ML20151K619

Discusses CW Brown 940920 Interview Re Dow Corning Investigation (3-93-028R) & Forwards Transcript & Related Documents.Suggests That Transcript & Documents Be Forwarded to Ig for Review

ML20151K619
Person / Time
Issue date:	10/03/1994
From:	Paul R NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION III)
To:	Pawlik E NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION III)
Shared Package
ML20151K340	List: ML20151K337 ML20151K387 ML20151K414 ML20151K422 ML20151K475 ML20151K486 ML20151K572 ML20151K601 ML20151K619 ML20151K631 ML20151K650 ML20151K663 ML20151K672 ML20151K723
References
FOIA-97-180 NUDOCS 9708060122
Download: ML20151K619 (19)

Text

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UNITED STATES 1

NUCLEAR REGULATORY COMMISSION l

OFFICE OF INVESTIGATIONS FIELD OFFICE, REGION lil g

301 WARRENVILLE ROAD j

LISLE, ILLINOIS 80632-4361

,,,g October 3,1994 MEMORANDUM T0:

Eugene T. Pawlik, Director, Office of Investigations Field Office, Region III i

Richard C. Paul, Senior Investigator, Office ofs h g [ 4 ]

l FROM:

Investigations Field Office, Region III

SUBJECT:

REFERRAL OF INFORMATION TO INSPECTOR GENERAL On September. 20, 1994, Clayton W. Brown, a consultant with Brand Fire Protection Services (BISCO), Addison, Illinois, was interviewed in regards i

to the Dow Corning investigation (3-93-028R), a copy of this transcript and 2

related documents are attached. Mr. Brown expressed concerns in his interview

{

regarding the NRC staff's handling of his technical concerns related to fire i

]

penetration seals. Brown provided additional documents related to his con-f cerns with the NRC.

It is suggested that Brown's transcript and his documents j

be forwarded to the IG for their review.

t Attachments: As stated l

l I ()L 9708060122 970730 I

PDR FOIA GUNTER97-190 PDR 9*)CVQ(pp y A

~

I o

e October 3, 1994 i

I MEMORANDUM T0:

Eugene T. Pawlik, Director, Office of Investigations Field Office, Region III FROM:

Richard C. Paul, Senior Investigator, Office of

[

Investigations Field Office, Region III 2

SUBJECT:

REFERRAL OF INFORMATION TO INSPECTOR GENERAL On September 20, 1994, Clayton W. Brown, a consultant with Brand Fire Protection Services (BISCO), Addison, Illinois, was interviewed in regards s

to the Dow Corning investigation (3-93-028R), a copy of this transcript and related documents are attached. Mr. Brown expressed concerns in his interview regarding the NRC staff's handling of his technical concerns related to fire penetration seals. Brown provided additional documents related to his con-cerns with the NRC.

It is suggested that Brown's transcript and his documents i

be forwarded to the IG for their review.

Attachments: As stated Distribution:

s/f 3-93-028R g,,-......,,.,..

. sw n..

c - c, -iim

.ti-m/.-i e - c.,, ism.is-nl.=>

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0FFICE OI:RIII e

NAME-RPaul:jh DATE 10/03/94 0FFICIAL RECORD COPY

i APPENDIX A+ TO BRANCll TECllN1 CAL POSITION ' PCSB 9 A

" GUIDELINES FOR FIRE PROTECTION FOR NUCLEAR POW DOCKETED PRIOR TO JULY 1,1976" (AUGUST 7.3e 1976)

His Appendix A provides guidance on the preferred and, where applicable acceptable alternatives to fire protection design for those nuclear power plants for which applications for construction permits were docketed prio to July 1, 1976.

of nuclear power plants:ne previsions of this appendix will apply to the follo (1)

Plants for which application for construction permits were docketed prior to July 1,1976, but have not received a construction permit; (2)

Plants for which construction permits were issued prior to July 1,1976, and operating plants.

This appendix modifies, as deemed appropriate, the guidelines in Branch Technical Position (BTP) APCSB 9.5-1, " Fire Protection for Nuclear Power Plants" which are intended for plants whose application for construction permit is docketed dLfter July 1, 1976.

% e guidelines of the above cited BTP were adopted for this appendix and are preferred in all instances.

i Alternative acceptable fire protection guidelines are identified in this appendix for areas where, depending on the construction or operation status m

of a given plant, application of the guidelines per se could have signi-ficant impact, e.g., where the building and system designs are already finalized and construction is in ptogress, or where the plant is in operation.

These alternative guidelines are intended to provide adequate and accep-table fire protection consistent with safe plant shutdown requirements without a significant impact on plant design, construction, and operation.

Particular sections that are intended to apply only to plants under review, under construction or operating are identified under the appropriate column.

Although this appendix provides specific guidance, alternatives may be proposed by applicants and licensees.

These alternatives will be evaluated by the NRC staff on a case-by-case basis where such departures are suitabl y jus tified.

Among the alternatives that should be considered is the

.~. -

provision of a " dedicated" system for assuring continued safe shutdown of the plant.

This dedicated system should be completely independent of other

- +

plant systems, including the power source; however, for fire protection, it is not necessary for the system to be designed to seismic Category 1 criteria or meet single failure criteria.

the other safety related systems would still be required.. Manual fire fighting

• (

' R is document includes the changes listed in the Errata Sheet dated Hovember 18, 1976, as indicated by a vertical line in the margin.

9.5.1-55 2/24/77 6

day

UT COH5Eddd10N ~'R mr m ---~_.

OPERATitlG P!)dit$

As or 7/1/76

_lectric Cable Construction, E

3.

le Construction, Cable Cable Trays and Cable _

le Penetrations _

Penitiations_

(a) SAME 17 non-combustible materials hould be used for cable tray construction.

(b) SAMb ~

See Section E.3 for fire pro-tection guidelines for cable spreading rooms.

(c) S A!!E. Een safety Automatic water sprinkler systems related cabler, do not (c) should be provided for cable satisfy the provisions trays outside the cable spreading of Regulatory Guide 1.75 Cables should be designed all exposed cables shoul room.

to allow wetting down with be covered with an deluge water without electrical approved fire retardant f aulting. Manual hose stations coating and a fixed and portable hand extinguishers automatic water fire should be provided as backup, suppression system Safety related equipment in the should be provided, vicinity of such cable trays, that does not itself require water fire protection, but is subject to unacceptable damage from sprinkler water discharge, should t

be protected from sprinkler i

l system operation of malfunction.

(d) SAME. Were installed Cable and cable tray penetration of penetration seals are t

f D. 3. (d) fire barriers (vertical and hori-deficient with respect zental) should be sealed to give to fire resistance, thest a

protection at least equivalent td seals may be protected that fire barrier. 'The'83tigd.

by covering both sides

'of fire barriers for horiiontal' with an approved fire l

and vertical' table. trays th6uld, retardant material, l

as a minimum, meet the reigtlitt:-

The adequacy of using l

ments 6f A$tM E-119e "Fite Tatt such materfal should be of Building Construction and demonstrated by suitcbie Haterials, including the h684 testing.

stress test.

(e) SAME Fire breaks should be provided as i

(e) l deemed necessary by the fire

1. "j Flame or flame hazards analysis.

j retardant coatings may be used As l

a fire break for grouped elec-l trical cables to limit spread of (Possible l

fire in cable ventings.

cable derating owing to use of such 3

2/24/77 s

9.5:1-83 l

i f

1 i

l i

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- ~ ~ " ' -

~- '*

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hl E 119 h E 119 e of the specimen.

peccedure with electric sensme elements esa be used

.ind after cooling but within 72 h after its design, and for building columns shall be not j *,f",

'M w"hm fire test completion shall sustain the dead load of the less than 9 ft 12.7 m). Apply the contemplated

'rior to fire test, condition construe-

'['

y i the objective of providing within s' with wood constructions the moisture meter est constructi a plus twice the superimposed details of connections, and their protection if

( e time, as moisture condition within based on the electrical resistance method can be load specified above. The assembly shall he any, according to the methods of acceptable I

nen tpproximately representative of used. when appropnate, as an afternative to the.

considered to have failed the hose stream field practice' eclative humidity method to indicate when wood has

) y to exist in similar construction in atta ned the proper moisture content. Electrical

. if an opening develops that permits a

'est i

For purposes of standardization.

methods are described on pages 320 and 321 of the projection of water from the stream beyond

• dI"E l lition is to be considered as that 19M ed' tion of the Wood Naadbook of ree forest,

the unexposed surface during the time of the 17.I Throughout the fire endurance test i

products Labonrrory. (J.S. Department of Agneut,,

hose stream test-

>uld be established at equilibrium ture. The relationsbps between relative humsdity.

expose 1he column to fire on all sides and I3.l. Transmission of heat through the load it in a manner calculated to develop the.

! from drying in an ambient atmos-and moisture content are given by the graphs,in, l 50 pcrces.t relative humidity'st 73 F Fig. 23 on p. 327. W indicate that wood has n' wall or partition during the fire endurance test oretically. as nearly as practicable. the moister, content e i3 percent at a relative humidity?.t shall not have been such as to raise the tem-r However, with some constructions

• or M penrnt for a temperature of 70 to 80 F (21 to m working stresses contemplated by the desi n.

F i e difficult or impossible to achieve 27 CK 3g pera ure n its unexmsed surface more than Make provision for transmitting the load to 3rmity within a reasonable period of Nors 7-If the moisture condition of the fire.

250 F (139 C) above its initial temperature.

the exposed portion of the column without

! cordingly, where this is the case, g' Q*,,,l;s p,, ( e o a nd I nr sing the effective column length.

test he mpt TesTT or NONaEAalNG Wang Aggy a

, maty be tested when the dampest should be made not later than 24.h prior to the test.,

pum;

..17.2 If the submitter and the testing body I the structure, the portion at 6-in.

. N

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Jomtly so decide, the column may tre sub-depth below the surface of massive tests OF BEAMING WAt.t3 ANo PAmTmg%s 9.M. Size of Saanple jected to 1% times its designed working load i

ons. his achieved a moisture content g g, gg,,,g 3,,,g, 4.1W 14.1.The area exposed to fire shsH be not

""'"'***N l ding to drying to equilibrium with d

less than.100 ft' (9 m'), with neither dimen.

The fact that such a test has been made shall II-po

' range of 50 to 75' percent relative hu-t m'h eith either' dig sion less than 9 ft (2.7 m). Restrain the test n t be construed as having h,ad a deleterious 73

• 5 F (23

• 3 C). In the event d h@

effect on the fire endurance test perfoyance. l mens dried in a heated buikling fail-hese ' req 1irements aner a'12.nionth, shall not be restrained o...n its vertical ed gg, Coedidea of Acceptance ing period, or in the event that the' gwg,,; m.,, n. i.., 4 c$l a i I. Regard t as s fut if the foi-18.1 Regard:the test as successful if the w'

~ hiconstruction is'such' thatnit if t

lire and h,o,se stres,m.ttsts apply a%.

c lumn sustams the applied load during the 1 12.1 nroughour[.,the, fig. de..

i '

oeditions are met:

.....a.

y...

ist 'dryin[of the specimen interioF n

e. wall or partition'shall 'have fire endurance test for a period equal to that i

, supen resented by hermetFsealingi thcac

-nts%sy be-was.ved?except.as.to at-posed 16a'd. to tfie c.on.struction in a man sage of flame. ire endurancelest without pas-f r which classificatio'n. is desired.,. '.[

the f g-

, or gases fiot enough'~to,. ignite At.TEmwanva Test.~or Pa'onctioE po'a'.

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of.a large portiors of final strenpi,d as practicable,#

,the;w. rbng. stresses c cotton waste, for a period equal to that for e

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epeciihen'leisted"in t6e 'coWdition an pgn.g@ouble $ ma

'fassification is desire'd.

hen exists.

.-."..P88 plated by x

PP eadom' " *C b-O' V'

e1 wall [o'rjartiti' n'sia"It have

.il u

A FF7 euremidhiisningr%4be lested either.with escli sidi ad'ed wi o

" fire l aiid hose s'trenar test.as19.leTitisdeEp'rM$ urn Nes not rekvire it appeartd'sira6Forf fa n==-ya or beh sides together.

e specified in Section ~9,'without passage"of column l'oading at any time' and ma'y be used oererstedMtyinfficihiiireessoimientheo be recorded' a 4. y T

flame, of gases hot'criough to ignit9 cotton at the discretion of the testing la6 oratory to

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ilitp o6tbatlab6ratory m ' %%

w.os. h u posed, wasse, or.of the hose stream. The assembly evaluate steel coluren pr'otections tha':are not void

' _ z N nuillr sigdfid!

t aner it kan failed.f+in be transferred to the shaR be considered to. ha,vc ; failed the hose required by design to carry any of the column eccthem seractusskrom lism enduranceg pased sist... " 7

"" % 5/-

"y stream, test if an' opening,iTrom the[ stream dtvelops that"per-load, e-t

+.e

.e sticwo,the-specimen.os:beth froma y

]{ ],}

mita a projection ('of wate withprocedunnghemia,lRI'.1%..s

' 13.1, ~Rtpid the testias haccessful if the beyond;the unexposed surfade derm, glhe{ time 2g. Sise and Chawof Sayne F

ducesh nothesivamis6 aEdrying_ia.ag, of the hose'sdeam St."g Q.

~20.1 The sirrof the steelacolamn used shall

^

WithM2 h prior to.the fire test ins lowin2 conditions'aretmec %: 4 n'4 ggy,,,.;;,,;,g

,,,g g,p.. ; g. g be such as to provide a test specimen that is ron the actual moisture content and.

13.1.1 De well or partition shall have

y truly representative of the ' design, materials.

m.

,n-withinithe specimen:shan beetA t,ained the s'pplied load dunng'llie ff're- -

' perm;;Q;p,;,g,M,,,,,p~

-shan um have M W.-

- and workmanship for whicir' classification is l

icludesthisiinfonnation int the test, ancz test 4without' passage of. flame.on' desired. Apply the protection acconting to the ote'7)T 00 v T m h ar W n M n hot en6 ugh-to ignite 1 cotton, waste,.for?

3 pen a n v

methods of acceptable efield practice, -De j,..r..

,,r. w. m. v. Ng.g, riod equal to that forwhn. classification es i

length *~of the'protectedicolume shall' be se

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,;43.M: rim 3ra :s bebrd sm 1

. TESTS or CowMN3 i Tt e i r3

,c.,, gener,{e,,,,,,g elements ic r!3;I:2 'Ilie wall'or partition shall-bave.

least' 8 fM2.4'm). Tisetolumn shsE be vertical a Appendia I of the paper. by Mad m tained the applied loadiduribgithe fire

16. see erSasapto.nw mmr J. during dpplicatids-of the9pictectiondand during t!Ie file exposiere;r unc ;-~ i. Wec Methed,for Determiaing thepoistum hose. stream.testoms specified<in. Section:

el6.line length of the column, exposed.to

' 20.2* Restrain > the' ap' lied protection t

p

~

)"

• [n

' g-without passage of flameg of gases hot eno fire dall/when practicablef approxistate the against' longitudinal' temperature expansion TEA,' Vol 55,1955. p*l085. A similar to ignite cotton waste, or of the hose st maximium clear length contemplated by the greeter than that of the steel' column by rigid

~

s July 10. 1991

• This Document is for Use As A Genera 1 Guide l

Test Criteria For Electrical Ctreuit Protective Systmas

• Condition of Acceptance -

And Other Generally Related Criteria l

Standard Fire Endurance Cfreuit inteority hemerature tielt Hose Streapr T6 mwle placement Other Criteria 1

NRC

• 1 hour or 3 hour3.472222e-5 days <br />8.333333e-4 hours <br />4.960317e-6 weeks <br />1.1415e-6 months <br />.

Not speciftod

• 250*F above ambient Not specifically Q/A 3.2.1 of Enclosure 2 Final Appendix 15 as required (Source:

or justification should specified of S.L. 86-10:

Rule pubits5sd ort Section III.G.2 of be provided for material (1) Reference to NFPA 251 Novester 19,1988 i

i Appendix R to 10 CFit which exceeds this tangera-on unexposed surface.

discusses the Part 50 and the ture (i.e., analysis demon-(2) Reference to staff technical basis Standard Review Plan strating the maximuur recorded position for electrical for fire barriers 9.5-1 Revision 2.

temperature (w/in the fire cenetration tests -

as rated for f tra-July 1981).

barrier enclosure) is suffic-temperature on the unex-resistancer by tently belom the cable insula -

posed side (

TC).

being exposed to lation ignition temp).

a stenderti test References-NFPA 251 (Source:

fire defined by Question / answer (Q/A) 3.2.1 of ASTit E-119-.

Enciesure 2 of Generic Letter

" Standard for Fire 86.10).

Resistance of' Saildtig fmurials '*

ANI 1 hour1.157407e-5 days <br />2.777778e-4 hours <br />1.653439e-6 weeks <br />3.805e-7 months <br /> or I hour.

• Fatlure if circutta Not spectffed

. t 1/2* playptpe On surface and at (1979) as required fell or fault during.

w/11/S* tips at L* Intervals in the test or during hese 20* and 3G PSI cable systee.

i strueur test.

. L 1/2" norzle at 30* at 5* and 75 PSI at 75 GPW

. L 1/2" nozzle at 15 at 10' ard 75 PSE at 75 GPW Apr L hour or I hour..

• M1 cables energtred.

Not specified

. 2"1/2* playptpe Orr surface and at (1967) ae required Caklam fatI 11" ctreuits:

w/L 1/8* tip at l' intervals in the fat 1 or fault during test 20' and 33 PSI cable syntaa.

or during home stroenn teet.

11.L.

L hour or 3; hout,

" Circuit integrity of" Not specified:

_ L 1/Z'" tip at 211*

Orr the interior of the Tlactr131Cirtaatt Std as required insulated electrical

. at a pressure te enclosure at the dis-protectivesystee 1724 condectors withtre the he detereined cretton of the testing shall russier intact pewtective system shall body.

during the fire her maintained during the and hose streme external fire==Pa=ure tant withat mW test, dering ther move to ing any openirg the water honor streme aro*

thru theelectrimi and during the home stree" andcaron runeap test.

that is visible.

9

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V C

u D

m m

l ASTM

• Fire stop shall Not specified Not spect'ffed

• 2 1/2" hose. I 1/8" At a sintenue. eight

' i j

E-814 have withstood the tip at 20' different locstions.

(F fire test for the

• During hose strees rating) rating period with-test, the fire stop t

(thru out permitting the shall not develop any i

t pene-possage of flame thru opening that accid per-tv openings of the ett a projecticr of tiorr occurrence of fleeing water from the strees Fire art any element of the beyond the unexpoemd 5 tope) unexposed fire stope.

side, t

I (T

Same as F Rating Not specified

• 325*F above its initial Same as F rating Same as F rating rating) temperature shall not be (Thrs reached arr any thermocouple p,snetre.

ort the unexposed surface of tion the fire stop or ort any Fir,

penetrating, itser.

Stopa) 1 NFPA

• The test specimarr Not specified

• 250*F above its initial For 1 hour1.157407e-5 days <br />2.777778e-4 hours <br />1.653439e-6 weeks <br />3.805e-7 months <br /> specimarr -

At a mininess, nine Temperature end point of 25L shall have withstood temperature arr itz Z' 1/2" hose. L 1/8- '

different locations the fire endurance period (Build-the fire endurance unexposed surface.

tip at 30 PSI for i shall be determined by try test without passage minute at 20*.

theaverageof thesmesure-constr-of flamar or gases hot monts taken at individual uctiorr enouger te Igrrite cottart points; except that if a and weste, for a periosi temperature rise 30Y. Irr mater-equel to that for dictt excess of the specified isla) classificatiore le limit occurs at any oneof destrut.

these potnts, the fire eukrancer period is judged as ended.

ASTpp

• Sume as NFP4 25L Not specified

'Same as NFP4 25L

• 3ame as ASTW E-814

• Same as NFPA-25L E-119 (8stid-Ing; com-struc-tioe and:

materials).

IEEE

• Phasedsif'ne poes-Not specified

• Neet througir the fire stopo L 1/2'" hose. 3G-

1. urininess at" 3) therino-STE agar of flame or gases shelf not raise the tempers-norrle. 75 PSL at couples shalT be located 63 4 hoc enougteto ignite ture on its uW surfacer 75 GPW for r 1 orr the surface of sectr fire (Cat:1e ther catale or other firm above the self-ignition temo-einutes/10E ft.[of stos under-test. Temperature pene-stop material our the ereture of the outer cattle test slair at IS".

shall bemeasured at thecable i

tre- ~

up-pa==* side for a covering the fire stao

• Fire stop shall jacket fire stop interface.

tiene period squel to the meterial. or material te have eithstood the interface betweerr fire stop r

Fire regaired fire rating.

contact wtir the fire step.

hose streme to e and thrts metallic components.

I Stope)

For pomer-generating; stations wethout the hoser the nestinese temperature is streme causing ass 70S*F.

opening thru, the test specimest.

r

..--~_-..-.,.,-.~-x.--

e e

a a*

e

( '

,..-~ - u k ' '[I tI( f Cil rem fiPE SEA L OVERVIElf 0F FIRE TEST PARAMETERS j

HAXIMUM THERMOCOUPLE STANDARD TEMPERATURE LOCATION (S)

NOSE STREAM j

(1)

(2)

(3) j ANI 3250F+

SURFACE 1%" N0ZZLE 1%" N0ZZLE 2%" HOSE AMBIENT 300 ANGLE 150 At:CLE 1 1/8" STANDARD TAPER TIP 75 PSI 75 PSI 30 PSI 75 CPM 75 CPM 20 FT.

4 5 FI.

10 FT.

4 i

NHL 2500F SURIACE 1%" N0ZZLE 300 ANGLE 75 PSI l

75 CPM 10 TT.

f.

ASTM AMBIENT 1 1/8" STANDARD TAPER TIP 2500 +

SURFACE 2%" HOSE p,

g.

g (E-119) l I

30 PSI 3

20 FT.

i

.IEEE 7000F SURFACE 1%" N0ZZLE (634)

SEALANT / CABLE 300 ANCI.E

[3 i

INTERFACE SEALANT / CABLE 10 FT.

3 INTERFACE j

t, (1)

,o p (2)'

QR (3) 2 NRC 3250F SURFACE '

1%" N0ZZLE 1%" N0ZZLE 2% HOSE i

(

- (PI.C 0800) 300 ANGLE 150 ANCLE 1 1/8" STANDARD TAPER TIP g

, ')

75 PSI 75 PSI 30 PSI e

75 CPM 75 CPM 20 FT.

9.v-, l ',

SRP 91sy \\

NOTES:

i The average of thermocouple reading shall not exceed 2500F.,

if any readin reason shall ge investigated and documentedexceeds the minimum average by 301 the 3

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..c U.S. NUCLEAR REGULATORY COMMISSION f) STANDARD REVIEW PLAN

/

OFFICE OF NUCLEAR REACTOR HEGULATION Pe //

l'"

V l2. -- I 3 3;

'h.'i.1 FIRE PROTECTION PROGRAM L

r.EVIEW RESPONSIBILITIES I

. Primary - Chemical Engineering Branch (CHEB) i' Secondary - None I.

AREAS OF REVIEW

~

a The purpose of thn fire protection p'ogram (FPP) is to hrovide assurance, through

/1 r

a defense in-depth design that a fire will not prevent the performance of necessary safeplantshutdownfunctIonsandwillnotsignificantlyincreasethe~riskof radioactive releases to the environment in accordance with, General Design

" Criteria 3 and 5.

l The fire protection program consists of fire detection and extinguishing systems and equipments'administrathe controls and procedures trained personnel,.. f',,

,.e L.L '. e and 7

s rq, io. a e. -

I-p pc ir.

The CHEB review of the fire protection prograhi includes a review of the evaluation of potential fire hazards descrioed in the applicant's safety Analysis Report

'5ARi (lo.dng f.he syst'!m characteristics and layout which define theand a review of the d s

fire. prevention" and " fire protection" portions of the program.

The CHEB reviews the total fire protection program described in the appitcant's Safety Analysis Report (SAR) with respect to the criteria of Branch Technical Position CMED 9.5-1 attached to this SRP section, specifically with respect to the following:

1.

Overall fire protection program requirements, includin

. involvement and assigned responsibility of management;g the degree of fire rotection administrative controls and quality assurance program; fire rigade training activities and coordination with offsite fire fighting organizations.

Including their capability in assisting in the extinguishment of plant fires.

4 2.

Evaluation of potential f're hazards for safety-related areas throughout the i

plantandtheeffectofpostulatedfiresrelativetomaintainingtheebgity Rev. 3 - July 1981 USNRC STANDARD REVIEW PLAN stre.derd review ptens are prepared fo* the guldence of the office of hvet*** Resetor flegulation etstf eesp6ntible icir the envie Ct plications to construct and operate nuclear power plentJ. These documents het enede evellette to the putilk st %et of the Ce nmission's policy to inform the nucleet industrv and the genovel public of tegulatory proceduras and pe:lses Stende:d review i etns see not substitutes for reguletory guides ce the Commission's tegulations and compliance

.tr.nderd review plan sections ese 6 eyed to the Stendeed Format and Content of safety Analysle fbports for @ <est Power Pleats.with th Mt Ett sections of the Stendeed i, emot have e conesponding soview plan.

'tished stenderd review plans will be tovised 3,aglodically, es appropriate. to accommodate L.sn. moms and to eaffect c:tw it. forms-md espeelence,

\\

nts and suggestions for lar peoveer ant will be considstad 6nd should be sent te the u.s Nr:1.or I*s tanc'y Commissioq 8 Nucteet Reactor Regulatio't. Wesfiington. o.C. 20%$.

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e.

Test and Test Control A test program should be estabitsbed and implemented to ensure that testings performed and verified by inspection and audit to demonstrate conformance with design and system readiness requirements.

The tests should be performed in accordance with written test procedures; test results should be properly evalu-ated and acted on.

J f.

Inspection, Test, and Operating Status Measures should be established to provide for the identification of items that have satisfactorily passed required tests and inspections.

g.

Nonconforming Items Heasurer should be established to control items that do not conform to specified requirements to prevent inadvertent use or installation.

h.

Corrective Action Measures should be established to ensure that conditions adverse to fire protec-tion, such as failures, malfunctions, deficiencies, deviations, defective compo-nents identlffed, reported,andcorrected. uncontrolled combustible material and nonconfor j

)

}

1.

Records Records should be prepared and maintained to furnish evidence that the criteria enumerated above are ooing met for activities affecting the fire protection program.

J.

Audits Audits should be conducted and documented to verify compliance with the fire 3

protection program, including design and procurement documents, instructions, procedures and drawings, and inspection and test activities.

5.

General Plant Guidelines l!

a.

Building Design Ii (1) Fire barriers with a minimum fire resistance rating of 3 hours3.472222e-5 days <br />8.333333e-4 hours <br />4.960317e-6 weeks <br />1.1415e-6 months <br /> should be provided to:

j (a) Separate safety related systems from any potential fires in nonsafety-related areas that could affect their ability to perform their safety function; (b) Separate redundant divisions or trcins of safety-related systems from eachotharsothatbotharenotsubjecttodamagefromasinglefire; (c) Separate individual units on a multiple-unit site unless the require-i ments of General Design Criterton 5 are met with respect to fires.

(2) Appropriate fire barriers should be provided within a single safety division to separate components that present a fire hazard to other safety-related g

9.5.1-28 Rev. 2 - July 1981

components or high concentrations of safety-related cables within that division.

- (3) Openings through fire barriers for pipe, conduit, and cable trays which separate fi'e areas should be sealed or closed to provide a fire resistance rating at least equal to that required of the barrier itself.

Openings inside conduit larger than 4 inches in diameter should be sealed at the fire barrier penetration.

Openings inside conduit 4 inches or less in 4

diameter should be sealed at the fire barrier unless the conduit extends at least 5 feet on each side of the fire barrier and is sealed either at both ends or at the fire barrier with noncombustible material to prevent the passage of smoke and hot gases.

Fire barrier penetrations that must maintain environmental isolation or pressure differentials should be qualified by test to maintain the barrier integrity under such conditions.

r-Penetration designs should utilize only noncombustible materials and should be qualified by tests.

The penetration qualification tests should use the time-temperature exposurs curve specified by ASTH E-119 " Fire Test of Building Construction and Haterials." TheacceptancecrIteriaforthe test should require that:

($)(The fire barrier penetration has withstood the fire endurance test without passage of flame or ignition of cables on the unexposed side for a period of time equivalent to the fire resistance rating required ofthebarrier]

Y (b)( The temperature levels recorded for the unexposed side are analyzed and demonstrate that the maximum temperature does not exceed 325 F.

(c)[Thefirebarrierpenetrationremainsintactanddoesnotallowprojec-tion pf water beyond the unexposed surface during the hose stream it Q H

J.

test.,The stream shall be delivered through a 1-1/2-inch nozzle set at a illscharge angle of 30Fwith a nozzle pressure of 75 psi and a minimum discharge of 75 gpm with the tip of the nozzle a maximum of 5 ft from the exposed face; or the stream shall be delivered through a 1-1/2-inch nozzle set at a discharge angle of 15% with a nozzle pressure of 75 psi and a minimum discharge of 75 gpm with the tip of the nozzle a maximum of 10 ft from the exposed face; or the stream shall be delivered through a 2-1/2-inch national standard playpipe equipped with 1-1/8-inch tip, nozzle pressure of 30 psi, located 20 ft from the exposed face.

(4) Penetration openings for ventilation systems should be protected by fire dampers having a rating equivalent to that required of the barrier (see NFPA-90A, " Air Conditioning and Ventilating Systems").

Flexible air duct coupling in ventilation and filter systems should be noncombustible.

(5) Door openings in fire barriers should be protected with equivalently rated doors, frames, and hardware that have been tested and approved by a nation-ally recognized laboratory.

Such doors should be self-closing or provided with closing mechanisms and should be inspected semiannually to vu ify that automatic hold-open, release', and closing mechanisms and latches are operable.

(See NFPA 80, " Fire Doors and Windows.")

One of the following measures should be provided to ensure they will protect the opening as required in case of fire:

9.5.1-29 Rev. 2 - July 1981

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SU4 4ubl APPENDt)( Qg W R:gulatory Comm,es,un Appenom g MPENDix D-UNeTED STATES NUCLEAR REGULATORY COMerSS10N RE art Teesphone ans mi h h i47.

Teaurluh12g

~

,9 UsNRC. 431 Part Avenue. King et (216) 337-5000 d'huen Addresses (24 honas) fort h**P=ur* 14e" en NcseI5e 100 Tegu,g g3,%'7---

Teg,iun>13 ip g, {

secag '

100 Tertieunkte0_ -_

5 t Dyrectm, Delamerk Diaszt of Colurntze. Mame.

- New Hampshre. New.lersey New Prussa. PA 16408 (FTS) 488-1000 Ahohdum03ra-hemup200_ _

,Gehunt -

• g' ppj

, m pesugeverse. Rhode taland, and VerenonL USNRC. 101 naanena Street. NW (404) 221-4W NioMuses __

N M20 3_,,,,,,

g a Ashame. Flunds.Georjipa, Ken 8ucky Mas @pi. North Sune 2900, Atienta. GA 30323 (FTS) 242-aSc3 Neotegergy,,,

202_ _-

g Puuno Aca. Sonah Carohrq. Tennessee. vegrna.

conuun165

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i ap asarunk and wens wprum USNRC. 799 Roosves Road. G6en Q12) 790-5500 g;

onnmn seis 128 ontruun ies~

"'* 170 --

g a usuza, t.ufiana. towe. uctugan, uinnesota. ussoun, g

Etyn. IL 60137.

(FTS) 386-5500 pp,cor gut USNRC,611 Ryan Plaza Dr:de. Sune (817) 86o 4 100 oenuum iss 100 Thuhur*171 5 w. AAansas. Conosadct sdeho. Kansas. taseana uan.1004 m TX NH CS) 72s+00

.,g)

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,g m ahmasta New Memet Norm Dahda. ok4hona Sadh Panadmnmiog D

(g ed Ph%37}

]

T1$~

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. asmaaTean utan end wyonuna USNRC. Region IV Uratsum Recovery 0 03) 234-7232 1

- - 1st ____

Plannurm m

unest=*ier _ __,,_

g

- gy Runs 0".=

^*=nuaies 10 yungsse,6185._ _

g, F,sid cenc 73o s.mm. Sireet.

(FTs> 234-7232 g

P o Bom 26325. Denwer. Co 80225 Cc Piannu,,,m,3

~

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USNRC.1440 64ans Lane, Sune 210.

(4:5) 943 3700 g

- ~ _

Gupa W Ah A:uona. Cahtcarma. Hamar Nevada, oregon.

Weinut Caeen CA 94596 (FTS) 443-3700 H

Plannurn197 ~~

V

-~

33' - - -

~ ~ ~ - ~ ' - - -

3 Plahnum 197 amas Taas Yerreenes. and wasnsngton.

PkApruuN239 34-Urannm*2[~~~~'~~--.

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U IE47023+08C 7.I900I Xenon.133 ~

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s GENEnat Paovistows Praseodymann 343 Pmn=em,* m.~

varo,. 90, -

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-PART 21-REPORTING OF DEFECTS ygrkr*

=.

he Promeeuu,5947

~^--~

- ~~~~-

L AND NONCOMPLIANCE a 21.1 Purpose.

on The regulations in this part estab-Zric-69rr[

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OrutaAL PaovistoNS lish procedures.ad requirements for t

Rhoeur*103m -

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implementation of section 206 of the

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100 tab 2'Consum.

El h rpose Energy Reorganization Act of 1974.

Ruthaursey' N

~

Rumen=,*siZ"~~

E2 pe That section requires any individual a

gg director or responsible officer of a "gacha 0

~ - ~ - ~ ~ ~ ~ - -

100 it

%,n,,,,,,lg,3 ----

• ' **ha *nmes or urw,,,,

• • i SA Interpretations.

firTn constructing, owning, operating A

Rumen=nb ioe __ _ '~--~ -

,j

~7

_m h'

B3 r%rnmunications.

or supplying the components of any

^"'

'**'**cW oei= C]e'~% or

' ~ - - - - -

8

- ~ ~ - -

• n=tns

• EA l'osting requirementa.

facility or activity which is licensed or Ms

____ Z.

• aot hstad anov "3"

80 e,

• """*'* of ur*no.n ce,,,,,,,'~~~'

11 Exemptions.

otherwise regulated pursuant to the i

~ ~ _ _ -

1 33 Information collet.tton requirements: Atomic Energy Act of 1954, as amend-(

scamnu,.47.

,y

• • ana.d.n,,n, W***" 'au at rh 232. Tue.g scaa*u=4a __, _,_ ~~' --~__

OMB approval.

e' aM"*D'o*

ed, or the Energy Reorganization Act i

s.6co,"I~'-~~

'_'JZ~~~-

to to nas

• • • **n'=ormma rate ce naas. g24 auf NoTtrication of 1974, who obtains information rea-

--~~__.._T';~--

s.ver.ios

~

sonably indicating- (a) That the f acili-soo seu.,.no,C ; ;,' '~ 1 Z Z Z ~ -

121 Nottf1 cation of failure to comply or erfstence of a defect.

ty, activity or basic component sup-

','g Non por purposes of '

plied to such f acility or activity fails to se svaneum-a'

~-- -.- iZ7 ~-

suonnum4,5 '7 - --

___.Z he is involved a combi

1. 1. ' O",,'

Paomnum hums comply with the Atomic Energy Act of to 80 swannum.80,,_7 _ - --. -~~_._

on'n amounts, the !!m t to 1954, as amended, or any applicable mine, f$r e d be derived as fol 131 Procurerr:ent documents.

rule, rcgulation, order, or license of

"*""h 2'.-.C"_ ~~

as s

'o the ratio be D' In the combg the Commission relating to substantial

, Ten'akewisi'~Z"~ ~~~ ~._"ij the combinatio U1e quante present in 8

suen#3s_ ~

safety hazards or (b) that the facility,

,tabIlshed for the s ffe 33oC other 1ae em 141 Inspeedons.

activity, or basic component supplied rec %,88;--.2.~~' ZZZ7~ -

ic en amt Ekl Maintmance of records.

n combination. The sum d such radas far to such facility or activity contains de-recnne u

,7 -~~ -_. f to

[ceed the isotopes in W %

hacum fects, which could create a substantial Tecnn. nun,.eCZ- -~~ -_.- _C

,'m8 I" (8.e ~ unity").

n may ass,

safety hazard, to immediately notify 7

7 to the Commission of such failure to m

XJI Pallure to noufy.

,Teamuni27.Z, C - -- __ ~.~

,'o %

642L Apr. 22,1970. a.,

Aeraoarm Secs.1611 and 161o Pub. L reau,,,,,,,, -- -

comply or such defect, unless he has 88 38

• E403, 68 Stat. 949 and 950, as amended,

24. IN8 Aug. 28.1972: 38 FR actual knowledge that the Commission

'***129m ~~._. __ Z Z " --

too est 334. Pub. L 91-181. 83 Stat. 444; seca.

992 June 28.1974; 4'S E8 and 206. Pub. L 93-438. 88 Stat.1242 has been at:equately informed of such

~~

'O 71763. Oct. 3 188 0 ta61346, as amended (42 U.S.C. 2201(1),

defect or failure to comply.

W iton,2282.5841.5846).

Bocact 42 FR 28893, June 8.1977, unless I 21.2 Scope.

" "Ot*d-The regulations in this part apply, except as specifically provided other.

272 273 J

$ 21.5

{2L3 10 CFR Ch.1 (1-185 Editirn)

Nuclxt hgulxtsry Ctmmissun ation could create a substant!al safety wise in Parts 31,34,35,40,60,61,70, 146 FR 58282 Dec.1,1981 as amended at 47 (b) " Commission" means the Nucle-hazard.

or 72 of this chapter, to each individ. FH 41338. Sept. 20.1982; 47 m 57480. Dec.

ar Regulatory Commission or its duly (h) " Operating, or,operat 27,1982; 48 FR 44173. Sept. 28,1983) ual, partnership, corporation, or other authorized representatives.

means the operation of a facility or (c) " Constructing" or " construction" entity licensed pursuant to the reguia-the conduct of a licensed activity a 21.3 Definitions.

tions in this chapter to possess, use means the design, manufacture, fabri-and/or transfer within the Unitect As used in this part.

cation Macement, ere h part and con uit g se ic r lat A

States source material, byproduct ma-(a)(1) " Basic component," when ap-ti n, godihcation insac ivity 'which is ed to operations that are important to on terial, special nuclear material, and/or plied to nuclear power reactors means I"#

1ations in this part safety.

spent fuel, or to construct, manufac-a plant structure, system, component ices related to the (1) " Procurement document" means ture, possess, own. Operate and/or or part thereof necessary to assure (1) transfer within the United States, any the integrity of the reactor coolant t vit hat are important a contract that defines the require-ments which f acilities or baric compo-Dedication" of a commercial nents must meet in order to se co production or utilization facility or in-pressure boundary, (11) the capability dependent spent fuel storage installa-to shut down the reactor and maintain tion. and to each director (see it in a safe shutdown condition, or (iii) rade item occurs after receipt when ered acceptable by the purcLaser, (c

(j) " Responsible officer" means the 5 21.3(f)) and responsible officer (see the capability to prevent or mitigate fhat item is designated for use as a president, vice-president or other indi-i 21.3(j)) of such a licensee. The regu-the consequences of accidents which basic component.

vidual in the organization of a corpo-lations in this part apply also to each could result in potential oilsite expo-(d)" Defect" means:

individual, corporation partnership or sures comparable to those *ferred to (1) A deviation (see i 21.3(e)) in a ration, partnership, or other entity other entity doing business within the in i 100.11 of this chapte' basic component delivered to a pur-who is vested with executive authority chaser for use in a f acility or an activi-over activities subject to this part.

(k) " Substantial safety hazard" United States, and each director and (2) " Basic component ~ -

t applied responsible officer of each organiza-to other facilities and wa E.,Ipplied to ty subject to the regulations in this means a loss of safety function to the part if. on the basis of an evaluation i 2L3(g)), the deviation could extent that there is a major reduction tion, that constructs (see 121.3(c)) a other activities licensed pursuant to create a substantial safety hazard; or in the degree of protection provided to production or utilization facility,11-Parts 30. 40. 50, 60, 61. 70, 71, or 72 of (see censed for manufacture, construction this chapter, means a corrsonent*

The installation, use, or oper-public health and safety for any facili-(2) or operation (see i 21.3(h)) pursuant structure, system, or part thereof that ation of a basic component contalning ty or activity licensed, other than for to Part 50 of this chapter or an inde' is directly procured by the licensee of a defect as defined in paragraph (d)(1) export, pursuant to Parta 30, 40, 50, pendent spent fuel storage installation a facility or activity subject to the reg.

60,61,70,ll, or 72 of this chapter.

of this section; or for the storage of spent fuel licensed ulations in this part and in which a (3) A deviation in a portion of a fa-(1) " Supplying" or " supplies" means cility subject to the construction contractually responsible for a basic pursuant to I art 72 of this chapter, or defect (see i 21.3(d)) or faildre to supplies (see 1 21.3(1)) basic compo-comply with any applicable regulation permit or manufacturing licensing re-component used or to be used in a fa-tivity licensed, other than for export, in this chapter'sion could create a sub-quirements of Part 50 of this chapter cilitt or activity which is subject to

..ents (see i 21.3(a)) for a facility or ac-order or !! cense issued by the Commis provided the deviation could, on the the regulations in this part.

under I arts 30,40,50,60,61,70.71,or 72 of this chapter. Nothing in these stantial safety hazard (see i 213(k))" n' basis of an evaluation, create a sub-(42 FR 28893, June 6.1971; 42 FR 36803, (3) In all cases '. basic component" i stantial safety hazard and the portion July 18,1977, as amended at 43 FR 48622.

regulations should be deemed to pre-cludes design, inspection, testing, or of the facility containing the deviation mt. to.1978; 46 m 58283 Nc.1. m M ciude either an individual or a manu-consulting services important to safety has been offered to the purchaser for facturer/ supplier of a commercial that are associated with the compo-acceptance; or grade item (see i 21.3(a-1)) not subject nent hardware, whether these services (4) A condition or cir matance in' 0 21.4 Interpretations, to the regulations in this part from re-are performed by the component sup-volving a basic component that could Except as specifically authorized by porting to the Commission a known or plier or others.

contribute to the exceeding of a safety the Commission in writing, no inter-suspected defect or failure to comply (4) A commercial grade item is not 4 timit, as defined in the technical spect. pretation of the meaning of the regu-and, as authorized by law, the identity of anyone so reporting will be with. part of a basic component until after fkations of a license for operation lations in this pa"t by any officer or dedication (see 121.3(e-1)).

issued pursuant to Part 50 of this employee of the Commission other held from discusure.i (a-1)

" Commercial grade item" chapter.

than a written interpretation by the means an item that is (1) not subject (e) " Deviation" means a departure General Counsel will be recognized to from the technical requirements in.

be binding upon the Commission.

i d$1

'] to design or specification requirements cluded in a procurement document i

1 o

telep one cal fo that are unique to facilities or activ!-

speak to NRO representatives concerning ties licensed pursuant to Parts 30,40, (see i 21.3(1)),

a 21.5 Gmmunications.

nuclear safety-related problems. The loca.

(f) " Director" means an individual, Except where otherwise specified in tion and telephone numbers (for Sight and 50, 60,61,70,71, or 72 of this chapter holidays as mell as regular hours) are listed and (2) used in applications other than appointed or elected according to law, below:

facilities or acthities licensed pursu-sho is authorized to manage and this part, sll communications and re-direct the affairs of a corporation, porta concerning the regulations in partnership or other entity. In the this part should be addressed to the R

ant to Parts 30,40.50,60,61.70,71,or 72 of this chapter and (3) to be or-case of an individual proprietorship, Director, Office of Inspection and En-il Pttanta.. Z i4 1 22 503 dered from the manufacturer / supplier

" director" means the individual.

forcement, U.S. Nuclear Regulatory tri (Cheagal -.. (312) 790-5500 on the basis of specifications set forth Commission. Washim;bn D.C. 20556, IV (Deas). _...... (si7)s60-aico (g) " Evaluation" means the process or to the Administrator of a Regional in the manufacturer's published prod.

acconiplished by or for a licensee to iV Uranium Recovery Field Offee (Denver)-. (ac3) 234-7232 uct description (for example a cala.

determine whether a particular devi-Office at the address specWed in Ap-V (San Francisco).

. (415} s43-3700 log).

274 275

9 21.51 Nudar Rguirtny Crmminixn (viiD Any advice related to the 10 CFR Ch. I (1-1-85 Editien)

{2M at to the licensing reqvrements defect or failure to comply about the pendix D of Part 20 of this chapter. this part to the Office of Management

'under Parts 30,40,50,60,61,.0,71,or facility, activity, or basic component c

Communications and reports also may and Budget (OMB) for approval as re-72 of this chapter. The abwe notifica-that has been, is being, or will be given be iv red in pe n at the Commis-QUred by the Papeework Reduction tion is not required if such individual to purchasers or licensees.

t f 1980 (44 U4C. 3501 et seq.).

has actual knowledge that the Com.

(4) The director or responsible offt-Varhington, DC-at 7920 o

OMB has approved the information mission has been adequately informed cer may authoriz.e an indlyidual to el Office at the locatlon specified t nder control number 3150-of such defect or such failure to provide the notification required by Avenue, Bethesda."Md'; or at a Regi He n requirements contained in this this paragraph, provided that, comply $ltial notification required by shall not relieve the director or re-Appendix D of Part 20 of this chapter-5.

(2) Ir (b) The approved information collec-this paragraph shall be made within sponsible officer of his or her responsi-8 21.6 Posting requirements.

u n requirements contained in this two days following receipt of the infor-bility under this paragraph.

(a) Each individual partnershi part appear in Id 21.21 and 21.51.

mation. Notification shall be made to (c) Individuals subject to paragraph poration or other ent'ity subiect 149 m 19624. May 9,10841 the Director, Office of Inspection and (b) of this section may be required by regulations in this part, shall post cur.

Enforcement, or to the Administrator the Commission to supply additio.'al of a Regional Of fice. If initial notifica. information related to the defect or rent copies of the following documents NOTIFICATION in a conspicuous position ort any prem.

tion is by means other than written failure to comply, ises, within the United States where NoMeation of failure to comply communication, a written report shall (42 m 28893, June 6.1971, as amended at the activi les subject to this part are or "istence of a defect.

be submitted to the appropriate Office 48 m 58233, Dec.1,1981; 47 m 57480 Dec.

(a) Each individual, corporation, within 5 days after the information is conducted (1) t'c regulations in this 27,19821 part,(2) section 103 of the Energy Re.

partnership or other entity subject to obtained, Three copies of each report organization Act of 1974, aad (3) pro.

the regulations in this part shall adopt shall be submitted to the Director, PaocuazuzNT DOCUMENTS cedures adapten pursuant to the regu.

appropriate procedures to.

Office of Inspection and Enforcement.

(1) Provide for: (i) EvaIuating devi.

13J The written report required by 8 21.31 Procurement documents.

Ittions m this part.

(b) If posting of the regulations in this part ur the procedures adopted ations or (ii) inforrning the 11 this parsgraph shall include, but need Each individual, corporation, part-not be limited to, the following infor-nership or other entity subject to the pursuant to the regulations in this purchater of the deviation i ord '

that the licensee or purchaser sna mati n, to the extent known' regulations in this part shall assure part is not practicable, the licensee or cause the deviation to be evaluated (1) Name and address of the individ-that each procurement document for a firm subject to the regulations in this ual or ind!.viduals informJng the Com-facility, or a basic component issued unless the deviation has been correc.'.

part may, in addition to posting sec-by him, her or it on or after Jancary tion 206, post a notice which describes ed; and mission.

(ID Identification of the facility, the 6,1978 specifies, when applicable, that the segulations/ procedures. including (2) Assure that a direct f tif

~

21 activity, et the basic component sup-the provisions of 10 CFR Part the name of the individual to whom sible offletr is informed reports may be made, and states where struction or operation of a facil t

• plied for such facility or st.ch activity apply.

activity, or a basic component suppff within the United States which fails to they may be examined-

c) he effective date of this section for such facility or activi;.

comp y w c n a ns a deE INarscrIows, Rzcoans been deferred until January 6.

(D Falls to comply with the Atomic (11D Identification of the firm con-structing the facility or supplying the

, g,

Energy Act of 1954, as amended or any applicable rule, regulation, order basic component which falls to comply Each individual, corporation, part-9 21.7 Exemptions.

or license of the Commission relatin r c ntains a defect.

nership or other entity subject to the The Commission may, upon applica-to a substantial safety hazard

• o UV) Nature of the defect or failure to regulations in this part shall permit comply and the safety hazard which is duly authorized representatives of the tion of any mterested person or upon (1D Contains def created or could be craated by such Commission, to inspect its records, its own imtlative, grant such exemp-date of this de.

defect or iallure to comply.

premises, activities, and basic compo-tions from the requirements of the ferred until J "

regulations in this phrt a.s it deter' (b)(1) A director or responsible offi' (v) The date on which the informa-nerts as necessary to effectuate the mines are authorized by law and will cer subject to the regulations of this tion of such defect or failure to purposes of this part.

not endanger life or property or the art or A designated person shall comply was obtained.

common defense and security and are n tify the Commission when he ob-vD In e case a as component 8 21.51 Maltdenance of records.

Su (6) Each licensee of a facility or ac-otherwise in the public interest [ts ar a ns information reasonably indicat-y,th umber location of al 11vity subject to the regulations in this all comW w a defect a0 pliers of commercial grade iter e: tempt from the provisions of this ghg such components in use at, supp]!ed part sM maMain such nM M f a facility o an acti ity wfth (l

r. w se d M one w mwe connection with the licensed facility PPI ation o

erci 1 g a e te '

the United States that is bj ct to fac111 ties or activities subject to the assure cumpliance with the regula-

1. 1. ~

142 m 28893, June 6.1977. as amended at the lic i

0,50,60,6 *7 or 72 (vil) The corrective action which has Lions in this part.

Parts 30 43 m 48622, Oct.19,19781 this chapter and that is within his or-been, is being, or will be taken; the (b) Each individual, corporation.

name of the individual or organization partnerahlp or other entity subject to 11 21.8 Information collect on require-ganization,a responsibility or (10 a menta: OMIl approval, responsible for the action; and the the regulations in this part shall pre-length of time that has ten or will be (a) The Nuclear Regulatory Commis-gan on 6

sfon has submitted the information plied for a ft 1 collection requirements contained in within the United States that st l

277 WA

2W 10 CFR Ch.1 (1 1-85 Editisn) termined pursuant to Executive Order 2201tiu; and il 25.13 and 25.33(b) are also

designs, manufacture' fabrication who k

. u lY f ils to issued under sec.1610, 68 Stat. 950. a.s 12356 or any predecessor order to re-placement,

erection, installation provide amended H2 N mie.

quire protection against unauthorized modification, inspection, or testing of shall be sub en ty equal Souacr 45 FR 14481. Mar. 5.1980, unim disclosure and that is so designated, "Need-to-know" means a determina-any facility, basic component supplied to the amou pro i db 11 n 34 therwise noted.

tion by persons having responsibility for any licensed facility or to be used of the Atomic En in any licensed activity sufficient to amended.

GENERAL Paovisions for classified information or matter, assure compliance with the regula-that a proposed recipient's access to L46 FR 13202, Feb. 20,19811 0211 l'ee, such classified information or matter tions in this part. After delivery of the facility or component and prior to the This part establishes procedures for is necessary in Qe performance of his destruction of the records relating to PART 25-ACCESS AUTHORIZATION granung, rewah WW. k of!!cial, contractual, or licensee duties evaluations (see i 21.3(g)) or notifica-FOR LICENSEE PERSONNEL ferring and terminating access autg,or-tions to the Commission (see i 21.21),

of the Commission.

such records uhall be offered to the G ma41. Paovisions contractors or agents and other per

" Person', means (1) any individual.

purchaser of the facility or compo.

sons (e.g. individuals involved in adju. corporation, partnership, firm. associa-cicatory procedures as set forth in 10 tion, trust, estate, public or private in-

'C-nent. If such purchaser determines 1

pose.

CFR Part 2. Subpart Il who may re-l any such records:

h[

quire access to information classified stitution, group, government agency (1) Are not related to the creation of at the Secret and Confidential Nation-other than the Commission or a substantial safety hazard, he may 25 i Inte Informat\\o o'11ecti "

al Security information and/or Re-partuent of Energy (DOE), except i

r.uthorize such records to be de.

25 8 that the DOE shall be considered a stroyed, or OMB approval stricted Data level.

person to the extent that its facilities 25.9 Communications.

(2) Are related to the creation of a are subject to the licensing and related 25.11 specific exemptions.

substantial safety hazard, he shall 0 25.3 Scope.

cause such records to be offered to the The regulations in this part spply to regulatory authority of the Commis-2113 Records maintenance.

licensees and others who may squire sion pursuant to section 202 of the organization to which he supplies A

basic components or for which he con. 25J5 Access permitted under "Q" or T access to National SecuritF Informa" Energy Reorganization Act of 1974 structs a facility or activity.

tion and/or Restricted Data related to and sections 104,105 and 202 of the g

8 "DDHC&nt8 a license or application for a license.

Uranium Mill Tailings Radiation Con-If such purchaser is unable to make 211 p a r

$2 trol Act of 1978. any State or any po-for access autho the determination as required above litical subdivision of, or any politicr61 25.19 Processing applications.

E then the responsibility for making the 212t Determinauon of inlual and contin-

" Access authorization" means an ad-entity within a State, any foreign gov-determination shall be transferred to ued eligibility for access authorizat:on.

ministrative determination t&.t an in-ernment or natio*n or any political sub-l the individual. corporation partner-5.23 NotMication of grant of access au-ship, or other entity subject to the dividual (including a consultant) who division of any such government or is emp! yed by or an appikant for ern-nation, or other entity; and (2) any 4

regulations in this part that issued the 25.25 C "n

fMu a r access procurement document to the pur-auth rianuon.

ployment wh We M. N cMN legal successor, representative, agent, chaser. In the event that the determi.

25.27 Reopening of cases in which requests

. ors. agents. and Mces M h N.

or agency of the foregoing.

nation cannot be made at that level for access authorizations are cancelled.

or other person designated by the Ex-

,* Access Authorization means an 25.29 Reinstatement of access authoriza.

ecutive Director for Operations. is ell-necess authorization granted by the then the responsibility shall be trans-gible for a security clearance for ti n.

Commission based on a full field inves-j ferred in a similar manner to another 25.31 Extensions and transfers of access access to Restricted Data or national tigation conducted by the Office of individual, corporation, partnership-auth rizations.

a or other entit bject t h I-13 Termination of access authorizations.

Security information.

tions in this part until !!

"Ae he o

^

u a fI s ga lon, or othe 4

the licensee shall snake t'he deter Cussirin VisrTs 9g gg 8

tgg ss led.

Government agency which conducts n-

'"!'d ' 'lt

" Commission" means the Nuclear l

(c) Records that are prepared on!

Regulatory Commist. ion or its duly au-personnel security investigations.

" Restricted Data', means all data Vroutrons thorized representatives.

i for the purpose of resuring complianc with the regulations in this part and 25.37 Violatt are not related to evaluations or notif t.

ArrtND x A s rom NRC Acctss AUTN access authorizClion granted by the lization of atomic weapons, the pro-Commission which is normally based duction of special nuclear material, or 4

cations to the Commission may be de.

IzATIoM stroyed af ter delivery of the facility or Avinoa:Tr Secs. 145.161. 68 Stat. 942 on a National Agency Check (NAC) or the use of special nuclear material in component.

948, as amer.ded (42 UAC. 2165. 2201); sec.

NAC and Inquiry (NACI) conducted the productica of energy. but shall not (d) The effective date of the section 201, 88 Stat.1242. as amended (42 U.S.C.

by the Office of Personnel Manage-include data ceclassified or removed 5841); s.O.10865, as amended. 3 CFR 1953 from the Restricted Data category has been deferred until January 6*

1963 COMP., p. 398 (50 U.S C. 401. note);

ment.

19'l8.

E.O.12356. 47 FR 14874. April 6.1982.

" License" means a license issued pursuant to section 142 of the Act.

i pursuant to 10 CFR Parts 50,70. or 72.

(M FR 14481. Mar. S.1980, on amended at I

ENroRCEMENT Appendix A also !ssued under 96 Stat.

" Matter" means documents or mate. 48 FR 58283. Dec.1.1981; 47 FR 38683.

1051 (31 U.S.C. 9701L 82141 Failure to notify.

For the purposed of sec. 223. 68 Stat. 958 rial.

Sept. 2,1982; 48 FR 34320. June l.19831 ame 42 U a c. 2273A ll2113

" National Security Information"

(

Any director or responsible officer $17 means informah mat has ken b subject to the regulations in this part sec.161 Stat.94 as nd 279 m

i-t UNITED STATES

(

NUCLEAR REGULATORY COMMISSION i

0FFICE OF NUCLEAR REACTOR REGULATION

)

WASHINGTON, D.C.

20555 August 4, 1988 NRC INFORMATION NOTICE N0. 88-56:

POTENTIAL PROBLEMS WITH SILICONE FOAM FIRE BARRIER PENETRATION SEALS Addressees:

j All holders of operating licenses or construction pemits for nuclear power reactors.

Purpose:

This information notice is being provided to alert addressees to potential problems in their installed fire barrier penetration seals that 'could result in the reduction of fire-resistive capabilities for protection of safety-related redundant equipment and electrical power and control circuits.

It is expected that recipients will review this information for applicability to their facili-ties and consider actinns, as appropriate, to avoid similar problems. However, p

suggestions contained in this information notice do not constitute NRC require-R/

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

Description of Circumstanc,e_s:

In May 1987, B&B Promatec submitted a 10 CFR Part 21 notification advising NRC that some silicone foam fire barrier penetration seals at Wolf Creek Nuclear Generating Station (WCNGS) did not meet minimum requirements. The noncon-forming conditions reported by BAB Promatec were described as voids, shrinkage, i

and lack of fill. The conditions were not obviously visible because they were masked by fire-resistant boards that were typically installed on both sides of a wall penetration and the bottom side of a floor penetration.

WCNGS licensee personnel found the problems during replacement of damaged fire-resistant boards.

Therea f ter, WCNGS adopted al. inspection methodology in which the fire boards were removed, the silicone foam barriers were inspected and reworked as neces-sary, and the boards replaced.

Initial results from sample inspections indicated that over 25 percent of the inspected seals were nonconforming.

Additional inspections performed before October 1987 revealed that 107 of 430 inspected seals required repair or rework and that 65 of the 107 contained voids. The licensee for WCNGS subsequer.tly determined that the void problem was caused, at least in part, by underfill at the time of installation. As a result of the WCNGS report, NRC has been evaluating whether the silicone foam nonconforming conditions found at WCNGS have generic applicab".ity for plan.ts other than those notified by B&B Promatec.

Part of this evaluat.c.) included a review of abstracts of licensee event reports.

pG

-S?07290111 2 EXHIBIT PAGE I OF k PAGE(S:

3q93;028 kbr. l[ NI$ (

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IN 88-56 August 4, 1988 Page 2 of 4 Information obtained from this review indicates that a number of licensees have 4

reported various fire barrier penetration seal nonconforming conditions.

Some of the previously reported nonconforming conditions appear to be similar to those reported for WCNGS but are not limited to any particular vendor or installer.

Silicone foam was the only fire barrier penetration seal material that was specifically mentioned in the infomation reviewed, although some reports did I

not specifically identify the particular sealing material for the affected seals.

On the basis of this information, NRC believes that if generic problems exist, j

1 they may be limited to only silicone foam fire barrier penetration seals but i

not to any particular vendor or installer.

4 Discussion:

This notice alerts addressees of the possibflity that some installed fire barrier penetration seals may contain nonconforming conditions such as splits, gaps, voids, and lack of fill in the sealing material. These conditions may not be detected during routine inspection because the surface of the seal material is typically covered by a fire-resistant dam material.

Infomation that is avail-4 able suggests that the extent of the possible problem may be limited to fire barrier penetrations filled with silicone foam material.

1 Silicone foam has been used extensively as a fire barrier penetration sealing material in many nuclear power plants since the early 1970's.

For silicone foam seals installed since the mid 1970's, the silicone sealing material has been formulated of a two-component RTV 3-6548 base product manufactured by Dow Corning.

The silicone foam seals are produced by mixing the two components, l

which then chemically react (" snap") a short time after they are mixed. The

)

resulting snap causes gas formation and material expansion, which produces a silicone foam cell structure.

Experience with silicone foam indicates that any one of many factors could affect the adequacy of the final seal instal-lation.

These factors include the method of installation (e.g., damming technique), technical and quality control of material, material mixing process, l

pouring and curing process, method of final inspection, training and experience i

of installing personnel, and environmental factors, such as temperature and

)

humidity. Loss of control for any one of these factors could result in seals j

that do not meet minimum reouirements.

a In many silicone foam fire barrier penetration seals, a pemanent dam constructed from a fire-resistar.t material is used. These dams must be present if they were i

part of the qualified seal design.

Normally, a pemanent dam is located on the 4

bottom of floor and ceiling penetrations and on both sides (although sometimes l

only on one side) of wall penetratinns. One common installation method used in the past called for installing the permanent damming material first so that it would contain the liquid seal material during pouring and curing.

bince the permanent dam was part of final installation and because removal and reinstal-lation of the dam could be difficult and time consuming, final inspection of 2

many silicone foam seals was performed with the pemsnent dam in place. When this approach was used, final determination of whether a proper seal had been attained was made without direct visual inspection of the seal surface, which i

appears to be a questionable practice.

Instead, indirect methods of checking, i

4

n 2

IN 88-56 August 4,1988 Page 3 of 4 such as tapping on the dam or inserting probe wires through the dam, were used.

In addition to precluding direct visual inspection of a new seal, installed dams also hinder subsequent detection of nonconforming conditions that may have been present since initial installation or that may have developed after initial installation'.

j As me.ntioned earlier, licensees have reported various fire barrier penetration seal nonconforming conditions in the past. The reported conditions that suggest j

a generic problem are discussed below:

2 Voids - One nonconforming condition for silicone foam seals is the presence of voids. Voids can be created in a number of ways.

First, proper preparation of 4

the volume to be sealed is required before liquid fill. Proper preparation 3

includes ensuring that the penetrating items (pipes and cables) have sufficient i

separation to permit the liquid to fill all the space in the volume. Second, 4

the mixed sealing material requires a sufficiently lot-g " snap" time to ensure that the expansion process does not prevent free flow of sealing liquid to all i

spaces in the volume. Third, the gas formed during the expansion process needs to diffuse from the material without creating large gas bubbles or pockets.

a l

Finally, a sufficient quantity of sealing material must be injected to ensure i

that all spaces within the volume will be filled.

j 1

h Gaps - Another nonconforming condition is the presence of gaps or the pulling j

i

{

away of silicone foam material from the surface of penetriting items or inside i

a surfaces of the fire barrier.

In some cases, these gaps extend only a short distance into the seal thickness.

In a few cases, gaps have been observed to 1

extend completely through the entire thickness of the seal. Causes of the gaps j

have been variously given as failure-to inject sufficient sealing material 1

during filling, bulging of damming material, shrinkage of silicone foam, and contraction of silicone foam caused by a temperature change. The physical

[

characteristics of the silicone foam are such that a 1 percent reduction in j

volume can be expected for a decrease of 20*F in temperature.

a Splits - A third nonconforming condition is splitting (cracking of solidified material) of the silicone foam material.

This condition was not reported at WCNGS but was reported by other licensees.

In conversations with NRC, B&B Promatec stated that the reasons for silicone foam splitting are not completely understood and that splitting is a topic of discussion in the power sealer and a

}

insulation industry.

I Some of the actions taken by licensees as a result of finding nonconforming silicone foam fire barrier penetration seals include (1) programs for inspec-i tion and periodic reinspection of installed seals, (2) repair of nonconforming i

seals (3) evaluation of alternative materials for repairing old seals and in-stalling new seals, and (4) development of alternative methods for installing and inspecting new silicone foam seals.

1

IN 88-56 August 4, 1988 Page 4 of 4 l

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

1 If you have any questions about this matter, please contact one of the technical contacts listed below or the Regional Administrator of the appropriate regional office.

i

]'

dha es E. i br

~

Division of OperatfM11 Events Assessment Office of Nuclear Reactor Regulation Technical Contacts: Joseph J. Petrosino, NRR (301) 492-0979 i

C. Vernon Hodge, NRR (301)492-1169

Attachment:

List of Recently Issued NRC Information Notices a

i j

(

i l

i l

i j

l 4

4 i

A h [$ t fSTRIBUTION -- NdT-POR PUBLMISCfaSURE

~

, INVESTIGATION STATUS RECORD 3-934 4 racility: Dow con.oJ>o, nio'evo. Mr_.

Case No.:

Case Agent: TO O L.

Allegation No.:

4Jo-6f7[) < ) Date Opened: $ p q 3

\\

Docket No.:

i Source of Allegation

• Date of Full-Scale Upgrade:

Notified by: C Priority:

Category: OMlM/M$

Case Code:

Status: Ev4vATso Estimated Completion Date:

j feLEO i

Subject / Allegation: Fo. luite -bo nam ~?w at 4>w./:urw 2 mma Fo.lce. S+c:<tw e d L Remarko:

i j

Pionthly Status Report:

csl AJ /24 A<hhM h 'i, I't i 3 i

$b.

N

+JF closed:

Closed Action:

Staff days to Completion (WAR):

Issued:

Referred:

Statute:

~

DOJ Action:

DOJ Action Date:

i

._ _ _IiEITEDDIsraiBUTION AT T,FOR PUBLICLDISC E WIYHOUT APPROVAL 9)/r

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a TS IB SC U'tE INVESTIGATION STATUS RECORD Case No.: 3-93-028R Facility: DOW CORNING Midland, MI 1

Allegation No.:

Case Agent: PAUL 4

Docket No.: 030-04783 Date Opened:

10/01/93 Source of Allegation: A Date of Full-Scale Upgrade: 01/21/94:

Notified by: NRR Priority: HIGH (Coordinated with RIII i

Management Staff)

Category: OM/AE/MS Case Code: RV Status:

Estimated Completion Date:

Subject / Allegation: ALLEGED FAILURE TO MAKE PART 21 NOTIFICATION AND MATERIAL FALSE STATEMENTS Remarks:

I 50nthly Status Report:

page 2 10/31/94:

Case report in draft, however, additional field work required as a result l

of new information from alleger. ECD is being changed to March 1995 to accommodate NRR review and additional field work. 01 awaiting NRR review of Dow Corning test report.

ECD 03/95.

i ECD 12/94.

J 11/30/94:

ROI in draft / review. ECD 03/95.

12/31/94:

ROI in final typing. ECD 03/95.

01/31/95:

ROI closed January 25, 1995. Case will be issued upon corapletion of i

exhibit repro.

02/10/95:

Case issued by 01:RIII.

Closed: 01/25/95 U Closed Action:

Staff days to Completion (WAR):

Issued: 02/10/95 Referred:

Statute:

DOJ Action:

00J Action Date:

khl,Tp (T BU

- N0 FOR PU IC SC SUR W HOU A

VAL

d

/ LIMIJ LISTRIBJJTION A-NOTN OR PUBt'IC,t[.,CL0 p RE INVESTIGATION STATUS RECORD Case No.: 3-93-028R Facility: DOW CORNING Midland, MI Allegation No.:

Case Agent:

PAUL Docket No.: 030-04783 Date Opened:

10/01/93 Source of Allegation: A Date of Full-Scale U;. grade: 01/21/94:

Notified by: NRR Priority: HIGH Category: OM/AE/MS Case Code:

Status: FWP Estimated Completion Date:

12/94 Subject / Allegation: ALLEGED FAILURE TO MAKE PART 21 NOTIFICATION AND MATERIAL FALSE STATEMENTS Remarks:

Monthly Status Report:

10/01/91: Opened for evaluation.

01/21/94: Upgraded to a full-scale investigation. ECD 12/94.

01/31/94-Field Work in progress.

ECD 12/94.

02/28/94: Field work initiation suspended because of other investigative priorities.

Anticipate field work to resume next reporting period.

ECD 12/94.

03/31/94: Field work resumed, one interview conducted.

ECD 12/94.

04/30/94: No Change.

05/31/94: No interviews con ^1cted this period because of other investigative priorities and unavailability of witness.

ECD 12/94.

01/30/94: Field work resumed, and interviews conducted.

ECD 12/94.

07/31/94: Contact was made wit re potential witnesses.

Investigator also reviewed records an test reports.

ECD 12/94.

08/31/94: Three interviews were conducted and additional records obtained from BISCO and Dow Corning.

ECD 12/94.

09/30/94: One interview conducted. Additional documents and test reports were obtained from BISCO and Dow Corning. A technical review of test reports has been requested from NRR. ECD 12/94.

LIMITEDDISTRIBYTION--N0h0

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