ML20210N342
| ML20210N342 | |
| Person / Time | |
|---|---|
| Issue date: | 11/17/1994 |
| From: | Khadijah West NRC OFFICE OF NUCLEAR REGULATORY RESEARCH (RES) |
| To: | Paul R NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION III) |
| Shared Package | |
| ML20210N260 | List: |
| References | |
| FOIA-97-180 TAC-M90340, NUDOCS 9708250190 | |
| Download: ML20210N342 (4) | |
Text
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.y/ LIMITED DISTRIBUTION November 17, 1994 MEMORANDUM TO: Richard C. Paul, Senior Investigator '
Office of Investigation Field Office Region Ill FROM: K. Steven West, Chief if Special Project Section , ', ( .M P1 ant Systems Branch ,
Division of Systems Safety and Analysis Office Nuclear Reactor P.%'ilation
SUBJECT:
REVIEW OF TECHNICAL INFORMATION REGARDING DOW. CORNING INVESTIGATION, 01 CASE NO. 3-93-028R (TAC NO. M90340)
We have reviewe'd the information on fire bar ier penetration seals that you provided with your memoranda of August 29, 1994, September 26, 1994, and September 28, 1994.
U.S. Nuclear Regulatory Commission requirements and guidelines for fire barrier penetration seals are contained in various documents, including 10 CFR Part 50, Appendix R, " Fire Protection Progr u for Nuclear Power Facilities Operating Prior to January 1, 1979;' 3r; 'h Technical Position APCSB 9.5-1, Appendix A, " Guidelines for Fire Proti ion for Nuclear Power Plants Docketed Prior to July 1, 1976;" and NUREG-i ), " Standard Review Pl an. " Supplemental guidance has al' betn pro,id, in a number of 1 information notices and in Generic Letter 66-10, "l slementation of Fire Protection Requirements," dated April 14,.1986. TF, extent to which these requirements and guidelines apply to a specific nuclear power plant depends on plant age, commitments _ made by the licensee in developing its fire protection plan, the safety _ evaluation reports, and the fire protection license condition. The requirements and guidelines specify that fire barrier penetration seals be qualified by standard fire tests. The staff has evaluated and accepted the results of fire tests conducted in accordance eith:
(1) American Society for Testing Materials (ASTM) E-119, " Standard Test Methods for- Fire Tests of Building Construction and Materials,"
(2) ASTM E-814,." Standard Test. Method for Fire Test of Through-Penetration Fire Stops," (3) American Nuclear Insurers (AN1) "AN1/MAERP Standard Method o' Fire Tests of Cable and Pipe-Penetration Fire Stops,"-(4 ) underwriters Laboratories, Incorporated 1479, " Fire-Tests of Through Penetration Fire Stops," and (5) Institute of Electrical and Electronic Engineers (IEEE) 634,
" Standard Cable Penetration Fire Stop Qualification _. Test." All of these test standards use the standard' time-temperature fire specified in ASTM E-119. The e maximum allowable unexposed surface temperature specified in these test methods ~ ranges from 250 'F plus ambient temperature to more than 700 *F.
Your memorandum of September 28, 1994, included Brand (BISCO) fire test report 3001-03-B, dated May 19, 1980. In your memorandum, you pointed out that in LIMITED DISTRIBUTION 9708250190 970P14 PDR FOIA GUNTER97-180 PDR 7 fp---}* h -- --- -
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R. Paul the text of the report, BISCO claimed that the fire test was successful and complies with NRC test standards, but the thermocouple readings showed temperatures greater than 325 'F. You also stated that your source expressed concerns about this penetration seal, but you did not provide a specific concern.. According to the test report, this test of a 9-inch thick undammed silicone foam seal was performed in accordance with ASTM E-119 and IEEE-634.
The maximum allowable unexposed surface temperature specified in ASTM E-Il9 is 250 'F plus ambient temperature. IEEE-634 specifies that the maximum allowable temperature should be based on the self-ignition temperature of the outer cable covering in contact with the penetration seal. The self-ignition temperatures of cable jackets are generally above 700 'F. The maximum unexposed-side temperature reported during the test of interest was 435 'F.
Ignition of the cable jackets on the unexposed side of the seal was not reported.
Therefora, this BISCO test appears to have met the acceptance criteria of IEEE-634. NRC Information Notice 88-04, " Inadequate Qualification and Documentation of Fire barrier penetration Seals," dated February 5,1988, identified IEEE-634 as an acceptable standard fire test for determining the fire resistance ratings of penetration seals. :n addition, although ASTM E-119 does not specifically address tests of penetration seals with penetrating items, we noted that the temperatures of the unexposed surface of the seal, measured away from the penetrating cable tray and cables, met the criteria of ASTM E-119.
With your memorandum of September 28, 1994, you also provided a Transco letter of May 2, 1985.
This letter summarized the resul+.s of fire tests of 10-inch thick dammed silicone foam seals and 12-inch thick undammed silicone foam seals. According to the summary information, the 12-inch thick seals did not meet the test acceptance criteria but the 10-inch seals did meet the test acceptance criteria.
We cannot offer technical judgements regarding these tests letter, results on the basis of the summary information provided in the Transco in addition, the letter did not contain data or information that could be used to compare the Transco fire tests to the 9-inch thick undammed BISCO test discussed above (Report 3001-03-B, dated May _ 19, 1980). We note, however, that the performance of fire barrier penetration seals is configuration and material dependent. Therefore, broad conclusions cannot be reached based simply on the depth of the seal material or on the presence or
_ _ absence of-damming materials.
In your memoranda of August 29, and September 26, 1994, you requested that we review the results of five side-by-side 3-hour fire' endurance tests
-(Construction Technology Laboratories Test Reports Dow Test 1, Dow Test 2, Dow <*
- Test 3, Dow Test 4, and Dow Test 5, all designated CR55022-4324 and dated October 1984) and supporting information regarding a change Dow Corning made to the- formulation of Dow Corning 3-6548 Silicone RTV Foam. You noted that in -
Test 1, two of the test specimens failed the hose stream test, and Test 2 and Test 3 had temperatures which exceeved 250 'F plus ambient.
We obtained the lot numbers far the old formulation and.the modified formulation from a letter o' anuary 8,1984, from J.L. Elias, Dow Corning, to
R. Paul , J. Anderson, Bisco Products, Incorporated, and from Deposition Exhibit 12 4le compared the test configurations and the fire and hose stream test results f the following test specimens: (1) Test 1, Seal A5 (old formulation) with Test 1, Seal A6 (modified formulation); (2) Test 1, Seal Al and Test 5, Seal B3 (old formulation) with Test 1, Seal A3 (modified formulation);
(3) Test 2, Tray 1 and Test 3, Tray 2 (old formulation) with Test 3, Tray 1 (modified formulation); and (4) Test 4, Tray 2 (old formulation) with Test 4, Tray 1 (modified formulation). (The other seals included in the tests were not pertinent to the formulation change.) On the basis of our reviu of the test reports, we concluded that the tests were conducted in accordance with accepted industry standards and NRC guidance. We also concluded that the tests were an appropriate method for assessing the effects of the formulatior, change. On the basis of our evaluation of interface, cable, cable tray, and seal temperatures, the thicknesses of unburned silicone seal materials, and the other observations documented in the test reports, we concluded that the change in formul'ation of Dow Corning 3-6548 Silicone RTV Foam did not materially effect the fire-resistive performance of the foam in the tested configurations.
During our review of the test results for the aforementioned test assemblies, we noted that the maximum allowable temperature rise specified in the test standards was not exceeded on tne unexposed surface of the seals (measured away from the penetrants), and there was no passage of flame through the seals. L also noted that the maximum allowable temperature rise specified in the test standards was exceeded at several points on the cable trays and on .
several cables. Finally, we noted that several of the seals did not meet the hose stream test acceptance criteria. The hose stream tests were performed at the end af the full 3-hour fire exposure and used a sclid hose stream. It is possible that these specimens may have passed the hose stream test if the tests had been performed at one-half of the fire exposure period, as allowed by the test standards, or if the tests had used a fog nozzle hose stream as allowed by NUREG-0800.
The purpose of our review of the test reports and supplemental information you provided was to assist you in your review of alleged wrongdoing. Our comments on the reports should not be interpreted as NRC staff approval or rejection of the test results for specific nuclear power plant applications. As you know, the NRC does not approve products for generic application. Our review of nuclear power plant components, structures, systems, and parts, including penetration seals, is performed within the scope of nuclear power plant-specific applications after the licensee has selected the item and determined that it meets NRC regulations or guidelines and its licensing commitments.
Therefore, even if a fire test report indicates that certain test acceptance criteria were not satisfied, a licensee may use the test results, with ;
additional evaluation as specified in Generic Letter 86-10, as the basis for installing a particular seal configuration in its plant.
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R. Paul Our review and evaluation of-the information you provided -is complete. We do not plan to take any additional action regarding this matter. If you have questions about our review or evaluation of the test results, please call me at 301-504-1220,. or Amarjit Singh at 301-504-1237.
Distribution:
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Filename: G:\SECTIONC\SINGH\M90340-SPLB:DSSA ' SPLB:DSSA. SPLB:ESA ASingh n SWest ICBcCiacken ll/;1/94J'd 11/6/94s%4 11/11/94 0FFICIAL RECORD COPY LIMITED DISTRIBUTION
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