ML20210N514
| ML20210N514 | |
| Person / Time | |
|---|---|
| Issue date: | 06/30/1995 |
| From: | Khadijah West NRC (Affiliation Not Assigned) |
| To: | Paul R NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION III) |
| Shared Package | |
| ML20210N260 | List: |
| References | |
| FOIA-97-180 NUDOCS 9708250328 | |
| Download: ML20210N514 (4) | |
Text
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NUCLEAR REGULATORY COMMISSION o WA$HINotoN o C. 20566 4001
- June 30 -1995 MEMORANDUM TO: Richard C Paul, Senior investigator Office of Investigation Field Office Region 111 FROM: K. Steven West, Chief d i Fire Protection Section Plant Systems Branch Division of Systems Safe y and Analysis d
Office of Nuclear Reactor Regulation
SUBJECT:
' TECHNICAL REVIEW 0F BISCO FIRE TEST REPORTS, 01 CASE NO. 3-94-068 (TAC N0, M91162)
With your memoranda of December 21, 1994 and February 8, 1995, you provided
- the B1500 penetration seal fire test reports listed in Attachment 1. You asked us to determine if there were any apparent misrepresentations regarding l the conduct of the tests. You also asked us to determine if there is a requirement for a utility to have a test performed by an independent laboratory and if the BISCO test reports meet NRC requirements for qualification tests by an independent laboratory, We did not find any apparent misrepresentations in the test reports, The test i reports document that the test assemblies were constructed by BISCO and that i the tests were performed by Construction Testing Laboratories (CTL), Detailed information is provided in Attachment 2.
We did not perform a technical review of the test reports and our comments should not be interpreted as NRC staff approval or rejection of the test results for specific nuclear power plant applications. As you know, NRC does not approve fire protection components or systems 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 J
the basis for installing a partir? ar seal configuration in its plant.
Our review of the information yo ovided is complete. We do not plan to
< take any additional action regarding this matter.
CONTACT: A. Singh, SPLB/DSSA/NRR 301-415-1237 w 3 6D /
3094-068 g q ,g 9708250328 970814 TE D JUGCQ L/V v u 190 PDR g
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i ATTACHMENT 1 FIRE TEST REPORTS SUBMITTED BY OFFICE OF INVESTIGATIONS REGION 111 FIELD OFFICE
- 1. BISCO Test No. 748-14, Metal Clad Fire Wall Penetration Barrier Fire Testing," dated-May 21, 1979
- 2. BISCO Report No. 748-31, " Fire Endurance Test on BISCO Flexible Boot &
Flexible Radiation Seal Systems," dated May 23, 1979
- 3. BISCO Report No. 748-41, " Fire Test Configurations for a Three-Hour Rated Fire Seal Utilizing BISCO SF-20 Silicone foam (Dow Corning 3-6548)," dated April 17, 1981
- 4. BISCO Report No. 748-42, " Fire Test Configurations for Three-Hour Rated Fire Seal Utilizing SF-150NH," dated July 29, 1981
- 5. BISCO Report No. 748-49, " Fire Test Configuration for a Three-Hour Rated Fire Seal Utilizing BISCO SF-20 Where; A Steel Sleeve Condition With Pipe Penetrant Exists," dated July 9, 1981
- 6. BISCO Report No. 748-57, " Fire Test Configuration for a Three-Hour Rated Fire Seal Utilizing SF-150NH " dated November 6,1981
- 7. BISCO Report No. 746-63-A, " Fire Test Utilizing BISCO SF-20 & SF-60 in Various Design Configurations," dated March 11, 1982
- 8. Report No. 3001-03-B, " Fire Test Configuration for BISCO Three-Hour Fire Seal," dated May, 19, 1980
- 9. Fire confirmation testing of cable tray penetration seals in concrete walls utilizing silicone elastomers (by Dow Corning Corporation) for Toledo Edison Company (Davis-Besse Unit No.1)
- 10. Fire Endurance test on BISCO penetration seal systems in a concrete floor utilizing BISCO systems SF-20 and SF-150L silicone polymers, dated October, 1976
- 11. BISCO Test No. 1042-01, " Qualification Fire and Hose Stream Tests,"
dated February, 1978
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ATTACHMENT 2 RESPONSE TO 0FFICE OF INVESTIGATIONS REGION 111 FIELD OFFICE QUESTIONS REGARDING PENETRATION SEAL FIRE TESTS BY OFFICE OF NUCLEAR REACTOR REGULATION PLANT SYSTEMS BRANCH OVEST10N 1 1s there is a requirement for a utility to have a test performed by an independent laboratory to qualify their fire j penetration seals?
RESPONSE
U.S. Nuclear Regulatory Commission (NRC) regulations do not require licensees to have fire endurance tests conducted by independent testing laboratories.
In general, a licensee's fire protection program is acceptable if it meets the NRC regulations in 10 CFR Part 50, Section 50.48, " Fire protection," and General Design Criteria (GDC) 3, " Fire protection," of Appendix A to 10 CFR Part 50. NRC guidance documents, such as Section 9.5-1, " Fire Protection Program," of the " Standard Review Plan" (SRP, NUREG 0800) provide detailed
] information, staff recommendations, and guidance which may be used by a licensee to meet Section 50.48 and GDC 3.
The SRP defines " fire barrier" as "those componen:s of construction . . . that are rated by approving laboratories in hours of resistance to fire..." The SRP defines " approved" as " tested and accepted for a specific purpose or application by a nationally-recognized testing laboratory " On the basis of this guidance, the staff would find a fire barrier acceptable if it had been tested and found acceptable for a specific application by a nationally-recognized testing laboratory, such as Underwriters Laboratories, Incorporated, without further review. However, licensees can use designs and methods different from the guidelines specified in the SRP if it provides suitable bases and justification for its alternative approaches and the staff concludes that adequate fire protection is provided by the alternative approaches. On this basis, licensees can use the results of fire tests that were not performed by an independent nationally-recognized testing laboratory, with appropriate verification that the tests are valid, to justify the use of particular fire barriers at its facility.
OVEST10N 2 Are test reports listed in Attachment I acceptable to meet NRC reqairements for qualification tests by an independent laboratory?
RESPONSE
As stated above, NRC regulations do not require that fire endurance tests be conducted by independent testing laboratories. Although some aspects of the test programs are not clear from the test reparts themselves, we did not find any apparent misrepresentations in the test reports. For example, it is not possible in all cases to determine which organization, Construction Testing Laboratories (CTL) or BISCO, prepared the test report. However, these reports
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e include a letter signed by the director of CTL's Fire Research Department that attests to the accuracy of the details of specimen fabrication, test procedures, test observations,_and test results. Each of the test reports also clearly documents that the test assemblies were constructed by BISCO and that the tests were performed and witnessed by CTL (and in some cases, other entities). These representations provide basic information on how the test programs were carried out and the fundamental roles of CTL and B1500 in the testing process. An organization that planned to utilize the test reports as its basis for installing specific seal configurations could obtain additional information about the tests, if needed, from CTL or BISCO. Similarly, the test reports and supporting documentation and information could be reviewed by the staff during an inspection or licensing review, in this case, the staff review would be within the scope of a nuclear power plaa' pecific application; af ter the licensee has' selected the penetts , u 1 seal configuration and determined that it meets NRC regulatiori, and guidelines and its licensing commitments.
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