Information Notice 1997-70, Potential Problems with Fire Barrier Penetration Seals

Potential Problems with Fire Barrier Penetration Seals
	ML031050108
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:	09/19/1997
From:	Roe J; Office of Nuclear Reactor Regulation
To:	;
References
	IN-97-070, NUDOCS 9709160254
	Download: ML031050108 (8)
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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.

9709

IN 97-70

K> k 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.

IN 97-70

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

AnRS d

K) K Attachment

IN 97-70

September 19, 1997 LIST OF RECENTLY ISSUED

NRC INFORMATION NOTICES

Information Date of

Notice No. Subject Issuance Issued to

97-69 Reactor Trip Breakers 09/19/97 All holders of OLs for

and Surveillance Testing pressurized water reactors

of Auxiliary Contacts except those who have per- manently ceased operat..ns

and have certified that

fuel has been permanently

removed from the reactor

vessel

97-68 Loss of Control of 09/03/97 Holders of a facility

Diver in a Spent or construction permit

Fuel Storage Pool issued for a power

reactor pursuant to

10 CFR Part 50

97-67 Failure to Satisfy 08/21/97 All holders of OLs for

Requirements for nuclear power reactors

Significant Manipula- except those who have

tions of the Controls permanently ceased

for Power Reactor operations and have

Operator Licensing certified that fuel has

been permanently removed

from the reactor vessel

97-66 Failure to Provide 08/20/97 All holders of operating licenses

Special Lenses for or construction permits for

Operators Using nuclear power and non-power

Respirator or Self- reactors and all licensed reactor

Contained Breathing operators and senior operators

Apparatus During

Emergency Operations

OL = Operating License

CP = Construction Permit