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 STATESNUCLEAR REGULATORY COMMISSIONOFFICE OF NUCLEAR REACTOR REGULATIONWASHINGTON, D.C. 20555February 5, 1988NRC INFORMATION NOTICE NO. 88-04: INADEQUATE QUALIFICATION AND DOCUMENTATIONOF FIRE BARRIER PENETRATION SEALS
{{#Wiki_filter: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==
==Addressees==
:All holders of operating licenses or construction permits for nuclear powerreactors.
:
All holders of operating licenses or construction permits for nuclear power
 
reactors.


==Purpose==
==Purpose==
:This notice is to alert addressees that some installed fire barrier penetrationseal designs may not be adequately qualified for the design rating of thepenetrated fire barriers. It is expected that recipients will review thisinformation for applicability and consider actions, if appropriate, to precludea similar problem and correct existing problems at their facilities.However, suggestions contained in this information notice do not constitute newNRC requirements; therefore, no specific action or written response is required.
:
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==
==Description of Circumstances==
:The NRC has been reviewing fire barrier penetration seal designs installed inseveral nuclear power plants. The reviews focused on whether the installedconfiguration 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 forfire barrier penetration seals were not being met in all aspects. The reviewincluded: 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; andinspections 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 tofire barrier penetration seal design qualification.The staff identified instances where installed fire barrier penetration sealdesigns could not be verified as qualified for the design rating of the pene-trated fire barrier. In some cases,-test qualification documentation was not8802020228 IN 88-04 -:February 5, 1988 available. In other cases, qualification test documentation was available butincomplete or inadequate because all qualification requirements had not beensatisfied or the installed seal design configuration or design parameters weresignificantly different from the tested seal.The NRC review also has identified a current practice that can affect thequalification status of installed seals. Plant modifications are being madethat require running new cable and conduits through existing penetration seals.These modifications are generally being made without an associated technicalreview to ensure that the resulting penetration seal design configuration ordesign parameters are consistent with those validated by initial qualificationtests. Over a period of time, numerous minor modifications to the same areacould 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 Ato 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 guidelinesare applicable to a specific plant depends on plant age, commitments establishedby the licensee in developing the fire protection plan, the staff safety evalua-tion reports (SERs) and supplements, and the license conditions pertaining tofire protection.The goal is to provide a fire barrier penetration seal that will remain inplace and retain its integrity when subjected to an exposure fire, and subse-quently, a fire suppressing agent. This will provide reasonable assurance thatthe effects of a fire are limited to discrete fire areas and that one divisionof safe-shutdown-related systems will remain free of fire damage.A number of licensees have conducted a comprehensive.assessment of the adequacyof in-plant fire barrier penetration seals. Their efforts began by determiningwhich specific NRC guidelines/requirements apply and which specific commitmentswere made to respond to those guidelines or requirements. Typically, in-plantseal assemblies were surveyed to catalogue the various types of existing sealconfigurations. Finally, the documentation was analyzed to confirm thatin-plant designs were fully qualified by a fire test and were installed in aproper 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 firetest, then the licensees have considered the seals degraded and have imple-mented compensatory measures, such as fire watch patrols, per the appropriatetechnical specifications or administrative procedures. These measures remainin force pending final resolution of the issue. Final resolution may includereplacing existing penetration seals with fully qualified seals, qualifyingin-plant seal assemblies by supplemental fire tests, and justifying in-plantconfiguration by fire hazards/safe shutdown analysis.
:
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


IN 88-04February 5, 1988 Appendix A contains a summary of various technical considerations that havebeen used for evaluating the qualification adequacy of fire barrier penetrationseal 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 technicalcontacts listed below or the Regional Administrator of the appropriate NRCregional office.a~r'es E. Ross ,DirectorDivision of Operational Events AssessmentOffice of Nuclear Reactor RegulationTechnical Contact(s): Dennis Kubicki, NRR(301) 492-0825Joseph Petrosino, NRR(301) 492-0979Attachments:1. Appendix A -Summary of Existing StaffGuidance Related to Fire BarrierPenetration Seals2. List of Recently Issued NRC Information Notices
12/28/87


Attachment 1IN 88-04February 5, 1988 APPENDIX ASUMMARY OF EXISTING STAFF GUIDANCE RELATEDTO FIRE BARRIER PENETRATION SEALSA. General Considerations Concerninq the Use of Test Results To Qualify FireBarrier Penetration Seal DesignsThe (fire barrier seal) test specimen shall be truly representative of theconstruction for which classification is desired, as to materials, work-manship, and details such as dimensions of parts, and shall be built underconditions representative of those obtaining as practically applied inbuilding construction and operation. The physical properties of thematerials and2ingredients used in the test specimen shall be determinedand recorded.B. Seal Acceptance Criteria1. 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 orIEEE-634).3. The test should be conducted by an independent, recognized testingauthority. The tested assembly should be representative of in-plantassemblies. The exposure fire should correspond to at least the time-temperature curve of ASTM E-119. Thermocouples should be positionedat 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 duringthe test or 3250F maximum, although higher temperatures at throughpenetrations are permitted when justified in terms of cable insulationignitability. There should be no burn-through of the seal during thetest, nor the passage of hot gases sufficient to ignite cotton wastematerial. 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.65. Appropyiate quality assurance/quality control methods should be inforce.6. Fire barrier penetrations that must maintain environmental isolationor pressure differentials should be qualified by test to maintain thebarrier integrity under such conditions.
===All holders of Ms===
Supp. 1 U.S. 1ight Water Reactors


Attachment 1IN 88-04February 5, 1988 C. Hose Stream Testing91. Hose stream testing is a requirement for all fire barrier penetrationseal qualification testing, regardless of whether the penetrationseal is for a wall or a ceiling or a floor.2. Hose stream testing should be performed on tested specimens that havesuccessfully 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 nozzlepressure of 75 psi and a minimum discharge of 75 gpm with the tipof the nozzle a maximum of 5 ft from the exposed face; a 1-1/2-inchnozzle set at a discharge angle of 150 with a nozzle pressure of 75psi and a minimum discharge of 75 gpm with the tip of the nozzle amaximum 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 streamtesting, the fire barrier penetration seal should remain intact andshould not allow a projection of water beyond the unexposed surface.D. Deviations10Deviations from NRC requirements or accepted industry standards for firebarrier penetration seals should be technically substantiated as part ofthe review and approval of the fire protection plan or in other separateformal correspondence. Supplemental guidance is provided in GenericLetter 86-10.References1. "The design of fire barriers for horizontal and vertical cable traysshould, as a minimum, meet the requirements of ASTM E-119, Fire Testof 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 andshall be qualified by tests that are comparable to tests used to rate firebarriers." (Section III.M of Appendix R to 10 CFR Part 50)."The penetration qualification tests should use the time temperatureexposure curve specified by ASTM E-119." (Section C.5.a. of BTP CMEB9.5-1).
or CPs for nuclear


-Attachment 1IN 88-04February 5, 1988 . 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 CMEB9.5-1.10. Generic Letter 86-10.r
power reactors.


A ment 2February S. 1988Pige 1 of ILIST Of RECENTLY ISSUEDNRC INFORMATION NOTICESLntonuatlol Dats ofNotice No. SubJect Issuance Issued to88-03 Cracks in Shroud Support 2/2/88 All holders of OLsAccess Hole Cover WVlds or CPs for BWRs.88.02 Lost or Stolen Gauges, 2/2/88 All NRC licenseesauthorized to possessgauges under aspecific or generallicense.88.01 Safety Injection Pipe 1/27/88 All holders of OLsFailus ror CPs for nuclearpower reactors.86-81, Broken External Closure 1/11/88 All holders of OMsSupp. 1 Springs on Atwood & Iorrill or CPs for nuclearmain Steam Isolation Valves power reactors.87-67 Lessons Learned from 12/31/87 All holders of OLsReional Inspections of or CPs for nuclearLicenses Action$ ia Response power reactors.to It Bolletin a0> -87-65 Inappropriate Application 12/31/87 All holders of OLsof Cofher1i1-l6rads or CPs for nuclearComponents powr reacton.87-28, Alp Systems Probi e at 12/28/87 All holders of MsSupp. 1 U.S. 1ight Water Reactors or CPs for nuclearpower reactors.87-65 Plant Operation Beyond 12/23/87 All holders of OLsAnalyzed Conditions or CPs for nuclearpower reactors.87-64 Conviction for Falsification 12/22/87 All nuclear powerof Security Training Records reactor facilitiesholding an OL or CPand all major fuelfacility licensees.ON : Operating LicenseCP
87-65 Plant Operation Beyond


* Construction PermitI :UNITED STATESNUCLEAR REGULATORY COMAISSIONWASHINGTON, D.C. 20555OFFICIAL BUSINESSPENALTY FOR PRIVATE USE $300FIRST CLASS MAILPOSTAGE 6 FEES PAIDUSNRCPERMIT No. 0-E7120555026886 1 1CO1CY1FB11S1US NRC-OARM-IRMDIV OF INFO SUP SVCSMICROGRAPHICS SPECIALISTRECORDS SERVICES BRANCH042WASHINGTON DC 20555 IN 88-04February 5, 988Appendix A contains a summary of various technical considerations that havebeen used for evaluating the qualification adequacy of fire barrier penetrationseal designs and installations, associated testing, and test data.No specific action orIf you have questionscontacts listed belowregional office.written response is required by this information notice.about this matter, please contact one of the technicalor the Regional Administrator of the appropriate NRCCharles E. Rossi, DirectorDivision of Operational Events AssessmentOffice of Nuclear Reactor RegulationTechnical Contact(s):Dennis Kubicki, NRR(301) 492-0825Joseph Petrosino, NRR(301) 492-0979Attachments:1. Appendix A -Summary of Existing StaffGuidance Related to Fire BarrierPenetration Seals2. List of Recently Issued NRC Information Notices*Transmitted by memo to C. E. Rossi from J. G.Partlow dated 12/21/87IC " m-a -044 %i'*SEE PREVIOUS*PPMB:ARMTechEd01/15/88*OGCB:DOEA:NRFRJKiessel01/14/88*VIB:DRIS:NRRJPetrosino12/15/87CONCURRENCES 4 **C/OGCB:DOEA:NR R RCHBerlinger a01/21/88 0245-/88t *D/DEST:NRR *ADT/DEST:NRR *D/DRIS:NRR *DD/DRIS:NRRLShao JRichardson JGPartlow BKGrimes12/17/87 12/16/87 12/16/87 12/16/87*ASC/VIB:DRIS:NRR*AC/VIB:DRIS:NRR*ECEB:DEST:NRR*BC/ECEB:DEST:NRREBaker JStone DKubicki CMcCracken12/15/87 12/18/87 12/16/87 12/16/87 IN 88-XXJanuary XX, 1988 Appendix A contains a summary of various technical considerations that havebeen used for evaluating the qualification adequacy of fire barrier penetrationseal 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, DirectorDivision of Operational Events AssessmentOffice of Nuclear Reactor RegulationTechnical Contact(s): Dennis Kubicki, NRR(301) 492-9424Joseph Petrosino, NRR(301) 492-4316Attachments:1. Appendix A -Summary of Existing StaffGuidance Related to Fire BarrierPenetration Seals2. List of Recently Issued NRR Information Notices*Transmitted by memo to C. E. Rossi from J. G. Partlow dated 12/21/87*SEE PREVIOUS CONCURRENCESPPMB:ARM C/OGCB: DOEA:NRR D/DOEA:NRRTechEdM CHBerlinger CERossi01/1</88 01/ /88 01/ /88OGCB:DOEA: V *D/DEST:NRR *ADT/DEST:NRR *D/DRIS:NRR *DD/DRIS:NRRRJKiessel IjNA LShao JRlchardson JGPartlow BKGrimesO1/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:NRRJPetrosino EBaker JStone DKubicki CMcCracken12/15/87 12/15/87 12/18/87 12/16/87 12/16/87  
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}}


{{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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