ML20236H161

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Part 21 Rept Re Insp Rept 99901020/87-01 for Brand Industrial Svcs,Inc & Notice of Violation.Evaluation of Quality & Acceptability of Product or Svc Provided by Vendor Requested
ML20236H161
Person / Time
Site: Comanche Peak  
Issue date: 07/30/1987
From: Gagliardo J
NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION IV)
To: Counsil W
TEXAS UTILITIES ELECTRIC CO. (TU ELECTRIC)
References
REF-PT21-87, REF-QA-99901020 NUDOCS 8708050081
Download: ML20236H161 (1)


Text

_-_ - _

f JUL 301987 In Reply Refer To:

Dockets: 50-445-50-446-eTU Electric ATTN: Mr. W..G. Counsil Executive Vice, President 400 North Olive, L.B._._81 Dallas, Texas 75201 Gentlemen:

The enclosed. vendor inspection report is forwarded for your information and' action. ' This report _ identifies. concerns found by our Vendor Program Branch during an inspection of the vendor's activities. You are requested,to evaluate the~sig'nificance of the reported findings with regard to the quality and acceptability 'of the. product or service provided by the: vendor.

Please' sign the blank below to acknowledge receipt of the-report and return the original to this office.

Sincerely, GQma! C;cnod bn

., f!, G AGU ARDO"

' James E. Gagliardo, Chief Reactor Project Branch

Enclosure:

In reply refer to:.CPSES-047 Vendor: ' Brand Industrial-Sycs., Inc.

Report No.:

99901020/87-01 Issue Date: May 22, 1987' Violations Identified: 1 Nonconformances Identified: 0 Other Concerns:

END0RSEMENT Received on

, 1987 Signature bec w/ encl:

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UNITED STATES l/

. NUCLEAR REGULATORY COMMISSION oI WASHINGTON, D. C. 20556 7q May 22, 1987

- Locket No. 999C1020/87-01 Brand Industrial Services. Incorporated

= ATTN: ' Mr. C. W. Brown, President

-Construction Group 1420 Renaissance Drive r

Park R1dge, Illinois 60068 Gentlemen:

This refers to the inspection conducted by J. J. Petrosino of this office on January 20-23, 1987, of your f acility at Park Ridge, Illinois, a follow-up NRC inspection at the V.C. Summer nuclear generating station on February 25-27,

'1987, and to the discussions of our findings with you and members of your staff at the. conclusion of the inspection.

The purpose'of this inspection was to obtain generic technical and testing E

information'concerning silicone foam fire protection applications and to-evaluate the implementation of your QA program. Areas examined during the inspection and our findings..are discussed in the enclosed report. Within.

these areas, the inspection consisted of an examination of procedures and representative records, interviews with personnel, and observations by the inspector. The specific. findings and references to the pertinent requirements are identified.in the enclosures to this letter..

.The most significant issue that was identified concerns the potential for nuclear plant licensees to have fire barrier penetration seal testing documen-l-

tation that is not representative of the particular as-installed penetration

-seal configurations. Some as-installed penetration seals may not be' adequate, because its installed configuration exceeds.the documented qualification test data parameters for specific characteristics.

Consequently, some NRC licensees may not be able to provide reasonable assurance that the effects of a fire are limited to discrete fire areas, and that one division of safe-shutdown related i

systems remains free of fire damage.

The enclosed Notice of Violation is sent to you pursuant to the provisions of Section 206 of the Energy Reorganization Act of 1974. You are' required tto submit-to this office within 30 days from the date of this letter a written

' statement containing:

(1) a description of steps that-have been or will be taken to correct these items; (2) a description of steps that have been or will:betakentopreventrecurrence;and(3)thedatesyourcorrectiveactions and preventive measures were or will be completed.

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Brand Industrial Services, Inc. May 22, 198/

i The responses requested by this letter are not subject to the clearance procedures of the Office of Management and Budget as required by the Paperwork l

Reduction Act of 1980, FL 96-511.

In accordance with 10 CFR 2.790 of the Comission's regulations, a copy of this letter and the enclosed inspection report will be placed in the NRC's Public Document Room.

Should you have any questions concerning this inspection, we will be pleased l

to discuss them with you.

Sincerely, EllisW.herschof, eting Chief VendorInspectionfranch Division of React'or Inspection and Safeguards Office of Nuclear Reactor Regulation

Enclosures:

1.

Appendix A-Notice of Violation 2.

Appendix B-Inspection Report No. 99901020/87-01 cc: Mr. J. Carney, Vice President American Nuclear Insurers f

The Exchange:

Suite 270

'270 Farmington Avenue Farmington, Connecticut 06032 1

4 Mr. C. A. McNeill, Jr.

l Vice President - Nuclear Fublic Service Electric and Gas Company Fost Office Box 236

, Hancocks Bridge, New Jersey 08038 South Carolina Electric & Gas Company ATTH: Mr. D. A. Nauman Vice President, Nuclear Operations L

Post Office Box 764 (Mail Code 167)

Columbia, South Carolina 29218

J.;

APPENDIX A t.

1 Brand Industrial Services. Incorporated Docket No. 99901020/87-01 l

NOTICE OF VIOLATION i

As a result of the inspection conducted on January 20-23, 1987, and in accordance with Section 206 of the Energy Reorganization Act of 1974 and its implementing regulation 10 CFR Part ?), the'follovring violation was identified and categor-ired'in accordance with the NRC Enforcement Policy (10 CFR Part 2, Appendix C),

49 FR 8583 (March 8, 1984):

Section 21.21 of 10 CFR Part 21, states, in part, "Each individual, corporation i

or other entity subject to the regulations in this part shall adopt appropriate (1) Provide for:

(1) Evaluating deviations or (ii) informing procedures to:

the licensee..'.and (2) Assure that a director.or responsible officer is informed if the construction or operaton of a facility, or activity, or a basic component supplied:

(i) fails to comply...or (ii) Contains a defect...."

Contrary to the_above, BISCO failed to adopt and establish a procedure to implement the provisions of 10 CFR Part 21.

'This is a Severity Level V violation (Supplement VII).

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EWOE0T6N2 870522 PDR-GA999 EECBRAI 99901020-PDR j,

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CEGANIZATfCE: BRAND INDUSTRIAL SERVICES, INCORPORATED PARK RIDGE, ILLINDIS REPORT INSPECTION INSPECTION hC.: 99901020/87-01 DATES: 01/20-23/87 ON-SITE HOURS:

71 CORRESPONDENCE ADDRESS: 'Brar.d Industrial' Services, Incorporated ATTh: Mr. C. W. Brown, President Construction Group 14EG Renaissance Drive Park Ridge, Illinois 60068 ORGANIZATIONAL CONTACT: Mr. Clayton Brown, President i

TELEPH0hE NUMBER:

(312)296-1200 i

NUCLEAR INDUSTRY ACTIVITY: Brand Industrial Services, Incorporated (BISCO) has been in the nuclear plant fire protection business for 15 years and has provided materials and/or installed fire penetration seals in over 50 domestic nuclear power plants.

ASSIGNED INSPECTOR:. Fav b d, b Sgate t7 J. J. Pe1frcsino, Program Development and Reactive InspectionSection(PDRIS)

OTHER INSPECTORS:

T. L. Tinkel, Brookhaven National Laboratory J. V. Ulie, Reac or Inspector, RIII Os APPROVED BY:

U. C.

tone,~ Chief, PDRIS, Vendor Inspection Branch at I

'INSFECTION BASES AND SCOPE:

A.

BASES:

10 CFR Part 21 and Appendix 0 to 10 CFR Part 50.

B..

SCOPE:

1) Obtain Seneric technical and testing information regarding silcone foam and silcone clastomer fire barrier penetration seals.
2) Evaluate BISCO's QA program implementation.

PLANT SITE AFFLICABILITY: Arkansas 1 & E (50-313/362); Callaway (50-482);

Clinton (50-461); Comanche Peak 1 & 2 (50-445/446); (continued on next page)

A'^i^ TOE 44 870522 FDR GA999 EECBRAI 99901020 paa L

1 dRCANIZATZON: ~ BRAND'INDUSTRfAL SERVICES, INCORPORATED PARK RIDGE, fLLIN015 REPORT INSPECTION NO.: 99901020/87-01.

RESULTS:

PAGE 2 of 10 I

PLANT SITE APPLICABILITY:

(continued) Cook 1 & 2 (50-315/316); Cooper Station (50-290); Crystal River (50-302 ; Davis-Besse (50-346); Diablo Canyon (50-275/

323);Dresden 2 &'3 (50-237/249 ; Enrico Fermi (50-341); Fort St. Vrain 50-267); Ginna (50-244); Hatch (50-321); Hope Creek (50-354); LaSalle 1 & 2 50-373/374 ; Limerick 1 & 2 (50-352/353); Maine Yankee (50-309); McGuire 1 & 2 50-369/370 ; Millstone 1,2,&3.(50-245/3~46/423); Nine Mile Point 1 & 2 50-369/370 ; Oyster Creek 1 (50-219); Palo Verde 1, 2, & 3 (50-528/529/530);

Peach Bottom 2 & 3 (50-277/278); Perry (50-440); Pilgrim (50-293); Quad Cities 1 & 2 (50-254/265); Rancho Seco (50-312); Robinson (50-261); Salem (50-272);

San Onofre 1,2,&3(50-206/361/362); Seabrook(50-443);Shoreham(50-322);

I St. Lucie 1 & 2 (50-335/389); Summer (50,395);Susquehanna 1 & 2 (50-387/389),

Three Mile Island 1&2(50-289/320); Trojan (50-344); Turkey Point 3 A 4 (50-250/251); Vermont Yankee (50-271); Vogtle 1 & 2 (50-424/425); Washington-Nuclear (50-397);Waterford 3 (50-382); Watts Bar (50-391); Wolf Creek (50-482);andZion(50-295/304).

A.

VIOLATIONS:

Contrary to Section 21.21, " Notification," of 10 CFR Part 21, BISCO failed to establish a written procedure to implement the regulations of 10 CFR Part 21 as imposed by Section 206 of the Energy Reorganization Act of.1974.

B.-

NONCONFORMANCES:

None.

C.

UNRESOLVED ITEMS:

None.

0; STATUS OF PREVIOUS INSPECTION FINDINGS:

s 1.

Section D.3 of BISCO report No. 99901020/85-01, mentions a 1976 test that was conducted and accepted by American Nuclear Insurers (ANI) for various BISCO fire barrier penetration design configurations.

ANI later withdrew its acceptance of the test in a August 20, 1985 ANI letter transmitted to BTSCO and several nuclear generating stations (NGS). This issue was reviewed during this NRC inspection.

Discussed below are the background and conclusions of this review.

Discussion - The technical basis for the ANI acceptance of BISCO's October, 1976 9-inch silcone foam (SF) fire penetration seal testing was not fully documented and did not substantiate that the generic i

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ORGAN!ZATION: BRAND INDUSTRfAL SERVICES, INCORPORATED PARK RIDGE, ILLIN0IS i

-REFORT-INSPECTICH NO.:- 99901020/67-01 RESULTS:

FAGE 3 of 10 l

ASTM-E119 and UShRC requirements had been met. Specifically, a review of the test reports and discussions with Ahl and BISCO personnel determined that:

a.

Although no specific mention was made of the 9-inch SF penetration test failing the requirec hose stream test, statements within the report indicate that it did fail.

Therefore, ANI should not have accepted the particular configuration; b.

'ANI and BISCO have stated that a successful hose stream test was conducted on a second 9-inch SF specimen, as allowed by ASTH E-119, but according to ANI, "was never formally de'tu-mented," in 1976 when it was performed; c.

ANI-discovered the lack of objective evidence of the hose stream test in 1985, contacted BISCO and attempted a make-up test that failed; ANI subsequently notified ten NGS. facilities of their acceptance withdrawal. The letter stated that the failed test was acceptable.to the ANI for " insurance purposes only," but also stated their 2-1/2 hour rating acceptance may not be acceptable where a strict 3-hour rating is required; and d.

Current industry practice allows fire barrier installer to utilize other installers-' tested design configurations to substantiate their installations. This practice creates the i

possibility that there are additional NRC. licensees that utilized the failed October 1976 BISC0/ANI design configuration for their installed 9-inch SF installations, and are not aware of the problem, since ANI may or may not be their insurance 2

agency.

A related concern is the design parameters of other BISCO test reports. A review of three penetration seal test reports that BISCO stated would substantiate their recinded 1976 test acceptance by Ahl, were found to be very restrictive in their parameters; however, BISCO's statement in their ANI follow-up letter could imply that the NRC licensee's recinded penetration seals were adequate and no additional review was required. The test report numbers are:

515C0 Report No. 3001-03-B, dated May 19, 1560 BISCO Report No. 748-134, dated May 14, 1984 BISCO Report No. 748-183(3), dated August 9, 1985

I itGAh32ATf0N:'BRANDINDUSTR3ALSERVZCES,THCCRPORATED

^

PARK RIDGE, ILLIN0IS-REPORT INSPECTION

- NO. : 99901020/07-01 RESULTS:

PAGE 4 of 10 i

In letters dated August 20, 1985 to various NGS facilities, and in another letter dated August 20, 1985 to BISCO, ANI advised of its withdrawal of three previously accepted BISCO fire barrier penetration seal design configurations. The ANI letter indicated that the subject designs involved penetrations for cable and pipe sealed with 9-inches of BISCO SF-20. ANI indicated that its acceptance, which was previously issued based on 1976 testing, was being withdrawn because a review indicated available evidence was insufficient to support the 2-hour and 3-hour ratings for these particular designs.. SISCO and ANI stated thht only one design was of a concern.

The particular design configuration identified by ANI and BISCO is for cable tray penetrations filled with 9-inches of SF with no permanant dans installed. These are typically wall penetrations and are 3-hour rated. The ANI review was performed following a request by Rancho Seco personnel in 1984 or 1985 for ANI to provide them additional documentation of ANI's 1976 technical basis 'or its subsequent acceptance of SF penetration seals at their plant.

The original test of this cable tray configuration was one of a number of configurations tested at the same time for 31500.by ANI at the Portland Cement Association (PCA) Laboratories in Skokie Illinois. This particular test is discussed in a BISCO report dated October 1976.

The test report is referred to as PCA-76 for most applications. The test specimen passed the 3-hour fire endurance test of ASTH-E119 and its unexposed surface did not exceed the allcwable ASTM-E119. temperatures. However." flame through" occurred at 3-hours 1-minute and PCA-76 does not mention whether or not the hose stream test was performed, but references in other report sections indicate that it failed the required hose stream j

1 test.

Both BISCO and ANI have M ated that a hose stream test was performed on a second 9-inch SF specimen as allowed by ASTM-E119, and passed. ANI additionally states that the test was performed on the second specimen but that "no formal documentation was ever generated for the test."

Following the Rancho Seco request for additional test documentation to ANI, BISCG and ANI conducted a more severe fire endurance test for a make-up test. This test failed after 2-hours and 35 minutes and was the basis for ANI's Au9ust 20, 1985 letter. The test was more severe because the total cross sectional area of the cable was greater than the 1976 tests and additionally all of the cables had jackets of PVC which are more combustible than the original test cable jackets. The test was conducted at PCA on August 6, 1985.

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' ORGANIZATION:

BRAND INDUSTRIAL SERV 8CES, INCORPORATED PARK RIDGE, fLLINCIS REPORT INSPECTION NO.: 99901020/87-01 RESULTS:

PAGE 5 of 10 i

BISCO and ANI witnessed the test. The results are presented in

~

EISCO Test Report 746-103 (Specimen 2), dated August 6, 1985. The I

test assembly was subjected to the ASTM E-119 standard 3-hour fire endurance test and developed a burn through after 2-hours and 35 minutes. This was a failure and consequently no hose stream test was performed.

Therefore, as.a result of no formal documentation to show that the 1976 hose stream test.was performed, and the subsequent August 6, 1985 fire test failure, ANI issued their August 20, 1985 letter to ten nuclear plants that' BISCO stated here affected, see list below. The August 20, 1985 ANI letter states, in part:

a.

"Since 1975, American Nuclear Insurers has reviewed and accepted for property insurance purposes only, over 200 fire stop systems...."

b.

"We recently found insufficient evidence to support the ANI acceptance of te ting form issued to BISCO for test data, various(1976)

"In an effort to verify the proper rating of this system, we c.

conducted a fire test of a sample of the subject system at an independent test laboratory. The sample withstood the fire exposure prescribed in AS1N E-119 for a duration of 2-hours, 35 minutes...."

d.

"This fire stop system presents a substantial barrier to the passage of fire between fire areas and except for some unanticipated fire loading hazard, all existing systems are considered by ANI to be acceptable for property insurance purposes for the separation of areas...."

e.

"However, this system may not be adequate where there is a strict requirement for a 3-hour rated barrier for other than insurance purposes...." and f.

"If it is necessary to upgrade this fire stop system for a 3-hour fire rating, the following sugEested methods may be L

adequate:" a) " Apply a ANI/MAERP acce i

to the bottom side of vertical (floor)pted damming board seals and on both i

sides of horizontal (wall) seals;" or b) " Apply a protective coating over the foam that has been fire tested in accordance with the ANI/MAERP fire test standard for penetration seals...."

)

0RGANIZAT10ft: BRAND INDUSTR8AL SERVICES, INCORPORATED PARK RIDGE, ILLINOIS j

REPORT INSPECTION h0.: 99901020/67-01 RESULTS:

PACE 6 of 10 I

ANI transmitted their August 20, 1985 letters to the following NGS facilities:

SEAL INSTALLATION SEAL INSTALLED FLOOR DAMS IllSTALLED NAEE IN FLOORS LEFT BY BISCO-IN WALLS

  • VC Summer Yes Yes Yes Ranche Seco Yes Yes Yes Davis Besse Yes Yes Yes
  • Susquehanna Yes Yes Yes Hanford Yes Yes Yes Shoreham Yes Yes Yes
  • Comanche Peak Yes Yes Yes
  • Clinton Yes Yes Yes
  • Palo Verde Yes No Yes Trojan Yes Yes Yes

Note:

No wall dams were left in place for the above plants.

Subsequent to ANI issuing its August 20, 1985 acceptance withdrawal letters, BISCO issued a followup form letter.

BISCO stated that to the best of their knowledge only four of the plants noted above responded to the ANI letter. BISCO's form letter states, in part:

a.

"Recently you received correspondence from ANI recinding their acceptance of fire testing conducted on two cable tray blockout designs by BISCO."

b.

"The reason behind this action had to do with the large scale fire test that was conducted and because of its size requiring separate hose stream tests that were originally submitted to ANI and received their certified acceptance."

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  • ORGANIZATION: BRAND INDUSTRIAL SERVICES, INCORPORATED PARK RIDGE, ILLIN0!S i

REPORT INSPECTION NO.: 99901020/87-01 RESULTS:

PAGE 7 of 10 I-c.

" Subsequent to the test, BISCO experienced a fire at their facilities...and apparently during this time the subject hose stream test was either destroyed or lost. This was brought to light when ANI unable to locate their file copy, requested a replacement from BISCO."

d.

"ANI requested BISCO to conduct a new test to their present standards, which experienced a burn-through at 2-hours and 35 minutes. However, ANI has stated they will accept all fire barriers of this BISCO design..." and; e.

" BISCO has testing documentation that substantiates the fire seal design that failed the. ANI fire test standards, does meet and surpass the test standards of ASTM-E119 and the NRC."

In summary, it is perceived that some NRC licensees may be relying on ANI for overall acceptance; though ANI is looking at the fire barriers only in regard to insurance purposes and not NRC licensing requirements.

2.

NRC previously reviewed a 6-inch SF fire barrier issue regarding the Salem Unit 1 NGS facility. NRC report.99901020/85-01 concluded that the test data satisfactorily supported, as required by ASTM-E119, the installed subject seals at Salem; however, the previous NRC report did not address the required ASTM-E119 hose stream tests.

Discussion - It was revealed that an NRC fire protection staff review had approved a Salem deviation request to its Appendix A to the NRC Branch Technical Position 9.5-1 guidelines.

The deviation acceptance i

by the NRC exempted Salem from having to perform a hose stream test following its fire endurance test. Therefore, the: Salem Unit 1 NGS

~

facility appears to have an adequate technical basis for its installed 6-inch SF seais and are acceptable according to the NRC criteria.

However, similar to issue 1. above, if these two test reports, SEMCO PR-55 (6/76) and PSEEG (AISCO 6/76), were adopted by use for seal qualifications at another facility, the potential would exist for an unqualified basis. Specifically:

a.

The ASTM-E119 required hose stream test would have to be performed or exempted by the NRC; i

'0RGAhlZATION: BRAND 3NDUSTRfAL SERV 3CES, fNCCRPORATED PARK RIDGE, ILLIN0IS e

REPORT INSPECTION NO.:

99901020/87-01 RESULTS:

PAGE 8 of 10 b.

The 6-inch SF seal as built configurations must have the daming boards installed on both sides as shown in the tested configurations.

E.

OTHER FINDINGS OR COMMENTS:

1.

10 CFR Part 21 Observations determined that BISCO did not have the required proce-dure posted that they adopted pursuant to the provisions of 10 CFR Part 21.

Discussions were conducted with B1500 concerning their requirements under 10 CFR Part 21 and it was revealed that they had not established the required procedure.

Within three weeks after the inspection was ccepleted, BISCO provided the inspector with a copy of their 10 CFR Part 21 procedure that was generated in compliance with the regulations.

2.

Facility Tour BISCO provided the NRC inspectors a tour of their warehouse facilities.

During the tour, it was noticed that some of BISCO's P&TE devices were not currently valid regarding calibration due dates.

However, a review of their QA manual determined that the specific devices were not required to be calibrated for use by their QC personnel.

It was noted to the QA manager that the area's that we noted as needing calibraton control appeared to. be an important link in the BISCO process control; however, BISCO stated that the final verification was performed by QC.

i 3.

V.C. Sunmer Nuclear Plant Facility The South Carolina Electric and Gas Company's (SCEG) V.C. Summer nuclear plant facility was visited on February 25-27, 1987 as a result of this inspection. Some of the information obtained during this inspection, in conjunction with previous NRC information, j

indicated that the potential exists for a nuclear plant to have penetration seal test reports and documentation that will not l

substantiate the validity of the particular plants installed penetration seal configurations. Therefore, the NRC performed a follow-up inspection at the SCEG facility.

l

l CRGAhlZATf0N: BRAND INDUSTRIAL SERVICES, INC'ORPORATED PARK RIDGE, ILLIh015 l

l REPORT INSPECTION l

NO.: 9990I020/87-01 RESULTS:

PAGE 9 of 10 It was determined, from a review of test report documentation, in-plant installed penetration seal dimensional measurements of blockouts, and cable tray / conduit sizes that some design parameter values in installed penetration seals exceed the values or range of values validated by the test report being cited to qualify these particular installed penetration seal design configurations.

SCEG is taking correct;ve action and performing a review of their fire protection system. This effort is being coordinated through the NRC Region II office.

F.

PERSONS CONTACTED:

81500:

  • Clayton Erown, President
  • Thomas Gilmore, Vice-President
  • Frank Barta, QA Manager Delores Lott, QC Supervisor Gary Fedor, Development Engineer USNRC:

D. Kubicki, NRR/PBPE L. Whitney, IE/CPRB J. Wermiel, NRR/PBPE

  • Attended Exit Meeting

'ANI:

P. Giaccaglia, Senior Staff Engineer W. holmes, Director / Technical Review J. Carney, Vice President / Technical Review PCA:

R. Hall, Engineer ASTM:

R. Sansone, Staff Engineer

ORGAhlZATION:. BRAND INDUSTRIAL SERV 2CES, INCORP0 RATED PARK RIDGE, ILLIN0IS REPORT INSPECTION NO.:

99901020/87-01 RESULTS:

PAGE 10 of 10 G.

, DOCUMENTS EXAMINED:

1.

ANI letter, August 20, 1985 - withdrawal of previous acceptance.

2.

BISCO QA Manual - certain sections.

3.

BISCO Procedure, dated February 5, 1987 - 10 CFR Part 21 Procedure.

4.

BISCO letter, dated September 16, 1985 - to TUGCO, following the ANI August 20, 1985 letter.

5.

BISCO letter, dated November 13, 1904 - BISCO response to TUGCC letter No. CPPA-41,594.

6.

ANI Bulletin. February 1983 - Fire stop systems, QA sign off.

7.

NRC Appendix A - to Branch Technical Position 9.5-1, dated Au5ust 23, 1976.

8.

NRC Standard Review Plan - 9.5-1, dated July 1981.

1 9.

NRC Generic letter 10, dated April 25, 1986.

10. BISCO Test Report

," Fire Endurance Test in BISCO Penetration Seal Systems in a Concrete Floor using B1500 Systems SF-20 ano SF-150L Silicone Polymers," dated October 1976 (PCA-76).

11. BISCOTestReport(748-183-(Specimen 2and3),"3-hourFire Test of Two Cable Tray Seal Configuration," dated August 6, 1985

[

and August 9, 1985, respectively.

12. BISCO Test for Public Service Electric and Gas Company (PSE&G) -

undated, regarding six inch SF-20 seals at Salem (1976).

i

13. SEMCO Test Report "SEMCO PR 855 RTV Silicone foam Sealant in l

Cencrete Floor," dated June 28, 1976.

14. BISCO Test Report #748-134, dated May 14, 1984. Overall size 2.5' x 2.5' that was divided ir, half. One side with SF-20 and the other with SE-Foam, both sides having one caole tray and one conduit.
15. BISCO Test Report (3001-003, dated May 19, 1980. Overall size 2.5' x 2.5', wall, with 9" of SF-20 and no dam.

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