Information Notice 1997-70, Potential Problems with Fire Barrier Penetration Seals
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UNITED STATES
NUCLEAR REGULATORY COMMISSION
OFFICE OF NUCLEAR REACTOR REGULATION
WASHINGTON, D.C. 20555-0001
September 19, 1997
NRC INFORMATION NOTICE 97-70: POTENTIAL PROBLEMS WITH FIRE BARRIER
PENETRATION SEALS
Addressees
All holders of operating licenses for nuclear power reactors except those who have
permanently ceased operations and have certified that fuel has been permanently removed
from the reactor vessel.
Purpose
The U.S. Nuclear Regulatory Commission (NRC) is issuing this information notice to alert
addressees to problems in installed fire barrier penetration seals that 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.
Description of Circumstances
The staff in NRC Region I inspected fire protection at Maine Yankee Atomic Power Plant
(Maine Yankee) from June 26 through 30, 1995. No safety concerns or violations were
identified at that time regarding the installed penetration seals. However, an unresolved item
was opened regarding the acceptability of penetration seal qualification and testing, and
qualifications of installers.
Subsequently, the licensee conducted a scoping study in preparation for a walkdown of fire
barrier penetration seals. The licensee reported that some penetration seals in fire barrier
walls had no damming material. On the basis of these findings, the licensee examined is
criteria for penetration seals and conducted a technical review of its penetration seal design
parameters. The licensee also found discrepancies between available test reports, procedural
guidance, and the in-plant penetration seal configurations. In response to the discrepancies, the licensee established compensatory fire watches and developed a corrective action
program. The planned corrective actions were (1) determining why the discrepancies had
not been found during previous reviews, (2) evaluating the adequacy of procedures, test
reports, acceptance criteria, and field inspections, (3) evaluating the adequacy of existing seal
configurations, and (4) inspecting all fire barrier penetration seals. In Licensee Event Report
(LER) 96-017-1, "Fire Barrier Penetration Seal Discrepancy," dated August 28, 1996 (Accession Number 9609030377), the licensee reported that it had found three additional
types of deficiencies: (1) inadequate thickness of silicone foam, (2) temporary seals that were
not upgraded to permanent seals for an indeterminate period, and (3) one seal in which the
expected pipe movement exceeded the design rating of the seal.
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September 19, 1997 During the week of May 12, 1997, NRR staff reviewed and observed the problems found at
Maine Yankee and the corrective actions taken by the licensee. During a telephone
conference on May 14, 1997, Office of Nuclear Reactor Regulation (NRR) staff and Region I
staff obtained detailed information from the licensee regarding the seal problems found and
the corrective actions taken.
Discussion
The penetration seals at Maine Yankee were installed around 1978. Most of the original
seals used silicone foam. Since the original installation, the licensee has inspected all the
seals visually at each refueling outage. During the inspections and walkdowns that were
documented in LER 96-017-01, the licensee found that more than a thousand seals required
further evaluation, including destructive examination; about a thousand other seals had
defects; and a small number of seals had no defects. The licensee found seals with
inadequate thickness (the predominant problem), foreign materials in seals, no damming
material, and the wrong seal material installed. Although the licensee's design criteria
specified a minimum seal thickness of 7 inches, the average seal thickness was 5 to
6 inches, and some seals were only 2 to 3 inches thick. Although the licensee was once
planning to repair and replace the seals with silicone foam and silicone elastomer, the
licensee has since certified permanent cessation of power operation and is now proceeding to
decommission the facility.
The licensee told the staff that the installations were deficient because the quality assurance
and quality control procedures that were used by the installation vendor during original seal
installation were inadequate. The licensee also told the staff that it believes that the
deficiencies were not discovered for an extended period because its inspection and
surveillance procedures did not cover all important penetration seal attributes (e.g., the
presence of damming material was not a critical attribute) and because its inspectors had not
been properiy trained. The licensee has since completed a major effort, rewriting of its
procedures.
NRC requirements and guidelines for fire barrier penetration seals are in various documents:
10 CFR Part 50, Appendix R, "Fire Protection Program for Nuclear Power Facilities Operation
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. These requirements and
guidelines 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 systems related to safe
shutdown will remain free of fire damage.
September 19, 1997 The staff is revising Inspection Procedure 64704, "Fire Protection Program," March 18, 1994, contained in the NRC Inspection Manual, to include specific guidance for inspecting fire
barrier penetration seals. It should be noted that nonconforming conditions may go
undetected if the surface of the seal is covered by thermal insulation or damming material. In
addition, the staff has included guidance for inspecting fire barrier penetration seal programs
in its procedures for the new fire protection functional inspection program.
In July 1996, the NRC published NUREG-1552, "Fire Barrier Penetration Seals in Nuclear
Power Plants," to document the findings of a comprehensive technical assessment of fire
barrier penetration seals. The assessment addressed reports of potential problems, and
determined the adequacy of NRC requirements, review guidance and inspection procedures.
The staff concluded that the general condition of penetration seal programs in the industry is
satisfactory and that there were no problems of safety significance. Previous acting along
with continued upkeep of existing penetration seal programs and continued inspections, are
adequate to maintain public health and safety. However, the staff is continuing to study this
issue to determine if further regulatory action is required. The staff also recommended
revisions to the NRC fire protection regulation and review guidance. The content of this
report was discussed with the NRC Commission before it was issued.
This information notice establishes no new NRC requirements; therefore, no specific action or
written response is required by this notice. However, recipients are reminded that they are
required by 10 CFR 50.65 to take industry-wide operating experience (including information
presented in NRC information notices) into consideration, where practical, when setting goals
and performing periodic evaluations. If you have any questions about the information in this
notice, please contact the technical contact listed below or the appropriate NRR project
manager.
Alck W. Roe, Acting Director
(Dg ision of Reactor Program Management
'Offce of Nuclear Reactor Regulation
Technical contact: Christopher Bajwa, NRR
301-415-1237 E-mail: csbl@nrc.gov
Attachment: List of Recently Issued NRR Information Notices
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Attachment
September 19, 1997 LIST OF RECENTLY ISSUED
NRC INFORMATION NOTICES
Information
Date of
Notice No.
Subject
Issuance
Issued to
97-69
97-68
97-67
Reactor Trip Breakers
and Surveillance Testing
of Auxiliary Contacts
Loss of Control of
Diver in a Spent
Fuel Storage Pool
Failure to Satisfy
Requirements for
Significant Manipula- tions of the Controls
for Power Reactor
Operator Licensing
Failure to Provide
Special Lenses for
Operators Using
Respirator or Self-
Contained Breathing
Apparatus During
Emergency Operations
09/19/97
09/03/97
08/21/97
08/20/97
All holders of OLs for
pressurized water reactors
except those who have per- manently ceased operat..ns
and have certified that
fuel has been permanently
removed from the reactor
vessel
Holders of a facility
or construction permit
issued for a power
reactor pursuant to
All holders of OLs for
nuclear power reactors
except those who have
permanently ceased
operations and have
certified that fuel has
been permanently removed
from the reactor vessel
All holders of operating licenses
or construction permits for
nuclear power and non-power
reactors and all licensed reactor
operators and senior operators
97-66 OL = Operating License
CP = Construction Permit
September 19, 1997 The staff is revising Inspection Procedure 64704, "Fire Protection Program," March 18, 1994, contained in the NRC Inspection Manual, to include specific guidance for inspecting fire
barrier penetration seals. It should be noted that nonconforming conditions may go
undetected if the surface of the seal is covered by thermal insulation or damming material. In
addition, the staff has included guidance for inspecting fire barrier penetration seal programs
in its procedures for the new fire protection functional inspection program.
In July 1996, the NRC published NUREG-1552, "Fire Barrier Penetration Seals in Nuclear
Power Plants," to document the findings of a comprehensive technical assessment of fire
barrier penetration seals. The assessment addressed reports of potential problems, and
determined the adequacy of NRC requirements, review guidance and inspection procedures.
The staff concluded that the general condition of penetration seal programs in the industry is
satisfactory and that there were no problems of safety significance. Previous actions, along
with continued upkeep of existing penetration seal programs and continued inspections, are
adequate to maintain public health and safety. However, the staff is continuing to study this
issue to determine if further regulatory action is required. The staff also recommended
revisions to the NRC fire protection regulation and review guidance. The content of this
report was discussed with the NRC Commission before it was issued.
This information notice establishes no new NRC requirements; therefore, no specific action or
written response is required by this notice. However, recipients are reminded that they are
required by 10 CFR 50.65 to take industry-wide operating experience (including information
presented in NRC information notices) into consideration, where practical, when setting goals
and performing periodic evaluations. If you have any questions about the information in this
notice, please contact the technical contact listed below or the appropriate NRR project
manager.
original signed by
Jack W. Roe, Acting Director
Division of Reactor Program Management
Office of Nuclear Reactor Regulation
Technical contact: Christopher Balwa, NRR
301-415-1237 E-mail: csbl @nrc.gov
Attachment: List of Recently Issued NRR Information Notices
Tech Editor has reviewed and concurred on 08/22/97
- SEE PREVIOUS CONCURRENCES
DOCUMENT NAME: 97-70.1N
___
Office
Tech Contacts
C:SPLB
(A)C:PECB
(A)D:DRPM
Name
JCarter/CBajwa*
LMarsh*
RDennig*
JRr
Date
08/26/97
08/26/97
09/02/97
094/i/97 V97
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September xx, 1997 The staff is revising Inspection Procedure 64704, "Fire Protection Program," March 18, 1994, contained in the NRC Inspection Manual, to include specific guidance for inspecting fire barrier
penetration seals. It should be noted that nonconforming conditions may go undetected if the
surface of the seal is covered by thermal insulation or damming material. In addition, the staff
has included guidance for inspecting fire barrier penetration seal programs in its procedures for
the new fire protection functional inspection program.
In July 1996, the NRC published NUREG-1552, "Fire Barrier Penetration Seals in Nuclear
Power Plants," to document the findings of a comprehensive technical assessment of fire barrier
penetration seals. The assessment addressed reports of potential problems, and determined
the adequacy of NRC requirements, review guidance and inspection procedures. The staff
concluded that the general condition of penetration seal programs in the Industry is satisfactory
and that there were no problems of safety significance. Previous actions, along with continued
upkeep of existing penetration seal programs and continued inspections, are adequate to
maintain public health and safety. However, the staff is continuing to study this issue to
determine if further regulatory action is required. The staff also recommended revisions to the
NRC fire protection regulation and review guidance. The content of this report was discussed
with the NRC Commission before It was issued.
This information notice establishes no new NRC requirements; therefore, no specific action or
written response is required by this notice. However, recipients are reminded that they are
required by 10 CFR 50.65 to take industry-wide operating experience (including Information
presented in NRC information notices) into consideration, where practical, when setting goals
and performing periodic evaluations. If you have any questions about the information in this
notice, please contact the technical contact listed below or the appropriate NRR project
manager.
Jack W. Roe, Acting Director
Division of Reactor Program Management
Office of Nuclear Reactor Regulation
Technical contact Christopher Balwa, NRR
301- 415-1237 E-mail: csbl@nrc.gov
Attachment: List of Recently Issued NRR Information Notices
- SEE PREVIOUS CONCURRENCES
DOCUMENT NAME: G:ITJC\\PEN SEAL.IN3 Office
Tech Contacts
Name
JCarter/CBajwa*
Date
08/26/97 I A\\
I l
JRoe
09/02/97
09/ /97
4td4-) 142/?7
- AVgust xx, 1997 The staff is revising Inspection Procedure 64704, "Fire Protection Program," March 18, 1994, contained in the NRC Inspection Manual, to include specific guidance for inspecting fire barrier
penetration seals. It should be noted that nonconforming conditions may go undetected if the
surface of the seal is covered by thermal insulation or damming material. In addition, the staff
has included guidance for inspecting fire barrier penetration seal programs in its procedures for
the new fire protection functional inspection program.
In July 1996, the NRC published NUREG-1552, "Fire Barrier Penetration Seals in Nuclear
Power Plants," to document the findings of a comprehensive technical assessment of fire
barrier penetration seals. The assessment addressed reports of potential problems, and
determined the adequacy of NRC requirements, review guidance and inspection procedures.
The staff concluded that the general condition of penetration seal programs In the Industry is
satisfactory and that there were no problems of safety significance. Previous actions, along
with continued upkeep of existing penetration seal programs and continued inspections, are
adequate to maintain public health and safety. However, the staff is continuing to study this
issue to determine if further regulatory action is required. The staff also recommended
revisions to the NRC fire protection regulation and review guidance. The content of this report
was discussed with the Commission before it was issued.
If you have any questions about the information in this notice, please contact the technical
contact listed below or the appropriate NRR project manager.
Jack W. Roe, Director
Division of Reactor Program Management
Office of Nuclear Reactor Regulation
Technical contact: Christopher Bajwa, NRR
301- 415-1237 Attachment:
List of Recently Issued Information Notices
- See previous concurrence
DOCUMENT NAME: G:\\TJC\\PENSEAL.IN4 Office
Tech Contacts
C:SPLB
(A)C:PECB
(A)D:DRPM
Name
JCarter/CBajwa
LMarsh*
RDenn.I'
JRoe
Date
08/26/97
08/26/97
0) W97
08/ /97
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7-'
August xx, 1997 The staff is revising Inspection Procedure 64704, "Fire Protection Program," March 18, 1994, contained in the NRC Inspection Manual, to include specific guidance for inspecting fire barrier
penetration seals. It should be noted that nonconforming conditions may go undetected if the
surface of the seal is covered by thermal insulation or damming material. In addition, the staff
has included guidance for inspecting fire barrier penetration seal programs in its procedures for
the new fire protection functional inspection program.
In July 1996, the NRC published NUREG-1552, "Fire Barrier Penetration Seals in Nuclear
Power Plants," to document the findings of a comprehensive technical assessment of fire
barrier penetration seals. The assessment addressed reports of potential problems, and
determined the adequacy of NRC requirements, review guidance and inspection procedures.
The staff concluded that the general condition of penetration seal programs in the industry Is
satisfactory and that there were no problems of safety significance. Previous actions, along
with continued upkeep of existing penetration seal programs and continued inspections, are
adequate to maintain public health and safety. However, the staff Is continuing to study this
issue to determine if further regulatory action is required. The staff also recommended
revisions to the NRC fire protection regulation and review guidance. The content of this report
was discussed with the NRC Commission before it was issued.
This information notice establishes no new NRC requirements; therefore, no specific action or
written response is required by this notice. However, recipients are reminded that they are
required by 10 CFR 50.65 to take industry-wide operating experience (including information
presented in NRC information notices) into consideration, where practical, when setting goals
and performing periodic evaluations. If you have any questions about the information in this
notice, please contact the technical contact listed below or the appropriate NRR project
manager.
Jack W. Roe, Director
Division of Reactor Program Management
Office of Nuclear Reactor Regulation
Technical contact: Christopher Bajwa, NRR
301- 415-1237 Attachment:
List of Recently Issued Information Notices
DOCUMENT NAME: G:\\TJC\\PEN SEAL.IN3 Office
Tech Contacts
(A)C:PECB
(A)D:DRPM
Name
LMarsh
RDennig
JRoe
Date
08/2197
08QJ97
08/
/97
08/
I
97