ML20133G963
| ML20133G963 | |
| Person / Time | |
|---|---|
| Site: | Byron, Braidwood, 05000000 |
| Issue date: | 07/30/1985 |
| From: | Ainger K COMMONWEALTH EDISON CO. |
| To: | Harold Denton Office of Nuclear Reactor Regulation |
| References | |
| 6596B, NUDOCS 8510160204 | |
| Download: ML20133G963 (4) | |
Text
,* f~'N Commonwealth Edison
- / ) Ons First National Plaza. Chictoo, Ilhnois
( Address Reply to: Post Office Box 767
( Chicago, Illinois 60690 July 30, 1985 Mr. Harold R. Denton, Director Office of Nuclear Reactor Regulation U.S. Nuclear Regulatory Commission Washington, DC 20555
Subject:
Byron /Braidwood Stations, Units 1 and 2 Acceptance Criteria for Firecode CT Gypsum Fire Seals NRC Docket Nos. 50-454, 50-455, 50-456. and 50-457
References:
- a. January 17, 1985 letter from R.L. Spessard to C. Reed with Inspection Report No. 50-454/84-76: 50-455/84-51 attached, j
- b. May 28, 1985 letter from H.L. Massin to H.R. Denton regarding Firecode CT Gypsum Fire Stops at LaSalle County Station.
- c. July 16, 1985 letter from W.R. Butler to D.L. Farrar regarding acceptance of criteria for Firecode CT Gypsum k Fire Stops at LaSalle County Station.
Dear Mr. Denton:
In the Inspection Report referenced in (a) above, Commonwealth Edison committed to the following criteria for Byron Firecode CT gypsum fire seals (documented on page 17 of the Inspection Rcport):
- 1. Cracks and/or separations greater than 1/16" wide by less than the full depth of the penetration fire seal would be repaired.
- 2. Cracks and/or separations greater than 1/32" but less than 1/16" wide and less than the full depth of the penetration fire seal would require a depth criteria as determined by test data.
- 3. Cracks and/or separations less than or equal to 1/32" wide by 1" deep will not require a repair.
We agreed to these requirements because we could not justify a larger separation criterion based on existing test reports.
The LaSalle County Station of Commonwealth Edison was faced with similar requirements and therefore when Transco successfully performed a fire test on November 20, 1984 on a gypsum fire seal with a 1/4" wide through crack, CECO requested a change in the crack size criteria for LaSalle as documented in reference (b) above. The NRC ccceptance of the CECO position at LaSalle is documented in reference (c) ebove.
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2-Transco is the installation contractor for all gypsum seals at both Byron and Braidwood. Since the gypsum and thermafiber fire penetration seals at Byron and Braidwood are similar in configuration to those at LaSalle and to those described in Transco Test Report No-TR-161, we propose to revise the acceptance criteria for cracks and separations in our installation and surveillance procedures at Byron and Braidwood for all CT Gypsum and Thermafiber fire seals except those in the refuel floor area to the same criteria approved for LaSalle in NRC letter dated July 16, 1985 (Reference (c) above). The approved criteria for LaSalle are as follows:
- 1. Initial and Repair Acceptance Criteria (initial installation and after repairs).
Crack Width Corrective Action
( 3/32" None Required.
2*3/32"
. Seal not acceptable-must be repaired.
- 2. Surveillance Acceptance Criteria Crack Width Corrective Action 4 5/32" None Required 3b 5/32" and < 1/4" Seal is operable and must be repaired on an orderly schedule.
2: l/4" Seal is inoperable and must be repaired.
The acceptance criteria for the fire stops in the area of the refuel floor of the Fuel Handling Building, the only area in the plant where solid hose stream nozzles are installed, will remain at 1/32".
We request your prompt review of this issue and concurrence with our revised acceptance criteria. We have attached copies of references (a), (b) and (c) for your use.
One signed original and fifteen copies of this letter and attachments are provided for NRC review.
1 Please direct any questions regarding this matter to this office.
f Very truly yours, t
4 K.A. Ainger i Nuclear Licensing
. Administrator i
MFP/bab/6596b i Attachments cc: Byron Resident Inspector i Braidwood Resident Inspector 1
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- Review of the Transco Products, Inc. test results and methodology against the acceptance criteria of the Standard Review Plan showed the following:
- a. The time temperature curve utilized for the test conformed to ASTM E-119 specifications. -
- b. The flame through and cable ignition criteria were satisfied. "
- c. The maximum unexposed surface temperatures remained below the 325' specified value.
- d. Temperature recording requirements were satisfied.
- e. The tested configuration is representative to the as-installed configurations at LaSalle.
- f. Hose stream tests performad in accordance with Items 1 and 2 above were successfully completed. A single successful test would have been sufficient. Thus, minimum hose stream test requirements were met or exceeded.
Given that the tested seal configuration with a 1/4 inch crack passed all required tests and bounds the seal configuration at LaSalle and the licensee's proposed crack and separation criteria, the staff finds the proposed criteria acceptable.
Environmental Consideration
, The proposed changes involve a change in the initallation or use of a facility comp'onent located within the restricted area as defined in 10 CFR Part 20.
The' staff has determined that the changes involve no significant increase in the amounts, and no significant change in the types of any effluents that may be relhased offsite, and that there is no significant increase in individual or cumulative occupational radiation exposure. Pursuant to 10 CFR 51.22(b) no environmental / impact statement or environmental assessment need be prepared in connection with the proposed changes.
Conclusion '
a l The staff has concluded, based on the censiderations discussed above, that:
! (1) there is reasonable assurance that the health and safety of the public will not be endangered by operation in the proposed manner, and (2) such activities will be conducted in compliance with the Commission's regulations and will not be inimical to the common defense and security or to the health and safety of the public.
Dated:
Principal Contributor W. G. Guldemand 4
Commonwealth Edson
@ one First National Plata. Chicago, hhnois Address Reply to. Post Ottice Box 767 Chicago. Illinois 60690 May 28, 1985 Mr. Harold R. Denton, Director Office of FA> clear Reactor Regulation U.S. Nuclear Regulatory Commission Washington, DC 20555
Subject:
LaSalle County Station Units 1 and 2 Acceptance Criteria for Firecode CT Gypsum Fire Stops NRC Docket Nos. 50-373 and 50-374 References (a): June 24, 1983, letter from D.L. Farrar to J.G. Keppler regarding Firecode CT Gypsum Cement Fire Stops.
(b): August 5, 1983, letter from C.W. Schroeder to J.G. Keppler on the same subject.
(c): Noverrber 23, 1983, letter from C.W. Schroeder to H.R. Denton regarding Fire Protection Commitments.
(d): February 10, 1984, letter from C.W. Schroeder to J.G. Keppler regarding same subject.
(e): Transco Test Report No. TR-161.
(f): Decerrber 10 and 13,1985, letters from R.J.
Smith of M&M Protection Consultants to D. Elias regarding Transco Test Reports TR-159 and TR-161.
(g): April 30, 1985, letter from R.J. Smith of M&M Protection Consultants to D. Elias regarding crack criteria.
(h): June 20, 1985 telecon between A. Bournia, R.
Ferguson, S. West, of your staff, and J. Marshall, H. Massin, et al of CECO.
Dear Mr. Denton:
In reference (d) we committed to revise the Firecode CT Gypsum Fire Stop surveillance and installation procedures to incorporate the 1/32" acceptance criteria for cracks and separations. We agreed to this stringent requirement because we could not justify a larger separation criterion based on existing test reports.
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H. R. Denton May 28, 1985 On November 20, 1984, Transco successfully performed a fire test on two 9" x 14.5" penetration fire seals consisting of 5" CT Gypsum Cement and 4" CT Thermafiber with a 14.5" long by 1/4" wide through crack in the cement. In one penetration the cement was on the bottom or exposed side, and in the other penetration the thermafiber was on the botton. Both penetration seals passed the temperature criteria on the unexposed side as well as the IEEE-634 and ANI hose stream tests. However, water did leak through one of the penetrations during the ASTM E119 solid hose strecm test. This test, which was witnessed by M&M, is documented in Transco Test Report No. TR-161, and this report was reviewed and approved by M&M (Refs.
(f) and (g)). ,
Because of this test M&M recommended that we expand the separation criteria for operability to 3/32" for initial installation and 1/4" for normal surveill&nce. However, M&M also recommended that we repair any seals with cracks wider than 1/8" even if the seal was considered to be operable (ref. (g)). Their recommendations were applicable to all fire penetration seal configurations consisting of 5" CT Gypsum Cement and 4" CT Thermafiber except those which could be subjected to a solid hose stream (paragraphs 6 and 7 of Ref. (g)).
Since the fire penetration seals at LaSalle are similar in configuration to those described above, we propose to revise the acceptance criteria for cracks and separations in our installation and surveillance procedures for all CT Gypsum and Thermafiber fire seals except those in the refuel floor area as follows:
- 1. Initial and Repair Acceptance Criteria (initial installation and after repairs)
Crack Width Corrective Action
< 3/32" None required.
- 2. 3/32" Seal not acceptable -
must be repaired.
- 2. Surveillance Acceptance Criteria Crack Width Corrective Action 4 5/32" None required 2 5/32" and( 1/4" Seal is operable and must be repaired on an orderly schedule.
2 1/4" Seal is inoperable and must be repaired.
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H. R. Denton May 28, 1985 The acceptance criteria for the fire stops in the refuel floor, the only area in the plant where solid hose stream nozzles are installed, will remain at 1/32". References (a), (b), and (c) document the fire penetration seal configurations installed at LaSalle and their basis.
All other commitments that we made in reference (c) regarding the training of plant personnel and the tracking of abnormal penetration seals will not be changed.
We request your prompt review of this issue and concurrence with our revised acceptance criteria. We have attached copies of references (a),
(b), (e), (f), and (g) for your use.
Very truly yours, Qw AMassin H. L.'
Nuclear Licensing Administrator
- 1m i
Attachments cc: Resident Inspector - LSCS A. Bournia - PER G. Diederich - LSCS D. Elias i
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.. . . . CommonwIlth Edison
,t , ,. On> First National Piare. Chicago. Ithnois ,
,- Address Reply to Post Once Box 767 Chicago, phnois 60690 .
June 24, 1983 Mr. James G. Keppler, Regional Administrator .
- Region III U.S. Nuclear Regulatory Commission 799 Roosevelt Road
.. . Glen Ellyn, IL 60137
Subject:
LaSelle County Station Units 1 and 2 Firecode CT Gypsum Cement Firestops NRC Inspection Report Not.
50-373/82-54 and 50-374/82-22 NRC Docket Nos. 50-373 and 40-374 References (a): R. L. Spessard letter to Cordell Reed dated April 28, 1983. .
(b): D. L. Farrar letter tc J. G. Keppler ~
dated May 27, 1983.
(c):
D. L. Farrar letter to J. G. Keppler dated June 10, 1983.
Dear Mr. Keppler:
l The subject inspection report requested that we address the I following issues concerning the fire endurance capability of U.S. Gypsum j Firecode CT Gypsum cement firestops: ,
- 1. Cracking and separation
- 2. Breakthroughs
- 3. Cable density
- 4. Deviation from test configurations
- 5. Mixture control -
Attached is our response to these items and the documentation which justifies our position. A list of the documentation that is enclosed is provided in Attachment 1.
As explained in Reference (c), our response regarding the Unit I wall penetrations will be submitted by August 5, 1983.
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J. G. Keppler June 24, 1983 To the best of my knowledge and belief the statements contained herein and in the attachment are true and correct. In some respects these statements are not based on my personal knowledge but ,upon informa- ~
tion furnished by other Commonwealth Edison and contractor employees.
Such information has been reviewed in accordance with Company practice and I believe it to be reliable.
If there are any further questions in this matter, please contact this of fice.
Very uly you A_-:_!-
D. L. Farrar Director of Nuclear Licensing im .
4 N . -
91 c)c:NRC Resident Inspector - LSCS 1/0 ~~
Attachment O
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ATTACHMENT Engineering Response to Inspection Report No.'s -
50-373/82-54 and 50-374/82-22
- 1. Cracking and separation The cracks and voids, which varied in width from hairline to 3/8",,found in some penetration firestops of Firecode CT Gypsum Cement do not degrade the fire endurance capability of the seal. Seven of the attached reports document cracking in fire seals that were successfully tested. U.S. Gypsum (USG) fire
.. . test report no.'s 1, 3, 5, and 6 reference hairline cracks USG report no. 7 and Transco report no. I reference 1/8" wide cracks, and USG report no. 2 references 1/2" wide cracks. ,
The LaSalle penetration firestops also have a layer of Thermafiber CT Felt in addition to the gypsum cement. Although the felt by itself can not withstand the hose stream test, it will prevent the passage of flame and hot gases.
Successful tests on penetration firestops containing only Thermafiber CT Felt are documented in USG report no.'s 6, 7, and 8. In test no. 6 the felt pre-vented the cables above a cable pan penetration from burning (see Detail DI).
USG report no. 7 also documents a successful three-hour test on a cable pan -
penetration in which only felt was installed around the pan. USG report no. 8 documents a successful 26-hour test on many different types of penetrations containing only thermafiber. This test was terminated before three hours had expired because of problems with the penatrations containing galvanized pipes. ,,
We consider a fire seal acceptable if it contains no cracks, voids, or sepa-rations greater than 3/8" wide. Cosmetic factors such as surface smoothness, ripples, craters, fine surf &ce cracks, chips, gouges, and all other minor blemishes are also acceptable. Any crack in the CT Gypsum cement greater than
- 3/8" wide is to be cleaned and repaired with the gypsum cement.
- 2. Breakthroughs Breakthroughs, the addition of cables to a seal, do not degrade the integrity of the firestop if the spaces around the new cables are filled with gypsum cement. USG report no. I and both Transco reports document successful three-hour fire tests on penetration firestops containing b-eakthroughs. In the USG test, four cables were removed from two openings and two cables were added to two penetrations. Transco report no. I documents a test on a penetration fire seal that four cables were added to. The second Transco report describes a l test.on a penetration fire seal with two breakthroughs. 'Although one of the l two cables that were added ignited, no openings in the seal occurred. This .
1 cable was not qualified to IEEE 383 and did not ignite due to the passage of flame or hot gases. The copper conductors in the cable transferred enough
' heat to cause the cable jacket on the unexposed side to auto-ignite.
Since breakthroughs do not degrade the fire seal because the new gypsum cement bonds to the old cement, there is no limit on the number of breakthroughs in .
the seal as long as the cable fill density has not been exceeded. A fire seal with "n+1" cables has the same integrity as a seal with "n" original cables and to which a cable is added.
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- 3. Cable Density -
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No cable tray penetration in a three-hour fire rated wall in Unit 2 or in a .
l three-hour fire rated floor in either unit has a cable density greater than the maximum density tes.ted. The maximum cable pan density tested is 40% for floor penetrations (USG report no. I and both Transco reports) and 51% for wall penetrations (USG report no.'s 5 and 7). As documented by the S&L letters, no floor penetration has a cable density greater than 40%, and the maximum density in a Unit 2 wall penetration is 49.1%. .
For your infonnation, the cable pan density is calculated by dividing the sum of the cross sectional area of the cables by the cross sectional area of the
- cable pan and multiplying by 100. The attached S&L letter dated June 17, 1983, l explains the relationship between the cable pan density (CD) and the S&L design i index (DI) for vertical cable riser penetrations. For horizontal cable pan penetrations, the formula is:
CD = (TT/4)2 X DI X 100 As stated in reference (c), we will furnish our response regarding the Unit I wall penetrations by August 5, 1983.
- 4. Deviation from Test Configurations l
i The design of all the penetration firestops at LaSalle is verified by the at- .
tached test reports. The installed penetration seals are either identical or ~ ~ i similar to at least one of the penetration configurations that were tested.
1 Some of the tests also represent a more severe service condition on this type i of seal than it can experience in the plant because thermafiber felt was not.
used in the test or the stress on the test specimen was greater.
- a. Control Room Floor penetrations .
The fire endurance capability of the control room flocr penetrations is verified by the two attached Transco test reports. Transco report no. -
l TR-109 describes 'a three-hour fire test on a 32" X 109.5" penetration containing Firecode CT Gypsum cement. Although the surface area of the test specimen is 26% smaller than the 28" X 170" control room floor pene-l i t ation, they have similar configurations. Both penetrations are long and narrow and have the same thickness of gypsum cement. However, the test
- specimen was subjected to a more severe service condition because it had cable trays, which increase the loading and heat conduction, and therma-fiber felt only inside the cable trays. The control room floor penetration fire
- aals have no cable trays and have a layer of felt throughout the -
seal. The test specimen is also four inches wider, and for these types of penetrations, the maximum stress that the seal can withstand decreases as the width increases but varies very little with changes in the length.
Therefore, the heat transfer rate per unit area and the stress on the test penetration is greater.
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The other Transco report describes a test on a 5' X 6' penetration which is only 10% smaller than the 28" X 170" control room floor penetration. -
This test aise represents a more severe service condition for the firestop '
because the test specimen had eight cable trays and no thermafiber felt.
The stresses at the side of the test seal are also greater because the hose ,
stream produces a greater bending moment, and the gypsum cement has less surface area to adhere to than in long and narrow type penetrations.
- b. Floor penetrations with 12" X 30" Cable Trays Although none of the attached reports describe a test on a penetration firestop with a 12" X 30" cable tray, many of them describe tests on pene-trations with similar or multiple cable trays. USG report no.'s 1 and 4 -
document a test on a 30" X 4" and 36" X 4" cable tray, respectively. The Transco reports describe tests on penetration seals with three and eight cable trays and the sum of the cross sectional area of the cable trays used in each test is greater than the 12" X 30" cable tray. This increases the heat transfer rate and loading of the seal. Thus, the test specimens were subje:t to a more severe service condition than the field installations can experience.
- 5. Mixture Control -
The attached USG 1etters/ provide additional information regarding Firecode CT Gypsum Cement. The June 8, 1983, letter describes what gypsum cement is, how it is,made, what happens when water is mixed with it, and how temperature af , ,-
fects it. The other USG letter furnishes additional information on the water-- -
to-plaster ratio and the dry density range. As explained in these letters, the effectiveness of the gypsum cement fire seal is not a function of this ratio or density, it is dependent on the integrity of the seal after it is installed.
Therefore, based on the inspection results, we consider the seals to be operable.
Please note that USG Research Center analyzed a portion of a seal that had been removed and found that its density was within the range of 25 to 30 lbs/f t3 ,
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Attachment 1 -
List of Attached Documentation - .
A. U.S. Gypsum Fire Test Reports
- 1. Concrete Floor Fire Stop Test of Nonqualified IEEE 383 Cable Penetrations Protected with Firecode CT Gypsum and Thermafiber Felt dated March 14, 1980.
- 2. Fire Stop Systems Without Cable in a Three-Hour Fire Rated Wall dated September 6, 1979. ,
. - 3. Concrete Floor Fire Stop Test of IEEE Qualified Cable Penetrations dated' August 13, 1979.
- 4. Poke-Thru Wall Fire Test dated May 21, 1979.
- 5. Firestop Systems for Electric Cable Penetrations Thru Three-Hour Fir,e Rated Wall dated March 20, 1979.
- 6. Fire Test of Concrete Floor Slab with Electrical Cable Penetration Firestops dated December 7,1978.
- 7. Firecode CT Gypsum Thermafiber Access Firestopping for Walls dated July 24, 1978.
- 8. Thermafiber Access Firestopping for Floors dated June 19, 1978.
B. Transc~o Fire Test Reports
- 1. Report No. TR-109, Fire and Hose Stream Tests of TCO-001 Cement (USG Firecode CT Gypsum Cement), dated April 7, 1983.
- 2. Fire Endurance Test on Transco Penetration Seal Systems in a Concrete Floor Utilizing Firecode CT Gypsum Cement dated August 5, 1981.
C. Letters
- 1. June 17,1983, letter from Mr. J.S. Esterman of S&L to Mr. T.E. Watts (SCE-1829).
- 2. June 14, 1983, letter from Mr. J.S. Esterman of S&L to Mr. T.E. Watts (SCE-1827).
- 3. June 8,1983, letter from Mr. R.G. Lange of USG to Mr. E.L. Seckinger.
- 4. June 3.' 1983, letter from Mr. R.L. Bartlett of USG to Mr. E.L. Seckinger.
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Commonweshh Edison -
One First National Pla:a. Ch<ago, Ilknois ~
Address Reply to: Post Office Box 767 Chicago, lihnois 60690 ,
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August 5, 1983 Mr. James G. Keppler, Regional Administrator
- Region III U.S. Nuclear Regulatory Commission 799 Roosevelt Road Glen Ellyn, IL 60137
Subject:
LaSalle County Station Units 1 and 2 Firecode CT Gypsum Cement Firestops -
Supplemental Information I.E. Inspection Report Nos.
50-373/82-54 and 50-374/82-22 NRC Docket Nos. 50-373 and 50-374 References (a): D.L. Farrar letter to J.G. Keppler dated. June 24, 1983.
(b): D.L. Farrar letter to J.G. Keppler dated July 6, 1983. ..
Dear Mr. Keppler:
Attached is the information that the NRC requested on the coeffi-cient of expansion for Firecode CT Gypsum cement and cable densities in Unit 1 cable tray penetrations. This completes our response to the subject inspection reports.
Commonwealth Edison Company is prepared to discuss this and
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other related information with your staff. Please contact this office if further discussion is desired.
Very truly yours, C. W. Schroeder U '
Nuclear Licensing Administrator 1m cc: NRC Resident Inspector - LSCS 7098N 1,' I D '1 J[D E v,j' s s t~
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ATTACHMENT Supplemental Response to Inspection Report No.'s 50-373/82-54 and 50-374/82-22
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- 1. Cracking and Separation - Thermal Expansion When Firecode CT Gypsum cement is heated, it will expand to fill or
~ decrease voids in the seal. Its thermal coefficient of linear expansion is between 8.35 and 8.60 x 10-6 in/in/0F inclusive.
Gypsum cement also expands about 0.12% during setting. The attached July 21, 1983, letter from U.S. Gypsum provides additional information on this subject.
- 3. Cable Density - Unit 1 Wall Penetrations As documented in reference (1), the maximum cable fill density tested in a wall penetration with a cable tray is 51%, and two Unit 1 cable tray penetrations in three-hour fire rated walls, AB2135 and AB2142, have cable fill densities greater than the tested limit.
Penetrations 52.6%, AB2135 and AB2142 have cable fill densities of 51.4% and respectively. The attached July 27, 1983, Sargent and Lundy letter lists all of the Unit I wall penetrations with cable fill densities greater than 40%.
Both penetrations are located in the wall between the cable spreading room in 749' (fire thezone 4D1) and auxiliary the cable area (fire zone SA4) at elevation building. This wall is approximately 12" thick, and the firestop in both penetrations consist of 5" of Firecode CT Gypsum cement and a layer of Thermafiber CT felt in the cable tray and 2" of cement and 6" of felt in the area around the cable tray. i Since the cable fill densities in these two penetrations are less than 2% above the test limit, we do not believe that the fire !
i endurance capability of the firestops is degraded. However, to provide additional assurance that the seal eeets the requirements for '
l a three-hour fire rated barrier, we propose to enlarge the firestop in each penetration by filling in the remainder of volume in the opening with gypsum cement and felt. Thus, each penetration will contain the equivalent of two three-hour fire rated seals.
will be completed within three months after NRC concurrence. This work , ;
To prevent any other penetrations from exceeding the cable fill density December limit, we will revise existing engineering procedures by 31, 1983, l of modifications. to ensure that this item is reviewed in the design The station will review its procedures and revise ('
them as necessary Shutdown Analysis to ensure that any design changes involving Safe
- required fire seals be submitted to engineering for review and approval.
To assist the station, engineering is in the process of issuing electrical firestops in fire rated walls or floors.
drawings that list all electrical !
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July 21, 1983 Mr. E. L. Seckinger
'~' Co=.onwealth Edison - SNED P.O. Box 767 Chicago, IL 60690
SUBJECT:
LaSalle County Station USG Fire Stop Systems NRC Allegation Regarding Thermal Expansion
Dear Mr. Seekinger:
In reply to the NRC requesting additional information that FIRECODE CT Gypsum Cement expanded duiing a fire, we offer the following for their consideration.
On page 100, Table VIII, of the Manual of Lathing and Plastering, John
- R. Diehl AIA Author, Copyright 1960, MAC Publishers Association, refers to typical properties of gypsum as reported by the Gypsum Association in which the Thermal Coefficient of Linear Expansion is one of the prop-erties listed (copy attached). The Thermal Coefficient of Linear Ex- -
pansion. (in/in/0Fx10-6) of gypsum aggregated with vemiculite aggregate ranges'from 8.35 to 8.60 x 10-6 FIRECODE CT Gypsum Cement is aggregated with vermiculite and falls within this range.
In addition to thermal expansion, gypsum expands during setting. FIRECODE CT Gypsum Cement has a setting expansion of 0.12% and unlike portlant '
cemene mixes which shrink, always has a net expansion.
If you require further information, please contact me.
Very truly yours, UNITED STATES GYPSUM COMPANY l
i R. L. Bartlett Technical Representative.
RLB/dlh attachment ec: #151 R. G. Lange Mr. Tom Hoff
- 173 P. G. Smith TRANSCO, Inc.
- 440-3 E. L. Whiteside 55 E, Jackson Blvd.
Chicago, IL 60604 l
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. Table Vill.
i Properties of Gypsum Job. Mixed Basecoot Plasters l i *. Sand Perlite Wrmiruhte Wrw=1 Filese 1 Io br.il
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1:2 1:3 1:2 1:3 1:2 1:3 1:0 1:1 E ;' el Cornpressive Strength g ! jj* Pounds per sq. in.
4 775-1050 525-700 600-800 450 600 400-52.5 250L325 1754 2350 i
1 h I: Tensile Strength
f %!ndulus of Elasticity -
j q i. Founds per sq. in. 108 1.0 1.15-1.20 0.2P-0.33 0 028 0 65-0.75 e i I?
- ; n ., Density In-Place I
. * ' Poundi per cu. ft. 104-120 104-120 50 56 41-45 50-55 42-45 79 82 sfi[: Coe$cient of 1.inear
{ .*
gp Espan h
- j .'*
inches / inch / degree gg F a l0-* 6 50 6.75 7.35 7.30 8.35 8 60 9.30
.'y,t Thermal Conductinty >
,6 e.! BTU />q. It./ hour /*F/. ,
's 1 inch thiciness 5.51 5.60 3.64 1.31 1,74 1.42 3 15 .
5<>urce: C 3 psum Awuciation. I
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.,i a relatively high percentage of cementitinus mate- Table IX. ~
- .* rial) are generally subject to greater initial shrink-I, E age upon drying than are tcan mises. It is generally Calculated Tensile Strains of Foilure for Various
- recommended that mises tending toward the lean Gypsum Plasters'
., ; :I side be used for esterior plaster, due to the rnate- - - . - I j?' rials used and the presence of environmental condi. .,.C"',',',f", d;,,"l ;
.1 f j tions producing movement. Along with this are the Tensile htnilulus of at Failiare
,J 61 more severe consequences of possible cracking re. Plaster Strength Elasticity htioninclies/
I ik-'. sulting from movement than would be the case in interior appliestions.
Proponions 1.bs /wa. in. 1.bs./us. in. in./in.
3 l Wond-Fahred -
8 Summary tabulations of some of the properties Cyp =.m Plaster 290 -
753.000 386 !
, of gypsum plasters are in Tables Vill and IX. g, g,,,
g,a ,
Brown Coat 80 175.000 457
- l ..[' i- o MIXING THE MATERIALS 1.i a ucing FeniJi Cnat 70 111.000 n31 l .\fising umsists primarily of two nperations
j . i first, measuring the enmponents acu)rding to the U Srrste Coat 310 985,000 315 2 reytiired prnportinns and adding them in the mix. _ .. _. , ,
I ing hon or machine; setund, cumbining ti.e oim-
- j}; /} *. j..
1:35 -1 ;
p<ments into a homogeneous mixture while adding B'".= Coat 210 730.txx) 2xn -
e -s C:srt >
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SARGENT & LUNDY ENGINEERS
- 95 E AST MONROE STREET CMIC AGO, IL LIN ot s 8 0 0 03 j $31212 8 9 2 000 TWR 980 229 2007 SCE-1853 July 27, 1983 Project No. 4267-02
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Commonwealth Edison Company , .,
La Salle County Station - Unit 1 . . .
Cable Tray Fill Density for Horizontal Cable Tray Wall Penetration Fire Seals .
Part of Sargent & Lundy Punchlist Item 3.96 .
Mr. T. E. Watts Commonwealth Edison Company .
P. O. Box 767 Chicago, Illinois 60690'-
Dear Mr. Watts:
After completing our work identifying all electrical openings in Unit 1 that require fire seals, we have prepared a list of the horizontal cable tray wall penetrations that exceed 40 percent of cable tray volume. This information was requested in your letter -
of May 12, 1983, to Mr. R. H. Pollock.
Routing Nearest Cable Required By Electrical Drawing Routing Design _ Fill Safe Shutdown Opening No. Number . Point Indez , _ Density, . Analysis -
AB2076 1E-1-3665 ~ .386B 1.25, , 49.1% ,, Yes A32081 1E-1-3665 445D 1.18 46.3% , Yes AB2101 1E-1-3665 373B 1. 20, , 47.1% Yes AB2135 1E-1-3667 592E 1.31 51.4% Yes AB2142 1E-1-3667 5773 1.34 52.6% Yes
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AB2146 1E-1-3667 5645 1.15 45.2% Yes RB2053 1E-1-3653 1395B 1.06 41.6% No RB2054 1E-1-3653 13955 1.06 41.6% No ,
AB2207 1E-1-3669 653B 1.15 45.2% Yes (Unit 2)
A32210 1E-1-3669 652B 1.15 45.2 No (Unit 2)
A32023 1E-1-3663 286A 1.14 44.8% Yes AB2059 1E-1-3664 430A 1.24' 48.7% Yes AB2065 1E-1-3664 426A 1.02 40.1% Yes i
TB2086 1E-1-3680 2113A 1.18 46.3% No T32145 1E-1-3683 2370A 1.39 54.6% No
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S~A RGENT & LUNDY -
EN GIN E ER S chscAso
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Mr. T. E. Watts July 27, 1983 Commonwealth Edison Company , , Page 2 The 3-hour fire walls were found using figure 9.5-1 of La Salle County FSAR Chapter 9. These 3-hour fire walls were compared -
with figure H.2-1 of Appendix H to verify that the 3 hour3.472222e-5 days <br />8.333333e-4 hours <br />4.960317e-6 weeks <br />1.1415e-6 months <br /> walls with electrical openings were required by the safe shutdown analysis. Cable fill density is calculated by using the following
.. formula and is equivalent to the method specified in your letter:
(Cable Pill Density) T
% Tray Fill = 4 x Design Index x 100 If you have any questions concerning this, please give me a call.
Yours very tr,uly, J.S.ESTERMAN J. S. Estorman Electrical Engineer ,
JSE:smg In duplicate Copics:
B. R. Shelton .
R. H. Holyoak -
G. J. Diederich E. L. Seckinger D. L. Shamblin R. H. Pollock e
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TRhNSCO PRODUCTS INC.
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TRANSCO TEST REPORT NO. TR-161 FIRE AND HOSE STREAM TESTS -
OF TCO-001 CEMENT, TCO-002 MEDIUM DENSITY SILICONE, AND TCO-007 SILICONE ADHESIVE USED IN ELECTRICAL CONDUIT AND BLOCKOUT PENETRATIONS
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! By: T. Hoff Test Date: 11/20/8ti G d E /"h s / - ;r - ;
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A CORPORATION OF THE TRANSCO GROUP
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- TR'ANSCO PRODUCTS INC. Test Report fTR-161 I RLVISCN 'IDG A.) As revised 2/13/85:
1.) Page 6 of 23, third paracraph, second and tlurd line, delete "anything", and insert "any seal surface,".
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2.) Page 9 of 23, first paragraph, fourth line, delete "inside".
3.) Page 9 of 23, thhd paragraph, second line, delete
" pressure".
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4.) Page 10 of 23, second line, delete " penetrate the seals" and insert " project frm tle unextosed surface ,
of the seals". .
5.) Page 10 of 23, seventh line, delete "are" insert "were". ,
6.) Page 10 of 23, ite. "c.)", delete the first " hose".
7.) Page 10 of 23, second to the last line, delete " exposed" -
and incert " unexposed". ~
O A CORPORATION OF THE TRANSCO GROUP
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- TRhNSCO PRODUCTSINC. Test Report #TR-161 Page 1 of 23 ,
, A.) SYNOPSIS:
This report describes a three-hour fire and subsequent hose stream tests (in a floor assembly) of Transco #TCO-001 Cement (US Cypsus Firecede CT Cypsum Cement), #TCO-002 Medium Density Silicone, and
- TCO-007 Silicone Adhesive (Dow corning 96-081) installed in sim-ulated electrical openings. The test was performed in accordance with the ASTM E .1,19 time / temperature curve for three hours along
, with provisions set forth in the ANI, NHL, and IEEE-634 standards for conducting qualification tests for penetration seals. The purpose of this test was to demonstrate the fire resistant qual-ities of the overall. seals when tested to the parameters of these standards. The test was conducted on November 20, 1984 at Portland ,
Cement Association / Construction Technology Laboratories Fire i
Research Laboratory (Skokie, Illinois).
i The specimen consisted of 6-5" diameter (I.D.) conduits cast in concrete into a 21" x 30" section of the 48" x 48" x 12" thick * '
concrete slab. ' 9" x 30" x 12" deep rectangular opening remained in the 48" x 48" x *12" thick slab which was divided into 2 equal I
sections of 9" x 14 " x 12" deep each using a 1" thick Carborundum Ceramic Hot Board. 2-2" diameter (I.D.) conduits with bends on both ends were inserted into the 2-9" x 14 " x 12" deep rectangular i
openings ( 1 in each). All conduits contained varying amounts of electrical cable (the 2. rectangular openings had no cable), and all penetrations were sealed using CT Gypsum, Medium Density Silicone, or i Silicone Adhesive, and US Cypsum CT Thermafiber damming.
. A CORPORATION OF THE TRANSCO GROUP .
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-TR'ANSCO PRODUCTS INC. Test Report #TR-161 Page 2 of 23 .
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B.) TEST SLAB:
The test slab measured 48" x 48" x 12" thick. The following are the specifics for each penetration:
PENE. A & B
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Consisted of 4-7/8" (I.D.) flex-type conduit with PVC coating which .
extended 9" on the fire side and 20" on the cold side.
PENE. C & D Consisted of 4-7/8" (I.D.),12" long flex-type conduit with PVC coating attached to 5" (I.D. continuous solid conduit at 15" above the cold side of the slab. The continuous solid conduit extended 9" on the
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fire side.
PENE. E.
Consisted of 5" (I.D.) continuous solid conduit which extended 9" on the fire side and 15" on the cold side. . -
PENE: F
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Consisted of a 4-7/8" (I.D.), 12" long flex-type conduit with PVC coating attached to 5" (I.D.) continuous solid conduit at 15" above the cold side. The continuous rigid conduit extended 9" on the fire side.
PENE. G & H Consisted of 9" x 141" s x 12" deep rectangular opening (each) with 1-2" (I.D.)
l solid continuous conduit (each) which extended through the opening and turned 900 on both the top (to 20" above slab) and bottom (to 9" below slab) l of the slab. A CORPORATION OF Tile TRANSCO GROUP s.
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TRANSCO PRODUCTS INC. Test Report #TR-161 Page 3 of 23 ,
C.) SPECIMEN CONFIGURATION:
Each conduit contained IEEE-383 rated electrical cable with Hypalon jacket as described as follows:
Penetrations A thru 2 pcs. 3/C - 1/0 F (Cable Power loading for Cable (Okonite) (@each conduig)ea 1.6231 in, . )............. 3.2462 in.2 4 pes. 12/C-#14 Control Cable (Okonite) (@ .6013 in.2 ea.)............ 2.4052 in.2
.. 45 pcs. IPR #16TW Instrumentation Cable (Samuel Moore)(@ .0621 in.2ea.).2.7945 in.2 Total Loading... 8.4459 in.4 Based on 5" diameter (I.D.) solid conduit (Pene. E) 0 19.64 in.2, total loading
. equals 43%_
Based on #4 /8" diameter (I.D.) flex conduit (Pene. A,B,C.D,P) @ 18.67 in.2, total
, loading equals 45.24%
Penetrations C and H (Cable Loading for each Conduit) 1 pc. of 12/C - #14 Control Cable (Okonite) (@ .6013 in.2 ea.)............... 6013 in.
13 pcs. of IPR - #16 TW Instrumentation Cable (Samuel Moore)(@ . 0621 in.2ea.). 8073 in.
Total Loading........ 1.4086 in.
Based on 2" diameter (I.D.) conduit @ 3.142 in.2, total loading equals 44'.83% -
All cables penetrated through the conduit sleeves l' on the exposed side of slab, l' through the sleeves, and 3' on the unexposed side of slab, for a total length of 5'.
Cables weresecured on the unexposed side of slab only using a steel frame and steel wire. The conduits in Pene. G and H were welded in place @ the unexposed side of slab. The cables and conduit were not secured on the exposed side of slab. All cable ends on the unex, posed side of slab were sealed with caulking compound in compliance with IEEE-634.
One conduit (P.ene. E) contained a P-Line (pull rope used for cable pulls) which passed continuously through the conduit out of both the fire and cold side ends of the conduit.
The outer surface of the flex conduits in Penetrations B and C vere taped with 3M #27 Tape to seal of f most of the PVC coating on the flex conduits. This was done on the unexposed side of these penetrations only.
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, A CORPORATION OF THE TRANSCO GROUP
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TRANSCO PRODUCTS INC. Test Report #TR-161 I Page 4 of 23 ;
1 D.) SEAL INSTALLATION: ,,
U.S. Cypsum CT Thermafiber was the only damming material used for this test, and was used and left-in-place in all penetrations. 4" of CT Thermafiber was used in Penetration F and the 2" conduit in Penetration H; 6" of CT Thermafiber was used in Penetration A,B,C,D,E; 5".of CT Thermafiber was used in Penetrations G and H; and
.. 2" CT Thermafiber was used in the 2" conduit in Penetration C. The CT Thermafiber was premeasured to these dimensions and then stuffed into the penetration and between the cables back far enough to allow the installation of the seal material so that the seal material, when installed, would end up flush with the top of the penetration. Damming measurements made for the 2" conduit penetrations (in .
Penetrations C and H) were made from the opening of the conduit along the back of the conduit (the long radius of the conduit). Also, these 2" conduits did not have any straight section where the seals were installed. ,
The dry #TCO-001 Cement was mixed with water in a large plastic bucket using a small e1~ectric drill motor equipped with a paddle mixer. Material was installed by hand and using a cartridgeless caulking gun. The #TCO-002 Medium Density Silicone was hand mixed (1:1 mixing ratio by weight) in a small plastic bucket using an electric drill motor equipped with a paddle mixer, and was installed by hand. The #TCO-007 S,ilicone Adhesive, supplied in tubes, was installed using a caulking gun. When installing the seal material between cables, the cables were moved by hand to allow the material to flow between the cables. The CT Cypsum was mixed to between a 3-1/2'A and 6-1/2" slump. CT Gypsum was installed to a fill depth of 2" in Penetrations A thru E, and Penetrations C,H, and the conduit in Penetration H had a 5" fill depth.
. A COPPORATION OF THE TRANSCO GROUP
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TR'ANSCO PRODUCTS INC. Test Report frR-161 ~
Page 5 of 23 .
D.) SEAL INSTALLATION (cont'd):
The iTCO-002 Medium Density Silicone was installed to a fill depth of 7" in the conduit in Penetration C. 'Ihe #TCO-007 Silicone Adhesive was installed to a fill
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depth of 1" in Penetration F. All seal material was installed flush with the top of the penetration except in Penetration H where the CT Gypsum (5" thick) was installed flush with the bottom of the penetration. All conduit ends were sealed on both the expo. sed and unexposed sides of the slab.
Penetrction G and H were tested to provide test data on cracks in CT Cypsum. The CT Cypsum in each penetration was cracked 1/4" vide x 14 " wide long x full depth . -
of CT Gypsum (approximately 5" thick) to demonstrate that a 1/4" wide straight through crack (straight through to CT Thermafiber damming) could pass the 3 hour3.472222e-5 days <br />8.333333e-4 hours <br />4.960317e-6 weeks <br />1.1415e-6 months <br />
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fire test and subsequent hose stream tests. Because the 5" CT Cypsum/4" CT Thermafiber seal configuration is used in wall penetrations as well as floor penetrations, this seal configuration was tested in both directions to demonstrate a symmetrical seal (CT Cypsum flush with top of slab in Penetration C, and CT Cypsum flush with bottom of slab in Penetration H). . .
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i l . A CORPORATION OF THE TRANSCO GROUP l .
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- Test Rzport #TR-161 TRANSCO PRODUCTS INC. Page 6 of 23 I E.) THERMOCOUPLES: ,,
Thermocouples were mounted to the test specimen to gather temperature data throughout the test at 5 minute intervals for the first 2 hours2.314815e-5 days <br />5.555556e-4 hours <br />3.306878e-6 weeks <br />7.61e-7 months <br /> and at 10 minute intervals for the remaining hour (per IEEE-634). Temperatures were recorded for the seal surface and seal / sleeve interface on the unexposed side of the slab for each penetration. Thermocouples were also placed at the point the continuous con-duits penetrated the tinexposed side of the slab (Penes. A thru F) and where the
. continuous conduits penetrated the unexposed side of the seal surface (Penes. C6H).
All nnexposed side seal surface thermocouples were pushed slightly into the seal surf ace to prevent contact' with ambient air temperatures. Thermocouples used for monitoring cable temperatures on the unexposed side were mounted so that the'ir tips were also positioned slightly below the seal surf ace.
A therm 6 couple was also placed over the k" wide crack in the CT Gypsum surf ace in Penetration G (@ unexposed side). This thermocouple was not in contact with any seal surface,hJt was positioned over the k" crack area at slightly below the surrounding CT Cypsum surface leve'l. to monitor the air temperature coming through the crack areakAnotherthermacouplewasplacedontheCTThermafiberdammingmaterialover theareawheretheN,"widecrackintheCTGypsumexistedinPenetrationH(@un-exposed side).
The thermocouples used in this test along with final temperature readings are as follows (temperature data for the entire test can be found in Section "H" of this report):
. A CORPORATION OF Tile TRANSCO GROUP
Test Raport #TR-161 -
TRANSCO PRODUCTS INC. Page 7 of 23 I
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l KEY: (a) = 3/C-1/0 Power Cable (Okonite)
(b) = 12/C-#14 Control Cable-(Okonit'e)
(c) = IPR #16 TW Instrumentation Cable (Samuel Moore)
T/C# Description (all unexposed side thermocouples) Final Temperature ( F) 1 Pene. H Seal Surface Over Crack Area 84 (143 high) 2 Pene. H Seal Surface 96 (129 high)
. 3 Pene. H Conduit / Seal Exit Interface 272 0 4 Pene. H Seal Interface 120 5 Pene. G Seal Surface 81*
6 Pene. C Seal Surface 118 7 Pene. C k" Wide CT Gypsum Crack 80
-8 Pene. G Conduit / Seal Exit Interface 205 9 Pene. G Seal Interface 101*
10 Pene. E Seal Surface 129 11 Pene. E Power Cable (a) 159 .
12 Pene. E Control Cable (b) 133 13 Pene. E Instrument Cable (c) 120 '
14 Pene. E Seal Interface 135 15 Pene. E Conduit / Slab Exit Interface 227 ~
16 Pene. F Seal Surface ~
88 17 Pene. F Power Cable (a) 92 .. .
18 Pene. F Centrol Cable (b) 88
, 19 Pene. F Instrument Cable (c) 88 0 20 Pene. F Seal Interface 79 21 Pene. F Conduit / Slab Exit Interface 230 .
22 Pene. C Seal Surface 93 23 Pene. C Power Cable (a) 94*
24 Pene. C Control Cable (b) 88 25 Pene. C Instrument Cable (c) 93, .
26 Pene. C Seal Interface 89 . .
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- 27 Pene. C Conduit / Slab Exit Interface 234 28 Pene. D Seal' Surface 89 29 Pene. D Power Cable (a) 101 30 Pene. D Control Cable (b) 92 31 Pene. D Instrument Cable (c) 88 i 32 Pene. D Seal Interface . 86 l 33 Pene. D Conduit / Slab Exit Interface 241 34 Pene. B Seal Surface 102 35 Pene. B Power Cable (a) 120 36 Pene. B Control Cable (b) 104 37 Pene. B Instrument Cable (c) 104*
38 Pene. B Seal Interface 102 39 Pene. B Conduit / Slab Exit Interf ace 166 (169 'high) 40 Pene. A Seal Surface 107*
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. A CORPORATION OF THE TRANSCO OROUP
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- ' "* Test Rzport ITR-161 .
TRANSCO PRODUCTS INC. Page 8 of 23 -
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T/C# Description (all unexposed side thermocouples) Final Temperature ( F) 41 Pene. A Power Cable (a) 125 -
42 Pene. A Control Cable (b) 103 43 Pene. A Instrument Cable (c) 106 44 Pene. A Seal Surface 106 45 Pene. A Conduit / Slab Exit Interface 230 46 Pene. H (Conduit) Seal Surface 89
- 47 Pene. H (Conduit) Control Cable (b) 91 48 Pene. H (Conduit) Instrument Cable (c) 93 49 Pene. H (Conduit) Seal Intsrface 92 50 Pene. G (Conduit) Seal Surface 91" .
51 Pene. G (Co'nduit) " Control Cable (b) 85 52 Pene. G (Conduit) Instrument Cable (c) 91 53 Pene. G (Conduit) Seal Interf ace 87 l .
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, A CORPORATION OF THE TRANSCO GROUP
"* * < Test Raport #TR-161 .
TRANSCO PRODUCTS INC. page 9 of 23 .
i F.) FURNACE:
The furnace used for this test measures approximately 4' X 4' at.its support points. The furnace atmosphere is controlled by 4 self-igniting burners which I burn natural gas and operate in unison. The burners are automatically controlled
- from the control room. ' As the furnace atmosphere temperatures are moni-4 tored in the control room, automatic adjustments can be made to account for
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- varying amountsof fuel contribution throughout the test.
1 4
The furnace atmosphere temperatures are monitored by three thermocouples locatte i
12" below the test slab. 'these temperatures are individually printed on a strip l
chart and automatica'11y averaged and compared to the AS'DI E119 time / temperature curve by computer. - -
The furnace draf t was controlled during the test to an average pres.sure of ap-
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proximate 1y negative .08" water throughout t'he test. Due to adjustments of fuel and draft during the test (in order to follow the ASTM E119 time / temper-l .
ature curve), br,ief' periods of positive pressure were introduced into the fur-nace.
G ) TEST RECORD:
The fire test was conducted for 3 hours3.472222e-5 days <br />8.333333e-4 hours <br />4.960317e-6 weeks <br />1.1415e-6 months <br /> in accordance with the ASTM E119 time /
temperature curve. Throughout the test, an even blanket of flame covered the I plan area of the furnace. All combustible materials located on the exposed sur-l face of the slab (ie, cable jacketing material) quickly ignited and continued i
to char for the duration of the test.
A CORPORATION OF THE TRANSCO GROUP f.
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a: .a Test Rcport #TR-161 -
TRANSCO PRODUCTS INC. PIge 10 of 23 ',
Three (3) separate hose stream tests were conducted on the specimen upon conclusion of the 3 hour3.472222e-5 days <br />8.333333e-4 hours <br />4.960317e-6 weeks <br />1.1415e-6 months <br /> fire test. Water did not project from the unexposed surface of the seals during any of the 24 second long exposures, except on Penetration G, where water did' pass through the premade 1/4" through crack in the CT Gypsum during the third and final hose stream test (ASTM E119 Solid Hose Stream) . Penetration G did pass the first two hose stream tests (IEEE-634
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and ANI). The hose stream tests conducted were as follows:
a.) IEEE-634: 75 psi hose stream delivered through a 1-1/2" hose equipped with
, a fog nozzle set at a discharge angle of 30 from a distance of 10 feet.
b.) ANI: Same as above except that the nozzle was set at a discharge angle .
of 15*.
c.) ASTM E119: 30 psi of.d stream delivered through a 2-1/2" hose equipped with a 1-1/8" tip set on a playpipe from a distance of 20 feet.
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7 H.) TEMPERATURE DATA:
The fo!!owing sheets identify both complete furnace atmosphere and unexposed surface temperatures throughout the 3 hour3.472222e-5 days <br />8.333333e-4 hours <br />4.960317e-6 weeks <br />1.1415e-6 months <br /> fire test.
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e r. . . ,. Test Raport #TR-161 ,
, Page 11 of 23
. . CR5549 - TRANSCO TR-161 - 11/20/84 ,
TEST COMMENTS
'0:10:00 LIGHT- SMOKE HOTED FROM BOTTOM COUPLING IH PIPE PEN B.
0:10:00 LIGHT SMOKE NOTED FROM PIPE IN PEH G.
8:10:00 LIGHT SMOKE NOTED FROM PIPE IN PEN H.
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9:10:00 BUBBLING LIQUID HOTED AT COUPLING IN PIPE IN PEH G.
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0:15:00 LIGHT SMOKE NOTED FROM TOP OF PIPE IN PEH F.
0:15:00 LIGHT SMOKE NOTED FROM 2 HD C'0UPLING IH PEH E.
8:20:00 LIGHT SMOKE NOTED IN GAP IN PEN G.
9:22:00 LIGHT SMOKE NOTED FROM EDTTOM COUPLING IN PEH B.
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0:50:00 SMOKE NO LONGER HOTED FROM TEST PENS.
1:05:00 WATER HOTED ALONG OUTER SIDES OF THE 30 X 30 OPENING ,
HOSE STREAM TESTS:
H0 llATER PROJECTED EEYOND THE UNEXPOSED SURFACE DURING IEEE-634 HOSE STREAM TEST FOR 24 SEC. IN ALL PEN.
HQ WATER PROJECTED BEYOND THE UNE : POSED SURFACE DURING AHI HOSE STREAM .
TEST FOR 24 SEC. IN ALL PEN.
N0 WATER PROJECTED BE, YOND THE UNE); POSED SURFACE DURING ASTM E-119 $0SE STREAM TEST FOR 24 SEC IN ALL PEN. EXCEPT IN PEN. G llHERE HATER '
DID PROJECT LEYOND THE UNEXPOSED SURFACE THROUGH THE PREMADE CAP.
H0TES:
DRAFT RUN AT .08 NEG.
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' Test R2part #TR-161 Page 12 cf 23 .
CR5549 - TRANSCO TR-161 - 11/20/84 FURNACE ATMOSPHERE TEMPERATURE (DEG. F)
TEST TIME, FURHACE ASTM E119 VARI ATION- FROM .
Hr: Mi n TEMP. TEMP. d5TM TEMP.
F F F 8:00 76 68 8 0:05 1003 1000 3 0:30 1333 1300 33 0:15 1385 1399 -14 8:20 1460 1462 -2 0:25 1504 1510 -6 0:30 1547 1550 -3 0:35 1576 1584 -8 J
0:40 1604 1613 -9 0:45 1640 1638 2 0:50 1669 1661 8 .
8:55 1683 1681 2 1:00 , 1683 1700 -17 1:05 1807 1718 89 ,
1:10. 1728 1735 -7
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1:15 1735 1750 -15 .".'.
1:20 1772 1765 7 1:25 1782 1779 3 1:30 1936, 1792 144
. . 1:35
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1799 1804 -5 1:40 1812 1815 -3 1: 45 1824 1826 -2 1:50 1835 1835 -
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1:55 . 1842 1843 -1 2:00 1848 1850 -2 2:10 1860 1862 -2 2:20 , 1874 1875 -1 2:30 1874 1888 -14 2:40 1890 1900 -10 2:50 1911 1912 -1 3:00 1914 1925 -11 AREA UNDER CURVE = 295275 DEG. F-MilluTES AREA UllDER ASTM E119 CURVE = 294600 DEG. F-M1HUTES VARI ATIOla FROM ASTM CURVE = 00.2291 %
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.a e,..,, Test Rsport #IR-161 CR5549 - TRANSCO TR-161 - 11/20/84 Page 13 cf 23 THERMOCOUPLE REFEREHCE CHART I i
FRAME PRINT THERM 0 COUPLE THERMDCOUPLE ;
HO. NO. HO. LOCATION 9 1 1 PEN H Seal Surface Over Crack Area 9 2 2 PEN H Seal Surface 9 3 3 PEN H Conduit / Seal Exit Interface 9 5 4 PEN H Seal Interface 9' 6 5 PEN C Seal Surface 9 7 6 PEN G Seal Surface ,
9 8 7 PEH G k," Wide CT Gypsum Crack 9 9 8 PEN G Conduit / Seal Exit Interf ace .
9 18 ..
9 PEN G Seal Interface 11 1 . 10 PEN E Seal Surface 11 2 11 PEN E Power Cable (a) ,
11 3 12 PEN E Control Cable (b) 11 4 13 PEN E Instrument Cable (c) -
11 5 14 PEN E Seal Interface .
11 6 ,,
15 PEN E Conduit / Slab Exit Interf ace 11 7 16 PEH F Seal Surface .
11 8 17 PEH F Power Cable (a) . , ,,-
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4 11 .
9 18 PEN F Control Cable (b) l 11 10 19 PEN F Instrument Cable (c) 11 11 20 PEN F Seal Interface 11 12 21 PEH F Conduit / Slab Exit Interface 12.- 1 22 PEN C Seal Surface 12 2 23 PEH C Power Cable (a) 12 3 24 PEN C Control Cable (b) 12 4 25 PEN C Instrument Cable (c) * -
PEN C Seal Interf ace 12 5 26 12 6 27 PEN C Conduit / Slab Exit Interface 12 7 28 PEH D Seal Surface 12 8 29 PEH D Power Cable (a) 12 9 30 PEN D Control Cable (b) 12 10 31 PEH D Instrument Cable (c) 12 11 32 PEN D Seal Interface 12 12 33 PEH D Conduit / Slab Exit Interf ace 13 1 34 PEH E Seal Surface
! 13 2 35 PEH E Power Cable (a) 13 3 36 PEN B Control Cable (b) 13 4 37 PEH E Instrument Cable (c) 13 5 38 PEN E Seal Interface 13 6 39 PEN E, Conduit / Slab Exit Interface 13 7 40 PEH A Seal Surface 13 8 41 PEH A Power Cable (a)
. 13 9 42 PEN A Control Cable (b) l
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Test Rsport #TR-161 Page 14 of 23 -
~ .
. 4 13 10 43 PEN A InsEruinMable (c) ,
i 13 11 ,
. 44 PEH R Seal Interface 13 12 45 PEN R Conduit / Slab Exit Interface 14 1 46 PEH H (Conduit) Seal Surface 14 2 47 PEN H (Conduit) Control Cable (b)
. 14 3 48 PEN H (Conduit) Instrument Cable (c) 14 4 49 PEN H (Conduit) Seal Interface 14 5 50 PEN G (Conduit) Seal Surface 14 6 51 PEN C (Conduit) Control Cable (b) 14 7 - -
52 PEH c (Conduit) Instrument Cable (c) 14 8 53 PEH G (Conduit) Seal Interf ace S
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Test R2 port #TR-161 Page 15 of 23
. . CR5549 - TRANSCO TR-161 - 11/20/84 .
TEST SPECIMEN THERMOCOUPLE READ 1 HGS (DEC. F)
TEST TIME. T/C HO.
Hr: Min 1 2 3 4 5 6 0:00 74 74 75 78 70 ,
71 0:05 74 74 99 78 70 71 0:10 75 74 204 79 70 71 0:15 12b 100 210 98 70 71 0:20 140 ' 122 211 'o6 70 71
.. 0:25 143 129 202 112 70 71 0:30 108 91 195 86 70 71 0:35 98 83 19,4 83 70 71 0:40 91- 79 194 80 . 70 71 0:45 88 77 196 80 70 71 0:50 88 76 200 80 7C 71 0:55 100 78 204 82 70 71 1:00 91 78 207 81 70 72 .
1:05 122 85 209 89 70 72 1:10 110 -
95 209 91 70 73 1:15 99 82 209 88 70 74 1:20 96 81 209 -
93 70 74 .
~
1:25 97 82 210 95 -
71 75 1:30 89 79 211 96 71 77 1:35 85 76 212 97 71 78 1: 40 82 79 214 97 71 79 1:45' 81 77 214 100 72 81 1:50 80 77 217 101 72 83 1:55 80 77 218 101 72 85 .
2:00 79 77 219 102 73 88 -
2:10 79' 82 224 107 74 93 2:20 SO 87 230 110 75 99 2:30 81 90 236 113 76 104 2: 40 82 92 248 116 78 109 2:50 83 94 259 118 79 114 3:00 84 96 272 120 31 118 o
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Na , . Test Riport #TR-161
.
- CR5549 - TRANSCO TR-161 - 11/20/84 ,
TEST SPECIMEN THERM 0 COUPLE READINGS (DEC. F)
~
TEST TIME, T/C NO. ,
Hr : Min 7 8 9 10 11 12
~
0:00 66 74 74 73 75 . 74 0:05 66 75 75 73 75 74 0:10 65 87 75 73 75 74 0:15 66 140 75 73 75 74 0:20 67 149 75 73 75 74
.. 8:25 67 149 75 73 76 75' 0:30 66 154 74 73 76 74 8:35 66 168 74 74 77 75 0:40 67 169 74 74 78 75 0:45 67 171 ~74 74 79 76 0:50 67 173 74 75 81 77 0:55 67 175 75 76 83 77 1:00 67 176 75 77 86 79 1:05 67 178 75 79 89 80 .
1:10 68 179 76 SO 91 81 1:15 68 179 76 82 94 83 1:20 68 177 77 - 84 97 -
85 ..-
"~
1:25 (1 178 77 86 100 83 1:30 69 178 78 88 104 90 1:35 69 180 79 91 107 92 1:40 69 181 80 94 111 95 1:45 70 183 81 97 113 99 1:50 71 184 82 100 117 102 1:55 70 186 83 103 121 104 2:00 71 187 84 105 124 106 2:10 73' 191 87 110 131 112 2:20 74 194 89 115 138 117 2:30 75 199 92 119 145 121 2: 40 76 201 95 123 150 126 2:50 78 203 98 126 155 123 3:00 80 205 101 129 159 133 6
O
_ _ . - _. . . _ . . . _ .._s _ ,
i 4
y.. . , . Test Rzport #TR-161 E" I
. . CR5549 - TRANSCO TR-161 -
11/20/84 ,
TEST SPECIMEH THERMOCOUPLE READ 1 HGS (DEG. F)
TEST TIME, T/C HO.
Hr: Min 13 14 15 16 17 18 i
0:00 74 74 78 74 74 . 74 0:05 74 75 78 74 74 74 .
9:10 74 75 80 74. 74 74 0:15 75 75 84 74 74 74 0:20 75
- 75 87 74 74 74
- 0:25 75 75 92 74 74 74' 0:30 75 76 97 74 74 74 0:35 76 76 103 74 74 74 0:40 76 77 110 75 74 74 0: 45 ,
77 78 118 74 74 74 0:50 77 79 126 75 75 74
. 9:55 78 80 132 75 75 75 1:00 79 82 136 75 75 75 -
1:05 81 84 140 75 75 75 -
1:10 82 86 144 75 75 75 i
1:15 83 88 146 75 76 75 1:20 85 90 149 - 75 76 -
75 ._ ;
1:25 87 93 155 76 77 76 1:30 89 96 158 76 77 76 1:35 90 97 162 76 77 76 1:40 93 100 169 77 78 77 1: 45 96 104 175 77 79 ,
77 1:50 99 108 180 78 80 78
- 1
- 55 100 111 183 78 80 78 -
' ^
2:00 102 112 185 78 8'8 79 2:10 107' 120 194 80 82 80 2:20 lie 123 203 81 84 82 2:30 113 126 208 82 86 83 2: 40 117 130 217 84 88 85 2:50 117 132 218 86 39 86 3:00 120 135 227 88 92 88 i
e i
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CIh..,, Test Rzport BTR-161 l
CR5549 - TRRHSCO TR-161 - 11/20/84 K82 8 f 23 I
TEST SPECIMEN THERMOCOUPLE READINGS (DEG". F)
~
TEST TIME, T/C NO.
Hr: Min 19 20 21 22 23 24 0:00 74 73 77 72 72 ,
72 0:05 74 73 78 72 72 72
~ "
0:10 74 74 79 72 72 72 0:15 74 74 83 72 72 72 0:20 74 74 84 72 72 72 0:25 74 75 87 72 72 72-0:30 74 75 91 72 72 72 0:35 74 76 100 73 72 72 0: 40 74- 76 111 73 72 72 0:45 74 76 120 73 73 72
~
0:50 74 76 125 73 73 ,
73 0:55 75 77 130 73 73 73 1:00 75 77 134 74 73 73 .
1:05 75 77 139 74 74 73 1:10 75 . 78 144 74 74 73 1:15 75 78 147 75 74 74 1:20 76 78 154 75 74 . 74 1:25 76 79 161 76 75 74 1:30 77 79 166 76 76 75 1:35 77 79 168 77 76 75 1: 40 77 78 173 78 77 75 1:45' 78 78 177 78 77 76 1:50 79 77 180 79 78 77 1:55 79 78 185 80 79 77 2:00 79 76 188 80 7'9 77 -
2:10 81* 76 196 82 31 79 2:20 82 77 202 84 83 80 2:30 84 77 207 86 86 82 2:40 85 78 213 89 89 84 2:50 86 78 223 91 92 87 3:00 88 79 230 93 94 88 l
l l
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Test Rrport #TR-161 en . .
Pegt 19 of 23 -
4
+ * - CR5549 - TRANSCO TR-161 - 11/20/84 .
TEST SPECIMEN THERMOCOUPLE READINGS (DEG. F)
TEST TIME, T/C HO.
! H.-: M i n 25 - 26 27 28 29 30 0:00 73 72 77 73 73 . 73 l 73 73 0:05 73 72 79 73 0:10 73 72 84 73 73 73 0:15 73 72 85 73 73 73 0:20 73 .
5 72 88 73 73 73
- 0:25 73 72 89 73 73 73' 0:30 73 73 91 73 73 73 9:35 74 73 96 74 73 73 0:40 74. 73 102 74 73 73 6: 45 74 73 110 73 73 73 0:50 74 73 118 74 73 73 0:55 74 73 126 73 74 73 i 1:00 74 74 131 76 74 73 1:05 74 74 135 74 74 73 i
4 1:10 74 74 140 75 75 73 1:15 75 75 146 75 75 74 I
1:20 75 75 149 76 76 -
74 , , ,
1:25 75 75 154 76 76 74
- 1
- 30 76 76 160 76 77 75 1:35 76 76 165 76 77 75 1: 40 77 77 171 80 78 76 1: 45- 78 77 176 84 80 76 1:50 79 78 180 82 81 77 1:55 79 78 165 81 8,2 ,
78 -
2:00 79 78 189 80 83 78
- 2
- 10 81" 80 192 86 85 80 2:20 84 82 200 88 88 82 2:30 86 83 211 86 91 84 2: 40 88 E5 215 87 95 87 2:50 90 87 225 87 98 29 I
3:00 93 89 234 89 101 92 l
9
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Test Rzport ,#TR-161 Page 20 of 23 -
. . CR5549 - TRANSCO TR-161 - 11/20/84 ,
TEST SPECIMEN THERMOCOUPLE READ 1 HGS (DEG. F)
TEST TIME, T/C HO.
Hr: Min 31 32 33 34 35 36 0:00 72 71 78 71 73 ,
72 0:05 72 72 78 72 73 72 0:10 72 72 79 72 73 72 0:15 72 72 83 71 73 72 0:20 72 72 90 71 73 72
- 0:25 72 72. 97 71 73 72' 0:30 72 72 104 71 73 72 0:35 72. 71 111 72 73 72 0: 40 72 . 72 123 72 74 73 0: 45 72 71 133 72 74 73 0:50 72 72 145 72 74 73 0:55 72 72 152 73 75 74 1:00 72 72 157 74 77 75 ,
1:05 72 - 72 161 74 78 75 .
1:10 72 72 164 76 80 77 1:15 72 72 166 77 82 78 1:20 73 72 168 - 79 85 .
- 79 ,,
1:25 73 73 170 80 87 81 1:30 73 73 173 82 89 83 1:35 73 73 179 83 91 84 1:40~ 74 74 184 84 93 85 1: 45 75 75 190 85 95 86
. 1:50 75 75 192 87 97 88 1:55 76 75 193 87 99 89 -
2:00 76 75 196 88 10'1 90
, 2:10 78' 77 202 90 104 92 i 2:20 80 79 208 93 108 95 1
2:30 82 81 216 96 112 98 2:40 84 83 225 98 115 100 2:50 -
86 84 234 100 118 102 3:00 80 86 241 102 120 104
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Test Rapsrt #TR-3 6,1 CR5549 - TRANSCO TR-161 - 11/20/84 Pags.21 cf 23
~
f TEST SPEC 1MEH THERMOCOUPLE READINGS (DEG. F) l l
TEST. TIME,, T/C HO. _
Hr: Min 37 38 39 40 41 42 0:00 72 72 78 73 74 ,
73 0:05 73 72 78 73 74 73 0:10 73 72 78 73 74 73 0:15 73 72 80 73 74 73 0:20 73 72 94 73 74 73
- 0:25 73 72 101 73 74 73 0:30 .73 72 104 73 74 73
~
0:35 73 73 106 73 74 73 0: 40 74' 73 116 74 75 74 0:45 74 73 128 74 75 73 0:50 74 73 129 75 76 74 0:55 75 74 135 75 77 74 1:00 76 75 140 76 78 74 -
1:05 77 - 75 14'2 76 79 75 ,
1:10 78 77 144 77 30 75 1:15 79 78 143 78 82 76 1:20 81 80 148 - 79 33 . 76 ;,
1:25 82 81 147 80 85 77 1:30 84 83 149 81 36 78 1:35 85 84 151 82 38 78 1: 40 87 86 152 83 89 80 1: 45 88 87 144 85 91 81 1:50 89 88 156 87 94 82 1:55 91 88 154 87 97 83
~
l 2:00 92 90 159 90 9'9 85
^
2:10 95 92 150 93 104 89 2:20 98 94 151 97 109 93 2:30 100 97 164 100 113 95
,2: 40 101 99 169 104 117 98 2:50 102 101 165 105 121 101 3:00 104 102 166 107 125 103 J
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Tant Raport #TR-161 c . . , ,
- CR5549 - TRANSCO TR-161 -
11/20/84 ,
TEST SPECIMEN THERMOCOUPLE READ 1 HGS (DEG. F)
TEST TIME, T/C HO.
43 44 45 46 47 48 Hr: Min 73 71 79 72 72 , 73 0:00 73 73 79 72 71 73
! 0:05 73 73 80 72 72 73 0:10 73 73 83 72 72 73 0:15 73 5 74 88 73 73 74 0:20 6:25 73 74 95 73 73 75' 73 74 102 73 74 76 0:30 73 74 108 74 75 77 8:35 74 75 120 75 76 78 0: 40 74 75 127 74 76 79 0:45 74 75 137 76 77 79 0:50 75 76 145 76 78 80 0:55 #
- 75 76 150 76 78 80 1:00 76 77 .o 151 76 78 81 1:05 ,
76 77 152 76 78 81 1:10 .
78 156 79 79 81 1:15 77 78 78 158 - 78 79 -
82 ,
1:20 _
79 160 73 80 82 1:25 79 79 80 164 78 80 83 1:30 80 E0 169 79 S1 83 1:35 62 81 172 80 82 84 1:40 84 83 178 83 83 85 1:45 86 85 180 82 S4 86 1:50 88 86 182 80 84 87 1:55 '
- 89. 87 188 82 8'4 87 -
2:00 93' 90 194 83 86 88 2:10 96 94 199 87 37 90 2:20 -
99 98 207 87 88 91 2:30 181 101 215 89 90 92 2:40 ,
103 103 222 88 90 92 2:50 106 106 230 89 91, . 93 3:00 e
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Test Rsport #TR-161
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a e CR5549 - TRANSCO TR-161 - 11/20/84 I TEST SPECIMEN THERMOCOUPLE READINGS (DEC. F)
T/C HO.
TEST TIME , ' '
50 51 52 53 He: Min 49 73 76 73 73 .
0:00 72 74 76 73 73 9:05 73 ~
74 76 74 73 0:10 73 74 75 74 73 0:15 73 74 76 74 73 0:20 73 ,
74 76 74 74 6:25 74 74 76 74 73 0:30 75 74 76 74 74 8:35 76 75 76 75 74 l 0:40 77' 75 77 75 74 0:45 78 76 77 76 75 0:50 79
- 77 77 77 75 0:55 79
- 77 78 78 76 1:00 80 78 78 79 76 .
80 1:05 '
79 79 80 77 1:10 80
- 80 79 81 78 I 1:15 81 81 80 81 79 -
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82 80 82 79 1:25 81 82 82 81 83 79 1:30 82 83 81 83 79 1:35 83 83 81 84 81 1: 40 84 84 81 85 82 1:4'5 85 85 82 86 83 1:50 86 86 82 86 82 1:55 ' '
86 86 82 86 82 .
l 2:00 87* 86 82 87 83 j
2:10 88 87 83 88 85 l 2:20 90 88 83 89 86 l 2:30 89 84 89 86 2: 40 91 90 84 90 87 2:50 91 92 91 85 91 87 3:00 6
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<e Mr. D. Elias ,
Commonwealth Edison Company P. O. Box 767 Chicago, IL 60690 Re: TRANSCO PRODUCTS, INC.
FIRE TEST REPORTS NOS. TR-159 AND TR-161
Dear Mr. Elias:
A fire test was conducted on November 14, 1984 on simulated electrical openings in a vall assembly, and on November 20, 1984 on simulated electrical openings in a floor assembly. The tests were conducted for the purposes of qualifying the fire batrier penetration seals in ,
accordance with the IEF.E-634 Standard. The fire tests were witnessed by M&MPC representatives and preliminary copies of the captioned reports were reviewed in accordance with IEEE-634 Standard acceptance criteria.
We find the fire tests satisfactorfly, meet the IEEE-634 test acceptance ,
criteria, except as indicated below. A final review and comment on the certified test reports will be provided when the reports are submitted.
TEST REPORT TR-159
~
This test report describes a three hour fire and subsequent hose stream l test for a vall assembly using Transco No. TCO-001 Cement (US Cypsum :
, fire code CT Cypsum cement). The test slab measured 48"x 48"x12" thick.
l A total of nine, 5" diameter steel conduits were installed within the -
test slab. As a result of our review of this test and test report we find that penetrations A, C, E. C, E and I satisf actorily meet the
' ~
f acceptance criteria. Penetrations B, F and D meet the acceptance ;
criteria to the extent that the penetration seals did not allow the passage of hot gases or flames through the barrier or the burning of i cable installations on the unexposed side. Penetrations B F and D did not satisfactorily pass the temperature criteria for conductor ,
temperatures on the unexposed surface.
.- i The IEEE-634 hose streas test ANI hose stream test and solid hose test ,
was conducted on all penetrations with satisf actory results.
In summary, the test results show that the installation of 2" of CT i gypsum with 6" CT thermafibre is not an acceptable installation where the seal is applied at the vall. The test does show that the fire penetration seal configuration of 2" of gypsum and 6" of CT thermafibre is acceptable for conduit end seals, where both ends of the conduit are ,
sealed with the same configuration. :
- , c.. a. o s.-.u. ca... rw wa Imanit 6MM Telenhnne H? MR4000
.. . M&M Protection Consultants Mr. D. Elias December 10, 1984 .
Page Two TEST REPORT NO. TR-161 s We find penetrntions A through F acceptable throughout the Byron ,
plant in both 3-hour floor assemblies as well as 3-hour fire walls. -
These penetrations performed in an acceptable manner in the configurations tested.
. . . Penetrations C and H have passed the temperature criteria on clie' ~
unexposed side as well as the IEEE-634 hose stream test and the ANI hose stream test. However, when the solid stream test was performed on these seals, penetration G did project water on the unexposed side and penetration H experienced a slight bulging of the seal. It should not
'be used in an area (such as: Fuel Handling Building) where solid stream hose nozzles are present.
Penetrations C and B both contained a 2" conduit. Conduit end seals were provided in each penetration. Penetration G contained 7" of silicone foam and 2" of CT thermafibre. Conduit H contained 5" of --
gypsum and 4" of CT thermafibre. Both penetration conduits contained a bend with no straight sections. The seals within the conduit were placed.within the bend area.
~
We would not recommend that penetration assemblies utilized in the plant be of any other configuration that would be larger or with less sealant material than tested within these fire tests. In areas of the plant where the configuration using 2" of gypsum and 6" of CT thermafibre is applied at the wall, we would recommend the necessary repairs as -
tested be implemented. Acceptable repairs would be to install either an additional 4 inches of thermafibre or apply the acceptable floor penetration seal configuration consisting of 5" of CT gypsum and 4 inches of CT thermafibre.
Should you have.any further questions regarding our comments, please let .
me know.
Very truly yours.
R.fho R. J. Smith, Jr.
Fire Protection Consultant
/gw.
RJS/lw cc: K. A. Ainger R. C. Ward C. Diaz -
S. J. Chingo N. F. Malicki J. Mahavelich J. D. Deress .
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6N< uttantsxMWM*Wir:#AF#WP.W@ ten *se A Technical Sen ice of Marsh & McLennan December 13, 1984 Mr. D. Elias Station Nuclear Engineering Department Co==onvenith Edison Company P. O. Box 767 =>
Chicago , 11. 60690 Re: CONSTRUCT' ION TECHNICAL 1.ABORATORIES CERTIF2ED TEST REPORTS FOR TRANSCO PRODUCTS INC.
FIRE TE.STS NOS. TR159 AND TR161
Dear Mr. Elias:
This is to confirm.our review and receipt of the Construction Technical --
Laroratories certification of the fire tests conducted for Transco Products Inc., report numbers TR159 and TR161 conducted on November 14, 1984 and Neverber 20, 1984 respectively. Based upon our review, we conclude that the fire tests were conducted in accordance with the .
IEEE-634 Standard and , sttisfactorily meet the IEEE-634 Standard acceptance c,riteria as detailed in my letter of December 10, 1984.
Should you have any further questions regarding the fire tests or our
. review, please let me know. -
Very truly yours,
-l R. J. Smith, Jr Fire Protection Consultant RJS/1w cc: K. A. Ainger R.'C. Ward C. J. Diaz S. J. Chingo N. F. Malicki J. Mihovilovich J. D. Derera l
i
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E f3 M @ r M f I.3 d M d 5 'd (8 R*JM 8]l i M 8]l W l NI IM[$N4477dp'67ddf581TM A Technical Service of Marsh & McLennan April 30, 1985 Mr. D. Elias Project Engineer Commonwealth Edison Company P. O. Box 767 Chicago, Illinois 60690 Re: Transco Fire Tests TR159 & TR161
" Crack Criteria"
Dear Mr. Elias:
As a result of our witnessing and review of the above referenced fire tests and corresponding fire test report, we recommend the existing inspection " crack criteria" for the Transco Products Inc. fire penetra-tion seal configurations consisting of combination CT gypsum and CT thermafiber as tested, may be expanded as follows:
Crack Dimensions Action To Be Taken Initial Acceptance Inspection
- No further action .
- 1. Cracks less than three thirty-seconds of an necessary.
inch (3/32") in width.
- 2. Cracks three thirty- Seal not acceptable seconds of an inch (3/32") for initial acceptance -
or greater in width. Repair per Transco Products.
Inc. fire penetration seal repair procedures.
Seal Surveillance Criteria **
- 1. Cracks less than five No immediate repairs required.
thirty-seconds of an Seal is considered operable.***
inch.(5/32") in width. Seal should be placed on the surveillances or monitoring of crack to ensure crack is periodically surveyed and measured for expansion.
- " Initial Acceptance Inspection" refers to the contractors' final inspection of the penetration seal prior to turnover to Station (CECO).
- Seal Surveillance Criteria refers to station's regular seal inspec-l tion program per station procedure requirements. -
- Reference to " Operable Seal" indicates seal integrity has not been jeopardized and remains a functioning rated fire penetration seal as tested in the Qualification Fire test.
w e c, ..a. os d. Pt m r%:,..a istinnis 60606 Telenhnn,'419 Ma. Anno l
? . _ _ _ . _
M&M Protection Consultants Mr. D. Elias ;
April 30, 1985 Page 2 .
Crack Dimensions Action To Be Taken -
- 2. Cracks greater than or Seal is considered operable, equal to five thirty- however, placed on a repair seconds of an inch (5/32") schedule to be repaired per the and less than one-quarter Transco Product Inc. teal of an inch (1/4") in width. repair procedures.
- 3. Cracks greater than or Seal considered inoperable
- equal to one-quarter of Necessary repairs should be an inch in width. made and normal station procedures should dictate i
necessary action for inoperable seals.
On March 29, 1985 a meeting was held at the Braidwood Station construc-tion site to discuss the crack criteria as previously described. In addition to the aforementioned criteria recommended by M&MPC to the attendees, the following briefly summarizes the meeting events.
- 1. A summary of the purpose of the meeting and brief history regarding the subject of cracks within the CT gypsum material was provided by T. Thornley (S&L), and T. Hoff (Transco Products Inc.).
l Mr. H. Massin (Ceco-SNED) also provided input with respect to some of the history to the crack subject regarding the discussions for
~
j the LaSalle County Station with the NRC.
- 2. It was agreed to that within the Transco procedures and CECO procedures there will be no attempt to differentiate between the
. previously identified types of " cracks" such as hairline cracks, surface cracks, or through cracks. The procedures will address
" cracks" to apply to all situations.
- 3. A discussion regarding the applicability of applying an acceptance criteria limiting the length of the crack and possibly the overall
- surface area'of the crack based upon the ratio between the crack tested compared to the seal configuration dimensions was discussed.
It was concluded at this time this criteria was not be applied to i the acceptance or surveillance of the penetration seals.
- 4. The aforementioned acceptance criteria recommended by M8MPC would l
be applied to the Braidwood site only at the present time. No
- immediate action would be taken at the LaSalle County Station and l
- Reference to " inoperable" seal indicates that seal no longer remains a functioning fire penetration seal as tested and requires appropriate repairs or replacement.
l I
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M&M Protection Consultants .
Mr. D. Elias -
April 30, 1985 .
Page 3 Byron Station Unit 2, with respect to the contractors' final inspections. It was felt that Byron Station personnel did not want to change the acceptance criteria from that which was previously applied to the Unit 1 and common areas fire penetration seals. A decision regarding the Byron Station 18-month surveillance pro-cedure criteria vill be determined at a later date.
- 5. Ceco-SNED will determine whether this " crack criteria" presented, with supporting fire tests, will be submitted to the NRC for their concurrence.
- 6. During the meeting. Transco confirmed that with the exception of conduit end-seals, all seal configurations at the three sites will use a fire penetration seal configuration consisting of a minimum five inches (5") of CT gypsum with four inches (4") of CT thermafiber.
- 7. Based upon M&MPC's review of the fire tests conducted and test results which successfully tested a ceal configuration with a crack (Test Report 161) the recommended crack criteria is applicable to all areas of the plants, except where solid stream hose nozzles are provided (i.e., refuel floor) with the seal installed in a config-uration such that the CT thermafiber is installed in a direction exposed to the area in which the solid stream hose nozzles are provided. With the exception of this situation, the " crack criteria" proposed can be applied to the referenced fire penetration seal ,
configuration in all other areas.
This concludes the summary of items discussed during this meeting. By copy of this letter, meeting attendees are requested to advise this writer if the information provided does not accurately reflect and summarize the discussions. Should you have any further questions, please do not hesitate to contact me.
Ve trul yours,
- i R. J. Smith r. /4 Fire Prote ion Consultant RJS/pf cc
- J. Deress A. Nies
! C. Gray D. Contorno S. Chingo L Huff P. Hart C. Ctaz T. Meyer M. Pietraszewski j E. McVey M. Smith H. Massin D. Thornley P. Hoffman R. Ward l J. Phelan M. Teras ,
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, - - -. - - -..---,n- , , ~ . , , . , ,
UNITED STATES y- , 7.
NUCLEAR REGULATORY COMMISSION g WASHINGTON. D. C. 20555 s ,
JUL 101905
! . < l.e t f.o! : Er-373/374 l's . Eerris L. Ferrar Lisetter cf Licensing I.f.. Box 767 (tin g , Illinois 60690 Leur 1:r. Ferrer:
SLbdECT: ACCEPTANCE OF CitiTEL A F0F. FIFFCODE CT GYMPSUti FIP.E STOPL-LA SALLE L0uliTY ST,ATIO!4, blel'it i 6 i r,. letter dated 11ay 28,1985. you ru,t.tstec thii statts concurrer.cc cr. is.r. r f certain reviert. tcctptotice criteria alia separ aticr.:.1csed on newly obtained test data for Firecetic Li bypsun Fire Stops for La Solle Cot. .ty Station, linits 1 lind P.
R.ned on our review. rr f 4rd that tiie testea sedi cor.f igur atics. Lctri!ds the ! a Sal's. cci.iicAration and thdt tlie prcpcr.rc criteria are arreptable.
A cery of ttc rtioted Sof ety Evo r.'atiori is er.clesed.
i Sincerely, Walter R. Octlu ',thiet Licensing Bronch ho. E Divir.icn of Licensing L't.t.i c: cre
- As stated z . -, n Ils $1 wa i e n I
- 1.i . Lo.i.::, L. Ferrar La Salle County thiclea r la u Lionen Cormori. cal t h f c i s u, C u..pci.y Units 1 6 2 CC:
Dhilip P. 5 :l..t.e. L t; Lire John b. hcCdff rey
, it.i tt CPO Chief, Public Utilitter D'e'?. h ,
Lt.e F irs t hatiosia'i Feart. 100 icr1i t t. !zlle Street, Roort 90" CHti to. 'iiiineis 6L603 Chicago, Illisei: CC601 15sistant Attorrey Gener.:1 ~
Its 1 est Ranoceph :,u tu Si, i f.e .Z!.
Il'arr. Illinois 60601 hesident Inspetturildalle, ?!PS l;.',. I.uciu r Fr p letery Comission iLi 1 Fcetc fio. I lost LFrice BUA d" 4 tierseiller . .'11' 05 t.1341 Chairnen
!..- Sellt Lt,uy buarc of Supervisors La Salle Court; Ca xtl.ouse ..
Ottawa, Ill h 11 (15LL Ar.torney General 50C 50t.11. Cr.c' fireet ip i 5. fit ld, Illinois 62701 Li 61 r:4.a ri Illinois Coriae ce Cr,rritsien Leland Bu.ildinc 527 Ea:,t Ccp.tci ati.ue f itin t;iit i(1, iiiiiiots 6%70c Pr. Gary N. liright. !!cnet'et-4 fiuclear facility Sr.itt 3 ~
Illirici:, f yi rtrert of fluclear Safety 1035 Outer Fork be ese, 5th Flor,r Springiitic. 1114rcis 62704 Regional Aoralien,tre ter, F!egion III U. S. liuclear Pegul.-tory Crv'inission M's i.c:.sevelt Road tisus Lilyn, Illinois f.0157 i
i
SAFETY EVALUATION BY THE OFFICE OF hUCLEAR REACTOR REGULATION OF PROPOSE 0 ACCEPIANCE CRITERIA FOR FIRECODE Cl GYPSUM FIRE STOPS COMMONWEALTH EDIS0N LASALLE COUNTY STATION UNITS 1 AND 2 DOCKETS N05. 50-373 AND $0-374 Introduction By memorandum dated February 10, 1984, the licensee committed to the NRC to revise their Firecode CT Gypsum Fire Stop surveillance and installation procedures to incorporate a 1/32 inch acceptance criteria for cracks and separations. This criteria was established based on a lack of test data supporting less stringent acceptance criteria. On May 28, 1985 the licensee submitted revised acceptance criteria for cracks and separations based on newly obtained test data and requested NRC concurrence on the new criteria.
This Safety Evaluation documents the NRC review of the revised acceptance criteria and their impact on the operation and administration of plant activities.
Summary of Evaluation The evaluation of the licensee's revised criteria consisted of a comparison of the test methodology and results that fom the basis for the revised criteria l
and the specifications contained in Branch Technical Position CMEB 9.5-1 Section C.Sa(3) including ASTM E110-81 as endorsed by Standard Review Plan Section 9.5-1.
, The staff found the proposed changes acceptabl6
.y Evaluation of Proposed Chance to Crack and Separation Criteria Describt'. ion of Change Existing criteria require cracks and separations greater than 1/32 inch wide to be repaired. Wider cracks would cause the affected seal to be declared inoperable. The following revised criteria are proposed: k *
- a. Following initial seal installation or repair: '
I Crack Width Corrective Action
< 3/32 inch None
-> 3/32 inch Seal unacceptable -
l iepairs required
- b. Periodic surveillance acceptance criteria:
Crack Width Corrective Action
< 5/32 inch None 1 5/32 inch and < 1/4 inch Seal is operable but must be repaired on an orderly schedule 1 1/4 inch Seal inoperable -
repairs required ,
,,sv mr
Evaluation The basis for the revised criteria is a test performed by Transco Products Inc. on November 20, 1984 and documented in Transco Test Report No. TR-161.
Two test configurations were used to demonstrate seal performance with cracks. Each configuration consisted of an opening 141/2 inches by 9 inches in a 12 inch thick concrete slab. Each opening, containing a 2 inch conduit, was filled with 5 inches of CT Thermafiber covered with 5 inches of Firecode CT Gypsum. A 1/4 inch crack 14 1/2 inches long with full thickness penetration was induced in each seal. One seal was exposed to the test fire on the Firecode CT Gypsum side. The second seal was exposed to the test fire on the CT Thermafiber side.
The test fire was provided by a natural gas-fired furnace measuring 4 feet by 4 feet at its support points. Furnace atmosphere temperatures were monitored by three thermocouples'12 inches below the test seal. Average pressure during the test was .08 inches of water negative.
Themocouples were placed on the side of the seal away from the fire as follows:
- a. Seal with CT Thermafiber exposed to the fire:
- 1. Two thermocouples'slightly depressed into the CT Gypsum surface.
- 2. One thermocouple suspended in the 1/4 inch crack slightly below the CT Gypsum surface.
- 3. One thermocouple at the conduit exit - seal interface.
b, , Seal with CT Gypsum exposed to the fire: ^4
- 1. One thermocouple slightly depressed into the CT Thermafiber surface.
- 2. One thermocouple on the CT Thermafiber surface directly over the 1/4
'- inch crack in the CT Gypsum.
- 3. One thermocouple at the conduit exit - seal interface.
Additional thermocouples were installed to monitor seal performance.inside the conduits. S-j Seal temperatures were recorded at 5 minute intervals for the first two hours "
of the test and at 10 minute intervals for the last hour of the test. ,
At the conclusion of the fire exposure test the seals were subjected to three separate hose stream tests. The first two tests consisted of a 75 psi hose stream delivered from a distance of 10 feet through a 1 1/2 inch hose equipped with fog nozzles with otscharge angles of 30* and 15*. The third test consisted of a 30 psi solid stream delivered through a 2 1/2 inch hose equipped with a 1 1/8 inch tip set on a playpipe from a distance of 20 feet.
Each test lasted 24 seconds.
The following test results were obtained:
2
- a. The maximum temperature attained over,the crack in the seal with the C1 Gypsum exposed to the fire was 140* at 20 minutes into the test. The maximum seal surface temperature attained was 129* F at 25 minutes into the test. The maximum conduit exit-seal interf ace temperature attained in this configuration was 272* F at the 3 hour3.472222e-5 days <br />8.333333e-4 hours <br />4.960317e-6 weeks <br />1.1415e-6 months <br /> point.
- b. The maximum temperature attained over the crack in the seal with CT fiberfill exposed to the fire was 80 F at the 3 hour3.472222e-5 days <br />8.333333e-4 hours <br />4.960317e-6 weeks <br />1.1415e-6 months <br /> point. The maximum seal surface temperature attained was 118* F at the 3 hour3.472222e-5 days <br />8.333333e-4 hours <br />4.960317e-6 weeks <br />1.1415e-6 months <br /> point. The maximum conduit exit - seal interface temperature attained was 205* F at the three hour point.
- c. The seal with the CT Gypsum side exposed to the fire passed all three hose stream tests with no water penetration.
- d. The seal with the CT fiberfill side exposed to the fire passed the first two hose stream tests without water penetration. Water penetration was observed on the. third test.
- e. No flame penetrated either seal nor did any penetrating cables ignite on the unexposed side of the seal.
Standard Review Plan Section 9.5-1 references Section C.5.a(3) of the Branch Technical Position (BTP) CMEB 9.5.1, " Fire Protection for Nuclear Power Plants",
which specifies testing requirements for fire seals installed in openings through fire barriers. The BTP specifies that seals be tested using the time temperature exposure curve of ASTM E-119. The acceptance criteria specified are:
. 9.
- a. , The fire barrier penetration has witt.,tood the fire endurance tests without passage of flame or ignition of cab,les on the unexposed side.
- b. Th'e maximum temperature reached on the unexposed side of the seal is 325*F.
- c. The penetration seal remains intact and does not allow penetration of water beyond the unexposed surfaces during one of the following three tests:
I
- 1. Stream delivered at a distance of 5 feet from t.he exposed surface through a 1 1/2 inch nozzle set at a aischarge angle of 30* With a nozzle pressure of 75 psi and a minimum flow of 75 gpm or
- 2. Stream delivered at a distance of 10 feet from the exposed surface through a 1 1/2 inch nozzle set at a discharge angle of 15* with a nozzle pressure of 75 psi and a minimum flow of 75 gpm or i
- 3. Stream delivered at a distance of 20 feet from the exposed surface through a 2 1/2 inch playpipe equipped with a 1 1/8 inch tip with a nozzle pressure of 30 psi.
3 i
i
Review of the Transco Products, Inc. test results and methodology against the acceptance criteria of the Standard Review Plan showed the following:
- a. The time temperature curve utilized for the test conformed to ASTM E-119 specifications. -
l
- b. The flame through and cable ignition criteria were satisfied. "
- c. The maximum unexposed surface temperatures remained below the 325*
specified value.
- d. Temperature recording requirements were satisfied.
- e. The tested configuration is representative to the as-installed configurations at,LaSalle.
- f. Hose stream tests performed in accordance with Items I and 2 above were successfully completed. A single successful test would have been sufficient. Thus, minimum hose stream test requirements were met or exceeded.
Given that the tested seal configuration with a 1/4 inch crack passed all required tests and bounds the sesl configuration at LaSalle and the licensee's proposed crack and separation criteria, the staff finds the proposed criteria acceptable.
Environmental Consideration
, The proposed changes involve a change in the initallation or use of a facility comp'onent located within the restricted area as defined in 10 CFR Part 20.
The staff has determined that the changes involve no significant increase in the amounts, and no significant change in the types of any effluents that may be rellased offsite, and that there is no significant increase in individual or cumulative occupational radiation exposure. Pursuant to 10 CFR 51.22(b) no environmental / impact statement or environmental assessment need be prepared in connection with the proposed changes.
y Conclusion
.n The staff has concluded, based on the considerations discussed above, that:
(1) there is reasonable assurance that the health and safety of the public will not be endangered by operation in the proposed manner, and (2) such activities will be conducted in compliance with the Commission's regulations and will not be inimical to the common defense and security or to the health and safety of the public. --
Dated:
Principal Contributor W. G. Guldemond 4
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TR-T~
UNITED STATES
/pME I NUCLEAR REGULATORY COMMisslON g a g( ( g g, nEason m r,, j m noosevetv noao f otru ettvu. itusois som Ju; 17 1935 JAN 21 E0 Docket No. 50-454 -
Docket No. 50-455 Comonwealth Edison Company ATTN: Mr. Cordell Reed Vice President Post Office Box 767 Chicago, IL 60690 Gentlemen:
This refers to the special safety inspection conducted by Messrs. K. Connaughton, W. Grant and J. Ulfe of this office on October 18-19, Decerber 10, 1984, and January 4,1985 cf activities at Byron Nuclear Station authorized by Operating License No. NPR-23 and Construction Permit No. CPPR-131 and to the discussion of our findings with Mr. R. Tuetken at the conclusion of the inspection.
The enclosed copy of our in'spection report identifies areas examined during the inspection. Within these areas, the inspection consisted of a selective examination of procedures and representative records, observations, and interviews with personnel.
During this inspection, certain of your activities appeared to be in non-compliance with NRC requirements, as described in the enclosed Appendix. With respect to Item 1 the inspection showed that action had been taken to correct the identified noncompliance and to prevent recurrence. Consequently, no reply to this item of noncompliance is required and we have no further questions regarding this matter at this time. Regarding the remaining item, a written response is required. Your response should address actions taken or planned to prevent recurrence of this item at Byron Unit 2 and at the Braidwocd Station.
In accordance with 10 CFR 2.790(a), a copy of this letter and the enclosures will be placed in the NRC Public Document Room unless you notify this office, by telephone, within ten days of the date of this letter and submit written application to withhold information contair.ed therein within thirty days of the date of this letter. Such application must be consistent with the
- requirements of 2.790(b)(1). If we do not hear from you in this regard within the specified periods noted above, a copy of this letter and the enclosures l will be placed in the Public Document Room.
l t
f c C() h >y
l Coninonwealth Edison Company 2 JAN 17 1935 We will gladly discuss any questions you have concerning this inspection.
Sincerely, W/
M mR. L. Spessard, Director Division of Reactor Safety
Enclosure:
Inspection ' Report No. 50-454/84-76(DRS);
No. 50-455/84-51(DRS) cc w/ enc 1:
D. L. Farrar, Director of Nuclear Licensing V. I. Schlosser, Project Manager Gunner Sorensen, Site Projec,t Superintendent R. E. Querio, Station Superintendent DMB/ Document Control Desk (RIDS)
Resident Inspector, Rill Byron Resident Inspector, RIII Braidwood '
Phyllis Dunton, Attorney General's Office, Environmental Control Division D. W. Cassel, Jr., Esq.
Diane Chavez, DAARE/ SAFE W. Paten, ELD L. 01shan, hRR LPM o
t
Appendix NOTICE OF VIOLATION Comonwealth Edison Company Docket No. 454; 455 As a result of the inspection conducted on October 18-19, December 10, 1984, "
and January 4, 1985, and in accordance with the General Policy and Procedures for NRC Enforcement Actions, (10 CFR Part 2, Appendix C), the following violations were identified:
- 1. Section 2.c(6) of facility operating license No. NPR-23 requires that the licensee maintain in effect all provisions of the approved fire protection program as described in the fire protection report for the facility through Amendment 4 and the licensee's letters dated August 20, 1984, October 11, 1984, and October 15, 1984, and es approved in the SER through Supplement 5. The Byron fire protection program includes commitments to NRC Branch Technical Position 9.5-1. Section C.4.b. of the Branch Technical Position states in part, " Inspections,...that govern the fire protection program should be prescribed by documented instructions, procedures, or drawings and should be accomplished in accordance with these documents."
Contrary to the above:-
- a. Step 9.3.13 of PSQAP No. 9.1, "Special Processes - Firecede CT Gypsum Cement," and Step 9.3.14 of PSQAP No. 9.3, "Special Processes - Radiation Shielding Silicones," were deficient in that these procedures required the verification of the penetration seal fill depth. This task could not have been perfonned without destructive testing of the penetration seal.
- b. The acceptance criteria listed in PSQAP No. 9.1, "Special Processes -
Firecode CT Gypsum," for the installation of fire seals did not specifically address the amount of cracking and/or separation considered acceptable to minimize the effect of fires with the result that the integrity of the seals could not be established.
This is a Severity Level V violation (Supplement II) (Unit I).
- 2. 10 CFR 50, Appendix B, Criterion V, states in part, " Activities affecting quality shall be prescribed by documented instructions, procedures, or drawings...and shall be accomplished in accordance with these instructions, procedures or drawings...."
Contrary to the above, there was no instruction, procedure, or drawing which ensured the timely review of radiation seal substitutions.
This is a Severity Level V violation (Supplement II) (Unit I). ,
i i
b
Appendix 2 With respect to Item 1, the inspection showed that action had been taken to correct the identified item cf ncncompliance and to prevent recurrence.
Consequently, no reply to this item of noncompliance is required and we have no further questions regarding this matter. With respect to Item 2, pursuant to the provisions of 10 CFR 2.201, you are required to submit to this office .
within thirty days of the date of this Notice a written statement or explanation in reply, including for each item of noncompliance: (1) corrective action taken and the results achieved; (2) corrective action to be taken to avoid further noncompliance; and (3) the date when full compliance will be achieved. Consideration may be given to extending your response time for good cause shown.
mm S/f0[ W Spessard, Director 47 Fated g / ,t, R. L'.
v Division of Reactor Safety 9
U.S. NUCLEAR REGULATORY COMMISSION REGION III Report No. 50-454/84-76(DRS);50-455/84-51(DRS)
Docket No. 50-454/50-455 License No. NPR-23; CPPR-131 Licensee: Commonwealth Edison Company Post Office Box 766 Chicago, IL 60690 Facility Name: Byron Station, Units 1 and 2 Inspection At: Byron Site, Byron, Illinois Inspection Conducted: October 18-19, December 10, 1984 and January 4, 1985 rn UCL, Inspectors:
s
. M. Ulie , /!6k Ddte '
f.,hputM A. Connaughton / f!8f Date J/ M % <//&
Date Approved . L. A. Reye Acting Chief M Operatio Programs Section Date Inspection Summary Inspection on October 18-19, December 10, 1984, and January 4, 1985 (Report No 50-454/84-76(DRST: 50-455/84-51(DRS))
Areas Inspected: 'Special unannounced inspection of the licensee's quality assurance / quality control program as it applies to fire protection and other areas including procedures, drawings and other documentation related to penetra-tion seal installations; and a review of allegations received relative to the installation of penetration seals. The inspection involved a total of 51 inspector-hours onsite and in-office review by three NRC inspectors, including 6 inspector-hours onsite during off-shifts.
Resultrl Of the six areas inspected, no items of nonccmpliance were identified in fiv2 areas; two items of noncompliance were identified in the remaining area (procedural deficiencies relating to verifying the penetration seal fill depth and the acceptable amount of cracking and/or separation in seal material -
Paragraph 4.a lack of pos-itive controls to ensure the timely review of radiation sAal substitutions - Paragraph 4.b.).
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DETAILS
- 1. Persons Contacted Commonwealth Edison Company (CECO) 2-B. Cook, Engineering 1-C. Diaz, Fire Protection Engineer 3-R. Guse, Senior Engineer K. Hansing, Quality Assurance Superintendent M. Lohmann, Assistant Construction Superintendent E. Martin, Quality Assurance Supervisor 4-J. Mihovilovich, Lead Structural Engineer C. Nagle, Quality Assurance Engineer 5-G. Serenson, Construction Superintendent 4-R. Tuetken, Star. tup Superintendent D. Thornley, Field Engineer S. Vovos, Construction Field Engineer Transco, Inc.
2-T. Hoff, Product Manager B. C. Machchlez, Quality Control Manager 2-M. Monson, Product Superintendent A. Rice, Quality Assurance Manager R. Tancinco, Assistant Quality Assurance Manager M&M Protection Consultants 1-R. Smith, Fire Protection Engineer Sargent and Lundy 3-W. DeLise, Nuclear Station Licensing Department 5-T. Thorsell, Senior Electrical Project Engineer 1-Denotes attendance at exit meeting of October 19, 1984 only.
2-Denotes attendance at exit meeting of December 10, 1984 only.
3-Denotes attendance at exit meeting of January 4,1985 only.
4-Denotes attendance at exit meetings of October 19, December 10, 1984 and January 4, 1985.
5-Denotes attendance at exit meetings of December 10, 1984 and January 4, 1985.
- 2. Documents Reviewed ,
- a. Procedures Reviewed ,
Number Title Transco PSQAP 2ce, Revision 0 Supplement to Penetration Seal Quality Assurance Procedures Applicable to Byron Nuclear Station only. ,
l 2
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. . 1 Transco PSQAP 2.0, Revisions 0, Qualification of Personnel (Chicago, 2, ar.d 3 QC Managers, QC Inspectors, and Field Supervisors)
Transco PSQAP 2.1, Revision 1 Qualification of Site Craft Personnel Transco PSQAM '., Revision 2 Penetration Seal Quality Assurance Paragraph 10.0-Inspection Program Manual Transco PSQAP 10.1, Revision 3 Supplement to Penetration Seal Quality Assurance Procedures Applicable to Byron Nuclear Station Only Transco PSQAP 9.3, Revisions Special Processes - Radiation Shielding 1 and 4 Silicones Transco PSQAP 9.0, Revision 1 Special Processes - Penetration Dams Transco PSQAP 5.0, Revision 1 Instruction, Procedures and Drawings 1
Transco PSQAP 4.0, Revision 1 Procurement Document Control Transco PSQAP 9.1, Revisions Special Processes - Firecode CT 1 and 4 ,
Gypsum Cement TranscoPSQAP9.50, Revision 1 Special Processes - Silicone Elastomer Transco PSQAP 15.0, Revision 2 Nonconforming Items Transco PSQAP 15.1, Revision 0 Reporting of Defects and Noncompliance (10 CFR 21)
No Number Firecode CT Gypsum Cement Application and Installation Procedures Tech-SIL TSP-Q220 Use of Tech-Sil Penetration Closure Tech-SIL QA-109 Card Procedure For Storage and Shipping
- b. Drawings Reviewed Number Date Title M-518, Revision R July 13, 1984 Schedule for Mechanical Seals S-717, Revision AE May 27, 1983 Auxiliary Building Foundation Section 1.1 S-1616, Revision BM August 13, 1984 Auxiliary Building S-1632, Revision AU December 5, 1983 Auxiliary Building Foundation 5-1738, Revision N July 31, 1984 Auxiliary Building Concrete Partition Wall l
3 l
S-1302, Revision CF September 20, 1984 Auxiliary Building Main Floor Plan 6E-0-33710, Revision BT May 10, 1984 Electrical Installation -
Auxiliary Building Plan 6E-0-3600, No Revision August 14, 1984 CECO - Byron Station Project Listed No. 4391; 4392 Sheet No. 37W 6E-0-3600, No Revision August 16, 1984 CECO - Byron Station Project Listed No. 4391; 4392 Sheet No. 31 6E-0-3600, No Revision September 19, 1984 CECO - Byron Station Project Listed No. 4391; 4392 Sheet No. 48E-6E-0-3600, Revision AE No Date Listed CECO - Byron Station Project Sheet No. 3A No. 4391; 4392 6E-0-3600, Revision March 6,1984 Fire Stops and Seals After AE Above Sheet No. 3A ,
Drawing Legend, September 25, 1984 Types of Seals Revision 1 6E-0-3600, Revision August 15 and Fire Stops and Seals AR and BA October 19, 1984 Respectively BY-E-02, Revision 0 Firecode CT Gypsum Cement Detail A Seals for Wall, Sleeve, or Conduits BY-E-02A, Revision 0 Firecode CT Gypsum Cement Detail A Seals for Wall, Sleeve, or Conduits BY-E-03, Revision 0 Firecode CT Gypsum Cement Detail B Seal for Floor, Sleeves or Conduits BY-E-04, Revision 0 Firecode CT Gypsum Cement Detail C Seal for Walls BY-E-04A, Revision 0 Firecode CT Gypsum Cement Detail C Seal for Tray / Cable BY-E-05, Revision 0 .Firecode CT Gypsum Cement
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Seal for Floor Penetrations 4
1 BY-E-05A, Revision 0 Firecode CT Gypsum Cement Detail D Seal with Collar for Floor Penetrations BY-E-06, Revision 1 Transco Silicone Elastomer BY-E-07, Revision 1 Transco Silicone Elastomer BY-E-08, Revision 1 Transco High Density Silicone BY-E-09, Revision 1 Transco High Density Silicone BY-E-10, Revision 1 Transco High Density Silicone BY-E-11, Revision 1 Transco High Density Silicone BY-E-11A, Rev'ision 1 #TCO-003 High Density Silicone Elastomer Penetration Seal for Non-Moving Instrument Lines (Walls or Floors)
BY-E-12, Revision 1 Transco Medium Density Silicone BY-E-13, RevisionL,1 TransCo Medium Density Silicone BY-E-14, Revision 0 TCO-003 High Density Silicone Elastomer for Thin Floors or Walls (Less than 12" thick)
BY-E-15, Revision 0 Damming Board Divider for Oversized Firecode CT Gypsum Penetration Seals BY-E-16, Revision 0 Sheet Metal Dividers for Oversized High Density Silicone Elastomer Penetration Seals BY-E-17A, Revision 3 Bus Duct Seal at Aluminum Bus Bars, #TCO-002 Medium Density Silicone Elastomer BY-E-178, Revision 3 Bus Duct Seal at Copper Bus Bars, #TCO-002 Medium Density Silicone Elastomer
- c. Audit Reports Number Date Title
l .
i6-84-119 February 22, 1984 QA Program Audit
- 6-83-44 October 4,1983 QA Program Audit
- 6-84-314 September 18, 1984 QA Program Audit
- 6-84-143 June 8, 1984 QA Program Audit
- 6-83-106 December 12, 1983 QA Program Audit
- 6-83-61 July 1, 1983 QA Program Audit
- d. Transmittals Date Title December 19, 1978 Quality Assurance Requirements for Fire Protection Systems Byron and Braidwood Stations July 21, 1982 CECO - Standard Reliability Articles March 25, 1983 Evaluation of Contractors Quality Assurance Program February 22, 1982" 8. B. Subbidder Package No. 147 Cable Penetration Seals and Conduit End Seals Final Package for Approval
- e. Test Results Number Title
'Transco Test Report Crack, Repair and Debris July 18, 1984 Transco Test Report Fire and Hose Stream Test of TCO-001 Cement, November 20,-1984 TCO-002 Medium Density Silicone and TC0-007 Silicone Adhesive Used in Electrical Conduit and Blockout Penetrations.
l f. Personnel Qualification / Certification Package Review Checklist The licensee provided to the inspector personnel certification packages l for all (8) of the presently employed (On October 19,1984) Transco j -
Quality Control Inspectors.
Nurrber Title Per PSQAP 2.0, Revision 0 Q.C. Inspector g: Sumary List of 4fnit 1 Radiation Seal Substitutions The licensee provided a sumary list of Unit I radiation seal sub-stitutions and an individual listing of those seals.
- 6 J
- 3. Licensee's Fire Protection Quality Assurance Program The inspector's examined the licensee's quality assurance / quality control program as it applied to fire protectier. by perfoming a detailed search and review of NRC, licensee, and their contractor's documents and commitments identified within those documents to provide an understanding of the fire protection penetration seal safety classification as it was being applied at Byron Station. The findings of those reviews are as follows:
Section 9.5.1.3 of Byron's Safety Evaluation Report dated February,1982 covering the Quality Assurance Program as it applied to fire protection states in part, "the applicant has classified the fire protection system as reliability related...."
Section 2.6 of the CECO Quality Assurance Program for Nuclear Generating Stations Topical Report, Revision 23, dated October 5,1984, states in part on page 7: "The Quality Assurance Program applies to safety related... items and related consumables plus fire protection...." It further states on page 8: "Also, the program is applicable to reliability related items...and as examples shall cover...special processes...."
The Byron Station Quality Assurance Program, Revision 13, dated January 12, 1984, states in part on page 1: "The Byron Station Quality Assurance Program is written to specifically describe the quality assurance program for control of work performed by personnel involving safety-related items...plus reliability designated as such by the company at the operating nuclear stations hereinafter referred to as "the station.""
Table 3.2-1 of the Byron FSAR lists the Quality Assurance requirements for.the " Fire Protection System" and "other cable penetrations (firesteps): as Level II (10 CFR 50, Appendix B does not apply)." During meetings on October 19, 1984, the site QA Superintendent stated the CECO Station QA Program does not apply to fire seal installations; however, the site QA Superintendent agreed that the CECO Corporate QA Program does state that the QA Program applies to fire protection but could not provide any further clarification regarding the corporate policy.
The licensee provided a transmittal letter dated December 19, 1978 that
! covered the subject of " Quality Assurance Requirements for Fire Protection Systems, Byron and Braidwood Stations." This letter stated in l part, "The fire protection and detection (FP) systems for Byron and l Braidwood Stations are classified as Safety retegory II." This transmittal letter further stated in part, "For the Safety Category II,... portion of the FP System quality requirements are applicable as follows: ...(b) for FP l
systems and equipment procured to Sargent and Lundy specifications whose l
Purchase Order issue date is after September 1,1978, and for site-prime contractors for installation of fire protection systems who started work on September 1,1978 er later." The following three articles apply:
(1) " CECO Standard Quality Articles for Non-Safety and Non-Code Related l
Equipment and the statement of policy dated February 17, 1978 covering Ceco commitments to the NRC BTP 9.5-1 apply.
7
(2) Quality Articles and NFPA Codes are applicable as stated in each specification.
(3) Certificates of Conformance are required for the acceptance of equipment. Approved procedures will be required for installation services."
The licensee 22, 1982 provided which a copy indicated of Bid in the Package Division No.147, dated February III Secticn(Quality Control )
that penetration and conduit seals were considered reliability related when the bid was issued. As noted above, the Byron QA Program was written to specifically describe the QA Program for control of work performed by personnel involving reliability related items designated as such by the station which referenced Table 3.2-1 of the Byron FSAR.
This table list the QA requircments for the fire protection system including cable penetration fire seals as level II indicating that 10 CFR 50, Appendix B does not apply. Thus, cable penetration fire seals do not fall under the stringent requirements of the safety classification known as " safety-related." The inspector's also determined that the CECO QA program for the installation of Firecode CT Gypsum Cement and the Silicone penetration seals used at Byron were implemented via the Transco Penetration Seal Quality Assurance Procedures (PSQAP's).
Although no items of noncompliance or deviations were identified during this review, the inspector's noted that the manner in which the wording is. phrased in Section 2.6 of the CECO Quality Assurance (QA)
Program for Nuclear Generating Stations Topical Report versus the wording used in the Byron Station QA Program certainly did not provide for a clear understanding of QA as it relates to fire protection and further
- clarification needs to be set forth.
The. information reviewed in this paragraph was used for the inspector's
- guidance in the review of the remaining portions of this report.
No items of noncompliance or deviations were identified.
- 4. Allegations Concerning Transco Penetration Seals f An individual contacted the NRC Resident Inspector's office regarding j Transco Incorporated penetration seals indicating the following concerns:
. Final inspection checklists performed after fire seal installation j required verification that sealing material has been installed in
' conduits to the same thickness as the barrier (wall or floor) penetrated by the conduit. Verification of the penetration thickness was not possible.
Where installation of high density silicone sealing material (type 3
- seal) sealingrequired material-by(design type 5 seal)is is determined substituted.to be " impractical", gypsum 8
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- e a,-,, g n,-., m -~, +,, s - we- a , e -~,- -
Comonwealth Edison Company (CECO) has not required that QC inspection personnel employed by Transco be certified in accordance with ANSI N45.2.6.
Resolution of these allegatiens was pursued through inspector review of the licensee's Quality Assurance (QA)fQuality Control (QC) program and Transco's Penetration Seals Quality Assurance Procedures and other documents (see Paragraph 2 of report) as they apply to fire protection, radiation shielding, ventilation, and flood seals. In addition, the inspector met with CECO ~
engineers, CECO QA personnel, Transco QA/QC personnel, and a licensee consultant to ascertain whether the licensee's QA/QC progran and their subcontractor's QA/QC program was in accordance with NRC regulations. As a result of these activities the following findings and conclusions were made:
- a. Allecation (Allegation No. RIII-84-A-0153-01): Final inspection checklists after seal installation require verification that sealing material has been installed in conduits to the same thickness as the barrier (wall or floor) penetrated by the conduit. Verification of the penetration thickness was not possible.
The inspector reviewed Transco's Penetration Seal Quality Assurance Procedures (PSQAP) numbered 9.1 titled, "Special Processes -
Firecode CT Gypsum Cement" and 9.3 titled, "Special Processes -
Radiation Shielding Silicones" dated June 28, 1983 regarding this allegation. Step 9.3.13 of PSQAP No. 9.1 requires quality control personnel to perform a final inspection of the completed seal when released by production for inspection activities. Criteria to be employed during the final inspection included the following:
(1) Temporary daming, where applicable, is totally removed and disposed of.
(2) Temporary supports, where applicable, such as, duct tape, wood shins, etc., have been removed and disposed of.
(3) Penetration fil1 is ' sufficient to completely fill or overfill the penetration to the specified fill depth.
(4) Proper materials were used for the sealing, damming, and identification of the penetration.
(5) The work location is clean.
(6) " Cosmetic" factors such as surface smoothness, ripples, craters, surface cracks, chips or gouges, and all other minor blemishes are normal characteristics of CT Gypsum and are acceptable.
(7)- Characteristics other than " Cosmetic" factors as described in Section (g) shall be repaired per Section 9.3.11.
(8) The dispersion of the CT Gypsum around the cables in the penetration shall be inspected.
9 i
The inspector reviewed the overall inspection methodology with the following results: (1) Step 9.3.2 of PSQAP No. 9.1 required completion of the daming operation prior to installation of the penetration seal materials. (2) Step 9.3.7 of PSQAP No. 9.0 dated March 7, 1984 required QC personnel to visually inspect a minimum of 25% of the installed dams for each different type of seal material (i.e., Gypsum, Silicone Foam, etc.) and document the results on the
" Field Takeoff, Installation, and Inspection Record" fonn. It was subsequently reported by the Transco QC Manager that 964 of 2268 dams were inspected from September 19, 1984 to October 19, 1984. (3) Step 9.3.8 of PSQAP 9.1 required the QC inspector to perform in-process inspections at random stages of the installation process and document the results on the " Field Takeoff, Installation, and Inspection Record" iorm. Further, of 6349 total penetrations installed, 187 in-process inspections were performed according to the Transco QC Manager. (4) Step 9.3.13(c) of PSQAP No. 9.1 and Step 9.3.14(d) of PSQAP No. 9.3 required a final inspection to check the penetration fill and verify that the thickness"is sufficient to completely fill the penetration to the specified fill depth. (5) During the inspector's review of PSQAP No. 9.3 similiar damming, in-process, and final inspections were identified as being required including similiar wording for the QC inspector to use as inspection criteria.
Regarding item (4), the inspector questioned the practicality of inspecting fill depth after the Fftrecode CT Gypsum cement and Radiation Shielding Silicones were in place due to the hardness of the finished product. Transco and CECO personnel present at the meeting agreed the wording in these two procedures inferred an impossible task short of removing the penetration; however, according
- to Transco personnel, the intent of this procedural instruction was to verify the surface conditions of the penetration seals not the depth of the penetration.
As discussed in Paragraph 3 of the report, Table 3.2-1 of the Byron FSAR lists the Quality Assurance requirements for the " Fire Prctection System" and "other cable penetrations (firestops)" as Level II (10 CFR 50, Appendix B does not apply).
Also discussed in Paragraph 3 was the licensee's transmittal letter dated December 19, 1978 covering the subject of Quality Assurance Requirements for Fire Protection Systems, Byron and Braidwood Stations." This letter stated in part, "The fire protection and detection (FP) systems for Byron and Braidwood Stations are classified as Safety category II. Further stating in part, "For the Safety Category II, portion of the FP System quality requirements are applicable as follows: ...(b) for FP systems and equipment procured to Sargent and Lundy specifications whose Purchase Order issue date is after September 1,1978, and for site-prime contractors for installation of fire protection systems who started work on September 1,1978 or later" (this included Transco's installing of of penetration fire seals). The following article applies:
(1) " CECO Standard Quality Articles for Non-Safety and Non-Code Related Equipment and the statement of policy dated February 17, 1978 covering CECO commitments to the NRC BTP 9.5-1 apply."
10
Thus, Section C.4.b. of the Branch Technical Position 9.5-1 stating in part,
" Inspections, ...that govern the fire protection program should be prescribed by documented instructions, procedures...and should be accomplished in accordance with these documents." The inspector's determined that a destructive test would be the only manner in which to verify penetration fill depth and this is not a feasible approach to ensure penetration seal adequacy as required by Technical Specifications. Inclusion of inspection requirements which could not be accomplished in surveillance procedures used to ensure the acceptable condition of the penetration fire seals is considered to be a violation of Section C.4.b of the Branch Technical Position 9.5-1 and of Section 2.C.(6) of facility (operating licenseThe pliance 454/84-76-01a(DRS). No. NPF-23 inspector and on verified is December an example of an 10, 1984 item that of nonc PSQAP Nos. 9.1 and 9.3 were revised to more accurately describe actions to be taken by Quality Control Personnel performing penetration seal inspections including the addition of the " Final Inspection Checklists" forms to each of these procedures to also be kept as part of the permanent records.
The inspectors concluded that the Quality Centrol inspections performed, regardless of the deficient steps noted, provided reasonable assurance that penetration seals have been installed to the required fill-depths.
It was the inspector's conclusion that this allegation was substantiated based on the wording used in PSQAP Nos. 9.1 and 9.3 regarding the verification of seal fill depth being a task unable to be performed without destructive testing'.
During this review, two additional items were identified: (1) Step 9.3.15(b) of PSQAP No. 9.3 regarding the inspection of Radiation Shielding Silicone samples included a check of the " Cell Structure" for unifonnity. The inspector noted that past inspection experience has identified that the silicone manufacturer has comparison charts for the silicone cell structure.which were missing from the procedure. The inspector questioned Transco's basis for not including the manufacturer's comparsion chart as part of the procedure. Through discussions with Transco personnel, the inspector was informed that the manufacturer of the silicone has no cell structures comparison chart for the type of silicone being used at Byron.
Thus, this concern is considered resolved. (2) Step 9.3.13 of PSQAP No. 9.1, "Special Processes-Firecode CT Gypsum" specify the items to be considered (acceptance criteria) during final inspection of the completed fire seal.
However, the items listed did not specifically address the amount of cracking '
and/or shrinkage considered acceptable as determined by test data. As a result, seals could be installed which would not perform their intended function. This was viewed as a weakness in Byron's construction quality assurance program. Failure to develop an adequate penetration fire seal surveillance procedure to ensure the acceptable condition of the penetration fire seals is considered to be a violation of Section C.4.b of the Branch Technical Position 9.5-1 and of Section 2.C.(6) of facility operating license No. NPF-73 and is an example of an item of noncompliance (454/84-76-01b(DRS).
The inspector verified on December 10, 1984, that Step 9.3.13(g) of Transco's PSQAP No. 9.1 does now address the amount of cracking being less than 1/32" as determined by test data. This item is discussed in mor'e detail in Paragraph 5 of the report. This allegation is considered closed.
11
- e b.. Allegation (Allegation No. RIII-84-A-0153-02): Where installation of high density silicone sealing material (Type 3 seal) required by design is determined to be " impractical", Gypsum sealing material (Type 5 seal) is substituted.
(1) The question of substituting Firecode CT Gypsum cement for Silicone was asked of the CECO staff. CECO personnel indicated that they were _
not aware of any such substitutions taking place in the field.
The inspector questioned the Transco QC Manager as to whether there existed any as-built Type 3 seals by design specifications (Radiation Seal - Nonnally containing High Density Silicone) in which material other than the Silicone based material had been substituted. The Transco QC Manager indicated that Firecode CT Gypsum cement had been substituted for the Silicone material inside conduits in barriers walls and floo'rs but was unclear as to the number and specific locations of the substitutions installed.
He also noted the type of seal, their designations, and the penetration sealant material intended to be used by design were denoted as the following: (1) for use as a Fire Seal (Type 1 only) was Firecode CT Gypsum cement; (2) for use as a Flood Seal (Type 2 only) was Medium Density Silicone;-(3) for use as a Radiation Seal (Type 3 only) was High Density Silicone; (4) for use also as a Radiation Seal (Type 4 only) was Medium Density Silicone; and (5) for use as a Ventilation Seal (Type 5 only) was Firecode CT Gypsum cement.
The inspector requested documentation be provided to show the final criteria used by Sargent and Lundy in performing their review relative to the substitutions for silicone. In addition, the inspectors
, requested the Transco QC Manager to perform a review of Transco records showing the number and location (s) of any penetrations which had Gypsum substituted for silicone. Subsequently, the licensee provided a detailed and summary list indicating that of thirteen hundred and seventeen radiation seals in conduits required for Unit No.1, four hundred and twenty-six seals had gypsum substituted for silicone.
The Transco QC Manager provided the inspector with Transco legend sheets dated September 25,1984,(datedincorrectly: 9-25-85),
Revision 1, regarding the " Types Of Seals" and categorization of the seals being used at Byron Station.
The inspector reviewed the legend sheets titled " Types of Seals" which indicated that penetration opening having more than one purpose, such as fire and radiation, may be filled with Firecede CT
- Gypsum cement (Type 1) instead of Silicone material (Type 3) if the gypsum was installed on both sides of the fire wall then indicate in the remarks column of the " Final Inspection Checklist" thu the penstration seal was done as a Type 1 seal. .Further, the legend sheets indicated if a penetration opening serves as both a radiation seal (Type 3) and a ventilation seal (Type 5), Firecode CT Gypsum may also replace the Silicone material on one side of the fire wall while l ,
1 12
~ - . .--
l * .
o .
l also indicating in the remarks column of the " Final Inspection Checklist" that the penetration seal was done as a Type 5 seal.
According to the legend sheets, either of the two conditions '
discussed above (i.e., Fire and Radiation or Ventilation and 1 Radiation) may have been employed if the craft installers determined i
that it was not practical to install silicone material. The S&L drawing detail dated August 16, 1984, (Rev. AR), required seals inside conduits to be installed at the barrier wall or floor unless physically impossible. According to licensee representatives, when a substitute sealant is installed it is so noted on the legend sheets and this information is transmitted to the AE (Sargent and Lundy) for l analysis and approval or corrective action. However there appeared to be no procedure, instruction, or drawing that describes how this was accomplished and no documentation existed that demonstrated any of the seal substitute data was being processed prior to the allegation i
follow-up. Fa'ilure to provide an instruction, procedure, or drawing to ensure the timely review of radiation seal substitutions is considered a viclation of 10 CFR 50, Appendix B, Criterion V (454/84-76-02(DRS) and an open item (455/84-51-01(DRS) for Unit 2. '
Engineering Change Notice (ECN) P-33, effective January 3,1985, revised Note 12 of drawing No. 6E-0-3600 to state that if radiation seals can not be installed, those seal numbers shall be submitted to the A/E for resolution.
The inspector reviewed Sargent and Lundy drawings numbered 6E-0-360,0, Sheet Nos. 3, 3A, and 3B which document the fire stop and seal 1
tabulation of Byron Station, Units 1 and 2 (Project No. 4391 and 4392). During the inspector's review of these drawings it could not be determined whether a gypsum sealing material was an approved substitute for high density silicone sealing material.
'According to a Ceco transmittal dated October 22, 1984, CECO committed to initiate a design review for substituting non-radiation sealing details at locations where radiation seals are specified by the design drawings. Subsequently this matter was discussed in phone calls on November 20, and December 26, 1984, between Region III staff and Mr. R. Tuetken, Start-Up Superintendent for the Byron Project in which it was determined to have this review completed by denuary 4, 1985. 1 On January 4, 1985, the inspector discussed the results of this review with licensee representatives. The A/E review analyzed over 700 conduit seals for conformance with FSAR radiation shielding i
commitments. All of the 426 conduits which contained a substitute sealant were analyzed-plus several hundred more which contained the design sealant. This general review identified 388 conduit seals which, based on initial, generic calculations, did not meet the FSAR radiation shielding criteria of 5x the design dose rates for wall penetrations from 0 to 10 ft above floor level and 10x design dose rates for wall penetration greater than 10 ft above floor level.
The 388 conduit seals were reanalyzed individually, utilizir.g expected source term, wall thickness, and cceduit size. Fifty-nine of the 388 conduits required the addition of radiation seals to meet the FSAR 13
criteria. The remaining 329 conduits were determined to meet the FSAR radiation shielding criteria based on the re-evaluations. All but four of the 59 seals have been installed. The remaining four were considered to be impractical at this time. All four are nonnally inaccessible and over 10 ft above floor level. Adding sealant to these conduits would require cutting the conduit and the many electrical cables in the conduit plus reinstallation. The licensee has placed administrative control requirements for monitoring the four conduits for radiation streaming during the Unit 1 power escalation radiation survey. These survey results will be reviewed during a future inspection.
This item is considered an open item (454/84-76-03(DRS);
455/84-51-02(DRS)).
It was the inspector's conclusion that the alleger's concern that high density silicone sealant required by design was being substituted with a Gypsunt cement sealant was substantiated; however, based on the inspectors review: in over 90% of the conduit seals analyzed, the type of sealant installed, either as designed or as substituted, did not significantly affect the shielding quality; the licensee took corrective action for the 10% that needed replacement; and the ifcensee's normal seal installation follow-up by the AE or the facility radiation survey during power escalation would probably have detected problem areas.
This allegation is considered closed.
(2) In addition to the review noted above, an inspector performed a walkdown on December 10, 1984 accompanied by CECO, Sargent and Lundy and Transco personnel of fourteen as-built penetration seal installations includin flood seals (silicone)g two
, four Type Type 1 fire seals 3 radiation seals (gypsum),
having siliconethree Type 2 material, installed as-designed, also three additional Type 3 radiation seals (having gypsum substituted for the silicone material), and two Type 5 ventilation seals (gypsum) were inspected. One of the three
' Type 3 radiation seals having been substituted for with gypsum was not inspected because of its hard to reach location coupled with the absence of having the proper tool to open the 5" conduit connections.
Twelve of the remaining thirteen penetration seals were inspected and found to be' intact and without any noticeable voids along the surface of the penetration. The inspector also referenced steps 9.3.13 of PSQAP 9.1 and 9.3.14 of 9.3 as applicable which identifies the items to be covered by QC personnel when performing a final inspection of completed seals. The remaining penetration seal (numbered 1848) was a Type 3 radiation seal having the gypsum cement installed in place of the silicone material located at a 11/2" conduit connection in the Auxiliary Building, EL. 401', Fire Zone No.
11.5-0. This penetration seal was found with the gypsum cement removed conduit)(having a visible void and opening existing. pieces of gypsum The licensee opened the next nearest penetration seal conduit connection which was also found with the gypsum removed and having an opening existing.
- Licensee and Transco personnel present believed that a cable had been added and indicated they would take action to determine the cause of the penetration seal voids. At the exit meeting on i
14
December 10, 1984, the licensee was unable to clearly establish the cause of the seal opening but indicated they would followup on the cause in addition to verifying a firewatch patrol was. established in accordance with their Technical Specification action statemer:t and other requirements.
Subsequent to the December 10, 1984 inspection visit, the licensee provided a copy of the " Notification of Fire Barrier Impairment' "
form dated November 21, 1984 to the inspector for review that indicated cable No. 2P9421 was being added and thereby needed a opening in the conduit seal. In addition, the licensee provided documentation that showed compensatory measures were being performed since November 21, 1984. Based on the above information, this item is considered closed.
- c. Alleoation (AllegationNo.RIII-84-A-0153-03): CECO has apparently not required that QC inspection personnel employed by Transco be certified in accordance with ANSI N45.2.6.
In response to this allegation the inspectors reviewed documentation provided by the licensee's QA Department and the job requirements of 4 the Transco Quality Control Personnel in performing their inspection duties. The insp'ector's determined those requirements to include the following:
(1) The ability to read blue prints to determine penetration location.
(2) An understanding of the Transco sealing designs, QC procedures and the S&L penetration schedule. -
(3) The ability to use a ruler to determine damming depth.
(4) An ability to document the results.
1 The inspectors review of these inspection requirements included a review of the Transco QC inspectors qualification packages indicating as determined by the inspectors that the Transco QC inspectors were qualified to perform their assigned tasks.
The inspector's also performed a review of other licensee and Transco documents including the licensee's subbidder Package No.147 dated February 18, 1982, covering cable Penetration Seals and Conduit End Seals, and Transco Penetration Seal Quality Assurance Procedures (PSQAP) No. 2.0, Revisions 2 and 3.
The review of the licensee's Subbidder Package No.147 showed that Transco was the successful bidder for the installation of penetration fire seals by CECO Purchase Order 261691 dated May 14, .
1982. The' licensee required the successful bidder (Quality Control Division Section) to submit their Quality Control Program including a list of pertinent Quality Control Procedures which were to be used in the design, installation, testing, and manufacture of the
- equipment and materials covered by the specification. The subbidder 15
package prevented any work from starting until the Station Construction Superintendent reviewed and accepted the Quality Control Procedures. The Station Construction Project Superintendent did accept Transco's Quality Control Procedures which did not include a reference regarding ANSI N45.2.6. However, it was determined by the inspector's through discussions held with the licensee and Transco personnel that on approximately July 10, 1984, at the request of a member of CECO's Station Technical Staff that Transco revise their QA Manual to include a reference to ANSI N45.2.6, which was done as part of Revision 2. In the inspectors review of PSQAP 2.0, Revision 2, a reference to ANSI N45.2.6 stating in Section 2.3.3, " Minimum inspector qualifications are as stated in ANSI N45.2.6" was inserted. Revision 3 of PSQAP No. 2.0 removed the reference to ANSI N45.2.6. The inspector's questioned the intent of including ANSI N45.2.6 in Revision 2 but deleting it from Revision 3.
The inspector's contacted the CECO Station Technical Staff member who requested the ANSI requirement be included in Transco's Procedures. It was the inspector's understanding that the Technical Staff member was unaware of Byron Station penetration fire seal requirements and at the time believed penetration fire seals were considered safety related. However, the inspectors determined that the penetration fire seal installations were not considered safety-related (as discussed in paragraph 3) as understood and accepted by NRR t'hrough CECO's QA Program requirements; It was the inspector's conclusion that the alleger's concern that Ceco was not requiring Transco's QC inspection personnel to be certified in accordance with ANSI N45.2.6 was substantiated; however, based on the inspector's review, the penetration seals being installed by Transco were not safety-related (discussed in paragraph 3). Therefore, neither the NRC or the licensee required Transco fire penetration seal inspectors to be certified in accordance with ANSI N45.2.6. Further, the inspector's review of the inspection requirements required of the Transco QC inspectors including their qualification packages indicated that the Transco QC inspectors were qualified to perform their assigned tasks. This allegation is considered closed.
No other items of noncompliance or deviations were identified.
- 5. Acceptance Criteria for Firecode CT Gypsum Cement Fire Stops Previous inspection experience at other nuclear plants has identified cracking, shrinkage, and/or separation problems related to penetration fire seal material. In general, it has also been found that adequate acceptance criteria for such problems have not been specified as identified in paragraph 4.a of the report.
By letter dated February 10, 1984 regarding LaSalle County Station, CECO proposed an acceptance criteria for cracks and separations in Firecode CT Gypsum Cement fire seals as less than or equal to 1/32" wide by 1" deep. Thus, only hairline cracks were to be allowed. During a meeting with NRR on November 16,1983, the 1/32" separation criteria was accepted based on fire test reports submitted to NRR, specifically Transco Fire Test Report No. TR-109 dated April 7,1983, which documented satisfactory performance of a fire seal with a hairline crack.
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T@ establish a consistent acceptance criteria for Firecode CT Gypsum
- - Cement, the inspector requested the licensee to propose specific acceptance criteria for performing the final inspections of fire seal installations at Byron. According to the Transco QC Manager a recent Transco test indicated that a 1/16" wide separation was acceptable.
The licensee has employed the services of M&M Protection Consultants to review the results of the Transco Test Report Numbered TR-150 dated July 20, 1984, which documented this test.
On October 26, 1984, during a telephone call between a representative of NRC-Region III and a representative of M&M Protection Consultants, Byron's acceptance criteria for firecode CT Gypsum fire seals was discussed. This discussion included the previously approved LaSalle acceptance criteria and the most recent test data results applicable to Firecode CT Gypsum. Based on this discussion the following was agreed upon:
(1) Cracks and/or separations greater than 1/16" wide by less than the full depth of the penetration fire seal would be repaired.
(2) Cracks and/or separations greater than 1/32" but less than 1/16" wide and less"than the full depth of the penetration fire seal would require a depth criteria as determined by test data.
(3) Cracks and/or separations less than or equal to 1/32" wide by 1" deep will not require a repair.
Based on the inspector's verification on December 10, 1984, that Step 9.3.13(g)(of cracking less Transco's..PSQAP No. 9.1 than 1/32") as determined does by test nowthis data, address item is the amount of considered resolved.
An additional concern was raised by the inspector regarding the acceptability of installing Firecode CT Gypsum cement and/or Silicone material in a conduit bend. To resolve this concern, Transco conducted a fire test on November 20, 1984 at Construction Technology Laboratories Fire Research Laboratory. The licensee has also employed the services of M&M Protection Consultants to review the results of this test with regard to evaluating the acceptability of installing Firecode CT Gypsum cement or Silicone material in a conduit bend. The inspectors reviewed test Report No. TR-161 and M and M Protection Censultants letter dated December 10, 1984 in which two penetration conduits (penetration G and H) having seals within the conduits and within the bend area were tested and found to meet the acceptance criteria in accordance with IEEE-634 Standard. The licensee acknowledged that no penetration assembly configurations installed at Byron Station are larger than or with less sealant material than can be supported by fire test data. Based on the above information, this item is considered resolved.
No items of noncompliance or deviations were identified.
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- 6. Open Items Open items are matters which have been discussed with the licensee, which will be reviewed further by the inspector, and which involve some action on the part of the NRC or licensee or both. An open item disclosed during this inspection is discussed in Paragraph 4.b.
- 7. Exit Interview _
The inspector met with licensee representatives (denoted in Paragraph 1) on October 19, December 10, 1984, and January 4,1985. The inspectors sunmarized the scope and findings of the inspection. The licensee acknowledged these findings.
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