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

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{{#Wiki_filter:UNITED STATES
{{#Wiki_filter:UNITED STATES


NUCLEAR REGULATORY COMMISSION
===NUCLEAR REGULATORY COMMISSION===
OFFICE OF NUCLEAR REACTOR REGULATION
 
WASHINGTON, D.C.


OFFICE OF NUCLEAR REACTOR REGULATION
20555


WASHINGTON, D.C. 20555 February 5, 1988 NRC INFORMATION NOTICE NO. 88-04:   INADEQUATE QUALIFICATION AND DOCUMENTATION
===February 5, 1988===
NRC INFORMATION NOTICE NO. 88-04: INADEQUATE QUALIFICATION AND DOCUMENTATION


OF FIRE BARRIER PENETRATION SEALS
===OF FIRE BARRIER PENETRATION SEALS===


==Addressees==
==Addressees==
Line 56: Line 60:
The current NRC review was prompted by reports, inspection findings, allegations, and other information that indicated the possibility that NRC requirements for
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
fire barrier penetration seals were not being met in all aspects.


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


Line 73: Line 80:
8802020228
8802020228


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


incomplete or inadequate because all qualification requirements had not been
incomplete or inadequate because all qualification requirements had not been
Line 84: Line 92:
The NRC review also has identified a current practice that can affect the
The NRC review also has identified a current practice that can affect the


qualification status of installed seals. Plant modifications are being made
qualification status of installed seals.


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


Line 102: Line 111:


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,
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
Standard Review Plan.


===The extent to which these requirements or guidelines===
are applicable to a specific plant depends on plant age, commitments established
are applicable to a specific plant depends on plant age, commitments established


Line 128: Line 138:
seal assemblies were surveyed to catalogue the various types of existing seal
seal assemblies were surveyed to catalogue the various types of existing seal


configurations. Finally, the documentation was analyzed to confirm that
configurations.
 
Finally, the documentation was analyzed to confirm that


in-plant designs were fully qualified by a fire test and were installed in a
in-plant designs were fully qualified by a fire test and were installed in a
Line 138: Line 150:
test, then the licensees have considered the seals degraded and have imple- mented compensatory measures, such as fire watch patrols, per the appropriate
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
technical specifications or administrative procedures.


in force pending final resolution of the issue. Final resolution may include
===These measures remain===
in force pending final resolution of the issue.


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


Line 164: Line 178:
a~r'es E. Ross ,Director
a~r'es E. Ross ,Director


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


Technical Contact(s):   Dennis Kubicki, NRR
Technical Contact(s): Dennis Kubicki, NRR


(301) 492-0825 Joseph Petrosino, NRR
(301) 492-0825


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


Guidance Related to Fire Barrier
===Guidance Related to Fire Barrier===
 
Penetration Seals
Penetration Seals


2. List of Recently Issued NRC Information Notices
2. List of Recently Issued NRC Information Notices


Attachment 1 IN 88-04 February 5, 1988 APPENDIX A
===Attachment 1===
IN 88-04


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


TO FIRE BARRIER PENETRATION SEALS
===TO FIRE BARRIER PENETRATION SEALS===
 
A. General Considerations Concerninq the Use of Test Results To Qualify Fire
A. General Considerations Concerninq the Use of Test Results To Qualify Fire


Barrier Penetration Seal Designs
===Barrier Penetration Seal Designs===
 
The (fire barrier seal) test specimen shall be truly representative of the
The (fire barrier seal) test specimen shall be truly representative of the


Line 199: Line 212:
building construction and operation. The physical properties of the
building construction and operation. The physical properties of the


materials and 2 ingredients used in the test specimen shall be determined
materials and2ingredients used in the test specimen shall be determined


and recorded.
and recorded.


===B. Seal Acceptance Criteria===
===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.
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 a4 standard fire test (i.e., ASTM E-814, ASTM E-119 or
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).
IEEE-634).


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


authority. The tested assembly should be representative of in-plant
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
assemblies. The exposure fire should correspond to at least the time- temperature curve of ASTM E-119. Thermocouples should be positioned
Line 220: Line 235:
(including the interface of seal material and through penetrations).
(including the interface of seal material and through penetrations).


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


the test or 325 0 F maximum, although higher temperatures at through
the test or 3250F maximum, although higher temperatures at through


penetrations are permitted when justified in terms of cable insulation
penetrations are permitted when justified in terms of cable insulation
Line 232: Line 247:
material. The assembly should withstand t e effects of a hose stream, as stipulated in the standard test method.
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
4. The seals should be installed by qualified individuals.6
  5.   Appropyiate quality assurance/quality control methods should be in
5. Appropyiate quality assurance/quality control methods should be in


force.
force.


6.   Fire barrier penetrations that must maintain environmental isolation
6. Fire barrier penetrations that must maintain environmental isolation


or pressure differentials should be qualified by test to maintain the
or pressure differentials should be qualified by test to maintain the
Line 243: Line 258:
barrier integrity under such conditions.
barrier integrity under such conditions.


Attachment 1 IN 88-04 February 5, 1988 C.   Hose Stream Testing9
===Attachment 1===
      1.   Hose stream testing is a requirement for all fire barrier penetration
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 qualification testing, regardless of whether the penetration
Line 250: Line 268:
seal is for a wall or a ceiling or a floor.
seal is for a wall or a ceiling or a floor.


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


successfully withstood the fire endurance test requirements.
successfully withstood the fire endurance test requirements.


3.   The hose stream shall be delivered in one of the following ways:
3.
          a 1-1/2-inch nozzle set at a discharge angle of 300 with a nozzle
 
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
pressure of 75 psi and a minimum discharge of 75 gpm with the tip
Line 265: Line 285:
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.
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
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
testing, the fire barrier penetration seal should remain intact and
Line 271: Line 291:
should not allow a projection of water beyond the unexposed surface.
should not allow a projection of water beyond the unexposed surface.


===D.  Deviations10===
D.
    Deviations from NRC requirements or accepted industry standards for fire
 
===Deviations10===
Deviations from NRC requirements or accepted industry standards for fire


barrier penetration seals should be technically substantiated as part of
barrier penetration seals should be technically substantiated as part of
Line 284: Line 306:
References
References


1.   "The design of fire barriers for horizontal and vertical cable trays
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
should, as a minimum, meet the requirements of ASTM E-119, Fire Test


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


"Penetration seal designs shall utilize only noncombustible materials and
"Penetration seal designs shall utilize only noncombustible materials and
Line 295: Line 319:
shall be qualified by tests that are comparable to tests used to rate fire
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).
barriers."  
(Section III.M of Appendix R to 10 CFR Part 50).


"The penetration qualification tests should use the time temperature
"The penetration qualification tests should use the time temperature


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


9.5-1).
9.5-1).


-Attachment 1 IN 88-04 February 5, 1988 2. ASTM E-119, "Fire Test of Building Construction and Materials."
-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.
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.
4. Section III.M. of Appendix R to 10 CFR Part 50.


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


7. Ibidem.
7. Ibidem.


8. Section C.5.a.(3) of BTP CMEB 9.5-1.
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. Section III.M of Appendix R to 10 CFR Part 50, Section C.5.a of BTP CMEB


9.5-1.
9.5-1.
Line 323: Line 349:
r
r


A     ment 2                             I :
A
                                                                                  February S. 1988 Pige 1 of I
 
ment 2


LIST Of RECENTLY ISSUED
===February S. 1988===
Pige 1 of I


===LIST Of RECENTLY ISSUED===
NRC INFORMATION NOTICES
NRC INFORMATION NOTICES


Lntonuatlol                                   Dats of
Lntonuatlol


Notice No.    SubJect                        Issuance    Issued to
Dats of


88-03          Cracks in Shroud Support      2/2/88      All holders of OLs
Notice No.


Access Hole Cover WVlds                    or CPs for BWRs.
SubJect


88.02          Lost or Stolen Gauges,        2/2/88      All NRClicensees
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
authorized to possess


Line 348: Line 392:
license.
license.


88.01         Safety Injection Pipe         1/27/88     All holders of OLs
88.01 Safety Injection Pipe
 
1/27/88  
 
===All holders of OLs===
Failus


Failusror                                      CPs for nuclear
ror


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


86-81,         Broken External Closure       1/11/88    All holders of OMs
86-81, Broken External Closure


Supp. 1       Springs on Atwood & Iorrill              or CPs for nuclear
1/11/88


main Steam Isolation Valves              power reactors.
===All holders of OMs===
Supp. 1 Springs on Atwood & Iorrill


87-67          Lessons Learned from          12/31/87  All holders of OLs
or CPs for nuclear


Reional Inspections of                    or CPs for nuclear
main Steam Isolation Valves


Licenses Action$ ia Response             power reactors.
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
to It Bolletin


a0>                                     -
a0>  
                      87-65           Inappropriate Application     12/31/87    All holders of OLs
-
87-65 Inappropriate Application


of Cofher1i1-l6rads                      or CPs for nuclear
12/31/87


Components                                powr reacton.
===All holders of OLs===
of Cofher1i1-l6rads


87-28,          Alp Systems Probie    at      12/28/87    All holders of Ms
or CPs for nuclear


Supp. 1         U.S. 1ight Water Reactors                 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.
power reactors.


87-65           Plant Operation Beyond       12/23/87    All holders of OLs
87-65 Plant Operation Beyond


Analyzed Conditions                       or CPs for nuclear
12/23/87
 
===All holders of OLs===
Analyzed Conditions
 
or CPs for nuclear


power reactors.
power reactors.


87-64           Conviction for Falsification 12/22/87   All nuclear power
87-64 Conviction for Falsification 12/22/87  


of Security Training Records             reactor facilities
===All nuclear power===
of Security Training Records
 
reactor facilities


holding an OL or CP
holding an OL or CP
Line 397: Line 484:
facility licensees.
facility licensees.


ON: Operating License
ON : Operating License


CP
CP
Line 403: Line 490:
* Construction Permit
* Construction Permit


UNITED STATES                                                                                  FIRST CLASS MAIL
 I


NUCLEAR REGULATORY COMAISSION                                                                          POSTAGE 6 FEES PAID
:


USNRC
===UNITED STATES===
NUCLEAR REGULATORY COMAISSION


WASHINGTON, D.C. 20555 PERMIT No. 0-E7 OFFICIAL BUSINESS
===WASHINGTON, D.C. 20555===
OFFICIAL BUSINESS


PENALTY FOR PRIVATE USE $300
PENALTY FOR PRIVATE USE $300
                                  120555026886                  1 1CO1CY1FB11S1 US NRC-OARM-IRM


DIV OF INFO SUP SVCS
===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
MICROGRAPHICS SPECIALIST


RECORDS SERVICES BRANCH
===RECORDS SERVICES BRANCH===
042 WASHINGTON
 
DC
 
20555


042 WASHINGTON                                DC 20555
IN 88-04


IN 88-04 February 5, 1988 Appendix A contains a summary of various technical considerations that have
===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
been used for evaluating the qualification adequacy of fire barrier penetration
Line 428: Line 530:
seal designs and installations, associated testing, and test data.
seal designs and installations, associated testing, and test data.


No specific action or written response is required by this information notice.
===No specific action or===
If you have questions
 
contacts listed below


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


contacts listed below or the Regional Administrator of the appropriate NRC
written response is required by this information notice.


regional office.
about this matter, please contact one of the technical


Charles E. Rossi, Director
or the Regional Administrator of the appropriate NRC


===Charles E. Rossi, Director===
Division of Operational Events Assessment
Division of Operational Events Assessment


Office of Nuclear Reactor Regulation
===Office of Nuclear Reactor Regulation===
Technical Contact(s):


Technical Contact(s):    Dennis Kubicki, NRR
===Dennis Kubicki, NRR===
 
(301) 492-0825
(301) 492-0825 Joseph Petrosino, NRR


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


Guidance Related to Fire Barrier
===Guidance Related to Fire Barrier===
 
Penetration Seals
Penetration Seals


2. List of Recently Issued NRC Information Notices
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'
*Transmitted by memo to C. E. Rossi from J. G. Partlow dated 12/21/87 IC
*SEE PREVIOUS CONCURRENCES                                          *      4
 
*PPMB:ARM       *C/OGCB:DOEA:NR       R     R
"  
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


===TechEd          CHBerlinger        a===
BKGrimes
01/15/88        01/21/88          0245-/88
*OGCB:DOEA:NRFt *D/DEST:NRR      *ADT/DEST:NRR    *D/DRIS:NRR    *DD/DRIS:NRR


RJKiessel      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


01/14/88        12/17/87          12/16/87        12/16/87      12/16/87
EBaker
*VIB:DRIS:NRR *ASC/VIB:DRIS:NRR*AC/VIB:DRIS:NRR*ECEB:DEST:NRR*BC/ECEB:DEST:NRR
 
JStone
 
DKubicki


JPetrosino      EBaker            JStone          DKubicki      CMcCracken
CMcCracken


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


IN 88-XX
IN 88-XX
Line 484: Line 646:
If you have questions about this matter, please contact the Regional Adminis- trator of the appropriate NRC regional office or this office.
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
===Charles E. Rossi, Director===
 
Division of Operational Events Assessment
Division of Operational Events Assessment


Office of Nuclear Reactor Regulation
===Office of Nuclear Reactor Regulation===
Technical Contact(s): Dennis Kubicki, NRR


Technical Contact(s):  Dennis Kubicki, NRR
(301) 492-9424
 
(301) 492-9424 Joseph Petrosino, NRR


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


Guidance Related to Fire Barrier
===Guidance Related to Fire Barrier===
 
Penetration Seals
Penetration Seals


Line 506: Line 666:
*SEE PREVIOUS CONCURRENCES
*SEE PREVIOUS CONCURRENCES


PPMB:ARM       C/OGCB: DOEA:NRR D/DOEA:NRR
PPMB:ARM
 
C/OGCB: DOEA:NRR D/DOEA:NRR


===TechEdM         CHBerlinger        CERossi===
TechEdM
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
CHBerlinger


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


JPetrosino     EBaker           JStone           DKubicki     CMcCracken
JPetrosino
 
EBaker
 
JStone
 
DKubicki
 
CMcCracken


12/15/87       12/15/87           12/18/87         12/16/87     12/16/87}}
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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