Information Notice 1988-04, Inadequate Qualification and Documentation of Fire Barrier Penetration Seals: Difference between revisions

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| issue date = 02/05/1988
| issue date = 02/05/1988
| title = Inadequate Qualification and Documentation of Fire Barrier Penetration Seals
| title = Inadequate Qualification and Documentation of Fire Barrier Penetration Seals
| author name = Rossi C E
| author name = Rossi C
| author affiliation = NRC/NRR
| author affiliation = NRC/NRR
| addressee name =  
| addressee name =  
Line 14: Line 14:
| page count = 9
| page count = 9
}}
}}
{{#Wiki_filter:UNITED STATES NUCLEAR REGULATORY
{{#Wiki_filter:UNITED STATES


COMMISSION
===NUCLEAR REGULATORY COMMISSION===
OFFICE OF NUCLEAR REACTOR REGULATION


===OFFICE OF NUCLEAR REACTOR REGULATION===
WASHINGTON, D.C.
WASHINGTON, D.C. 20555 February 5, 1988 NRC INFORMATION


NOTICE NO. 88-04: INADEQUATE
20555


QUALIFICATION
===February 5, 1988===
NRC INFORMATION NOTICE NO. 88-04: INADEQUATE QUALIFICATION AND DOCUMENTATION


===AND DOCUMENTATION===
===OF FIRE BARRIER PENETRATION SEALS===
OF FIRE BARRIER PENETRATION
 
SEALS


==Addressees==
==Addressees==
:
:
All holders of operating
All holders of operating licenses or construction permits for nuclear power
 
licenses or construction


permits for nuclear power reactors.
reactors.


==Purpose==
==Purpose==
: This notice is to alert addressees
:
This notice is to alert addressees that some installed fire barrier penetration


that some installed
seal designs may not be adequately qualified for the design rating of the


fire barrier penetration
penetrated fire barriers. It is expected that recipients will review this


seal designs may not be adequately
information for applicability and consider actions, if appropriate, to preclude


qualified
a similar problem and correct existing problems at their facilities.


for the design rating of the penetrated
However, suggestions contained in this information notice do not constitute new


fire barriers.
NRC requirements; therefore, no specific action or written response is required.


It is expected that recipients
==Description of Circumstances==
:
The NRC has been reviewing fire barrier penetration seal designs installed in


will review this information
several nuclear power plants. The reviews focused on whether the installed


for applicability
configuration was qualified by adequate testing and documentation.


and consider actions, if appropriate, to preclude a similar problem and correct existing problems at their facilities.
The current NRC review was prompted by reports, inspection findings, allegations, and other information that indicated the possibility that NRC requirements for


However, suggestions
fire barrier penetration seals were not being met in all aspects.


contained
The review


in this information
included:
evaluations of fire barrier penetration seal specifications and pro- cedures developed by licensees, licensee agents, and licensee contractors;
evaluations of various fire barrier penetration seal tests and test data; and


notice do not constitute
inspections of various fire barrier penetration seal designs and installations.


new NRC requirements;
The types of concerns identified to date and mentioned below are related to weak- nesses in the implementation of NRC requirements and guidelines as related to
therefore, no specific action or written response is required.Description


of Circumstances:
fire barrier penetration seal design qualification.
The NRC has been reviewing


fire barrier penetration
The staff identified instances where installed fire barrier penetration seal


seal designs installed
designs could not be verified as qualified for the design rating of the pene- trated fire barrier. In some cases,-test qualification documentation was not


in several nuclear power plants. The reviews focused on whether the installed configuration
8802020228


was qualified
IN 88-04
-:
February 5, 1988 available. In other cases, qualification test documentation was available but


by adequate testing and documentation.
incomplete or inadequate because all qualification requirements had not been


The current NRC review was prompted by reports, inspection
satisfied or the installed seal design configuration or design parameters were


findings, allegations, and other information
significantly different from the tested seal.


that indicated
The NRC review also has identified a current practice that can affect the


the possibility
qualification status of installed seals.


that NRC requirements
===Plant modifications are being made===
that require running new cable and conduits through existing penetration seals.


for fire barrier penetration
These modifications are generally being made without an associated technical


seals were not being met in all aspects. The review included:
review to ensure that the resulting penetration seal design configuration or
evaluations


of fire barrier penetration
design parameters are consistent with those validated by initial qualification


seal specifications
tests. Over a period of time, numerous minor modifications to the same area


and pro-cedures developed
could cumulatively result in a degraded fire barrier rating.


by licensees, licensee agents, and licensee contractors;
Discussion:
evaluations
NRC requirements and guidelines for fire barrier penetration seals are con- tained in various documents, including Appendix R to 10CFR 50, Appendix A


of various fire barrier penetration
to Branch Technical Position (BTP) APCSB 9.5-1, "Guidelines for Fire Protec- tion for Nuclear Power Plants Docketed Prior to July 1, 1976," and NUREG-0800,
Standard Review Plan.


seal tests and test data; and inspections
===The extent to which these requirements or guidelines===
are applicable to a specific plant depends on plant age, commitments established


of various fire barrier penetration
by the licensee in developing the fire protection plan, the staff safety evalua- tion reports (SERs) and supplements, and the license conditions pertaining to


seal designs and installations.
fire protection.


The types of concerns identified
The goal is to provide a fire barrier penetration seal that will remain in


to date and mentioned
place and retain its integrity when subjected to an exposure fire, and subse- quently, a fire suppressing agent. This will provide reasonable assurance that


below are related to weak-nesses in the implementation
the effects of a fire are limited to discrete fire areas and that one division


of NRC requirements
of safe-shutdown-related systems will remain free of fire damage.


and guidelines
A number of licensees have conducted a comprehensive.assessment of the adequacy


as related to fire barrier penetration
of in-plant fire barrier penetration seals. Their efforts began by determining


seal design qualification.
which specific NRC guidelines/requirements apply and which specific commitments


The staff identified
were made to respond to those guidelines or requirements. Typically, in-plant


instances
seal assemblies were surveyed to catalogue the various types of existing seal


where installed
configurations.


fire barrier penetration
Finally, the documentation was analyzed to confirm that


seal designs could not be verified as qualified
in-plant designs were fully qualified by a fire test and were installed in a


for the design rating of the pene-trated fire barrier. In some cases,-test
proper manner.


qualification
If these efforts revealed instances where seals were not installed where re- quired, were not installed properly, or were not qualified by a standard fire


documentation
test, then the licensees have considered the seals degraded and have imple- mented compensatory measures, such as fire watch patrols, per the appropriate


was not 8802020228 IN 88-04 -: February 5, 1988 available.
technical specifications or administrative procedures.


In other cases, qualification
===These measures remain===
in force pending final resolution of the issue.


test documentation
===Final resolution may include===
replacing existing penetration seals with fully qualified seals, qualifying


was available
in-plant seal assemblies by supplemental fire tests, and justifying in-plant


but incomplete
configuration by fire hazards/safe shutdown analysis.


or inadequate
IN 88-04 February 5, 1988 Appendix A contains a summary of various technical considerations that have


because all qualification
been used for evaluating the qualification adequacy of fire barrier penetration


requirements
seal designs and installations, associated testing, and test data.


had not been satisfied
No specific action or written response is required by this information notice.


or the installed
If you have questions about this matter, please contact one of the technical


seal design configuration
contacts listed below or the Regional Administrator of the appropriate NRC


or design parameters
regional office.


were significantly
a~r'es E. Ross ,Director


different
===Division of Operational Events Assessment===
Office of Nuclear Reactor Regulation


from the tested seal.The NRC review also has identified
Technical Contact(s): Dennis Kubicki, NRR


a current practice that can affect the qualification
(301) 492-0825


status of installed
===Joseph Petrosino, NRR===
(301) 492-0979 Attachments:
1. Appendix A - Summary of Existing Staff


seals. Plant modifications
===Guidance Related to Fire Barrier===
Penetration Seals


are being made that require running new cable and conduits through existing penetration
2. List of Recently Issued NRC Information Notices


seals.These modifications
===Attachment 1===
IN 88-04


are generally
===February 5, 1988 APPENDIX A===
SUMMARY OF EXISTING STAFF GUIDANCE RELATED


being made without an associated
===TO FIRE BARRIER PENETRATION SEALS===
A. General Considerations Concerninq the Use of Test Results To Qualify Fire


technical review to ensure that the resulting
===Barrier Penetration Seal Designs===
The (fire barrier seal) test specimen shall be truly representative of the


penetration
construction for which classification is desired, as to materials, work- manship, and details such as dimensions of parts, and shall be built under


seal design configuration
conditions representative of those obtaining as practically applied in


or design parameters
building construction and operation. The physical properties of the


are consistent
materials and2ingredients used in the test specimen shall be determined


with those validated
and recorded.


by initial qualification
===B. Seal Acceptance Criteria===
1. The fire resistance rating of the penetration seal should bS equiva- lent to the rating of the barrier in which it is installed.


tests. Over a period of time, numerous minor modifications
2. The fire resistance rating of the penetration seal should be deter- mined by a4standard fire test (i.e., ASTM E-814, ASTM E-119 or


to the same area could cumulatively
IEEE-634).


result in a degraded fire barrier rating.Discussion:
3. The test should be conducted by an independent, recognized testing
NRC requirements


and guidelines
authority.


for fire barrier penetration
The tested assembly should be representative of in-plant


seals are con-tained in various documents, including
assemblies. The exposure fire should correspond to at least the time- temperature curve of ASTM E-119. Thermocouples should be positioned


Appendix R to 10CFR 50, Appendix A to Branch Technical
at representative locations on the cold side of the tested assembly


Position (BTP) APCSB 9.5-1, "Guidelines
(including the interface of seal material and through penetrations).


for Fire Protec-tion for Nuclear Power Plants Docketed Prior to July 1, 1976," and NUREG-0800, Standard Review Plan. The extent to which these requirements
The cold-side temperature should not exceed 2500F above ambient during


or guidelines
the test or 3250F maximum, although higher temperatures at through


are applicable
penetrations are permitted when justified in terms of cable insulation


to a specific plant depends on plant age, commitments
ignitability. There should be no burn-through of the seal during the


established
test, nor the passage of hot gases sufficient to ignite cotton waste


by the licensee in developing
material. The assembly should withstand t e effects of a hose stream, as stipulated in the standard test method.


the fire protection
4. The seals should be installed by qualified individuals.6
5. Appropyiate quality assurance/quality control methods should be in


plan, the staff safety evalua-tion reports (SERs) and supplements, and the license conditions
force.


pertaining
6. Fire barrier penetrations that must maintain environmental isolation


to fire protection.
or pressure differentials should be qualified by test to maintain the


The goal is to provide a fire barrier penetration
barrier integrity under such conditions.


seal that will remain in place and retain its integrity
===Attachment 1===
IN 88-04


when subjected
===February 5, 1988 C. Hose Stream Testing9===
1. Hose stream testing is a requirement for all fire barrier penetration


to an exposure fire, and subse-quently, a fire suppressing
seal qualification testing, regardless of whether the penetration


agent. This will provide reasonable
seal is for a wall or a ceiling or a floor.


assurance
2. Hose stream testing should be performed on tested specimens that have


that the effects of a fire are limited to discrete fire areas and that one division of safe-shutdown-related
successfully withstood the fire endurance test requirements.


systems will remain free of fire damage.A number of licensees
3.


have conducted
The hose stream shall be delivered in one of the following ways:
a 1-1/2-inch nozzle set at a discharge angle of 300 with a nozzle


a comprehensive.assessment
pressure of 75 psi and a minimum discharge of 75 gpm with the tip


of the adequacy of in-plant fire barrier penetration
of the nozzle a maximum of 5 ft from the exposed face; a 1-1/2-inch


seals. Their efforts began by determining
nozzle set at a discharge angle of 150 with a nozzle pressure of 75 psi and a minimum discharge of 75 gpm with the tip of the nozzle a


which specific NRC guidelines/requirements
maximum of 10 ft from the exposed face; a 2-1/2-inch national stan- dard playpipe equipped with 1-1/8-inch tip, nozzle pressure of 30 psi, located 20 ft from the exposed face.


apply and which specific commitments
4. The duration of the hose stream test should meet the minimum require- ments specified in ASTM E-119 for fire barriers. During hose stream


were made to respond to those guidelines
testing, the fire barrier penetration seal should remain intact and


or requirements.
should not allow a projection of water beyond the unexposed surface.


Typically, in-plant seal assemblies
D.


were surveyed to catalogue
===Deviations10===
Deviations from NRC requirements or accepted industry standards for fire


the various types of existing seal configurations.
barrier penetration seals should be technically substantiated as part of


Finally, the documentation
the review and approval of the fire protection plan or in other separate


was analyzed to confirm that in-plant designs were fully qualified
formal correspondence. Supplemental guidance is provided in Generic


by a fire test and were installed
Letter 86-10.


in a proper manner.If these efforts revealed instances
References


where seals were not installed
1.


where re-quired, were not installed
"The design of fire barriers for horizontal and vertical cable trays


properly, or were not qualified
should, as a minimum, meet the requirements of ASTM E-119, Fire Test


by a standard fire test, then the licensees
of Building Construction and Materials, including the hose stream test."
[Section D.3.(d) of Appendix A to BTP APCSB 9.5-1].


have considered
"Penetration seal designs shall utilize only noncombustible materials and


the seals degraded and have imple-mented compensatory
shall be qualified by tests that are comparable to tests used to rate fire


measures, such as fire watch patrols, per the appropriate
barriers."
(Section III.M of Appendix R to 10 CFR Part 50).


technical
"The penetration qualification tests should use the time temperature


specifications
exposure curve specified by ASTM E-119."
(Section C.5.a. of BTP CMEB


or administrative
9.5-1).


procedures.
-Attachment 1 IN 88-04 February 5, 1988 2. ASTM E-119, "Fire Test of Building Construction and Materials."
3. Section D.3.(d) of Appendix A to BtP APCSB 9.5-1.


These measures remain in force pending final resolution
4. Section III.M. of Appendix R to 10 CFR Part 50.


of the issue. Final resolution
5. ASTM E-119, "Fire Test of Building Construction and Materials."
6. Section C of Appendix A to BTP APCSB 9.5-1, Section C.4 of BTP CMEB 9.5-1.


may include replacing
7. Ibidem.


existing penetration
8. Section C.5.a.(3) of BTP CMEB 9.5-1.


seals with fully qualified
9. Section III.M of Appendix R to 10 CFR Part 50, Section C.5.a of BTP CMEB


seals, qualifying
9.5-1.


in-plant seal assemblies
10. Generic Letter 86-10.


by supplemental
r


fire tests, and justifying
A


in-plant configuration
ment 2


by fire hazards/safe
===February S. 1988===
Pige 1 of I


shutdown analysis.
===LIST Of RECENTLY ISSUED===
NRC INFORMATION NOTICES


IN 88-04 February 5, 1988 Appendix A contains a summary of various technical
Lntonuatlol


considerations
Dats of


that have been used for evaluating
Notice No.


the qualification
SubJect


adequacy of fire barrier penetration
Issuance


seal designs and installations, associated
Issued to


testing, and test data.No specific action or written response is required by this information
88-03 Cracks in Shroud Support


notice.If you have questions
2/2/88


about this matter, please contact one of the technical contacts listed below or the Regional Administrator
===All holders of OLs===
Access Hole Cover WVlds


of the appropriate
or CPs for BWRs.


NRC regional office.a~r'es E. Ross ,Director Division of Operational
88.02 Lost or Stolen Gauges,  
2/2/88


===Events Assessment===
===All NRC licensees===
Office of Nuclear Reactor Regulation
authorized to possess


Technical
gauges under a


Contact(s):
specific or general
Dennis Kubicki, NRR (301) 492-0825 Joseph Petrosino, NRR (301) 492-0979 Attachments:
1. Appendix A -Summary of Existing Staff Guidance Related to Fire Barrier Penetration


Seals 2. List of Recently Issued NRC Information
license.


Notices
88.01 Safety Injection Pipe


Attachment
1/27/88


1 IN 88-04 February 5, 1988 APPENDIX A SUMMARY OF EXISTING STAFF GUIDANCE RELATED TO FIRE BARRIER PENETRATION
===All holders of OLs===
Failus


SEALS A. General Considerations
ror


Concerninq
===CPs for nuclear===
power reactors.


the Use of Test Results To Qualify Fire Barrier Penetration
86-81, Broken External Closure


Seal Designs The (fire barrier seal) test specimen shall be truly representative
1/11/88


of the construction
===All holders of OMs===
Supp. 1 Springs on Atwood & Iorrill


for which classification
or CPs for nuclear


is desired, as to materials, work-manship, and details such as dimensions
main Steam Isolation Valves


of parts, and shall be built under conditions
power reactors.


representative
87-67 Lessons Learned from


of those obtaining
12/31/87


as practically
===All holders of OLs===
Reional Inspections of


applied in building construction
or CPs for nuclear


and operation.
Licenses Action$ ia Response


The physical properties
power reactors.


of the materials
to It Bolletin


and 2 ingredients
a0>
-
87-65 Inappropriate Application


used in the test specimen shall be determined
12/31/87


and recorded.B. Seal Acceptance
===All holders of OLs===
of Cofher1i1-l6rads


Criteria 1. The fire resistance
or CPs for nuclear


rating of the penetration
Components


seal should bS equiva-lent to the rating of the barrier in which it is installed.
powr reacton.


2. The fire resistance
87-28, Alp Systems Probi e


rating of the penetration
at


seal should be deter-mined by a 4 standard fire test (i.e., ASTM E-814, ASTM E-119 or IEEE-634).
12/28/87


3. The test should be conducted
===All holders of Ms===
Supp. 1 U.S. 1ight Water Reactors


by an independent, recognized
or CPs for nuclear


testing authority.
power reactors.


The tested assembly should be representative
87-65 Plant Operation Beyond


of in-plant assemblies.
12/23/87


The exposure fire should correspond
===All holders of OLs===
Analyzed Conditions


to at least the time-temperature
or CPs for nuclear


curve of ASTM E-119. Thermocouples
power reactors.


should be positioned
87-64 Conviction for Falsification 12/22/87


at representative
===All nuclear power===
of Security Training Records


locations
reactor facilities


on the cold side of the tested assembly (including
holding an OL or CP


the interface
and all major fuel


of seal material and through penetrations).
facility licensees.


The cold-side
ON : Operating License


temperature
CP


should not exceed 250 0 F above ambient during the test or 325 0 F maximum, although higher temperatures
* Construction Permit


at through penetrations
 I


are permitted
:


when justified
===UNITED STATES===
NUCLEAR REGULATORY COMAISSION


in terms of cable insulation
===WASHINGTON, D.C. 20555===
OFFICIAL BUSINESS


ignitability.
PENALTY FOR PRIVATE USE $300


There should be no burn-through
===FIRST CLASS MAIL===
POSTAGE 6 FEES PAID


of the seal during the test, nor the passage of hot gases sufficient
USNRC


to ignite cotton waste material.
PERMIT No. 0-E7
120555026886
1 1CO1CY1FB11S1 US NRC-OARM-IRM


The assembly should withstand
===DIV OF INFO SUP SVCS===
MICROGRAPHICS SPECIALIST


t e effects of a hose stream, as stipulated
===RECORDS SERVICES BRANCH===
042 WASHINGTON


in the standard test method.4. The seals should be installed
DC


by qualified
20555


individuals.
IN 88-04


6 5. Appropyiate
===February 5, 1988===
Appendix A contains a summary of various technical considerations that have


quality assurance/quality
been used for evaluating the qualification adequacy of fire barrier penetration


control methods should be in force.6. Fire barrier penetrations
seal designs and installations, associated testing, and test data.


that must maintain environmental
===No specific action or===
If you have questions


isolation or pressure differentials
contacts listed below


should be qualified
regional office.


by test to maintain the barrier integrity
written response is required by this information notice.


under such conditions.
about this matter, please contact one of the technical


Attachment
or the Regional Administrator of the appropriate NRC


1 IN 88-04 February 5, 1988 C. Hose Stream Testing9 1. Hose stream testing is a requirement
===Charles E. Rossi, Director===
Division of Operational Events Assessment


for all fire barrier penetration
===Office of Nuclear Reactor Regulation===
Technical Contact(s):


seal qualification
===Dennis Kubicki, NRR===
(301) 492-0825


testing, regardless
===Joseph Petrosino, NRR===
(301) 492-0979 Attachments:
1. Appendix A - Summary of Existing Staff


of whether the penetration
===Guidance Related to Fire Barrier===
Penetration Seals


seal is for a wall or a ceiling or a floor.2. Hose stream testing should be performed
2. List of Recently Issued NRC Information Notices


on tested specimens
*Transmitted by memo to C. E. Rossi from J. G. Partlow dated 12/21/87 IC


that have successfully
"
m-a


withstood
-044
%i'
*SEE PREVIOUS


the fire endurance
*PPMB:ARM


test requirements.
TechEd


3. The hose stream shall be delivered
01/15/88
*OGCB:DOEA:NRF


in one of the following
RJKiessel


ways: a 1-1/2-inch
01/14/88
*VIB:DRIS:NRR


nozzle set at a discharge
JPetrosino


angle of 300 with a nozzle pressure of 75 psi and a minimum discharge
12/15/87 CONCURRENCES


of 75 gpm with the tip of the nozzle a maximum of 5 ft from the exposed face; a 1-1/2-inch
4
*
*C/OGCB:DOEA:NR


nozzle set at a discharge
R


angle of 150 with a nozzle pressure of 75 psi and a minimum discharge
R


of 75 gpm with the tip of the nozzle a maximum of 10 ft from the exposed face; a 2-1/2-inch
CHBerlinger


national stan-dard playpipe equipped with 1-1/8-inch
a


tip, nozzle pressure of 30 psi, located 20 ft from the exposed face.4. The duration of the hose stream test should meet the minimum require-ments specified
01/21/88
0245-/88 t *D/DEST:NRR


in ASTM E-119 for fire barriers.
*ADT/DEST:NRR


During hose stream testing, the fire barrier penetration
*D/DRIS:NRR


seal should remain intact and should not allow a projection
*DD/DRIS:NRR


of water beyond the unexposed
LShao


surface.D. Deviations
JRichardson


1 0 Deviations
JGPartlow


from NRC requirements
BKGrimes


or accepted industry standards
12/17/87
12/16/87
12/16/87
12/16/87
*ASC/VIB:DRIS:NRR*AC/VIB:DRIS:NRR*ECEB:DEST:NRR*BC/ECEB:DEST:NRR


for fire barrier penetration
EBaker


seals should be technically
JStone


substantiated
DKubicki


as part of the review and approval of the fire protection
CMcCracken


plan or in other separate formal correspondence.
12/15/87
12/18/87
12/16/87
12/16/87


Supplemental
IN 88-XX


guidance is provided in Generic Letter 86-10.References
January XX, 1988 Appendix A contains a summary of various technical considerations that have


1. "The design of fire barriers for horizontal
been used for evaluating the qualification adequacy of fire barrier penetration


and vertical cable trays should, as a minimum, meet the requirements
seal designs and installations, associated testing, and test data.


of ASTM E-119, Fire Test of Building Construction
No specific action or written response is required by this information notice.


and Materials, including
If you have questions about this matter, please contact the Regional Adminis- trator of the appropriate NRC regional office or this office.


the hose stream test."[Section D.3.(d) of Appendix A to BTP APCSB 9.5-1]."Penetration
===Charles E. Rossi, Director===
Division of Operational Events Assessment


seal designs shall utilize only noncombustible
===Office of Nuclear Reactor Regulation===
Technical Contact(s): Dennis Kubicki, NRR


materials
(301) 492-9424


and shall be qualified
===Joseph Petrosino, NRR===
(301) 492-4316 Attachments:
1. Appendix A - Summary of Existing Staff


by tests that are comparable
===Guidance Related to Fire Barrier===
Penetration Seals


to tests used to rate fire barriers." (Section III.M of Appendix R to 10 CFR Part 50)."The penetration
2. List of Recently Issued NRR Information Notices


qualification
*Transmitted by memo to C. E. Rossi from J. G. Partlow dated 12/21/87
*SEE PREVIOUS CONCURRENCES


tests should use the time temperature
PPMB:ARM


exposure curve specified
C/OGCB: DOEA:NRR D/DOEA:NRR


by ASTM E-119." (Section C.5.a. of BTP CMEB 9.5-1).
TechEdM


-Attachment
CHBerlinger


1 IN 88-04 February 5, 1988 2. ASTM E-119, "Fire Test of Building Construction
CERossi


and Materials." 3. Section D.3.(d) of Appendix A to BtP APCSB 9.5-1.4. Section III.M. of Appendix R to 10 CFR Part 50.5. ASTM E-119, "Fire Test of Building Construction
01/1</88  
 
01/ /88  
and Materials." 6. Section C of Appendix A to BTP APCSB 9.5-1, Section C.4 of BTP CMEB 9.5-1.7. Ibidem.8. Section C.5.a.(3)
01/ /88 OGCB:DOEA:  
of BTP CMEB 9.5-1.9. Section III.M of Appendix R to 10 CFR Part 50, Section C.5.a of BTP CMEB 9.5-1.10. Generic Letter 86-10.r
V *D/DEST:NRR
 
A ment 2 February S. 1988 Pige 1 of I LIST Of RECENTLY ISSUED NRC INFORMATION
 
NOTICES Lntonuatlol
 
Dats of Notice No. SubJect Issuance Issued to 88-03 Cracks in Shroud Support 2/2/88 All holders of OLs Access Hole Cover WVlds or CPs for BWRs.88.02 Lost or Stolen Gauges, 2/2/88 All NRC licensees authorized
 
to possess gauges under a specific or general license.88.01 Safety Injection
 
Pipe 1/27/88 All holders of OLs Failus ror CPs for nuclear power reactors.86-81, Broken External Closure 1/11/88 All holders of OMs Supp. 1 Springs on Atwood & Iorrill or CPs for nuclear main Steam Isolation
 
Valves power reactors.87-67 Lessons Learned from 12/31/87 All holders of OLs Reional Inspections
 
of or CPs for nuclear Licenses Action$ ia Response power reactors.to It Bolletin a0> -87-65 Inappropriate
 
Application
 
12/31/87 All holders of OLs of Cofher1i1-l6rads
 
or CPs for nuclear Components
 
powr reacton.87-28, Alp Systems Probi e at 12/28/87 All holders of Ms Supp. 1 U.S. 1ight Water Reactors or CPs for nuclear power reactors.87-65 Plant Operation
 
Beyond 12/23/87 All holders of OLs Analyzed Conditions
 
or CPs for nuclear power reactors.87-64 Conviction
 
for Falsification
 
12/22/87 All nuclear power of Security Training Records reactor facilities
 
holding an OL or CP and all major fuel facility licensees.
 
ON : Operating
 
License CP
 
* Construction
 
PermitI : UNITED STATES NUCLEAR REGULATORY
 
COMAISSION
 
WASHINGTON, D.C. 20555 OFFICIAL BUSINESS PENALTY FOR PRIVATE USE $300 FIRST CLASS MAIL POSTAGE 6 FEES PAID USNRC PERMIT No. 0-E7 120555026886
1 1CO1CY1FB11S1 US NRC-OARM-IRM
 
DIV OF INFO SUP SVCS MICROGRAPHICS
 
SPECIALIST
 
RECORDS SERVICES BRANCH 042 WASHINGTON
 
DC 20555 IN 88-04 February 5, 1988 Appendix A contains a summary of various technical
 
considerations
 
that have been used for evaluating
 
the qualification
 
adequacy of fire barrier penetration
 
seal designs and installations, associated
 
testing, and test data.No specific action or If you have questions contacts listed below regional office.written response is required by this information
 
notice.about this matter, please contact one of the technical or the Regional Administrator
 
of the appropriate
 
NRC Charles E. Rossi, Director Division of Operational
 
===Events Assessment===
Office of Nuclear Reactor Regulation
 
Technical
 
Contact(s):
Dennis Kubicki, NRR (301) 492-0825 Joseph Petrosino, NRR (301) 492-0979 Attachments:
1. Appendix A -Summary of Existing Staff Guidance Related to Fire Barrier Penetration
 
Seals 2. List of Recently Issued NRC Information
 
Notices*Transmitted
 
by memo to C. E. Rossi from J. G.Partlow dated 12/21/87 IC " m-a -044 %i'*SEE PREVIOUS*PPMB:ARM TechEd 01/15/88*OGCB:DOEA:NRF
 
RJKiessel 01/14/88*VIB:DRIS:NRR
 
JPetrosino
 
12/15/87 CONCURRENCES
 
4 **C/OGCB:DOEA:NR
 
R R CHBerlinger
 
a 01/21/88 0245-/88 t *D/DEST:NRR


*ADT/DEST:NRR
*ADT/DEST:NRR
Line 714: Line 687:
*DD/DRIS:NRR
*DD/DRIS:NRR


LShao JRichardson
RJKiessel IjNA
 
JGPartlow


BKGrimes 12/17/87 12/16/87 12/16/87 12/16/87*ASC/VIB:DRIS:NRR*AC/VIB:DRIS:NRR*ECEB:DEST:NRR*BC/ECEB:DEST:NRR
LShao


===EBaker JStone DKubicki CMcCracken===
JRlchardson
12/15/87 12/18/87 12/16/87 12/16/87 IN 88-XX January XX, 1988 Appendix A contains a summary of various technical


considerations
JGPartlow


that have been used for evaluating
BKGrimes


the qualification
O1/ll/88
12/17/87
12/16/87
12/16/87
12/16/87
*VIB:DRIS:NRR *ASC/VIB:DRIS:NRR*AC/VIB:DRIS:NRR*ECEB:DEST:NRR*BC/ECEB:DEST:NRR


adequacy of fire barrier penetration
JPetrosino
 
seal designs and installations, associated
 
testing, and test data.No specific action or written response is required by this information
 
notice.If you have questions
 
about this matter, please contact the Regional Adminis-trator of the appropriate
 
NRC regional office or this office.Charles E. Rossi, Director Division of Operational
 
===Events Assessment===
Office of Nuclear Reactor Regulation


Technical
EBaker


Contact(s):
JStone
Dennis Kubicki, NRR (301) 492-9424 Joseph Petrosino, NRR (301) 492-4316 Attachments:
1. Appendix A -Summary of Existing Staff Guidance Related to Fire Barrier Penetration


Seals 2. List of Recently Issued NRR Information
DKubicki


Notices*Transmitted
CMcCracken
 
by memo to C. E. Rossi from J. G. Partlow dated 12/21/87*SEE PREVIOUS CONCURRENCES
 
PPMB:ARM C/OGCB: DOEA:NRR D/DOEA:NRR
 
TechEdM CHBerlinger
 
CERossi 01/1</88 01/ /88 01/ /88 OGCB:DOEA:
V *D/DEST:NRR
 
*ADT/DEST:NRR
 
*D/DRIS:NRR
 
*DD/DRIS:NRR
 
RJKiessel
 
IjNA LShao JRlchardson
 
JGPartlow
 
BKGrimes O1/ll/88 12/17/87 12/16/87 12/16/87 12/16/87*VIB:DRIS:NRR
 
*ASC/VIB:DRIS:NRR*AC/VIB:DRIS:NRR*ECEB:DEST:NRR*BC/ECEB:DEST:NRR
 
JPetrosino


===EBaker JStone DKubicki CMcCracken===
12/15/87  
12/15/87 12/15/87 12/18/87 12/16/87 12/16/87}}
12/15/87  
12/18/87  
12/16/87  
12/16/87}}


{{Information notice-Nav}}
{{Information notice-Nav}}

Latest revision as of 10:26, 16 January 2025

Inadequate Qualification and Documentation of Fire Barrier Penetration Seals
ML031150660
Person / Time
Site: Beaver Valley, Millstone, Hatch, Monticello, Calvert Cliffs, Dresden, Davis Besse, Peach Bottom, Browns Ferry, Salem, Oconee, Mcguire, Nine Mile Point, Palisades, Palo Verde, Perry, Indian Point, Fermi, Kewaunee, Catawba, Harris, Wolf Creek, Saint Lucie, Point Beach, Oyster Creek, Watts Bar, Hope Creek, Grand Gulf, Cooper, Sequoyah, Byron, Pilgrim, Arkansas Nuclear, Braidwood, Susquehanna, Summer, Prairie Island, Columbia, Seabrook, Brunswick, Surry, Limerick, North Anna, Turkey Point, River Bend, Vermont Yankee, Crystal River, Haddam Neck, Ginna, Diablo Canyon, Callaway, Vogtle, Waterford, Duane Arnold, Farley, Robinson, Clinton, South Texas, San Onofre, Cook, Comanche Peak, Yankee Rowe, Maine Yankee, Quad Cities, Humboldt Bay, La Crosse, Big Rock Point, Rancho Seco, Zion, Midland, Bellefonte, Fort Calhoun, FitzPatrick, McGuire, LaSalle, 05000000, Zimmer, Fort Saint Vrain, Shoreham, Satsop, Trojan, Atlantic Nuclear Power Plant, Crane
Issue date: 02/05/1988
From: Rossi C
Office of Nuclear Reactor Regulation
To:
References
IN-88-004, NUDOCS 8802020228
Download: ML031150660 (9)
v • d • e


UNITED STATES

NUCLEAR REGULATORY COMMISSION

OFFICE OF NUCLEAR REACTOR REGULATION

WASHINGTON, D.C.

20555

February 5, 1988

NRC INFORMATION NOTICE NO. 88-04: INADEQUATE QUALIFICATION AND DOCUMENTATION

OF FIRE BARRIER PENETRATION SEALS

Addressees

All holders of operating licenses or construction permits for nuclear power

reactors.

Purpose

This notice is to alert addressees that some installed fire barrier penetration

seal designs may not be adequately qualified for the design rating of the

penetrated fire barriers. It is expected that recipients will review this

information for applicability and consider actions, if appropriate, to preclude

a similar problem and correct existing problems at their facilities.

However, suggestions contained in this information notice do not constitute new

NRC requirements; therefore, no specific action or written response is required.

Description of Circumstances

The NRC has been reviewing fire barrier penetration seal designs installed in

several nuclear power plants. The reviews focused on whether the installed

configuration was qualified by adequate testing and documentation.

The current NRC review was prompted by reports, inspection findings, allegations, and other information that indicated the possibility that NRC requirements for

fire barrier penetration seals were not being met in all aspects.

The review

included:

evaluations of fire barrier penetration seal specifications and pro- cedures developed by licensees, licensee agents, and licensee contractors;

evaluations of various fire barrier penetration seal tests and test data; and

inspections of various fire barrier penetration seal designs and installations.

The types of concerns identified to date and mentioned below are related to weak- nesses in the implementation of NRC requirements and guidelines as related to

fire barrier penetration seal design qualification.

The staff identified instances where installed fire barrier penetration seal

designs could not be verified as qualified for the design rating of the pene- trated fire barrier. In some cases,-test qualification documentation was not

8802020228

IN 88-04

-:

February 5, 1988 available. In other cases, qualification test documentation was available but

incomplete or inadequate because all qualification requirements had not been

satisfied or the installed seal design configuration or design parameters were

significantly different from the tested seal.

The NRC review also has identified a current practice that can affect the

qualification status of installed seals.

Plant modifications are being made

that require running new cable and conduits through existing penetration seals.

These modifications are generally being made without an associated technical

review to ensure that the resulting penetration seal design configuration or

design parameters are consistent with those validated by initial qualification

tests. Over a period of time, numerous minor modifications to the same area

could cumulatively result in a degraded fire barrier rating.

Discussion:

NRC requirements and guidelines for fire barrier penetration seals are con- tained in various documents, including Appendix R to 10CFR 50, Appendix A

to Branch Technical Position (BTP) APCSB 9.5-1, "Guidelines for Fire Protec- tion for Nuclear Power Plants Docketed Prior to July 1, 1976," and NUREG-0800,

Standard Review Plan.

The extent to which these requirements or guidelines

are applicable to a specific plant depends on plant age, commitments established

by the licensee in developing the fire protection plan, the staff safety evalua- tion reports (SERs) and supplements, and the license conditions pertaining to

fire protection.

The goal is to provide a fire barrier penetration seal that will remain in

place and retain its integrity when subjected to an exposure fire, and subse- quently, a fire suppressing agent. This will provide reasonable assurance that

the effects of a fire are limited to discrete fire areas and that one division

of safe-shutdown-related systems will remain free of fire damage.

A number of licensees have conducted a comprehensive.assessment of the adequacy

of in-plant fire barrier penetration seals. Their efforts began by determining

which specific NRC guidelines/requirements apply and which specific commitments

were made to respond to those guidelines or requirements. Typically, in-plant

seal assemblies were surveyed to catalogue the various types of existing seal

configurations.

Finally, the documentation was analyzed to confirm that

in-plant designs were fully qualified by a fire test and were installed in a

proper manner.

If these efforts revealed instances where seals were not installed where re- quired, were not installed properly, or were not qualified by a standard fire

test, then the licensees have considered the seals degraded and have imple- mented compensatory measures, such as fire watch patrols, per the appropriate

technical specifications or administrative procedures.

These measures remain

in force pending final resolution of the issue.

Final resolution may include

replacing existing penetration seals with fully qualified seals, qualifying

in-plant seal assemblies by supplemental fire tests, and justifying in-plant

configuration by fire hazards/safe shutdown analysis.

IN 88-04 February 5, 1988 Appendix A contains a summary of various technical considerations that have

been used for evaluating the qualification adequacy of fire barrier penetration

seal designs and installations, associated testing, and test data.

No specific action or written response is required by this information notice.

If you have questions about this matter, please contact one of the technical

contacts listed below or the Regional Administrator of the appropriate NRC

regional office.

a~r'es E. Ross ,Director

Division of Operational Events Assessment

Office of Nuclear Reactor Regulation

Technical Contact(s): Dennis Kubicki, NRR

(301) 492-0825

Joseph Petrosino, NRR

(301) 492-0979 Attachments:

1. Appendix A - Summary of Existing Staff

Guidance Related to Fire Barrier

Penetration Seals

2. List of Recently Issued NRC Information Notices

Attachment 1

IN 88-04

February 5, 1988 APPENDIX A

SUMMARY OF EXISTING STAFF GUIDANCE RELATED

TO FIRE BARRIER PENETRATION SEALS

A. General Considerations Concerninq the Use of Test Results To Qualify Fire

Barrier Penetration Seal Designs

The (fire barrier seal) test specimen shall be truly representative of the

construction for which classification is desired, as to materials, work- manship, and details such as dimensions of parts, and shall be built under

conditions representative of those obtaining as practically applied in

building construction and operation. The physical properties of the

materials and2ingredients used in the test specimen shall be determined

and recorded.

B. Seal Acceptance Criteria

1. The fire resistance rating of the penetration seal should bS equiva- lent to the rating of the barrier in which it is installed.

2. The fire resistance rating of the penetration seal should be deter- mined by a4standard fire test (i.e., ASTM E-814, ASTM E-119 or

IEEE-634).

3. The test should be conducted by an independent, recognized testing

authority.

The tested assembly should be representative of in-plant

assemblies. The exposure fire should correspond to at least the time- temperature curve of ASTM E-119. Thermocouples should be positioned

at representative locations on the cold side of the tested assembly

(including the interface of seal material and through penetrations).

The cold-side temperature should not exceed 2500F above ambient during

the test or 3250F maximum, although higher temperatures at through

penetrations are permitted when justified in terms of cable insulation

ignitability. There should be no burn-through of the seal during the

test, nor the passage of hot gases sufficient to ignite cotton waste

material. The assembly should withstand t e effects of a hose stream, as stipulated in the standard test method.

4. The seals should be installed by qualified individuals.6

5. Appropyiate quality assurance/quality control methods should be in

force.

6. Fire barrier penetrations that must maintain environmental isolation

or pressure differentials should be qualified by test to maintain the

barrier integrity under such conditions.

Attachment 1

IN 88-04

February 5, 1988 C. Hose Stream Testing9

1. Hose stream testing is a requirement for all fire barrier penetration

seal qualification testing, regardless of whether the penetration

seal is for a wall or a ceiling or a floor.

2. Hose stream testing should be performed on tested specimens that have

successfully withstood the fire endurance test requirements.

3.

The hose stream shall be delivered in one of the following ways:

a 1-1/2-inch nozzle set at a discharge angle of 300 with a nozzle

pressure of 75 psi and a minimum discharge of 75 gpm with the tip

of the nozzle a maximum of 5 ft from the exposed face; a 1-1/2-inch

nozzle set at a discharge angle of 150 with a nozzle pressure of 75 psi and a minimum discharge of 75 gpm with the tip of the nozzle a

maximum of 10 ft from the exposed face; a 2-1/2-inch national stan- dard playpipe equipped with 1-1/8-inch tip, nozzle pressure of 30 psi, located 20 ft from the exposed face.

4. The duration of the hose stream test should meet the minimum require- ments specified in ASTM E-119 for fire barriers. During hose stream

testing, the fire barrier penetration seal should remain intact and

should not allow a projection of water beyond the unexposed surface.

D.

Deviations10

Deviations from NRC requirements or accepted industry standards for fire

barrier penetration seals should be technically substantiated as part of

the review and approval of the fire protection plan or in other separate

formal correspondence. Supplemental guidance is provided in Generic

Letter 86-10.

References

1.

"The design of fire barriers for horizontal and vertical cable trays

should, as a minimum, meet the requirements of ASTM E-119, Fire Test

of Building Construction and Materials, including the hose stream test."

[Section D.3.(d) of Appendix A to BTP APCSB 9.5-1].

"Penetration seal designs shall utilize only noncombustible materials and

shall be qualified by tests that are comparable to tests used to rate fire

barriers."

(Section III.M of Appendix R to 10 CFR Part 50).

"The penetration qualification tests should use the time temperature

exposure curve specified by ASTM E-119."

(Section C.5.a. of BTP CMEB

9.5-1).

-Attachment 1 IN 88-04 February 5, 1988 2. ASTM E-119, "Fire Test of Building Construction and Materials."

3. Section D.3.(d) of Appendix A to BtP APCSB 9.5-1.

4.Section III.M. of Appendix R to 10 CFR Part 50.

5. ASTM E-119, "Fire Test of Building Construction and Materials."

6. Section C of Appendix A to BTP APCSB 9.5-1, Section C.4 of BTP CMEB 9.5-1.

7. Ibidem.

8. Section C.5.a.(3) of BTP CMEB 9.5-1.

9.Section III.M of Appendix R to 10 CFR Part 50, Section C.5.a of BTP CMEB

9.5-1.

10. Generic Letter 86-10.

r

A

ment 2

February S. 1988

Pige 1 of I

LIST Of RECENTLY ISSUED

NRC INFORMATION NOTICES

Lntonuatlol

Dats of

Notice No.

SubJect

Issuance

Issued to

88-03 Cracks in Shroud Support

2/2/88

All holders of OLs

Access Hole Cover WVlds

or CPs for BWRs.

88.02 Lost or Stolen Gauges,

2/2/88

All NRC licensees

authorized to possess

gauges under a

specific or general

license.

88.01 Safety Injection Pipe

1/27/88

All holders of OLs

Failus

ror

CPs for nuclear

power reactors.

86-81, Broken External Closure

1/11/88

All holders of OMs

Supp. 1 Springs on Atwood & Iorrill

or CPs for nuclear

main Steam Isolation Valves

power reactors.

87-67 Lessons Learned from

12/31/87

All holders of OLs

Reional Inspections of

or CPs for nuclear

Licenses Action$ ia Response

power reactors.

to It Bolletin

a0>

-

87-65 Inappropriate Application

12/31/87

All holders of OLs

of Cofher1i1-l6rads

or CPs for nuclear

Components

powr reacton.

87-28, Alp Systems Probi e

at

12/28/87

All holders of Ms

Supp. 1 U.S. 1ight Water Reactors

or CPs for nuclear

power reactors.

87-65 Plant Operation Beyond

12/23/87

All holders of OLs

Analyzed Conditions

or CPs for nuclear

power reactors.

87-64 Conviction for Falsification 12/22/87

All nuclear power

of Security Training Records

reactor facilities

holding an OL or CP

and all major fuel

facility licensees.

ON : Operating License

CP

  • Construction Permit

 I

UNITED STATES

NUCLEAR REGULATORY COMAISSION

WASHINGTON, D.C. 20555

OFFICIAL BUSINESS

PENALTY FOR PRIVATE USE $300

FIRST CLASS MAIL

POSTAGE 6 FEES PAID

USNRC

PERMIT No. 0-E7

120555026886

1 1CO1CY1FB11S1 US NRC-OARM-IRM

DIV OF INFO SUP SVCS

MICROGRAPHICS SPECIALIST

RECORDS SERVICES BRANCH

042 WASHINGTON

DC

20555

IN 88-04

February 5, 1988

Appendix A contains a summary of various technical considerations that have

been used for evaluating the qualification adequacy of fire barrier penetration

seal designs and installations, associated testing, and test data.

No specific action or

If you have questions

contacts listed below

regional office.

written response is required by this information notice.

about this matter, please contact one of the technical

or the Regional Administrator of the appropriate NRC

Charles E. Rossi, Director

Division of Operational Events Assessment

Office of Nuclear Reactor Regulation

Technical Contact(s):

Dennis Kubicki, NRR

(301) 492-0825

Joseph Petrosino, NRR

(301) 492-0979 Attachments:

1. Appendix A - Summary of Existing Staff

Guidance Related to Fire Barrier

Penetration Seals

2. List of Recently Issued NRC Information Notices

  • Transmitted by memo to C. E. Rossi from J. G. Partlow dated 12/21/87 IC

"

m-a

-044

%i'

  • SEE PREVIOUS
  • PPMB:ARM

TechEd

01/15/88

  • OGCB:DOEA:NRF

RJKiessel

01/14/88

  • VIB:DRIS:NRR

JPetrosino

12/15/87 CONCURRENCES

4

  • C/OGCB:DOEA:NR

R

R

CHBerlinger

a

01/21/88

0245-/88 t *D/DEST:NRR

  • ADT/DEST:NRR
  • D/DRIS:NRR
  • DD/DRIS:NRR

LShao

JRichardson

JGPartlow

BKGrimes

12/17/87

12/16/87

12/16/87

12/16/87

  • ASC/VIB:DRIS:NRR*AC/VIB:DRIS:NRR*ECEB:DEST:NRR*BC/ECEB:DEST:NRR

EBaker

JStone

DKubicki

CMcCracken

12/15/87

12/18/87

12/16/87

12/16/87

IN 88-XX

January XX, 1988 Appendix A contains a summary of various technical considerations that have

been used for evaluating the qualification adequacy of fire barrier penetration

seal designs and installations, associated testing, and test data.

No specific action or written response is required by this information notice.

If you have questions about this matter, please contact the Regional Adminis- trator of the appropriate NRC regional office or this office.

Charles E. Rossi, Director

Division of Operational Events Assessment

Office of Nuclear Reactor Regulation

Technical Contact(s): Dennis Kubicki, NRR

(301) 492-9424

Joseph Petrosino, NRR

(301) 492-4316 Attachments:

1. Appendix A - Summary of Existing Staff

Guidance Related to Fire Barrier

Penetration Seals

2. List of Recently Issued NRR Information Notices

  • Transmitted by memo to C. E. Rossi from J. G. Partlow dated 12/21/87
  • SEE PREVIOUS CONCURRENCES

PPMB:ARM

C/OGCB: DOEA:NRR D/DOEA:NRR

TechEdM

CHBerlinger

CERossi

01/1</88

01/ /88

01/ /88 OGCB:DOEA:

V *D/DEST:NRR

  • ADT/DEST:NRR
  • D/DRIS:NRR
  • DD/DRIS:NRR

RJKiessel IjNA

LShao

JRlchardson

JGPartlow

BKGrimes

O1/ll/88

12/17/87

12/16/87

12/16/87

12/16/87

  • VIB:DRIS:NRR *ASC/VIB:DRIS:NRR*AC/VIB:DRIS:NRR*ECEB:DEST:NRR*BC/ECEB:DEST:NRR

JPetrosino

EBaker

JStone

DKubicki

CMcCracken

12/15/87

12/15/87

12/18/87

12/16/87

12/16/87


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