Information Notice 1988-04, Inadequate Qualification and Documentation of Fire Barrier Penetration Seals

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)

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

and 2 ingredients

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 a 4 standard 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 250 0 F above ambient during the test or 325 0 F 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. Deviations

1 0 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

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

• D/DRIS:NRR

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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