Information Notice 1994-28, Potential Problems with Fire-Barrier Penetration Seals

Potential Problems with Fire-Barrier Penetration Seals

ML031060475
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, Fort Saint Vrain, Shoreham, Satsop, Trojan, Atlantic Nuclear Power Plant
Issue date:	04/05/1994
From:	Grimes B Office of Nuclear Reactor Regulation
To:
References
IN-94-028, NUDOCS 9403300072
Download: ML031060475 (10)

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V UNITED STATES

NUCLEAR REGULATORY COMMISSION

OFFICE OF NUCLEAR REACTOR REGULATION

WASHINGTON, D.C. 20555 April 5, 1994 NRC INFORMATION NOTICE 94-28: POTENTIAL PROBLEMS WITH FIRE-BARRIER

PENETRATION SEALS

Addressees

All holders of operating licenses or construction permits for nuclear power

reactors.

Purpose

The U.S. Nuclear Regulatory Commission (NRC) is issuing this information

notice to alert addressees to potential problems in installed fire-barrier

penetration seals that may have gone undetected as a result of inadequate

surveillance inspection procedures and inadequate acceptance criteria. It is

expected that recipients will review the information for applicability to

their facilities and consider actions, as appropriate, to avoid similar

problems. However, suggestions contained in this information notice are not

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

required.

Description of Circumstances

Nine Mile Point Nuclear Station, Unit 1, (NMP 1)

On April 25, 1988, Niagara Mohawk Power Corporation, the licensee for NMP 1, reported (licensee event report [LER] 88-009) that on March 26, 1988, it had

determined that some existing fire barriers were inoperable because the

barriers contained potentially nonfunctional penetrations through the fire- barrier. Initially, the licensee verified fire detection on one side of the

affected penetrations, established a fire-watch patrol, and walked down

additional potentially inoperable fire barriers. When these walkdowns

revealed additional potentially nonfunctional fire-barrier penetrations, the

licensee took additional corrective actions that included performing a

100-percent visual reinspection of the penetration seals, performing an

engineering evaluation of each penetration that did not meet accepted design

configurations, and upgrading its surveillance inspection procedure.

Supplements 1 and 2 to LER 88-009 (June 8 and August 16, 1990, respectively)

attributed the root cause of the event to personnel error due to a lack of

understanding of the fire-barrier commitments; a contributing cause was a lack

of required documentation and inadequate surveillance procedures. Additional

documentation of this event can be found in NRC Region I Inspection Reports

50-220/88-15 and 50-220/89-33 (June 2, 1988, and March 8, 1990, respectively).

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IN 94-28 April 5, 1994 James A. FitzPatrick Nuclear Power Plant (FitzPatrick)

During the performance of fire-barrier penetration surveillance inspections by

the licensee at FitzPatrick between May and November 1990, inspectors

documented numerous nonconforming conditions. One predominant condition was

the lack of adequate damming material. In August 1990, the licensee Quality

Assurance group forwarded an adverse quality condition report describing these

nonconforming conditions to the Site Engineering group for evaluation. Site

Engineering determined that the barriers were acceptable pending further

evaluation by the Corporate Engineering group. No compensatory fire watches

were established at that time. In December 1990, after additional condition

reports were submitted to Site Engineering documenting these nonconforming

conditions, an operability determination was performed and 2-hour fire patrols

were established. In December 1990, the NRC reviewed the licensee activities

(Region I Inspection Report 50-333/90-09, March 1, 1991) and concluded that

licensee control of the fire-barrier penetration seals was inadequate because:

(1) the licensee had not documented determinations of the ability of the

nonconforming penetrations to perform as fire barriers for 3 hours3.472222e-5 days <br />8.333333e-4 hours <br />4.960317e-6 weeks <br />1.1415e-6 months <br />; (2) there

was no documented justification for establishing 2-hour fire patrols when the

Technical Specifications required continuous compensatory fire watches; and

(3) the inspection criteria used by the licensee were inadequate because the

criteria did not provide the information necessary to allow inspectors to

determine that the seals were not in conformance with the as-built design.

In October 1991 a NRC diagnostic evaluation team noted problems regarding the

implementation of the fire-protection program and Appendix R regulations at

FitzPatrick. As a result, a special NRC fire-protection review was conducted

at FitzPatrick in March 1992 (Region I Inspection Report 50-333/92-80,

April 8, 1992). The special NRC fire-protection review team conducted a

walkdown of fire barriers and reviewed the corrective actions initiated by the

licensee as a result of the concerns identified in Region I Inspection Report

50-333/90-09 and the findings in the licensee July 1991 triennial fire- protection audit. The team noted that some of the existing penetration seals

in fire-barrier walls were made of a combustible urethane foam and fiberglass.

In addition, several silicone foam seals were degraded or were not well

maintained. The licensee initiated a corrective action program that included:

(1) reverifying the location of the 10 CFR Part 50, Appendix R, required fire

barriers in the plant; (2) performing a baseline inspection of all fire- barrier penetration seals associated with Appendix R and the fire-protection

license condition in the plant license; and (3) evaluating the deficiencies, making operability determinations, and completing repairs as required.

Vermont Yankee Nuclear Power Station (Vermont Yankee)

On January 15, 1993, Vermont Yankee Nuclear Power Corporation, the licensee

for Vermont Yankee, reported (LER 93-001) that on December 17, 1992, an

insulated pipe-penetration seal was identified as potentially not in

IN 94-28 April 5, 1994 compliance with design requirements. The seal was only partially filled with

the expected fire-barrier material because it was partially filled with

insulation. A second similar insulated pipe penetration seal was identified

on December 22, 1992. The following day the licensee declared all similar

insulated pipe penetrations inoperable and compensatory measures were

instituted. The licensee stated that these conditions had probably existed

since the fire-barrier penetration seals were upgraded by a 1979/1980 fire- barrier modification. Supplement 1 to LER 93-001 (March 5, 1993) indicated

that certain noninsulated penetrations and the boot-seal design for lines with

large displacements were also of concern. The licensee assigned the following

root causes: (1) inadequate documentation of assumptions during the 1979 effort to scope the penetration sealing effort, (2) inadequate procedures,

(3) inattention to detail, (4)failure to follow procedures, and (5)an

inadequate surveillance procedure. Additional documentation of this event can

be found in NRC Region I Inspection Reports 50-271/92-24 and 50-271/93-05 (February 1 and April 1, 1993, respectively).

Discussion

This notice alerts addressees to the possibility that some installed fire- barrier penetration seals may contain nonconforming conditions that have not

been identified because of inadequate acceptance criteria and inadequate

surveillance inspection procedures. Additionally, nonconforming conditions

may go undetected if the surface of the seal is covered by thermal insulation

or damming material.

NRC requirements and guidelines for fire-barrier penetration seals are

contained in various documents, including 10 CFR Part 50, Appendix R, "Fire

Protection Program for Nuclear Power Facilities Operating Prior to January 1,

1979;" Branch Technical Position APCSB 9.5-1, Appendix A, "Guidelines for Fire

Protection 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 nuclear power plant depends on plant

age, commitments established by the licensee in developing the fire protection

plan, the staff safety evaluation reports and supplements, and the license

conditions pertaining to fire protection.

The goal of these requirements and guidelines is to ensure that fire-barrier

penetration seals will remain in place and retain their integrity when exposed

to a fire. By so doing, there is reasonable assurance that the effects of a

fire will be limited to discrete fire areas and that one division of safe- shutdown-related systems will remain free of fire damage.

Related Generic Communications

The NRC has issued other generic communications that have discussed

requirements, guidance, and potential problems with fire-barrier penetration

seals. For example:

I. -:

IN 94-28 April 5, 1994 (1) On April 24, 1986, the NRC issued Generic Letter 86-10, "Implementation

of Fire Protection Requirements,* to provide information concerning the

interpretation and implementation of NRC fire-protection requirements.

(2) On February 5, 1988, the NRC issued Information Notice (IN)88-04,

"Inadequate Qualification and Documentation of Fire Barrier Penetration

Seals,' to alert addressees that some installed fire-barrier penetration

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

the penetrated fire barrier. This IN discussed an NRC staff review

which identified some instances where installed fire-barrier penetration

seal configurations were not qualified by adequate testing or were not

supported by adequate qualification documentation.

(3) On August 4, 1988, the NRC issued IN 88-56, "Potential Problems With

Silicone Foam Fire Barrier Penetration Seals," to alert addressees to

potential problems in their installed fire-barrier penetration seals

that could result in the reduction of fire-resistive capabilities for

protection of safety-related redundant equipment and electrical power

and control circuits. The IN discussed a vendor report (10 CFR Part 21,

"Reporting of Defects and Noncompliance') which identified the potential

for nonconforming conditions, such as splits, gaps, voids, and lack of

fill in the sealing material not being detected during routine

inspections because the surface of the seal material is typically

covered by damming material.

(4) On August 9, 1988, the NRC issued IN 88-04, Supplement 1, "Inadequate

Qualification and Documentation of Fire Barrier Penetration Seals," to

alert addressees to problems caused by potential misapplication of

silicone foam material used in penetration openings at nuclear power

plants.

This information notice requires no specific action or written response. If

you have any questions about the information in this notice, please contact

one of the technical contacts listed below or the appropriate 0 fice of

Nuclear Reactor Regulation (NRR) project mana er.

Brian K. Grimes, Director

Division of Operating Reactor Support

Office of Nuclear Reactor Regulation

Technical contacts: Fred L. Bower, III, RI

(610) 337-5328 Jeff Holmes, NRR

(301) 504-2280

Attachment:

List of Recently Issued NRC Information Notices

6f7 nrAJ)i' 'Jab ~

S. -

I

Attachment

IN 94-28 April 5, 1994 LIST OF RECENTLY ISSUED

NRC INFORMATION NOTICES

Information Date of

Notice No. Subject Issuance Issued to

94-27 Facility Operating 03/31/94 All holders of OLs or CPs

Concerns Resulting from for nuclear power reactors.

Local Area Flooding

94-26 Personnel Hazards and 03/28/94 All holders of OLs or CPs

Other Problems from for nuclear power reactors.

Smoldering Fire-Retard- ant Material in the

Drywell of a Boiling- Water Reactor

93-17, Safety Systems Response 03/25/94 All holders of OLs or CPs

Rev. 1 to Loss of Coolant and for nuclear power.

Loss of Offsite Power

94-25 Failure of Containment 03/25/94 All holders of OLs or CPs

Spray Header Valve to for nuclear power reactors.

Open due to Excessive

Pressure from Inertial

Effects of Water

94-24 Inadequate Maintenance 03/24/94 All holders of OLs or CPs

of Uninterruptible Power for nuclear power reactors.

Supplies and Inverters

94-23 Guidance to Hazardous, 03/25/94 All NRC Licensees.

Radioactive and Mixed

Waste Generators on the

Elements of a Waste

Minimization Program

94-22 Fire Endurance and 03/16/94 All holders of OLs or CPs

Ampacity Derating Test for nuclear power reactors.

Results for 3-Hour Fire- Rated Thermo-Lag 330-1 Fire Barriers

94-21 Regulatory Requirements 03/18/94 All fuel cycle and materials

when No Operations are licensees.

being Performed

OL - Operating License

CP - Construction Permit

IN 94-28 April 5, 1994 (1) On April 24, 1986, the NRC issued Generic Letter 86-10, "Implementation

of Fire Protection Requirements," to provide information concerning the

interpretation and implementation of NRC fire-protection requirements.

(2) On February 5, 1988, the NRC issued Information Notice (IN)88-04,

"Inadequate Qualification and Documentation of Fire Barrier Penetration

Seals," to alert addressees that some installed fire-barrier penetration

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

the penetrated fire barrier. This IN discussed an NRC staff review

which identified some instances where installed fire-barrier penetration

seal configurations were not qualified by adequate testing or were not

supported by adequate qualification documentation.

(3) On August 4, 1988, the NRC issued IN 88-56, "Potential Problems With

Silicone Foam Fire Barrier Penetration Seals," to alert addressees to

potential problems in their installed fire-barrier penetration seals

that could result in the reduction of fire-resistive capabilities for

protection of safety-related redundant equipment and electrical power

and control circuits. The IN discussed a vendor report (10 CFR Part 21,

"Reporting of Defects and Noncompliance") which identified the potential

for nonconforming conditions, such as splits, gaps, voids, and lack of

fill in the sealing material not being detected during routine

inspections because the surface of the seal material is typically

covered by damming material.

(4) On August 9, 1988, the NRC issued IN 88-04, Supplement 1, "Inadequate

Qualification and Documentation of Fire Barrier Penetration Seals," to

alert addressees to problems caused by potential misapplication of

silicone foam material used in penetration openings at nuclear power

plants.

This information notice requires no specific action or written response. If

you have any questions about the information in this notice, please contact

one of the technical contacts listed below or the appropriate Office of

Nuclear Reactor Regulation (NRR) project manager. Ogina ligned by

Brian K. Grimes, Director It L dme

Division of Operating Reactor Support

Office of Nuclear Reactor Regulation

Technical contacts: Fred L. Bower, III, RI Jeff Holmes, NRR

(610) 337-5328 (301) 504-2280

Attachment: List of Recently Issued NRC Information Notices

Transmitted by TTMartin memorandum to TEMurley dated June 9. 1993

• see previous concurrence DOC NAME: 94-28.IN

l*OGCB/DORS/NRR *Tech Editor *Region I

RJKiessel RSanders FLBower,III

2/22/94 2/22/94 3/3/94

• Region I *Region I *SPLB/DSSA/NRR *SPLB/DSSA/NRR

ARBlough JTWiggins JHolmes KSWest

3/3/94 3/3/94 3/07/94 3/07/94

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CEMcCracken MJVirgilio AJKugler /

3/09/94 3/14/94 3/17/94 /94

IN 94-xx

March xx, 1994 This information notice requires no specific action or written response. If

you have any questions about the information in this notice, please contact

one of the technical contacts listed below or the appropriate Office of

Nuclear Reactor Regulation (NRR) project manager.

Brian K. Grimes, Director

Division of Operating Reactor Support

Office of Nuclear Reactor Regulation

Technical contacts: Fred L. Bower, III, Region I

(215) 337-5328 Jeff Holmes, NRR

(301) 504-2280

Attachment: List of Recently Issued NRC Information Notices

Transmitted by TTMartin memorandum to TEMurley dated June 9. 1993

• see previous concurrence

• OGCB/DORS/NRR *Tech Editor *Region I

RJKiessel RSanders FLBower,III

2/22/94 2/22/94 3/ 3/94

• Region I *Region I *SPLB/DSSA/NRR *SPLB/DSSA/NRR

ARBlough JTWiggins JHolmes KSWest

3/ 3/94 3/ 3/94 3/07/94 3/07/94 l*C:SPLB/DSSA/NRR *D:DSSA/NRR AC:OGCB/DORS/NRR D:DORS/NRR

CEMcCracken MJVirgilio AJKugler BKGrimes

3/09/94 3/14/94 3/17/94 3/ /94 Document Name: G:\RJK\NRCINS\NRCIN.371

IN 94-xx

March xx, 1994 This information notice requires no specific action or written response. If

you have any questions about the information in this notice, please contact

one of the technical contacts listed below or the appropriate Office of

Nuclear Reactor Regulation (NRR) project manager.

Brian K. Grimes, Director

Division of Operating Reactor Support

Office of Nuclear Reactor Regulation

Technical contacts: Fred L. Bower, III, Region I

(215) 337-5328 Jeffrey Holmes, NRR

(301) 504-2280

Attachment: List of Recently Issued NRC Information Notices

Transmitted by TTMartin memorandum to TEMurley dated June 9. 1993

• see previous concurrence

• OGCB/DORS/NRR *Tech Editor *Region I

RJKiessel RSanders FLBower,III

2/22/94 2/22/94 3/ 3/94

• Region I *Region I l SPLB/DSSA/NRR SPLB/DSSA-IIHU

ARBlough JTWiggins JHolmes

3/ 3/94 3/ 3/94 3/ /94 _-__3/_7 /94 C:SPLBSd X i DSSA/NR If AC:OGCB/DORS/NRR D:DORS/NRR

CEMcCracken MJVirgi JeAJKugler BKGrimes

3/f/94 3/1i/94 5Iq 3/ /94 3/ /94 Document Name: G:\RJK\NRCIN5\NRC1N.371

material.

This information notice requires no specific action or written response. If

you have any questions about the information in this notice, please contact

one-of the technical contacts listed below or the appropriate Office of

Nuclear Reactor Regulation (NRR) project manager.

Brian K. Grimes, Director

Division of Operating Reactor Support

Office of Nuclear Reactor Regulation

Technical contacts: Fred L. Bower, III, Region I

(215) 337-5328 Jeffrer Holmes, NRR

(301) 504-2280

Attachment: List of Recently Issued NRC Information Notices

• Transmitted by TTMartin memorandum to TEMurley dated June 9. 1993 OGCB/DORS/NRR Tech Editor Region I Region I

RJKiessel R/(uO ) FLBower,III WHRuland

2f94 -7 2/2;994 2/ ./94 2/ /94 Region I Region I SPLB/DSSA/NRR SPLB/DSSA/NRR

JPDurr MWHodges JHolmes KSWest

2/ /94 2/ /94 2/ /94 2/ /94 C:SPLB/DSSA/NRR D:DSSA/NRR C:OGCB/DORS/NRR D:DORS/NRR

CEMcCracken ACThadani AJKugler BKGrimes

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03/04/94 14:05 DRS DIV. -* 3015043725 NO.979 D6or

IN 94-XX

March 3, 1994 Transmitted by ITMardn memorandum to TEMurley dated Juno 9-122

• see previous concurrence F

• OGCB/DORS/NR *Tech Editor Region I Region ,--l/

RJKiessel RSanders FBowerM V F q

=2/294 2122194 - g'94 /94 Region I Region I SPLBIDSSA/NRR SPLB/DSSA/NRR

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2/ /94 2/ /94 2/ /94 2/ /94