe pipe size is changed
E. The interface temperature between the conduit andthe unexposed surface of the firestop materialwhen the conduit size and type is changed
F. The unexposed surface of the firestop materialnear the cable group when the number of cables ina group is changed
G. The cracking and deflection of the firestopmaterial when different size openings are used
The investigation consisted of fifty-one fire test experimentsthat were conducted on firestops installed in concrete floorslabs. Each test was conducted in general accordance withIEFE 634 with the data obtained being the physical performance(cracks and flaming) and the temperature measurements at variouslocations within and on the unexposed surface of the firestopmaterial and on the penetrating items.
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The plan of the investigation consisted of the following:
1. Experiments
2. Comparative Analysis
3. Findings
The experiments were organized into groups to simplify datacomparisons and are identified in Tables 1-8. To consolidateexperimentation, some fire tests consisted of two firestopsamples, each considered a separate experiment.
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2. EXPERIMENTAL PROCEDURE
2.1 SAMPLES:
The firestops that were tested were designed and installed toobtain data on the effects that changes in certain testparameters have on performance. They were not intended to obtaina 3 h or any other specific rating.
Floor Slabs
The normal weight concrete slabs, except for Experiment 51, were36 by 36 by 6 in. thick (0.915 by 0.915 by 0.15 m thick). Theslabs were cast with either 2 in. (0.05 m), 6 in. (0.15 m), 9 in.(0.229 m) or 12 in. (0.305 m) diameter holes or with a 12 in.(0.305 m) square opening, as shown in Fig. 1. The mix was onepart Type I Portland cement, 2.13 parts sand and 3.45 partsgravel by bulk volume and mixed with about 7 gal (0.027 M 3 ) ofwater per bag of cement. The concrete strength, as determinedfrom standard 6 in. (0.35 m) by 12 in. (0.305 m) cylinders thatwere aged 28 days at room temperature, ranged from 3290 to 3430psi (22.68 to 23.65 MPa) and averaged 3350 psi (23.10 MPa). The28 day unit weight was 147 lb/ft3 (2.35 Mg/m3).
The slab for Experiment 51 was 36 by 36 by 2 in. thick (0.915 by0.915 by 0.051 m thick). Four holes, 6 in. (152 mm), 3 in.(76 mm), 0.75 in. (19 mm) and 0.50 in. (12 mm) in diameter weredrilled in the slab located as shown in Fig. 1.
Penetrating Items
Each penetrating item was cut from the nominal lengths suppliedby the manufacturer into 54 in. (1.37 m) long pieces.
Cables - Eight different constructions were used asdescribed in Table 9.
Conduits - Steel and aluminum rigid conduits were used in 1and 3 in. trade sizes (Table 10).
Pipes - Schedule 40 steel pipes were used in 1 and 3 in.trade sizes (Table 10).
Cable Tray - The open ladder type tray was made from0.065 in. (0.65 mm) thick galvanized steel. The side rails were3.375 in. (86 mm) deep with 0.75 in. (19 mm) flanges. The rungswere ventilating type, 4 in. (0.102 mm) wide and spaced 9 in.(0.229 m). The loading depth was 3.0 in. (75 mm).
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Firestop Materials
The materials used were proprietary products. Investigation ofother similar firestop materials was not conducted.
Silicone Foam - A two component, room temperature vulcanizedfoam was used. Part A and Part B were hand mixed in accordancewith the manufacturer's installation instructions. The free risedensities were between 27.5-32.0 lb/ft 3 (0.44-0.51 Mg/m3).
Silicone Elastomer - A two component, room temperaturevulcanized elastomer was used. Part A and Part B were hand mixedin accordance with the manufacfurer's installation instructions.The free rise densities were between 86.0-89.0 lb/ft
3
(1.38-1.43 Mg/m 3 ).
Device - The device consisted of three components. Steelpressure discs, 0.365 in. (9 mm) thick, were located one at thetop and one at the bottom. Between the steel discs were twolayers of 1 in. ('5 mm) thick intumescent material with a singlelayer of 3 in. (25 mm) thick neoprene grommet at the center. Thedevices were installed by tightening screws until the grommetmaterial squeezed around the cables and inside of the opening.When cables were used, holes for the cables were drilled toproper size and location at the factory.
2.2 FIRESTOP SAMPLE CONSTRUCTION:
Typically, the test samples were constructed by installingpenetrating items through the hole in the slab and theninstalling the firestop material or device. The penetratingitems were installed so that 12 in. (0.305 m) was below the slaband 36 in. (0.915 m) was above the slab. Cables were fastened toa rack on the unexposed side for support. The firestop materialswere prepared and installed into the hole in accordance with theinstructions from the manufacturer. The type of slab, type offirestop material and the number and type of penetrating itemsused for each experiment are described in Tables 11-17.
2.3 EQUIPMENT:
Furnaces
The small-scale floor furnace of ULI (Fig. 2) was used to providethe fire exposure condition. Natural gas was used for fuel. Thegas entered the furnace through multi-jet burners and togetherwith castable refractory baffles produced luminous and welldistributed flames within the furnace. The furnace chamber wasexhausted with an induced-draft fan.
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The furnace was located within a test building which was heated,if needed, to increase the initial temperature of the samples andthe surrounding air to at least 60OF (166C).
Enclosure
in some experiments, to obtain the desired pressure differential,an enclosure (Fig. 3) was placed on the unexposed side of thesample with the air within the enclosure exhausted as needed.
Air flowed continuously through the enclosure through holes inthe sides. The inlet hole was dampered to provide the desiredpressure across the firestop. Flow through the inlet hole wasdiverted toward the walls of the enclosure away from the sampleand penetrating items to minimize convection cooling.
2.4 INSTRUMENTATION:
Unexposed Surface Temperatures
Temperatures on the unexposed surface of the firestop weremeasured with No. 28 gauge chromel-alumel thermocouples. Eachthermocouple bead was held against the surface and covered withan 0.75 by 0.75 by 0.156 in. (19 by 19 by 4 mm) asbestos pad.
Firestop Material Temperatures
Temperatures within the silicone elastomer and silicone foammaterials were measured with No. 28 gauge chromel-alumelthermocouples with an 0.062 in. (1.6 mm) diameter inconel shield.Temperatures between layers of the device were measured withunshielded No. 28 gauge chromel-alumel thermocouples.
Furnace Temperatures
Furnace temperatures were measured with No. 14 AWG chromel-alumelthermocouples within a 3/4 in. (19 mm) steel pipe. Thethermocouples were located 12 in. (305 mm) from the exposedsurface of the slab'and symmetrically distributed within thefurnace chamber.
Pressure Differential
The pressure differential at the exposed surrace with respect tothe unexposed surface was measured with probes connected to amanometer or electron pressure gauge. The probes were located asshown in Fig. 4.
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Data Acquisition System
Voltage outputs from the thermocouples were connected to anAccurex Autodata 9 data logger. Readings from the manometers andelectronic pressure gauge were recorded manually.
PhotographyExperiments were recorded on 35 mm color slides. The camera wasan Olympus OM-2 with a 50 mm f 1.8 lens.
2.5 METHOD:
The fire experiments were conducted in accordance with IEEE 634,except for certain procedure details under investigation.
The relative humidity of the concrete slabs at a depth of 3 in.(wettest section) prior to experiment are given in Table 18. Theinstallation of the firestop materials was completed at least18 h prior to the start of the experiment.
Throughout each experiment, observations were made of thecharacter of the fire and its control, the conditions of theunexposed surface, temperatures within the firestop materials andpenetrating items, temperatures on the unexposed side and thepressure differential between the exposed and unexposed surfaces.
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3. RESULTS AND DISCUSSION
3.1 GENERAL:
During each fire experiment, the furnace fire was luminous andwell-distributed, and the furnace temperatures followed theStandard Time-Temperature Curve, except for Experiments 24-26 inwhich the furnace temperatures were controlled to a predeterminedcurve as shown in Fig. 5.
Each sample was subjected to the prescribed fire exposure untileither flaming occurred on the exposed side or the desiredinformation was obtained. The temperatures recorded during eachfire experiment were extensive. Only those portions of datanece.ssary for the specific objectives are discussed here. Thelocations of these thermocouples are described in Table 19.
3.2 PRESSURE DIFFERENTIAL EXPERIMENTS:
Discussion
In the interest of safety and convenience, organizations may beoperating their furnaces used for testing firestops at a slightnegative differential pressure. This condition of operationallows controlled exhaust of smoke and gases through the furnacestack while reducing the amount of smoke that escapes from thefurnace and into the laboratory. This also reduces the smoke inthe furnace so as to permit observations of the exposed side ofthe sample.
However, questions have been raised about the effect of operatingfurnaces at a negative pressure differential. The conjecture isthat operating a furnace at a slight negative pressuredifferential provides a means for cool air from the laboratory toleak into the furnace through cracks or other openings in thefurnace or sample. To limit these conditions, some have proposedthat a positive pressure differential be used. They contend thatthis would be appropriate since it would better evaluate thefirestop by providing a more severe fire condition with respectto the following:
A. Unexposed surface temperaturesB. Time at which flaming occurred on the unexposed sideC. Formation of cracks in the firestop materialD. Structural failure.
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Additionally, if openings are present, the positive pressuredifferential would allow flames to penetrate through the holes.
To provide the data with respect to these questions, 24experiments were conducted with the differential pressure rangingfrom -0.05 in. H 0 (-12 Pa) to +0.50 in. H 0 (+125 Pa). Thesilicone foam, silicone elastomer and the device wereinvestigated with and without cables. Some samples wereconstructed with through holes in them in the form of cracks orholes in the firestop materials, or as empty holes in theconcrete slab.
Results
Unexposed Surface Temperatures - For comparison, thetemperatures of the unexposed surface at the center of thefirestop material were plotted versus time for Experiments 1, 3,5, 7 and 9 (Fig. 6) and for Experiments 2, 4, 6, 8 and 10(Fig. 7).
The temperatures were about the same for each group ofexperiments, except for Experiment 9. This experiment is suspectas shown by the comparatively long duration (215 min vs. 117 forExperiment 3) without flame occurrence on the unexposed side.
Flame Occurrence - The times when flaming was observed areshown in Table 20. For Experiments 3, 5 and 7, the times whenflaming occurred were about the same. The physical performanceduring Experiments 1 and 9 were significantly different than theother experiments (3, 5 and 7). In Experiment 1, the char layerthat formed at the exposed surface of the silicone materialquickly passed through the material while in Experiment 9, thechar layer formed, but remained at the exposed surface. This mayhave been caused by variances in the air cell structure of thematerial that developed during installation and cure or due toother differences in material properties that developed duringinstallation.
For Experiments 20 and 23, the time when flaming occurred wasabout the same (154 min and 153 min, respectively), even thoughExperiment 20 was at -0.05 in. H2 0 (-12 Pa) and Experiment 23 at+0.01 in. H 0 (+2 Pa). However, the way flaming occurred inExperiment 30 was different. In Experiment 23, the materialcracked and collapsed with the unexposed surface then igniting.In Experiment 20, the material cracked and collapsed, but sincethe flames from the furnace were being drawn downward due to thenegative pressure, the unexposed surface of the material did notignite. However, the radiant energy from the furnace ignited thecables on the unexposed side of the sample.
-10-
Flaming did not occur on the unexposed side during any of theexperiments with the silicone elastomer and device.
Crack Formation and Structural integrity - The same patternof crack formation and structural collapse of the siliconematerial were observed in Experiments 1, 3, 5, 7, 10, 19 and 23where flaming occurred. In all these experiments, propagation ofa crack through the material was rapid, usually occurring within5 min after crack formation. Collapse of the material occurredimmediately after the crack had propagated through the material.
Openings/Flaming - Experiments 21 and 22 were conducted withtwo nominal 0.50 in. (12 mm) diameter holes in the siliconematerial created by pulling cables from the firestop after thematerial had been installed and cured. Experiment 21 wasconducted at 0.01 in. H 0 (+2 Pa) pressure differential, whileExperiment 22 was conducted at -0.05 in. H 0 (-12 Pa). DuringExperiment 21, smoke and hot gases issued ?hrough the holes, butflames were not seen. After about 15 min, the cablejacket/insulation materials surrounding the holes were seenmelting. The gases that issued through the holes were rich inunburned fuel and could be ignited by a match. During Experiment22, smoke and hot gases were not observed as in Experiment 21.However, after 27 min, the cable-jacket/insulation materialsurrounding the holes began to melt, probably due to the radiantheat from the furnace, which produced smoke on the unexposedside.
In Experiment 51, there were four holes in the concrete slabwhich were left unfilled. During the experiment, flames wereseen issuing from each hole, but the time when they firstappeared was different for each hole size. The times and thedifferential pressure at the observed flaming times are given inTable 21.
3.3 FIRE EXPOSURE:
Discussion
There has been interest as to the effect on firestop performance,if the firestop is exposed to a fire other than the StandardTime-Temperature Curve (ASTM E119) that is used in investigatingfire resistance ratings for building assemblies. The StandardTime-Temperature Curve was developed during the early 1900's andwas based upon temperatures found in the various stages of growthof actual fires in buildings. Typically, the fuel load for thesefires would have wood furniture and paper with windows thatprovided ventilation for the fire. This exposure may not beapplicable for fires in nuclear power plants since the fuel loadin the plants usually consist of synthetic combustibles and theventilation is limited.
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To provide data, Experiments 24-26 were conducted using atime-temperature curve less than the Standard Time-TemperatureCurve defined in ASTM E119 (Fig. 5).
Results
Unexposed Surface Temperatures - The temperatures of theunexposed surface were plotted versus time for Experiments 23-26and 49 and are shown in Fig. 8-12. As shown, the temperaturesfor Experiments 24, 25 and 26 using the lessseiver' temperaturecurve were cooler than Experiments 23 and 49 using the StandardTemperature Curve.
Flame Occurrence - The times when flaming was observed areshown in Table 22. As shown, flaming occurred later inExperiments 24 and 25 as compared to Experiment 23. Nocomparison could be made between Experiment 26 and Experiment 49since flaming did not occur during the 270 min fire exposureperiod in Experiment 26.
3.4 SAMPLE CONSTRUCTION EXPERIMENTS:
Discussion
The construction parameters of firestop construction arenumerous. The opening size, the location of the penetrating itemwithin the opening and the type and number of penetrating itemsall can be different. The performance of the firestop can bedifferent for different firestop constructions.
Experiments 27-50 were conducted to provide data to quantify theeffects due to changes in firestop construction for thosematerials and penetrating items investigated. In twentyexperiments, the penetrating items differed with respect to cableconstruction (conductor type, conductor size, insulation andjacket materials), conduit type and size, pipe size and cableloading. In four experiments, the size of the opening variedfrom 2 in. (51 mm) to 11 in. (305 mm).
Results
Conductor Size - The unexposed surface temperatures near thecable were plotted versus time. For Experiments 35, 39, 41 and38, 40 and 42 were plotted versus time and are shown in Figs. 13and 14. As shown, the temperatures were greater near the 300 MCMcable as compared to the 3C/12 AWG and 7C/12 AWG cables.
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Conductor Type - The unexposed surface temperatures near thecable were plotted versus time for Experiments 35-38 and areshown in Figs. 15 and 16. As shown, the temperatures weregreater near the copper conductor 300 MCM cable as compared tothe aluminum conductor 300 MCM cable.
Cable Jacket-Insulation Materials - The conductortemperatures at the unexposed surface were plotted versus timefor Experiments 31-34 and 39 are shown in Fig. 17. As shown, thetemperatures were the greatest for Cable A compared to Cables G,H and F.
Also, each cable construction performed differently as the cabletemperature on the unexposed side increased. Cable A melted anddripped with the molten material slowing coagulating into apuddle on the firestop material. Cable G swelled and crackednear the unexposed surface but did not melt. Cable H swelledlike Cable G but did not crack.
Pipe Size - The temperatures at the firestop material/pipeinterface were plotted versus time for Experiments 43 and 44 asshown in Fig. 18. These data show that the temperatures weregreater at the 3 in. (76 m) pipe as compared to the 1 in.(25 mm) pipe.
Conduit Type and Size - The temperatures at the firestopmaterial/conduit interface were plotted versus time forExperiments 45-48, as shown in Fib. 19. As shown, thetemperatures were greater at the material/conduit interface forthe 3 in. (76 mm) conduits as compared to the 1 in. (25 mm)conduits. Also, temperatures were greater at thematerial/conduit interface for the aluminum conduit than for thesteel conduit.
Cable Loading - The temperatures on the firestop materialnear the cables were plotted versus time for Experiments 49 and50, in Fig. 20. The graph indicates that the temperatures weregreater in Experiment 50 with three layers of cables as comparedto Experiment 49 with one layer of cables.
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Opening Size - The times when flaming occurred are shown inTable 23. Comparing the performance of the firestop material inExperiments 27-30, it was noted that the Experiments with thelarger holes (6 in. (152 mm), 9 in. (230 mm) and 12 in.(305 mm)), the material tended to deflect downward at the centerof the opening during fire exposure. The greatest deflection wasfor the material in the 12 in. (305 mm) hole and with thedeflection being greater for the 9 in. (230 mm) hole compared tothe 6 in. (152 mm) hole. The deflection tended to affect theperformance of the material by causing cracks about the peripheryof the hole, which in turn decreased the strength of the materialand increased the deflection.
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4. FINDINGS
The data and related analysis generated through thisinvestigation and presented in this Report, lead to certainfindings, substantiated by the experimental data.
4.1 DIFFERENTIAL PRESSURE:
For those materials that remained integral during fire exposureand did not allow a path for gas flow, the effect of changing thedifferential pressure was not significant.
(When the firestop materials remained integral, changing thedifferential pressure between -0.05 in. H 0 (-12 Pa) to+0.50 in. H 0 (+125 Pa) did not significagitly change theunexposed sarface temperatures of the firestop materials,the time when flaming occurred on the unexposed side, theformation of cracks in the firestop materials or thestructural failure of the firestop materials. SeePages 10-11.)
For those materials with pre-formed holes, positive differentialpressure provided a means for smoke and hot gases to penetratethrough to the unexposed side.
(When holes were created in the firestop material prior tothe test, positive differential pressure provided a meansfor gases to penetrate through the holes to the unexposedside. These gases were rich in unburned fuel and could beignited by a match. When a negative pressure differentialwas used, smoke and hot gases were not observed, but thecables near the holes melted and issued smoke, probably dueto the radiant heat from the furnace. See Page 11.)
With a positive pressure differential, flames penetrated throughlarger diameter holes sooner than through smaller diameter holes.
(During a test with positive pressure, the times when flameswere observed through holes in a slab were inversely relatedto hole size. See Page 11.)
4.2 FIRE EXPOSURE:
When a less severe fire exposure was used, the rate of heattransmission to the unexposed surface was less and time toflaming failure longer.
-15-
(The unexposed surface temperatures for firestop materialssubjected to a "cooler" time-temperature furnace curve wereless than for firestop materials subjected to the StandardTime-Temperature Furnace Curve. Also for the silicone foammaterial, flaming occurred later for the "cooler" curveexperiments as compared to the standard curve experiments.See Page 12.)
4.3 SAMPLE CONSTRUCTION:
Increasing the gauge (diameter) of the conductor of a cable,increased the unexposed surface temperature of the firestopmaterial near the wire or cable.
(The unexposed surface temperatures of the firestop materialwere greater near the 300 MCM conductor than the 3C/12 AWGcable. See Page 12.)
The unexposed surface temperatures near cables were greater whenthe cable conductors were copper as compared to aluminumconductors.
(The temperatures were greater near the copper conductor300 MCM cable as compared to the aluminum conductor 300 MCMcable. See Page 13.)
The conductor temperatures at the unexposed surface weredifferent for cables of the same size, but of different jacketand insulation materials.
(The conductor temperatures were the greatest for Cable A ascompared to Cables G, H and F. See Page 13.)
Each cable construction performed differently as the cabletemperature on the unexposed side increased.
(The performance of the jacket and insulation materials inresponse to increased temperatures was different for thecable constructions tested with the same conductor.size.See Page 13.)
The temperatures at the firestop material/pipe interface weregreater for larger size pipe.
(The temperatures were greater for the 3 in. (76 mm) pipe ascompared to the 1 in. (25 mm) pipe. See Page 13.)
-16-
The temperatures at the firestop material/conduit interface weregreater for larger size conduit and were greater for aluminum ascompared to steel conduit.
(The temperatures were greater for the 3 in. (76 mm)conduits as compared to the 1 in. (05 mm) conduits. Also,the temperatures were greater for the aluminum conduit ascompared to the steel conduit. See Page 13.)
The temperatures on the firestop material near a cable bundleincreased as the number of cables increased.
(The temperatures were greater near three layers of cablesas compared to a single layer bunch. See Page 13.)
The material deflection during fire exposure increased withincreasing hole size.
(The deflection was the greatest for the 12 in. (305 mm)hole as compared to the 9 in. (230 mm) and 6 3n. (152 mm)holes. See Page 14.)
-17-
5. REFERENCES
i. U.S. Nuclear Regulatory Commission, "Water Reactor SafetyResearch Program," USNRC Report NUREG-0006, February 1979.Available for purchase from National Technical InformationService, Springfield, Virginia 22161.
2. "Physical Independence of Electric Systems, Revision 1,"
U.S. Nuclear Regulatory Commission, Regulatory Guide 1.75,Washington, D.C., January 1975. Available for purchase fromNational Technical Information Service, Springfield, Virginia22161.
3. U.S. Nuclear Regulatory Commission, "Recommendations Relatedto Browns Ferry Fire," USNRC Report NUREG-0050, February 1976.Available for purchase from National Technical InformationService, Springfield, Virginia 22161.
4. U.S. Nuclear Regulatory Commission, "Guidelines for FireProtection for Nuclear Power Plants Docketed Prior to July 1,1976," Appendix A to Branch Technical Position APCSB 9.5-1.Available for inspection and copying for a fee in the NRC PublicDocument Room.
5. U.S. Nuclear Regulatory Commission, "Guidelines for FireProtection for Nuclear Power Plants," Branch Technical PositionAPCSB 9.5-1. Available for inspection and copying for a fee inthe NRC Public Document Room.
6. "Standard Methods of Fire Tests of Building Construction andMaterials," ASTM E119-82. Available for purchase from theAmerican Society for Testing and Materials, 1916 Race Street,Philadelphia, PA 19103.
7. "IEEE Standard Cable Penetration Fire Stop QualificationTest," IEEE 634-1978. Available for purchase from the Instituteof Electrical and Electronics Engineers, Inc., 345 East 47thStreet, New York, NY 10017e
-18-
TABLE 1
Pressure Differential Experiments
SampleExperiment Reference*
PressureIn H.0 (Pa)
Firestop CableMaterial Construction** Number
91357
102468
12111412
1517
1618
100100100100100
100100100100100
101101101101
102102
102102
+0.01+0.05+0.05+0.05+0.50
+0.01+0.05+0.05+0.25+0.50
+0.50+0.01+0.50+0.01
(+2)(+12)(+1i)(+125)(+125)
(+2)(+12)(+12)(+62)(+125)
(+125)(+2)(+125)(+2)
SFSFSFSFSF
SFSFSFSFSF
SRSRSRSR
AAAAA
33333
NoneNoneNoneNoneNone -
AA
NoneNone
33
+0.05 (+12)+0.50 (+125)
+0.05 (+12)+0.50 (+125)
DD
DD
AA
33
NoneNone
SF = Silicone foamSR = Silicone elasta
D = Firestop Device
* = See Table 11.** = See Table 9.
ner V
-19-
TABLE 2
Pressure Differential Experiments - Cracks and Holes
Sample Pressure Firestop CableExperiment Reference* In H.0 (Pa) Material Construction** Number
23 103 +0.01 (+2) SF B 120 103 -0.05 (-12) SF B 1
19 103 +0.50 (+125) SF B 1
21 103 +0.015 (+3) SR B 3122 103 -0.05 (-12) SR B 31
SF = Silicone foamSR = Silicone elastomer
* = See Table 12.
** = See Table 9.
-20-
TABLE 3
Fire Exposure Experiments
Experiment
2425
26
SampleReference*
104104
105
FirestopMaterial
SFSF
SR
CableConstruction**
BB
A
Number
11
11
SF = Silicone foamSR = Silicone elastomer
* = See Table 13.** = See Table 9.
-21-
TABLE 4
Sample Experiments - Conductor Construction & Size
Experiment
35363738
4139
4240
SampleReference*
106106107107
109108
109108
FirestopMaterial
SRD
SRD
SRSR
DD
CableConstruction** Number
CCEE
BF
BF
1111
11
11
SR = Silicone elastomerD = Device
* = See Table 14.** = See Table 9.
-22-
TABLE 5
Sample Experiments - Cable Construction
Experiment
313334
SampleReference*
110111111
FirestopMaterial
SRSRSR
D
CableConstruction** Number
AGH
A
111
32 110
SR = Silicone elastomerD = Device
* = See Table 14.** = See Table 9.
-23-
TABLE 6
Sample Experiments - Conduit or Pipe Type & Size
Sample Firestop Cable per Item Pipe or ConduitExperiment Reference* Material Construction** Number Number Size, in. (mm)
4344
4547
4648
112112
113114
113114
SRSR
SRSR
SRSR
NoneNone
AA
AA
11
33
32
33
22
1 (25)3 (76)
1 (25)1 (25)
3 (76)3 (76)
SR = Silicone elastomer
* =See Table 15** =See Table 9
-24-
TABLF 7
Sample Experiments - Cable Loading
Experiment
4950
SampleReference*
115116
FirestopMaterial
SRSR
CableConstruction**
AA
Number
1133
SR = Silicone elastomer
* = See Table 16.** = See Table 9.
-25-
TABLE 8
Sample Experiments - Size
Sample FirestopReference* MaterialExperiment
27282930
117117118119
SFSFSFSF
HoleSize, in. (mm)
2 (51)6 (152)9 (130)
12 (305)
SF = Silicone foam
* = See Table 17.
-26-
TABLE 9
Cable Constructions
Cable CrossSection
Diameter,i n. (mm)
ApproximateConductor
Insulation/Jacket
Thickness,in. (nm))
ConductorNo./Size Type
Insulation/JacketMaterial
CableJacket Material
7/12 AWG Cu 0.785 Ethylene propylene(19.9) rubber/chloro-
sulphonated poly-ethylene
7/12 AWG Cu 0.493 Crosslinked(12.5) polyolefin/none
7/12 AWG Cu 0.602 Polyethylene/(15.3) Polyvinyl chloride
7/12 AWG Cu 0.515 Polyvinyl chloride(13.1) nylon
3/12 AWG Cu 0.445 Polyethylene/(11.3) Polyvinyl chloride
0.028/0.017 Chlorosulphonated(0.71/0.43) polyethylene
0.030/- Crossl inked
(0.76/-) polyoleffn
0.029/0.012 Polyvinyl(0.74/0.31) chloride
0.022/0.006 Polyvinyl(0.56/0.15) chloride
0.039/0.012 Polyvinyl(0.99/0.30) Chloride
ApproximateCable
JacketThickness,in. (,,m)
0.134 (3.4)
0.054 (1.4)
0.062 (1.6)
0.050 (1.3)
0.056 (1.42)
300 1C0 Cu 0.821(10.8)
300 1104 Al 0.832(21.1)
350 104 Cu 0.884(22.5)
Polyvinyl chloride
Polyvinyl chloride
Polyvinyl chloride
0.149(2.78)
0.140(3.56)
0.100(2.54)
None
None
None
None
None
None
Identification of materials was based upon the manufacturer'sproduct literature.
-27-
TABLE 10
Conduit and Pipes
Conduit
Trade Sizein. (mm)
1 (25)1 (25)3 (76)3 (76)
MaterialType
SteelAluminumSteelAluminum
Inside Diameterin. (mm)
1.049 (26.6)1.049 (26.6)3.068 (77.9)3.068 (77.9)
Wall Thicknessin. (mm)
0.133 (3.38)0.133 (3.38)0.216 (5.49)0.216 (5.49)
Pipes
Trade Size
in. (mm)
1 (25)
3 (25)
Material Inside Diameter
in. (mm)
Wall Thickness
in. (mm)
0.133 (3.38)
0.216 (5.49)
Steel
Steel
1.049 (26.6)
3.068 (77.9)
-28-
TABLE 11
Pressure Differential Samples
SampleReference
Floor SlabType No.
Firestop MaterialThickness,
Type in. (mm)
Hole 1
T•ype No.
Hole 2Cable
Type No.
100101102
* 5 SFI 2 SRI 2 D
6.0 (150)6.0 (150)3.75 (95)
AAA
333
NoneNoneNone
SF = Silicone foamSR = Silicone elastomer
D = Firestop device
-29-
TABLE 12
Pressure Differential Samples
Firestop MaterialSample Floor Slab Thickness, Cable
Reference Type No. Type in. (mm) Type No.
103 II 2 SF 6.0 (150) B 1103** II 1 SF 6.0 (150) B 1
103*** II 2 SR 2.5 (64) B 31
SF = Silicone foamSR = Silicone elastomer
** = Firestop formed with an 0.38 in. (10 mm) wide by9.5 in. (240 mm) long by 4 in. (100 mm) deep crack, asseen from the unexposed side, along one edge of theopening.
= Firestop formed with two holes caused by pulling cablesout after material had cured. Cable tray used asraceway for the cable bundle.
-30-
TABLE 13
Fire Exposure Samples
Sample
Reference
104105
Floor Slab
Type No.
II 2II 1
Firestop Material
Thickness,
Type in. (mm)
SF 6.0 (150)SR 4.0 (100)
Cable
Type No.
B 1A 11
SF = Silicone foam
SR = Silicone elastomer
-31-
TABLE 14
Sample Construction - Conductor Type & Size
Hole 1Firestop Material
Sample Floor Slab Thickness, Cable*Reference Type* No. Type In. (mm) Construction No.
Hole 2Ffrestop Material
Thickness, Cable*Type in. (mm) Construction No.
106107108109110111
111111
SRSRSR
SRSRSR
6.0 (150)6.0 (150)6.0 (150)6.0 (150)6.0 (150)6.0 (150)
CEF
111
DDDDD
SR
3.75 (95)3.75 (95)3.75 (95)3.75 (95)3.75 (95)6.0 (150)
CEFBAH
111111
B 1A 1G 1
SR = Silicone elastomerD = Firestop device
* = See Table 9
-32-
TABLE 15
Sample Construction - Conduit or Pipe
SampleReference
112
113
114
Floor Slab Penetrating Items Cable/ItemType No. Type No. Size** Construction No.
II
II
XI
1 Steel PipeSteel Pipe
1 Steel ConduitSteel Conduit
1 AL ConduitAL Conduit
32
32
32
13
13
13
NoneNone
AA
AA
13
13
Silicone elastomer, 4.0 in. (100 mm) thick, used as firestopmaterial.
** = Trade Size (in.)
-33-
TABLE 16
Sample Construction - Cable Loading
SampleReference
Floor SlabType No.
CableFirestop Material
Thickness,No. Type in. (mm)Construction
115116
I 1I 1
AA
1133
SRSR
4.0 (101)4.0 (101)
Cables installed in a 6 in. wide cable tray.
SR = Silicone elastomer
* = See Table 9
-34-
TABLE 17
Sample Constructions - Opening Sizes
Sample
Reference
117
118119
Floor Slab
Type No.
III 1
Opening
Size in. (mm)
2 (51) and6 (150)9 (230)
12 (300)
Firestop MaterialThickness,
Type in. (mm)
SF 6.0 (150)
IVV
11
SFSF
6.0 (150)6.0 (150)
All samples installed without cables.
SF = Silicone foam
-35-
TABLE 18
Slab Humidities
Slab Humidity Priorto Experiments, percentExperiments
1, 23, 45, 67, 89, 10
11, 1213, 1415, 1617, 18
1920212223242526
27, 282930
31, 3'33, 3435, 3637, 3839, 4041, 4243, 4445, 4647, 48
495051
7571757474737074746467606264616062707067736674717369666161666160
-36-
TABLE 19
Thermocouple Locations
ThermocoupleFigure No. Location
6
7
8
33
28
24
25
22
23
9
10
11
25
22
23
26
27
29
On unexposed surface ofat the centerOn unexposed surface ofat the center.On unexposed surface ofon N-S centerline 3 in.On unexposed surface ofon E-W centerline 3 in.On unexposed surface of1/2 in. from cableOn unexposed surface of3/4 in. from cableOn unexposed surface ofon N-S centerline 3 in.On unexposed surface ofon E-W centerline 3 in.On unexposed surface of1/2 in. from cableOn unexposed surface of3/4 in. from cableOn unexposed surface ofon N-S centerline 2-1/4On unexposed surface ofon E-W centerline 1-1/2On unexposed surface of1/16 in. from cableOn unexposed surface of1/16 in. from cableOn unexposed surface of1/16 in. from cableOn unexposed surface of1/16 in. from cable
firestop material
firestop material
firestop materialfrom north edge.firestop materialfrom east edge.firestop material
firestop material
firestop materialfrom north edge.firestop materialfrom east edge.firestop material
firestop material
firestop materialin. from south edge.firestop materialin. from east edge.firestop material
firestop material
firestop material
firestop material
12
13
14
15
16
1718
19
20
83
153
1541
29
24
orororororor
292192143
In conductor at the unexposed surfac-On 1 in. pipe at the unexposed surf eOn 3 in. pipe at the unexposed sur' -eOn 1 in. conduit at the unexposed L rfaceOn 3 in. conduit at the unexposed surfaceOn unexposed surface of firestop material1 in. from cable
-37-
TABLE 20
Duration and Time to FlamingFor Pressure Differential Experiments
ExperimentExperiment
Duration (min) Time to Flaming (min)
91357
102468
21588117112113
21588117112113
270245185
155
156
106
125125
NR86116110112
208NRNRNRNR
NRNRNR
153
154
104
13, 1411, 12
15, 16, 17, 18
2320
19
2122 NR
* - After 15 min, smoke,was ignited by matchthe experiment.
which issued through hole,several times during
NR = Flaming did not occur during experiment.
-38-
TABLE 21
Flame Occurrence Time and Pressure
Experiment 51
Hole Diameter, in. (nm)
6.003.000.?50.50
Time, s
2560640780
Pressure, in. H.0 (Pa)
0.00070.00760.01230.0161
(0.18)(1.88)(3.05)(4.02)
-39-
TABLE 22
Duration and Time to Flamingfor Fire Exposure Experiments
Experiment Duration (min) Time to Flaming (min)
242526
180:! 12270
177211NR
NP = Flaming did not occur during experiment.
-40-
Experiment
35, 3637, 38
41, 3942, 40
31, 32, 33, 34
43, 44
45, 4746, 48
49, 50
27282920
TABLE 23
Duration and Time to Flamingfor Sample Experiments
Duration (min) Time to Flaming (min)
245 NR245 NR
245 NR245 NR
245 NR
270 NP
270 NR170 NR
270 NR
120 NR120 119132 131125 .124
NR = Flaming did not occur during experiment.
-41-
_____ 9
__________________ 4.
TYPE II
TYPE III
- 79"
52.2
L
TYPE IV TYPI V,
ALL SLABS - NOMINAL 36 x 36 x 6 IN. THICK
Figure 1 - Floor Slabs
-42-
OBSERVATION PORTS
Figure 2 - Furnace
-43-
cable
For positive pressure experiments of 0. 25 in water(63 Pa) or greater. the enolo'ure woe used withair exhausted from the enclosure. For negitive pressureexperiments (PB.P18). the enclosure was used withair forced into the enclosure. In the remainingexperiments, the enolosure was not used.
Figure 3 - Enclosure
-44-
911
171- 17
36"
a ~
-3b"
Figure 4 - Pressure Probe Locations
-45-
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/
NFRC FORM 335 U.S. NUCLEAR REGULATORY COMMISSION 1. REPORT NUMBER (Asignedby DDC1141 NUREG/CR-4112, Vol. 2
BIBLIOGRAPHIC DATA SHEET US 75-24. TITLE AND SUBTITLE (Add Volume No., if eppropriete) 2. (Leave blank)
Investigation of Cable and Cable System FireTest Parameters 3. RECIPIENT'S ACCESSION NO.Task B: Firestop Test Method
7. AUTHOR(S) 6. DATE REPORT COMPLETEDMONTH j YEAR
DPrpmbpr 19849. PERFORMING ORGANIZATION NAME AND MAILING ADDRESS (Include Zip Code) DATE REPORT ISSUED
Underwriters Laboratories Inc. MONTH J YEAR333 Pfingsten Rd. Thntiiry 1985Northbrook, IL 60062 6. (Leave blank)
8. (Leave blank)
12. SPONSORING ORGANIZATION NAME AND MAILING ADDRESS (Include Zip Code)
Division of Engineering TechnologyOffice of Nuclear Regulatory Research 11. FINNO.U.S. Nuclear Regulatory CommissionWashington, DC 20555 B6197
13. TYPE OF REPORT PERIOD COVERED (inclusive dates)
Final
15. SUPPLEMENTARY NOTES 14. tLeave blank)
16. ABSTRACT (200 words or less)
An experimental investigation was conducted to provide dataconcerning the effects that changes in pressure differential,fire exposure and sample construction have on firestop performancewhen exposed to a standard fire test. Fifty-one fire test experi-ments were conducted using pressure differentials between -12 to+120 Pa, different sample constructions and two fire exposureconditions. Findings were that small changes in pressure differentialdid not have a significant effect on firestop materials that did nothave cracks or through openings to allow passage of gases during fireexposure. If the materials allowed passage for gases through cracksor holes, such as those left open after pulling a cable, changingthe pressure differential affected the firestop performance. Also,it was demonstrated that changing the size of the opening; size,location and type of the penetrating items installed through theopening; and severity of fire exposure affected the performance ofthe firestop.
17. KEY WORDS AND DOCUMENT ANALYSIS 17a. DESCRIPTORS
Firestops, Penetrating Items, Pressure Differential, FireExposure Conditions, Sample Construction, Temperatures
17b. IDENTIFIERSIOPEN-ENOED TERMS
18. AVAILABILITY STATEMENT 19. SECURITY ASS (This report; 21. NO. OF PAGES
Unlimited 20. SECUJbiLASS (This Pra) 22. PRICES
NRC FORM 335 111411
4b
.1 .............. I- - -
UNITED STATESNUCLEAR REGULATORY COMMISSION
WASHINGTON, D.C. 20555
OFFICIAL BUSINESSPENALTY FOR PRIVATE USE, 430
FOURTH CLASS MAIL
POSTAGE b FEES PAIDUSNAC
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