Information Notice 1988-04, Inadequate Qualification and Documentation of Fire Barrier Penetration Seals

Inadequate Qualification and Documentation of Fire Barrier Penetration Seals

ML031150660
Person / Time
Site:	Beaver Valley, Millstone, Hatch, Monticello, Calvert Cliffs, Dresden, Davis Besse, Peach Bottom, Browns Ferry, Salem, Oconee, Mcguire, Nine Mile Point, Palisades, Palo Verde, Perry, Indian Point, Fermi, Kewaunee, Catawba, Harris, Wolf Creek, Saint Lucie, Point Beach, Oyster Creek, Watts Bar, Hope Creek, Grand Gulf, Cooper, Sequoyah, Byron, Pilgrim, Arkansas Nuclear, Three Mile Island, Braidwood, Susquehanna, Summer, Prairie Island, Columbia, Seabrook, Brunswick, Surry, Limerick, North Anna, Turkey Point, River Bend, Vermont Yankee, Crystal River, Haddam Neck, Ginna, Diablo Canyon, Callaway, Vogtle, Waterford, Duane Arnold, Farley, Robinson, Clinton, South Texas, San Onofre, Cook, Comanche Peak, Yankee Rowe, Maine Yankee, Quad Cities, Humboldt Bay, La Crosse, Big Rock Point, Rancho Seco, Zion, Midland, Bellefonte, Fort Calhoun, FitzPatrick, McGuire, LaSalle, 05000000, Zimmer, Fort Saint Vrain, Shoreham, Satsop, Trojan, Atlantic Nuclear Power Plant
Issue date:	02/05/1988
From:	Rossi C Office of Nuclear Reactor Regulation
To:
References
IN-88-004, NUDOCS 8802020228
Download: ML031150660 (9)

UNITED STATES

NUCLEAR REGULATORY COMMISSION

OFFICE OF NUCLEAR REACTOR REGULATION

WASHINGTON, D.C. 20555 February 5, 1988 NRC INFORMATION NOTICE NO. 88-04: INADEQUATE QUALIFICATION AND DOCUMENTATION

OF FIRE BARRIER PENETRATION SEALS

Addressees

All holders of operating licenses or construction permits for nuclear power

reactors.

Purpose

This notice is to alert addressees that some installed fire barrier penetration

seal designs may not be adequately qualified for the design rating of the

penetrated fire barriers. It is expected that recipients will review this

information for applicability and consider actions, if appropriate, to preclude

a similar problem and correct existing problems at their facilities.

However, suggestions contained in this information notice do not constitute new

NRC requirements; therefore, no specific action or written response is required.

Description of Circumstances

The NRC has been reviewing fire barrier penetration seal designs installed in

several nuclear power plants. The reviews focused on whether the installed

configuration was qualified by adequate testing and documentation.

The current NRC review was prompted by reports, inspection findings, allegations, and other information that indicated the possibility that NRC requirements for

fire barrier penetration seals were not being met in all aspects. The review

included: evaluations of fire barrier penetration seal specifications and pro- cedures developed by licensees, licensee agents, and licensee contractors;

evaluations of various fire barrier penetration seal tests and test data; and

inspections of various fire barrier penetration seal designs and installations.

The types of concerns identified to date and mentioned below are related to weak- nesses in the implementation of NRC requirements and guidelines as related to

fire barrier penetration seal design qualification.

The staff identified instances where installed fire barrier penetration seal

designs could not be verified as qualified for the design rating of the pene- trated fire barrier. In some cases,-test qualification documentation was not

8802020228

IN 88-04 -:

February 5, 1988 available. In other cases, qualification test documentation was available but

incomplete or inadequate because all qualification requirements had not been

satisfied or the installed seal design configuration or design parameters were

significantly different from the tested seal.

The NRC review also has identified a current practice that can affect the

qualification status of installed seals. Plant modifications are being made

that require running new cable and conduits through existing penetration seals.

These modifications are generally being made without an associated technical

review to ensure that the resulting penetration seal design configuration or

design parameters are consistent with those validated by initial qualification

tests. Over a period of time, numerous minor modifications to the same area

could cumulatively result in a degraded fire barrier rating.

Discussion:

NRC requirements and guidelines for fire barrier penetration seals are con- tained in various documents, including Appendix R to 10CFR 50, Appendix A

to Branch Technical Position (BTP) APCSB 9.5-1, "Guidelines for Fire Protec- tion for Nuclear Power Plants Docketed Prior to July 1, 1976," and NUREG-0800,

Standard Review Plan. The extent to which these requirements or guidelines

are applicable to a specific plant depends on plant age, commitments established

by the licensee in developing the fire protection plan, the staff safety evalua- tion reports (SERs) and supplements, and the license conditions pertaining to

fire protection.

The goal is to provide a fire barrier penetration seal that will remain in

place and retain its integrity when subjected to an exposure fire, and subse- quently, a fire suppressing agent. This will provide reasonable assurance that

the effects of a fire are limited to discrete fire areas and that one division

of safe-shutdown-related systems will remain free of fire damage.

A number of licensees have conducted a comprehensive.assessment of the adequacy

of in-plant fire barrier penetration seals. Their efforts began by determining

which specific NRC guidelines/requirements apply and which specific commitments

were made to respond to those guidelines or requirements. Typically, in-plant

seal assemblies were surveyed to catalogue the various types of existing seal

configurations. Finally, the documentation was analyzed to confirm that

in-plant designs were fully qualified by a fire test and were installed in a

proper manner.

If these efforts revealed instances where seals were not installed where re- quired, were not installed properly, or were not qualified by a standard fire

test, then the licensees have considered the seals degraded and have imple- mented compensatory measures, such as fire watch patrols, per the appropriate

technical specifications or administrative procedures. These measures remain

in force pending final resolution of the issue. Final resolution may include

replacing existing penetration seals with fully qualified seals, qualifying

in-plant seal assemblies by supplemental fire tests, and justifying in-plant

configuration by fire hazards/safe shutdown analysis.

IN 88-04 February 5, 1988 Appendix A contains a summary of various technical considerations that have

been used for evaluating the qualification adequacy of fire barrier penetration

seal designs and installations, associated testing, and test data.

No specific action or written response is required by this information notice.

If you have questions about this matter, please contact one of the technical

contacts listed below or the Regional Administrator of the appropriate NRC

regional office.

a~r'es E. Ross ,Director

Division of Operational Events Assessment

Office of Nuclear Reactor Regulation

Technical Contact(s): Dennis Kubicki, NRR

(301) 492-0825 Joseph Petrosino, NRR

(301) 492-0979 Attachments:

1. Appendix A - Summary of Existing Staff

Guidance Related to Fire Barrier

Penetration Seals

2. List of Recently Issued NRC Information Notices

Attachment 1 IN 88-04 February 5, 1988 APPENDIX A

SUMMARY OF EXISTING STAFF GUIDANCE RELATED

TO FIRE BARRIER PENETRATION SEALS

A. General Considerations Concerninq the Use of Test Results To Qualify Fire

Barrier Penetration Seal Designs

The (fire barrier seal) test specimen shall be truly representative of the

construction for which classification is desired, as to materials, work- manship, and details such as dimensions of parts, and shall be built under

conditions representative of those obtaining as practically applied in

building construction and operation. The physical properties of the

materials and 2 ingredients used in the test specimen shall be determined

and recorded.

B. Seal Acceptance Criteria

1. The fire resistance rating of the penetration seal should bS equiva- lent to the rating of the barrier in which it is installed.

2. The fire resistance rating of the penetration seal should be deter- mined by a4 standard fire test (i.e., ASTM E-814, ASTM E-119 or

IEEE-634).

3. The test should be conducted by an independent, recognized testing

authority. The tested assembly should be representative of in-plant

assemblies. The exposure fire should correspond to at least the time- temperature curve of ASTM E-119. Thermocouples should be positioned

at representative locations on the cold side of the tested assembly

(including the interface of seal material and through penetrations).

The cold-side temperature should not exceed 2500 F above ambient during

the test or 325 0 F maximum, although higher temperatures at through

penetrations are permitted when justified in terms of cable insulation

ignitability. There should be no burn-through of the seal during the

test, nor the passage of hot gases sufficient to ignite cotton waste

material. The assembly should withstand t e effects of a hose stream, as stipulated in the standard test method.

4. The seals should be installed by qualified individuals.6

5. Appropyiate quality assurance/quality control methods should be in

force.

6. Fire barrier penetrations that must maintain environmental isolation

or pressure differentials should be qualified by test to maintain the

barrier integrity under such conditions.

Attachment 1 IN 88-04 February 5, 1988 C. Hose Stream Testing9

1. Hose stream testing is a requirement for all fire barrier penetration

seal qualification testing, regardless of whether the penetration

seal is for a wall or a ceiling or a floor.

2. Hose stream testing should be performed on tested specimens that have

successfully withstood the fire endurance test requirements.

3. The hose stream shall be delivered in one of the following ways:

a 1-1/2-inch nozzle set at a discharge angle of 300 with a nozzle

pressure of 75 psi and a minimum discharge of 75 gpm with the tip

of the nozzle a maximum of 5 ft from the exposed face; a 1-1/2-inch

nozzle set at a discharge angle of 150 with a nozzle pressure of 75 psi and a minimum discharge of 75 gpm with the tip of the nozzle a

maximum of 10 ft from the exposed face; a 2-1/2-inch national stan- dard playpipe equipped with 1-1/8-inch tip, nozzle pressure of 30 psi, located 20 ft from the exposed face.

4. The duration of the hose stream test should meet the minimum require- ments specified in ASTM E-119 for fire barriers. During hose stream

testing, the fire barrier penetration seal should remain intact and

should not allow a projection of water beyond the unexposed surface.

D. Deviations10

Deviations from NRC requirements or accepted industry standards for fire

barrier penetration seals should be technically substantiated as part of

the review and approval of the fire protection plan or in other separate

formal correspondence. Supplemental guidance is provided in Generic

Letter 86-10.

References

1. "The design of fire barriers for horizontal and vertical cable trays

should, as a minimum, meet the requirements of ASTM E-119, Fire Test

of Building Construction and Materials, including the hose stream test."

[Section D.3.(d) of Appendix A to BTP APCSB 9.5-1].

"Penetration seal designs shall utilize only noncombustible materials and

shall be qualified by tests that are comparable to tests used to rate fire

barriers." (Section III.M of Appendix R to 10 CFR Part 50).

"The penetration qualification tests should use the time temperature

exposure curve specified by ASTM E-119." (Section C.5.a. of BTP CMEB

9.5-1).

-Attachment 1 IN 88-04 February 5, 1988 2. ASTM E-119, "Fire Test of Building Construction and Materials."

3. Section D.3.(d) of Appendix A to BtP APCSB 9.5-1.

4. Section III.M. of Appendix R to 10 CFR Part 50.

5. ASTM E-119, "Fire Test of Building Construction and Materials."

6. Section C of Appendix A to BTP APCSB 9.5-1, Section C.4 of BTP CMEB 9.5-1.

7. Ibidem.

8. Section C.5.a.(3) of BTP CMEB 9.5-1.

9. Section III.M of Appendix R to 10 CFR Part 50, Section C.5.a of BTP CMEB

9.5-1.

10. Generic Letter 86-10.

r

A ment 2 I :

February S. 1988 Pige 1 of I

LIST Of RECENTLY ISSUED

NRC INFORMATION NOTICES

Lntonuatlol Dats of

Notice No. SubJect Issuance Issued to

88-03 Cracks in Shroud Support 2/2/88 All holders of OLs

Access Hole Cover WVlds or CPs for BWRs.

88.02 Lost or Stolen Gauges, 2/2/88 All NRClicensees

authorized to possess

gauges under a

specific or general

license.

88.01 Safety Injection Pipe 1/27/88 All holders of OLs

Failusror CPs for nuclear

power reactors.

86-81, Broken External Closure 1/11/88 All holders of OMs

Supp. 1 Springs on Atwood & Iorrill or CPs for nuclear

main Steam Isolation Valves power reactors.

87-67 Lessons Learned from 12/31/87 All holders of OLs

Reional Inspections of or CPs for nuclear

Licenses Action$ ia Response power reactors.

to It Bolletin

a0> -

87-65 Inappropriate Application 12/31/87 All holders of OLs

of Cofher1i1-l6rads or CPs for nuclear

Components powr reacton.

87-28, Alp Systems Probie at 12/28/87 All holders of Ms

Supp. 1 U.S. 1ight Water Reactors or CPs for nuclear

power reactors.

87-65 Plant Operation Beyond 12/23/87 All holders of OLs

Analyzed Conditions or CPs for nuclear

power reactors.

87-64 Conviction for Falsification 12/22/87 All nuclear power

of Security Training Records reactor facilities

holding an OL or CP

and all major fuel

facility licensees.

ON: Operating License

CP

• Construction Permit

UNITED STATES FIRST CLASS MAIL

NUCLEAR REGULATORY COMAISSION POSTAGE 6 FEES PAID

USNRC

WASHINGTON, D.C. 20555 PERMIT No. 0-E7 OFFICIAL BUSINESS

PENALTY FOR PRIVATE USE $300

120555026886 1 1CO1CY1FB11S1 US NRC-OARM-IRM

DIV OF INFO SUP SVCS

MICROGRAPHICS SPECIALIST

RECORDS SERVICES BRANCH

042 WASHINGTON DC 20555

IN 88-04 February 5, 1988 Appendix A contains a summary of various technical considerations that have

been used for evaluating the qualification adequacy of fire barrier penetration

seal designs and installations, associated testing, and test data.

No specific action or written response is required by this information notice.

If you have questions about this matter, please contact one of the technical

contacts listed below or the Regional Administrator of the appropriate NRC

regional office.

Charles E. Rossi, Director

Division of Operational Events Assessment

Office of Nuclear Reactor Regulation

Technical Contact(s): Dennis Kubicki, NRR

(301) 492-0825 Joseph Petrosino, NRR

(301) 492-0979 Attachments:

1. Appendix A - Summary of Existing Staff

Guidance Related to Fire Barrier

Penetration Seals

2. List of Recently Issued NRC Information Notices

• Transmitted by memo to C. E. Rossi from J. G. Partlow dated 12/21/87 IC " m-a -044 %i'

• SEE PREVIOUS CONCURRENCES * 4

• PPMB:ARM *C/OGCB:DOEA:NR R R

TechEd CHBerlinger a

01/15/88 01/21/88 0245-/88

• OGCB:DOEA:NRFt *D/DEST:NRR *ADT/DEST:NRR *D/DRIS:NRR *DD/DRIS:NRR

RJKiessel LShao JRichardson JGPartlow BKGrimes

01/14/88 12/17/87 12/16/87 12/16/87 12/16/87

• VIB:DRIS:NRR *ASC/VIB:DRIS:NRR*AC/VIB:DRIS:NRR*ECEB:DEST:NRR*BC/ECEB:DEST:NRR

JPetrosino EBaker JStone DKubicki CMcCracken

12/15/87 12/15/87 12/18/87 12/16/87 12/16/87

IN 88-XX

January XX, 1988 Appendix A contains a summary of various technical considerations that have

been used for evaluating the qualification adequacy of fire barrier penetration

seal designs and installations, associated testing, and test data.

No specific action or written response is required by this information notice.

If you have questions about this matter, please contact the Regional Adminis- trator of the appropriate NRC regional office or this office.

Charles E. Rossi, Director

Division of Operational Events Assessment

Office of Nuclear Reactor Regulation

Technical Contact(s): Dennis Kubicki, NRR

(301) 492-9424 Joseph Petrosino, NRR

(301) 492-4316 Attachments:

1. Appendix A - Summary of Existing Staff

Guidance Related to Fire Barrier

Penetration Seals

2. List of Recently Issued NRR Information Notices

• Transmitted by memo to C. E. Rossi from J. G. Partlow dated 12/21/87

• SEE PREVIOUS CONCURRENCES

PPMB:ARM C/OGCB: DOEA:NRR D/DOEA:NRR

TechEdM CHBerlinger CERossi

01/1</88 01/ /88 01/ /88 OGCB:DOEA: V *D/DEST:NRR *ADT/DEST:NRR *D/DRIS:NRR *DD/DRIS:NRR

RJKiessel IjNA LShao JRlchardson JGPartlow BKGrimes

O1/ll/88 12/17/87 12/16/87 12/16/87 12/16/87

• VIB:DRIS:NRR *ASC/VIB:DRIS:NRR*AC/VIB:DRIS:NRR*ECEB:DEST:NRR*BC/ECEB:DEST:NRR

JPetrosino EBaker JStone DKubicki CMcCracken

12/15/87 12/15/87 12/18/87 12/16/87 12/16/87