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Fire Barrier Penetration Seals in Nuclear Power Plants. Draft Report for Comment
	ML20153D350
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Issue date:	06/30/1998
From:	Chris Bajwa, Khadijah West; NRC (Affiliation Not Assigned)
To:	;
References
	NUREG-1552, NUREG-1552-S01, NUREG-1552-S01-DR-FC, NUREG-1552-S1, NUREG-1552-S1-DR-FC, NUDOCS 9809250036
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NUREG-1552, Supp.1 1

Fire Barrier Penetration Seals in Nuclear Power Plants Draft Report for Comment Manuscript Completed: June 1998 Date Published: June 1998 C. S. Bajwa, K. S. West Division of Systems Safety Analysis Omce of Nuclear Reactor Regulation U.S. Nuclear Regulatory Commission W:shington, DC 20555-0001 (O..... )

COMMENTS ON DRAFT REPORT Any interested party may submit comments on this report for consideration by the NRC staff.

Please specify the report number, drail NUREG-1552, Supp.1, in your comments, and send them by the due date published in the FederalRegister notice to:

Chief, Rules Review and Directives Branch Office of Administration Mail Stop T6-D59 Washington, DC 20555-0001

ABSTRACT In NUREG 1552," Fire Barrier Penetration Seals in systems and components within an area from a fire Nuclear Power Plants," the U.S. Nuclear Regulatory outside the area. For the reasons given in this report, Commission staff documented the results ofits it is the staff's judgment that, generically, typical comprehensive technical assessment of penetration penetration seal deficiencies do not equate to a lack seals. Subsequently, the staff assessed new of adequate protection or result in undue risk to information for new insights. 'Ihe results of the public health and safety. It is the staff's opinion that updated assessment are documented in this report. continued licensee upkeep of existing peneuation Nuclear power plants use the " defense in depth" seal programs and continued NRC reviews and concept of echelons of fire protection to achieve a inspections are adequate to (1) provide reasonable high degree of fire safety. Fire barrier penetration assurance that penetration seal problems are seals, which are one element of the fire protection discovered and resolved and (2) maintain public defense-in-depth concept, are designed to confine a health and safety, fire to the area in which it started or to protect plant i

i iii NUREG-1552, Supp.1 l

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TABLE OF CONTENTS Ensn ABSTRACT: .... . .. . .. . . .. . . . .. iii EXECUTIVE

SUMMARY

.. . . . . . . . . . . . . . . . . . . .. . . vii 1 - DEFENSE-IN.DEP'lli CONCEPT AND THE ROLE OF PENETRATION SEALS . .. . .. I 1.1 Assessments of Fire Barrier Penetration Seals . . . . . . . . . . . . . ... . ..I 1.2 'Ihe Rob of Penetration Seals in the Defense.in. Depth Concept . . .. . ..1 4

2 REVIEW OF REAC'lDR OPERATING EXPERIENCE . . . . . .. .. . . .3 2.1 Licensee Event Reports . .. .... ......... ....... 3 2.2 NRC Inspections.... . . . . . . . . . . . .... 4 2.3 Fire Experience.. .. ........ . .5 2.4 Summary of Operating Experience . . ... .. .. . . . 6 3 SAFETY SIGNIFICANCE . .. ... . . . . ... .. ... .6 l 3.1 Fire Protection Program .. .. .. ..... .. . ...

.. . 6 3.2 Safety Significance Ranking of Penetration Seal Deficiencies . . . . . ..

7 3.3 Generic Assessment of Safety Significance . .. .... .. .. . . . . 7 ,

1 3.3.1 Improperly Installed or Degraded Seals and Inadequate Documentation . ;8 3.3.2 Unsealed and Breached Penetrations = .. . 9 3.4 Seal-Specific Assessment of Safety Significance = ... . . . ... . 10 4 RISK SIGNIFICANCE - .. .. ... . . . . . . .. I1

.5 . COMPENSA'IURY MEASURES - . . . . .. .. . . ... 11 6 PLANT-SPECIFIC EXPERIENCE WITH FIRE BARRIER PENETRATION SEALS .. . . . .. ... . . . . I1 6.1 Vermont Yankee Nuclear Power Station ...... . . . . . . . . . . I1 6.2 Wolf Creek Nuclear Generating Station .. .. . . . . . . . . . .. ... .. . ... 12 6.2.1 Operating Experience . ... . . . . . . . . . . . ... . .. . . . . . . . . . . . .. . .. . 12 6.2.2 OI Investigation .. . . . . .. . .. . . . . . . . . . . . . . 12 6.3 Salem Nuclear Generating Station ... . .. .. .. .. . . . . . . .. . . . . . .. ... 13 6.4 Millstone Nuclear Power Station.: . . . . . . . ...... . 13 6.5 Maine Yankee Atomic Power Plant ... . . . . . . . . . . . . . . . . . . . . 13 6.5.1 NRC Inspection . . . . . . . .. .. . .. .. 13 6.5.2 Licensee Event Reports . . . . . . . . . . . . . . . . . 14 6.5.3 Staff Followup .. .. .... .. .... . . . . . . . . . . . . . . . . . . 14 6.5.4 Conclusions on Maine Yankee Operating Experience ... . ...... . .. . .. . 15 6.6 Conelusions . . . . . . . . . . . . . - . . = . . . . .. 15 7 REVIEW OF PLANT SPECIFIC LICENSING BASES RELATED TO SECTION III.M OF APPENDIX R TO 10 CFR PART 50 - ... . 15 7.1 Introduction . . . . . . . . . . . m.. 15 l 7.2 Plant. Specific Licensing Bases .. . . . . 16 7.2.1 Calvert Cliffs Nuclear Power Plant, Units 1 and 2... . ... . .. .16 7.2.2 Duane Arnold Energy Center = . 16 7.2.3 James A. FitzPatrick Nuclear Power Plant . . . . . . . . . . . . ... ... .16 7.2.4 Maine Yankee Atomic Power Plant.. . . . . 17 7.2.5 Monticello Nuclear Generating Plant ... ..... 17 y NUREG-1552, Supp. I

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Eagt 7.2.6 Peach Bottom Atomic Power Station, Units I and 2. . . .. . 17 7.2.7 Pilgrim Nuclear Power Station, Unit ! . .. . . . . . . .. 17 7.2.8 Point Beach Nuclear Plant, Units 1 and 2.. . . . . . 17 7.2.9 H.B. Robinson Steam Electric Plant, Unit 2.. .. .. . .. .. 18 7.2.10 Surry Power Station, Units 1 and 2.. . .. . . . . . . .18 7.2.11 Vermont Yankee Nuclear Power Station . . . . . . . . .. . .. .18 7.3 Summary.. . . . . .. . . . . . . . . . . I8

. . . . . . 19 l 8 RECOMMENDATIONS MADE IN THE FINAL STAFF REPORT . .

8.1 Introduction . . . . . . . . . .. . . . .. . 19 l . .. .19 l 8.2 Status . . . . . . .. - . . .. .

8.2.1 Recommendations I,2, and 3 (Pending) . . . . .. . 19 8.2.2 Recommendation 4 (Complete). . . .- . . . . . 20 8.2.3 FPFI Program (Complete) . . . .. . .20

. 20 9 CONCLUSIONS . .. .. . . ..

APPENDICES *

..... . D-1 D Acronyms and Abbreviations ... . . . . . . . . . . . .

F Licensee Event Reports Submitted by Year,1987 'Ihrough June 1997. . .... . . -F1 Summary of Reported Problems,1987 Through 1997. .. .. . . . = .. . . G- 1 G .. . . . . . . . . .

l Summary of Licensee Event Reports,198'7 'Ihrough June 1997 . ..... . H 1 H .. .

... I-1 I Summary of NRC Inspections.. . . .

Plants Known to Have Performed 100 Percent Inspection Seal Inspections.. . . .. . J-l J

K Reference Summary . . . . . . . . . . . . . . .. . .. . .. . .. . . .. K- 1

Appendices A E appear in NUREG-1552

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l NUREG-1552, Supp. I vi

EXECUTIVE

SUMMARY

Nuclear power plants use the " defense in depth" practices, and corrective actions on the part of concept of echelons of fire protection to achieve a industry. The staff concluded that these actions high degree of fire safety. De objective of this together with continued NRC inspections, and concept is to (1) prevent fires from starting; continued licensee upkeep of existing penetration (2) rapidly detect, control, and extinguish those fires seal programs, were adequate to maintain public that do occur; and (3) protect structures, systems, and health and safety. De staff documented its components important to safety so that a fire that is assessment in SECY-96-146,' Technical Assessment i not promptly extinguished will not prevent the safe of Fire Barrier Penetration Seals in Nuclear Power shutdown of the plant. He multiple layers of fire Plants"(July 1,1996), and NUREG-1552," Fire protection provided by the defense-in-depth concept Barrier Penetration Seals in Nuclear Power Plants" offer reasonable assurance that weaknesses or (July 1996).

deficiencies in one layer will not present an undue risk to public health and safety. De NRC staff has since continued to review potential penetration seal problems on a case-by-case Fire barriers, which are one element of the fire basis as they are found or reported. This report protection defense-in-depth concept, accomplish their supplements the NRC staff assessment of fire barrier intended design function by remaining in place penetration seals by reviewing additionalinformation during a fire. They are important because they are on seal problems reported by licensees and found ~

the first and also the last lines of defense against a during NRC inspections performed prior to as well as fire. That is, during the early stages of a fire, the since the assessment documented in SECY-96-146 barriers confine the fire and protect important and NUREG-1552. De staff reconsidered the systems and components until the fire detection and operating experience reported in NUREG-1552, and automatic fire suppression systems operate. In considered the results of the effort, as documented in addition, in the event that an automatic fire protection this report, for insights and appropriate opportunities system fails to operate or fire brigade response is for actions by the NRC and the industry.

delayed, the fire barriers continue to provide passive fire protection. Fire barrier penetration seals are As part of this reassessment, the staff reviewed another element of defense in depth and, like the previous NRC inspections of penetration seal l structural fire barriers in which they are installed, are programs. Between 1991 and 1997, the staff had i passive fire protection features. Deir design function conducted 140 inspections that involved installed is to confine a fire to the area in which it started or to penetration seals and penetration seal programs at 82 protect plant systems and components within an area plants. In general, the inspectors found that the from a fire outside the area. Fire barrier penetration penetration seal programs were comprehensive, seals are not safety related. timely, and acceptable. In some cases, the inspectors found deficiencies and issued notices of vidations.

Between 1994 and 1996, the Office of Nuclear These inspections are summarized in Appendix H. In Reactor Regulation (NRR) staff conducted a addition, the staff reviewed the licensee event reports comprehensive technical assessment of penetration (LERs) on fire barrier penetration seals that were seals to address reports of potential problems, to submitted in 1987, 1988, and 1994-1997, inclusive.

determine if there were any problems of safety The staff also reviewed again LERS that were significance, and to determine if NRC requirements, submitted from 1989 through 1993. (The staff review guidance, and inspecti = ,;rocedures were originally documented the results ofits review of adequate. The staff did not find any plant-specific these LERs in NUREG-1552.) The staff found that 9 problems of safety significance or any concerns with plant sites submitted 16 LERs during 1987; 12 plant generic implications. De staff concluded that the sites submitted 19 LERs during 1988; and 11 plant general condition of penetration seal programs in sites submitted 26 LERs between 1994 and June industry was satisfactory. He staff also concluded 1997. Appendix F shows the numbers of LERs and l that the information notices it had issued in 1988 and LER supplements regarding fire barrier penetration 1994, increased industry awareness of potential seals that were submitted by year from January 1987 penetration seal problems and resulted in more through June 1997. Appendix G details the types of comprehensive surveillance activities, maintenance problems (the four major categories and vii NUREG-1552, Supp. I g

Executive Summary subcategories) that were reported by year for the problems and resulted in more comprehensive same period, and the number of times the problems surveillance activities, maintenance practices, and occurred. Appendix H summarizes each LER and corrective actions. He staff also concludes that the LER supplement that the staff considered during this general condition of penetration seal programs in reassessment of penetration seals. His report also industry is satisfactory. The staff expects that plant-contains a detailed review of the status of penetration specific deficiencies may occasionally be found seal programs at several plants that have undertaken during licensee surveillances and during NRC major corrective action programs for penetration reviews and inspections. However, potential seals. penetration seal problems are understood; industry consensus fire test standards are available and are Section III.M of Appendix R to 10 CFR Part 50 complied with; and fire test results and qualified fire-specifies that penetration seals utilize only resistant seal materials and designs are available.

noncombustible materials. To address questions herefore, licensees have the means to identify and abets' the NRC regulatory requirements regarding the correct problems, and continued staff oversight will use of these penetration seal materials, the staff ensure corrections on a case by-case basis.

reviewed the fire protection licensing basis for all nuclear plants. The staff determined which plants are In addition, the concept of fire protection defense in required to comply with Section III.M of Appendix R depth reasonably assures that deficiencies will be to 10 CFR Part 50. He staff then conducted a found and remedied before they present an undue risk detailed review of the fire protection licensing bases to public health and safety. In summary, it is the for those units to determine if the plants used staff's opinion that continued licensee upkeep of silicone-based fire barrier penetration seal materials existing penetration seal programs and continued and, if they did, how the licensees and the staff NRC inspections are adequa's to (1) provide addressed the regula'ory requirement of Section III.M reasonable assurance that penetration seal problems of Appendix R. are discovered and resolved and (2) maintain public health and safety. To provide added assurance of this, On tk basis of everything it identified and during the assessment documented in this report, the considered, the staff judges that, overall, potential fire staff issued Information Notice 97 70, " Potential barrier penetration seal deficiencies are not a safety Problems With Fire Barrier Penetration Seals,"

concern. For the reasons given in this report, typical September 19,1997, and revised the NRC fire penetration seal deficiencies do not equate to protection core inspection module to provide more inadequate protection or result in undue risk to public specific inspection guidance to NRC inspectors health and safety, regarding fire barriers and fire barrier penetration seals. The staff will continue to assess new On the basis of the reassessment documented here, information regarding penetration seals for new the staff concludes that the actions it took in 1988 and insights and appropriate opportunities for additional 1994 to alert licensees to potential penetration seal actions by the staff or the industry.

problems increased industry awareness of such NUREG-1552, Supp. I viii m__ _ _ _ __.. .... .....

1 DEFENSE-IN-DEPTH Plants" Quly 1,1996), and NUREG-1552, " Fire CONCEPT AND THE ROLE Barrier Penetration Seals in Nuclear Power Plants" OF PENETRATION SEALS (July 1996). Notwithstanding these findings, the NRC staff reviews potential problems on a case-by-case basis as they are found or reported. Therefore, 1.1 Assessments of Fire Barrier the NRC staff updated its assessment of fire barrier Penetration Seals penetration seals by assessing information on seal problems reported by licensees and found during Over the years, the U.S. Nuclear Regulatory NRC inspections since the assessment documented in Commission (NRC) staff has completed a number of SECY-96-146 and NUREG-1552. The staff assessments of fire barrier penetration seals. In 1987 reconsidered the operating experience reported in and 1988, Office of Nuclear Reactor Regulation NUREG-1552 in light of the new information, and (NRR) and regional office staff performed a also considered the results of this effort, which is comprehensive assessment of fire barrier penetration documented herein, for insights and appropriate seals. Although it found no widespread problems or opportunities for actions by the NRC and the safety-significant generic issues, the staff alerted industry.

industry to potential problems by means of a series of information notices. Later,in 1993, NRR staff reassessed the fire protectior orogram for nuclear 1.2 The Role of Penetration Seals reactors. In its " Report on t' Reassessment of the in the Defense-in-Depth NRC Fire Protection Prog- (February 27,1993), Concept the staff concluded that liet .:es were complying with regulatory requiremt and that there were no Nuclear power plants use the " defense in depth" major or recurring issues wia penetration seals. In c neept of echelons of fire protection to achieve a 1995, the Office for the Analysis and Evaluation of high degree of fire safety. The objective of the Operational Data (AEOD) reviewed fire barrier c neept is to (1) prevent fires from starting;(2) penetration seals and reached many of the same Promptly detect, control, and extinguish those fires conclusions as NRR had reached. Finally, between that do occur; and (3) protect structures, systems, and 1994 and 1996, NRR staff conducted a c mp nents important to safety so that a fire that is comprehensive technical assessment of penetration n t pompti; extinguished will not prevent the safe seals to address reports of potential problems, to shutdown of the plant. The severallayers of fire determine if there were any problems of safety pr tection produced by the defense in-depth concept significance, and to determine if NRC requirements, ffer reasonable assurance that weaknesses or review guidance, and inspection procedures are deficiencies in one layer will not present an undue adequate. The staff did not find any safety- risk to public health and safety. To achieve defense in significant plant-specific problems or concerns with depth, each operating reactor maintains an NRC-generic implications. The staff concluded that the approved fire protection program. The licensees have general condition of penetration seal programs in the designed the fire protection programs by analyses nuclear industry was satisfactory. The staff also that (1) considered potential fire hazards, (2) concluded that the information notices it had issued determined the effects of fires in the plant on the in 1988 and 1994 increased industry awareness of ability to safely shut down the reactor or on the potential penetration seal problems and resulted in ability to minimize and control the release of more comprehensive surveillance activities, radioactivity to the environment, and (3) specified maintenance practices, and corrective actions. meawes for fire prevention, fire confinement, fire Moreover, the staff concluded that these staff actions, detection, automatic and manual fire suppression, and together with continued licensee upkeep of existing Post fire safe-shutdown capability.

) penetration seal programs and continued NRC inspections, were adequate to maintain public Nuclear power plants are divided into separate areas health and safety. The staff documented its by such structural fire barriers as concrete floors, assessment in SECY 96-146," Technical Assessment walls, and ceilings. The Src protection function of of Fire Barrier Penetration Seals in Nuclear Power these barriers is to prevent a tu ; ' bat starts in one 1 NUREG-1552, Supp.1 L

Defense in-Depth Concept and the Role of Penetration Seals and Materials'." This time-temperature curve, which L plant area from spreading to another area. A barrier's fire-resistance rating, which is a measure of the extent is used to determine the fire resistance of all types of to which the barrier resists the effects of fire, is building fire barriers, represents a severe fire determined by exposing a mockup of the barrier to an exposure. (It is important to note that fire tests are intense test fire for a designated period. Nuclear not intended to model any specific room fire or the conditions under which the seals will be exposed power plant fire barriers typically have a fire-resistance rating of 1,2, or 3 hours3.472222e-5 days 8.333333e-4 hours 4.960317e-6 weeks 1.1415e-6 months . Openings are during a fire, but rather to provide a specific standard needed in structural fire barriers to allow such items fire exposure against which similar fire rated as cable trays, conduits, pipes, and ventilation ducts assemblies can be evaluated.)

to pass from one plant area to another. To maintain the fire protection function of the structural fire ne fire protection effectiveness of structural fire barriers, the openings and the gaps and annular barriers is largely dependent on their inhcrent fire resistance, details of construction, and protection of spaces around the penetrating items (penetrations) are sealed with materials that offer the same fire penetrations. Some fire barriers (both structural resistance as that of the barrier in which they are barriers and penetration seals) are more important to installed. The average number of fire barrier the fire protection defense-in-depth concept than penetration seals per nuclear power plant unit is about others. The importance of specific fire barriers 3000 and a single unit can have up to 10,000 seals. depends on many factors, such as the importance of the plant systems and components in the fire area Fire barriers, which are but one element of the fire (and adjacent areas); the types, amounts, protection defense-in-depth concept, accomplish their configurations, and locations of combustible intended design function simply by remaining in materials and fire hazards,if any,in the areas; the place during a fire. They are important because they potential for fire growth in the areas; the fire are the first and also the last lines of defense against a protection features installed in the areas; and the fire. That is, during the early stages of a fire, the accessibility of the areas to the plant fire brigade, barriers confine the fire and protect important The importance of specific penetration seals depends i

systems and components until the fire detection and on these factors and on such other factors as their automatic fire suppression systems operate. In size, their location or position in the fire barrier, and addition, in the event that an automatic fire protection the number and sizes of the other seals in the barrier.

system fails to operate or fire brigade response is delayed, the fire barriers continue to provide passive In order of overall importance to fire protection fire protection. Fire barrier penetration seals are defense in depth, structural fire barriers, being another element of defense in depth and, like the necessary for the structuralintegrity of a building or structural fire barriers in which they are installed, are fire area, are generally considered to be more passive fire protection features. Reir design function important than fire barrier penetration seals.

is to confine a fire to the area in which it started or to Qualified fire protection enginects determine the protect plant systems and components within an area importance of individual fire barriers by analyzing from a fire outside the area. fire hazards.

To gain reasonable assurance that a penetration seal Although a detailed discussion of such analyses is will have the required firuresistance capability or fire beyond the scope of this paper, the following rating, a penetration seal test assembly is subjected to discussion illustrates this approach.

a fire endurance test. The test methods involve the furnace-fire exposure of a full-scale penetration seal Consider, for purposes of a worst-case analysis, that a structural fire barrier fails and collapses upon test specimen that is representative of the construction for which a fire-resistance rating is exposure to a fire. In this event, the adjoining fire desired. He heat input to the test furnace is area and its contents would be exposed to the same controlled so that the average temperature in the fire and would, themselves, become in,olved in the furnace follows the time-temperature curve specified in the test standard. In the United States, the standards for testing penetration seals use the time- ' Representative points on the curve that determine its character are: 1000 %F at 5 minutes,1550 %F at 30 temperature curve defined in American Society for minutes,1700 %F at I houc,1850 %F at 2 hours2.314815e-5 days 5.555556e-4 hours 3.306878e-6 weeks 7.61e-7 months , and Testing and Materials (ASTM) E-119, " Standard Test Methods for Fire Tests of Building Construction 1938 %F at 3 hours3.472222e-5 days 8.333333e-4 hours 4.960317e-6 weeks 1.1415e-6 months .

1 NUREG 1552, Supp. I 2

Review of Reactor Operating Experience fire in a short period of time. (Because of the Overall, the staff found that the technical problems substantial construction of structural fire barriers i.i with penetration seals that were reported between nuclear power plants and fire protection defense in 1987 and 1997, inclusive, could be classified into depth, the staff does not consider this a credible four major categories. In descending order of the nuclear power plarq fire scenario.) Similarly, number of reported occurrences, these were catastrophic failure of a penetration seal could expose the adjacent fire area to the fire. However, since the (1) seal not installed or breached (56 occurrences),

penetration seal is not necessary for structural integrity, its failure is not as significant a fire threat as (2) seal not properly installed (56 occurrences),

the failure of a structural fire barrier would be. In addition, in most cases, a seal failure would initially .

(3).madequate documentation (18 occurrences), and create a localized hot spot in the adjacent fire area in the area of the seal. If there are no combustible materials in the adjacent fire area in the vicinity of (4) seal degraded or damaged (17 occurrences).

the failed seal (for example, if the penetration seal surrounds a pipe), smoke and hot gases will migrate Appendix E shows the numbers of LERs regarding into the adjacent area, but the spread of fire into the fire barrier penetration seals that were submitted by area will be limited. If there are combustible year from January 1987 through June 1997.

materials in the vicinity of the failed seal (for Appendix F details the types of problems (the four example, if the penetration seal surrounds a loaded major categories and subcategories) that were cable tray that passes from one fire area to another), reported by year for the same period, and the number the fire could spread imo the adjacent area more of times the problems occurred. Appendix 0 reports readily. In this instance, a more detailed fire hazards on each LER that the staff considered during this analysis is needed to assess the potentially adverse reassessment of penetration seals. (The total number effects of the fire spread. Regardless, such a fire of LERs for 1989 through 1993 differs from the scenario is less threatening than the failure of a number reported in NUREG-1552 because the stalT structural tire barrier. removed from consideration reports that were not related to technical problems, e.g., missed surveillances. Note also that some licensees do not 2 REVIEW OF REACTOR consider that penetration seal deficiencies are OPERATING EXPERIENCE conditions that put a plant outside its design basis and, therefore, do not report such deficiencies in LERs.)

2.1 Licensee Event Reports In NUREG-1552, the staff reported that in 1994 the ^ ' E" '"""****"I' "'" * **

s semMWunng W87 and W88 and those licensee event report (LER) database maintained by submitted from 1994 through 1997. The staff also Oak Ridge National Laboratory contained about 58,000 LERs and that 318 (about 0.5 percent) of rec nsidered the LERs that were submitted from them,invo:ved fire barrier penetrations. (For this 1989 through 1993. On the basis ofits reviews, the discussion, "LERs" also includes LER supplements.) staff made the following observations:

In NUREG-1552 the staff documented the results of (1) The types of problems that were reported its review of the LERs submitted between 1989 and during 1987 and 1988 and from 1994 through 1993, inclusive. The staff found that licensees for 1997, were consistent with the types of about 20 plant sites had submitted 141 LERs Problems reported in the LERs submitted from regarding fire banier penetration seals. In support of 1989 through 1993. The staff did not uncover the reassessment documented here, the staff obtained new types of problems.

the LERs regarding fire barrier penetration seals that were submitted in 1987 and 1988, and 1994-1997 (2) The types of problems and deficiencies that inclusive. The staff found that 12 plant sites have been found (e.g., voids, cracks, submitted 19 LERs during 1988; 9 plant sites inadequate documentation) have involved each submitted 16 LERs during 1987; and 11 plant sites type of seal used by industry (e.g., grout, submitted 26 LERs between 1994 and 1997. silicone foam, and silicone elastomer).

3 NUREG-1552, Supp.1

Review of Reactor Operating Experience (3) Overall, the number of LERs submitted each assemblies. Sometimes this is not done and year has decreased from a high of 23 in 1989 the discrepancies are not found until a

' to a low of 2 in 1997 (through June). mbsequent penetration seal surveillance.

De number of occurrences of penetration seal (8) In some cases, licensees conservatively (4) deficiencies has decreased from a high of 25 in reported such superficial problems as surface 1989 to a low of 0 in 1997 (through June), imperfections and small cracks, splits, and gaps, which would not have precluded the After its first comprehensive technical seals from performing their intended fire (5) assessment of fire barrier penetration seals, the protection design function.

NRC staff issued Information Notices (ins)

(9) Licensees appear to understand potential 88-04; 88-04, Supplement 1; and 88-56 to alert problems with and corrective actions for fire industry to potential seal problems. In barrier penetration seals.

response to these ins, there was significant industry scrutiny ofinstalled penetration seals (10) Plant age does not appear to be a critical and penetration seal programs. On the basis of attribute as to whether or not a plant is prone its best-effort search of LERs and NRC to seal problems. Of the 43 plants known to inspection reports (see Section 2.2, below), the have completed 100-percent seal inspection staff found that the licensees for at least 43 programs, about half operated before January plants have conducted enhanced 2100-percent 1,1979 (and are covered by the regulations in penetration seal inspections in response to the A Ppendix R), and half began operations later ins. (See Appendix I for a complete list of and are not covered by the regulations in references.) Appendix R.

(6) Most of the licensees that have conducted 100 (11) Overall, the safety sigmficance and risk percent seal inspection programs found seal sigmficance f the reported deficiencies were deficiencies. He findings ranged from e Potential saby sign &ana of the I W-negligible to widespread problems involving rep rted problems ,is discussed in Section 3.

each of the four categories of problems. Rese sign anu is ussed in Section 4.

licensees strengthened their programs to reduce the likelihood of recurrence. Of the LERs submitted since the stsffissued NUREG-1552, two indicated widespread plant-(7) Many deficiencies, including failure to install specific deficiencies. The first involved Washington seals, improper seal in::tallation, and Nuclear Project 2 (WNP2) and the second involved madequate documentation existed since the Maine Yankee. He staff was aware of the plant was tailt. However, these types of deficiencies at WNP2 through previous NRC pioblems can occur at any time during the life inspections and it documented these deficiencies and of the plant. For example, during plant the licensee's corrective actions in Section 5.5.5 of outages, temporary and permanent NUREG-1552. He staff 4 assessment of the Maine modifications that involve routing cables are Yankee report is in Section 6.6 of this report.

commonplace. Such modifications require breaching existing penetration seals or making 2.2 NRC Inspections new penetrauons. Plant procedures specify that the breached seals be restored and that As part of this reassessment, the staff conducted a new penetrations be scaled with properly best-effort search for NRC inspections of penetration designed and tested penetration seal seal programs. He staff found that between 1991 and 1997,it conducted 140 inspections that involved 2For purposes of this discussion, an enhanced installed penetration seals and penetration seal program is one that exceeds the requirements of he programs at 82 plants. Of these,38 (46 percent) licensee's routine surveillance program. For were Appendix R plants (operating prior to example, the licensee may have compared test January 1,1979). He inspectors reviewed the documentation to installed seal configurations or adequacy of penetration seal installations, removed damming boards to verify the thickness of qualification, and surveillances. Rey also followed the installed seals. up on issues reported in LERs and weaknesses noted NUREG-1552, Supp.1 4 1

. v

Review of Reactor Operating Experience during previous NRC inspections. In some cases, the in NUREG-1552, the staff also reported that it was inspectors reviewed the 100-percent penetration seal preparing the new fire protection functional reevaluation programs performed by the licensees. In inspection (FPFI) program that it had described in other cases, the inspectors walked down the seal SECY-95-034, " Status of the Recommendations installations to assess their adequacy. In general, the Resulting from the Reassessment of the NRC Fire inspectors found that the penetration seal programs Protection Program." Since it issued NUREG-1552, were comprehensive, timely, and acceptable. In the staff has drafted the FPFI procedures and some cases, the inspectors found deficiencies and guidelines and has started the pilot FPFI program, issued notices of violations. Each of these The FPFI procedures and guidance contain detailed 4

inspections is summarized in Appendix H. guidance for inspecting fire barrier penetration seals and seal programs. These procedures and guidelines On the basis of its review of the NRC inspection are being used during the FPFIs and are available for findings, the staff made the following observations: NRC inspectors and licensees to use on an as-needed basis independent of an FPFL (1) The types of problems found during inspections were consistent with the types of problems reported in LERs. The staff did not identify new types of problems during its 2.3 Fire Experience nsPedont The staff reviewed the fire event databases compiled The inspection reports, like the LERs, revealed by Sandia National Laboratories, which contained (2) that licensees occasionally find penetration data from 1965 thorough 1985, and the Electric Power Research Institute, which contained data from seal deficiencies in their plants.

1965 through 1988. The staff found no reports of (3) For the most part, the licensees maintained nuclear power plant fires that challenged the ability satisfactory fire barrier penetration seal f fire rated structural barriers or fire rated programs. Penetration seals to confine a fire in accordance with their fire protection design function. The staff also (4) Licensees understand potential fire barrier 'eviewed the LER database discussed in Section 2.1, penetration seal problems, have the means to which contains data from 1980 to the present, and correct problems, and have taken appropriate again, found no reports of nuclear power plant fires and timely actions to correct penetration seal that caused the failure of a fire rated structural barrier deficiencies. or a fire rated penetration seal. In addition, since the staffissued NUREG-1552, AEOD issued a special (5) The NRC inspection reports did not reveal study titled " Fire Events-Feedback of U.S.

widespread or potentially generic problems of Operating Experience"(June 1997), which covers safety significance, operating experience from 1965 through 1994. This AEOD study does not contain fire events that As noted in NUREG-1552, the NRC's routine fire challenged either fire-rated structural barriers or fire-protection inspection procedures are contained in the rated penetration seals.

NRC Inspection Manual m Inspection Procedure 64704," Fire Protection Program" It has been suggested that the March 22,1975, fire at (March 18,1994). 'Ihis procedure directs the the Browns Ferry Nuclear Plant propagated through a inspectors to visually inspect the fire barriers fire rated penetration seal and, therefore, there is associated with two plant fire areas and ensure that industry experience that a fire challenged such a seal, the electrical and mechanical penetration seals are The staff does not agree. As reported in functional. However, the procedure did not give NUREG-0050, " Recommendations Related to specific guidance for inspecting the seals or Browns Ferry Fire"(February 1976),"the seal that establishing their functionality. The lack of specific caught fire differed from the [ fire] seal as designed inspection guidance was viewed as a potential and tested." For example, the installed seal used weakness in the NRC reactor fire protection program. flexible polyurethane foam rather than the spray Tncrefore, the staff revised Procedure 64704 in polyurethane foam specified in the design criteria. In September 1997, to add guidance for inspecting addition, the installed seal did not have the fire-penetration seals as a part ofits routine fire retardant coating specified in the design criteria.

protection inspections.

l 5 NURsG-1552, Supp.1

~ .

Review of Reactor Operating Experience / Safety Significance Furthermore, the report stated that "a properly made for nuclear power plants is contained in Branch fire stop of the Browns Ferry design (with Technical Position (BTP) Auxiliary Power Flammastic and without flexible foam) would Conversion Systems Branch ( APCSB) 9.5-1, probably not have initiated the fire" and "even if a " Guidelines for Fire Protection for Nuclear Power fire had started, a fire stop made in accordance with Plants;" and Appendix A to BTP APCSB 9.5-1, the original design may well have prevented its " Guidelines for Fire Protection for Nuclear Power Plants Docketed Prior to July 1,1976." These two spread outside of the room where it started."

NRC documents specify preferred methods for fire piotection program design. In addition, Section l 2.4 Summary of Operating 50.48(b) states that Appendix R to 10 CFR Part 50, l

Experience " Fire Protection Program for Nuclear Power Facilities Operating Prior to January 1,1979,"

The LERs and NRC inspection reports show that establishes fire protection features required to satisfy many plants have performed 100-percent penetration GDC 3 with respect to certain generic issues for seal inspections and corrective action programs since nuclear power plants licensed to operate before 1987. The staff found no evidence of generic January 1,1979. Fire protection programs that meet problems of safety significance with penetration seal the criteria of either BTP APCSB 9.5-1 or Appendix materials or safety-significant failures of penetration A to BTP APCSB 9.5-1 and the applicable sections seals. On the basis of its review, the staff concluded of Appendix R satisfy 10 CFR 50.43 and GDC 3.

that the licensees have been effective in finding NUREG-0800, " Standard Review Plan," (SRP) penetration seal deficiencies and have taken timely Section 9.5-1," Fire Protection Program,"

and appropriate actions to correct identified incorporates the guidance of BTP APCSB 9.51 and discrepancies. In view of the large number of Appendix A to BTP APCSB 9.5-1 and the criteria of penetration seals installed in nuclear power plants, Appendix R. Therefore, fire protection programs that the staff expects that plant-specific deficiencies may meet the guidelines of SRP Section 9.5-1 also satisfy occasionally be found during beensee surveillances 10 CFR 50.48 and GDC 3.

and NRC inspections. However, the LERs and NRC inspection findings show that licensees understand The objective of the fire protection program required the potential fire barrier penetration seal problems by 10 CFR 50.48 is to minimize both the probability and that fire test results and qualified fire resistant and consequences of fires. As discussed in Section 1, seal materials and designs are available. Therefore, the licensees use the concept of defense in depth to licensees have the means to correct problems. achieve a high degree of fire safety. The licensees Appendix I lists plants that, on the basis of docketed determine the adequacy of fire protection for plant information, are known to have performed 100 safety systems and fire areas by analyzing the effects percent penetration seal inspection programs that of postulated fire. A primary means of fire protection exceeded the specifications of the licensees

normal consists of fire barriers and fixed automatic fire fire barrier surveillance programs. Appendix J lists detection and suppression systems. In addition, the docketed references (LERs and NRC inspection manual fire fighting capability is provided throughout the plant to limit the extent of fire damage. In reports), by plant, that the staff considered ir. this general, the plant fire hazards analysis addresses the reassessment of fire barrier penetration seals.

following variables and attributes:

(1) the NRC fim psetion mquimments and 3 SAFETY SIGNIFICANCE guidance that apply; 3.1 Fire Protection Program (2) amounts, types, configurations, and locations of cable insulation and other combustible The basic fire protection regulation for commercial materials; nuclear power plants is Title 10 of the U.S. Code of '

Fedeml Regulations, Part 50, Section 50.48, " Fire (3) fire loading and calculated fire severities; protection." Section 50.48(a) states that each operating nuclear powei plant must have a fire (4) in situ fire hazards; protection plan that satisfies General Design Criterion (GDC) 3 of Appendix A to 10 CFR Part 50, " Fire (5) automatic fire detection and suppression protection," and notes that fire protection guidance capability; 1

NUREG-1552, Supp.1 6

Safety Significcnce l 1

1 (6) layout and configurations of safety trains; lowest as follows: (1) seal not installed or breached, (2) seal not properly installed, (3) seal degraded or (7) reliance on and qualifications of fire barriers, damaged, and (4) inadequate documentation.

including fire test results, the quality of the ,

materials and system, and the quality of the 3.3 Generic Assessment of Safety installation; Significance (8) fire area construction (walls, floor, ceiling, For purposes of the following discussion, the safety dimensions, volume, ventilation, and significance of a fire barrier penetration seal can be congestion); thought of as being the role the seal plays in preventing a fire from spreading from the fire area of (9) location and type of manual fire fighting origin to an adjacent fire area. In the Federal Register equipment and accessibility for manual fire notice that issued the proposed Appendix R to 10 fighting; CFR Part 50,8 the staff stated that the " phenomenon of fire is believed to be sufficiently well understood (10) potential disabling effects of fire suppression to permit evaluation of existing and potential fire systems on shutdown capability; hazards and probable extent of damage should a fire occur. Such evaluations are useful in assessing the (11) availability of oxygen to support combustion poss ble consequences of fire in a given area." In this (for example, inerted containment); and regard, a generic assessment is instructive for understanding the safety significance of fire barrier (12) post-fire safe shutdown capability including penetration seals. j alternative or dedicated shutdown capability.

As discussed in Section 1, licensees rely on a During its reviews and inspections of the licensees' defense-in-depth concept that incorporates several fire protection programs, the staff ensured that each fire safety measures. In sum, automatic fire detection licensee had provided an adequate level of fire and suppression systems are provided in most areas protection. that have safe-shutdown equipment. Trained fire

, , brigades are required to be on duty 24 hours2.777778e-4 days 0.00667 hours 3.968254e-5 weeks 9.132e-6 months a day at 3.2 Safety Significance Rankm, g of all plants. All areas that have safe-shutdown Penetration Seal Deficiences equipment contain manual fire suppression features.

Fuels that can feed a fire and ignition sources to start In general, the potential safety significance of a a fire are controlled. Taken together, these factors deficient fire barrier penetration seal depends on such generally represent an adequate means of fire factors as the nature and extent of the deficiency; the protection at the plants and ensure that operations can importance of the plant systems and components in be conducted without an undue risk to the health and the fire area (and adjacent areas); the amounts, types, safety of the public. In general, every echelon of fire configurations, and locations of any combustible protection defense in depth would have to either fail materials and fire hazards in the areas; the potential or be significantly compromised for a fire to breach a for fire growth in the areas; the fire protection fire banier penetration seal and adversely affect the features installed in the areas; and the accessibility of safe-shutdown capability or cause other operational the areas to the plant fire brigade. The actual safety problems. Assuming that redundant safe shutdown significance and the importance of a specific seal trains are located in adjacent fire zones, which are depends on these factors and on such other factors as separated by a 3-hour fire rated barrier with its size, its location or position in the fire barrier, and penetration seals, the following would have to occur:

the number and sizes of the other seals in the barrier.

(1) Despite the plant fire prevention program, a Appendix F summarizes the types of penetration seal fire would have to occur.

problems and deficiencies that were reported in LERs, by year, from 1987 through June 1997, inclusive. It is the staff's judgment that, in general, 'U.S. NRC," Fire Protection Program for Nuclear the four categories of deficiencies presented in Power Plants Operating Prior to January 1,1979,"

Section 2.1 of this report and in Appendix F can be Federal Register, Vol. 45, No.105, May 29,1980, ranked from nighest potential safety significance to pp.36082-36090.

7 NUREG-1552, Supp.1 H y

Sifety Significance (2) The fire would have to go undetected. That is, components located in the adjacent fire zone, the automatic fire detection and alarm system where it must cause sufficient fire damage to would have to fail. In addition, plant the components to affect their ability to personnel would have to fail to discover the function. That is, the scenario described under fire. items I through 6 would also have to occur in the second fire zone.

(3) The fire would have to grow beyond the incipient stage, spread, and become large. As discussed in Section 1, fire barrier penetration This means that the fire zone would have to seals are passive fire protection features that contain transient and in situ combustible accomplish their intended fire protection function by materials of sufficient types, amounts, and their very presence. Penetration seals are important configurations to support fire growth and features because they help confine a fire to its area of spread, origin. 'Ihere can be no question that when properly designed and installed, the various types of (4) The automatic fire suppression system (if there penetration seals currently installed in nuclear power is one) would not operate and control the fire, plants will provide fire resistance equivalent to the or if it operated, it would fail to control the barriers in which they are installed and will perform fire. their intended fire protection function by confining a fire to the area of origin. The types of penetration Manual fire suppression activities would not seal deficiencies described in Section 2 and in (5) be employed to control and suppress the fire. Appendix F can reduce the fire-resistance capabilities of penetration seals. Nevertheless, it is the staff's The fire must expose the safe-shutdown pini n that, in general, the relative safety (6) significance of such deficiencies is low for the components located in the originating fire zone f 11 wing reasons: in most cases, the deficiencies and cause fire damage that renders the may reduce the fire resistance of the seal, but they do components nonfunctional. For this to happen, n t render it useless; the defense-in. depth concept the fire must either start near the components ensures that multiple safety measures are or it must spread close enough to the inC rPorated; automatic fire detection and sprinkler components so that the components are systems are provided in areas that have safe.

damaged by direct flame impingement or shutdown systems and components; trained fire radiative heat transfer. Alternately, the fire's bngades are required to be on duty 24 hours2.777778e-4 days 0.00667 hours 3.968254e-5 weeks 9.132e-6 months a day at products must adversely affect the safe all plants; and transient and in situ fuels and fire shutdown components located in the fire zone.

hazards that can feed a fire, and ignition sources that For example, hot gases from the fire would rise can start a fire, are controlled. Therefore, it is to the ceiling and form a hot gas layer. Safe-unlikely that a fire significant enough to challenge a shutdown components (e.g., cables) located fire barrier penetration seal will occur. How these near the ceiling and within the hot gas layer f ct rs affect the various types of penetration seal could be damaged by the convected heat even deficiencies is discussed in Sections 3.3.1 and 3.3.2, if they are located away from the burning area.

below.

(7) The fire must also spread to a penetration seal installed in a structural fire barrier that 3.3.1 Improperly Installed or Degraded separates the fire zone of origin from the Seals and Inadequate adjacent fire zone with the other train of Documentation redundant safe-shutdown components.

As discussed in Section 1, the fire endurance tests (8) The uncontrolled fire must burn through the maximize fire severity by subjecting the penetration fire-resistant penetration seal assembly (which seal to a fire of rapidly rising temperature in a in some cases, could take more than 3 hours3.472222e-5 days 8.333333e-4 hours 4.960317e-6 weeks 1.1415e-6 months ). relatively small and confined space. In the event of an actual fire at a nuclear power plant, the fire (9) After the fire burns through the penetration resistance required of a penetration seal depends on seal, it must continue to burn and spread from the expected severity of the fire to which it may be the penetration to the redundant safe-shutdown exposed. With few exceptions, nuclear plant fire NUREG-1552, Supp. I 8

Safety Significance loads are not great enough to produce a fire 3.3.2 Unsealed and Breached approaching the severity of a test fire (time and Penetrations temperature). It is expected that the temperature of most actual fires at nuclear power plants would rise For the cases discussed in Section 3.3.1, the installed more slowly than the temperature of the test fire.

penetration seals are degraded or deficient, but will Most plant areas have controls on igmtion sources; these controls help reduce the occurrences of fires.

provide some measure of fire protection. Intuitively, conditions involving missing and breached seals Most plant areas are equipped with other passive and involve potentially higher safety significance, active fire protection features, and many are because this measure of protection is missing continuously or regularly occupied by plant altogether and the fire may have a direct path to operators, security staff, and other personnel, all of spread from one fire area to another.

whom contribute to early fire detection and suppression activities. For example, plant fire It is important to note that there is no regulatory detection systems give reasonable assurance that a requirement that fire-rated seals be installed in all fire will be detected in its incipient stage and before penetrations through fire barriers that form fire area there is any significant propagation of flame; or rise boundaries or that seals have either (1) the same fire-in temperature. The detection system would send an resistance rating as the structural fire barrier in which alarm to the continuously manned control room, and they are installed or (2) a 3-hour fire resistance the control room operators would dispatch the plant rating. In Generic Letter (GL) 86-10, fire brigade. The fire brigade would then extinguish

" Implementation of Fire Protection Requirements" the fire.

(April 24,1986), the staff presented guidance for satisfying NRC regulatory requirements for fire In a plant area that is protected by an automatic fire protection. In Enclosure I to GL 86-10, the staff suppression system, should the fire develop beyond interpreted Appendix R requirements. Interpretation the incipient stage before the fire brigade responds, 4, " Fire Area Boundaries," stated, in part, the system would actuate and either control or extinguish the fire. Therefore, there is reasonable The term " fire area" as used in Appendix R assurance that a fire will not challenge a fire barrier means an area sufficiently bounded to penetration seat withstand the [ fire] hazards associated with the area and, as necessary, to protect important In addition, in large open spaces, such as exist in equipment within the area from a fire outside many nuclear plant fire areas, a fully developed fire the area. In order to meet the regulation, fire may occur in one part of the area (e.g., in area boundaries need not be completely scaled concentrations of cables), but it is not , Uble that floor-to-ceiling, wall-to wall boundaries.

the entire volume (fire area) would be engulfed in However, all unsealed openings should be flames (flashover) before an automatic fire identified and considered [in] evaluating the suppression system actuated or manual fire effectiveness of the overall barrier. Where fire suppression activities were employed. Unless a fire area boundaries are not wall-to-wall, floor-to-reaches the fully developed stage, it is not likely to ceiling boundaries with all penetrations sealed present a credible challenge to any nuclear power to the fire rating required of the boundaries, plant penetration seal. Moreover, even in cases in licensees must perform an evaluation to assess which the fire barrier penetration seals are degraded the adequacy of fire boundaries in their plants or deficient, they will offer some measure of fire to determine if the boundaries will withstand protection. In fact, some of the reported deficiencies all [ fire] hazards associated with the area.

will reduce the fire resistance rating of the seal under test conditions and the fire protection effectiveness of This regulatory position established that certain in-plant seals (e.g., inadequate seal thickness).

penetration seals need not have the same fire rating as the barrier in which they are installed and,indeed, However, other deficiencies (splita, shrinkage, that certain fire barrier penetrations may not need to inadequate documentation) may have no or only be scaled at all. Licensees evaluate such seals on a negligible impact.

case-by-case basis. The engineering evaluations performed to assess the effectiveness of the penetration seals are based on the expected 9 NUREG-1552, Supp. I

MC % M - ______

Safety Significance fire-resistive performance of the seal and on the fire significant and challenging nuclear power plant fire hazards and fire protection features in th: fire area. could be readily extinguished if appropriate and timely fire fighting efforts are employed. Since the Nevertheless, on the basis of its experience, the staff fire at Browns Ferry, licensees have made significant believes that most licensees install 2-hour and 3-hour improvements in fire baigade training and fire fire-rated penetration seals in fire area boundancs. fighting capabilities. The staff believes that if timely I and appropriate action is initiated, a fire at an open It should be noted that with up to 10,000 fire barrier penetration will not create any significant problems.

Therefore, on the aforementioned bases, although the penetration seals per nuclear unit, the instances of unsealed penetrations and breached penetration seals staff considers an open penetration to be more that have been reported are rare. Open penetntions significant than a degraded seal, it believes that the are more safety significant than degraded penetration relative safety significance of missing and breached seals. However, even in cases of missing or breached seals, although potentially higher than the other seals, most of the considerations discussed in Section common types of seal deficiencies,is low.

3.3.1 still apply. That is, the defense-in-depth concept ensures that multiple safety measures are 3.4 Seal-Specific Assessment of incorporated; automatic fire detection and sprinkler Safety Significance systems are provided in areas that have safe-shutdown systems and components; trained fire For the reasons discussed above, in general, the brigades are reqtired to be on duty 24 hours2.777778e-4 days 0.00667 hours 3.968254e-5 weeks 9.132e-6 months a day at safety significance of deficient fire barrier penetration all plants; and transient and in situ fuels and fire seals is low. However, the actual safety significance huards that can feed a fire and ignition sources that of specific deficiencies in fire barrier penetration can start a fire are controlled. To spread through an seals depends on many factors and variables. 'Ihese open penetration, the fire would have to be larg and include the importance of the plant systems and uncontrolled. In this case, a localized hot spot would components in the fire area (and adjacent areas); the occur in the adjacent fire area in the area of the seal, types, amounts, configurations, and locations of any If there are no combustible materials in the adjacent combustible materials and fire hazards in the areas; fire area in the vicinity of the open penetration (for the potential for fire growth in the areas; the fire example,if the penetration seal encloses a pipe), protection features installed in the areas; the smoke and hot gases will move into the adjacent area, accessibility of the areas 'a the plant fire brigade; the but the spread of fire into the area would be limited. type, size, and location of the penetration scal; the Conversely,if there are combustible materials in the nature and extent of the seal deficiencies; and the vMinity of the failed seal (for example,if the overall effectiveness of the defense-in-depth process.

penetration seal encloses a loaded cable tray that passes from one fire area to another), the fire could Clearly, certain fire areas present a more credible spread into the adjacent area more readily. However, challenge to deficient fire barrier penetration seals in the event a fire spreads through an unsealed than others. For example, it is likely that a fire penetration, the fire threat to the adjoining fire area involving a turbine generator lubricating oil system would be readily mitigated by the plant fire brigade. would present a significant fire exposure to the fire barrier penetration seals installed in the fire wall that As an example, consider the following. On March separates the turbine building from the auxiliary 22,1975, the Browns Ferry Nuclear Power Plant had building. If the seals are properly designed and the worst fire ever to occur in a commercial nuclear installed and the other components of the fire power plant operating in the United States. As protection program (e.g., fire brigade) are effective, reported in NUREG-0050, the fire sprecd along cable they are likely to withstand the challenge and prevent trays from the cable spreading room, through a cable the fire from spreading from the turbine building into pene' ration, and into the reactor building. The fire the au7iliary building. However,if the seals are burned cables in cable trays for almost 7 hours8.101852e-5 days 0.00194 hours 1.157407e-5 weeks 2.6635e-6 months . deficient, it is conceivable that they could fail under During that time. portab!e utinguishers were used the fire exposure and allow the fire to spread into the intermittent!"'.o no effect. Af ter almost 7 hours8.101852e-5 days 0.00194 hours 1.157407e-5 weeks 2.6635e-6 months , the auxiliary building. Again, the actual adverse decab., was made to fight the fire with water. Two consequences of this situation would depend on such men using a fire hose extinguished the fire within 15 factors as the location of the burnthrough into the minutes. This experience demonstrated that a auxiliary building and the location of combustibles NUREG 1552, Supp. I 10

Risk Significance / Compensatory Measures / Plant-Specific Experience l l

and important plant equipment in the vicinity of the 5 COMPENSATORY burnthrough. The significance of such a scenario MEASURES could be compo'mded by the fact that the fire wall in the turbine building could be common to several The use of fire watches in instances of degraded or auxiliary building fire areas. Therefore,if the inoperable fire barriers is an integral part of NRC-penetration seals were to fail, a single fire could approved fire protection programs. In general, these adversely impact several plant components and approved compensatory measures specify the systems.

establishment of a continuous " fire watch"if automatic fire protection systems are not installed in On the other hand, a fire involving a charging pump the fire area or an hourly fire watch patrol where motor is not likely to present nearly as significant a automatic detection systems are installed. Fire challenge to fire barrier penetrati ons installed in the watches are personnel trained by the licensees to pump cubicle walls. In this case, even if the seals are nspect for the control ofignition sources, fire deficient, the fire is not likely to have an adverse hazards, and combustible materials; to look for signs effect on plant safety systems located outside of the ofincipient fires; to provide prompt notification of Pump cubicle.

fire hazards and fines; and, in some cases, to take appmpriate actions to begin fire suppression activities. Generally, therefore, by providing 4 RISK SIGNIFICANCE additional fire prevention activities through enhanced capabilities to find fire hazards and, in the case of a De calculated core-damage frequency (CDF) from fire, through augmented suppression activities before fires, and the contribution of fire risk to a plant's total a penetration seal's ability to endure a fire is CDF,is a plant-specific determination that is challenged, fire watches compensate for degraded fire dependent on the plant configuration and the barrier penetration seals. He licensees that reported methodology and assumptions that are used for the fire barrier penetration seal deficiencies established analysis. In general, the apphcation of the calculated fire watches in accordance with their technical CDF to assess the fire risk of one plant against the spu.ifications or license conditions as a fire risk at another plant is inappropriate. compensatory measure.

The postulated fire scenarios that are the major 6 PLANT-SPECIFIC contributors to core damage for most plants are those m which the redundant divisions of post fire safe. EXPERIENCE WITH FIRE shutdown components and systems are located in the BARRIER PENETRATION same fire area. In these scenarios, fire barrier SEALS penetration seals are not considered (not modeled)in the assessment, because the factors mentioned earlier The staff reviewed in detail the status of penetration A have a greater effect on CDF. seal programs at several plants that have undertaken major penetration seal corrective action programs.

Scenarios involving the spread of fire from one plant fire area to another and evolving to core damage are 6.1 Vermont Yankee Nuclear of h..v frequency. His is a result of several defense- Power Station in-depth measures, such as administrative controls on combustible materials and " hot" work, automatic fire On March 19,1992, during an inspection of fire detection, automatic fire suppression, and barrier penetration seals at Vermont Yankee Nuclear intervention by the plant fire brigade. On the basis of Fower Station, the licensee found a penetration its reviews of fire risk assessments completed thus containing unapproved material. The next day, far, penetration seals have not been relied upon for another penetration seal was found to be degraded.

the prevention of core damage. It is the staff's The licensee took compensatory measures ed began judgment that failure of most fire barrier penetration an investigation into the cause of the degradation.

seals, would not significantly alter the overall Later, while implementing corrective actions in contribution of are risk to the plant's total calculated December 1992, the licensee found more problems.

CCF.

It performed additional seal in pections and found that the seal discrepancies were more widespread I

1I NUREG-1552, Supp.1 i

l

).

Pirnt-Specific Experience than was originally believed. On January 15,1993, of the inspections, the licensee repaired more than the licensee issued Licensee Event Report (LER) 93- 600 seals during 1987 Since 1987, the licensee has 001. The licensee declared 57 penetration seals found only minor problems during routine inoperable and established a task force to inspect all inspections, ar,d the licensee addressed these fire barrier penetration seals. Ultimately, the licensee promptly.

repaired more than 900 (64 percent) of the 1400 fire barrier penetrations installed at Vermont Yankee and 6.2.2 OIInvestigation upgraded almost 300 penetrations (21 percent). The licensee attributed most of the as-found unacceptable In September 1988, the NRC Office of Investigations penetrations to inadequate design or to installations (01)in Region IV initiated an investigation to made by a contractor between 1979 and 1980. (That determine if company officials at Promatec or contractor is no longer in business.) The licensee WCNGS knowingly and intentionally failed to notify antibuted the failure to identify these issues to the NRC in 1984 and 1985 about the defective seals.

inadequate surveillance procedures. The licensee In May 1987, Promatec had submitted a 10 CFR Part completed the repairs to affected barriers and the 21 report to the NRC, which stated that some silicone required st,rveillances in May 1993. In subsequent foam fire barrier penetration seals installed by years (1994-1997), routine fire barrier surveillances Promatec at WCNGS did not meet minimum discovered five degraded penetration seals. These specification s. During replacement of damaged fire-events were described in LERs94-018,94-018 01, resistant boards, WCNGS personnel found voids,95-004,96-026, and 96-026-01. shrinkage, and 'ack of fill in approximately 25 percent of the si als.

6.2 Wolf Creek Nuclear ne ol investigaton revealed that hath Promatec and Generating Station Kansas Gas & Electi;c (KG&E)'.)ecame aware in 1983 of a simitar problem with silicone seals at 6.2.1 Operating Experience Callaway Nuclear Power Plant, also installed by Promatec. However, a different method of in December 1984, tFe licensee for Wolf Creek installation, a two-stage damming process, was Nuclear Generating Station (WCNGS) issued a utilized at WCNGS. Following the discovery of the nonconformance report because 22 penetration seals problem at Callaway, Promatec conducted two seal lacked document traceability. The licensee reinspections at WCNGS. KG&E rejected the results completed corrective actions in 1985. Later,in early of the first of these as too $nited and indicative of a 1987 B&B Promatec Corporation (Promatec), potential problem similar to the problem encountered Houston, Texas, the penetration seal installation at Callaway. The scop: of the reinspection was contractor, notified the NRC that of 40 seals expanded; the second reinspection led Promatec to inspected, the silicone foam material in 20 showed conclude that there was a less than 2-percent rejection voids and shrinkage. The problems had involved rate of these seals from shrinkage and voids. KG&E instatstion methodology, inadequate quality control accepted the results of this reinspection and (QC) methods, and rapid, chemically induced, cor,cluded that the problem at WCNGS was minor expansion of the silicone foam material. He licensee and not indicative of the problem fond at Callawr,y.

issued LER 87-010 on February 6,1987. This problem affected several other nuclear reactors. On the basis ofits invest;gation,01 concluded that Promatec informed the industry of the probicms and the problem with the seals at WCN9S was generic, submitted a Part 21 notification. The NRC issued IN inherent both in the material and in the cable tie 88-56 to advise licensees of the problems discovered inspection method utilized at the time the seals were at Wolf Creek. installed. Of concluded that the silicone material shrinks and expands depending on temperature in 1987, the licensee established a task force to changes and that it is difficult to install seals so as to ,

develop a corrective action plan. The inspection plan ensure a complete fill, even utilizing the stage covered the removal of damming boards and damming method ofinstallation. 01 also concluded inspection of accessible foam penetrations. The that the inspection method used at WCNGS was scope of the program included inspections of more inaccurate and could not reveal all voids, gaps, or than 1700 silicone foam penetration seals. As a result missing fillin the seals.

l l

NUREG-1552, Supp. I 12

Plant-Specific Expericnce From the time the seals were first installed KG&E Rc NRC recently inspected Salem's corrective was aware of the inspection method used by actions to satisfy 10 CFR Part 50, Appendix R, Promatec. His was the acceptable method of Sections III.G, and III.L (Inspection Report 97-09).

inspection used by all sealing contractors at the time. The inspectors compared "as tanilt" penetration seals Although KG&E knew about Callaway's pro".,lems, to the fire endurance test configurations to verify that and was questioned by an American Nuclear Insurers as-built configurations were qualified by appropriate (ANI) inspector and by the NRC regarding the fire endurance tests. The inspectors opened an adequacy of the inspection method,it took no steps to inspection followup item (IFI) for as-built drawings, change to a visualinspection of the seals. which did not identify parameters regarding cable fill, thermal mass, and the maximum free area of 01 concluded that its investigation did not find unsupported penetration sealinstalled within the evidence that KG&E or Promatec personnel were penetration.

aware of specific problems at WCNGS and willfully failed to notify the NRC, as required by 10 CFR Overall, the inspectors concluded that test specimens 50.55(e). O! also concluded that there is a potentia! of the seals adequately represented and supported for similar problems at any nuclear plant that utilized qualification of the as-built seal designs that were silicone foam seals and the method ofinspection used reviewed. The inspectors also concluded that the at WCNGS, regardless of who installed the seals. licensee's engineering analysis methods appeared to The staff addressed these findings in IN 88-56, be adequate.

" Potential Problems with Silicone Foam Fire Barrier Penetration Seals." 6.4 Millstone Nuclear Power 63 Salem Nuclear Geneniting Station In LERs93-006,93-006-01, and 94-035, Millstone Nuclear Power Station reported penetration seal Fire barrier penetration seals have been inspected at discrepancies. Dese LERs addressed unsealed '

least three times at the Salem Nuclear Generating penetrations found by the licensee. He staff Station. NRC Inspection 93-80 was an Appendix R reviewed LER 93-006 in NRC Inspection Report 93-inspection in which the licensee's penetration seal 19. The inspector reviewed the licensee's actions in inspection program was evaluated. He inspection response to the discovery of the missing seals, and procedure was reviewed and the latest surveillance reviewed the surveillance procedure that the licensee report was reviewed. The liceasce inspects 10 uses to inspect seals. The inspector noted that the percent of the fire barrier penetration seals every 18 procedure was adequate to enable proper inspection months. If one failure is found, then an additional of the seals. The inspector noted that Unit I had 10-percent sample of seals is inspected until no more identified only six other missing seals since 1990 failures are identified. No failures were noted in the through the seal surveillance program. His indicates surveillance that was reviewed. The inspectors also that unsealed penetrations are not a programmatic reviewed the licensee's response to IN 88-56. He concern at Millstone.

licensee's silicone foam seals were installed without the use of damming boards, making it very easy to detect voids or gaps.

6.5 Maine Yankee Atomic Power Plant Penetration seals were inspected again as a restart issue for Salem Inspection Report 96-10. The 6.5.1 NRC Inspection licensee had completed a 100-percent inspection and evaluation of all fire-rated penetration seals in 1992. From June 26--30,1995, NRC Region I staff The inspectors reviewed the design analyses of conducted a fire protection inspection at Maine various types of penetrations and verified that the Yankee Atomic Power Plant. The inspection is licensee's penetration seal details were representative documented in NRC Inspection Report 50-309/95-15, of the tested seals, and that seals were bounded by which was transmitted to Maine Yankee Atomic acceptable fire endurance tests. The inspector Power Company (the licensee for the Maine Yankee concluded that the quality and configuration of plant) by letter dated September 20,1995.

penetration seals were acceptable.

13 NUREG-1552, Supp.1 l

Plant-Specific Experience The inspector reviewed the fire barrier program to deficiencies: (1) inadequate thickness of silicone verify the adequacy of penetration seal installation, foam, (2) temporary seals that were not upgraded to qualification, and inspection activities. permanent seals for an indeterminate period, and (3) one seal for which the expected pipe movement he inspector reported that Maine Yankee relied on exceeded the design rating of the seal.

Insulation Consultants & Management Services.

- Incorporated (ICMS), to install the original 6.5.3 Staff Followup penetration seals. De licensee informed the inspector that it had reviewed its purchase order During a telephone conference on May 14,1997, information and project files and found that it did not Office of Nuclear Reactor Regulation (NRR) and apply any in-house quality control review for the Region I staff obtained detailed information from the ICMS fire barrier installation work. The licensee licensee regarding the seal problems found and the could not find the qualification and test reports corrective actions. In addition, during the week of completed by ICMS to support the seal installations, May 12,1997, NRR staff reviewed and observed the including fire and pressure test reports and problems found at Maine Yankee and the licensee's qualification of seal installers. Derefore, the corrective actions.

inspector could not verify the qualification of the penetration seals installed at Maine Yankee. The penetration seals at Maine Yankee were installed around 1978. Most of the original seals 2 sed silicone De inspector opened an unresolved item regarding foam. Since the original installation, the licensee has the acceptability of penetration seal qualification, visually inspected all the seals at each refueling testing, and installer qualifications. outage.

6.5.2 Licensee Event Reports During the inspections and walkdowns that were documented in LER 96-017 01, the licensee found After the NRC staff fire protection inspection, the that more than a thousand seals required further licensee conducted a scoping study in preparation for evaluation (inch. ding destructive examination); about fire barrier penetration seal walkdowns. By letter a thousand other seals had defects; and a small dated July 29,1996, the licensee submitted LER 96- number of seals had no defects. The licensee found Ol7. " Fire Barrier Penetration Seal Discrepancy." seals with inadequate $ickness (the predominant ne licensee reported that, during the scoping study, problem), foreign matenals in seals, no damming it found fire barrier wall penetration seals that did not material, and the wrong seal material installed.

have damming material in the proper location. On Although the licensee's design criteria specified a the basis of these findings, the licensee examined its minimum seal thickness of 7 inches, the average seal criteria for penetration seals and conducted a thickness was 5 to 6 inches, and some seals were only technical review of its penetration seal design . 2 to 3 inches thick. Although the licensee once parameters. The licensee found discrepancies planned to repair and replace the seals with silicone between available test reports and procedural foam and silicone elastomer, the licensee has since guidance, and the in-plant penetration seal certified permanent cessation of power operation and configurations. In response to the discrepancies, the is now proceeding to decommission the facility. ,

licensee implemented compensatory fire watches and developed a corrective action program. De planned The licensee informed the staff that it believes that corrective actions were (1) determining why the the installation deficiencies occurred because the

- discrepancies were not found during previws quality assurance and quality control procedures used reviews; (2) evaluating the adequacy of procedures, by the installation contractor during original seal test reports, acceptance criteria, and field inspections; installation were inadequate. He licensee also (3) evaluating the adequacy of existing seal informed the staff that it believes it took so long to configurations; and (4) inspecting all fire barrier discover the deficiencies becauce its inspection and penetration seals. surveillance procedures did not cover all important penetration seal attributes (e.g., the presence of

. By letter dated August 28,1996, the licensee damming material was not a critical attribute) and

- submitted Revision I to LER 96-017. De licensee because training was insufficient. De licensee has reported that it had found three additional types of completed a major rewrite ofits procedures.

l NUREG-1552, Supp. I 14

Plant-Specific Experience / Review of Licensing Bases 7 REVIEW OF PLANT-t The staffissued Information Notice (IN) 97-70,

" Potential Problems With Fire Barrier Penetration SPECIFIC LICENSING Seals " on September 19,1997, to tellindustry of the BASES RELATED TO proolems found at Maine Yankee. As mentioned SECTION III.M OF above, the licensee has since decided to shut the plant APPENDIX R TO 10 CFR down permanently. PART 50 6.5.4 Conclusions on Maine Yankee 7.1 Introduction Operating Experience On November 19,1980, the U.S. Nuclear Regulatory In NUREG-1552," Fire Barrier Penetration Seals in Commission (NRC) published Appendix R, " Fire Nuclear Power Plants" (July 1996), the staff stated Protection Program for Nuclear Power Facilities that even though the overall condition of penetration Operating Prior to January 1,1979," to Title 10 of the seal programs in industry is satisfactory, it expects Code of Federal Regulations (10 CFR) Part 50, and a that plant :pecific deficiencies may be found during revised Section 50.48," Fire protection,"in the future licensee surveillances and NRC inspections. Federal Register. The revised Section 50.48 and Furthermore, the staff noted that licensees undastand Appendix R became effective on February 17,1981.

potential fire barrier penetration seal problems; It is important to note that Appendix R is not a set of industry consensus fire test standards are available generically applicable fire protection requirements and licensees adhere to them; and fire test results and and that it applies only to plants that were operating ,

qualified fire-resistant seal materials and designs are before January 1,1979. l available. On these bases, the staff concluded that i

licensees have the means to correct problems, and Section III of Appendix R contains 15 subsections, ;

staff oversight will continue to ensure corrections on lettered A through O, which specify requirements for j a case-by-case basis. The penetration seal problems nuclear power plant fire protection features. %ese I found by the NRC inspector at Maine Yankee and requirements are divided into two categories. The i later reported by the licensee are consistent with the first consists of those requirements that were backfit known types of problems, as previously documented to facilities operating before January 1,1979, by the staffin NUREG-1552. He reported problems regardless of whether or not the staff had previously !

do not indicate new trends. approved attematives to the requirements of those sections. These requirements are found in Section 6.6 Conclusions Ill.G," Fire protection of safe shutdown capability"; l Section III.J, " Emergency lighting"; and Section l LERs, NRC inspections, and plant-specific corrective

, c n systems f r re et r c lam Pumps.' he second category consists of j

action programs summarized above show that licensees knew and understood the fire-resistive requirements that were backfit ou a plant-specific I basis to the extent needed to resolve the "open" items capabilities of the penetration seal materials and f previ us NRC staff fire protection reviews. An

)

configurations; potential penetration seal testing, Pen item was defined as a fire protection feature that design, installation, inspection, and maintenance problems; and possible remedies and corrective had not been previously approved by the NRC staff actions. These findings also indicate that the actions ,as satisfying the guidelines of Appendix A to Branch taken by the staffin 198G and 1994 had increased

"#*' sition (BTP) APCSB 9.5-1, as I documented m. a staff safety evaluation report (SER).

industry awareness of possible penetration seal Section III.M, " Fire barr%r cable penetration seal problems, leading industry to more comprehensive surveillance activities, maintenance practices, and 9"*". . cati n," f Appendix R was one such j corrective actions. To provide added assurance that Provision. '

penetration scal deficiencies will be found, the staff Secti n III.M states that penetration seal designs shah.

revised the NRC fire protection core inspection utilize only noncombustible materials and shall be module to provide specific inspection guidance to NRC inspectors. qualif ed by tests that are comparable to tests used to

rate fire barriers.Section III.M contains the l following acceptance criteria

15 NUREG-1552, Supp. I

Review of Licensing Bases (1) Cable fire barrier penetration seal has materials was addressed by the licen:ees and the withstood the fire endurance test without staff. The findings of these reviews are documented passage of flame or ignition of cables on the below.

unexposed side.

7.2 Plant-Specific Licensing Bases (2) Temperatures recorded on the unexposed side are analyzed and the maximum temperature is 7.2.1 Calvert Cliffs Nuclear Power sufficiently below the ignition temperature of Plant, Units 1 and 2 the cable insulation temperature.

He fire barrier penetration seal remains intact By letter dated November 24,1980, the staff (3) informed Baltiraore Gas & Electric Company, the and does not allow a projection of water licensee for the Calvert Cliffs Nuclear Power Plant, beyond the unexposed surface during the hose Units I and 2, that the issue of ventilation and duct stream test.

fire dampers was an open item. The issue of fire l barrier penetration seals was not an open item when l After it published Appendix R in the Federal Appendix R was issued. Therefore, Section Ul.M of

! Register, the staff sent letters to the licensees it Appendix R does not apply to the fire barrier applied to summarizing the open fire protection items and told each licensee which specific Appendix R penetration seals installed at Calvert Cliffs.

requirements it had to comply with to resolve the items. Before the staff published NUREG-1552, 7.2.2 Duane Arnold Encrgy Center Brookhaven National Laboratory (BNL), the staff's technical assistance contractor, reviewed these letters Silicone-based penetration seal materials are installed l

and found that 13 units had open items regarding fire in the plant.

l barrier penetrations when Appendix R was published.

They' were: In a letter of April 1,1980, Iowa Light and Power Company, the licensee for the Ouane Arnold Energy Calvert Cliffs 1/2 Maine Yankee Centes, stated that the penetration fire stops were Point Beach I/2 Duane Arnold conservatively designed and provided an adequate Peach Bottom 2/3 Robinson 2 margin of safety for the plant fire protection design.

FitzPatrick Pilgrim 1 In a letter of November 24,1980, the staff infonned Surry 1/2 the licensee that the tests described in its letter of April 1,1980, did "not substantiate the fire resistance On the basis of BNL's review, the staff reported in of the penetration seals installed at the plant." The NUREG-1552 that Section Ill.M of Appendix R staff also stated that "[t]o meet the requirements of applied to 13 nuclear power plants. In support of the Section III.M of Appendix R to 10 CFR Part 50, the review documented here, the staff again reviewed the licensee should provide additional documentation to licensing basis for the Appendix R plants and added verify that the seals which were tested and passed Monticello and Vermont Yankee to the list of plants were representative of those actually installed."

that may be required to comply with Section III.M of Appendix R. The staff then conducted a detailed The licensee responded in a letter of February 4, review of the fire protection licensing bases for these 1981, in which they compared the fire barrier 15 units to determine if the plants used silicone based penetration seal configurations they tested to those fire barrier penetration seal materials, which are installed in the plant, and claimed that the classified as " combustible" when tested in information provided in previous correspondence was accordance with ASTM Standard E-136,4 and,if they sufficient to close the open item regarding fire barrier did contain such material, how the regulatory penetration seals.

requirement of Section III.M of Appendix R that penetration seals utilize only noncombustible 7.2.3 James A. FitzPatrick Nuclear Power Plant

'" Behavior of Materials in a Vertical Tube Furnace at Silicone-based penetration seal materials are installed 750 %C," a pass / fail combustibility test metliod in the plant.

accepted by the NRC.

l NUREG-1552, Supp. I 16

Review of Licensing Bases In a letter of February 13,1981, the stafT transmitted issued an exemption from the technical requirements to Power Authority of the State of New York, the of Section III.M of Appendix R to the extent that licensee for James A. FitzPatrick Nuclear Power certain penetration seals contain combustible Plant (FitzPatrick), a supplemental SER in which it material. In the safety evaluation supporting the concluded that the silicone elastomer penetration exemption, the staff stated that the penetration "scals ,

seats installed at FitzPatrick met the criteria of which contain combustible materials will provide an l

Section III.M of Appendix R and were, thereft re, equivalent level of protection to that required by l acceptable. The open item regarding fire barrie Section III.M of Appendix R." In the exemption, the l penetration seals at FitzPatrick was closed befon the staff stated that "the application of the regulation in effective date of Appendix R. Therefore, Sectior, this particular circumstance is not necessary to III.M of Appendix R does not apply to FitzPatrick achieve the underlying purpose of the rule.

l Additionally, compliance with Section III.M i

7.2.4 Maine Yankee Atomic Power Plant concerning the subject seals would result in costs that are significantly in excess of those contemplated l In Section 6.5 of this report, the staff discusses Maine when the regulation was adopted since it would result l Yankee. The plant has been permanently shut down in the complete removal and total replacement of all and is being decommissioned. seals in question."

7.2.5 Monticello Nuclear Generating 7.2.7 Pilgrim Nuclear Power Station, Plant Unit 1 In a letter of November 24,1980, the staff informed Silicone-based penetration seal materials are installed Northern States Pcwer Company, the licensee for in the plant.

Monticello Nuclear Generating Plant, that the cable tray penetrations at the south wall of the pipe and In a letter of December 15,1980, the staff transmitted cable tray penetration area do not have adequate fire to Boston Edison Company, the licensee for Pilgrim stops or adequate penetration seals. An NRC review Nuclear Power Station, Unit 1, an SER closing an determined that the vertical cable trays that open item regarding fire barrier penetration seals. In penetrated the fire barrier were not sealed tc provide that SER, the staff sated: "[t]he licensee's proposed adequate 3-hour fire resistance. Therefore,in order upgrading of penetration seals will result in seals to comply with Section III.M of Appendix R, the which meet the requirements of Section III(M) [ sic) licensee needed to install penetration seals that have a of Appendix R to 10 CFR 50 and, therefore, are 3-hour Fre-r6 stance rating. On October 20-24, acceptable." The open item regarding fire barrier 1986, a team of Region III and NRR personnel penetration seals at Pilgrim was closed before the performed an inspection to determine the licensee's effective date of Appendix R. Therefore, Section implementation of and compliance with the III.M of Appendix R does not apply to Pilgrim.

applicable requirements of 10 CFR Part 50, Appendix R. In Inspection Report 50-263/86008 (DRS), the 7.2.8 Point Beach Nuclear Plani, inspection team determined,"the licensee does now Units 1 and 2 meet Section III.M of Appendix R and this 'Open' item is now considered closed." Silicone-based penetration seal materials are installed 7.2.6 Peach Bottom Atomic Power Station, Units 1 and 2 In a letter of November 24,1980, the staffinformed Wisconsin Electric Pc wer Company, the licensee for Silicone-based penetration seat materials are installed Point Beach Nuclear Plant, Units 1 and 2, that the in the plant, issue of penetration seals was an open item and that the licensee was required to comply with Section In a letter of November 24,1980, the staff informed III.M of Appendix R. In a letter of January 22,1981, i

Philadelphia Electric Company, the licer.see for the staff transmitted to the licensee a supplemental l Peach Bottom Atomic Power Station, Units 1 and 2, SER, in which it concluded that the penetration seals that the issue of penetration seals represented an open installed at Point Beach met the criteria of Appendix L

item. ~ By letter of November 14,1986, the staff A to BTP APCSB 9.5-1 and were, therefore, 17 NUREG-1552, Supp.1

Review of Licensing Bases acceptable. He open item regarding fire barrier 7.2.11 Vermont Yankee Nuclear Power 7

penetration seals at Point Beach was closed before Station the effective date of Appendix R. Therefore, Section Ill.M of Appendix R does not apply to Point Beach. In a letter of January 13,1978, the NRC issued License Amendment 43 to Vermont Yankee Nuclear 7.2.9 H.B. Robinson Steam Electric Power Station's operating license. This amendment, Plant, Unit 2 included item 3.1.8," Cable penetrations do not have a fire rating and do not provide adequate protection."

Silicone-based penetration seal materials are installed In a letter of November 24,1980, to Vermont Yankee in the plant. Nuclear Power Corporation (VYNPC), the licensee for Vermont Yankee, the staff again noted that Item In a letter of November 24,1980, to Carolina Power 3.1.8 was unresolved owing to the lack of supporting and Light Company, the licensee for H.B. Robinson qualification tests. In a letter of December 19,1980, Steam Electric Plant, Unit 2, the staff stated that to to the NRC, VYNPC stated:" Vermont Yankee intends meet Section III.M of Appendix R to 10 CFR Part 50, to maintain its commitment to provide 3-hour rated "the licensee should provide cable penetration seals fire barrier penetration seals." In a letter of which utilize only noncombustible materials and December 31,1980, Region I followup inspection 50 should be qualified by tests that are comparable to 271/80-18 of Vermont Yankee fire barrier penetration those used to rate fire barriers." In a letter of seals, three inspection items were opened ccncerning November 25,1983, the staff issued an exemption the item 3.1.8. The open items were 80-18-01, an from the technical requirements of Section III.M of untested configuration; 80-18-02, questions on Appendix R to 10 CFR Part 50, to the extent thtt the materials used to construct the penetration seals; and acceptance criteria for penetration seal qualification 80-18-03, a commitment tc, replace / upgrade existing required that the temperatures recorded on the penetration seals. In a letter of December 23,1981, a unexposed side of the seal be below the cable Reson I inspector reviewed open item 80-18-02, insulation ignition temperature. Neither the found the licensee actions acceptable, and closed the exemption nor its supporting safety evaluation item. In a letter of April 22,1982, Region I addressed the fact that the penetration seals used inspectors reviewed open items 80-18-01 am! 80 combustible materials. 03, found the licensee actions acceptable, and closed the open items. Additionally,in an intemal NRC 7.2.10 Surry Power Station, memcrandum dated April 16,1982, to nomas Novak, Assistant Director for Operating Reactors, Units 1 and 2 from William Johnson, Assistant Director of In a letter of in a letter of November 24,1980, to Materials and Qualifications Engineering, Johnson stated: "open item 3.1.8 is now considered clos.ed Virginia Electric and Power Company, the licensee based on VYNPC's commitment to comply with for Surry Power Station, Units 1 and 2, the staff stated that "[t]o meet the requirements of Section Section III.M of Appendix R."

III.M of Appendix R to 10 CFR 50, the licensee should upgrade all unsealed or inadequately sealed 7.3 Summary penetration openings to provide a 3-hour ASTM E-119 fire rated penetration seal where the fire rating of On the basis of its review of letters that the staff sent the barrier pnetrated would be 3 hours3.472222e-5 days 8.333333e-4 hours 4.960317e-6 weeks 1.1415e-6 months ." December to the licensees of plants that were operating before 18,1980, th: staff transmitted to the licensee a January 1,1979, after Appendix R was approved but supplementi SER in which it concluded that the before it became effective, it appeared that Section penetration seals installed at Surry llI.M of Appendix R applied to 15 nuclear power met the criteria of Appendix A to BTP APCSB 9.5 1 plants. However, on the insis of the detailed review and were, therefore, acceptable. He oper item summarized above, the staff found that Section Ill.M regarding fire barrier penetration seals at Surry was of Appendix R applied to: Duane Arnold, H.B.

closed before the effective date of Appendix R. Robinson 2. Maine Yankee, Monticello, Peach Rerefore, Section Ill.M of Appendix R does not Bottom 2/3, ?nd VermontYankee. Of these plants, apply to Surry, the staff has granted exemptions for H.B. Robinson 2 and Peach Bottom 2/3. On the basis of its review of docketed information, the staff could not determine I

NUREG-1552, Supp. I 18

Recommendations how the penetration seal open items were resolved at stated that it would present guidance for inspecting Duane Arnold and Maine Yankee. The staff will fire barrier penetration seal programs in the FPFI continue its review of Duane Arnold. Because the procedures and guidelines for use by NRC inspectors licensee has permanently shut down Maine Yankee on an as-needed basis.

and is currently decommissioning it, the staff will not pursue this issue at Maine Yankee. Tb other plants 8.2 Status discussed above, FitzPatrick, Pilgrim, Point Beach _,

and Surry _, resolved the penetration seal open item before the effective date of Appendix R. Herefore, 8.2.1 Recommendations 1,2, and 3 Section III.M of Appendix R does not apply to these (Pending) plants.

Recommendations 1,2, and 3 involved revising the NRC fire protection regulation (Appendix R) and 8 RECOMMENDATIONS IN miew guidance (SRP). In its final report on THE FINAL STAFF REPORT $"pf',"$"a';**f t the re oNend t$ns would be s

useful to the industry, but did not identify technical or 8.1 Introduction safety bases that justified an immediate need to implement them.

In SECY-96-146,' Technical Assessment of Fire Burier Penetration Seals in Nuclear Power Plants" The NRC staff is considering a performance-based, (July 1,1996), the staff informed the Commission risk informed fire protection regulation. After the that the Office of Nuclear Reactor Regulation (NRR) staffissued its final report " Technical Assessment of had completed the subject assessment and forwarded Fire Barrier Penetration Seals in Nuclear Power to the Commission a copy ofits fir,al report entitled, Plants"(June 14,1996), it issued SECY-96-134,

" Technical Assessment of Fire Barrier Penetration " Options for Pursuing Regulatory Improvement in Seals in Nuclear Power Plants"(June 14,1996). In Fire Prote: tion Regulations for Nuclear Power its final report, the staff recommended the following: Plants" (June 21,1996). In that SECY paper, the staff recommended developing (1) a rulemaking that (1) Revise the NRC fire protection guidance would remove the current Appendix R regulatory do^uments to reflect the current National Fire requirements and (2) a comprehensive regulatory Protection Association (NFPA) position on guide on fire protection. He Commission approved testing laboratories. this staff recommendation in a staff requirements memorandum (SRM) of October 2,1996. Later, in (2) Remove the noncombustibility criterion from SECY-98-058," Development of a Risk-Informed Appendix R to 10 CFR Part 50 and Standard Performance-Based Regulation for Fire Protection at Review Plan (SRP) Section 9.5.1. Nuclear Power Plants," March 26,1998, the staff provided three additional rulemaking options for the (3) Develop c.nd issue guidance for comparing fire Corrmission's consideration and proposed to develop test configurations to as-built configurations. a comprehensive regulatory guide for reactor fire protection.

(4) Make [the technical assessment report attached to SECY-96-146] available to the general For the reasons detailed in " Technical Assessment of publie and industry by placing it in the NRC Fire Barrier Penekation Seals in Nuclear Power Public Document Room and issuing an Plants"(June 14,1996) and summarized in this information notice publicizing its availability. supplement to NUREG-1552, it is the staff's position that implementation of Recommendations 1,2, and 3 does not warrant urgent or high-priority staff action in its fina' report, the staff also noted that it was or the commitment oflimited staff resources.

preparing the new Fire Protection Functional nerefore, the staff will implement the Inspection (FPFI) Program that it had described in recommendations as pan ofits ongoing performance-SECY-95-034," Status of the Recommendations based, risk-informed fire protection rulemaking effort Resulting from the Reassessment of the NRC Fire as described in SECY-96-136 and SECY-98-058, or Protection Program"(February 13,1995). The staff as directed by the Commission. His will resolve 19 NUREG-1532, Supp. I u __

Recommendations / Conclusions t

Recommendation 2,in part. In addition, issuing a to comply with one regulation or another is an comprehensive regulatory guide on fire protection, indication of the absence of adequate also described in SECY-96-136 and SECY-98 058, protection, at least in a situation where the will satisfy the intent of Recommendations 1,2, and 3. Commission has reviewed the noncompliance and found that it does not pose an " undue risk" 8.2.2 Recommendation 4 (Complete) to the public health and safety.8 In July 1996, the staff published NUREG-1552," Fire The failure to have fire barrier penetration seals that Barrier Penetration Seals in Nuclear Power Plants." meet the criteria specified by the NRC fire protection This action completed Recommendation 4. guidance documents does not indicate that a plant is unsafe.

8.2.3 FPFI Program (Complete)

On the basis of everything it found and considered, it is the staff's judgment that, generically, the issue of The staff is currently using its FPFI procedures to ,

conduct C.e pilot FPFI program. The NRC's routine Potential fire barner penetration seal deficiencies, does not affect safety. For the reasons given in this fire protection inspection procedures are in the NRC rep rt, typical penetration seal deficiencies do not Inspection Manual, Inspection Procedure 64704, equate to a lack of adequate protection or result m

" Fire Protection Program." In September 1997, the undue n,sk to public health and safety, staff revised these procedures to provide more specific guidance for inspecting the seals and On the bas,s i of the reassessment documented here, establishing their functionality.

the staff concluded that the actions it took m 1988 ;

and 1994 to alert licensees to potential penetration i se I pr blems increased industry awareness of such I 9 CONCLUSIONS problems and resulted in more thorough surveillances, maintenance, and corrective actions.

Since the fire at the Browns Ferry Nuclear Plant m March 1975, nuclear power plant licensees have The staff also concluded that the general condition of made sigmficant improvements in their fire protection I penetration seal programs in industry is satisfactory.

programs. These improvements, especially the adoption of the defense-in-depth concept of echelons The staff will continue its reviews and inspections of of fire protection, have reduced both the probability penetration seals and licenseo penetration seal and the potentially adverse consequences of nuclear programs. The staff expects that plant-specific power plant fires. Using documented industry deficiencies may occasionally be found during operating expenence, the staff carefully and licensee surveillances and NRC reviews and objectively evaluated issues associated with fire inspections. In such cases the staff will continue to barrier penetration seals. The staff considered the take appropriate regulatory action ta address any potential safety and risk significance of potential deficiencies discovered. However, potential penetration seal deficiencies and the use of

. penetration seal problems are understood; industry compensatory measures for any potential degradation consensus fire test standards are asailable and are in the fire protection effectiveness of seals.

followed; and fire test results and qualified fire.

For the reasons discussed in Section 3 through 5, the

""*#"'** * "" *8"*"' ***"" '

. . . Therefore, licensees have the means to identify and staff considers that the relative safety sigmficance of correct problems, and continued staff oversight '. vill the subject fire barrier penetration seal concerns is continue to ensure corrections on a case-by-case low. Even assuming that certain fire barrier basis. In addition, the fire protection defense.in.

penetration seals are deficient, it does not follow that depth concep; provides reasonable assurance that the deficiencies indicate the absence of adequate deficiencies will not present an undue risk to public protection. The Commission has explained that health and safety before they are found and corrected.

j [W]hile it is true that cc,mpliance with a!! NRC

! regulations provides reasonable wurace of adequate protection of the public health and ' Ohio Citizens for Responsible Energy, l safety, the converse is not correct, that failure DPRM 88-4,28 NRC 411 (1988).

i NUREG 1552, Supp. I 20

. . _ _ _ . _ . . _ _ . . _ _ _ _ _ . _ . _ _ _ _ . _ . . _ - . _ _ _ _ _ _ . . _ . . . ~ .

Conclusions l

l- .

l The results of this assessment, which used adequate (1) to ensure that penetration seal problems information that the staff had not considered in the are discovered and resolved and (2) to maintain evaluation documented in NUREG 1552," Fire public heahb and safety. To provide added assurance Barrier Penetration Seals in Nuclear Power Plants," of this, during the assessment documented in this l have reinforced the staff's earlier conclusion that report, the staffissued Information Notice 97 70, RTV silicone foam penetration seals like other types " Potential Problems With Fire Barrier Penetration of penetration seals installed in US nu:Icar power Seals," September 19,1997, and revised the NRC fire

. plants, provide reasonable assurance that a fire in a protection core inspection module to provide more specific fire area or zone will be confined to the area specific inspection guidance to NRC inspectors ofits origin. regarding fire barriers and fire barrier penetration seals. De staff will continue to assess new In sum, it is the staff's opinion that continued information regarding penetration seals for new licensee upkeep of existing penetration seal programs insights and appropriate opportunities for additional and continued NRC reviews and inspections are actions by the staff or the industry.

l 1

l l

1 I

21 NUREG-1552, Supp.1

i l

Appendix D Acronyms and Abbreviations BNL Brookhaven National Laboratory CDP. core-damage frequency CDR construction deficiency report DRS division of reactor safety ICMS Insulation Consultants & Management Services, Incorporated IFI inspection followup item

)

KG&E Kansas Gas & Electric 01 Office ofInvestigations (NRC)

ORNL Oak Ridge National Laboratory )

1 PVC polyvinyl chloride )

RTV room temperature vulcanizing SER safety evaluation report -)

SRM staff requirements memorandum j URI unresolved issue VYNPC V:rmont Yankee Nuclear Power Corporation WCNGS Wolf Creek Nuclear Generating Station l

l i

D-1 NUREG-1552, Supp. 1

Appendix F Licensee Event Reports Submitted by Year 1987 Through June 1997 1 l jYeai/K $NaianetSisih, yNumbeferLIJts' 4$$ $ amber:NSuM%y 1987 12 16 3 1988 9 12 4 1989 12 14 9 1990 8 11 5 1991 7 8 10 1992 3 8 8 l

1993 7 8 6 I

1994 6 6 5 1995 4 4 3 1996 5 5 1 1

1 1997 2 0 2 TOTAL 40 92 56 -

I 1

I l

l l

F1 NUREG-1552, Supp. I

Appendix G Summary of Reported Problems 1987 Through June 1997

- 46nun ;gs:4'ProblesseydMg,g? . _sgw .

gc. -~w s Wm%% .: w.ww ~x ~ w x m., =y n ng .v, _e.. ~.

D - 9 M afOeeerreness" nip'%M %C ,l a- w % , M; p; p es-.s . re-

gy . 23- 239. ; gg . 591e r-'92--

yp" yt:./a t-r w_4 e e ;e ;;p_ . A eu % % s. . .4 n ,:*. w% i t -- a-i x: ce % % .:n

. g3 -

93: 194' t 95 ' E 96s i 97 Seheseal a $TeleI7' Penetrations unsealed 10 6 6 4 1 3 4 ! I - -

36 Seal breached and not repaired 4 I I 2 -

2 - -

.1 - -

1I Internal conduit seal not installed I 1 3 1 -

1 -

2 - - -

9 Qpwn

m. _ ; . . : - , m,_ _ . , ,. ,, .

.y g~

LTegel ' Seal PIst ammamand es Breached '- U . , ~* ,.

2 15 8 10 7 1 6 4 3 2 - - W 56 W, Voids, gaps, splits, shrinkage, cell structure 1 4- 3 4 2 2 -

2 - - -

18 Inadequate seal thickness 1 2 1 - -

3 2 2 -

1 -

12 2 Seal not properly installed - -

1 I 2 2 2 2 -

1 -

1I Incorrect seat material installed 1 2 1 -

I - -

1 - - -

6 Temporary s-al not replaced 1 -

1 - -

1 I - -

1 -

5 Inadequate seal repair ' -

1 - -

1 I - -

1 - -

4 bty ... . . Zi:

^

J b :: HS.c TeenI-Semiltee Peteesty E==amaand e

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+

4 9 7 5 6 9 m.unw M;.f56*6 Q ^ .^ y '

5 7 1 3 -

~m p , - m v- _

,,qq. , ;g TeseILIsedeensle h; n%

- , g ; .. . .

1 5 2 3 1 -

1 I 1 3 -

18 : U18 9 +

Seal degraded or damaged 2 2 1 -

1 3 - -

1 I -

1I g Missing or damaged damming boards 1 1 1 - -

1 -

6

. wm , , ,~r.-

y,g,g;Seid Degraded dIbsessmed'A

< ; .- 2. -n+

?"* !n , . XemW 3 3 2 -

I 4 -

1 I 2 -

W17M*

3 Totals 23 25 21 15 9 19 10 12 5 8 0 147 C/3 C

'O E

~~

Appendix H Summary of Licensee Event Reports 1987 Through June 1997 (Appendix R plants (plants operating prior to January 1.1979) are shown in bold font.)

khbhh$hMbNMbhhbi6hMbMD' NtEREN$$hN Nbbib R NMb$b$hNd$$$$

PLANT LER NO. ACCESSION NO. REPORT ANO2 87-001-00 8703180073 2 conduits missing internal seals.

FitzPatrick 87-011-00 8709020094 224 out of a total of 16,000 pencrations found unsealed.

a 87-011-01 8802030335 Updated 87-01100. Installation specification, surveillance procedures revised.

Fort St. Vrain 1 87-006-00 8704160030 Unsealed penetrations and degraded seals.

87-006-01 8705180247 Updated 87-006-00.

Monticello 87-011-00 8705260063 1 unsealed penetration.

Nine Mile Point 2 87-016-00 8703310063 1 penetration sealed with incorrect seal material. Similar seals inspected.

87 016-01 8707010536 Unsealed penetrations and breached seal.

87-018-00 8704150327 1 breached seal.

Quad Cities % 87-028-00 8803080281 Several damaged seals, several unsealed penetrations, and 7 inadequate temporary seals.

River Bend Station 87-021-00 8711170189 2 unsealed penetrations.

Salem % - 87-007 8706150188 1 unsealed penetration.

Susquehanna1 87 011-00 8705050296 1 unsealed penetration.

TMI-l 87-003-00 8705080327 1 unsealed penetration.

WNP2 87 004-00 8705130234 Design drawings were incomplete,2 unsealed penetrations, and I seal not included in surveillance procedure.

87-029-00 8710220153 I seal not repaired after breaching to remove cables.

87 030-00 Penetrations not sealed.

l l

H1 NUREG-1552, Supp. I

Summary of Lic:nsee Event R: ports J

(;: >- :.A ; , 1, '

1987lc$t!nuhd) '

W

=_.

PLANT LER NO. ACCESSION NO. REPORT WolfCreek 87-001-00 8702100286 I seal was found breached.

87-010-00 8703250035 Several seals found breached. Surveillance procedure enhanced, personnel trained.

87-010-01 8707150537 Fire protection program to be upgraded. Nonconforming silicone foam seals found (missing or damaged damming boards, inadequate seal thickness, voids, shrinkage).

l 87-010-02 8804050361 Final update of 87-010-00. Perfonned sample inspection program by removing l

damming boards from 40 seals; 13 rejected for insufficient foam thickness,9 rejected for voids and shrinkage. Performed 10G%

inspection (1700 seals). Repaired and reworked over 600 seals.

~'u< s M / Q it ]

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b Ginna1 88-009-00 8811090368 Several degraded seals and seals with incorrect seat material found.

II.B. Robinson 2 88-018-00 8810070343 101 cable tray penetration seals inspected.

38 not sealed inside tray covers due to inadequate installation procedure.

Procedures revised.

88-018-01 8906190260 Updated 88-018-00.

McGuire 1 88-030-00 8811150235 Review conducted in response to IN 88-04.

96 seals declared inoperable due to lack of test documentation.

88-030-01 89022700381 Updated 89-030-00. Seals qualified by test.

Procedures impreved.

Nine Mile Point 88-009-00 8804280564 Replaced by 88-009-01.

88-009-01 9006180174 Task force formed and 100% seal inspection initiated.13 seals did not have adequate supporting documentation. Fire prcsection progrem enhanced.

88-009-02 9008230138 14 seals did not have adequate documentation.

NUREG-1552, Supp. I H-2

l Summary of Licensee Event Reports l

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? 890B(continued)i PLANT LER NO. ACCESSION NO. REPORT Oconee %/3 88-005-00 8806270349 Review conducted in response to IN 88-04.

100% sealinspection revealed 188 inoperable seals due to inadequate documentation. Procedures revised.

River Bend Station 88-009-00 8804050384 3 unsealed penetrations and one inadequate seal found.

88-009-01 8805100011 1 unqualified penetration seal found.

88-009-02 8808310152 Unsealed conduits, unsealed penetrations, !

l breached seals, and incompletely sealed penetrations found.

Salem % 88-013-00 88L9140180 Several silicone foam seals did not conform to correct color and cell structure. Existed since originalinstallation. Installation procedure revised.100% of foam seals inspected to verify compliance with installation criteria.

88-014-00 E810040008 Purpose of LER was to report missed surveillance for inoperable penetration seals.

Also, summarized seals inoperable because of degradation, wrong seal material, shrinkage, and unsealed penetrations.

Waterford 3 88-011-00 8806300078 1 seal found that did not conform to standard design.

88-025-00 8811170093 Unsealed penetrations found.

88-030-00 8812150039 100% seal inspection.

Found unsealed penetrations, missing damming boards, and silicone foam seats with voids.

88-030-01 8906050115 Updated 88 030-00. Damming boards removed from seals for inspection. Found 99 seals with voids,123 seals that differed from typical design details,17 seals that deviated from vendor requirements, and 19 unsealed penetrations.

88-030-02 8907190362 Updated 88-030-00. Installation procedures l changed.

l 88-030-03 9109060034 Updated 88-030-00. 228 seals to be j reworked.

113 NUREG-1552, Supp. I

Swnmary of Lictnsee Event Reports O [ 9 '; E, d :lgggg( b g ;: W t yg Q 4 %M ', f@-: 'Og l .

l PLANT LER NO. ACCESSION NO. REPORT WNP2 88-008-00 8805030155 11 inoperable seals due to unapproved configuration, inadequate seal thickness, seals improperly repaired. Updated seal database.100% dccumentation review and seal inspection.88-008 01 9302220125 Updated 88-008-00.

y ;)V ' r

y 3:.

39g9 ? W; * ' ,4 ap * ' [lj PLANT LER NO. ACCESSION NO. REPORT ANO1 89-003-00 8903280098 2 penetrations sealed with unqualified material.

Big Rock Point 89-006-00 8908240314 Licensee initiated penetration seal verification program in response to In 88-04 and IN 88-56. I seal breached and not repaired, I seal inadequately installed.

89-006-01 9004130265 3 inadequate scals and I seal with a gap were found.

Calvert Cliffs 2 89-002-00 8904050315 Conduit missing internal seal.

89-002-01 8911210052 Updated 89-002-00.

Clinton 1 89-006-00 8902230041 3 conduits missing intemal seals.

Dresden 2 89-030-00 8911280062 1 unsealed penetration. Procedures improved.

Fort St. Vrain 89-014-00 8909250113 4 seals did not meet cell structure criteria.

89-014-01 8912270289 Updated 89-014 00,2 seals deleted from the LER.

Haddam Neck 89-001-00 8902070157 1 temporary seal found inoperable. Seal upgrade program conducted in response to IN 88-04.

89-001-01 9101140199 Several unsealed penetrations found during seal upgrade program.

Monticello 89-001-00 8902080493 6 unsealed penetration found.100%

inspection initiated.

NUREG-1552, Supp. I H-4

Summary of Licensee Event Reports khkkM$$ kf@N D NYSM /NNYIggpk M '$@ntM N N M % $8?d M 4N M PLANT LER NO. ACCESSION NO. REPORT Monticello 013 00 8908070189 Several unsealed penetrations found.

(continued) a 89-013-01 9001100234 Updated 89-013 00. Inspection completed.

No additionaldeficiencies found.

Palisades 89-024-00 8912260122 Inspection conducted in response to IN 88-04. I unsealed penetration found.

River Bend Station ' B9-005-00 8903240060 Void found in I low density silicone elastomer seal. Sample of similar seals inspected.

89-010-00 8904260064 1 unsealed penetration and 4 conduhs without internal seals.

89-010-01 8906190263 Updated 89-010 00. Task force formed.

89-010-02 8909080115 Updated 89-010-00.

89-010-03 9008060246 Updated 89-010-00. Based on results of sample inspections, conducted 100% seal inspection.

89-010-04 9401060365 Completed program end of 1993. 3385 penetration seals inspected; 1961 found unacceptable. Reworked or reevaluated deficient seals. Deliciencies included:

gouged or damaged damming material, shrinkage of silicone foam, inadequate seal thickness, cuts in boot material, and inadequate documentation.

89-010-05 9409140061 Updated 89 010-00.

Seabrook 89-011-00 8910170274 3 unsealed pipe penetrations.89-011 01 8912270219 Updated 89-011-00. Initiated 100% seal inspection, developed comprehensive seal program, clarified surveillance requirements.

Susquehanna 89-019-00 8907060047 Damaged seats determined to be inoperable.

Consistent inspection and acceptance criteria developed.

H5 NUREG-1552, Supp. I y . .

.....~__. ..- .-- -_ _

Summary t.f Licensee Event Reports VKGGf% W$}ff M R M %QfGMh$$$$ M&BlN1%$$@QWW4$

ANO1 90-004-00 9007090045 1 unqualified penetration seal.

90-004-01 9105160074 Small voids around groutjoint.

90-004-02 9204300230 in response to IN 88-04, found 2 seals not properly installed.

90-017-00 9008200077 Void in large grout blockout seal.90-023 00 9012120354 1 unsealed penetration.

Fort Calhoun 1 90-022-00 9010170151 In response to IN 88-04, assessed and walked down 100% of seals. Found about 460 of 3500 seals may be inoperable because documentation did not exist or installed configurations did not match documentation.90-022 01 9101090184 Updated 90-022 00. Found 92 more potentially inoperable seals due to lack of Fort Calhoun 1 90-022 02 9102120021 Updated 90-022-00. Found more (continued) potentially inoperable seals resolved others.

Final count of potential inoperable seals due to lack of documentation was 441 of 3500.

Performed evaluations, repaired, and replaced seals. Upgraded procedural controls and drawings.

H.B. Robinson 2 90-003-00 9002220099 Missing internal conduit seal.

90-008-00 9006050277 1/4" plastic tube found passing through (breaching) a seal.

l I 90-010-00 9002220099 I unsealed penetration.

90-010-01 9103270201 Performed 100% inspection,14 additional inoperable seals found.

Monticello90-009-00 9008280179 Seal breached and not rescaled.

Palo Verde 1/2/3 90-009-00 9010310125 Performed 100% inspection of Unit 2, found about 256 questionable seal attributes out of 2000 examined. Deficiencies included unsealed penetrations, seal shrinkage, improperly installed seals, and I gaps in damming materials.

90-009-01 9208200192 Performed 100% inspection of Units I and

3. Found about 1437 questionable seal l attributes out of more than 10,000 l examined. Deficiencies included unsealed penetrations, seal shrinkage, improperly installed seals, and gap in damming materials.

NUREG 1552, Supp. I H-6

. - . . . - __ -. - _- - - _ _- - .- . - . ~ .-. -- . - _ - . - . - .

Summary of Licensee Event Reports py-i4 ~

J. - :

' it990(Acetinued) W- ' NN*bMD[N o M N)

EL M LER NO. ACCESSION NO. REPORT l Trojan 90-022-00 9007230142 In response to IN 88-56, found silicone foam suls with splits.

90-022-01 9012060223 Destructive testing revealed 17 similar seals l with splits.

1 i Waterford 3 90-019-00 9101150362 Removed penetration seal around HVAC damper as a part of modification and did not replace.

90-019-01 9103040377 Updated 90-019-00. FoundI

, additional unsealed penetration.

l l 90-019-02 9109190291 Updated 90-019-00.

l! +

'19931 4 e, 4

. :d , , $]

l l PLANT LER NO. ACCESSION NO. RFJORT l

ANO2 91-016-00 9110250001 Seal not installed properly (filled with rags rather than grout).

Big Rock Point 91 001-00 9102200140 Voids found in 3 seals in response to IN 88-56.

91 001-01 9103260311 8 more seals found with voids.

l FitzPatrick 91-024-00 9112170535 7 penetrations sealed with incorrect

! material.

91 024-01 9403230046 Performed 100% inspection. Deviations from design were found in 39% of 7200 seats inspected.15% required cosmetic repairs. Problems included: inadequate seal thickness, seals not properly installed, incorrect seal material, holes in grout, unsealed penetrations, voids, holes, edge curl, and separation. All seals restored to design condition through rework or evaluation.

! Monticello 91-021 00 9111050217 Seal damaged due to pipe movement.

Peach Bottom 2 91-013 00 9106190190 2 seals contained voids and uncured sealant

- material.

Point Beach 1 91-007-00 9107300239 2 seals left inoperable after design modification.

Sequoyah1 91-013-00 9107030303 Improperly installed seal around a conduit 91 013-01 9108050172 Updated 9l-013 00.

t I H7 NUREG 1552, Supp. I l

Summary of Licensee Event Repoits 1991 (continbed) I <

2 i '

F' N % 4 LER NO. ACCESSION NO. REPORT PLANT.

91-016-00 9108190108 9 Mechanical Seals irioperable due ta Sequoyah pipe movement.

(continued) 91-016-01 9202140203 Schedule update.

p,, + z

-c' 3u

) pe %- e ,

t992(contimied)I -

l 92-003-00 9203190032 1600 seals inspected. I penetration found Duane Arnold unsealed since design modification.

l Program improvements made to minimize likelihood of recurrence.

92-007-00 9206150398 6 penetrations unsealed since original plant construction. Found during first time inspection using new, enhanced inspection program.

92-007-01 9208040177 Updated 92-007-00. Improved inspection schedule.

92-008-00 9203270186 I sealinoperable. Silicone foam had been IIaddam Neck removed and replaced with ceramic fiber.92-006 00 9203090105 2 seals missing damming boards and Trojan inadequate silicone foam thickness since originalinstallation (1979). Corrective actions included inspecting all similar seals.

92-006-01 9205110198 Inspection of similar seals found I additional seal without damming board.92-011 00 9206080031 I seal not repaired and I breached seal not resealed. Fire barrier inspection procedures were upgraded.

92-026-00 9209300187 During 18 month surveillance found grout missing from I seal. Inspectors retrained.

92-026-01 9211030238 1-inch diameter hole found through a silicone foam seal.

92-026-02 9211160031 1 seal with inadequate grout thickness and I grout seal damaged.

92-026-03 9211300072 2 conduits did not have internal seals, 92-026-04 9301050162 4 seals found with inadequate thickness of silicone foam and I seal with inadequate thickness of grout. Personnel retrained.

NUREG-1552, Supp.1 H8

Summary of Licensee Event Reports !

QN#M@Y%fX;$$;$lQQy;&7 & j & %fylN %:k",%g;ylfd!M)

PJ4NI LER NO. ACCESSION NO. REPORT t

Trojan 92-026-05 9310250073 Updated 92 026 00. Degraded l (continued) penetration seals resulted from personnel errors and inadequate procedural controls.

Extensive procedural controls implemented.

92-031-00 9211190123 1 grout seal degraded and inadequate grout thickness.

92-034-00 9301250264 A small gap was found between a grout seal and the pencuating pipe. Two grout seals were degraded and 1 of these had inadequate grout thickness.

h5$ ?Uh??$$ ?$3%i. m 195$i ;;N T?? Y $ % l D ? b W W S E bhhh Brunswick 93-006-00 9304060055 During 100% inspection, found 9 unqualified seals.

Haddam Neck 93-003 00 - 9305030266 Found I unsealed penetration and I seal with a temporary seal Indian Point 3 93-029-00 9309240036 In response to IN 88-04, initiated seal inspection program. 2 seals found that did not conform to tested configuration.

LaSalle 1 93-009-00 9303290295 3 unsealed penetrations. Sample of penetrations inspected. No additional deficiencies found.

. Millstone 1 93 006-00 9307200165 1 unsealed penetration found using improved inspection procedure.

Trojan 93-001-00 9302230261 I unsealed penetration.

93 002 00 9303180036 2 grout seals had inadequate thickness.

Vermont Yankee 93-001 00 9301220246 In .1992, all seals containing insulated lines were declared indeterminate. Inspection revealed I penetration with inadequate seal thickness and 3 others that did not conform to design details. Licensee notified industry through Nuclear Network.

93 001-01 9303090037 Updated 93-001-00. Boot seals to be used for some pipe penetrations.

93-001-02' 9307140180 Updated 93-001-00. All seals to be i inspected using enhanced surveillance procedure. Design change implemented.

H9 NUREG-1552, Supp. I

Summary of Licensee Event Reports i

i

. [j r i f h',

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i .'

' 'j9$47 5 4 g 2

__.' e e r Cooper 94-008-00 9405240103 Improperly installed seal found. Seal was repaired.

Diablo Canyon 1/2 94-001-00 9403090054 Seals may not meet required Gre rating due to lack of damming boards. All seals declared indeterminate. Program to qualify and repair seats.

l 94-001 01 9408310118 Updated 94-001-00.

Maine Yankee 94-010-00 9408180131 2 conduits without internal seals found.

94-010-01 9508290022 Conduit seals missing. The conduits were part of a new installation. They were scaled and inspected.

94-035-00 9412060226 Breached / missing internal conduit seal.

Millstone 2 Seals installed.

Vermont Yankee 94-018-00 9501190145 2 seals degraded. One was missing caulk and the other had a 3/8 inch void in the brick and mortar seal.

94-018-01 9506140431 Updated 94-018-00.

WNP2 94-002-00 9403230142 In response to employee concem, licensee found original constmetion, managerial methods, written procedures and documents, design configuration and analysis, work practices, and resource management less than adequate. Seal deficiencies included inadequate seal thickness, PVC sleeved penetrations, blockouts that exceeded design specifications. Seals declared inoperable.

Corrective action included walkdowns, engineering evaluations, and establishing Gre test documentation to support seal installations.

94-002-01 9407130092 Updated 94-002-01.

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Calvert Cliffs 1 95-004 00 9509210118 3/4-inch gap (breach) found in a seal. Seal repaired seal surveillance procedure upgraded.

Iladdam Neck 95-001-00 9502230065 1 degraded grout seal and I unsealed penetration found.18-month surveillance revealed 4 inoperable seals and 3 unsealed NUREG-1552, Supp.1 H 10

Summary of Licensee Event Reports

($$$0*Y^3Nd$. < dR ?$$$gggjMsk$$5MhMMid$s?)MM)hhM PLANT LER NO. ACCESSION NO. REPOkT Haddam Neck penetrations.100% field walkdown (contir oed) as corrective action.

95-001-01 950808017 Updated 95 001-00.

Susquehanna 95-011-00 9511070336 Review of fire test reports revealed that hose stream test did not meet commitment. Strff inspected this issue January 1996.

Vermont Yankee 95 004-00 95050304.4 Improperly repaired seal declared inoperable. Seal was repaired.

a

.I@ d!N d $ k i$Id1U$M d h M I5 5 $ $ 4$$f M A @ hld$$Nid khM M M $E M N!d[ N M D.C. Cook 2 % -004 00 % 04180325 Seal found degraded / damaged when a 100% scalinspection was completed.

l Diablo Canyon 1/2 96-011 00 9609170363 Epoxy grout seals untested and, therefore, outside design basis.

% 011-01 9706040331 Reported qualification of epoxy grout seals by test.

Maine Yankee % -017-00 9608060017 Fire barrier penetration inspection revealed seals missing damming boards, inadequate seal thickness, and temporary seals. No fire

- tests to support some configurations.

Attributed to weaknesses in original installation QC, and surveillance procedures.

l

% 017-01 9608060017 Updated 96-017-00.

Palisades . % 009-00 9608200212 Two seals deficient because fire barrier evaluations not documented. Penetration seal program weaknesses noted.

Commitments made to develop a design !

basis document for fire barriers.

Vermont Yankee 96-026-00 % I1130511 Two seals improperly installed during originalinstallation.

% 026-01 9703280401 Updated %026-00.

l$M?iI5k ($@@O$$N$p[M#Ef$p[jh$Mhhf$$N8/MhkhMj$hM:jhlkh NONE 1

H 11 NUREG 1552, Supp.1

Appendix I NRC Inspections (Appendix R plants (plants operating prior to January 1,1979) are shown in bold font.)

E Plant 1 - Report $Datel Scope ~ Findaags ._. Summaryf .

Bener Valley I 93-12, 93-13 07/02/93 Narrow Minor Licensee could not verify that eight internal conduit seals were installed. A fire Beaver Valley 2 watch was posted until the seals wcre installed per procedures.

Browns Ferry 1/2/3 92-11 05/01/92 Narrow None Inspectors reviewed procedures for maintenance of fire barrier penetrations.

Inspection results for fire rated barriers were also reviewed. No discrepancies were noted.

95-60 12/12/95 Broad None The inspector revicwed typical mechanical, electrical conduit, and cable tray penetration seal installation procedures, draw ings, details, quality control (QC) records, quality assurance (QA) records, engineering evaluations, and qualification test documentation. The inspector did not find any discrepancies.

E Brunswick 1/2 92-31 10/26 S 2 Narrow None Inspectors observed performance of a portion of the periodic inspection of fire barrier seals. Inspectors noted the inspections were detailed, and that the licensee had initiated a re-inspection effort for fire barriers w hich was seen as a positive initiative for self-identification and corrective action of fire barrier inspection program deficiencies. In addition, inspectors noted that penetration seals were acceptable during a general plant walkdown.

93-38 09/10/93 Narrow Nonc Inspectors closed LER 92-12-01 which concemed inadequate fire barrier wall gap material. As part of the close-out actions, the licensee conducted a detailed review and inspection of fire barriers and penetration seals during a Unit I outage.

97-07 06/20/97 Narrow Nonc Inspectors noted that penetration seals were acceptable during a general plant

. walkdown.

Z C

g Byron 1/2 92-007 04/13/92 Narrow None The inspector observed fire penetration seals while conducting a plant walkdown a and did not observe any problems.

4 Callaway 94-012 12/06/94 Narrow Nonc Inspectors noted that barrier seats in the plant were in generally good condition.

4

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Calvert Cliffs 1/2 94-15 05/06/94 Narrow Nonc lhe inspectors noted that the licensee has scheduled a review of all plant penetrations to verify the adequacy of the installations. The inspectors concluded that there were no safety-significant issues associated with the penetration seals.96-201 05/06/96 Broad None NRR staffinspected the fire barrier penetration seal program and concluded that the licensee had an acceptable program. The inspectors did not find safety-significant problems or evidence of generic problems. Ongoing licensee cfTorts to improve the penetration seal program were seen as positive.

Comanche Peak I/2 96-10 09/24/96 Narrow Nonc Inspectors observed installation of a penetration seal and no discrepancies were noted.

96-12 11/27/96 Broad None The inspector inspected silicone foam seals and verified that they were insta!!cd in r

" the proper configuration and had adequate documentation to support a 3-hous fire rating.

Cooper 95-17 02/0586 Narrow None laspectors closed LER 94-008 regarding inoperable penetration seals.

Crystal River 92-18 10/01/92 Narrow None Inspectors reviewed fire barrier penetration technical specification requirements, including daily fire barrier breach reports.

Davis-Besse N/A I1/23/94 Broad None NRR stafT audited the penetration seal program. On the basis of the audit, the staff concluded that the licensee had implemented and maintained an acceptable fire barrier penetration seal program and that no significant problems existed with the fire barrier penetration seal installations at Davis-Besse. The staff did not find j information that suggested problems with generic impiications. f l

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Report 4j?%hj* Fleet s ' f Date G.* - Scope t FirAlmesli !Suss'assry iM" Diablo Canyon 1/2 94-01 03/15/94 Broad Minor In 1994, the licensee found that certain fire barrier penetration seals may not have met the required 3-hour fire rating because damming boards were not installed on both sides of silicone foam seals. A walldown of additional seals revealed about 100 representative silicone foam seals with missing damming boards. The licensee has established a corrective action program. The staff followed up on the licensee's activities during inspections in February ;994 and March 1995. The inspectors concluded that the licensee had taken appspriate corrective actions. The stafTis continuing to follow the licensee's actions.

95-03 05/01/95 Broad Minor Inspectors reviewed the licensee's corrective actions for LER 94-001, which reported inadequate silicone foam fire barriers due to lack ofdamming boards. The inspectors found that the licensee's actions were appropriate, but the item remained open, as action was still ongoing.

C 96-13 08/l8/96 Bread None Inspectors closed LER 94-001 cone-ning inadequate fire barrier gnetration seals due to lack of damming boards. Licensee undenook a 100% inspection of required seals to do:ument all installed configurations. The inspectors concluded that the licensee's program would correct the seal deficiencics.

D.C. Cook 1/2 94-012 06S4 Broad Minor The inspector noted that inoperable fire barrier penetration gap seals were a major problem at the plant, but the licensee had begun a proactive program to inspect 485 additional gap seals.

Dumme Atsold 93-012 10'A Narrow Minor Inspectors described problems licensee was experiencing regarding fire barrier i penetration seals. A major problem was noted in this area in an LER in 1992. The licensee was in the process of a 100% inspection of seals to identify problems.

Z 93-16 Irv01/93 Narrow Significant Violation was issued to the licensee based on the lack of action taken regarding degraded barriers betwxn control room and cele spreading room.

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$ that self-extinguish times for a certain lot of RTV foam were out of specification. @

the licensee found one penetration seal that was formed of the suspect foam. At E In the time of the inspection, the licensee had scheduled to replace the penetration seal.

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95-20 01/96 riarrow None Licensee discovered ronduit penetrations through a fire carrier without an internal seal. A broad review of conduit penetrations revealed that there were 125 conduits (3/4* to 4" diameter) that did not appear to be properly sealed. All conduit inspections and repairs had been completed and documented.

96-13 12/23/96 Narrow &ne inspectors concluded that licensee's evaluation ofIN 94-28," Potential Problems With Fire Barrier Penetration Seals " was appropriate and required corrective actions were completed.

Fermi 2 94-012 11/21/94 Narrow None As part of a restart inspection, inspectors noted that the licensee had reviewed installation records, including QA/QC records, for all installed seals and found them mdicative of proper installations. In addition, the licensee had not found any mdications of improper installation upon removal and inspection of several a

penetration seals.

Ginna 94-14 06/13/94 Broad None The inspector verified that evaluations for existing penetration seat materials supported their qualification for use throughout the plant. The inspector determined that qualification documentation for penetration seal matenals was concise. The inspector concluded that Ginna had good controls for maintaining the integrity of fire barriers and considered this a strength in the fire protection program.

Haddam Neck 93-08 07/26/93 Narrow None Inspectors closed out LER 93-003," Fire Barriers Inoperable Due to Fire Seal Deficiencies

95-09 06/19/95 Broad None 1 he inspector performed a review of the fire barrier and penetration seal program to verify the adequacy of seal installations, qualification, and surveillance activities.

The inspector found that tbc licensee conducted a 100 % visual inspecion as part of its seal upgrade program in 1988. The licensee found 20 degraded or inoperable seats since the upgrade proe , ram. The inspectcT concluded that the licensee took prompt and appropriate corrective actions. On the basis of the inspection, the inspector concluded that no safety concerns exist at the facility regarding fire l barriers.

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116 ch 1/2 92-09 04/20/92 Narrow None Inspectors noted that penetration scals were acceptable during a general plant 93-22 11/2/93 walkdown.

97-01 03/24/97 Nanow None Inspectors concluded that licensce's evaluation of IN 94-28. " Potential Problems I

With Fire Barrier Penetration Seals," was appropriate and required correct:ye actions were comple ed.

97-03 6/l7/97 Broad None Inspectors reviewed procedures, drawings and other documents related to fire-rated scaled penetrations and conducted walkdowns of selected scaled penetrations. The inspectors concluded that the licensce's program for determining the operability of scaled penetrations was adequate. No deficiencies were identified with the penetrations inspected.

Indian Poirt 2 93-18 09/13/93 Broad None inspectors reviewed the licensee's fire barrier penetration seal installation and [

surveillance program, in addition, the inspectors reviewed the licensee's actions in ,

response to IN 88 04. No discrepancies were found. The licensee does not use silicone foam-type penetration seals. Scals here are grouted in place.

g Indian Point 3 93-24 12/14/93 Broad Minor Inspectors opened URI 93-24-03, which concerned operability determinations of degraded and potentially nonconforming fire barritrs and fire barrier penetration g

seals and the methodology that the licensee used to determine self-ignition 8

temperatures of cables installed in penetrations in the plant. He latter issue has yet to be resolved.

93-80 06/21/93 Narrow Minor Inspectors identified weaknesses in programs dealing with fire barrier penetration seals. Specifically licensee commitments to revise technical specifications to add fire barrier penetrations needed to meet Section Ill.G of Apper 't t

95-10 06/26/95 Narrow Minor The inspec ors questioned the methodology used by the licens - s determine the self-ignition temperature of cables that pass through penetration seals. Ilowever, the inspectors had found the licensec's penetration seal analyses and supporting documentation to be generally sufficient. The NRC is currently tracking corrective

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/ 95-81 05/l1/95 Narrow Minor Inspectors reviewed fire barrier penetration seal qualification tests and concluded W that insufficient evidence was available to support the cable ignition temperatures of h

h cables installed at IP3. (Sirnitar to above.) 4

' 8 LaSalle 96-04 07/03/96 Narrow Broad Inspectors noted that barrier seals in the plant were in generally good condition. 5'

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The inspector reviewed the fire barrier program to verify .he adequacy of penetration seal installations, qualification, and inspection activities. This review also assessed the appropriateness of acceptance criteria established for penetration seah to validate operability and degradation, that could prevent fire barriers from providing effective separation during a fire. The inspector concluded that the licensee's procedures for seat inspections and training provided to seat inspectors were good for maintaining proper seal configuration and early detection of degraded conditions. These actions were found to provide a defense against the propagation of fire to adjacent plant areas.

96-08 09/16/96 Broad Significant The inspectors reviewed actions taken by the licensee to address problems l

identified with penetration seals. The inspectors concluded that the licensee took

_ prompt and effective actions to addsess these problems.

McGi. ire I/2 92-01 02/19/92 Narrow None Inspectors noted that pene' ration seats were acceptable during a general plant walkdown.

l l Milktone 1/3 93-19,93- 10/06/93 Narrow None Inspector reviewed licensee corrective actions for LER 93-06, discovery of 2 Millstone 2 14, unsealed penetrations. Licensee conducts 100% inspection every I8 months. Poor 93-15 personnel performance and an inadequate inspection procedure were presented as the root cause of the event. The inspector reviewed revised penetration seal surveillance procedure and found it adequate. Overall, the corrective actions were appropriate.

Monticello 92-007 04/10/92 Narrow None The inspector observed fire penetration seats while conducting a plant walkdown and did not observe problems.93-005 04/93 Narrow None Inspectors closed LER 91-21 which reported inoperable fire barrier penetration seals due to pipe movement caused by a water hammer. The inspectors felt the actions taken by the licensee to resolve this problem were adequate.

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North Anna 1 92-18 10/19/92 Broad Significant inspectors identified several degraded penetration seals and reviewed the fire barrier North Anna 2 penetration program and found deficiencies in procedures and documentation. The inspectors issued two violations for failure to maintain penetration fire barriers (92-I8-04) and failure to establish adequate fire barrier inspection procedure (92 05).

93-13 03/30/93 Narrow None During a general plant walkdown, inspectors noted th. penetration seals were acceptable 91-10 06/09/94 Narrow None Ir-pectors reviewed licensee's corrective actions for violation 92-18-04 which remained open, pending licensce's review of penetration seat inspection schedule.

The inspectors reviewed licensee's revised penetration seal inspection procedures, and closed violation 92-18-05.

96-13 02/07/97 Broad None in 1995, the licensee initiated destructive inspections of penetration sests. It found and repaired a number of degraded seals. On the basis of this inspection, the inspectors concluded that the licensee's corrective action program was very 7

4 effective.

Oyster Creelt 93-10 06/21/93 Broad None Inspectors viewed penetration seals during plant walkdown. No visible discrepancies were noted. The inspectors also reviewed licensee actions in response to IN 88-56. Licensee conducted inspections ofinstalled silicone foam quality during ir.stallation and at periodic intervals by removing damming boards.

a 95-11 07/21/95 Broad Minor This inspection was conducted because the licensee reported that it had found degraded penetration seals (125 of about 1560 seats) during its 18 month seal ,

inspection program. The inspector concluded that the licensee had properly identified, evaluated, and initiated proper compensatory and/or repair activities.

The inspector concluded that there were no outstanding operability or functionality 2: issues.

C h Palisades 92 0s0 03/92 Narrow None Inspector reviewed licensee's fire barrier penetration surveillance procedure. No 2

O. discrepancies were noted. :c u O u

.N Pa:o Verde 1/2/3 94-29 09/02/94 Broad None The inspector reviewed the licensce's fire barrier seal program and found that [

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surveillsnce program. Voids were discovered in some silicone foam penetration 3

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'3 seals. The licensee responded by inspecting all seals supperted by a given detail. ,

- The inspectors concluded that the licensee's penetration Lgair program awpeared to be an adequate approach for identifying and conecting nonconforming penetrations Perry 1 96-016 02/04/97 Narrow Minor Inspector opened an unresolved item regarding penetration seals that were installed in a different configuration from the supporting tested assembly. The licensee was t

to complete an engineering evaluation.

i Prairie Island 1/2 92-010 08/14/92 Narrow None Seals for separation ofdiesel generators from other plant areas were inspected and verified as 3-hour rated.

River Bend Station 94-17 01/17/95 Narrow None Inspection team observed penetration seals during a fire protection-related plant tour. No discrepancies were noted.

5 94-22 01/26/95 Norrow Nonc Inspectors questioned the radiation shielding capability of Keowool installed as a g

penetration seal. fhe licensee was able to adequately justify the application. r r

95-01 03/08/95 Narrow Minor De inspectors had found that the licensee's corrective actions were not adequate in response to the misapplication of seal material in 1991. The seals were not i designed for the high ambient temperatures to which they were exposed; therefore, ;

the seals degraded. The inspectors opened unresolved item 9501-02.

i 95-02 05/03/95 Narrow Minor inspectors followed up on unresolved item 9501-02 and concluded that the licensee was acting appropri-tely, but more work was needed to resolve the problems.

95-17 06/09/95 Narrow Minor The licensee received a non-cited violation for failure to promptly identify and conect the inadequate design of the boot seal that had degraded. The inspector l closed unresolved item 9501-02, based on the licensee's ongoing efforts to correct ;

the seal problem. i ll.B. Robinson 96-12 12/1fd96 Narrow None Inspectors r:e'.ed that penetration seals were adequate during a general plant walkdown. In addition, inspectors concluded that licensee's evaluation ofIN 94-28,

Potential Problems With Fire Barrier Penetration Seals," was appropriate and required corrective actions were completed.

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x St. Lucie 1 96-08 07/08/96 Narrow None The inspectors evaluated the licensee's actions to resolve fire protection St. Lucie 2 discrepancies during the 1996 Unit I refueling outage. The licensee had inspected penetration seals and found small cracks in the surfaces of the seals. The inspectors concluded that the discrepancies did not appear to degrade the fire resistance of the seals. Ilowever, the licensee considers seals with even cosmetic problems to be >

inoperable. De inspectors found that the licensce's corrective actions and compensatory measures were appropriate. j 93-80 10/14/93 Narrow None Inspectors reviewed results of 18-month fire barrier penetration seal surveillance Salem I conducted by the licensee. No discrepancies were noted.

Salem 2 i 96-10 10/30/96 Broad None This issue was a restart action plan item. The inspectors reviewed work donc

_ during the penetration seal improvement program and concluded that the quality y

, 6 and configuration of penetration seals were acceptable.

97-09 06/03/97 Broad None The inspectors reviewed the qualification-type fire endurance tests and associated engineering evaluations for certain seal designs in floors and walls in Unit I and Unit 2 auxiliary buildings. The inspectors focused on verifying that design and !

installation parameters for the as-built configurations were bounded and justified by the licensee's engineering evaluations. De inspectors concluded that the licensee's ,

, engineering analysis methods appearcd to have established a basis that the as-built seal designs would accomplish their intended function.

San Coofre 2/3 94-01 01/28/94 Broad None The licensee conducted a 100 % reverification program of the installed configurations as a part of the validation of the Plant and Fauipment Data z Management System database. The licensee found that 4 of 1500 seats (a 20 %

sample of a total of 7000 seals) did not meet acceptance criteria. (ne reverification g process was ongoing at the time of the inspection.) The inspector walked down and

. verified the adequacy of a sample ofinstalled seals. The inspector did not report Z tJ any safety-significant problems. $

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Licensee had planned a 100% inspection and reverification of all installed seats in inwid-.cc with IN 88-04. LERs91-010,91-008,91-016, and 91-012 were closed.

i 94-16 07/19/94 Broad None Inspectors reviewed the licensee's response to IN 88-04, which mcluded inspection and seal re-wont The inspectors concluded that the licensee's followup on the IN I was adequate. :-

96-02 04/22/96 Broad Minor Inspectors reviewed a 1994 licensee audit in which items identified included ,

inadequate design control over fire barrier penetration seals and restoration of pen seals to operability following maintenance Conective actions on the.,e items had not been completed a the time of the inspection.

96-10 09/27/96 Broad Minor Inspectors reported that a 100% seal inspection had been completed (24,500 seals inspected) and 1500 seals with design documentation problems remained to be g ,

resolved. Scheduled for completion late 1997.

97-03 05/12/97 Narrow None Inspectors concluded that licensce's evaluation ofIN 94-28," Potential Problems With Fire Barrier Penetration Seals was appropriate and required corrective actions were completed.

Shearon liarris 95-02 03/02/95 Narrow None Inspectors observed penetation seal 18-month visual inspection conducted by licensee personnel. Performance of the inspection was found to be satisfactory.

South Texas 1/2 94-15 06/07/94 Narrow Minor Inspection followup item regarding excessive shrinkage of penetration seals was closed in the report.

9' 3. . 03/06/95 Narrow None Inspector visually inspected penetration seals in various fire areas and no discrepancies were identified.

Surry 1/2 96-10 10/28/96 Narrow None Inspectors concluded that licensee's evaluation ofIN 94-28," Potential Problems With Fire Barrier Penetration f als," was appropriate and required corrective i

actions were completed.

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-N@ N MIYg $Ohg _ m$ k Psi SusquehannaI 95-12 08/02/95 Narrow Min.or The inspectors followed up on LERs94-003 and 94-007 for a missing seal and a degraded seal. Both discrepancies were corrected, 95-14 07/31/95 Broad None The inspector conducted a 6. .y.i!.i.Wve inspection of the licensee's penetration seal proaram including, reviewing the adequacy of the penetration seal installations, qusJiii ation, and inspection activities. The inspector also assessed the appepriateness of acceptance criteria for validating operability and degradation.

The inspector concluded that the licensee had an excellent program 96-201 04/05/96 Broad Minor NRR staf! inspected the fire barrier penetration seal program and found the damming matenal missing from one penetration seal. The licensee took immediate corrective actions. The inspectors concluded that the licensee had implemented an.1 maintained an acceptable fire barrier penetration seal program. The inspectors did O

not find safety-significant problems or evidence of generic problems with penetration seals.

Turkey Point 3/4 96-06 06M3/96 Narrow Minor Licensx QA audits of fire protection program were reviewed. Findings r garding swton seal documentation were identified. Corrective actions were addressed ed determined to be adequate.

Verment Yankee 93-05 05/13/93 Broad Significes A violation was issued to the licensee for inadequate appR:stion of quality principles to the original installation and the subsequent ineff::ctive periodic iaW% of the fire barner penetration seals installed in the reactor building, control building, and the diesel generator rooms.

7 Virgil C. Summer 96-11 I1/25/96 Narrow None Inspectors concluded that licensee's evaluation ofIN 94-28," Potential Problems C

with Fire Barrier Penetration Seals," was appropriate and required corrective actions E g werecompleted.

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Yogtle I/2 92-13 08/M/92 Broad None Inspectors completed an Inspection Manual Chapter 71707 inspection on fir-barrier penetration seals. The inspectors reviewed surveillances, noted discrepancies, and confirmed that all deficiencies were corrected. The inspectors had no findings in this area.

93-08 05/17/93 Narrow Nonc Inspectors noted that penetration seals were adequate during a general plant

_ walkdown. Inspectors also closed violation 91-10-01, which included corrective h raions for missing penetration seals.

95-31 02/96 Narrow None Inspectors closed LER 95-01 for lack of penetrat:on seals placing plant in condition outside of design basis. Corrective actions were concluded to be adquare.

97-01 04/14!97 Narrow Nonc Inspectors concluded that licensee's evaluation et IN 94-28," Potential Problems With Fire Barrier Penetration Seals" was appropriate and required corrective actions were completed.

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[ INient ?, ^ Report 'kDade( -Scope , Fladings 4 . N[b As' i Sus anary!_1 m t w y. S.D 4 L Washington Nuclear 2 94-08 02/25/94 Broad Minor in December 1993, the licensee started a review ofissues related to its penetration seal inspection program. The licensee found deficiencies with criginal installations, periodic inspections, and repairs. The licensee declared all seals inoperable, established compensatory measures, and initiated a comprehensive penetration seal upgrade program. The program included seal calculations backed by fire tests; new seal design guide; typical details; revised plant specifications and procedures; closure of penetration seal impairments; engineering evaluations for certain non-rated barriers; and updated installe:: ion and surveillance procedures for training s:al installers and inspectors. Region 17 conducted three inspections of the program.

The inspectors concluded that the licensee was taking aggressive corrective actions.

94-28 11/09/94 Broad Significant The staffissued a violation (9428-01) for not taking prompt compensatory measures upon the discovery ofinstallation and inspection deficiencies for fire

-. barrier penetration seals. Inspectors viewed approximately 100 penetration seals C and noted that many had small cracks or gaps along the scal-wall interface. The ;

inspectors did not believe that the deficiencies made the barriers nonfunctional.

95-18 06/29/95 Broad Nonc Inspectors c:osed violation 9428-01. The licensee had completely restructured its l fire protection program, including its penetration seal program.

I 95-201 IM3/95 Broad None An NRC integrated assessment team inspected the licensee activities mentioned above. The team assessed licensee efTectiveness in identifying issue.y crforming l root cause analyses, and implementing corrective actions. The inspect.bn focused on the areas of maintenance ar d engineering. The team inspected activit es i i involving procurement, storage, installation, quality control, and long-term maintenance associated with the installation and maintenance of penetration seals. l' The team concluded that the licensee's current performance in the areas of receipt 2

inspection and storage control, quality control, and inspection sud surveilLnce was

% adequate. The assessment team also considered the licenser's corrective action y ,

] program on penetrat ion seals to be a strength. y a

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~L however, that the fire barrier penetration seal program was sa'isfactory and that the discrepancies did not create any problems with the penetration seal installations.

De staff did not find safety-significant problems or evidence to suggest that generic problems existed with penetration seals.

95-11 02/16/95 Narrow None Inspector 5isually inspected penetration seals in various fire areas. No discrepancies were identified. Fire barrier penetration seal program implementing procedure was also reviewed.

Wctts Bar ! 94-62 11/16/94 Narrow Minor Inspectors opened coastruction deficiency reports (CDRs) *.,5-18/19 and 90-10 for fire rated penetration deficiencies and unqualified cable penetration seals. Rese issues were inspected several times over a 2-year period.

[ 94-78 12/21/94 Broad None Inspectors reviewed penetrations and supportirig documentation for a number of seals. In additior s.he inspectors observed several seal installations. The inspectors concluded that an effective program was being implemented for the evaluation of existing electrical and mechanical fire barrier pmetration seals and the repair, modification, and installation of penetration seals to meet design requirements.

95-32 06/09/95 Narrow None Inspectors continued followup on CDR 85-19.

95-38 07/l1/95 Narrow Mir'or inspectors discovered degraded penetration seals during a plant tour.

95-39 07/18/95 Narrow Nonc Inspectors closed CDR 87-13, which concerned deficiencies with mechanical fire protection penetration seals.

95-45 08/15M5 Narrow Minor inspector noted that a penetration seal had been breached.

95-40 09/12/95 Nar*ow Minor Docuraentation of the fire testing for fire barrier penetration seals did not conform to the design details for some installed seals. This follows from previous CDRs.

95 72 11/17/95 Narrow None Inspecors closed CDR 85-19 for penetration assembly deficiencies.

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Watts Bar I 95-?? 12/06/95 Narrow None Inspectors closed second CDR (90-10) for unqualified penetration seals.

(continued) 95-68 e i19/95 Broad Nonc Inspectors reviewed design details and QA/QC records, and walked dc-wn g - penetration seals. No discrepancies were identified for the seals that were reviewed.

During the walkslown some seals were noticed to have damaged damming boards.

The applicant was already aware of these deficiencies.

WolfCreek 95-19 08/1035 Narrow None Inspector visually inspected penetration seals in various fire areas. No discrepancies were identified.

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Appendix J l

- Plants Known To Have Performed 100-Percent Penetration Seal Inspections l Appendix R plants (plants operatinj; prior to January 1,1979) shown in bold font.

l Whwhhibathhk%st $C55&Q b$"%;? INS llt?hatedaee%4,5&;'$$ 1 Arkansas Nuclear One 1 1974 \

l LER 91-016.

Arkansas Nuclear One 2 1980 LER 91-016 Big Rock Point 1963 LERs89-006 and 91-001. -

l Brunswick I/2 1977/1975 LER 93-006-00. i Calvert Cliffs 1/2 1975/1977 NRC IR 94-15. ,

1 Catawba 1/2 1985/1986 McGuire LER 88 030-01. l D.C. Cook I/2 1975/i978 LER 96-004-00.

Diablo Canyon 1/2 1985/1986 LER 94-001-00. NRC irs 94-01 and 95-03.

Duane Arnold 1975 NRC IR 93-012.

l'itzPatrick 1975 LER 91-024-01.

Fort Calhoun 1973 LER 90-022.

Haddam Neck 1968 LERs 89-00100 and 95-001-00. NRC IR 95-09.

Indian Point 3 1976 NRC IR 95-81.

McGuire 1/2 1981/1984 LER 88-030-01.

Maine Yankee 1973 LER 96-017-00. NRC IR 96-08.

Millstone i 1986 LER 93-006-01.

Monticello 1971 LER 89-001-00.

Nine Mile Point 1 1969 LER 88-009-00.

Oconee 1/2/3 1973/1973/1974 LERs 89-010-03 and 88-005.

Palo Verde 1/2/3 1986/1986/!988 Leuer of March 16,1990.

River Bend Station 1986 LER 89-010-03.

H.B. Robinson 2 197i LER 91-010-01.

Salem 1 1977 LER 88-013-00.

Salem 2 1981 LER 88-013-00.

San Onofre 2/3 1982/1983 NRC IR 94-01.

COMM. OP. - Date of Commercial Operation, LER = Licensee Event Report, NRC IR = NRC Inspection Report J-l NUREG-1552, Supp. I

100% Penetration SealInspection

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,. ,aa n.sm k %4-Susquehanna1 1983 NRC IR 95-12.

Vermont Yankee 1972 LER 93 001.

Washington Nuclear 2 1984 LER 88-008-00. NRC 1Rs 94-08,94-28,95 18, and 95-201.

Watts Bar i 1996 NRC IR 95-77.

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NUREG-1552, Supp. I J-2

Appendix K RefereBee Summary Appendix R plants (plants operating prior to January 1,1979) shown in bold font.

$ hbhY hkk& W% $ $ kiY$$$$ hhh?thhh Arkansas Nuclear One 1 19h LERs 89-003-00,90-004-00,90-04-01,90-004-02, 90-017-00, and 90-023-00.

Arkansas Nuclear One 2 1980 LERs 87-001-00 and 91-016-00.

Beaver Valley 11 1976 NRC irs 93-12 and 93-13.

Beaver Valley 2 1987 NRC irs 9312 and 9313.

Big Rock Point 1%3 LER 89-006-00,91-001-00, and 91-001-01.

Braidwood 1/2 1988/1988 N/A.

Browns Ferry 1/2/3 1974/1975/1977 NRC irs 89-13,89-28,90-11,92-11,9312,9313,95 37, and 95-60.

Brunswick 1/2 - 1977/1975 LER 93-006-00; NRC 1Rs 92 31,93-08,93-38, and 97-07.

Byron 1/2 1985/1987 NRC 1R 92-007.

i Callaway 1984 NRC IR 93-08.

i' Calvert Cliffs 1/2 1975/1977 LERs 89-002-00,89-002-01, and 95-004-00; NRC irs 9415 and 96-201; Catawba 1/2 1985/1986 McGuire LER 88-030-01; NRC 1R 91-22.

, Clinton 1987 LER 89-006-00.

Comanche Peak I/? 1990/1993 NRC irs 96-10 and 9612.

f -- Cooper 1974 LER 94-008-00; NRC IR 95 17.

i Crystal River 3 1977 NRC irs 9218,92 23, and 95-09. j Davis-Besse 1978 1994 NRR audit.

D.C. Cook 1/2 1975/1978 LER 96-004-00; NRC IR 94-012.

Diablo Canyon 1/2 1985/1986- LERs 89-030-00, 94-010-00, 94-010-01,96-011 00, and 96-011-01; NRC irs 94-01,95-03, and 96-13.

Dresden 2/3 1970/1971 N/A.

Duane Arnold 1975 LERs 92-003-00,92-007-00, and 92 007-01; NRC irs93-012 and 93-16.

Farley 1 1977 NRC irs 88-27,94-30, and 95-20.

Farley 2 1981 NRC irs 88 27,94-30, and 95 20.

COMM. OP. = Date of Commercial Operanon, LER = License Event Report, NRC IR = NRC Inspection Report K-1 NUREG 1552, Supp.1 n.e n , , , ~e w <- -sv-- - -- ne ~~ ~ ~ - - - --m , v

L Reference Summary l

hikskikkNkNhh kCNbk Nhbh$fhhMMMIS$Nk$kN 1 Fermi 2 1988 LER 94-012.

I 1

l FitzPatrick 1975 LERs 87-011-00,87-011-01, ^1-024-00, and 91-024-01.

l Fort Calhoun 1973 LERs 90-022-00,90-022-01, and 90-022-02. I L

Fort St. Vrain LERs 87-006-00. 87-006-01,89-014-00, and 89-014-01. l Ginna 1970 LER 88-009-00; NRC IR 94-14.

Grand Gulf 1 1985 N/A, Haddam Neck' 1968 Leks 89-001-00,89-001-01,92-008-00,93-003-00, 95 001-00, and 95-001-00; NRC irs 93-08,95-09.

Hatch 1 1975 NRC 1Rs 88-21,91-30,92-09,93-05,93-22,97-01, and '

97-03.

Hatch 2 1979 NRC irs 88-21,91-30,92-09,93-05,93 22,97-01, and 97-03.

Hope Creek 1 1986 N/A, Indian Point 2 1974 NRC IR 93-18.

Indian Point 3 1976 LER 93-029-00; NRC irs 93 24,93-80,95-10; and 95-81.

Kewaunee 1974 N/A.

. LaSalle 1/2 1984/1984 LER 93-009-00; NRC IR 96-04.

i l Limerick 1/2 1986/1990 N/A.-

McGuire 1/2 1981/1984 LERs 88-030-00 and 88-030-01; NRC irs 89-03,91 30, 92-01, and 93-03.

Maine Yankee 1973 LERs %017-00 and 97-017-01; NRC irs 95-15 and 96-08.

Millstone 1 1986- LERs 93-006-00 and 93-006-01; NRC IR 93 19.

Millstone 2 1975. LER 94-035 00; NRC IR 93-14.

F Millstone 3 1986 NRC 1R 93-15.

Monticello 197i LERs 87-011-00,89-001-00,89-013-00,89-013-01, 90-009-00, and 9l-021-00; NRC irs92-007 and 93-005.

Nine Mile Point i 1969 LERs 88-009-00,88-009-01, and 88 009-02.

Nine Mile Point 2 1988 LERs 87-016-00,87-016-01, and 87-018-00 North Anna 1 1978~ NRC irs 88-13,92-18,93 13,94-10,94-21, and 96-13.

North Anna 2 1980 NRC irs 88-13,92-18,9313,94-10,94 21, and %l3.

Oconee 1/2/3 1973/1974/1974 LERs 88-005-00 and 89-010-03; NRC irs 88-19 and 91-14.

Oyster Creek 1%9 NRC irs 9310 and 95-11.

9

- NUREG-1552, Supp. I K2

,-n-- - , ~w, -m,-- - , ,v- - - ,w

Reference Summary M.4,YFlest[$M N G$Channi.OpfM p;$$$ l'N#fMReferencej ' NN6 MhM Palisades 197i LERs 89-024-00 and 96-009-00; NRC IR 92 010. l Palo Verde 1/2/3 1986/1986/1988 LERs 90-009-00 and 90-009-01; HRC IR 94 'd Peach Bottom 2/3 1974/1974 LER 91-013-00; NRC IR 93-09.

Perry 1 1987 NRC 1R 96-06.

Pilgrim i 1972 N/A. >

Point Beach 1/2 1970/1972 LER 91-007-00.

Pralrie Island 1/2 1973/1974 NRC 1R 92-010.

Quad Cities 1/2 1973/1973 LER 87-028-00 River Bend Station 1986 LERs 87-021-00,88-009-00,88-009-01,88-009-0?.,

89-005-00,89-010-00,89-010-01,89-010-02,89-010 03, 89-010-04, and 89-010-05; NRC 1Rs 94 17,94-22,95-01, 95-02, and 95 17.

H.B. Robinson 2 197i LERs 88-018-00,88-018-01,90-003-00,90-008-00, i 90-010-00,90-010-01, and 91-010-01; NRC 1Rs 88-31, l 90-15,91-13, and 95-12.

St. Lucie 1 1976 NRC irs 88-05,90-03,91-09, and 96-08.

St. Lucie 2 1983 NRC irs 88-05,90-03,91-09, and 96-08.

Salem i 1977 LERs 87-007-00,38-013-00, and 88-014-00; NRC irs 93-80,96-10, and 97-09. l l

Salem 2 1981 LERs 87-007-00,88-013-00, and 88-014-00; l NRC irs 93-80,96-10, and 97-09.

San Onofre 2/3 1983/1984 NRC 1R 94-01.

Seabrook1 1990 LERs 89-011-00 and 89-011-01 Sequoyah 1/2 1981/1982 LERs 91 013-00,91-013-01,91-016-00, and 91-016-01; NRC 1Rs 88-54,9214,93-18,93-20,94-16,96-02,96-10, and 97-03.

Shearon Harris 1987 NRC irs 93-12,94-03, and 95-02.

South Texas 1/2 1988/1989 NRC irs 94-15 and 95-01.

Susquehanna i 1983 LERs 87-011-00,89-019-00, and 95-011-00; NRC 1Rs 95-12,95 14, and 96-201.

Summer 1984 NRC irs 88-04, 92 13, 92 17, 93-22, 94-03, 95-08, and l

l' 96-11.

Surry 1/2 1972/1973 NRC irs 88-07,9017,93-18,93-30,95-17, and 96-10.

Three Mile Island i 1974 LER 87-003-00 t

K-3 NUREG-1552, Supp.1 l

Reference Summary NMb)#6PNEfD % n'dCondSTOM/ M[ied dk$$$$RefefenceNh@g hD Troja~n LERs 90-022-00,90-022-01,92-006-00,92-006-01,92-011 00,92-026-00, 92-026-01,92-026-02,92-026-03, 92-026-04,92-026-05;92-031-00;92-034-00,93-001-00, and 93-002-00. i Turkey Point 3/4 1972/1973 NRC irs 88-37,91 10,92-23, and 96-06.

Vermont Yankee 1972 LERs 93-001-00,93-001-01, o,.3-001-02,94-018-00, 94-018-01,95-004-00,96-026-00, and 96-026-0I; NRC II( 93-05.

Vogtle 1/2 1987/1989 NRC irs 88-24,91-10,92-13,93-08,93 16,95-31, and 97-01.

Washington Nuclear 2 1984 LERs 87-004-00,87-029-00,87-030 00,88-008-00, 88-008-01,94-002-00, and 94-002-01; NRC irs 94-08, 9J 28,9.i-!8, and 95 201.

Waterford 3 1985 LERs 88-011-00,88-025 00,88-030-00,88-030-01, 88-030-02, 88-030-03, 90-019-00, 90-019-01, and 90-019-02; NRC IR 95-11 and NRR addit.

Watts Bar i 1996 NRC irs 94-62,94-78,95 32,95-38,95-39,95-40,95-45, 95-68,95 72, and 95-77.

Wolf Creek 1 1985 LERs 87-001-00,87-010-00,87-010-01, and 87-010-02; NRC 1R 95 19.

Zion 1/2 1973/1974 N/A.

NUREG 1552, Supp. I K-4

l NRC FOfW 338 u.a. NUCLEAR REouLAloRY Commission 1. REPORT NUMBER (Assioned ter NRC, Add Vet. Supp., Rev,

@ 1102' i BIBLIOGRAPHIC DATA SHEET l csee sammeme on memorm) !

) 2. TITLE AND SusTITLE NUREG-1552, Supplement 1 b Fire Barrier Penetration Seals in Nuclear Power Plants, N;;t.: 1

' D ftabh I k fuf 6)wb1f ,

June 1998 )

4. FIN OR GRANT NUMsER 3

5. AUTHOR (S) 6. lYPE OF REPORT C.S. Bajwa and K.S. West Technical

7. PERIOD COVERED (recemve onese)

I

e. PERFORMING ORGANIZATION NAME AND ADDRESS (#Mtc, poede DMeco, Once or % u& Nucceer Reedwory comnwesen, e<w memog eeweet acontrecear j

- poo nenn and menne senmen)

Division of Systems Safety Analysis

! - Ot. ice of Nuclear Reartor Regulation l

. U.S. Nuclear Regulatory Commission i Washington, DC 20555-0001

9. SPONSORING ORGANIZATION NAME AND ADORESS (rwic, type 1eme ne admet #condressor, som NRC 0% cace or Aspen, uS. Nocdoor Meeudefory Conwasson.

! andmemng edeosa)

Same as Above

10. SUPPLEMENTARY NOTE 5

11. AsSTRACT(200 eense or asse)

Nuclear plants use the " defense in depth" concept of echelons of Are protection to achieve a high degree of fire safety.

The % of this concept is to (1) prevent Ares from starting; (2) rapidly detect, control, and extinguish those fires that do occur; anc ~ 3) protect structu 'es, systems, and components important to safety so that a firo that is not promptly extinguished will not prt. vent the safe shutdown of the plant. Fire barrier penetration seals, which are but one element of me fire protection defense-in-depth cencept, are des ned to confine a fire to the area in which it started or to protect plant systems and components within an area from a re outside the area. Or, the basis of ev ing it found and considered, it is the staffs judgment that, overall, the issue of p;tential Are barrier penetration seal def . s does not affect safety. For the reasons geven in this paper, pical penetration seal danciencies do not necessarily equate to a lack of adequate protection or result in undue risk to and safety. It is the staffs opinion that continued licensee upkeep of existing penetration seal programs continued NRC in s are adequate (1) to ensure that penetration seal problems are discovered and resolved and (2)to maintab pu besith and safety.

l I

1

12. KEY WORDs/DEsCRIPTORs (uet sense orpareses met ust esset ressercners m asceans me importJ 11 AvAsLAstuTV sTATunnetT I Fire Barrier Penetration Seals N h Foem 14. SECURITY CLAssaFICATION Fire Barriers (m eese) I unclessified (77e8 Maport) i Unclassified

15. NUneman oF PAGEs is. PRICE seRC FoIW 336(240) The term was steesreresesy presumed by Ems Federal Fonne ma

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NUREG-1552, Supp. I FIRE BARRIER PENETRA110N SEALS IN NUCLEAD POWER PRANTS ~ JUNE 1998

-- DRA5T UNITED STATES - FIRST CLASS MAN.

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SUMMARY

SUMMARY

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