ML20203D054

Fire Barrier Penetration Seals in Nuclear Power Plants

ML20203D054
Person / Time
Issue date:	01/31/1999
From:	Chris Bajwa, Khadijah West Office of Nuclear Reactor Regulation
To:
References
NUREG-1552, NUREG-1552-S01, NUREG-1552-S1, NUDOCS 9902120364
Download: ML20203D054 (68)

Text

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q AVAILABILITY NOTICE  !

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NUREG-1552, Supp.1 1

Fire Barrier Penetration Seals I in Nuclear Power Plants  !

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Manuscript Completed: December 1998 Date Published: January 1999 C. S. Bajwa, K. S. West

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Division of Systems Safety Analysis Office of Nuclear Reactor Regulation U.S. Nuclear Regulatory Commission Washington, DC 20555-0001 i-4

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4 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 of its 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 j -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 attention to existing penetration 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 4 high degree of fire safety. Fire barrier penetration assurance that penetration seal problems are l_ 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 arca in which it started or to protect plant e

iii - NUREG 1552, Supp.1

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l TABLE OF CONTENTS j i

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1 A B STRA CT h . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . iii j 4

4 1

EXEC UTIVE S UMMARY . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . vil

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1- ~ DEFENSE-IN.DEFni CONCEPT AND THE ROLE OF PENE'IRATION SEALS . . . . . . . . . . . . . . . 1

1.1 Assessments of Fire Barrier Penetration Seals . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 1 1.2 'Ihe Role of Penetration Seals in the Defense-in-Depth Concept . . . . . . . . . . . . . . . . . . . . . . . . . . 1 i

j. 2 REVIEW OF REACTOR OPERATING EXPERIENCE . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 3

. ' 2.1 Licensee Event Reports . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 3

! - 2.2 NRC Inspections . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 4 23 ' Fire Experience . . . . . . . . . . . . . . . . . . . . ' . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 5 - )'

. 2.4 Summary of Operating Experience . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 6 3 S AFETY S IGNIFICANCE . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 6 3

3.1 Fire Protection Program . .. . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 6 3.2 ' Safety Significance Ranking of Penetration Seal Deficiencies . . . . . . . . . . . . . . . . . . . . . . . . . . . . 7 3.3 Generic Assessnent of Safety Significance . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 7

[ 3.3.1 Improperly Installed or Degraded Seals and Inadequate Documentation . . . . . . . . . . . . . . . 8 2

- 3.3.2 Unsealed and Breached Penetrations . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 9 3.4 Scal-Specific Assessment of Safety Significance . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 10 1

RIS K S IGNIFICANCE . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 1 1 5 COMPENSATORY MEASURES . . . . . . . . . . . . . . . . . . . . . . . ... ....... . . ......... 11 6 PLANT. SPECIFIC EXPERIENCE WITH FIRE BARRIER PENETRATION SEALS . . . . . . . . . . . . . ' 11 '

6.1 Vermont Yankee Nuclear Power Station . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 11 I 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 i nspection . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 13 6.5.2 Licensee Event Reports . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . ............ 14 6.5.3 S taff Followup '. . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 14 l 6.5.4 - Conclusions on Maine Yankee Operating Experience .. . . . . . . . . . . . . . . . . . . . . . . . . . . . 15

1 6.6 - Concl us ions . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 15 4

7  :. REVIEW OF' PLANT-SPECIFIC LICENSING BASES RELATED TO SECTION III.M

OF APPENDIX R TO 10 CFR PART 50 . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 15 4

- 7.1 - . ' Introduction . . . . . . . . .. . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 15

. 7.2 Plant. Specific Licensing B ases . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 16 f 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 . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 17 i

7.2.4 Maine Yankee Atomic Power Plant . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . .... .. 17 7.2.5 Monticello Nuclear Generating Plant . .. ....................... ........ 17 l 7.2.6 Peach Bottom Atomic Power Station, Units 1 and 2 . . . . . . . . . . . . . . . . . . . . . . . 17

.7.2.7 Pilgrim Nuclear Power Station, Unit 1 . . . . . . . ........................... 17 t ,

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! 7.2.8. Point Beach Nuclear Plant. Units 1 and 2 . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 18 7.2.9 . H.B. Robinson Steam Electric Plant, Unit 2 . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . I8- ,

i 7.2.10 Surry Power Station, Units 1 and 2 . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 18 7.2.11 Vennont Yankee Nuclear Power Station . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . I 8 7.3 Summary....................................................................19 I' '8 RECOMMENDATIONS IN THE FINAL STAFF REPORT . . . . . . . . . . . . .. . . . . . . . . . . . . . . . . . . . 19 8.1 ' Introduction . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 19  ;

8.2 Status . . .

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! 8.2.1 - Recommendations 1, 2, and 3 (Pending) . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 19 l- 8.2.2 Recommendation 4 (Complete) . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 20 8.2.3 FPFI Program (Complete) . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 20 l 9 PUBLIC COMMENTS ON DRAFT NUREG-1552, SUPPLEMENT 1 . . . . . . . . . . . . . . . . . . . . . . . . 20 10 CONCLU S ION S . . . . . . . . . . . .. . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 20

' APPENDICES

• D ~ Acronyms and ' Abbreviations . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . , . p. ]

~F' Licensee Event Reports Submitted by Year (1987 Through September 1998) . . . . . . . . . . . . . . . . . . . . . . . . F-1 l

G- Summary of Reported Problems (1987 'Ihrough September 1998) . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . G-1 H Summary of Licensee Event Reports (1987 Through September 1998) . . . . . . . . . . . , . . . . . . . . . . . .. . . . H-1 I NRC Inspections (March 1980 'Ihrough August 1998) . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . I-l J~ ' Plants Known To Have Performed 100-Percent Penetration Seal Inspections . . . . . . . . . . . . . . . . . . . . . . . . J-l i K. Re ference S ummary . . .. . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . K.1

• Appendices A.E appear in NUREG-1552.

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z-L EXECUTIVE

SUMMARY

i i Nuclear power plants use the " defense in depth" industry. The staff concluded that these actions concept of echelons of fire protection to achieve a together with continued NRC inspections, and high degree of fire safety. He objective of this continued licensee attention to existing penetration

, . concept is to (1) prevent fires from starting; seal programs, were adequate to maintain public (2) rapidly detect, control, and extinguish those fires health and safety. The staff documented its

{ that do occur; and (3) protect structures, systems, and assessment in SECY-96-146," Technical Assessment components important to safety so that a fire that is of Fire Barrier Penetration Seals in Nuclear Power -

[ not promptly extinguished will not prevent the safe Plants"(July 1,1996), and NUREG-1552," Fire

shutdown of the plant. He multiple layers of fire Barrier Penetration Seals in Nuclear Power Plants"

[

protection provided by the defense-in-depth concept

' offer reasonable assurance that weaknesses or (July 1996).

5 deficiencies in one layer will not present an undue - The NRC staff has since continued to review

,. ' risk to public health and safety. potential penetration seal problems on a case-by-case

. basis as they are found or reported. %is report l' ire barriers, which are one element of the fire supplements the NRC staff assessment of fire barrier b' protection defense-in-depth concept, accomplish their penetration seals by reviewing additional information

intended design function simply by remaining in on seal problems reported by licensees and found

place during a fire. They are important because they during NRC inspections performed prior to as well as

are the first and also the last lines of defense against since the assessment documented in SECY-96-146

a fire. Hat is, during the early stages of a fire, the . and NUREG-1552. In light of the new information,

!' - barriers confine the fire and protect imponant the staff reconsidered the operating experience I systems and components until the fire detection and reported in NUREG-1552, and considered the results

{ automatic fire suppression systems operate. In of the effort, as documented in this report, for 1 addition, in the event that an automatic fire protection insighta and appropriate opportunities for actions by system fails to operate or fire brigade response is the NRC and the industry.

delayed, the fire barriers continue to provide passive i 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 structural fire barriers in which they are installed, are . programs. Between 1988 and March 1998,it passive fire protection features. %eir design conducted 153 inspections that involved installed i function is to confine a fire to the area in which it penetration seals and penetration seal programs at 87

• started or to protect plant systems and components plants. In general, the inspectors found that the within an area from a fire outside the area. Fire - penetration seal programs were comprehensive, i~ bartier penetration seals are not safety related. timely, and acceptable. In some cases, the inspectors

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. found deficiencies and issued notices of violations. ,

t- ' Between 1994 and 1996, the Office'of Nuclear %ese inspections are summarized in Appendix L in 3

Reactor Regulation (NRR) staff conducted a addition, the staff obtained the licensee event reports

comprehensive technical assessment of penetration (LERs) on fire barrier penetration seals that were i seals to address reports of potential problems, to submitted in 1987,1988, and 1994 through 5

determine if there were any problems of safety - September 1998, inclusive. ne staff also reviewed e , significance, and to determine if NRC requirements, LERS that were submitted from 1989 through 1993 )

review guidance, and inspection procedures were for a second time. (%e staff originally documented 1 adequate. %e staff did not find any plant-specific the results of its review of these LERs in NUREG-problems of safety significance or any concerns with 1552.) The staff found that 9 plant sites submitted 16 j generic implications. %e staff concluded that the LERs during 1987; 12 plant sites submitted 19 LERs I general condition of penetration seal programs in during 1988; and 14 plant sites submitted 34 LERs industry was satisfactory. De staff also concluded between 1994 and September 1998. Appendix F

.- that the information notices it had issued in 1988 and shows the numbers of LERs and LER supplements j, .1994, increased industry awareness of potential regarding fire barrier penetration seals that were

penetration seal problems and resulted in more submitted by year from January 1987 through comprehensive surveillance activities, maintenance September 1998. Appendix G details the types of

. practices, and corrective actions on the part of problems (the four major categories and

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1 Executive Sununary subcategories) that were reported by year for the found during licensee surveillances and NRC same period, and the number of times the problems inspections. However, potential penetration seal occurred. Appendix H reports on each LER and LER problems are understood; industry consensus fire test supplement that the staff considered during this standards are available and are complied with; and reassessment of penetration seals. This report also fire test results and qualified fire-resistant seal contains a detailed review of the status of penetration materials and designs are available. Therefore, seal programs at several plants that have undertaken licensees have the treans to correct problems, and major corrective action programs for penetration continued staff oversight will ensure that corrections seals. are made on a case-by-case basis.

Section III.M of Appendix R to 10 CFR Part 50 In summary, it is the staff's opinion that continued specifies that penetration seals utilize only licensee attention to existing penetration seal noncombustible materials. To address questions programs and continued NRC inspections are i about the NRC regulatory requirements regarding the adequate (1) to ensure that penetration seal problems use of these penetration seal materials, the staff are discovered and resolved and (2) to maintain l reviewed the fire protection licensing basis for all public health and safety. j nuclear plants. The staff determined which plants are required to comply with Section III.M of Appendix R To provide added assurance of this, during the to 10 CFR Part 50. He staff then conducted a assessment documented in this report, the staff issued ,

detailed review of the fire protection licensing bases Information Notice 97-70, " Potential Problems With for those units to determine if the plants used Fire Barrier Penetration Seals," September 19,1997, silicone-based fire barrier penetration seal materials and revised the NRC fire protection core inspection and, if they did, how the licensees and the staff module to provide more specific inspection guidance addressed the regulatory requirement of to NRC inspectors regarding fire barriers and fire Section Ill.M of Appendix R. barrier penetration seals. He staff will continue to assess new information regarding penetration seals On the basis of everything it identified and for new insights and appropriate opportunities for considered, the staff judges that, overall, the issue of additional actions by the staff or the industry.

potential fire barrier penetration seal deficiencies is not a safety concern. For the reasons given in this During the 454th meeting of the Advisory Committee report, typical penetration seal deficiencies do not on Reactor Safeguards (ACRS), July 8-10,1998, the necessarily equate to inadequate protection or result staff presented the results of the assessment in undue risk to public health and safety. documented in this supplement to NUREG-1552 to the ACRS. The ACRS provided its views regarding On the basis of the reassessment documented here, the efforts of the NRC staff and the nuclear industry the staff concludes that the actions it took in 1988 to resolve issues related to fire barrier penetration and 1994 to alert licensees to potential penetration seals in a letter of July 20,1998, from RL Scale, seal problems increased industry awareness of such Chairman, ACRS, to Chairman Jackson. He ACRS problems and resulted in more comprehensive found it clear that, overall, the NTC staff and the surveillance activities, maintenance practices, and licensees have the issues of fire barrier penetration corrective actions. The staff also concludes that the seals well in hand and that the efforts of the staff and general condition of penetration seal programs in the licensees have been successful in addressing the industry appears to be satisfactory. He staff expects problems of the past.

that plant-specific deficiencies may occasionally be NUREG-1552, Supp. I viii

1 DEFENSE-IN-DEPTH Notwithstanding these findings, the NRC staff reviews potential problems on a case-by-case basis as CONCEPT AND THE ROLE they are found or reported. nerefore, the NRC staff OF PENETRATION SEALS updated its assessment of fire barrier penetration seals by assessing information on seal problems reported by licensees and found during NRC 1.1 Assessments of Fire Barrier inspections since the assessment documented in Penetration Seals SECY-96-146 and NUREG-1552. He staff reconsidered the operating experience reported in Over the years, the U.S. Nuclear Regulatory NUREG-1552 in light of the new information, and Commission (NRC) staff has completed a number of also considered the results of this effort, which is assessments of fire barrier penetration seals. In 1987 documented herein, for insights and appropriate and 1988, the Office of Nuclear Reactor Regulation opportunities for actions by the NRC and the (NRR) and regional office staff perfornrd a industry.

comychensive assessment of fire barrier penetration seals. Although it found no widespread problems or safety-significant generic issues, the staff alerted 1.2 The Role of Penetration Seals mdustry to potential problems by means of a series of ,

information notices. Later,in 1993, NRR staff Concept reassessed the fire protection program for nuclear reactors. In its " Report on the Reassessment of the Nuclear power plants use the " defense in depth" NRC Fire Protection Program"(February 27,1993), concept of echelons of fire protection to achieve a the staff concluded that licensees were complying high degree of fire safety. He objective of the with regulatory requirements and that there were no concept is to (1) prevent fires from starting; major or recurring issues with penetration seals. In (2) promptly detect, control, and extinguish those 1995, the Office for the Analysis and Evaluation of fires that do occur; and (3) protect structures, Operational Data (AEOD) reviewed fire barrier systems, and components important to safety so that a penetration seals and reached many of the same fire that is not promptly extinguished will not prevent conclusions that NRR had reached. Finally, between the safe shutdown of the plant. The severallayers of 1994 and 1996, NRR staff conducted a fire protection produced by the defense-in-depth comprehensive technical assessmen: of penetration concept offer reasonable assurance that weaknesses seals to address reports of potential problems, to or deficiencies in one layer will not present an undue determine if there were any problems of safety risk to public health and safety. To achieve defense significance, and to detennine if NRC requirements, in depth, each operating reactor maintains an NRC-review guidance, and inspection procedures are approved fire protection program. De licensees adequate. De staff did not fit;d any safety-have designed the fire protection programs by significant plant-specific problems or concerns with analyses that (1) considered potential fire hazards, generic implications. He staff concluded that the (2) determined the effects of fires in the plant on the general condition of penetration seal programs in the ability to safely shut down the reactor or on the nuclear industry was satisfactory. The staff also ability to minimize and control the release of concluded that the information notices it had issued radioactivity to the environment, and (3) specified in 1988 and 1994 increased industry awareness of measures for fire prevention, fire confinement, fire potential penetration seal problems and resulted in detection, automatic and manual fire suppression, more comprehensive surveillance activities, and post-fire safe-shutdown capability, maintenance practices, and corrective actions.

Moreover, the staff concluded that these staff Nuclear power plants are divided into separate areas actions, together with continued licensee attention to by structural fire barriers such as concrete floors, existing penetration seal programs and continued walls, and ceilings. The fire protection function of NRC inspections, were adequate to maintain public these barriers is to prevent a fire that sta'ts in one health and safety. He staff documented its plant area from spreading to another area. A barrier's assessment in SECY-96-146," Technical Assessment fire-resistance rating, which is a measure of the of Fire Barrier Penetration Seals in Nuclear Power extent to which the barrier resists the effects of fire, Plants" (July 1,1996), and NUREG-1552, " Fire is determined by exposing a mockup of the barrier to Barrier Penetration Seals in Nuclear Power Plants" an intense test fire for a designated period. Nuclear (July 1996).

I NUREG-1552, Supp. 1

. Defrnse-in-Depth Concept and the Role of Penetration Seals power plant fire barriers typically have a fire- and Materials'." 'Ihis time-temperature curve, which resistance rating of 1,2, or 3 hours3.472222e-5 days <br />8.333333e-4 hours <br />4.960317e-6 weeks <br />1.1415e-6 months <br />. Openings are is used to determine the fire resistance of all types of

~

needed in structural fire barriers to allow such items building fire barriers, represents a severe fire  :

as cable trays, conduhs, pipes, and ventilation ducts exposure. (It is important to note that fire tests are f to pass from one plant area to another. To maintain not intended to me<lel any specific room fire or the

~ the fire protection function of the structural fire conditions under which the seals will be exposed barriers, the openings and the gaps and annular during a fire, but rather to provide a specific standard

' spaces around the penetrating hems (penetrations) fire exposure against which similar fire rated -

should be sealed in a configuration that offers the assemblies can be evaluated.)

same fire resistance as that of the barrier in which they are installed. 'Ihe average number of fire barrier The fire protection effectiveness of structural fire :  !

penetration seals per nuclear power plant unit is barriers is largely dependent on their inherent fire  !

~a bout 3000 and a single unit can have up to 10,000 resistance, details of construction, and protection of -  !

seals. penetrations. Some fire barriers (both structural . ,

barners and penetration seals) are more important to i Fire barriers, which are one element of 'he fire the fire protection defense-in-depth o ncept than ,

protection defense-in-depth concept, accomplish their others. 'Ihe importance of specific fire barriers intended design function simply by remaining in depends on many factors, such as the importance of

. place during a fire. "Ihey are important because they ~ tPe plant systems and components in the fire area may serve as the first and also the last lines of. (and adjacent areas); the types, amounts, defense against a fire. 'Ihat is, during the early stages configurations, and locations of combustible

of a fire, the barriers confine the fire and protect materials and fire hazards, if any, in the areas; the important systems and components until the fire potential for fire growth in the areas; the fire detection and automatic fire suppression systems protection features installed in the areas; and the operate. In addition, in the event that an automatic accessibility of the areas to the plant fire brigade.

fire protection system fails to operate or fire brigade The importance of specific penetration seals depends response is delayed, the fire barriers continue to on these factors and on such other factors as their  ;

provide passive fire protection. Fire barrier size, their location or position in the fire barrier, and penetration seals are another element of defense in the number and sizes of the other seals in the barrier. -

depth and, like the structural fire barriers in which ,

they are installed, are passive fire protection features. In order of overall importance to fire protection

. 'Iheir design function is to confine a fire to the area defense in depth, structural fire barriers, being in which it started or to protect plant systems and necessary for the structural integrity of a building or components within an area from a fire outside the . fire area, are generally considered to be more area.. important than fire barrier penetration seals.

Qualified fire protection engineers determine the To gain reasonable assurance that a penetration seal importance of individual fire barriers by analyzing will have the required fire-resistance capability or fire hazards and the locations of safe shutdown and

fire rating, a penetration seal test assembly is safety-related systems and components.

, subjected to a fire endurance test. 'Ihe test methods i

. involve the furnace-fire exposure of a full-scale Although a detailed discussion of such analyses is penetration seal test specimen that is representative beyond the scope of this paper, the following of the construction for which a fire-resistance rating . discussion illustrates this approach.

is desired.?Ihe heat input to the test furnace is controlled so that the average temperature in the Consider, for purposes of a worst-case analysis, that ,

furnee follows the time-temperature curve specified a structural fire barner fails during exposure to a fire.

in the test standard. In the United States, the in this event, the' adjoining fire area and its contents standards for testing penetration seals use the time- would be exposed to the same fire and would, 2 tempere'ure curve defined in American Society for themselves, become involved in the fire in a short

! Testing and Materials (ASTM) E-119, " Standard Test Methods for Fire Tests of Building Construction

' Representative points on the curve that determine its character are: 1000 'F at 5 minutes,1550 'F at 30 minutes,1700 'F at I hour,1850 'F at 2 hours2.314815e-5 days <br />5.555556e-4 hours <br />3.306878e-6 weeks <br />7.61e-7 months <br />, <

and 1938 'F at 3 hours3.472222e-5 days <br />8.333333e-4 hours <br />4.960317e-6 weeks <br />1.1415e-6 months <br />.

NUREG-1552, Supp; I - 2 m _ m ~ _u2_ _ ._ _ _,_ .- ~ _. _

1 Review of Reactor Operating Experience

, period of time. (Because of the substantial Overall, the staff found that the technical problems construction of structural fire barriers in nuclear with penetration seals that were reported between i

! power plants and fire protection defense in depth, the 1987 and September 1998, inclusive, could be l staff does not consider this a credible nuclear power classified into four major categories. In descending I plant fire scenario.) Similarly, catastrophic failure of order of the number of reported occurrences, these a penetration seal could expose the adjacent fire area were to the fire. Ilowever, since the penetration sealis not -

necessary for structural integrity, its failure is not as (1) seal not installed or breached (58 occurrences),  :

significant a fire threat as the failure of a structural i fire barrier would be. In addition, in most cases, a (2) seal not properly installed (63 occurrences),

seal failure would initially create a localized hot spot '

(3) inadequate documentation (19 occurrences), and in the adjacent fire areain the area of the seal. If there are no combustible materials in the adjacent fire (4) seal degraded or damaged (17 occurrenc,es).

area in the vicinity of the failed seal (for example, if the penetration seal surrounds a pipe), smoke and hot Appendix F shows the numbers of LERs regarding gases will migrate into the adjacent area, but the fire barrier penetration seals that were submitted by spread of fire into the area will be limited. If there year from January 1987 through September 1998.

are combustible materials in the vicinity of the failed Appendix G details the types of problems (the four seal (for example,if the penetration seal surrounds a major categories and subcategories) that were loaded cable tray that passes from one fire area to reported by year for the same period, and the number ,

another), the fire could spread into the adjacent area of times the problems occurred. Appendix 11 reports more readily. In this instance, a nere detailed fire on each LER that the staff considered during this hazards analysis is needed to assess the potentially reassessment of penetration seals. (The total number adverse effects of the fire spread. Regardless, such a of LERs for 1989 through 1993 differs from the fire scenario is less threatening than the failure of a number reported in NUREG-1552 because the staff structural fire barrier, removed from consideration reports that were not related to technical problems, e.g., missed 2 REVIEW OF REACTOR surveillances. Note also that some licensees do not c nsider that penetration seal deMaies are OPERATING EXPERIENCE conditions that put a plant outside its design bas,si and, therefore, do not report such deficiencies in 2.1 Licensee Event Reports LERs.)

In NUREG-1552, the staff reported that in 1994 the licensee event report (LER) database maintained by As part of this reassessment, the staff reviewed the Oak Ridge National Laboratory contained about LERs submitted during 1987 and 1988 and those 58,000 LERs and that 318 (about 0.5 percent) of submitted from 1994 through September 1998. He them, involved fire barrier penetrations. (For this staff also reconsidered the LERs that were submitted discussion, "LERs" also includes LER supplements.) from 1989 through 1993. On the basis of its reviews, the staff made the following observations:

In NUREG-1552 the staff documented the results of its review of the LERs submitted between 1989 and (1) The types of problems that were reported 1993, inclusive. ne staff found that licensees for during 1987 and 1988 and from 1994 through about 20 plant sites had submitted 141 LERs 1998, were consistent with the types of regarding fire barrier penetration seals. In support of Problems reported in the LERs submitted from the reassessment documented here, the staff obtained 1989 through 1993. He staff did not uncover

. the LERs regarding fire barrier penetration seals that new types of problems.

were submitted in 1987 and 1988, and 1994 through September 1998, inclusive. He staff found that 9 (2) It appears that the types of problems and plant sites submitted 16 LERs during 1987; 12 plant deficiencies that have been found (e.g., voids, sites submitted 19 LERs during 1988; and 14 plant cracks, inadequate documentation) have sites submitted 34 LERs between 1994 and involved each type of seal used by industry

[ September 1998. (e.g., grout, silicone foam, and silicone clastomer).

3 NUREG-1552, Supp. 1 i

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 8 in 1998 (through September). subsequent penetration seal surveillance.

(4) He number of occurrences of penetration seal (8) In some cases, licensees conservatively deficiencies has decreased from a high of 25 reported such superficial problems as surface in 1989 to 7 in 1998 (through September). imperfections and small cracks, splits, and gaps, which would not have precluded the (5) After its first comprehensive technical seals from performing their intended fire assessment of fire barrier penetration seals, the protection design function.

NRC staff issued Information Notices (ins) 88-04; 88-04, Supplement 1; and 88-56 to alert (9) Licensees appear to understand potential industry to potential seal problems. In problems with and corrective actions for fire response to these ins, there was significant barrier penetration seals.

industry scrutiny of installed penetration seals and penetration seal programs. On the basis of (10) Plant age does not appear to be a critical its best-effort search of LERs and NRC attribute as to whether or not a plant is prone inspection reports (see Section 2.2, below), the to seal problems. Of the 45 plants known to staff found that the licensees for at least 45 have completed 100-percent seal inspection plants have conducted enhanced 2100-percent programs, about half operated before January penetration seal inspections in response to the 1,1979 (and are covered by the regulations in ins. (See Appendix J for a complete list of Appendix R), and half began operations later references.) and are not covered by the regulations in Appenuix R.

(6) Most of the licensees that have conducted 100 percent seal inspection programs found seal (11) Overall, the rafety significance and risk deficiencies. He findings ranged from significance of the reported deficiencies were negligible to widespread problems involving low. The potential safety significance of the each of the four categories of problems. Rese reported problems is discussed in Section 3.

licensees strengthened their programs to Re risk significance is discussed in Section 4.

reduce the likelihood of recurrence.

Of the LERs submitted since the staffissued (7) Many of the deficiencies conceming failure to NUREG-1552, two indicated widespread plant-install seals, improper seal installation, and specific deficiencies. De first involved Washington inadequate documentation existed since the Nuclear Project 2 (WNP2) and the second involved plant was built. However, these types of Maine Yankee. He staff was aware of the deficiencies at WNP2 through previous NRC problems 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 1 outages, temporary and permanent NUREG-1552. The staff's assessment of the Maine modifications that involve routing cables are ,

Yankee report is m Section 6.6 of this report.

commonplace. Such modifications require breaching existing penetration seals or making j new penetrations. Plant procedures specify 2.2 NRC Inspections i that the breached seals be restored and that new penetrations be sealed with properly As part of this reassessment, the staff conducted a designed and tested penetration seal best-effort search for NRC inspections of penetration l seal programs. He staff found that between 1988 and March 1998, it conducted 153 inspections that 2 inv Ived installed penetration seals and penetration For purposes of this discussion, an enhanced seal programs at 87 plants. Of these,42 (48 percent) program is one that exceeds the requirements of the were Appendix R plants (operating prior to licensee's routine surveillance program. For January 1,1979). De inspectors reviewed the example, the licensee may have compared test adequacy of penetration seal installations, documentation to installed seal configurations or qualification, and surveillances. Rey also followed removed damming boards to verify the thickness of up on issues reported in LERs and weaknesses noted the installed seals.

NUREG-1552, Supp.1 4

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.

!ssued notices of violations. Each of thes e FPFI procedures and guidance contain detailed inspections is summarized in Appendix I.

and seal programs. Rese procedures and guidelines On the basis of its review of the NRC inspection are bemg 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 The types of problems found during basis independent of an FPFI. I (1) inspections were consistent with the types of problems reported in LERs. De staff did not 2.3 Fire Experience identify new types of problems during its inspections. %e staff reviewed the fire event databases compiled  ;

by Sandia National Laboratories, which contained (2) ne inspection reports, like the L.ERs, revealed data from 1965 thorough 1985, und the Electric that licensees occasionally find plant-specific Power Research Institute, which contained data from deficiencies. 1965 through 1988. The staff found no reports of l nuclear power plant fires that challenged the ability l (3) For the most part, the licensees maintained of fire rated structural barriers or fire rated satisfactory fire barrier penetration seal penetration seals to confine a fire in accordance with programs.

)

their fire protection design function. The staff also l reviewed the LER database discussed in Section '2.1, l (4) Licensees understand potential fire barrier which contains data from 1980 to the present, and penetration seal problems, have the means to again, found no reports of nuclear power plant fires correct pmblems, and have taken appropriate that caused the failure of a fire rated structural barrier l and timely actions to correct penetration seal or a fire rated penetration seal. In addition, since the I deficiencies. staff issued NUREG-1552, AEOD issued a special study titled " Fire Event.6-Feedback of U.S.

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

protection inspection procedures are contained in the NRC Inspection Manualin Inspection It has been suggested that the March 22,1975, fire at Procedure 64704, " Fire Protection Program" the Browns Ferry Nuclear Plant propagated through a (March I8,1994). This procedure directs the fire-rated penetration seal and, therefore, there is inspectors to visually inspect the fire barriers industry experience that a fire challenged such a seal.

associated with two plant fire areas and ensure that The staff does not agree. As reported in the electrical and mechanical penetration seals are NUREG-0050, " Recommendations Related to functional. However, the procedure did not give Browns Ferry Fire"(February 1976),"the seal that specific guidance for inspecting the seals or caught fire differed from the [ fire] seal as designed establishing their functionality. The lack of specific and tested." For example, the installed seal in which inspection guidance was viewed as a potential the fire started used flexible polyurethane foam rather weakness in the NRC reactor fire protection program. than the spray polyurethane foam specified in the herefore, the staff revised Procedure 64704 in plant's original design criteria. In addition, the September 1997, to add guidance for inspecting installed seal did not have the fire-retardant coating penetration seals as a part of its routine fire specified in the design criteria. Furthermore, the l

protection inspections. report stated that "a properly made fire stop of the 5 NUREG-1552, Supp. I

P Safety Significance s

Browns Ferry design (with Flammastic and without Branch Technical Position (B'IP) Auxiliary Power ,

flexible foam) would probably not have initiated the Conversion Systems Branch (APCSB) 9.5-1,  ;

fire" and "even if a fire had started, a fire stop made " Guidelines for Fire Protection for Nuclear Power l

in accordance with the original design may well have Plants;" and Appendix A to BTP APCSB 9.5-1, t

- prevented its spread outside of the room where it " Guidelines for Fire Protection for Nuclear Power ,

started." Plants Docketed Prior to July 1,1976." Dese two '

NRC documents specify preferred methods for fire  ;

2.4 Summary of Operating Protection program design. In addition,

[

Sution 50.48(b) states that Appendix R to 10 CFR EXpedence Part 50, " Fire Protection Program for Nuclear Power [

Facilities Operating Prior to January 1,1979,"  !

The IERs and NRC inspection reposts show that esta es Gm pmtat n featms required to sausfy many plants have performed 100-percent penetration ,

GDC 3 with aspat to cdn gMcisms for seal inspections and corrective action programs since nudear power plants la,nsed to operam Me  ;

1987. The staff sound no evidence of generic problems of safety significance with penetration seal """*'Y I. . I 82 Pmtation pmgrams that meet materials or safety-significant failures of penetration ntena oh M ESNI w Appendix .

A to BTP APCSB 9.5-1 and the applicable sections ,

seals. On the basis ofits review, the staff concluded f Appendix R sadsfy M GR 5&48 and GDC 3.

that the licensees have been effective in finding REG-0800, ,

penetration seal deficiencies and have taken timely Secti n 9.5-1, Fire"Protection Standard Review Plan,"(SRP)

Program, '

and appropriate actions to correct identified

, . incorporates the guidance of BTP APCSB 9.5-1 and i discrepancies. In view of the large number of  !

Apperidix A to B'IP APCSB 9.5-1 and the criteria of penetration seals installed in nuclear power plants, Appendix R. Therefore, fire protection programs -

the staff expects that plant-specific deficiencies may that meet the guidelines of SRP Section 9.5-1 also occasionally be found during Lcensee surveillances satisfy 10 CFR 50.48 and GDC 3. -

and NRC inspections. Hcwever, the IIRs and NRC inspection findings show that licensees understand The objective of the fire protection program required the potential fire barner penetration seal problems by 10 CFR 50.48 is to minimize both the probability '

and that fire test results and qualified fire-resistant .

L and consequences of fires. As discussed in j seal materials and designs are available. Therefore,

! Secti n 1, the licensees use the concept of defense m, .l licensees have the means to correct problems.

depth to achieve a high degree of fire safety. The l ' Appendix J lists plants that, on the basis of docketed I licensees determine the adequacy of fire protection l information, are known to have performed 100-l safety systems and areas by analyzing the f r P ant  ;

l percent penetration seal inspection programs that e#ects of postulated Gres. In general, k pnmary exceeded the specifications of the licensees' normal mean8 f fire Protection consists of fire barriers and j fire barrier surveillance programs. Appendix K lists ixed automatic fire detection and suppression  ;

l the docketed references (LERs and NRC inspection systems. In addition, manual fire fighting capability "

I reports), by plant, that the staff considered in this

' 18 Provided throughout the plant to limit the extent of reassessment of fire barrier penetration seals.

fire damage. The plant fire hazards analysis ,

l. addresses the following variables and attributes. 1 3 SAFETY SIGNIFICANCE (1) the NRC fire protection requirements and 3.1 Fire Protection Program  !

, (2) amounts, types, configurations, and locations  !

The basic fire protection regulation for commercial of cable insulation and other combustible

. nuclear power plants is Title 10 of the U.S. Code of materials; Federal Regadations, Part 50, Section 50.48, " Fire

protection." Section 50.48(a) states that each (3) fire loading and calculated fire severities; operating nuclear power plant must have a fire i protection plan that satisfies General Design (4) in situ fire hazards; 4

Criterion (GDC) 3 of Appendix A to 10 CFR Part 50,

" Fire protection," and notes that fire protection (5) automatic fire detection and suppression j gW~e for nuclear power plants is contained in capability; )

l NUREG-1552, Supp.1 6

Safety Significance (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 installation; 3.3 Generic Assessment of Safety Sigmficance (8) fire area construction (walls, floor, ceiling, dimensions, volume, ventilation, and For pugoses of the following discussion, the safety congestion); significance of a fire barrier penetration seal can be thought of as being the role the seal plays in (9) location and type of manual fire fighting Preventing a fire from spreading from the fire area of equipment and accessibility for manual fire origin to an adjacent fire area. In the Federal fighting; Register notice that issued the proposed Appendix R to 10 CFR Part 50,2 the staff stated that the (10) potential disabling effects of fire suppression "Phenomenon of fire is believed to be sufficiently systems on shutdown capability; well understood to permit evaluation of existing and potential fire bazards and probable extent of damage (11) availability of oxygen to support combustion should a fire occur. Such evaluations are useful in (for example, inerted containment); and assessing the possible consequences of fire in a given area." In this regard, a generic assessment is (12) post-fire safe-shutdown capability, including instructive for understanding the safety significance alternative or dedicated shutdown capability. of fire barrier penetration seals.

During its reviews and inspections of the licensees' As discussed in Section 1, licensees rely on a fire protection programs, the staff ensured that each defense-in-depth concept that incorporates several licensee had provided an adequate level of fire fire safety measures. In sum, automatic fire detection protection. and suppression systems are provided in most areas that have safe-shutdown equipment. Trained fire brigades are required to be on duty 24 hors a day at 3.2 Safety Significance Ranking of all plants. All areas that have safe-shutdown Penetration Seal Deficiencies 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 represent an adequate means of fire protection at the factors as the nature and extent of the deficiency; the plants and ensure that operations can be conducted importance of the plant systems and components in _ without an undue risk to the health and safety of the the fire area (and adjacent areas); the amounts, types, public. In general, every echelon of fire protection configurations, and locations of any combustible defense in depth would have to either fail or be materials and fire hazards in the areas; the potential significantly compromised for a fire to breach a fire for fire growth in the areas; the fire protection barrier penetration seal and adversely affect the safe-features installed in the areas; and the accessibility of shutdown capability or cause other operational the areas to the plant fire brigade. He actual safety problems. Specifically, the following would have to significance and the importance of a specific seal occur:

depends on these factors and on such other factors as its size, its location or position in the fire banier, and (1) Despite the plant fire prevention program, a

- the number and sizes of the other seals in the barrier. fire would have to occur.

Appendix G summarizes the types of penetration seal (2) The fire would have to go undetected. Hat is, problems and deficiencies that were reported in LERs, by year, from 1987 through September 1998, inclusive. It is the staffijudgment 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 G can be Federal Register. Vol. 45, No.105, May 29,1980, ranked from highest potential safety significance to pp.36082-36090.

7 NUREG-1552, Supp. I

Safety Significance the automatic fire detection and alarm system the components to affect their ability to would have to fail. In addition, plant function. That is, the scenario described under personnel would have to fail to discover the items I through 6 would also have to occur in fire. the second fire area.

(3) he fire would have to grow beyond the As discussed in Section 1, fire barrier penetration incipient stage, spread, and become large. seals are passive fire protection features that his means that the fire area would have to accomplish their intended fire protection function by contain transient and in situ combustible their very presence. Penetration seals are important materials of sufficient types, amounts, and features because they help confine a fire to its area of configurations to support fire growth and origin. There can be no question that when properly spread. designed and installed, the various types of penetration seals currently imtalled in nuclear power (4) The automatic fire suppression system (if there plants will provide fire resistance equivalent to the is one) would not operate and control the fire, bacriers in which they are installed and will perform or if it operated, it would fail to control the their intended fire protection function by confining a fire. fire to the area of origin. The types of penetration sea' deficiencies described in Section 2 and in (5) Manual fire suppression activities would not Appendix G can reduce the fire-resistance be employeu~ to control and suppress the fire. capabilities of penetration seals. Nevertheless,it is the staff's opinion that, in general, the relative safety (6) He fire must expose the safe-shutdown significance of such deficiencies is low for the components located in the originating fire area following 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 not render it useless; the defense-in-depth concept happen, the fire must either start near the ensures that multiple safety measures are components or it must spread close enough to incorporated; automatic fire detection and the components so that the components are suppression systems are provided in areas that have damaged by direct flame inpingement or safe-shutdown systems and components; trained fire radiative heat transfer. Alternately, the fire's brigades are required to be on duty 24 hours2.777778e-4 days <br />0.00667 hours <br />3.968254e-5 weeks <br />9.132e-6 months <br /> a day at

~

products must adversely affect the all plants; and transient and in situ fuels and fire safe-shutdown components located in the fire hazards that can feed a fire, and ignition sources that area. For example, hot gases from the fire can start a fire, are controlled. herefore, it is would rise to the ceiling and form a hot gas unlikely that a fire significant enough to challenge a layer. Safe-shutdown components (e.g., fire barrier penetration scal will occur. How these cables) located near the ceiling and within the factors affect the various types of penetration seal hot gas layer could be damaged by the deficiencies is discussed in Sections 3.3.1 and 3.3.2, convected heat even if they are located away below.

from the burning area.

3.3.1 Improperly Installed or Degraded (7) The fire must also spread to a penetration seal Seals and Inadequate installed in a structural fire barrier that Documentation separates the fire area of origin from an adjacent fire area with the other train of As discussed in Section 1, the fire endurance tests redundant safe-shutdown components.

nuximize fire severity by subjecting the penetration seal to a fire of rapidly rising temperature in a (8) The uncontrolled fire must burn through the relatively small and confined space. In the event of fire-resistant penetration seal assembly (which an actual fire at a nuclear power plant, the fire in some cases, could take more than 3 hours3.472222e-5 days <br />8.333333e-4 hours <br />4.960317e-6 weeks <br />1.1415e-6 months <br />).

resistance required of a penetration seal depends on f the expected severity of the fire to which it nmy be (9) After the fire burns through the penetration exp sed. With few exceptions, nuclear plant fire seal, it must continue to burn and spread from I ads are not great enough to produce a fire the penetration to the redundant safe-shutdown approaching the severity of a test fire (time and [

components located in the adjacent fire area, temperature). It is expected that the temperature of where it must cause sufficient fire damage to NUREG-1552, Supp. I 8

Safety Significence most actual fires at nuclear power plants would rise involve potentially higher safety significance, slower than the temperature of the standard test fire, because this measure of protection is missing Most plant areas have controls on ignition sources; altogether and the fire may have a direct path to these controls help reduce the occurrences of fires. spread from or,e fire area to another.

Most plant areas are equipped with other passive and active fire protection features, and many are It is important to note that there is no regulatory continuously or regularly occupied by plant requirement that fire-rated seals be installed in all operators, security staff, and other personnel, all of penetrations through fire barriers that form fire area whom contribute to early fire detection and boundaries or that seals have either (1) the same fire-suppression activities. For example, plant fire resistance rating as the structural fire barrier in which detection systems give reasonable assurance that a they are installed or (2) a 3-hour fire resistance fire will be detected in its incipient stage and before rating. In Generic Ixtter (GL) 86-10. "Implemen-there is any significant propagation of flame; or rise tation of Fire Protection Requirements" in temperature. The detection system would send an (April 24,1986), the staff presented guidance for alarm to the continuously manned control room, and satisfying NRC regulatory requirements for fire the control room operators would dispatch the plant protection. In Enclosure I to GL 86-10, the staff fire brigade. He fire brigade would then extinguish interpreted Appendix R requirements.

the fire. Interpretation 4," Fire Area Boundaries," stated,in part, In a plant area that is protected by an automatic fire suppression system, should the fire develop beyond he term " fire area" as used in Appendix R the incipient stage before the fire brigade responds, me;.ns an area sufficiently bounded to the system would actuate and either control or withstand the [ fire] hazards associated with extinguish ti.e fire. Therefore, there is reasonable the area and, as necessary, to protect assurance that a fire will not challenge a fire barrier important equipment within the area from a penetration seal. fire outside the area. In order to meet the regulation, fire area boundaries need not be In addition, in large open spaces, such as exist in completely sealed floor-to-ceiling, wall-to-many nuclear plant fire areas, a fully developed fire wall boundaries. However, all unsealed may occur in one part of the area (e.g., in openings should be identified and considered concentrations of cables), but it is not probable that [in] evaluating the effectiveness of the overall the entire volume (fire area) would be engulfed in barrier. Where fire area boundaries are not flames (flashover) before an automatic fire wall-to-wall, floor-to-ceiling boundaries with suppression system actuated or manual fire aP penetrations sealed to the fire rating suppression activities were employed Unless a fire required of the boundaries, licensees must ,

reaches the fully developed stage, it is not likely to perform an evaluation to assess the adequacy '

present a credible challenge to any nuclear power of fire boundaries in their plants to determine plant penetration seal. Moreover, even in cases in if the boundaries will withstand all [ fire) which the fire barrier penetration seals are degraded hazards associated with the area. l or deficient, they will offer some measure of fire protection. Some of the reported deficiencies could his regulatory position established that certain have reduced the fire-resistance rating of seals under penetration seals need not have the same fire rating test conditions and the fire protection effectiveness of as the barrier in which they are installed and, indet d, in-plant seals (e.g., inadequate seal thickness). that certain fire barrier penetrations may not need to However, other deficiencies (splits, shrinkage, be sealed at all. Licensees evaluate such seals on a inadequate documentation) may have little or no case-by-case basis. He engineering evaluations effect on seal performance. performed to assess the effectiveness of the penetration seals are based on the expected fire.

3.3.2 Unsealed and Breached Penetrations resistive performance of the seal and on the fire hazards and fire protection features in the fire area.

For the cases <liscussed in Section 3.3.1, the installed Nevertheless, on the basis of its experience, the staff penetration seals are degraded or deficient, but will believes that most licensees install 3-hour fire-rated provide some measure of fire protection. Intuitively, Penetration seals in fire area boundaries, conditions involving missing and breached seals 9 NUREG-1552, Supp. I

__ _ _ _ ._m _

Safety Significance It should be noted that with up to 10,000 fire barrier staff considers an open penetration to be more penetration seals per nuclear unit, the instances of significant than a degraded seal, it believes that the unsealed penetrations and breached penetration seals relative safety significance of missing and breached that have been reported are rare. Open penetrations seals, although potentially higher than the other >

are more safety significant than degraded penetration common types of seal deficiencies, is low, seals. However, even in cases of missing or breached seals, most of the considerations discussed in 3.4 Scal-Specific Assessrnent of Section 3.3.1 still apply. That is, the defense-in- . .

depth concept ensures Qat multiple safety measures - Safety Significance are incorporated; automatic fire detection and suppression systems are provided in areas that have For the reasons discussed above, in general, the safe,-shutdown systems and components; trained fire safety significance of deficient fire barrier brigades are required to be on duty 24 hours2.777778e-4 days <br />0.00667 hours <br />3.968254e-5 weeks <br />9.132e-6 months <br /> a day at Penetration seals is low. However, the actual safety all plants; and transient and in situ fuels and fire significance of specific deficiencies in fire banier hazards that can feed a fire and ignition sources that Penetration seals depends on many factors and can start a fire are controlled. To spread through an variables. These include the importance of the plant open penetration, the fire would have to be large and systems and components in the fire area (and uncontrolled. In this case, a lucalized hot spot would adjacent areas); the types, amounts, configurations, occur in the adjacent fire area in the area of the seal. and locations of any combustible materials and fire If there are no combustible materials in the adjacent hazards in the areas; the potential for fire growth in '

fire area in the vicinity of the open penetration (for the areas; the fire protection features installed in the example,if the penetration seal encloses a pipe), areas; the accessibility of the areas to the plant fire smoke and hot gases will move inta the adjacent area, brigade; the type, size, and location of the penetration but the spread of fire into the area would be limited. scal; the nature and extent of the seal deficiencies; Conversely,if there are combustible materials in the and the overall effectiveness of the defense-in-depth vicinity of the failed seal (for example,if the 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 should 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 separates the turbine building from the auxiliary ,

March 22,1975, the Browns Ferry Nuclear Power building. If the seals are properly designed and ,

Plant had the worst fire ever to occur in a commercial installed and the other components of the fire nuclear power plant operating in the United States. Protection program (e.g., fire brigade) are effective, As reported in NUREG-0050, the fire spread along they are likely to withstand the challenge and prevent cable trays from the cable spreading room, through a the fire from spreading from the turbine building into

, cable penetration, and into the reactor building. He the auxiliary building. However,if the seals are i fire burned celer in cable trays for almost 7 hours8.101852e-5 days <br />0.00194 hours <br />1.157407e-5 weeks <br />2.6635e-6 months <br />. deficient, it is conceivable that they could fail under I During that time, portable extinguishers were used the fire exposure and allow the fire to spread into the intermittently to no effect. After almost 7 hours8.101852e-5 days <br />0.00194 hours <br />1.157407e-5 weeks <br />2.6635e-6 months <br />, the auxiliary building. Again, the actual adverse decision 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 significant and challenging nuclear power plant fire and important plant equipment in the vicinity of the could be readily extinguished if appropriate and bumthrough. De significance of such a scenario timely fire fighting efforts ax employed.' Since the could be compounded by the fact that the fire wall in fire at Browns Ferry, licensees have made significant the turbine building could be common to several ,

improvements in fire brigade training and fire auxiliary building fire areas. Herefore,if the fighting capabilities. De staff believes that if timely Penetration seals were to fail, a single fire could and appropriate action is initiated, a fire at an open adversely impact several plant components and penetration will not create any significant problems, systems.

Herefore, on the aforementioned bases, although the

. NUREG-1552, Supp. I 10

Plant-Specific Experience On the other hand, a fire involving a charging pump inspect for the control of ignition sources, fire motor is not likely to present nearly as significant a hazards, and combustible materials; to look for signs challenge to fire barrier penetrations installed in the of incipient fires; to provide prompt notification of pump cubicle walls. In this case, even if the seals are fire hazards and fires; and, in some cases, to take deficient, the fire is not likely to have an adverse appropriate actions to begin fire suppression effect on plant safety systems located outside of the activities. Generally, therefore, by providing pump cubicle. additional fire prevention activities through enhanced capabilities to find fire hazards and, in the case of a fire, through augmented suppression activities before 4 RISKSIGNIFICANCE a penetration seat , adiiity to endure a fire is challenged, fire watches compensate for degraded he calculated core-damage frequency (CDF) from fire barrier penetration seals. The licensees that +

fires, and the contribution of fire risk to a plant's total reported fire barrier penetration seal deficiencies CDF, is a plant-specific determination that is established fire watches in accordance with their dependent on the plant configuration and the technical specifications or license conditions as a methodology and assumptions that are used for the compensatory treasure, analysis. The application of the calculated CDF to assess the fire risk of one plant against the fire risk at another plant is inappropriate.

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

6.1 Vermont Yankee Nuclear Scenarios involving the spread of fire from one plant power Station fire area to another and evolving to core damage are of low frequency. His is a result of several defense-On March 19,1992, during an inspection of fire in-depth measures, such as administrative controls on barrier penetration seals at Vermont Yankee Nuclear combustible materials and " hot" work, automatic fire Power Station, the licensee found a penetration detection, autornatic fire suppression, and containing unapproved material. The next day, intervention by the plant fire brigade. On the basis of another penetration seal was found to be degraded.

its reviews of fire risk assessments completed thus he licensee took compensatory measures and began far, penetration seals have not been relied upon for an investigation into the cause of the degradation.

. the prevention of core damage. It is the staff's Later, while implementing corrective actions in judgment that failure of a plant's barrier penetration December 1992, the licensee found more problems.

seals would not significantly alter the overall 11 performed additional seal inspections and found contribution of fire risk to the plant's total calculated that the seal discrepancies were more widespread CDF.

than was originally believed. On January 15,1993, the licensee issued Licensee Event Report 5 COMPENSATORYMEASURES (LER)93-001. He licensee declared 57 penetration l seals inoperable and established a task force to )

The use of fire watches in instances of degraded or inspect all fire barrier penetration seals. Ultimately, l inoperable fire barriers is an integral part of NRC- the licensee repaired more than 900 (64 percent) of I l approved fire protection programs. In general, these the 1400 fire barrier penetrations installed at approved compensatory measures specify the Vermont Yankee and upgraded alnrast 300 establishment of a continuous " fire watch" or an penetrations (21 percent). He licensee attributed hourly fire watch patrol where automatic detection most of the as-found unacceptable penetrations to i systems protect the affected components. Fire inadequate design or to inadequate installations made l watches are personnel trained by the licensees to by a contractor between 1979 and 1980. (That 1I NUREG-1552, Supp.1 l

L Plant-Specific Experience contractor is no longer in business.) Thelicensee 6.2.2 OIInvestigation attributed the failure to identify these issues to inadequate surveillance procedures. The licensee In September 1988, the NRC Office ofInvestigations completed the repairs to affected barriers and the (OI) in Region IV initiated an investigation to required surveillances in May 1993. In subsequent determine if company officials at Promatec or years (1994-1997), routine fire barrier surveillances WCNGS knowingly and intentionally failed to notify discovered five degraded penetration seals. These the NRC in 1984 and 1985 about the defective seals.

events were described in LERs94-018,94-018-01, In May 1987, Promatec had submitted a 10 CFR Part 95-004,96-026, and 96-026-01. In 1998, the 21 report to the NRC, which stated that some silicone

. license, reported seal problems in LERs98-001, foam fire barrier penetration seals installed by -

98-001-01,98-008,98-008-01,98-014, and Promatec at WCNGS did not meet minimum 98-014-01. These LERs repotted problems with 4 specifications. During replacement of damaged fire-penetration seals. These problems were resolved by resistant boards, WCNGS personnel found voids, the licensee- shrinkage, and lack of fill in approximately 25 percent of the seals.

6.2 Wolf Creek Nuclear

. He 01 investigation revealed that both Promatec and Generating Station Kansas Gas & Electric (KG&E) became aware in 1983 of a similar problem with silicone seals at 6.2.1 Operating Experience Callaway Nuclear Power Plant, also installed by t

Promatec. However, a different method of In December 1984, the 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 i lacked document traceability, ne licensee reinspections at WCNGS KG&E rejected the results completed corrective actions in 1985. Later, in early of the first of these as too limited and indicative of a 1987, B&B Promatec Corporation (Promatec), potential problem similar to the problem encountered I

Houston, Texas, the penetration seal installation at Callaway. The scope 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 voids and shrinkage. The problems had involved rejection rate of these seals from shrinkage and installation methodology, inadequate quality control voids. KG&E accepted the results of this (QC) methods, and rapid, chemically induced, reinspection and concluded that the problem at expansion of the silicone foam material. The WCNGS was minor and not indicative of the licensee issued LER 87-010 on February 6,1987, problem found at Callaway.

This problem affected several other nuclear plants.

Promatec informed the industry of the problems and On the basis of its investigation,01 concluded that

. submitted a Part 21 notification. The NRC issued the problem with the seals at WCNGS was generic,

, IN 88-56 to advise licensees of the problems inherent both in the material and in the cable tie discovered at Wolf Creek. inspection method utilized at the time the seals were

{

installed. OI concluded that the sihcone material In 1987, the licensee established a task force to shrinks and expands depending on temperature develop a corrective action plan. The inspection plan changes and that it is difficult to install seals so as to covered the removal of damming boards and ensure a complete fill, even utilizing the stage inspection of accessible foam penetrations. The damming method ofinstallation. OI also concluded scope of the program included inspections of more that the inspection method used at WCNGS was than 1700 silicone foam penetration seals. As a inaccurate and could not reveal all voids, gaps, or resuit of the inspections, the licensee repaired more missing fillin the seals. 1 than 600 seals during 1987. Since 1987, the licensee has found only minor problems during routine From the time the seals were first installed, KG&E inspections, and the licensee addressed these was aware of the seal inspection method used by promptly. Promatec. This was the acceptable method of j inspection used by all sealing contractors at the time. l Although .KG&E knew about Callaway's problems, 1

NUREG-1552, Supp. I 12

Plant-Specific Experience and was questioned by an American Nuclear Insurers fire endurance tests. The inspectors opened an (ANI) inspector and by the NRC regarding the inspection followup item (IFI) for as-built drawings, adequacy of the inspection method, it took no steps which did not identify important parameters with l to change to a visual inspection of the seals. respect to cable fill and its thermal mass, and the  !

maximum free area of unsupported penetration seal O1 concluded that its investigation did not find installed within the penetration. i evidence that KG&E or Promatec personnel were I aware of specific problems at WCNGS and willfully Overall, the inspectors concluded that test specimens failed to notify the NRC, as required by of the seals adequately represented and supported I 10 CFR 50.55(e). 01 also concluded that there is a qualification of the as-built seal designs that were ]

potential for similar problems at any nuclear plant reviewed. De inspectors also concluded that the i that utilized silicone foam seals and the method of licensee's engineering analysis methods were inspection used at WCNGS, regardless of who adequate.

. installed the seals. 1 The licensee's staff has not identified any significant  ;

, problerr.s at Salem regarding penetration seals. ,

6.3 Salem Nuclear Generating '

Station 6.4 Millstone Nuclear Power Fire brrier penetration seals have been inspected at on least three times at the Salem Nuclear Generating In LERs93-006,93-006-01, and 94-035, Millstone Station. NRC Inspection 93-80 was an Appendix R Nuclear Power Station reported penetration seal inspection in which the licensee's penetration seal discrepancies. These LERs addressed unsealed inspection program was evaluated. He inspection Penetrations found by the licensee. He staff procedure was reviewed and the latest surveillance reviewed LER 93-006 in NRC Inspection Report repon was reviewed. He licensee inspects 10 93-19. He inspector reviewed the licensee's actions percent of the fire barrier penetration seals every 18 months. If one failure is found, then an adoitional in response to the discovery of the missing seals, and 10-percent sample is inspected until no more failures "VI'**d the surveillanc procedure that the licensee uses to m.spect seals. The inspector noted that the are identified. No failures were noted in the surveillance that was reviewed. He inspectors also pr cedure was adequate to enable proper inspection l reviewed the licensee's response to IN 88-56. The f the seals. He inspector noted that Unit I had identified only six other missing seals since 1990 licensee's silicone foam seals were installed without the use of damming boards, making it very easy to through the seal surveillance program. This indicates  ;

that unsealed penetrations do not seem to be a l detect voids or gaps.

programmatic concern at Millstone.

Penetration seals were inspected again as a restart '

issue for Salem Inspection Report 96-10. He 6.5 Maine Yankee Atomic Power licensee had completed a 100-percent inspection and plant evaluation of all fire-rated penetration seals in 1992.

The inspectors reviewed the design analyses of various types of penetrations and verified that the 6.5.1 NRC Inspection licensee's penetration seal details were representativ From June 26-30,1995, NRC Region I staff of the tested seals, and that seals were bounded by ,

e nducted a fire protection inspectson at Maine acceptable fire endurance tests. The inspector ,

Yankee Ammic Power Plant. The m, spection is concluded that the quality and configuration of documented in NRC Inspection Report penetration seals u ere acceptable.

50-309/95-15, which was transmitted to Maine Yankee Atomic Power Company (the licensee for the The NRC recently inspected Salem's corrective Maine Yankee plant) by letter dated actions to satisfy 10 CFR Part 50, Appendix R, ScPtember 20,1995.

Sections Ill.G, and Hl.L (Inspection Report 97-09).

The inspectors compared "as built" penetration seals i The inspector reviewed the fire barrier program to to the fire endurance test configurations to verify that ,

verify the adequacy of penetration seal installation, I as-built configurations were qualified by appropriate qualification, and inspection activities. This review 13 NUREG-1552, Supp. I

1 Plint-Specific Experi:nce l

also assessed the appropriateness of acceptance (3) evaluating the adequacy of existing seal l criteria established for penetration seals to validate configurations; and (4) inspecting all fire barrier '

operability and degradation that could prevent fire penetration seals.

barriers from providing effective separation during a fire. The inspector concluded that the licensee's By letter dated August 28,1996, the licensee procedures for seal inspections, and the training submitted Revision I to LER 96-017. The licensee program for seal inspectors, were good for reported that it had found three additional types of

. maintaining proper seal configuration and for early deficiencies: (1) inadequate thickness of silicone detection of degraded conditions. These actions were foam, (2) temporary seals that were not upgraded to ,

found to provide a defense against the propagation of permanent seals for an indeterminate period, and fire to adjacent plant areas. (3) one seal for which the expected pipe movement exceeded the design rating of the seal.

He inspector reported that Maine Yankee relied on Insulation Consultants & Management Services, 6.5.3 Staff Followup Incorporated (ICMS), to install the original penetration seals. he licensee informed the During a telephone conference on May 14,1997, inspector that it had reviewed its purchase order Office of Nuclear Reactor Regulation (NRR) and information and project files and found that it did not Region I staff obtained detailed information from the apply any in-house quality control review for the licensee regarding the seal problems found and the ICMS fire barrier installation work. The licensee corrective actions. In addition, during the week of could not find the qualification and test reports May 12,1997 NRR staff reviewed and observed the completed by ICMS to support the seal installations, problems found at Maine Yankee and the licensee's including fire and pressure test reports and corrective actions, qualification of seal installers. herefore, the inspector could not verify the qualification of the The penetration seals at Maine Yankee were installed penetration seals installed at Maine Yankee. around 1978. Most of the original seals used silicone foem. Since the original installation, the licensee has The inspector opened an unresolved item regarding visually inspected all the seals at each refueling the acceptability of penetration seal qualification, outage.

testing, and installer qualifications.

During the inspections and walkdowns that were 6.5.2 Licensee Event Reports documented in LER 96-017-01, the licensee found that more than a thousand seals required further After the NRC staff fire protection inspection, the evaluation (including destructive examination); about licensee conducted a scoping study in preparation for a thousand other seals had defects; and a small fire barrier penetration seal walkdowns. By letter number of seals had no defects. He licensee found dated July 29,1996, the licensee rubmitted seals with inadequate thickness (the predominant LER 96-017," Fire Barrier Penetration Seal problem), foreign materials in seals, no damming Discrepancy." The licensee reported that, during the, material, and the wrong seal material installed.

scoping study, it found fire barrier wall penetration Although the licensee's design criteria specified a seals that did not have damming material in the minimum seal thickness of 7 inches, the average seal proper location. On the basis of these findings, the thickness was 5 to 6 inches, and some seals were licensee examined its criteria for penetration seals only 2 to 3 inches thick. Although the licensee once and conducted a technical review of its penetration planned to repair and replace the seals with silicone seal design parameters. De licensee found foam and silicone elastomer, the licensee has since discrepancies between available test reports and certified permanent cessation of power operation and procedural guidance, and the in-plant penetration seal is now proceeding to decommission the facility.

configurations. In response to the discrepancies, the licensee implemented compensatory fire watches and The licensee informed the staff that it believes that developed a corrective action program. He planned the installation deficiencies occurred because the corrective actions were (1) determining why the quality assurance and quality control procedures used discrepancies were not found during previous by the installation contractor during original seal reviews; (2) evaluating the adequacy of procedures, installation were inadequate. He licensee also test reports, acceptance criteria, and field inspections; informed the staff that it believes it took so long to I

NUREG-1552, Supp. I 14 I

l

i l

Review of Licensing Bases discover the deficiencies because its inspection and penetration seal deficiencies will be found, the staff surveillance procedures did not cover all important revised the NRC fire protection core inspection i penetration seal attributes (e.g., the presence of nxxlule to provide specific inspection guidance to damming material was not a critical attribute) and NRC inspectors. i because training was insufficient. The licensee has  !

completed a major rewrite of its procedures. 7 REVIEW OF PLANT- I ne staff issued Information Notice (l'N) 97-70, SPECIFIC LICENSING i

" Potential Problems With Fire Barrier Penetration BASES RELATED TO SECTION III.M OF Seals," on September 19,1997, to tell industry of the problems found at Maine Yankee. As mentioned  !

APPENDIX R TO 10 CFR  !

above, the licensee has since decided to shut the plant PART 50 l down permanently.

1 7.1 Introduction l 6.5.4 Conclusions on Maine Yankee Operating Experience The following supplements information presented in l Section 4 of NUREG-1552. On November 19,1980, l In NUREG-1552, " Fire Barrier Penetratiot. Seals in the U.S. Nuclear Regulatory Commission (NRC) J Nuclear Power Plants" (July 1996), the staff stated Published Appendix R, " Fire Protection Program for I that even though the overall condition of penetration Nuclear Power Facilities Operating Prior to i seal programs in industry is satisfactory, it expects January 1,1979," to Title 10 of the Code of Federal  !

that plant-specific deficiencies may be found during Regulations (10 CFR) Part 50, and a revised Section 1 50.48, " Fire protection," in the Federal Register. I future licensee surveillances and NRC inspections.

Furthermore, the staff noted that licensees understand The revised Section 50.48 and Appendix R became potential fire barrier penetration seal problems; effective on February 17,1981. It is important to l industry consensus fire test standards are available note that Appendix R is not a set of generically l and licensees adhere to them; and fire test results and applicable fire protection requirements and that it  ;

qualified fire-resistant seal materials and designs are applies only to plants that were operating before I available. On these bases, the staff concluded that January 1,1979, licensees have the means to correct problems, and i staff oversight will continue to ensure corrections on Section III of Appendix R contains 15 subsections, a case-by-case basis. He penetration seal problems lettered A through O, which specify requirements for found by the NRC inspector at Maine Yankee and nuclear power plant fire protection features. Rese later reported by the licensee are consistent with the requirements are divided into two categories. The known types of problems, as previously documented first consists of those requirements that were backfit by the staffin NUREG-1552. The reported problems to facilities operating before January 1,1979, j do not indicate new trends. regardless of whether or not the staff had previously i approved alternatives to the requirements of those g,g Conclusions sections. These requirernents are found in Section III.G," Fire protection of safe shutdown

. capability";Section III.J, " Emergency lighting"; and LERs, NRC m.spections, and plant-specific corrective Section III.0, " Oil collection systems for reactor action programs summarized above show tha! coolant pumps." The second category consists of licensees knew and understood the fire-resistive requirements that were backfit on a plant-specific capabilities of the penetration seal materials and basis to the extent needed to resolve the "open" items configurations; potential penetratmn seal testmg, of previous NRC staff fire protection reviews. An design, installation, inspection, and maintenance open item was defined as a fire protection feature problems; and possible remedies and corrective that had not been previously approved by the NRC actions. Dese findings also indicate that the actions staff as satisfying the guidelines of Appendix A to

, taken by the staff in 1988 and 1994 had increased Branch Technical Position (BTP) APCSB 9.5-1, as mdustry awareness of possible penetration seal

, documented in a staff safety evaluation report Problems, leading mdustry to more comprehensive (SER).Section III.M," Fire barrier cable penetration surveillance activities, maintenance practices, and

- corrective actions. To provide added assurance that 15 NUIEG-1552, Supp. I

Conclusions i

seal qualification," of Appendix R was one such 15 units. If the plants used silicone-based fire barrier )

provision. penetration seal materials, which are classified as j

" combustible" when tested in accordance with Section III.M states that penetration seal designs ASTM Standard E-136,5 the staff reviewed how the shall utilize only noncombustible materials4 and shall regulatory requirement of Section III.M of j be qualified by tests that are comparable to tests used Appendix R that penetration seals utilize only

- to rate fire barriers. Section IILM contains the noncombustible materials was addressed by the following acceptance criteria: licensees. The findings of these reviews are documented below. )

(1) Cable fire barrier penetration seal has withstood l the fire endurance test without passage of flame 7.2 Plant-Specific Licensing Bases  !

or ignition of cables on the unexposed side.

7.2.1 Calvert Cliffs Nuclear Power Plant, (2) Temperatures recorded on the unexposed side are analyzed and the maximum temperature is Units 1 and 2 )

sufficiently below the ignition temperature of the cable insulation. By letter dated November 24,1980, the staff i informed Baltimore Gas & Electric Company, the l licensee for the Calvert Cliffs Nuclear Power Plant, (3) The fire barrier penetration seal remains intact Units 1 and 2, that the issue of ventilation and duct and does not allow a projection of water beyond the unexposed surface during the hose stream fire dampers was an open item. De issue of fire test. barrier penetration seals was not an open item.

Herefore,Section III.M of Appendix R does not After it published Appendix R in the Federal apply to the fire barrier penetration seals installed at Register, the staff sent letters to the licensees it Calvert Cliffs.

applied to summarizing the open fire protection items and told each licensee which Appendix R 7.2.2 Duane Arnold Energy Center requirements it had to comply with to resolve the items. Before the staff published NUREG-1552, Silicone-based penetration seal materials are installed Brookhaven National Laboratory (BNL), the staff's in the plant.

technical assistance contractor, reviewed these letters and found that 13 units had open items regarding fire In a letter of Aprn 1,1980, Iowa Light and Power barrier penetrations when Appendix R was Company, the licensee for the Duane Arnold Energy published. ney were: Center, stated that the penetration fire stops were conservatively designed and provided an adequate Calvert Cliffs 1/2 Maine Yankee margin of safety for the plant fire protection design.

Point Beach % Duane Arnold In a letter of November 24,1980, the staff informed Peach Bottom 2/3 Robinson 2 the licensee that the tests described in its letter of FitzPatrick Pilgrim 1 April 1,1980, did "not substantiate the fire resistance Surry 1/2 of the penetration seals installed at the plant." He staff also stated that "[t]o meet the requirements of On the basis of BNL's review, the staff reported in Section III.M of Appendix R to 10 CFR Part 50, the NUREG-1552 that Section Ill.M of Appendix R licensee should provide additional documentation to applied to 13 nuclear power plants. In support of the verify that the seals which were tested and passed review documented here, the staff again reviewed the were representative of those actually installed."

licensing basis for the Appendix R plants and added Monticello and Vermont Yankee to the hst of plants The licensee responded in a letter of February 4, that may be required to comply with Section III.M of 1981, in which it compared the fire barrier Appendix R. He staff then conducted a detailed penetration seal configurations it tested to those review of the fire protection licensing bases for these installed in the plant, anE .laimed that the A technical assessment regarding the combustibility '" Behavior of Materials in a Vertical Tube Furnace of silicone-based seal materials is presented in at 750 *C," a pass / fail combustibility test method Section 5.8 of NUREG-1552. accepted by the NRC.

NUREG-1552, Supp. I 16

Review of Licensing Bases information provided in previous correspondence does now meet Section III.M of Appendix R and this was sufficient to close the open item regarding fire 'Open' item is now considered closed."

barrier penetration seals.

7.2.6 Peach Bottom Atomic Power 7.2.3 James A. FitzPatrick Nuclear Power Station, Units 1 and 2 Plant Silicone-based penetration seal materials are installed Silicone-based penetration seal materials are installed in the plant.

in the plant.

In a letter of November 24,1980, the staff informed In a letter of February 13,1981, the staff transmitted Philadelphia Electric Company, the licensee for to the Power Authority of the State of New York, the Peach Bottom Atomic Power Station, Units 1 and 2, l licensee for James A. FitzPatrick Nuclear Power that the issue of penetration seals represented an I Plant (FitzPatrick), a supplemental SER in which it open item. By letter of November 14,1986, the staff I concluded that the silicone elastomer penetration issued an exemption from the technical requirements l seals installed at FitzPatrick met the criteria of of Section III.M of Appendix R to the extent that j Section III.M of Appendix R and were, therefore, certain penetration seals contain combustible acceptable. He open item regarding fire barrier material. In the safety evaluation supporting the penetration seals at FitzPatrick was closed before the exemption, the staff stated that the penetration " seals effective date of Appendix R. Therefore, which contain combustible materials will provide an Section Ill.M of Appendix R does not apply to equivalent level of protection to that required by FitzPatrick. Section III.M of Appendix R." In the exemption, the staff stated that "the application of the regulation in 7.2.4 Maine Yankee Atomic Power Plant this particular circumstance is not necessary to achieve the underlying purpose of the rule.

Silicone-based penetration seal materials are installed Additionally, compliance with Section III.M in the plant. concerning the subject seals would result in costs that are significantly in excess of those contemplated In Section 6.5 of this report, the staff discusses when the regulation was adopted since it would result Maine Yankee. He plant has been permanently shut in the complete removal and total replacement of all down and is being decommissioned. seals in question."

7.2.5 Monticello Nuclear Generating 7.2.7 Pilgrim Nuclear Power Station, Plant Unit i In a letter of November 24,1980, the staff informed Silicone-based penetration seal materials are installed Northern States Power 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 cable tray penetration area do not have adequate fire transmitted to Boston Edison Company, the licensee stops or adequate penetration seals. An NRC review for Pilgrim Nuclear Power Station, Unit 1, an SER determined that the vertical cable trays that penetrate closing an open item regarding fire barrier the fire barrier are not scaled to provide adequate 3- penetration seals. In that SER, the staff stated:"[t]he hour fire resistance. Herefore,in order to comply licensee's proposed upgrading of penetration seals with Section III.M of Appendix R. the licensee needs will result in seals which meet the requirements of to install penetration seals that have a 3-hour fire- Section III(M) [ sic] of Appendix R to 10 CFR 50 resistance rating. On October 20-24,1986, a team of and, therefore, are acceptable." 3e open item Region III and NRR personnel performed an regarding fire barrier penetration seals at Pilgrim was announced inspection to determine the licensee's closed before the effective date of Appendix R.

implementation of and compliance with the Herefore,Section III.M of Appendix R does not applicable requirements of 10 CFR Part 50, apply to Pilgrim.

Appendix R. In Inspection Report 50-263/86008 (DRS), the inspection team determined, "the licensee 17 NUREG-1552, Supp. I

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

J l Conclusions i

i

7.2.8 Point Beach Nuclear Plant, Units 1 or inadequately sealed penetration openings to ]

i and 2 Provide a 3-hour ASTM E-119 fire rated penetration seal where the fire rating of the barrier penetrated w uld be 3 hours3.472222e-5 days <br />8.333333e-4 hours <br />4.960317e-6 weeks <br />1.1415e-6 months <br />." In a letter of December 18,1980, Silicone-based penetration seal materials are installed the staff transmitted to the licensee a supplemental i in the plant.

l. SER in which it concluded that the penetration seals in a letter of November 24,1980, the staffinformed installed at Surry met the criteria of Appendix A to BTP APCSB 9.5-1 and were, therefore, acceptable.

Wisconsin Electric Power Company, the licensee for Point Beach Nuclear Plant, Units 1 and 2, that the DC Pen item regarding fire barrier penetration seals t

at Surry was closed before the effective date of issue of penetration seals was an open item and that A PPendix R. %erefore,Section III.M of the licensee was required to comply with Appendix R does not apply to Surry.

i Section III.M of Appendix R. In a letter of January 22,1981, the staff transmitted to the licensee I

a supplemental SER, in which it concluded that the 7.2.11 Vermont Yankee Nuclear Power i penetration seals installed at Point Beach met the Station enteria of Appendix A to BTP APCSB 9.5-1 and were, therefore, acceptable. The open item regarding In a letter of January 13,1978, the NRC issued fire barrier penetration seals at Point Beach was Licensing Amendment 43 to Vermont Yankee closed before the effective date of Appendix R. Nuclear Power Station's operating license. In this Herefore,Section III.M of Appendix R does not amendment, the NRC identified item 3.1.8, " Cable apply to Point Beach. penetrations do not have a fire rating and do not provide adequate protection." In a letter of 7.2.9 H.B. Robinson Steam Electric November 24,1980, to Vermont Yankee Nuclear Plant, Unit 2 Power Corporation (VYNPC), the licensee for Vermont Yankee, the staff again noted that Item 3.1.8 was unresolved owing to the lack of supporting Silicone-based penetration seal materials are installed qualification tests. In a letter of December 19,1980, in the plant.

to the NRC, VYNPC stated: "Vennont Yankee In a letter of November 24,1980, to Carolina Power intends t maintain its commitment to provide 3-hour rated fire barrier penetration seals."

and Light Company, the licensee for H.B. Robinson Steam Electric Plant, Unit 2, the staff stated that to In a letter f December 31,1980, Region I followup l meet Section III.M of Appendix R to 10 CFR

' inspecti n 50-271/80-18 of Vermont Yankee fire Part 50, "the licensee should provide cable barrier penetration seals, three inspection items were penetration seals which utilize only noncombustible Pened concerning the onginal " Item 3.1.8, Fire materials and should be qualified by tests that are Barrier Penetrations." He open items were 80-18 comparable to those used to rate fire barriers." In a letter of November 25,1983, the staff issued an 01, an untested configuration; 80-18-02, questions on materials used to construct the penetration seals; and exemption from the technical requirements of 80-18-03, a commitment to replace / upgrade existing Section III.M of Appendix R to 10 CFR Part 50, to I penetration seals.

the extent that the acceptance criteria for penetration seal qualification required that the temperatures In a letter of December 23,1981, a Region I recorded on the unexposed side of the seal be below  ;

Inspector reviewed open item 80-18-02, found the the cable insulation ignition temperature. Neither the licensee actions acceptable, and closed the item. In a exemption nor its supporting safety evaluation ,

letter of April 22,1982, Region I Inspectors reviewed  !

addressed the fact that the penetration seals used Pen items 80-18-01 and 80-18-03, found the combustible materials.

licensee actions acceptable, and closed the open items. Additi nally,in an internal NRC 7.2.10 Surry Power Station, Units 1 and 2 memorandumdated April 16.1982, to Thomas Novak, Assistant Director for Operating Reactors.

In a letter of November 24,1980, to Virginia Electric from William Johnson, Assistant Director of and Power Company, the licensee for Surry Power Materials and Qualifications Engineering, Johnson Station, Units 1 and 2, the staff stated that "[t]o meet stated: "open item 3.1.8 is now considered closed the requirements of Section III.M of Appendix R to

, 10 CFR 50, the licensee should upgrade all unsealed NUREG-1552, Supp. I 18

Staff Recommendations based on VYNPC's commitment to comply with (3) Develop and issue guidance for comparing fire Section III.M of Appendix R." test configurations to as-built configurations.

1 7.3 Summary (4) Make this technical assessment report available l to the general public and industry by placing .t in On the basis of its review ofletters that the staff sent !he NRC Public Document Room and issuing an I

to the licensees of plants that were operating before inf rm ti n n lice publicizing its availability.

January 1,1979, after Appendix R was approved but before it became effective, it appeared that In its final report, the staff also noted that it wasSection III.M of Appendix R applied to 15 nuclear Preparing the new Fire Protection Functional power plants. However, on the basis of the detailed Inspecti n (FPFI) Program that it had described in review summarized above, the staff found that SECY-95-034," Status of the RecommendationsSection III.M of Appendix R applied to Duane Resulting from the Reassessment of the NRC Fire Arnold, H.B. Robinson 2, Maine Yankee, Protection Program"(February 13,1995). The staff Monticello, Peach Bottom 2/3, and Vermont Yankee. stated that it would present guidance for inspecting Of these plants, the staff has granted exemptions for fire barrier penetration seal programs m, the FPFI H.B. Robinson 2 and Peach Bottom 2/3. On the Procedures and gmdelines for use by NRC mspectors basis of its review of docketed information, the staff n an as-needed basis. j could not determine how the penetration seal open items were resolved at Duane Arnold and Maine 8.2 Status l Yankee. Because the licensee has permanently shut down Maine Yankee and is currently 8.2.1 Recommendations 1,2, and 3 decommissioning it, the staff will not pursue this (Pending) issue at Maine Yankee. The other plants discussed above, FitzPatrick, Pilgrim, Point Beach 1/2, and Recommendations 1,2, and 3 involved revising the Surry 1/2, resolved the penetration seal open item NRC fire protection regulation ( Appendix R) and before the effective date of Appendix R. Therefore, review guidance (SRP). In its final report on Section III.M of. Appendix R does not apply to these penetration seals, the staff indicated that plants.

mplementation of the recommendations would be useful to the industry, but did not identify technical 8 RECOMMENDATIONSIN or safety bases that justified an immediate need to THE FINAL STAFF REPORT implement them.

. The NRC staff, under the Regulatory Improvements 8.1 Introduct10n Program, is considering a performance-based, risk-informed fire protection regulation. After the staff In SECY-96-146," Technical Assessment of Fire issued its fm' al report " Technical Assessment of Fire Barrier Penetration Seals in Nuclear Power Plants" Barrier Penetration Seals in Nuclear Power Plants" (July 1,1996), the staffinformed the Commission (June 14,1996), it issued several Commission papers that the Office of Nuclear Reactor Regulation (NRR) regarding fire protection rulemaking. Most recently, had completed the subjxt assessment and forwarded in SECY-98-058," Development of a Risk-Infonned to the Commission a copy of its final report entitled, Performance-Based Regulation for Fire Protection at

" Technical Assessment of Fire Barrier Penetration Nuclear Power Plants," March 26,1998, the staff Seals in Nuclear Power Plants"(June 14,1996). In provided rulemaking options for a performance-its final report, the staff recommended the following: based, risk-informed fire protection regulation; 1 proposed to develop a comprehensive regulatory (1) Revise the NRC fire protection guidance guide for reactor fire protection; and proposed to documents to reflect the current National Fire revise Section H1.M of Appendix R to 10 CFR Part Protection Association (NFPA) position on 50 to resolve the combustible penetration seal issue testing laboratories. (see Section 5.8 of NUREG-1552). j 1

(2) Remove the noncombustibility criterion from in a staff requirements memorandum of June 30, i Appendix R to 10 CFR Part 50 and Standard 1998, the Commission directed the staf f to develop i Review Plan (SRP) Section 9.5.1. the comprehensive regulatory guide and to pursue l 1

i l l 19 NUREG-1552, Supp. I l

1

Conclusions rulemaking to amend Section III.M of Appendix R to March 1975, nuclear power plant licensees have climinate the requirement that penetration seal made significant improvements in their fire materials be noncombustible. Later,in a letter of protection programs. These improvements, July 20,1998, from R.L. Scale, Chairman, ACRS, to especially the adoption of the defense-in-depth Chairman Jackson, the ACRS stated its agreement concept of echelons of fire protection, have reduced with the Commission direction to amend both the probability and the potentially adverse Section III.M of Appendix R. The staff will consequences of nuclear power plant fires. Using implement the Commission's direction. His will documented industry operating experience, the staff satisfy the intent of Recommendations 1,2, and 3. carefully and objectively evaluated issues associated with fire barrier penetration seals. The staff 8.2.2 Recommendation 4 (Complete) considered the potential safety and risk significance of potential penetration seal deficiencies and the use In July 1996, the staff published NUREG-1552, of compensatory measures for any potential

" Fire Barrier Penetration Seals in Nuclear Power degradation in the fire protection effectiveness of Plants. His action completed Recommendation 4. seals.

8.2.3 FPFI Program (Complete) For the reasons discussed in Sections 3 through 5, the staff considers that the relative safety significance of The staff is currently using its FPFI procedures to the subject fire barrier penetration seal concerns is conduct the pilot FPFI program. The NRC's routine low. Even assuming that certain fire barrier fire protection inspection procedures are in the NRC penetration seals are deficient,it does not follow that Inspection Manual, Inspection Procedure 64704, the deficiencies indicate the absence of adequate

" Fire Protection Program." In September 1997, the Protection. He Commission has explained that staff revised these procedures to provide more specific guidance for inspecting the seals and [WJhile it is true that compliance with all establishing their functionality. .NRC regulations provides reasonable assurance of adequate protection of the public health and safety, the converse is not 9 PUBLIC COMMENTS ON correct, that failure to comply with one DRAFT NUREG-1552, reguladon or another is an indication of the absence of adequate protection, at least in a SUPPLEMENT 1 situation where the Commission has reviewed the noncompliance and found that On July 13,1998, the staff noticed in the Federal it does not pose an " undue risk" to the Register (Volume 63, Number 133) that it was Public health and safety.'

accepting public comments on Draft NUREG-1552, Supplement 1. De staff also made the report .

he failure t have fire barrier penetration seals that available on the World Wide Web at the NRC meet the criteria specified by the NRC fire protection website. During the public comment period, the stzff guidance documents does not necessarily indicate received two letters in response to the draft report. In that a piant is unsafe.

a letter dated September 11,1998, the Nuclear Energy Institute (NEI) stated agreement with the . . i On the basis of everythm.g it found and considered,it 1 conclusions of this report. In a letter dated I is the staff's j,udgment that, overall, the issue of

- September 16,1998, the Nuclear Information and Potential fire barrier penetration seal deficiencies Resource Service (NIRS) stated disagreement with does not adversely affect safety. For the reasons the conclusions of the report. Neither of the letters given in this paper, typical penetration seal included new technical or safety information.

deficiencies do not necessarily equate to a lack of herefore, the comments did not result in changes to ,

adequate protection or result m undue nsk to pubh,c this report, nese letters are part of the public record health and safety.

and are available at any NRC Public Document Room.

On the basis of the reassessment documented here, 10 CONCLUSIONS

' Ohio Citizens for Responsible Energy, DPRM 88-4, Since the fire at Browns Ferry Nuc! car Plant in 28 NRC 411 (1988).

NUREG-1552, Supp. I 20

Conclusions the staff concluded that the actions it took in 1988 origin, and 1994 to alert licensees to potential penetration l seal problems increased industry awareness of such During the 454th meeting of the Advisory Conunittee problems and resulted in more thorough on Reactor Safeguards (ACRS), July 8-10,1998, the i surveillances, maintenance, and corrective actions, staff presented the results of the assessment documented in this supplement to NUREG-i S52 to l Re staff also concluded that the general condition of the ACRS. He ACRS provided its views regarding penetration seal programs in industry is satisfactory. the efforts of the NRC staff and the nuclear industry to resolve issues related to fire barrier penetration The staff will continue its reviews and inspections of seals in a letter of July 20,1998, from R.L Scale, penetration seal programs. He staff expects that Chairman, ACRS, to Chairman Jackson. He ACRS plant-specific deficiencies may occasionally be found noted that it is clear that, overall, the NRC staff and during licensee surveillances and NRC reviews and the licensees have the issues of fire barrier inspections. However, potential penetration seal penetration seals well in hand and that the efforts of problems are understood; industry consensus fire test the staff and the licensees have been successful in  ;

standards are available and are followed; and fire test addressing the problems of the past. I results and qualified fire-resistant seat materials and designs are available. Herefore, licensees have the In sum, it is the staff's opinion that continued licensee means to correct problems, and continued staff attention to existing penetration seal programs and  ;

oversight will continue to ensure corrections on a continued NRC inspections are adequate (1) to case-by-case basis. In addition, the fire protection ensure that penetration seal problems are discovered defense-in-depth concept provides reasonable and resolved and (2) to maintain public health and assurance that deficiencies will not present an undue safety. To provide added assurance of this, during risk to public health and safety before they are found the assessment documented in this report, the staff and corrected. issued Information Notice 97-70, " Potential Problems With Fire Barrier Penetration Seals,"

he results of this assessment, which used September 19,1997, and revised the NRC fire information that the staff had not considered in the protection core inspection module to provide more evaluation documented in NUREG-1552, " Fire specific inspection guidance to NRC inspectors Barrier Penetration Seals in Nuclear Power Plants," regarding fire barriers and fire barrier penetration have reinforced the staff's earlier conclusion that seals. He staff will continue to assess new RTV silicone foam penetration seals like other types information regarding penetration seals for new of penetration seals installed in US nuclear plants, insights and appropriate opportunities for additional provide reasonable assurance that a fire in a specific actions by the staff or the industry, fire area or zone will be confined to the area of l

21 NUREG-1552, Supp. 1 l

\

l 1

Appendix D l

Acronyms and Abbreviations j BNL- Brookhaven National Laboratory CDF~ core-damage frequency ,

CDR- construction deficiency report I DRS division of reactor safety ICMS Insulation Consultants & Management Services, Incorpcated IFI inspection followup item KG&E Kansas Gas & Electric -  :

01-' Office ofInvestigations (NRC)

ORNL Oak Ridge National Laboratory .

PVC polyvinylchloride RTV rem temperature vulcanizing SER safety evaluation report SRM staff requirements memorandum URI unresolved issue VYNPC Vermont Yankee Nuclear Power Corporation WCNGS Wolf Creek Nuclear Generating Station b

D-1 NUREG-1552, Supp. I

Appendix F Licensee Event Reports Submitted by Year (1987 Through September 1998)

&%D$ @muussMMY es==A-stmass; ci! % iMm/d W " 9 1987 -12 16 3 1988 9 12 4 1989 12 14 9 1990 8 11 S 1991 7 8 10 1992 3 8 8 1993 7 8 6 1994 6 6 5 1995 4 4 3 1996 5 5 1 1997 4 3 3 1998 4 5 3 TOTAL 46 100 62 F-1 NUREG-1552, Supp. I

I Appendix G

Summary of Reported Problems .

l (1987 Through September 1998) e

. ^ ..z '

- y Reported Problems -

Naade of Occurrences

. 3- ~

37

ggL : 'g, ' 490'

. 91 92' '93 94  : 95 96 97' 98- Suhtotal ' Total Penetrations unsealed 10 6 6 4 1 3 4 1 1 - 1 1 38 Seal breached and not repaired 4 1 1 2 -

2 - -

1 - - -

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

2 - - - -

9

- Total - Seal Not Installed or Breached 15 8 10 7 1 6 4 3 2 - 1 1 - -- 58 Voids, gaps, splits, shrinkage. ce!! structure 1 4 3 4 2 2 - 2 - - -

1 19 h inadequate seal thickness 1 2 1 - -

3 2 2 -

1 -

2 14 Seal not properly installed - -

1 I 2 2 2 2 -

1 -

2 13 Incorrect seal material installed 1 2 1 -

1 - -

1 - -

1 -

7 Temporary seal not replaced 1 - 1 - -

1 1 - - 1 - - 5 Inadequate seal repair -

1 - -

1 1 - -

1 - -

1 5 , , .

Total- Seal Not Properly Installed 4 9 7 5 6 9 5 7 1 3 1 6 -63 3

Total-Inndequate Documentation 1 5 2 3 1 -

1 1 1 3 1 - 19 19 '

h Seal degraded or damaged 2 2 1 -

1 3 - -

1 I - - 11

c Missing or damaged damming boards 6 h 1 - -

1 1 1 - -

1 -

1 -

Total- Seal Degraded or Damated ~

3 3 2 - 1 4 -

1 I 2 - -

' 17 '

[

?

Totals 23 25 21 15 9 19 10 12 5 8 3 7 157

1 Appendix H Summary of Licensee Event Reports (1987 Through September 1998)

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

f0@VfgjdhD4(hk@l%j@@yjgM n 1Old$y ggge %Q$ g l @j ,

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

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

87-011-01 8802030335 Updated 87-011-00. 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 1/2 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 1/2 87-007-00 8706150188 1 unsealed penetration.

Susquehanna1 87-011-00 8705050296 1 unsealed penetration.

TMI1 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 scaledt i

H-1 NUREG-1552, Supp. I l

Surnmary of Licensee Event Reports

[d%Ol{NN)MAMk$$$@fdjihhihhMsih!M$Nh $2NkdhNihMYkd PLANT LER NO, ACCESSION NO. REPORT

. Wolf Creek 87-001-00 8702100286 I seal 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).

87-010-02 880405036i Finalupdate of 87-010-00. Performed sample inspection program by removing ,

damming boards from 40 seals; 13 rejected for insufficient foam thickness,9 rejected fog voids and shrinkage. Performed 100%

inspection (1700 seals). Repaired and reworked more than 600 seals.

fbhkkhkh$$%h h$$Yhh $ hilhi?$ $ $$?*> Whhhh&EUhh$$ bkNb Ginna 1 88-009-00 8811090368 Several degraded seals and seals with incorrect seal material found.

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

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

Procedures revised.88-018 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 improved.

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

I

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

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

! i NUREG-1552, Supp. I H-2 l

I

Summary of Licensee Ev:nt Reports hga1:M8f g g ~ g yh;$ h"f9) g j h sjpg yij g gji $ $ gg Q h Q h PLANT ' LER NO. ACCESSION NO. REPORT

. North Anna 1/2 88 4 07-00 8802290350 Eight fire barrier penetration seal breaches were identified. These breaches were repaired.

Oconee 1/2/3 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 88 409-00 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, breached seals, and incompletely sealed penetrations found.

Salem 1/2 88-013-00 8809140180- 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 8810040008 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% sealInspection. Found unsealed penetrations, missing damming boards, and silicone foam seals 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 88-03040. Installation procedures changed.

H-3 NUREG-1552, Supp. I

Summary of Licensee Ev:nt Reports

$hhhh b hY $ YN PLANT LER NO. ACCESSION NO. REPORT Waterford3 88-030-03 9109060034 Updated 88-03040. 228 seals to (continued) be reworked.

WNP2 88-008-00 8805030155 11 inoperable seals due to unapproved configuration, inadequate seal thickness, seals improperly repaired. Updated seal database.100% documentation review and seal'- ;:-1-:=.

88-008-01 9302220125 Updated 88-008-00.

kh hh ANO1 89-003-00 8903280098 2 penetrations scaled with unqualified material.

Big Rock Point 89 4 06-00 8908240314 Licensee initiated penetration seal verification programin response to IN 88-04 und IN 88 56. I seal breached and not repaired, I seal inadequately installed.

89-006-01 9004130265 3 inadequate seals 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 4 0 8902230041 3 conduits missing internal seals.

Dresden 2 8943000 8911280062 1 unsealed penetration. Procedures improved.

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

E9414-01 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 4 01-01 9101140199 Several unsealed penetrations 7

found during seal upgrade program.

1. NUREG-1552, Supp.1 H-4 1

j I

Summary of Licensee Event Reports l;;;[,' f' i h ? f NN{Af f f ft 5

h05l PLANT LER NO. ACCESSION NO. REPORT Monticello 89-001-00 8902080493 6 unsealed penetration found.100%

inspection initiated.

89-013-00 8908070189 Several unsealed penetrations found.

89-013-01 9001100234 Updated 89-013-00. Inspection completed.

No additional deficiencies found.

North Anna 1/2 8940340 8902140025 A void was discovered in one fire barrier penetration seal. A fire watch was put into place, and the void was then repaired.

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

River Bend Station 89-005-00 8903240060 Void found in i low-density silicone elastomer seal. Sample of similar seals inspected.

89-010-00 8904260064 1 unsealed penetration and 4 conduits 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. Deficiencies included:

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

l 89-010-05 9409140061 Updated 89-010-00. 1 i

Seabrook 89-011-00 8910170274 3 unsealed pipe penetrations. I l

89-011-01 8912270219 Updated 89-011-00. Initiated 100% seal laspection, developed comprehensive seal l

, program, clarified surveillance l requirements.

l H-5 NUREG-1552, Supp. 1

Surivnary of Licensee Event Reports

?' "

1989 (continued) > ' 'i J @ -

PLANT LER NO. ACCESSION NO. REPORT Susquehanna 89-019-00 8907060047 Damaged seals determined to be inoperable.

Consistent inspection and acceptance criteria developed.

'1990' ' '

-6 ANO1 90-0N-00 9007090045 1 unqualified penetration seal.

90-004-01 9105160074 Small voids around grout joint.

90-004-02 92N300230 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 90-0~22-00. Found 92 more potentially inoperable seals.

90-022-02 9102120021 Updated 90-022-00. Found more potentially inoperable seals and resolved others. Final count of potential inoperable seals due to lack of documentation was 441 out of 3500.

'Ihe licensee performed evaluations, repaired, and replaced seals. Upgraded procedural controls and drawings.

II.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.

90-010-00 9002220099 1 unsealed penetration.

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

Monticello 90-009-00 9008280179 Seal breached and not resealed.

H-6

.. . .- . - . . . . . . . - . . - . . ~ . - . . . .- . . - - - .- - . .

Summary of Licensee Ev nt Rrports k%d [C'[.[DM.((hhN-[MM[hh$h[j@[kg$MkQh PLANT LER NO, ACCESSION NO. REPORT Palo Verde 1/2/3 90 009-00 9010310125 Performed 100% '- ; :"+= of Unit 2, found about 256 questionable seal attributes out of 2000 examined. Deficiencies included unsealed penetrations, seal shrinkage, improperly installed seals, and j gaps in damming materials.

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

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

Trojan 90-022-00 -9007230142 In response to IN 88-56, found silicone foam seals with splits.

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

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

90 419-01 9103040377 Updated 90019-00. Found 1 l additional unsealed penetration.

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

r 2; ,,n .

,[by f T'

{' . -' .

, - , . ~ , l~

k 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.

l 9140141 9103260311 8 more seals found with voids.

l FitxPatrick 91-024-00 9112170535 7 penetrations scaled with incorrect material.

9l-024-01 9403230046 Performed 100%

• E"-- Deviations from design were foundin 39% of 7200 seals inspected. 15% required cosmetic repairs. Problems included: inadequate seal i thickness, installation, or seal material,

.i unsealed penetrations, voids, holes, edge i curl, and separation of foam. All seals were mstored to design condition or evaluated.

, H-7 NUREG-1552, Supp. 1 i..

l-

. Summary of IJc:nsee Ecnt Reports bbk bbf hbN bb bkbh MISSMb bNNbN PLANT LER NO. ACCESSION NO. REPORT

' 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 9l-013-01 9108050172 Updated 91-013-00.

91-016-00 9108190108 9 mechanical seals inoperable due to pipe movement.

91-016-01 9202140203 Schedule update, hhbbhbbhk hh hb bh S h h h kb '

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

Program improvements made to minin'ize 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 924)07-00. Improved inspection ,

schedule.

Haddam Neck 92-008-00 9203270186 1 seal inoperable. Silicone foam had been removed and replaced with ceramic fiber.

Trojan 92-006-00 9203090105 2 seals mi sing damming boards and 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 1 seal not repaired and I breached seal not resealed. Fire barrier inspection procedures wcre upgraded.

92-026-06 9209300187 During 18-month surveillance found grout

• missing from I seal. Inspectors retrained.

H-8

+,

Summary of Licensee Event Rrports hihb$h5hh&?N$$$$$00 ?$&& $l' '

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PLANT LER NO. ACCESSION NO. REPORT l

Trojan 92-02M)1 9211030238 1" diameter hole found through a I (continued) silicone foam seal. ,

l 92-026-02 9211160031 1 seal with inadequate grout thickness and 1 l 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 1 seal with inadequate  !

thickness of grout. Personnel retrained.  ;

92-026-05 9310250073 Updated 92-026-00. Degraded penetration seals resulted from personnel errors and inadequate procedural controls. 4 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 penetrating pipe. Two grout seals were degraded and I of these had inadequate grout thickness.

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Brunswick 93-006-00 9304060055 During 100% inspectic.n, 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 4

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 1 unsealed penetration.

93-002-00 9303180036 2 grout seals had inadequate thickness.

H-9 NUREG-1552, Supp. I

Summary of Licensee Event Reports i

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I PLANT LER NO. ACCESSION NO. REPORT Vermont Yankee 93-001-00 9301220246 In 1992, all seals containing insulated lines were declared indeterminate. Inspection revealed 1 penetration with inadequate ser.i thickness and 3 others that did not conform to design details. Licensee notified iw;ustry through Nuclear Network.

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

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

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s :j 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 fire rating due to lack of damming boards. All seals declared indeterminate. Program to qualify and repair seals.

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. 'Ihe conduits were part of a new installation. They were sealed and inspected.

Millstone 2 94-035-00 9412060226 Breached / missing internal conduit seal.

Seals installed.

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

94-018-01 9506140431 Updated 94-0184)0. ,

WNP2 94-002-00 9403230142 Due to an employee concern, licensee found originalinstallation of seals, including written procedures, design configuration, l' and analysis less than adequate.

Deficiencies included: inadequate thickness, PVC sleeves and seals that exceeded design specifications. Seals declared inoperable.

Corrective actions included walkdowns, engineering evaluations, and establishing supporting fire test documentation.

H-10

_ _ _ . _ _ _ _ ... _ . _ . - _ _ _ . .._.-_.-m __ __ _ - _ . _ _

Summary of Licensee Event Rrports 1

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I PLANT LER NO, ACCESSION NO, REPORT WNP2 . 94-002-01 9407130092 Updated 94-002-01.

(continued) k&$$Y'hi$$$4Aikh$h?NWh & & & &$$@h Calvert Cliffs 1 - 95-004-00 9509210118 3/4" gap (breach) found in a seal. Seal I

repaired, seal surveillance procedure )

, upgraded.

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Haddam Neck 95-001-00 9502230065 1 degraded grout sealand I unsealed i i penetration found. 18-month surveillance )

revealed 4 inoperable seals and 3 unsealed l l

penetrations.100% field walkdown as corrective action.

i 1

! 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. Staff I inspected this issue January 1996.

Vermont Yankee 95-004-00 9505030454 Improperly repaired seal declared inoperable. Seal was repaired.

' D.C. Cook 2 96-004-00 9604180325 Seal found degraded / damaged when a 100% sealinspection was completed.

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

96-011-01 9706040331 Reported qualification of epoxy grout seals by test.

Maine Yankee 96-017-00 9608060017 Fire barrier penetration inspection revealed

, seals missing damming boards, inadequate seal thickness, and temporary seals. No fire )

tests to support some configurations. 1 Attributed to weaknesses in original installation QC, and surveillance procedures. i l l

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

Palisades 96-009-00 9608200212 Fire barrier evaluations not documented for two seals. Penetration seal program weaknesses noted. Commitment made to develop a design-basis document for fire barricts.

H-11 NUREG-1552, Supp. 1

Summary of Licensee Event Reports hMNdSNNkS$$$hd$k5$$$fk$$ N[i M h NkkihdhNkNNMk MMk$dMM PLANT LER NO, ACCESSION NO, REPORT Vermont Yankee 96-026-00 9611130511 Two seals improperly installed during originalinstalk tion.96-026 01 9703280401 Updated 96-02(-00.

kNh;kSNNNhfh[dd$NhishldO $ @ N M I M $$$ N D M @ $ 9 NiE M kNS5fNS N M.N!$MIM Fermi 97-014-01 9804140118 Penetration seals were found missing from the auxiliary building wall and parallel turbine building wall. Ecse walls were rated fire barriers.16 penetrations were not scaled at the auxiliary building wall, and 4 were unsealed at the turbine building wall.

He unsealed penetrations were scaled to comply with Appendix R.

St. Lucie 97-004-00 9707150008 Two-sided cable tray firestop was discovered to be missing ceramic fiber insulation between cables. All cable tray fire stops were declared inoperable, and will be upgraded accordingly.

97-008-00. 9709040179 15 penetration seals were declared inoperable as they could not be bounded by supporting fire tests. The seal manufacturer (Promatec)did not supply proper qualification docunentation. Seals will be re-worked to meet applicable configuration drawings.

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Clinton 98-021-00 9808250144 Cracks were discovered in a penetration seal 1

during a "NUREG 1552" walkdown of l penetration seals. Some cracks went completely through the seal. He licensee is inspecting other seals, repairing any that l

need repair and revising procedures.

! Licensee issued 10 CFR Part 21 notification concerning the seal material.

1 11-1 2

Summary of Licensee Event Reports h

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EANT LER NO. ACCESSION NO. REPORT PrairieIsland 98-003-00 9806300550 Penetrations were discovered that were not sealed. The openings were to be evaluated and then scaled according to plant procedures.

Vermont Yankee 98-001-00 9803020316 Following work potentially affecting a penetration seal, the seal was inspected and found not to conform to the tested configuration for a 3-hour seal. He grout seal was inadequately installed during the construction of the plant and was to be repaired. Other grout block-out seals were to be inspected.98-001 41 9805210006 Updated 98-001-00.

98-008-00 9805060322 Penetration seal was found to have 3" of seal depth where 6" was required for a 3-hour rating (silicone elastomer). Root cause was determined to be inadequate QA/QC on original installation.

98-008-01 9808240312 Updated 98-008-00.

98-014-00 ')806250116 VY discovered 2 non-conforming seals.

One seal was inadequately repaired with 7" of silicone foam rather than the required 12" for a 3-hour rating. He other seal was improperly installed with 7" of foam rather than the required 12" He seals were repaired.

98-014-01 OGD8180028 Updated 98-014-00.

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l E13 NUREG-1552, Supp. I v

Appendix I NRC Inspections (March 1988 Through August 1998)

(Appendix R plants (plants operating prior to January 1,1979) are shown in beid font.)

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Beaver Valley 1 93-12 07/02/93 Narmw Minor Licensee could not verify that eight internal conduit seals were installed. A fire watch was Beaver Valley 2 93-13 posted until the seals were installed per procedures.

Browns Ferry 1/2/3 89-28 09/15/89 Narrow None During a fire protection inspection, inspectors opened follomvp item 89-28-03 to track completion of penetration seals for electrical raceways and rnechanical fire barrier penetrations. Inspectors found the licensee's penetration seal program to be acceptable.

90-1I 05/11/90 Narrow None inspectors closed followup item 89-28-03 regarding installation of penetration seals.

92-11 05/01/92 Narrow None inspectors reviewed procedures for maintenance of fire bamer penetrations. Inspection results for fire rated bamers were also reviewed. No discrepancies were noted.

95-60 12/12/95 Bmad None Inspector reviewed typical mechanical, electrical conduit, and cable tray penetration seal installation procedures, drawings, details, quality contml (QC) records, quality assurance (QA) records, engineering evaluations, and qualification test documentation. Inspector did not find any discrepancies.

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98-01 03/24/98 Bmad None Inspectors reviewed the licensce's penetration seal program and determined that it was adequate. licensee had evaluated numerous seals to demonstrate that they were adequate for their given applications. Licensee was performing 100% seal inspection every 18 months. This was considered a strength in the fire protection program.

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

93-08 03/25/93 Narrow None During a fire protection la=~~_ inspectors reviewed the licensce's fire barrier

, reinspection program and found it to be adequate.

'2l c: 93-38 09/10/93 Narmw None Inspectors closed IER 92-12-01 which concemed madequate fire barrier wall gap

@ material. As part of the close-out actions, the licensee conducted a detailed review and O

inspecuon of fire bamers and penetranon seals during a Unit I outage.

Z p 97-07 06/20/97 Narrow Nonc laspectors noted that penetration seals were acceptable during a general plant walkdown.

$ 97-13 01/23/98 Broad Minor Inspectors reviewed a sample of silicone foam fire barrier peneration seals including seal 3 g design and testing. Inspectors opened IF197-13-04 to track missing penetraten seal l testing documentation.

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'92@" ^ h iE a f Byron 1/2 92-007 04/13/92 Narrow None Inspector observed fire penetration seals while conducting a plant walkdown and did not E g observe any problems.

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p Callaway 94-012 12/06/94 Narrow None inspectors noted that barrier seals in the plant were in generally good condition. g 5-Calvert Cliffs 1/2 94-15 05/06/94 Narrow None Inspectors noted that the licensee has scheduled a review of all plant penetrations to venty

~

the adequacy of the installations. Inspectors concluded that there were no safety-significant issues associated with the penetration seals.

93-99 07/10/95 Bmad None SAlf report concluded that licensee lacked a formal engineering evaluation for qualification of certain fire barrier penetration seat materials.

95-08 10/16/95 Bmad Minor Cork expansion joints found to be inadequate fire barriers; polysulfide caulk found to be inadequate sealant for a fire-rated barrier. 'Ihese de iciencies resulted in a Severity level IV violation.

l 96-201 05/06/96 Broad None The staffinspected the fire barries penetration seal program and concluded that the licensee had an acceptable pmgram. Ongoing licensee efforts to improve the penetration seal program were seen as positive.

E Catawba 1/2 91-22 11/01/91 Narrow None During a fire pmtection inspection, inspectors did not identify any discrepancies in fire barrier penetration seal installations while on a plant walkdown.

97-07 05/23/97 Broad None Inspectors reviewed licensee's evaluations and corrective actions related to IN 94-28,

" Potential Problems with Fire Barrier Penetration Seals."

98-07 07/27/98 Broad Minor inspectors reviewed licensee's corrective actions for penetration seals that were found with gaps and lack of proper scalant material. Inspectors issued a non-cited violation for the noncompliance.

Comanche Peak l/2 96 10 09/24/96 Narmw None Inspectors observed installation of a penetration seal and no discrepancies were noted.

96-12 11/27/96 Bmad None Inspector inspected silicone foam seals and verified that they were installed in the proper configuration and had adequate documentation to support a 3-hour fire rating.

Cooper 95-17 02/05/96 Narrow None . Inspectors closed 1 ER 94-008 regarding inoperable penetration seals.

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

97-18 01/06/98 Narrow Minor Inspectors m=4=+a_i an Appendix R inspection. Inspectors closed restart issues on penetration seals. Inspectors opened IFl 97-18-01 to track lack of documentation supporting the seal installations.

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Davis-Besse N/A II/23/94 Broad None NRR staff 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. He staff did not find information that suggested problems with generic implications.

Diablo Canyon 1/2 94-01 03/15/94 Broad Minor In 1994, the licensee found that certain fire barrier penetration seals may not lave met the required 3-hour fire rating because damming boards were not installed on both sides of silicone foam seals. A walkdown of additional seals revealed about 100 representative silicone foam seals with missing damming boards. De licensee has established a corrective action prograrn Re staff followed up on the licensee's activities during inspections in February 1994 and March 1995. Inspectors concluded that the licensee had taken appropriate corrective actions. He staffis continuing to follow the licensee's actions.

94-07 04 S 4 Broad None LER 94-01, Inadequate Fire Barrier Penetration Seals Due to Imk of Damming Boards,"

was closed by inspectors.

{ 94-18 08/15/94 Bread Minor During an inspection of fire barrier penetration seals, inspectors noticed a breached seal, ne breach in the seal was the result of ongoing work and the licensee had appropriate compensatory measures in place for the breached seal.

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

96-13 08/l8/96 Broad None inspectors closed LER 94-001 concerning inadequ te fire barrier penetration seals due to lack of damming boards. Licensee undertook a 100% inspection of required seals to document all installed configurations. Inspectors concluded that the licensee's program would correct the seal deficiencies.

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

@ seals.

O y Duane Arnold 93-012 10/93 Narrow Minor Inspectors described problems licensee was experiencing regarding fire barrier penetration j g seals. A major problem was noted in this area in an LER in 1992. He licensee was in the n y process of a 100% inspion of seals to identify problems. y 93-16 10/01/93 Narrow Significant Violation was issued to the licensee based on the lack of action taken regarding degraded barriers between control room and cable spreading room.

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$ ffyll z Farley 1/2 88-27 11/03/88 Narmw Minor Inspectors found several unseald penetrations during a plant walkdown. These discrepancies were quickly dispositioned and repairix1.

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s 9 94-30 01/06/95 Narrow None Inspectors reviewed licensee actions regarding notificanon frcm a foam seat vendor that j G self-extinguish times for a certain lot of R1V foam were out of specification. The licensee Q

$ found one penetranon seal that was formed of the suspect foam. At the time of the @

h inspection, the licensee had scheduled to replace the penetration seal. **

5 l 'P 95-20 01/96 Narmw None lhe licensee discovered conduit penetrations through a fire barrier without an intemal 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 scaled. All conduit inspections and repairs had been completed and documented.

96-13 12/23/96 Narmw None Inspectors concluded that licensee's evaluation ofIN 94-28," Potential Problems With Fire Barrier Penetration Seals," was appropriate and required cornctive actions were completed.

97-12 09/26/97 Narmw Minor inspectors reviewed silicone foam penetration seals. Seal documentation did not contain important design parameters. GL 86-10 evaluations were not available for identified deviations. IFI 97-124)I was opened to track these discrepancies.

Fermi 2 94-012 11/23/94 Narmw 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 indicative of a proper installations. In addition, the licensee had not found any indications of improper installation upon removal and inspection of several penetration seals.

FitzPatrick 93-12 07/15/93 Broad None Inspectors reviewed licensee special report 93-003 regardmg nonfunctional fire barrier penetration seal. Inspectors concluded that appmpriate action was taken to address the event.

93-14 08/24/93 Broad Minor A seal was opened as part of a plant modification and was not properly restored. The seal was inoperable for more than 7 days before it was repaired and returned to operability.

Inspectors issued a non-cited violation due to the licensees prompt actions.

93-26 01/04/94 Narrow None As part of a fire protection inspection, penetration seals were inspected.

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

Grand Gulf 1 90-10 06/04/90 Narrow Minor Inspectors reviewed an annual fire protection audit, which stated that a number of fire barrier penetrations that require repair or rework were identified during a walkdown of Unit I rated penetrations.

Mb)hh h h [k h b hNN hib M $); Y NShkk Haddama Neck 93 07/26/93 Narrow None Inspectors closed out LER 93-003. Tire Barriers Inoperable Due to Hre Seal Deficiencies."

95-09 06/IM5 Broad None Inspector reviewed the fire barner and penetration seal program to verify the adequacy of seal installations, quahfication, and surveillance activities. Inspector found that the 3

licensee conducted a 100 % visual inspection as part ofits seal upgrade program in 1988.

licensee found 20 degraded or inoperable seals since the upgrade program. Inspector I canchided that the licensee took prompt and appropriate corrective actions. On the basis of the inspection, inspector concluded that no safety concerns exist at the facility regarding fire barriers.

Hatch 1/2 88-21 08/23/88 Narrow None Inspectors reviewed the licensee's actions taken in response to IN 88-04," Inadequate Qualification and Documentation of Fire Barrier Penetration Seals ' Inspectors concluded that the licensee had planned to implement an adequate action plan, and that the -

implementation would be the subject of a future inspection p 91-30 12/19/9' , Narrow None Inspectors noted that penetration seals were acceptable during a general plant walkdown.

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92-09 04/20t92 Narmw None Inspectors noted that penetration seals mae acceptabic during a general plant walkdown.

93-22 11/2/93 Narmw None Inspectors noted that penetration seals were acceptable during a general plant walkdown. ,

97-01 03/24/97 Narrow None Inspectors concluded that licensee's evaluation ofIN 94-28. " Potential Problems With Fire Barrier Penetration Seals," was appropriate and required corrective actions were completed.  :

i 97-03 6/17/97 Broad None Inspectors reviewed procedures, drawings, and other documents related to fire-rated l scaled penetrations and conducted walkdowns of selected sealed penetrations. Inspectors concluded that the licensee's program for determining the operability of scaled '

penetrations was adequate. No deficiencies were identified wi.h the penetrations inspected.

Z C 98-01 04/21/98 Broad Minor Inspectors reviewed several fire barrier penetration seals, including supporting h documentation. A visual inspection did not reveal any discrepancies. Inspectors opened 7

9 IF198-01-05 to track issues related to fire test documentation that was unavailable at the :e  !

g time of the inspection.

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N 3 v3 Indian Point 2 93-18 09/13/93 Emad None Inspectors reviewed the licensee's fire banier penetration seal installation and surveillance 8 program and the licensee's actions in response to IN 88-04. No discrepancies were found. ]e. ,

? The licensee does not use silicone foam-type penetration seals. Grout seals are utilized. 8 l

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-Q h Indian Point 3 93-24 12/1.W93 Bcoad Minor Inspectors opened URI 93-24-03, which concerned operability determinations of degraded h and potentially nonconforming fire baniers and fire barrier penetration seals and the O

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methodology that the licensee used to determine self-ignition temperatures of cables [

installed in penetrations in the plant. The latter issue has yet to be resolved.

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P 93-80 06/21S 3 Narrow Minor Inspectors identified weaknesses in programs dealing with fire barrier penetration seals. k'a

$ Specifically licensee commitments to revise technical specifications to add fire barrier 3

penetrations needed to meet Section III.G of Appendix R.

95-10 06/26/95 Narrow Minor Inspectors questioned the methodology used by the licensee to determine the self-ignition temperature of cables that pass through penetration seats. Ilowever, inspectors had found the licensee's penetration seal analyses and supporting documentation to be generally sufficient. 'Ihe NRC is currently tracking corrective actions at IP3.

95-81 05/1185 Narrow Minor Inspectors reviewed fire barrier penetration seal qualification tests and concluded that ,

insufficient evidence was available to support the cable ignition temperatures of cables i installed at IP3. (Similar to preceding summary.)

Kewaunce 96-004 06/05/96 Broad Minor Inspector cited the licensee for a lack of corrective action in restoring a degraded fire barrier penetration seal that was identified as impaired, but not dispositioned or repaired.

There were no compensatory measures taken for this degraded fire bamer. The licensee was issued a level IV violation.

Y

• 07/0386 Inspectors noted that bamer seals in the plant were in generally good condition.

LaSalle 96-G8 Narrow Broad Maine Yankee 95-15 09/20/95 Broad None Inspector reviewed the fire barrier program to verify the adequacy of penetration seal installations, qualification, and inspection activities. Inspector concluded that the licenscet procedures for seal inspections and training provided to seal inspectors were good for maintaining proper seal configuration and early detection of degraded  !

conditions.

96-08 09/16/96 Broad Significant inspectors reviewed auions taken by the licensee to address problems identified with penetration seals. Inspectors concluded that the licensee took prompt and effective actions to address these problems.

97-03 06/05/97 Broad Minor Inspectors reviewed the licensee's activities involving the fire barrier penetration seal repair project. 90% of the 2600 seals inspected were determined to require repair or replacement.

89-03 04/06/89 Narrow None Inspectors reviewed the licensee's actions in response to IN 88-64 and found that they McGuire 1/2 were adequate to address the concerns outlined in the IN. ,

92-01 02/19/92 Narrow None Inspectors noted that penetration seals were acceptable during a general plant walkdown. >

98-07 08/04/98 Broad None Inspectors reviewed licensee's fire banier penetration seal program and concluded that seal designs were properly supported by seal testing documentation, vendor data, design data and inspection.

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Millstone 1/3 93-19, 10/06/93 Narrow None Inspectors reviewed licensee corrective actions for LER 93-06. 100% inspections are Millstone 2 93-14, done every 18 months for Unit 1. Inspectors reviewed revised penetration seal 93-15 surveillance procedure and found it adequate. Overall, the corrective actions were appropriate.

Monticello 92-007 04/10/92 Narrow None Inspector observed fire penetration seals 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. Inspectors felt the actions taken by the licensee to resolve this problem were adequate.

North Anna I 88-13 09/13/88 Narrow None Inspectors reviewed several exemptions requests and inspected penetration seats including North Anna 2 supporting documentation. Inspectors did not identify any discrepancies.

92-18 10/19/92 Broad Significant Inspectors identified several degraded penetration seals and upon review of the

, penetration seal program found deficiencies in procedures and documentation. Two 4 violations were issued for failure to maintain penetration fire barriers (92-18-04) and failure to establish adequate fire barrier inspection procedure (92-18-05).

93-13 03/30/93 Narrow None During a general plant walkdown, inspectors noted that penetration seals were acceptable.

93-20 09/17/93 Broad Minor Inspectors observed penetration seal inspections where removal of marinite damming boards revealed gaps in penetration seal underneath. "Ihe same problems were found in 5 other seals. Fire watches were put into place tantil the inspections and repair were completed.

94-10 06/09/94 Narrow None Inspectors reviewed licensee's corrective actions for violations 92-18@ and 92-18-05.

Violation 92-18& remained open, pending licensee's review of penetration seal inspection schedule. Violation 92-18-05 was closed.

g 94-15 08/02/94 Broad None Inspectors reviewed the licensee's results from penetration seal inspections. Based on the c: conclusions of the inspections, inspector closed violation 92-18-04.

c h 96-13 02/07/97 Broad None In 1995, the licensee initiated destructive inspections of penetration seals. It found and y repaired a number of degraded seats. On the basis of this inspection, inspectors concluded O

g that the licensee's corrective action program was very effective. , {

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y Oconee 1/2/3 88-19 07/21/88 B. el None Inspectors closed IIR 88-05 on inoperable fire barrier penetration seals based on their x review of the licensee's corrective actions. h tn O f 91-14 08/01/91 Narrow None Inspectors reviewed the licensee's procedure for 18-month surveillance of fire barrier E g penetration seals. They also inspected seals during a plant walkdown and noted no F discrepancies. }c.

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• g 97-15 12/15/97 Broad Minor Inspectors reviewed the licensee's penetration seal program. The licensee had initiated a *

reverification program for penetration seals in all 3 unit.. Inspectors opened IFI 97-15-07 to follow this effort.

Oyster Creek 93-10 06/21/93 Broad None Inspectors viewed penetration seals during plant walkdown. No visible Escrepancies were noted. Inspoors also reviewed licensee actions in response to IN 88-56. licensee conducted inspections of installed silicone foam quality during installation and at periodic intervals by removing damming boards.

95-11 07/21/95 Broad Minor Inspection was conducted because licensee reported finding degrnded penetration seals (125 of about 1560 seals) during its 18-month seal inspection program. Inspector concluded that the licensee had accurately identified, evaluated, and initiated proper compensatory andeur repair activities. Inspector concluded that there were no outstanding operability or functionality issues.

-. Pahsades92-010 03/92 Narrow None inspector reviewed licensee's fire barrier penetration surveillance procedure. No C

discrepancies were noted. '

Palo Verde 1/2/3 94-29 09/02/94 Broad None Inspector reviewed the licensee's fire barrier seal program and found that exicnsive inspections had been completed and deficiencies were being addressed by the licensee.

Peach Bottom 2/3 93-09 05/14/93 Broad Minor Inspectors reviewed the licensee's fire barrier penetration seal installation and surveillance program. Voids were discovered in some silicone foam penetration seals. De licensee responded by inspecting a!I seals supported by a given detail. Inspectors concluded that the licensee's penetration repair program appeared to be an adequate approach for identifying and correcting nonconforming penetrations.

Perry I 96-016 02/04/97 Narrow Minor inspector opened an unresolved item regarding penetration seals that wem installed in a different configuration from the supporting tested assembly. he licensee was to complete an engineering evaluation.

Pilgrim 1 92-27 12/30/92 Narrow None During a ftre protection inspection, while on a plant tour, inspecton inspected peneu anon seals. No edverse conditions were noted.

97-03 07/22/97 Broad Minor Inspector diwovered a penetration seal with a small void at the top of the seal. He seal was determined to be degraded but operable. Tlw: seal was to be repaired.

Prairie Island 1/2 92-010 08/I4/92 Narrow None Seals for seperation of diesel gr.crators from other plant areas were inspected and verified as 3-hour rated.

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River Bend Station 94-17 01/I7/95 Narrow None inspection team observed penetration seals during a fire protection-related plant tour. No discrepancies were noted.

94-22 01/26/95 Narrow None inspectors questioned the radiation shielding capability of Kaowool installed as a penetration seal. We licensee was able to adequatelyjustify the application.

95-01 03/08/95 Narrow Minor Inspectors found that inadequase corrective actions for misapplication of seal material in 1991 caused seals to degraded by high ambient temperatures. Inspectors opened URI 95-01-02.

95-02 05/03/95 Narrow Minor Inspector follow-up on URI 95-01-02 concluded that the licensee was acting appropriately, but more work was needed to resolve the problems.

95-17 06/09/95 Narrow Minor ne licensee received a non-cited violation for failure to promptly identifv and correct the inadequate design of the boot seal that had degraded _ Inspectors closed URI 95-01-02,

'o based on the licensee's ongoing cfTorts to correct the seal problem.

H B. Robinson 2 88-31 01/12/89 Narrow Minor Inspectors generated IFI 88-31-01 based on their review of GL 86-10 ev.1uations of seals that did not meet the technical specification surveillance acceptance criteria. Seals were dispositioned in engineering ed . ions rather than being repaired.

90-15 08/06/90 Nanow None inspectors reviewed the licensee's fire barrier inspection project, which was initiated to ensure that all seals were operable per plant technical specifications. IFI 88-31-01 remained open pending the completion of this project.

91-13 05/17/91 Narrow None inspectors closed LER 90-10 on an inoperable penetration seal, and IFI 88-31-01 based on the completion of the licensee's penetration seal inspection project. Several seals were scheduled to be repatred because of the inspection project.

2 96-12 12/16/96 Nanow None inspectors noted that penetration seals were adequate during a general plant walkdown.

h Also, inspectors concluded that licensee's evaluation of IN 94-28, " Potential Problems y With Fire Barrier Penetration Seals," was appropriate and required corrective actions were a

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Inspectors evaluated the licensee's actions to resolve fire pmtection discrepancies during i 3 St. lxcie 2 the 1996 Unit I refueli' ng outage. De licensee had inspected penetration seals and found @,

P small cracks in the surfaces of the seals. Inspectors concluded that the discrepancies did p not appear to degrade the fire resistance of the seals. Ilowever, the licensee considers g seals with even ecsmetic problems to be inoperable. Inspectors found that the licensee's L corrective actions and compensatory measures were appropriate.

97-06 08/25/97 Broad Minor inspectors cited licensee for failure to promptly take appropriate corrective actions to resolve mechanical penetration seal deficiencies.

Salecn 1 93-80 10/14 S 3 Narmw None Inspectors reviewed results of I8-month fire barrier penetration seal surveillance Salem 2 conducted by the licensee. No discrepancies were noted.

96-01 03/2586 Broad None Inspectors reviewed the licensee's procedure for fire barrier penetration seat inspections.

96-10 10/30/96 Broad None his issue was a restart action plan item. Inspectors reviewed work done during the penetration seal improvement program and concluded that the quality and configuration of penetration seals were acceptable.

E 97-09 06/0387 Broad None Inspectors reviewed the qualification-type fire endurance tests and associated engineering C

evaluations for certain seal desigr.s in floors and walls in Unit I and Unit 2 auxiliary buildings. Inspectors focused on verifying that design and installation parameters for the as-built configurations were bounded and justified by the licensee's engineering evaluations. Inspectors concluded that the licensee's engineering analysis methods appeared to have established a basis that the as-built seal designs would accomplish their intended function.

San Onofre 2/3 94-01 01/28S4 Broad None ne licensee conducted a 100 % reverification program of the installed configurations as a part of the valida' ion of the Plant and Equipment Data Management System database.

TM licensee founc: that 4 of 1500 seals (a 20 % sample of a total of 7000 seats) did not meet acceptance criteria. (De reverification process was ongoing at the time of the inspection.) Inspector walked down and verified the adequu y of a sample of installed seals. Inspector did not report any safety-significant prohlem<

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Sequoyah 1/2 88-54 01/13/89 Narrow Minor Inspectors reviewed procedures for licensee penetration seal in<pections. Inspectors also found 2 fire barrier penetration seals that were breached by a rubber hose. Inspectors opened IFI 88-54-05.

92-14 06/05/92 Broad Minor Inspectors closed IIRs91-010,91-008,91-016, and 91-012. Licensee had planned a i 100% inspection and reverification of all installed seals in accordarne with IN 88-St.

94-16 07/19 S 4 Broad None Inspectors reviewed the licensee's response to IN 88-04, which included inspection aruf seal re-work. Inspectors concluded that the licensee's followup on the IN was adequate.

96-02 04/22S6 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. Corrective actions on these items were incomplete at the time o' the inspection.

96-10 09/27 S 6 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 resolved.

J_. Scheduled for completion late 1997, 97-03 05/12S7 Narrow None Inspectors concluded that licensee's evaluation ofIN 94-28," Potential Problems With Fire Barrier Penetration Seals." was appropriate and required corrective actions were completed.

98-07 08/07/98 Broad Minor Inspectors reviewed l'icensee's penetration seal program, including a waltdown of 24 silicone foam penetration seals. Inspectors opened IFl 97-08-10 to track licensee's actions concerning the evaluation ofinstalled seal configurations that are not adequately supported ty a fire test.

Shearon Harris 95-02 03/0265 Narrow Nonc laspmors observed penetration seal 18-month visual inspection conducted by licensee personnel. Performance of the inspection was found to be satisfactory.

98-01 03/2768 Broad Minor Inspectors reviewed the licensce's penetration seal program. 3 of the seals inspected lacked adequate supporting documentation and engineering analysis. A violation was cited based on this weakness b *Z e South Texas 1/2 94-15 06/07S 4 Narrow Minor IFI regarding excessive shrinkage of penetration seals was closed in the report. $

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93-18 07/27/93 Narrow None During a fire protection inspection, inspectors reviewed procedures for the licensee's fire s, B r stop and fire retardant coatings surveillances.

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96-10 10/28/96 Narmw Nonc Inspectors concluded that licensee's evaluation of IN 94-28," Potential Problems With Fire Barrier Penetration Seals.** was appropriate and required corrective actions were comp?cted.

Susquehanna I 95-12 08/02/95 Narrow Minor Inspectors followed up on LERs94-003 and 94-007 for a missing seal and a degraded i seal. Both discrepancies were corrected.

95-14 07/31/95 Rroad None Inspector conducted a comprehensive inspection of the licensee's penetration seal program including, reviewing the adequacy of the penetration seal installations, qualification, and inspection activities. Inspector also assessed the appropriateness of neces=ca criteria for validating operability and degradation. Inspector concluded that the licensee had an excellent program.

y 96-201 04/05/96 Broad Minor NRR staffinspected the fire barrier penetration seal program and found the damming C material missing from one penetration seal. The licensee took immediate corrective actions. Inspect ars concluded that the licensee had implemented and maintained an acceptable fire barrier penetration seal program Inspectors did net find safety-significant problems or evidence of generic problems with penetration seals.

Turkey Point 3/4 88-37 01/05/89 Narrow Minor During a fire protection inspection, inspector reviewed the procedure for penetration fire -

barrier surveillances. Inspector noted that the procedure did not identify that all the installed fire barriers met Appendix R requirements. 'Ihe procedure was being revised at the time of the inspection.

92-23 10/29/92 Narmw None During a fire protection inspection, inspector reviewed the penetration seal inspection proch inspector noted no discrepancies in penetration seals during a plant walk-down.

96-06 06/03/96 Narrow Minor Ucensee QA audits of fire protection program were reviewed. Findings regarding penetration seal documentation were identified. Corrective actions were determined to be adequate.

97-11 11/24/97 Broad Minor Inspectors reviewed the licensee's actions in response to ins 8844,88-56, and 94-28. The 9

licensee was evaluating the adequacy of silicone elastomer seals and found scme seals ,

without supporting documentation. Inspectors opened IFI 97-11-04 to track the licensee's progress in evaluating all the seals installed at the plant.

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Vermont Yankee 93-05 05/13/93 Broad Significant A violation was issued to the licensee for inadequate apphcation of quality principles to the original installation and the subsequent ineffective periodic inspections of the fire banier penetration seals installed in the reactor building, control building, and diesel generator roorns.

Virgil C. Summer 96-11 11/25M6 Narrow None inspectors concluded that licensee's evaluation ofIN 94-28 " Potential Problems with Fire Banier Penetration Seals," was appropriate and required corrective actions were completed.

Vogtle 1/2 88-24 06/29/88 Narrow Minor Following a spurious actuation of a fire suppression systent several fire penetration seats allowed the passage of water from one fire area to ancther. Inspector issued a level IV violation for the failure to adequately design and install watertight penarration seals.

91-10 06/13/91 Narrow Minor During a fire protection inspection, inspector (during a walkdown), found an unsealed

':" penetration. Inspector issued a level IV violation for this and other fire protection I

t.a deficiencies.

92-13 08/04M2 Broad None hspectors completed an inspection on fire barrier penetration seats. Inspectors reviewed surveillanas, noted discrepancies, and confirnxxf that all deficiencies were conected There were no findings in this area.

93-08 05/17M3 Nanow None Inspectors found penetration seals to be adequate during a general plant walkdown.

Violation 91-10-01, concerning conective acuons for missing penetration seals, was closed.

95-31 02/96 Narrow None laspectors closed IIR 95-01 for lack of penetration seals placing pimt in condition outside of design basis. Carective actions were found to be adequate 97-01 04/14/97 Nanow None laspectors concluded that liansee's evaluation ofIN 94-28. " Potential Prob! cms With Fire Barrier Penetration Seals," was appropriate and required corrective actions were h l

'""P ded 97-12 02/23/98 Broad None Inspectors reviewed the licensee's fire banier penetration seals program, which included the inspecuon ofindividual penetration seals. Inspectors concluded that seal designs were g

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Minor in December 1993, the licensee began a review of issues related to its penetration seal 5 f

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Washington Nuclear 2 94-08 02/25/94 Broad inspection program. He licensee found deficiencies with original installations, periodic inspections, and repairs. He licensee declared all seals inoperable, established

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E2 compensatory measures, and initiated a comprehensive penetration seal upgrade program. 3

@ NRC Region IV conducted three inspections of the program. Inspectors concluded that L the licensee was taking aggressive corrective actions.

94-09 05/M/94 Broad None SALP report noted that penetration seal problems were not properly addressed by the licensee until the NRC became involved.

94-28 11/09/94 Broad Significant he staff issued a violation (94-28-01) for not taking prompt compensatory measures upon the discovery of installation' and inspection deficiencies for fire barrier penetration seals. Inspectors viewed approximately 100 penetration seals and noted that many had small cracks or gaps along the seal-wall interface. Inspectors did not believe that the deficiencies made the barriers nonfunctional.

95-18 06/29/95 Broad None Inspectors closed violation 94-28-01. He licensee had completely restructured io fire protection program, including its penetration seal program.

':95-201 10/03/95 Broad None An NRC integrated assessment team inspected the licensee activities mentioned in the E previous inspection reports. He team assessed licensee effectiveness in identifying issues, perfortaing root cmse analyses, and implementing corrective actions. He inspection focused on the areas of maintenance and engineering. He team inspected activities involving procurement, storage, installation, quality control, and long-term maintenance associated with the installation and maintenance of penetration seals. De team concluded that the licensee's current performance in the areas of receipt inspection and storage control, quality control, and inspection and surveillance was adequate. He assessment team also considered the licensee's corrective action program on penetration seals to be a strength.

W xerford 3 N/A 10/07/94 Broad None NRR staff audited the penetration seal progrm. De staff found several minor weaknesses with fire test results and training records. De staff concluded, however, that the fire barrier penetration seal program was satisfactory and that the discrepancies did not create any problems with the penetration seal installations. De staff did not Gnd safety-significant proHems or evidence to suggest that generic problems existed with penetration seals.

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

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Mg m Watts Bar 1 94-62 11/16/94 Narrow Minor Inspectors opH mnstruction deficiency reports (CDRs) 85-18/19 and 90-10 for fire-rated penetra' ;ficiencies and unqualified cable penetration seals. These issues were inspected ses ' .mes over a 2-year period.

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

95-32 06/09M5 Narrow None Inspectors continued followup on CDR 85-19, 95-38 07/lI/95 Narrow Minor Inspectors discovered degraded penetration seals during a plant tour.

95-39 07/I8/95 Narrow None Inspectors closed CDR 87-13, which concerned deficiencies with mechanical fire protection penetration seats.

95-40 09/1285 Narrow Minor Documentation of the fire testing for fire barrier penetration seals did not conform to the design details for some installed seats. His follows from previous CDRs.

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

95-f 8 10/19/95 Broad None Inspectors reviewed design details and QA/QC records, and walked down penetration seals. No discrepancies were identified for the seals that were reviewed. During the walkdown some seals were noticed to have damaged damming boards. He applicant was already aware of these deficiencies.

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

95-77 12/06/95 Narrow None Inspectors closed second CDR (90-10) for unqualified penetration seals.

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se Wolf Creek 94-02 G4/15/94 Broad Minor m Cracks found in fire barrier material which formed a penetration seal between two areas.

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n 95-19 08/10/95 Narrow None Inspector visually inspected penetration seats in various fire areas. No discrepancies were is O

h identified.

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

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Arkansas Nuclear One 1 1974 ER 91-016.

Arkansas Nuc! car One 2 1980 &R 91-016 Big Rock Point 1963 LERs89-006 and 91-001.

Browns Ferry 2/3 1975/1977 NRC 1R 98-01.

Brunswick 1/2 1977/1975 MR 93-006-00 Calvert Cliffs 1/2 1975/1977 NRC IR 94-15.

Catawba 1/2 1985/1986 McGuire LER 88-030-01.

D.C. Cook 1/2 1975/1978 LER 96-004-00.

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

Duane Arnold 1975 NRC IR 93-012.

FitzPatrick 1975 ER 91-024-01.

Fort Calhoun 1973 LER 90-022.

IInddam Neck 1968 ERs 89-001-00 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.

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

Millstone 1 1986 LER 93-006-01, NRC IR 93-19.

hionticello 1971 LER 89-001-00.

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

Oconee 1/2/3 1973/1973/1974 LERs 89-010-03 and 88-005, NRC IR 97-15. .

Palo Verde 1/2/3 1986/1986/1988 Letter of March 16,1990.

River Bend Station 1986 LER 89-010-03.

H.B. Robinson 2 1971 MR 91-010-01.

Salem 1 1977 LER 88-013-00.

Salem 2 1981 ER 88-013-00.

COMM. OP. = Date of Commercial Operation, LER = Ihcr Event Report, NRC IR = NRC Inspection Report J-l NUREG-1552, Supp. 1 l

100% Penetration SealInspection

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

Susquehanna1 1983 NRC IR 95-12.

Sequoyah 1/2 1981/1982 NRC IR 96-10.

Vermont Yankee 1972 LER 93-001.

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

Watts Bar 1 1996 NRC IR 95-77.

l l

l i

i NUREG-1552, Supp.1 J.2

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

S)UNEbO(b 'Mkh ,,Cassen, M [ di Nh M yf ~ % A , . "O Arkansr N:: clear One 1 1974 LERs 89-003-00,90-004-00,90-N-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 1 1976 NRC irs 93-12 and 93-13.

Beaver Valley 2 1987 NRC irs 93-12 and 93-13.

Big Rock Point 1963 LERs 89-006-00,89-006-01,91401-00, and 91-001-01.

Braidwood 1/2 1988/1988 N/A.

Browns Ferry 1/2/3 1974/1975/1977 NRCIRs 89-28,90-11,92-11,95-60, ud 98-01.

Brunswick 1/2 1977/1975 LER 93-006-00; NRC irs 92-31,93-08, 93-38,97-07, and 97-13.

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

Callaway 1984 NRC IR 9412.

Calvert Cliffs 1/2 1975/1977 LERs 89-002-00, 89-002-01, a.'d 95-004 S; NRC irs 94-15,93-99,95-08, ano 90-201.

Catawba 1/2 1985/1986 McGuire LER 88-030-01; NRC irs 9 l-22,97-07, and 98-07.

Clinton 1987 LERs 89-006-00 and 98-021-00.

Comanche Peak 1/2 1990/1993 NRC irs 96-10 and 96-12. r Cooper 1974 LER 94408-00; NRC IR 95-17.

Crystal River 3 1977 NRC irs 92-18 and 97-18.

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 94-001-00,94-00141,96-011-00, and 96-011-01; NRC irs 94-01,94-07,94-18,9543, and 96-13.

Dresden 2/3 1970/1971 LER 89-030-00.

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 88-27,94-30,95-20,96-13, and 97-12.

Farley 2 1981 NRCIRs 88-27,94-30,95-20,96-13, and 97-12.

COMM. OP. = Date of Commercial Operation, LER = License Event Report, NRC IR = NRC Inspection Report i

E K-1 NUREG-1552, Supp.1

Reference Summary r.7 - gy gy7;g gggsygggggggg Fermi 2 1988 LERs 97-014-00 and 97 014-01; NRC IR 94412.

I FitxPatrick 1975 LERs 87 011-00,87-011-01,91-024-00, and 9l-024-01, NRC irs 93-12,93-14, and 93-26.

rt Calhoun 1973 1.ERs 90-02240,90422-01, and 90-02242.

Fort St.Vrain LERs 87-00640. 87-006-01,89-014-00, and 89 014-01.

Ginna ' 1970 LER 8840940; NRC IR 94-14.

Grand Gulf i 1985 NRC IR 90-10.

Haddam Neck 1968 LERs 89-001-00,89401-01,9240840,93-00340, 95-001-00, and 95-001-01; NRC irs 93-08 and 95-09. J Hatch 1 1 5 NRC irs 88-21,9l-30,92-09,93-22,97-01,97-03, and 98-01.

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Hatch 2 1979 NRCIRs 88-21, 91-30, 92-09, 93-22, 97-01, 97-03, and j 98-01. j Hope Creek i 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 NRC IR 96-004.

LaSalle 1/2 1984/1984 LER 93 009-00; NRC IR 9604.

Ilmerick 1/2 1986/1990 N/A.

Maine Yankee 1973 LERs 94-010-00,94-01(M)l,96-017-00 and 9 T-017-Ol; l NRC irs 95-15 and 96-08.

McGuire 1/2 1981/1984 LERs 88-03040 and 88-03001; NRC irs 89-03,92-01, 97-03, and 98-07.

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.

Millstone 3 1986 NRC IR 93-15.

MonticeBo 1971 LERs 87-011-00,89-001-00,89-013-00,89-013-01, 90-00940, and 91-021-00; NRC irs92-007 and 93-005.

Nine Mile Point 1 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 LERs88-007 00 and 89-003-00; NRC irs 88-13,92-18, 93-13,93-20,94-10,94-15, and 96-13.

North Anna 2 1980 LERs 88-007-00 and 89-003-00; NRC irs 88-13,92-18, 93-13,93-20,94-10,94-15, and 96-13.

NUREG-1552, Supp.1 K-2

Reference Summary

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4, g, Oconee 1/2/3 1973/1974/1974 LERs 88-00540 and 89-010-03; NRC 1Rs 88-19,91-14, and 97-15.

Oyster Creek 1969 NRC irs 93-10 and 95-11.

Palisades 1971 LERs 89-02440 and 96-009-00; NRC IR 92-010.

Palo Verde 1/2/3 1986/198 &l988 LERs 90-00940 and 90-009-01; NRC IR 94-29 Peach Bottom 2/3 1974/1974 LER 91-013-00; NRC IR 93-09.

Perry 1 1987 NRC IR 96-06.

Pilgrim 1 1972 NRC irs 92-27 and 97-03.

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

Prairie Island 1/2 1973/1974 LER 98-003-00; NRC IR 92-010.

Quad Cities 1/2 1973/1973 LER 87-028-00 River Bend Station 1986 LERs 87-021-00,88-009-00,88409-01,88-00942, 89-005-00, 89-01 M0, 89-01041, 89-010-02, 89-010-03, 89-01044, and 89-010-05; NRC irs 94-17,94-22,95-01, 95-02, and 95-17.

H.B. Robinson 2 197i LERs 88-018-00,88-01841,90-003-00,9000840, 90-010-00,90 010-01, and 91-010-01; NRC irs 88-31, 90-15,91-13, and 96-12.

St. Lucie 1 1976 LERs 97-004-00 and 97-00840; NRC irs 96-08 and 97-06.

St. Lucie 2 1983 LERs 97-004-00 and 97-008-00; NRC irs 96-08 and 97-06.

Salem 1 1977 LERs 87-007-00,88-013-00, and 88-014-00; NRC irs 93-80, 96-01,96-10, and 97-09.

Salem 2 1981 LERs 87-007-00,88-013-00, and 88-014-00; NRC EP 93-80, 96-01,96-10, and 97-09.

San Onofre 2/3 1983/1984 NRC IR 9441.

Seabrook i 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 irs 88 54,92-14,94-16,96-02,96-10,97-03, and 9847, Shearon Harris 1987 NRC IR; 95-02 and 98-01.

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

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

Summer 1984 NRC IR 96-11. I Surry 1/2 1972/1973 NRC irs 88-07,93-18, and 96-10.

Reference Summary

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Three Mile Island 1 1974 LER 87-003-00 Trojan LERs 90-02240,90-022-01,92-006-00,92-006-01, 92-011-00,92-026-00,92-026-01,92-026-02,92-026 03, 92426-04, 92-026-05; 92-031-00; 92-034-00, 93-001-00, and 93-002-00.

Turkey Point 3/4 1972/1973 NRC irs 88-37,92-23,96-06, and 97-11.

Vermont Yankee 1972 LERs 93-001-00,93-001-01,93-001-02,944I8-00, 94-018-01,95-004-00,96-02640,96-026-01,98-00140,98-001 -01, 98-008-00, 98-00841, 98-014-00, 98414-01 ; NRC IR 93-05.

Vogtle 1/2 1987/1989 NRC irs 88-24,91-10,92-13,93-08,95-31,97-01, and 97-12.

Washington Nuclear 2 1984 LERs 87-004-00,87-029-00,87-030-00,88-008-00, 88-008-01,94-00240, and 94-002-01; NRC irs 94-08, 94-09, 94-28, 95 18, 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 1994 NRR audit.

Watts Bar 1 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 87-001-00,87-010-00,87410-01, and 87-010-02; NRC irs 94-02 and 95-19.

Zion 1/2 1973/1974 N/A.

l NUREG-1552, Supp. I K-4

NRC DORM 3J5 U S. NUCLEAR REGUUJ/ORYCOMMISSCDN 1. REPORT NUMBER 1102. . U )

m .32o2 BIBLIOGRAPHIC DATA SHEET (see ineeuenor. on e. re ) NUREG-1552, Supplement 1 a wuuloSuenu 3 DATE REPORT PUBUSHED Fire Barrier Penetration Seals in Nuclear Power Plants uoNTw I vEAR January 1999

4. FIN OR GRANT NUMBER

5. AUTHORG51 6. IWE OF REPOR T Technical C. S. Bajwa and K. S. West

7. PERICO COVERED (Inclueve Detee) 6, PERFORMING ORGANil.AilGN - NAME AND ADDRESS p NRC. pro.co Onnaart Omco or Regiors U S. Nucseer Reguatory Commesmorg and rnslatig address, d contractor _

prov6de name and rnaihrig eddreet)

Division of Systems Safety Analysis Office of Nuclear Reactor Regulation U.S. Nuclear Regulatory Commission Washington, DC 20555 - 0001 a SPoNSORiNo ORoANeAmN - NAue ANo AcoRess a NRC. ivo. S no .e eav., d cor ecier. prowd. NRC o,..on. Ome. or R.g,on, u S Nuaear Rogueio,y Comm,=

ord meeng addrese }

Same as above , l

10. SUPPLEMENTARY NOTES

11. ABSTRACT (200 worce or lese)

Nuclear power plants use the " defense in depth" concept of echelons of fire protection to achieve a high degree of fire safety. The objective of this concept is to (1) prevent fires from starting; (2) rapidly detect, control, and extinguish those fires that do occur; and (3) protect structures, systems, and components important to safety so that

. a fire that is not promptly extinguished will not prevent the safe shutdown of the plant. Fire barrier penetration seals, which are but one part of one element of the fire protection defense-in-depth concept, are designed to maintain the fire rating of a barrier where penetrating items pass through the barrier. This is essential if the barrier is to conf'me a fire to the area in which it started or to protect plant systems and components within an area from a fire outside the area. On the basis of everything it found and considered,it is the staff's judgment that, overall, the issue of potential fire barrier penetration seal deficiencies does not affect safety. For the reasons given in this paper, typical penetration seal deficiencies do not necessarily equate to a lack of adequate protection or result in

unGe risk to public health and safety. It is the staff's opinion that continued licensee upkeep of existing penetration seal programs and continued NRC inspections are adequate (1) to ensure that penetration seal problems are discovered and resol. red and (2) to maintain public health and safety.

12. KEY WOROS/DESCRIPTOR$ (Last words or phrases that wil assst ressereners in locating the report) 13. AVAllAS4UTYSTATEMENT Unlimited Fire Barrier Penetration Seals Silicone Foam **

Fire Barriers Unclassified (This Report)

Unclassified 15 NUMBER OF PACES 16, PRICE

_ NRC FORM 335 (2-88)

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~ NNREG-155[SdI FIRE EARRIER PENETRATION SEALS IN NUCI POWER PLANTS .' JANUARY 1999 UNITED STATES SPECW. STANDARD Wut.

NUCLEAR REGULATORY COMMISSION . POSTAGE AND FEES PAfD

WASHINGTON, DC 20555-0001

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