05000313/FIN-2016007-17
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Finding | |
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| Title | Determine Impact of Modifying Fire Seals for Flood Protection |
| Description | The team identified an unresolved item related to ability to meet the requirements of License Condition 2.C.(8) and 2.C.(3)(b), Fire Protection Program, in Units 1 and 2, respectively. Specifically, the team identified ANO had modified numerous fire rated seals to also provide a flood protection barrier without ensuring existing fire protection requirements continued to be met. ANO Units 1 and 2 used a 3- hour fire rated silicon foam material to seal floor and walls penetrations in order to provide adequate separation to prevent the spread of fire between fire areas. ANO determined that numerous exiting fire seals were also required to provide flood protection. To provide an 3-hour fire barrier and also be capable of withstanding a design basis flood, ANO issued design changes to use several materials, such as Polywater FST Foam Sealant, Promatec Product 12 (P12), Sylgard, and Promatec High Density Silicone Elastomer (HDSE and HDSE-IR), to create dual purpose seals. The team determined that HDSE, HDSE-IR and Sylgard have been tested as a 3-hour fire barrier and tested satisfactorily to provide adequate flood protection. However, ANO could not produce documentation to show that fire rating testing or qualification testing had been performed for the new dual function seals using P12 and Polywater. This was documented in CR-ANO-C-2016-00490. ANO has determined that the population of the non-qualified seals was 139 (96 containing Polywater and 43 containing P12). ANO stated that all of the new dual function seals using P12 consist of the flood protective layer of P12 being placed on top of the existing originally qualified 10 inch fire silicone seal, and that no credit was given to the P12 layer to provide any additional fire protection capabilities. The P12 has been tested by Promatec with silicone seals for flood and was flood tested by the station for use with silicone foam seals. Therefore, ANO believes that no negative chemical reactions can be expected. ANO installed Polywater material either on top of the currently installed fire barrier seal, or in electric conduits that are not required to have a fire seal present. Polywater is designed to create an air and watertight barrier suitable for use in conduits. ANO did not remove any portion of the originally qualified silicon foam fire seals, therefore the flood protection layer of Polywater was applied on top of the existing qualified fire seal. As part of the approved Fire Protection Program, a periodic visual inspection of fire penetration seals is required by TRM 3.7.12.3 and TRM 3.7.5, for Units 1 and 2 respectively, such that 10 percent of the total fire seal population is inspected each year. These inspections are conducted per Unit 1 procedure OP 1405.016, U-1, Penetration Fire Barrier Visual Inspections, and Unit 2 procedure OP 2405.016, U-2, Penetration Fire Barrier Visual Inspections. The team reviewed the inspection procedures and interviewed the fire protection engineers. The team was concerned that for many of the new dual function seals, the original fire rated and qualified seal was no longer accessible for performance of required visual inspections. The team was concerned that because the silicone fire seals are no longer accessible for inspection, the intent of the required fire seal inspection to detect surface flaws or damage to indicate potential underlying damage has occurred to the qualified fire penetration system per the fire protection program could not be met. The team concluded that not having fire rating qualification testing for the existing configuration of some fire seals, and the inability to perform required periodic visual inspections for newly modified fire seals, was a performance deficiency that was reasonably within ANOs ability to foresee and prevent. Since ANO has not yet completed the evaluation or fire testing qualification of the modified seals, the team was unable to evaluate the overall impact of this condition or classify the performance deficiency. ANO intended to complete the evaluation of these issues and document the results in CR-ANO-C-2016-00490. Some of the actions being considered include performing required 3-hour fire testing in representative dual function configurations containing Polywater or P12; and doing a feasibility study for removal and replacement of these seals with fire and flood qualified materials. The team concluded that further review is necessary in order to properly evaluate and disposition the significance of this condition. Specifically, the NRC will need to review the following: ANOs evaluation, extent of condition, and disposition and/or testing results of the non-qualified dual function fire/flood seals; and the significance of the non-qualified population (139 seals containing Polywater or P12). This item is being treated as an unresolved item (URI)05000313/2016007-17 and 05000368/2016007-17, Fire Seals Modified for Flood with Material not Qualified for Fire and Inability to Perform Required Periodic Visual Inspection. |
| Site: | Arkansas Nuclear  |
|---|---|
| Report | IR 05000313/2016007 Section 4OA4 |
| Date counted | Mar 31, 2016 (2016Q1) |
| Type: | URI: |
| cornerstone | Barrier Integrity |
| Identified by: | NRC identified |
| Inspection Procedure: | IP 95003 |
| Inspectors (proximate) | B Correll C Osterholtz D Betancourt D Lackey D Willis E Duncan G Hansen J Brand J Dixon J Mateychick L Mckown M Holmberg M Keefe M Phalen N O'Keefe P Mckenna R Alexander R Deese R Kopriva R Kumana S Graves S Morrow S Rich S Smith T Hartman W Sifre Z Hollcraftb Correllb Tindell G Pick J Choate J Dixon J Mateychick M Phalen M Tobin N Greene N O'Keefe P Jayroe R Deese S Money M Kirk |
| Violation of: | Pending |
| INPO aspect | |
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Finding - Arkansas Nuclear - IR 05000313/2016007 | ||||||||||||||||||||||||||||||||||||||||||||||||||||||||||||||||||||||||||||||||||||||||||||||||||||||||||||||||||||||||||||||||||||||
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Finding List (Arkansas Nuclear) @ 2016Q1
Self-Identified List (Arkansas Nuclear)
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