IR 05000348/1997012
| ML20211K840 | |
| Person / Time | |
|---|---|
| Site: | Farley  |
| Issue date: | 09/26/1997 |
| From: | NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION II) |
| To: | |
| Shared Package | |
| ML20211K788 | List: |
| References | |
| 50-348-97-12, 50-364-97-12, NUDOCS 9710100053 | |
| Download: ML20211K840 (51) | |
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U.S. NUCLEAR REGULATORY COMMISSION (NRC)
REGION 11 Docket Nos: 50 348 and 50 364 License Nos: NPF-2 and NPF-8 Report Nos: 50-348/97-12 and 50 364/97-12 Licensee: Southern Nuclear Operating Company. Inc.
Facility: Farley Nuclear Plant (FNP), Units 1 and 2 Location: 7388 North State Highway 95 Columbia, AL 36319 Dates: August 18 22, 1997 Inspectors: G. Wiseman, Reactor inspector Approved by: C. A. Julian, Acting Chief Special Inspection Branch Division of Reactor Safety ENCLOSURE 2 9710100053 970926 DR ADOCK 0500 3 8
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EXECUTIVE SUMMAM Farley Nuclear Power Plant. Units 1 and 2 NRC Inspection Report Nos. 50-348/97-12 and 50-364/97-12 This inspection included review of fire protection program activities to support the design basis of silicone foam fire barrier penetration seals and the Kaowool Electrical Raceway Fire Barrier System (ERFBS) used to separate safe shutdown functions as required by 10 CFR Part 50, Appendix R.
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Results:
. The design and construction attributes of as-built silicone foam penetration seals were consistent with the methods used to construct the fire endurance test specimens (Section F2.1).
. The installation and repair procedures for penetration seals provided adequate guidance to ensure materials were ir. stalled per design requirements and the 18 month surveillance requirements were established appropriately to verify operability (Section F2.1).
. The silicone foam penetration seal designs were not supported by engineering evaluations that satisfy the guidance of GL 86-10 for deviations from the f 4 e barrier configuration qualified by tests (Section F2.1).
. A violation was identified for failure to correctly translate applicable design basis input requirements of the design specifications for Kaowool ERFBS into the installation procedure (Section F2.2).
. Additional discrepancies were identified where the in-plant configurations did not replicate the tested configurations. The additional information addressed in the discreparcies t.ontained in this report are identified as a portion of unresolved item 50-348, 364/96-09-08. This issue is pending further NRC review (Section F2.2).
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REPORT DETAILS: -;
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. IV.l P1 ant Sucoort :
- :F2L Status of-Fire ~ Protection Facilities-and Equipment
F2.1 -Silicone Foam Penetration Seals a..- Insoection Scoce (64704)
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Fire barriers include penetration seals, wraps. walls, structural member fire resistant' coatings, doors, dampers, etc. Fire barrier penetration 1
' seals are used to prevent the spread of fire and to protect redundant: :
- safe shutdown equipment. Laboratory testing of fire barrier- materials'
is done only on a limited rmge of test assemblies. Inolant installations can vary from' the tested configurai. ions. Jnder the-
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provisions _ of:GL 8610 Implementation of; Fire Protection Requirements.
l licensees are permitted to-develop engineering evaluations justifying such deviations. The inspector reviewed the fire barrier silicone foam penetration _ seal design and testing. The inspector compared as-built fire barrier silicone foam penetration seals _to fire endurance test- -
configurations _ to verify that those as-built penetration seals reviewed were qualified by appropriate fire endurance tests.. representative 01, and bounded by the design and' construction of the fire endurance test sp'ecimens. During plant walkdowns the inspector observed the installation configuratiori of selected fire barrier silicone foam ,
penetration seals to confirm that the licensee had established an *
acceptable design basis for those fire barriers used to separate safe shutdown functions.
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b. Qb.sgrvations and Findinas Final Safety Analysis Report (FSAR) Section 98.4.1.4. Fire Barrier Penetrations, states that, with the exception of penetrations between
< containments'and the electrical-penetration rooms, all electrical and-mechanical penetrations through fire rated barriers are sealed with fire tested designs _of either silicone foam, silicone rubber boots, non -
shrink grout, or_ Nelson multi-cable transit systems. Silicone foam penetration. seal designs were qualification tested in accordance with ASTM E119-73 and ASTM E84 testing criteria.
The inspector reviewed Bechtel Power Corporation Specification
- No;-SS-1102-132.l Addendum 10. " Piping.
- Instrumentation Tubing. Ductwork.
ElectricaliRaceways and Firewall Penetration Seals":~ electrical maintenance procedure FNP-0-EMP-1370.02.- Revision 7, " Installation and y Repair-of Penetration or-Conduit Seals";~ Factory Mutual Research:(FM)
! fire. test report Serial No. 27290-(4510). dated February 19. 1976. and
. drawings D 1760S8 through D-176063 for the physical location of fire
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areas; and, assessed the licensee's supporting technical justification and any available engineering evaluations for the sampled silicone foam type penetration seals.
The 1ollowing Unit 1 silicone foam penetration seals were reviewed.
. 24-100-32 Silicone foam elastomer blockout opening with penetrating conduit
. 09-139-9 Silicone foam elastomer blockout with penetrating cable tray and conduit
. 02-139-29 Silicone foam elastomer blockout opening with penetrating conduit The inspector's review focused on verifying that the following design and installation parameters for the as-built configurations were adequately bounded and justified by licensee's engineering evaluations:
. cable f il conditions:
. cable type and size:
. penetration opening sizes:
. clearances of penetrating items:
. unexposed surface temperatures: and
. thermocouple locations.
The inspector found that penetration seal field verification documentation was maintained by the lic u see. However, the as-built documentation did not identify important design parameters with respect to cable tray fill, the maximum or minimum clearances of penetrating items and its thermal mass, and the maximum free area of unsupported penetration seal material installed within the penetration. The installation and repair procedures for penet ation seals provided adequate guidance to ensure materials were a: stalled per design requirements and the 18-month surveillance requirements were established appropriately to verify operability. Although the construction attributes of the as-built drawings were bounded by the tested prototype configurations for the silicone foam seals, the thermal mass of the items that peretrate the as-built penetration seals, the clearances of penetrating items and the maximum free area could not be determined by the inspector.
The licensee was unable to locate GL 86-10 engineering evaluation documentation that evaluated the adequacy of the deviations from a tested fire barrier configuration. This does not satisfy the guidance of GL 86-10. The licensee stated that industry documentation is ENCLOSURE 2
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available to support silicone foam penetration seal installations'at Farley and~ appropriate engineering evaluations will be documented to evaluate the as-built seal configurations.
The clearances of penetrating items, the maximum free area. the actual thermal mass of the items that penetrate as-built silicone foam
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penetration seals and evaluations of deviations from tested fire barrier configurations will be reviewed during a subsequent NRC inspection.
This is identified as Inspector Follow-up Item-(IFI) 50-348, 364/97-12-01. Review of Engineering Evaluations to Establish the Fire Rating or Fire Resistant Capabilities of Fire Rated Silicone foam Penetration Seals.
A similar issue related to an evaluation to establish the qualification of Unit 1 silicone foam penetration seals was identified during a NRC design inspection. This issue was identified as Unresolved Item (URI)
50-348/201-20. Fire Barrier Penetration Seal Documentation, and will be inspected as a portion of IFI 50-348. 364/97-12-01 above.
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c. Conclusions The inspector concluded that the design and-construction attributes of as built silicone foam penetration seals were consistent with the methods used to construct the fire endurance test specimens. The installation and repair procedures for penetration seals provided adequate guidance to ensure materials were installed per design requirements and the 18-month surveillance requirements were established appropriately to verify operability. However, the designs were not supported by engineering evaluations that satisfy the guidance of GL 86-10 for deviations from the fire barrier configuration qualified by tests.
F2.2 Kaowool Electricai Raceway Fire Barrier Svstems (ERFBS)
(00en) Unresolved Item Nos. 50-348. 364/96-09-08. Adeauacy of Kaowool
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Qualification Tests to Scope Installed Confiaurations.
a. Insoection Scoce (64704)
The inspector performed a review of the. design and testing basis of the installed ERFBS used to separate safe shutdown functions within the same fire area as required by 10 CFR Part 50. Appendix R.Section III.G.2.c.
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Additional reviews are documented in NRC Inspection Reports 50-348:
364/96-09 and 96-13. The inspector compared as-built Kaowool ERFBS to fire endurance test configurations. This comparison was made to verify that those as-built fire barrier configurations which were audited were ENCLOSURE 2
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qualified by fire endurance tests, representative of, and bounded by the design and construction of the fire endurance test specimens. During plant walkdowns the inspector observed and photographed the installation configurations of selected Kaowool ERFBS to confirm that the licensee had established an acceptable design basis for those fire barriers used to separate safe shutdown functions within the same fire area.
b. Observations and Findinos Kaowool ERFBS (approximately 6300 lineal feet installed in 1979-80) was used to separate safe shutdown functions within the same fire area and was accepted by the NRC prior to the effective date of Appendix R.
Plants that had Kaowool ERFBS accepted by the NRC and installed prior to the effective date of Appendix R were not required to replace them even though this system did not meet the 325'F cold sido temperatures criterion. Unresolved Item 50-348. 364/96-09-08 was opened to track the issue of the adequacy of Kaowool qualification tests to bound the installed fire barrier system configurations.
As discussed in NRC inspection reports 96-09 and 96-13. the inspectors found that the fire tests performed to support fire endurance performance of Kaowool were limited and small scale. The test specimens had not been subjected to a hose stream tests to demonstrate structural integrity. Further, the acceptance criteria for qualifying the material was based on circuit integrity monitoring and cables were found to exhibit significant signs of fire damage at the conclusion of the test.
The inspector found the qualification status of the Kaowool fire barrier remained unchanged since the 1996 NRC inspections.
The inspector reviewed the following documentation associated with the Kaowool ERFBS:
- Babcock and Wilcox (B&W) fire test report dated October 24. 1978.
" Test for Fire Protection for Complete Fire Engulfment of Cable Trays and Conduits Containing Grouped Electrical Conductors."
. B&W Evaluation dated January 5. 1978. " Sealants for Prevention of Soaking of Flammable Liquids into Kaowool Blanket Wrap Around Cable Trays During Complete Engulfment Fires."
. Southern Nuclear Operating Company internal memorandum NEL-93-0336. dated October 21. 1993. "NRC Information Notice 93-41" ENCLOSURE 2
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. Design specification drawings A-177541. Sheets 18G-18V. "Kaowool Blanket Wrap for Fire Protection. Tray and Conduit General Details and Notes.'
. Design drawings D-180500 series. Sheets 180529-180549. Unit 1 Tray and Conduit Layout. Safe Shutdown Raceway ID & Location of Kaowool Wrap."
. Procedure FNP-0-PMP-507. Revision 7. "Kaowool Installation Procedure."
. Operations Quality Assurance Procedure Manual. Chapter 3. Revision 31. " Design Control."
The following summarizes the open technical issues for the Kaowool ERFBS used at Farley:
Discrepancies Between As-Tested Fire Barrier Details. Design Specification Details. and Farley Kaowool Installation Procedure The ERFBS at Farley consists of two 1-inch layers of Kaowool and an overall layer of Zetex fabric. The layers of material have butt joints where the different inner layers meet and the outer layers meet. The butt joints of the outer layer of Kaowool material are secured with steel banding.
The Babcock and Wilcox fire test report established the tested fire endurance rating of the Kaowool ERFBS. According to the B&W fire test report, test specimens consisted of two 1-inch layers of Kaowool blanket installed on 18-inch wide cable trays and 4-inch diameter conduits.
Along the length cf the tested specimens, where one blanket ended and another began, the blankets were butted together. The butt joints of the inner blanket and outer blanket of tested fire barrier specimens were separated by a distance of at least 18 inches. Farley Kaowool ERFBS design specification drawings A-177541. Sheets 18G-18V.
established the design input requirements of the fire barrier wrap.
Specifically drawings A-177541. Sheets 18K and 18M. specified the separaticr 'tistance of these butt joints at 15 inches for a cable tray and 14 incom * r a conduit, respectively. Section 6.2.5 of the Kaowool installation praedure and the associated procedure sketches. specified only a 12 inch separation of any exterior to interior butt joint. The reduction in the butt joint separation distance from 18 inches in the tested configuration to 15 inches in the design specification and to 12 inches in the installation procedure for the as-built Kaowool ERFBS configurations was considered by the inspector to be nonconservative.
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Also the inspector'noted that both the tested specimens-and the design-specification drawings required the butt joint banding be placed at a maximum of three inches from each side of the butt joints on the outer
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Kaowool blanket wrap for cable trays. However..Section 6.2.6 of the installation procedure allowed the bands to be placed as much as four inches from any butt joint on the exterior blanket Drap. According to the B&W fire test report, the separation distance of the inner layer _ and any outer layer butt joints and the placement (not greater than three inches) of the outer butt joint holding bands to keep the butt joints tightly sealed were critical attributes of the barrier to prevent
- passage of heated gases through the barrier via the joints. The test
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report stated that for the tested specimens, the Kaowool ceramic fiber blanket wrap was effective in retarding the heat flow into the cable tray vid conduit as long as the butt joints were kept tightly sealed.
During the B&W fire endurance testing, the circuit integrity in one circuit was lost at one hour and one minute for the tested specimens.
Licensee Number NPF-2 Condition 2.C(4), and Licensee Number NPF-8.
Condition 2.C(6), require that Southern Nuclear implement and maintain in effect all provisions of the approved Fire Protection Program (FPP)
as described in the FSAR. FSAR Appendix 9B. Section 9B.2.5.1, and FSAR Section 17.2.3 Design Control describe the design control measures established to assure that design bases are properly translated into specifications, drawings, procedures, and instructions.
The inspector concluded that the design specification input requirements for the Kaowool ERFBS blanket wrap butt joint separation distance and banding location were not correctly translated into Installation Procedure FNP-0 PMP-507. This is identified as a violation of the Operating License VIOLATION 50-348. 364/97-12-02. Failure to Correctly Translate Applicable Design Input Requirements for Kaowool ERFB5 into the Installation Procedure.
The inspector determined that fire watches had been in place as compensatory measures for the degraded electrical raceway fire barriers since October 2.1996, when other issues were identified by the NRC resident inspectors and have provided effective monitoring of assigned
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plant-locations.
-Discrecancies Between As-Tested Unsuocorted Soan Lenath. and As-Installed Unsunoorted Soan Lenath
. According to the B&W fire test report the test specimens consisted of.
two 1 inch layers of Kaowool installed on 18-inch wide cable trays and 4-inch diameter conduits with a maximum unsupported length of 24-inches, During the inspector's walldown of Kaowool ERFBS the inspector noted ENCLOSURE 2
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unsupported span lengths of cable trays and conduits that were greater than the tested 24 inches. These as-t'uilt configurations (illustrated in Attachment 1 Frame #2) were not bounded by the licensee fire endurance testir.g basis.
Discreoancies Between As-Tested Barrier Material Continuity and As-Built Material Continuity The licensee fire endurance qualification test specimen configurations consisted of a Kaowool wrapped cable tray and conduit extending through a catenary furnace. These tested Kaowool fire barrier material wrap configurations were continuous with no interruptions. In all cases the Kaowool wraps extended 12 inches through the walls of the test furnace and were terminated outside the furnace. The furnace openings were then sealed with Kaowool material and firebrick dust. The installed Kaowool ERFBS configurations at Farley were not continuous, but were butted against fire rated barrier floors, ceilings, walls, and penetration seals, and attached to the structure using a mastic coating. These plant configurations (illustrated in Attachment 1, Frames #4, #7, and
- 8) do not appear to be bounded by the fire endurance test specimen documents.
DiscreoJncies Between Tested Cable Tray and Conduit Succort Protection and As-Built Suonort Protection The licensee fire endurance qualification test specimen configurations consisted of a Kaowool wrapped cable tray and conduit extending through the walls of the test furnace. No cable tray or conduit supports typical of those installed at Farley were included in the testing program. The Kaowool installation procedure. FNP-0-PMP-507, Sections 6.2.7 and 6.3.1, state that supports shall be wrapped to a distance not less than 6-inches from the protected raceway or as shown on associated procedure Sketches. The installed Kaowool ERFBS configurations at Farley contained exposed raceway support penetrations wrapped as required by the installation procedure. These plant configurations (illustrated Attachment 1. Frames #1 and #7) do not appear to be bounded by the fire endurance test specimen documents.
The NRC granted an exemption (Request 2-38, FSAR Section 98.b.41.0) from the technical requirements of 10 CFR 50. Appendix R.Section III.G.2 that requires the structural steel supporting raceway fire barrier assemblics to be protected by a fireproofing material having a fire rating of one hour. The exemption was granted on the basis that the licensee's analysis demonstrated that the structural steel supports affected by the area of fire influence were of adequate strength to ensure that the raceways would retain their structural integrity for a ENCLOSURE 2
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9 l-hour fire duration. However, the licensee was unable to locate GL 86-10 engineering evaluation documentation that either evaluated the adequacy of the 6-inch suppo,t wrap design to protect from heat transfer
- from exposed support steel into the ERFBS or supported the deviation from a tested fi e barrier configuration. This does not satisfy the guidance of GL 86-10. The licensee stated that the evaluations were being conducted and estimated that results would be available in 6-8 weeks.
Discrenancies Between As-Tested Cable Tray Size and Percent (%) Fill and As-Built Tray Size and Percent Fill According to the B&W fire test report, the tested cable tray specimens consisted of 18-inch wide cable trays containing a 30-35% cable fill.
During the inspector's walkdown the inspector noted that most of the fire barrier material was installed on 24-inch wide cable trays.
However, Kaowool fire barrier material was also installed on a significant number of smaller 4 , 6- and 12-inch wide cable trays, some containing only 15% cable fill. These plant configurations (illustrated in Attachment 1. Frames #3 and #7) do not appear to be bounded by the fire endurance test specimen documents.
Discrecancies Between As-Tested Conduit Size and Number and As-Built Conduit Size and Number According to the B&W fire test report, the tested specimens consisted of a single 4-inch diameter conduit. During the inspector's walkdown of Kaowool ERFBS the in pector observed that a significant number of multiple conduits were installed within a Kaowool fire barrier. Kaowool fire barrier material was also installed on a significant number of conduits and flexible shielded cables less than four inches in diameter.
These plant configurations (illustrated in Attachment 1 Frame #4, #6,
- 5. #8 and #9) do not appear to be bounded by the fire endurance test specimen documents.
Lack of Testina Basis for Cable Pull Boxes The licensee fire endurance qualification test specimen configurations consisted of two 1-inch layers of Kaowool installed on 18-inch wide cable trays and 4-inch diameter conduits. The inspector observed that a number of cable pullboxes were installed within a Kaowool fire barrier.
No cable pullboxes typical of those installed were included in the licensee's fire endurance testing program. The Kaowool installation procedure, FNP-0-PMP-507. Section 6.6 states that cable pullboxes shall be wrapped as shown on procedure Sketch (No. 10). The designed and ENCLOSURE 2
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installed Kaowool ERFBS pullbox configurations had no design basis that was supported by the fire endurance test specimen documents.
Discrepancies Between As-Tested Fire Barrier and As-Built Fire Barrier with Penetrations for Airdroo Cables. Conduits. Cable Trays. and Raceway S_gpoorts According to the B&W fire test report, test specimens consisted of two 1-inch layers of Kaowool installed on 18-inch wide cable trays and 4-inch diameter conduits. These tested Kaowool fire barriers had no intervening raceway or other penetrations. The inspector observed that the installed raceway fire barriers contained many penetrations. The inspector observed examples of bare cable penetrations (illustrated in Attachment 1 Fra c s #8 and #9), conduit penetrutions (illustrated in Attachment 1. Frames #1, #2, #3, #4, and #9), cable tray penetrations.
(illustrated in Attachment 1 Frames #2, #5, #6, and #7), and raceway support penetrations (illustrated in Attachment 1, Frames #1, #5, #7, and #8). Although design specification drawings A-177541. Section 5.10 of Sheet 18J-1, required that the Kaowool fire barrier wrap be extended to cover the intervening object far enough to insure that a 2-inch minimum coverage is maintained on the protected raceway, and that a mastic coating be installed to secure the Kaowool and protect against potential physical damage, these plant configurations do not appear to be bounded by the fire endurance test specimen documents.
c. Crclusions A violation was identified for failure to correctly translate applicable design basis input requirements of the design specifications for Kaowool ERFBS into the installation procedure.
Additional discrepancics were identified where the in-plant configurations did not replicate the tested configurations. The additional information addressed in the discrepancies contained in this report are identified as a portion of Unresolved Item 50-348. 364/96-09-08. This issue is pending further NRC review.
Fire watches have been in place as compensatory measures for the degraded electrical raceway fire barriers since October 2,1996, when these issues were identified by the Resident Inspectors and have provided effective monitoring of assigned plant locations.
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EXIT INTERVIEW The inspection scope and results were summarized on August 22, 1997 with members of licensee management. The inspector described the areas inspected and discussed in detail the inspection results. Proprietary information is not contained in this report. The licensee's positions concerning the Kaowool ERFBS and the silicone foam penetration seal findings and the inspection documentation are included as Attachment 2 to this report.
PARTIAL LIST OF PERSONS CONTACTED Licensee
- S. Fulmer. Technical Manager
- J. Gates. Maintenance Team Leader
- D. Grissette. Operations Manager
- R. Hill General Manager
- J. Hayes, Fire Marshall
- D Jones. Configuration Management Project Manager
- R. Martin Superintendent Operations Support
- C. Nesbitt. Assistant General Manager - Support
- R. Sprankle. Fire Protection-Engineer
- J. Thomas. Engineering Support Manager NRC Personnel
- T. Ross. Senior Resident inspector
- J. Bartley. Resident Inspector
- R. Caldwell. Resident Inspector
- Attended exit INSPECTION PRDCEDURE USED IP 64704: Fire Protection ENCLOSURE 2
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ITEMS OPENED, CLOSED, AND DISCUSSED Opened lyp_e Item Number Status Descriotion and Reference-IFI 50-348, 364/97-12-01 OPEN Review of Engineering Evaluations to Establish the Fire Rating or Fire Resistant Capabilities of Fire Rated Silicone Foam Penetration Seals.
(Section F2.1)
VIO 50-348. 364/97-12-02 _0 PEN Failure to Correctly Translate Applicable Design Input Requirements
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for Kaowcal ERFBS into the Installation Procedure.
(Section F2.2)
Riscussed URI 50-348. 364/96-09-08 OPEN Adequacy of Kaowool Qualification Tests to Scope Installed Configurations (Section F2.23 URI 50'-348/201-20 OPEN Fire Barrier Penetration Seal Documentation (Section F2.1)
LIST OF ACRONYMS USED B&W Babcock and Wilcox CFR Code of Federal Regulations ERFBS Electrical Raceway Fire Barrier System FNP Farley_ Nuclear Plant FOL Facility Operating License FPP Fire Protection Program FSAR Final Safety Analysis Report GL Generic Letter IFI Inspector Followup Item IP Inspection Procedure IR Inspection Report NRC U.S. Nuclear Regulatory Commission NRR Office of Nuclear Reactor Regulation POR Public Document Room PMP Plant Maintenance Procedure URI Unresolved Item VIO Violation ENCLOSURE 2
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ATTAQHMENT 1 Photographs - Frames #1 through #9
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CONFIGURATION: MOTECTED RACEWAY IVAHD102-LOCATION: UNIT 1. EL. 121'. FIRE AREA 1-4. CORRIDOR ROOMS 208/209 TYPE OF RACEWAY: CONSISTS OF A KA0 WOOL WRAPPED 4" ALUMINUM CONDUIT NRC CONCERNS: I'lINTERFERENCE CONDUlT PENETRATION INTO THE FIRE BARRIER MSTEM (2)THE MINIMAL WRAP ON THE CONDUIT SUPPORTS i
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LOCATION: UNIT 1, EL. 121'. FIRE AREA 1-4. CORRIDOR ROOMS 208/209
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TYPE OF RACEWAY: CONSISTS OF A KA0 WOOL WRAPPED 4" ALUMINUM CONDUIT
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i l NRC CONCERNS: (1) UNSUPPORTED SPAN OF THE AS-BUILT CONFIGURATION IS GREATER l THAN THE TWO FEET SUPPORTED TESTED CONFIGURATION,
(2) INTERFERENCE CONDUll PENETRATION INTO THE FIRE BARRIER
! SYSTEM (3) INTERFERENCE CABLE TRAY PENETRATION INTO THE FIRE BARRIER
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CONFIGURATION: PROTECTED RACEWAYS IVADDA15 / 1'/ADDA09-l
LOCATION: UNIT 1. EL 100', FIRE AREA 1-4 CORRIDOR ROOM 161 TYPE OF RACEWAY: CONSISTS OF WO KA0 WOOL WRAPPED 12" ALUMINUM CABLE TRAYS WITH
- 15% CABLE FILL NRC CONCERNS
- (1) WRAPPED CABLE TRAYS ARE SMALLER 12" WIDE AND HAVE LESS l
'
,
(15%) CABLE FILL DENSITY THAN THE 18" WIDE (30-35% CABLE FILL)
TESTED CABLE iRAY CONFIGURATIONS: INDUSTRY TESTING HAS SHOWN i THAT THESE SMALLER AND REDUCED PERCENT FILL CONFIGURATIONS
., PROVIDE LESS THERMAL MASS (HEAT SINK) CAPACITY AND ARE MORE
'
SUBJECT TO FAILURE DURING FIRE ENDURANCE TESTS (2) INTERFERENCE MULTIPLE CONDUIT PENETRATIONS INTO THE FIRE BARRIER SYSTEM i
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i TYPE OF RACEWAY: CONSISTS OF A KA0 WOOL WRAPPED 3" ALUMINUM CONDUIT i
NRC CONCERNS: (1) LACK OF MATERIAL CONTINUITY OF BARRIER MATERIAL THAT ENDS
! AT THE WALL PENETRATION SEAL; THE FIRE ENDURANCE TEST I
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l (3) INTERFERENCE CONDUIT GROUP PENETRATIONS INTO THE FIRE
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CONFIGURATION: PROTECTED RACEWAY 1VCDIB05-LOCATION: UNIT 1. EL 100'. FIRE AREA 1-5. HALLWAY ROOM 172 l TYPE OF RACEWAY: CONSISTS OF A KA0 WOOL WRAPPED 3" ALUMINUM CONDUIT l
l NRC CONCERNS: (1) INTERFERENCE CABLE TRAY AND STEEL SUPPORT PENETRATIONS INTO THE FIRE BARRIER SYSTEM
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{ TYPE OF RACEWAY: CONSISTS OF A KA0 WOOL WRAPPED 24" ALUMINUM CABLE TRAY NRC CONCERNS: (1) LACK OF MATERIAL CONTINUITY OF BARRIER MATERIAL THAT ENDS
- AT THE WALL PENETRATION SEAL
- THE FIRE ENDURANCE TEST
! CONFIGURATION RR KA0 WOOL DEMONSTRATED SUuCESS WHEN THE 4 MATERIAL WAS CONTINUOUS THROUGH THE PENETRATION.
(2) INTERFERENCE CABLE TRAY PENETRATION INTO THE FIRE BARRIER SYSTEM.
(3) THE TRAY SIZE IS LARGER THAN THE TESTED TRAY CONFIGURATIO1 i
(4) THE 6" SUPPORT WRAPS SHOWN ARE NOT BOUNDED BY OR SUPPORTED
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CONFIGURATION: PROTECTED RACEWAYS BHD099/ BHD064-LOCATION: UNIT 1. EL 100', FIRE AREA 1-6, COMPONENT CCOLING WATER HEAT EXCHANGER ROOM 185 TYPE OF RACEWAY: CONSISTS OF A KA0 WOOL WRAPPED 1-1/2" FLEXIBLE CONDUIT AND 4" CABLE CHANNEL NRC CONCERNS: (1) LACK OF MATERIAL CONTINUITY OF BARRIER MATERIAL THAT ENDS AT THE COMPONENT: THE FIRE ENDURANCE TEST CONFIGURATION FOR KA0 WOOL DEMONSTRATED SUCCESS WHEN THE MATERIAL WAS CONTINUOUS.
(2) THE PROTECTED CONDUIT TYPE AND SIZE IS LESS THAN TESTED:
INDUSTRY TESTS HAVE DEMONSTRATED THAT SMALLER CONDUITS AND FLEXIBLE CONDUITS PROVIDE A REDUCED THERMAL MASS (HEAT SINK)
WITHIN THE INSULATED SYSTEM AND ARE MORE LIKELY TO FAIL FIRE ENDURANCE TESTS, (3) THE 4" CABLE TRAY CHANNEL SIZE IS SMALLER THAN THE TESTED TRAY CONFIGURATION
- _ - _ _ - _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ . _
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! TYPE OF RACEWAY: CONSISTS OF A KA0 WOOL WRAPPED 3" ALUMINUM CONDUIT j
NRC CONCERNS: (1) 1HE PROTECTED CONDUIT TYPE AND SIZE IS LESS THAN TESTED:
- INDUSTRY TEST HAVE DEMONSTRATED THAT SMALLER CONDUITS AND I
FLEXIBLE CONDUlTS PROVIDE A REDUCED THERMAL MASS (HEAT SINK)
WITHIN THE INSULATED SYSTEM AND ARE MORE LIKELY TO FAIL FIRE .
'
ENDURANCE TESTS.
(2) THE BARE CABLE, CONDUlT. AND PULL BOX PENETRATIONS INTO
.
THE FIRE BARRIER SYSTEM
4
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ATTACHMERL2 Licensee Positions and Inspection Documentation
. _ _ _ _ _ _ . . . _ _ _ _ - . _ _ _ _
- * '
. FNP Position .
-
Kaowool
. Kaowool as-installed at FNP will perform its intended design' function.
Therefore, operability is not an issue.
-* Compliance issue - level of documentation necessary to justify installatim -
'
details that deviate from the tested configuration.
. Kaowool approved by NRC 11/20/79, (Reference IN 9341)
. Exemption requests to Appendix R for FNP submitted to NRC requesting approval of two 1-inch thick Kaowool blanket.
. - NRC approved this configuration in SERs (1985) based upon inspections.
. Installation tolerance / deviations was not identified as a concern.
~
. GL 86-10 issued 4/24/86 stated that Kaowool already installed need not be replaced.
'
. NRC Inspection Report dated 11/3/88 identified no violations or deviations
,
relative to Kaowool installations.
,
. IN 93-41 "One Hour Fire Endurance Test Results" recognized the acceptance of Kaowool. Specifically, this IN recognized that the tested configuration was not representative of the in-plant configurations, and the
- ' staff will evaluate whether further gener'n communications are needed to address these issues.
. No further generic written communication concerning installation details deviating from the tested configuration has been distributed by the NRC.
. On 10/16/96, in a conference call, the NRC - NRR informed SNC that GL 86-10 (Enclosure 2, question / answer 3.2.2) cannot be applied to Kaowool since it was " grandfathered" from the Appendix R requirements. FNP should maintain its barriers in the originally designed configuration.
'
. -Therefore resolution of this issue must be addressed by NRC through 10CFR50.109.
FUTURE PLANS
-. Re-analysis of safe shutdown for Appendix R compliance. Existing conservative assumptions will be removed.
. Identify required cables.
- Develop resolution.
. Implement resolution.
- .
' '
- w ,
. . - - _. __ - . - -
..
. . . .
.
.
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FNP; Position Penetration Seals M
. - Installed penetration seals at FNP will perform their intended design function, and prevent fire propagation across fire area boundaries. Therefore, operability is not an issue, .
. Compliance issue -level of docum9ntation necessary to ensure installed!
_ penetration seals are enveloped by tests.
. Original Test Report for penetration seals was selected to be representative of those used at FNP.
. This test reference is documented in the FSAR.-
.- Industry documentation is available to support penetration seal installations at FNP.
. Future inspections will verify that installed configurations are bounded by available test data or appropriate engineering evaluations will be documented.
. FNP staff inspects every fire barrier penetration once every '8 months.
-
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Intrac::mpany Corre: pond:nca SOUthem Nudear Operating Company I
'
NEL 93-0336
-. .
DATE: October 21, 1993
.
RE: - One Hour Fire Endurance Test Results For Thermal Ceramics Kaowool, 3M '. .,mpany FS-l'95 and 3M Company Interam E 50. Fire Barrier Systems IN 93-41
-
FROM: . D. H. Jones TO: Peter Webb Information Notice 93-41, "O$e Hour Fire Endurance Test Results For Thermal Ce Knowool,3M Company FS 195 and 3M Company Interam E-50 Fire Barrier Systems,"
was issued by the NRC May 28,1993 t,9 alert licensees ofNRC concerns associated with .
the results of fire endurance tests for various fire barriers. In response to IN 93-41, REA 93 0271 was issued to Bechtel.
Of the fire barrier systems mentioned by the NRC via IN 93-41, only Kaowool is presently installed at FNP. The licensing buis for use ofKaowool for FNP is clearly documented in the FSAR and various NRC correspondence (see Attachment 1). This fact seems to be acknowledged by the NRC in Attachment I to IN 93-41 which indicates that Knowool was accepted by the NRC 11/20/79. Given that Knowool is clearly an approved barrier, the issues identified by the IN were reviewed to determine whether there was any safety signincance.
. -
The Bechtel response to REA 93-0271 was provided by letter dated 10/01/93 (Attachment 2). In summuy, none of the concems expressed by the NRC alter the conclusion that existing fire endurance tests adequately demonstrate that Kaowool can be
, expected to perform as required in response to a postulated fire.
Approximately 50 manhours (53,500) were expended reviewir@ IN 93-41. Ifyou have any questions please contact Paul Hayes at 8-821-5753.
OPH:maf IN93-41. DOC
-
,-. -
,
Attachments cc: B. L. Moore '
File: ES 92-2388 ^
REA 93-0271 IN 93-41
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9801 W:shsngtorunn Bov4vstid ylgt yung L's *
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G:nhersburg. Maryland 20678 53$6 2 , 4.*,
.(301) 417 3000 gG , * f
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In reply refer ~to AP-20482 y LTC 2 g '
Mr. J. Vice President - Nuclear Southern Nuclear Operating Company c-c. h ^ '^ k '
Nuclear Generation Department Post Office Box 1205 --l c, E bJ 93-Q l Birmingham, Alabama 35201-1295 Cloda<c *
-
Dear Mr. Woodard:
Joseph M. Farley Nuclear Plant Operating Services Bechtel Job 7597-042 Licensing Basis for Kaowool Fire Barrier (ES 92-2388)
Bechtel File A-88 and E-18 This letter.provides a complete response to your ES 92-2388.
In Amendment 3 of the FPPR (Fire Protection Program Re-evaluation)
dated October 1978 a commitment was made to add a double-thick bar2 consisting of two layers of a 30-min rated enclosure around on' e tra of electrical cable where the train-to-train separation was less tt 20 feet.
Prior to Amendment 3, ithak.beendecided (after reviewing several types of fire barriers) that two one inch thick layers of Kaowool-would be an acceptable enclosure ~. Subsequently Drawing A-180561 wa issued to show the raceway locations where Kaowool was required and=
, installation procedures were issued via A-177541. Note that D-size drawings have since been issued to incorporate the information provided in A-180561 as well as to provide hs-built information for.
subsequent Appendix R related design.
On April 13, 1979, the NRC issued the Fire Protection Safety
, Evaluation Report for FNP. It stated that the fire protection prog;;
as then <*adan=<t (as. dar-^nt -a in. Amendments 2, 3 and 4) was acceptable since it met the conditions of Genera 1' Design' Criterion :
as well as the guidelines of Appendix A to BTP APCSB 9.5-1.
'
-
Bechtel Power Corporation a.n< ds,cw cama,
-
__ _ _ _ _ . .. _ -- _ _ . . - . -- -
Mr..J. D.- Woodard-
, ,
-
AP-20482
,
Page 2 ,
.
Effective February 19, 1981, the 1GC again amended its regulations t:
include a - nev - Part 50.4 8 and a new Appendix R to 10 .C!m 50 to upgradJ fire protection at nuclear power plants licensed to operate prior to '
January 1, 1979. After extensive reanalysis which included room-by-room walkdowns and sevegal interim amendment submittals based on additional NRC clarification concerning certain provisions of Appendix R, APCo - (Southern Nuclear . opera ting Co=pany) submitted Appendix 9B of the FSAR to the NRC via letters dated March 13, 1985 and May 31, 1985 to document the technical exemptions requested from-Section III.G., J. and O of Appendix R. Specifically, several of those requested involved Section III.G.2.c to the extent that one train of redundant safe shutdown cable and equipment be enclosed in t fire barrier having a 1 hour1.157407e-5 days <br />2.777778e-4 hours <br />1.653439e-6 weeks <br />3.805e-7 months <br /> rating. As an example, F.xemption Reques 2-2 for Fire Area 2-043 describes additional' protection being afforde in rooms 24 62 and 2452 by enclosing one train of redundant raceways ji a fire-rated barrier. The corresponding NRC EVALUATION for this area states.in part "The S/G-B pressure transmitters and the redundant-S/G-C pressure transmitters located in room 2462 are physically separated by a distance greater than 20 ft. and two channels of the redundant S/G-A, S/G-B and S/G-C pressure transmitter cable raceways routed through room 2462 are protected with fire barriers. The raceway fire barriers are composed of two 1-in.-thick Kaowool blanket wraps with one overall layer of Zetex woven fabric." The NRC then goes on to conclude that this exemption be granted. This is one example which is typical of =any such Exemption Requests which have been approved by the NRC.
Finally, the NRC issued Generic Letter 86-10 on April 24, 1986 to provide further guidance resul' ting from Regional Workshops which had been conducted to clarify various Appendix R requirements. Under Section 3.2.1 Acceptance Criteria for Fire Barrier OualificatioD of that letter it states in part that " Conduit and cable tray enclosure materials accepted by the NRC as 1 hour1.157407e-5 days <br />2.777778e-4 hours <br />1.653439e-6 weeks <br />3.805e-7 months <br /> barrier prior to Appendix R (e.g. some Kaowool and 3M materials) and already installed by the licensee need not be replaced even though they.may not have met the 325 F criteria." Note that the initial tests for Kaowool were based on ASTM E-119 time temperature curves.
The NRC has indicated that an:
"new" wrapping material which is required meet the acceptance criterit as defined in Chapter 7 of NFPA 251, i.e , - the unexposed barrier surface should not be more than 250 F above ambient which is generall!
recognized to be 325 F.
,,
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=
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_ . _ _ _ _ _ _ . . . _ _ _ _ _ _ _ _ _ . _ ,
'
Mr. J. D. Wonderd
. * '
AP-20482
. PC90 3 l
i
{
!
a Therefore, the issuance of Amendment 3 of the TPPR along with the ;
'
subsequent response to App.endix R and the information contained in [
Generic Letter 36 *10 all form the licent!.ng basis for the use of r Xaowool. Consequently the existing installation of XaoWool at TNP !
acceptable even though future applications are not covered by the I
reterenced documents.
If yu have any questions or comments, please contact Bob Puhl at (301) 417-8632. *
T
,
Sincerely yours, 1
'
'
BECHTEL POWER CORPORATION <
i
.
A, UNIT OF BECHTEL CORPORATION S
i J. E. Love !
l Project Engineer
'
JEL/JES/RJP saf
'
ci:: R. D. Hill,. FNP
,
D.-J.-Shelton, SCS f
i J. A. Wahrenberg, SCS
^
J. H. Shivers, SCS J. W. Wilson, SCS D. H, Jont n, SNC,.,w/ original .
i J. A. Knochel, WEC
.
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, . .
.
EUNEISEE 9801 washongtonen Bov4.orcf i
Gartnersbyg, Marytend 20618$356
, (301) d t ?.3000
-
OCT 01 1993 ,
In reply refer to AP-20847 CL cM M <-- [
.
i Mr. D. N. Morey -
-o EQ 93-N ;
Vice President - Nuclear i Southern Nuclear Operating Company \O N'C Nuclear Generation Department Post Office Box 1295 Birmingham, Alabama 35201-1295 Dear Mr. Morey - -
Joseph M. Tarley Nuclear Plant Operating Services
Bechtel Job 7597 Technical Justification Review of IN93-41 Bechtel File A-88 and E-18 (REA 93-0271)
,
This letter provides a complete response to your REA 93-0271. c The information contained herein is per your request to provide a
'
>
technical justification of the three fire bar.rier systems (FS-195, ,
Interam E-50 and Kaowool) addressed in NRC Informatich Notice 93-41.
As listed in Attachment 1 of the Notice, JM Company's ~ FS-195 was onl ~
used at Salem. In addition, 3M Company's Interam E-50 Fire Barrier System has not been used or specified for use at FNP. However, for referer.ce please note that 3M Company's Interam E-53 and E-54A fire protective systems have been specified for use at FNP as acceptable alternate fire barrier systems as documented in AP-19390 dated
. November 12, 1991 and AP-20534 De,cember 29, 1992.
Knowool was selected and installed at FNP between 1979 and 1980.
The selection was based on several presentations and verbc1 discussions with Babcock & Wilcox along with*a test report they had issued entitled " TESTS FOR FIRE PROTECTION FOR COMPLETE ENGULTMENT 01 CADLE TRAYS AND CONOUITS CONTAINING GROUPED ELECTRICAL CONDUCTORS" dated October 24, 1978. Subsequently, due to a concern regarding other testing which had been done at Sandia Labs as to the ability 01:
Kaowool to provide sixty minutes of protection, B&W was epntacted anc alerted to our concern over this issue. In response, B&W sent us UL test report 78NK5345 dated September 6, 1978, a test report conducted by Cincinnati Gas & Electric and an affidavit 1' rom the NRC stating their acceptance of Kaowool. Therefore, based on these reports and general industry and HRC acceptance of Knowool, it was concluded that!
Knowool would provide adequate protection.
.
k i
e r e- w e , -r t- -
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- _ . - ___._._._
.
,
Mr. D. N. M2rcy
< *
AP-20847 *
. Pego 2 l r
'
.
. i f
The format you requested for the details of the technical justification for Kaowool is presented below.
. .
" summary of Test Results" l
Parameter Knowool ,
scale of test small-scale (1) l
'
!
Test laboratory Independent (2)
'
'
Hose stream test Not performed (3)
Cable damage Charred
.
Tested Representative of (4)
configuration . in-plant '
'
,
configurations Maximum Approx. 425 deg.F (S) !
temperature at i hour [
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Comments Accepted by NRC I 11/20/1979 ,
i 1. Even though the tests conducted involved only several trays and conduit and therefore are defined as small. in scale, they do provide enough engineering data (ie, banding techniques, overlapping at joints, termination techniques and etc.) to ju'stic
. either directly or by engineering analysis that the installationi at FNP will provide the appropriate protection, t
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3. Underwriters Laboratories Inc. File R875B and Project 78NK5345
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dated September 6, 1978.
3. The hose stream test was not performed in any of the referenced I tests. For a cable wrapping system that is designed to provide '
one hour protection, it is unclear and appears unreasonable that the NRC maintains that this test. be a, condition of acceptance.
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t 4. The configurations tested are representative of actual installations at FNP. Every possible combination of wrapped i raceways performed. was However, not tested or even known when the initial testing wd by these tests to justify acceptance.as in (1),-there is sufficient-data provide S. This temperature was obtained from the_ thermocouple location in Test No. 3 of the referenced U.L. test which would approximate tti
" cold side" temperature of the barrier.
The ASTM E-119 acceptant i criteria is that the transmission of heat through the syecimen shall not have been such as to raise the average temperature on its unexposed surface more than 250 dag. F above its initial temperature. The ambient (initial) temperaturp is generally take;[
as 75 deg.,-thus the acceptable cold side' temperature per E-119-would be 325.deg._r. However,_since all the circuits in Test No.'
3 were still functioning after 61130 minutes (with a correspondin:
temperature of approx. 430 deg. F), it is concluded that 425. ;
-deg. F (since cable integrity is maintained at this temperature)
is justifiably-acceptable even though it-is-higher than the acceptance criteria of-325 deg. F.
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If you have any questions or comments, please contact Bob Pub 1_at '
(301) 417-8632.
Sincerely yours, BECHTEL POWER CORPORATION A UNIT CF BECHTEL CORPORATION-M 6IJ. E. Love Project-Engineer'
JEL/JFP/RJP:nmf *~
cc: R. D. Hill, FNP D. J. Shelton, SCS J. A. Wehrenberg, SCS J. H. Shivers, 'SCS e
J. W. Wilson, SCS -
D. H. Jones, SNC, w/ Original
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UNITED STATES -
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NUCLEAR REGULATORY CDMMI55!0N
OFFICE *
OF NUCLEAR REACTOR REGULATION WASHINGTON, D.C. 20555 May 28, 1993
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NRC INFORMATION NOTICE 93-41: ONE HOUR FIRE ENDURANCE TEST RESULTS FOR THERMAL CERAMICS KADWOOL, 3M COMPANY FS-195 AND
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3M C05PANY INTERAM E-50 FIRE BARRIER SYSTEMS
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6ddressees All holders of operating licenses or construction permits for nuclear power reactors. .
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Rurpose The U.S. Nuclear Regulatory Commission (NRC) is issuing this information notice to alert addressees to the results of fire endurance tests for Thermal Ceramics Xaowool, Minnesota Mining and Manufacturing Company (3M Company)
FS-195, a.d 3M Company,Interam E-50 1-hour fire barrier systems reviewed Wy NRC inspectors during a reverification inspection. It is ' expected that .
recipients will review the information for' applicability to their facilitfes *
and consider ~ actions as appropriate to avoid similar problems. However,
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suggestions contained in this information notice are not NRC requirements; therefore, no specific ' action or written response is required. -
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Descriotion of Circumstances
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in Generic Letter 92-08, "Thermo-Lag 330-1 Fire Barriers,' the staff stated it would evaluate other known fire barrier materials and systems that are used by licensees to fulfill NRC fire protection requirements pursuant to Appendix R to 10 CFR Part 50 of the Code of Fedefal Reaulationi. The staff has started its review of fire barriers manufactured by vendors other than Thermal Science; Incorporated, to verify the capability of the fire barrier systems to adequately perform their 1-hour or 3-hour fire-resistive functions ar,d to meet stated ampacity derating values. #
A reverification inspection was conducted by NRC inspectors at the Salem Nuclear Generating. Station, owned by Public Service Gas and Electric Company
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(the licensee), the week of May 17, 1993. NRC inspectors reviewed fire endurance test results for the electrical raceway fire barrier systems used by the licenree to separate safe shutdown functions within the same fire area.
The systems used were Thermal Ceramics Kaowool, 3M Company FS-195"and 3M Company Interam E-50. The fire test results, as documented in the fire barrier qualification test reports, are discussed below and are summarized in the attached table.
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IN 93-41 May 28, 1993
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Page 2 of 3 gqwool fire Barrier Thermal Ceramics, Inc., was fonnerly the Insulating Products Division of -
Babcock and Wilcox, Inc., of Augusta, Georgia. The licensee fire endurance testing basis for Kaowool is a Babcock and Wilcox fire test report of October 24, 1978. According to the report, five specimens of the Kaowool barrier were tested on cable trays in a small-scale furnace. The maximum length of the 45.7 cm [18 inch) wide cable trays was 61 cm [24 inches). Cable fill ranged from 33 percent to 35 percent. According to the report, the fire test acceptance criterion was circuit integrity. The tests were not conducted or controlled by an independent testing laboratory.
The test report stated that the circuit integrity in one circuit was lost at I hour and 1 minute. It also stated that cable temperat.,res exce&ded 139 *C
[250 'F) above ambient air temperature in about 22 minr.es. At 60. minutes into the test, the cable temperatur.e was about 426.5 *, [800 'F). Hose streae tests were not performed. The results section of tr. test report. stated that cables in all tests exhibited signs of fire damage, suen as charring.
3M Comoany FS-195 Fire BarricI ,
The licensee fire endurance qualification testing basis for the 3M Company F5'195 fire, barrier system is a 3M Company ' test report of October 31, 1980.
Test acceptance criteria were not reported. The report stated that this was a A
- small-scale test at the 3M test facility. The figure in the report showing the test specimen was conceptual and did not give dimensions. According to g
the figure, the fire barrier was constructed by placing a cable tray in a metal air duct with the tray support in the middle of the duct.- The metal duct was covered with FS-195, there was an air space.around the cable tray, and the tray contained 40 percent cable fill.
According to the test report, the metal duct temperature on the unexposed side -
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of the fire barrier material exceeded 139 *C [250 'F) above ambient in about 30 minutes. At 60 minutes the temperature was 326.5 *C [620 'F). The test specimen was not subjected tp a hose stream test. The candition of the cables at the end of the test was not reported.
3M Com any Interam E-50 Fire Barrier The licensee fire endurance qualification testing basis for the 3H Company Interam E-50 fire barrier system is a Twin City Testing Corporation test report of September 1986. The fire test acceptance criterion was stated as circuit integrity as specified by American Nuclear Insurers.
According to the test report, the cable tray test specimen was a 61 cm (24 inch wide aluminum. cable tray installed in the test slab in a horseshoe configura) tion. The vertical drops into the furnace were 58.4 cm [23 inches),
and the horizontal run was 86.4 cm [34 inches). The tray configuration was divided into four segments. A vertical run of solid bottom tray was connected to a ladder-back 90' radial bend. This bend was connected to a solid bottom tray s yment, which was connected to a vertical ladder-back tray segnent. The
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IN 93-41 May 20, 1993
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Page 3 of 3
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test specimen also included an air drop. One half of the tray had 14 percent cable fill. Thq other half had 40 percent cable fill. A second test specimen consisted of one 12.7 cm [5 temh) diameter steel conduit and one 12.7 cm J5 inch) diameter aluminum conduit and a 25.4 cm (10 inch) by 25.4 cm
[10 inch)by15.2cm[6 inch]junctionbox.
The fire barrier installation procedures appended to the test report specified multiple installation methods. However, the fire barrier construction details and methods of fire barrier application for the test specimens were not documented in the test report.
The temperatures within the fire barrier and the condition of the cables at the end of the test were not reported.
As a result of the issues raised during the inspection, the licensee posted fire watches as compensatory measures in accordance with plant procedures.
Discussion
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The staff is continuing its review of these fire barrier systems including a reassessment of any previous staff reviews of these systems. The staff previously requested additional information on Laowool from Thermal Ceramics, Inccrporated, in a letter of April 27, 1993, and on the 3M fire barrier systems from 3M Company in a letter of May 4, 1993. The staff Will evaluate
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whether further generie communications are needed to address the issues *
discussed abose.
This infonnation notice requires no specific action or written response. If you have any questions about the information in'this notice, please contact the technical contact listed below or the appropriate Office of Nuclear Reactor Regulation (NRR) project manager.
a
.~ .1 Brian K. Grimes, Director Division of Operating Reactor Support Office of Nuclear Reactor Regulation
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Technical contact: Pat Mcdden,.NRR 301-504-2854 '
Attachments:
1. Sumary of Test Results 2. List of Recently Issued Information Notices
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Attccinem i FN 93-41 May 28, 1993 J 9 Suctury of Test Results Page 1 of 1
?[dN/N#5556: NIbTiRSE65ip: -
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, ISIEjPIRM45 5'Rli?.~s _AI5_ fsY1_0_;eNI5E5
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Scale of test Small-scale Small-scale small-scale
' Test laboratory Not independent Not independent Not independent, but witnessed by Twin City Testing Corp.
l Sose stream test Not performed Not performed Performed Cable damage Charred Unknown Unknown Tested Not Not Not configuration representative of representative of representative in-plant in-plant of in-plant
confiourations configurations configurations Haximum -426.5 *C 326.5 *C [620 'F) Unknown tempprature at 1 [-800'F)
hour Conments Accepted by NRC Accepted by NRC Installed in
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S 11/20/1979 3/18/1981 1991; not submitted to NRC*
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In a letter of May 18, 1993, to the NRC, the 3H Company stated that the FS-195 fire barrier system is used only at Salem.
3H Company provided additional test reports to the licensee on Hay 20, 1993. The licensee is evaluating-the applicability of these test reports to the in-plant configurations.
.e 3 NRC acceptance criteria is 139 *C [250 'F] above ambient.
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Attachment 2 IN 93-41 May 23, 1993
.3, Page 1 of 1 LIST OF RECENTLY ISSUED NRC INFORMATION WOTICES Inf onr.ation Date of Notice No. Subject Issuance Issued to
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93-40 Fire Endurance Test 05/26/93 All holders of OLs or cps Results for Thermal for nuclear power reactors.
Ceramics FP-60 Fire Barrier Material 93-39 Radiation Beams from 05/25/93 'All holders of OLs or cps Power Reactor Biolog- for nuclear power reactors.
ical Shields .
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93-38 Inadequate Testing of 05/24/93 All holders of OLs on cps Engineered Safety for nuclear power reactors.
Features Actuation System-37 Eyebolts with Indeter- 05/19/93 All holders of OLs or cps
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minate Properties In- for nuclear power reactors.-
stalled in Limitorque Valve Operator Housing Covers 93-36 Nr*1fications, Reports, ,s 05/07/93 All U.S. Nuclear Regulatory and Records of Misadmin- Comission swdical istrations licensees.
93-35 Insights from Comon- 05/12/93 All holders of OLs or cps Cause failure Events ~for nuclear power plants (NPPs).
93-34, Potential for loss of 05/06/93 All holders of Ots or cps Supp. 1 Emergency Cooling for nuclear power reactors.
Function Due to A Combination of "
Operational and Post-Loca Debris in Contain-ment L - Operating License
- - Construction Permit
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l NRC Fire Barrier Inspection Argust 18 through 22,97
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i Question From: Jon Bartley/Gerry Wiseman Question No.: 97 10 01 I
i To: Foltz/Sprankle Date: 8/18/97 Time: 1500 !
Question:
l Provide engineering justi0 cation / evaluation for Kaowool wrapped conduit smaller than the j tested con 0guration. This question is asked following an inspection of a Kaowool wrapped I 1/2" Dexible conduit supplying a CCW MOV. The inspector's concern is that a conduit or tray that is smaller than the tested condguration will have less total mass of Kanwn! insulation. l It is assumed that less mass will have less thermal protection. Is there an evaluation on this7 :
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Responsibil ty: Bob Puhl, Bechtel
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Response:
This evaluation is being conducted. It is estimated that results will be available in 4 6 weeks.
Fire watches have been established in all rooms containing Kaowool required for Appendix R compliance.
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. NRC Fire Barrier Inspection August 18 through 22,97 i Question From: Jon Dartley/Gerry Wiseman Question No.: 97 10-02 To: Foltz/Sprankle Date: 8/18/97 Time: 1500
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Question:
Provide engineering justification / evaluation for Knowool termination configuration of wrapped raceway at walls versus those in the tested configuration. This question follows from an
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inspection of a tray raceway in fire areas 1/2-42.
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Responsibility: Bob Publ. Dechtel
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Response:
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This evaluation is being conducted It is estimated that results will be available in 4 6 weeks.
Fire watches have been established in all rooms containing Kaowool required for Appendix R compliance.
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Response Reviewed: ') Date: Time:
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.. NRC Fire Barrier Inspection August 18 through 22,97 Question From: Jon Bartley/Geny Wiseman Question No.: 97-10 03 To: Foltz/Sprankle Date: 8/18/97 Time: 1500 Question:
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Provide engineering justification / evaluation for Kaowool wrapped raceway support configuration. i.e., wrap overlap distance onto an unprotected raceway support. The inspector noted that such a support was found in a CCW heat exchanger room. .
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This evaluation is being conducted. It is estimated that results will be available in 6-8 weeks.
Fire watches have been established in all rooms containing Knowool required for Appendix R compliance.
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August 18 through 22,97 Question From: Jon Bartley/Gerry Wiseman Question No.: 97 10 04 ,
To: Foltz/Sprankle Date: 8/18/97 Time: 1500
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Question:
Provide engineeringjustification/ evaluation for Kaowool wrapped raceway cordiguration where an unwrapped tray connects to the wrapped tray. For example protected tray 1VBHLZ45 is .
penetrated by unprotected tray 1VBHDC64.
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Responsibility: Bob Puhl, Bechtel
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Response:
This evaluation is being conducted. It is estimated that results will be available'in 6-8 weeks.
Fire watches have been established in all rooms containing Kaowool required for Appendix R compliance.
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. NRC Fire Barrier Inspection August 18 through 22,97 i
Question From: Jon Dartley/Gerry Wiseman Question No.: 97 10-05 To: Foltz/Sprankle Date: 8/18/97 Time: 1500 Question:
How do over painted door drain grates affect calculated floor drain capacity?
l Responsibility: Miles Coleman, FNP Maintenance
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Response:
Maintenance has initiated a project to restore the drains to acceptable condition. This item was cited by FNP SAER as audit finding AFR 97-55, and Maintenance is responding per CAR 2294. The NRC inspector stated that this issue is dropped frorn the FPS audit because it is being addressed as indicated.
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NRC Fire Darrier Inspection August 18 through 22. 97 Question From: Jon Bartley/Gerry Wiseman Question No.: 97-10 06 To: Foltz/Sprartkle Date: 8/18/97 Time: 1500 Question:
Provide engineering justification / evaluation for cork seal in seismicjoints (rattle space).
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Responsibility: Dob Puhl, Dec'itel .
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Response:
The NRC inspector stated that this issue is being dropped from the FPS audit.
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NRC Fire Barrier inspection August 18 through 22,97
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l Ques: ion From. Jon Dartley/Geny Wiseman Question No.: 97 10 07 ,
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To: Foltr/Sprankje Date: 8/18/97 Time: 1500 !
Question: '
Provide engineeringjusti0catiorvevaluation for Kaoucijoint/ banding variances from the
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tested con 6guration. For example, the tested overlap on outer and inner buttjoints on Knowool for raceways is 18", yet we allow 15" (14" on conduit) overlap, and the bands are i tested at 3" max, distance from the buttjoint while FNP allows 2" (conduit)or 4" maximum.
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distances from the joint .
Responsibility: Bob Puhl, Bechtel
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Response:
This evaluation is being conducted. It is estimated that results will be available in 4-6 weeks.
Fire watches have been established in all rooms containing Kaowool required for Append!x R compliance.
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NRC Fire Barrier Inspection August 18 through 22,97 Question From: Jon Bartley/Gerry Wiseman Question No.: 97-10 08 To: Foltz/Sprankle Date: 8/18/97 Time: 1500 ,
Question:
Is there a problem with aging Kaowool sagging from the bottom of trays and potentially stretching, and thinning, on the top of the trays? This question also concems the change in air
, space inside the Knowool insulation resulting from aging. ,
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Responsibility: Bob Publ, Bechtel Response:
Installation of the Knowool system, along with its overall layer ofZetex in accordance with the
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notes and details (with banding at 14" intervals) should preclude this condition. No examples of this occuring have been identified.
Fire watches have been established in all rooms .ontaining Kaowool required for Appendix R compliance. .
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NRC Fire Barrier inspection August 18 through 22,97 Question From: Jon Bartley/Gerry Wiseman Question No.: 97 10 09 To: Foltz/Sprankle Date: 8/18/97 Time: 1500 Question:
The following concern was noted by the NRC Resident inspector:
One of the WPG Knowool installers reported to the NRC (Banley) that he had seen a number of raceway wrap problems but didn't know how to report problems, that he was not a trained inspector and believed that people would think he was trying to make work for himself.
This question was initially answered with respect to employee concems; however, the question re addressed with respect to the ability of a contract worker to report equipment deficiencies.
Response:
FNP managemeM was notified of this issue with respect the concems program, FNP AGM - Operations stated that the Administrative Supervisor will discuss with WPG management FNP's requirement to provide all WPG onsite employees the details of the FNP concerns program. Attached is the related concerns program info.
With respect to equipment deficiencies: WPG supervision states that their personnel are briefed upon arrival onsite and at weekly safety meetings the avenues that are available to report equipment deficiencies, Following the notification of the above reported concem onsite WPG were again briefed, Their policy is to report deficiencies to their supervision, who are then responsible for pointing out the deficiency to an SNC / FNP employee, Response From:
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NRC Fire Barrier inspection August 18 through 22,97 Question From: John Bartley/Geny Wiseman Question No.: 97-10 10 To: C. Foltz Date: 08/19 Time: 10:30 Question:
On Unit 2 El.139' Room 2312, a Knowool wrapped bundle appears to have a notch to allow a door swing, has an evaluation of this condition been performed? If so, please provide.
Responsibility: Carl Foltz, Bechtel Response:
This condition was identified and documented during the October 96 inspection. The Kaowool bundle protects raceway 2VAEM302 which carries cables redundant to some on El.121*. The identified configuation was reviewed, and an evaluation was performed by Bechtel to determine the adequacy of the installation. The evaluation determined that the installed condition.
provided sufucient protection for the Safe Shutdown functions invovett, The inspection form and evaluation are attached.
Response From:
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NRC Fire Barrier Inspection August 18 through 22,97 i
Question From: Jon Bartley/Gerry Wiseman Question No.: 97 10 11 To: Ray Sprankle Date: 08/19 Time: 15:02 Question:
Provide documentation to support penetration seal qualification for the following Unit I seals: I 24 100 32 09 139 9;02 139 29
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Response:
Fire watches for these seals have been established while this evaluation is being conducted.
Since Dow Corning silicone foam is a common nuclear industry penetration seal material, industry documentation is available to support penetration sealinstallations at FNP.
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Future inspections will verify that installed configurations are bounded by available test data, or appropriate engineering evaluations will be documented.
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FNP staffinspects every fire penetration seal once every 18 months. -
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NRC Fire Barrier inspection August 18 through 22,97 i
Question From: Jon Bartley/Geny Wiseman Question No.: 97 10 12 l
To: Bob Puhl Date: 8/21/97 Time: 1435 i
Question: ,
SSD Raceway Identification and Knowool Wrap Location Drawing D180534, sheets 2 and 3, note 3, identifies specific raceways that are wrapped with Kaowool but r ,t required for J
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Appendix R as defined in the safe shutdown raceway report A.1805' The NRC inspector states that this is in direct conflict with Appendix R ans .o Appendix R exemptions in the FS AR. .
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The NRC inspector further stated that this could be an indication that the design process is not evaluating wrap requirements against Appendix R, Appendix R exemptions, and licensing agreements.
Response:
The specific raceways cited are not required to be wrapped fcr Appendix R considerations.
The safety evaluation for the ABN (ABN 1030.. attached), indicates that this will be reflected :
in the next revision of the FSAR. SNC is developing a major revision to FSAR Apapendix 9B
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that will correct these anomolies (see attached for draft pages applicable to the cited raceways).
Note that this situation applies to raceways other than the specific ones cited. However, configuration management is maintained during this protracted process 4y ensuring that applicable drawings reflect the required configuration.
Fire watches will be maintained in these areas until the FSAR is revised.
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NRC Fire Darrier inspection August 18 through 22,97 Question From: Jon Banley/Gerry Wiseman Question No.: 97 10 13 To: Bob Puhl Date: 8/21/97 Time: 1435 l Question:
Please provide an estimate of the total number oflinear feet of Appendix "R" required Kaowool wrap on both units at FNP.
Response:
Our best estimate is 6300' on both units. Attached is supporting in'ormation.
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