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

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{{#Wiki_filter:UNITED STATES NUCLEAR REGULATORY
{{#Wiki_filter:UNITED STATES


COMMISSION
NUCLEAR REGULATORY COMMISSION


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


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


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


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


licenses or construction
reactors.
 
permits for nuclear power reactors.


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


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


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


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


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


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


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


It is expected that recipients
==Description of Circumstances==
 
:
will review this information
The NRC has been reviewing fire barrier penetration seal designs installed in
 
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
several nuclear power plants. The reviews focused on whether the installed


result in a degraded fire barrier rating.Discussion:
configuration was qualified by adequate testing and documentation.
NRC requirements


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


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


seals are con-tained in various documents, including
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


Appendix R to 10CFR 50, Appendix A to Branch Technical
inspections of various fire barrier penetration seal designs and installations.


Position (BTP) APCSB 9.5-1, "Guidelines
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


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
fire barrier penetration seal design qualification.


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


are applicable
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


to a specific plant depends on plant age, commitments
8802020228


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


by the licensee in developing
incomplete or inadequate because all qualification requirements had not been


the fire protection
satisfied or the installed seal design configuration or design parameters were


plan, the staff safety evalua-tion reports (SERs) and supplements, and the license conditions
significantly different from the tested seal.


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


to fire protection.
qualification status of installed seals. Plant modifications are being made


The goal is to provide a fire barrier penetration
that require running new cable and conduits through existing penetration seals.


seal that will remain in place and retain its integrity
These modifications are generally being made without an associated technical


when subjected
review to ensure that the resulting penetration seal design configuration or


to an exposure fire, and subse-quently, a fire suppressing
design parameters are consistent with those validated by initial qualification


agent. This will provide reasonable
tests. Over a period of time, numerous minor modifications to the same area


assurance
could cumulatively result in a degraded fire barrier rating.


that the effects of a fire are limited to discrete fire areas and that one division of safe-shutdown-related
Discussion:
NRC requirements and guidelines for fire barrier penetration seals are con- tained in various documents, including Appendix R to 10CFR 50, Appendix A


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


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


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


of the adequacy of in-plant fire barrier penetration
fire protection.


seals. Their efforts began by determining
The goal is to provide a fire barrier penetration seal that will remain in


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


apply and which specific commitments
the effects of a fire are limited to discrete fire areas and that one division


were made to respond to those guidelines
of safe-shutdown-related systems will remain free of fire damage.


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


Typically, in-plant seal assemblies
of in-plant fire barrier penetration seals. Their efforts began by determining


were surveyed to catalogue
which specific NRC guidelines/requirements apply and which specific commitments


the various types of existing seal configurations.
were made to respond to those guidelines or requirements. Typically, in-plant


Finally, the documentation
seal assemblies were surveyed to catalogue the various types of existing seal


was analyzed to confirm that in-plant designs were fully qualified
configurations. Finally, the documentation was analyzed to confirm that


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


in a proper manner.If these efforts revealed instances
proper manner.


where seals were not installed
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


where re-quired, were not installed
test, then the licensees have considered the seals degraded and have imple- mented compensatory measures, such as fire watch patrols, per the appropriate


properly, or were not qualified
technical specifications or administrative procedures. These measures remain


by a standard fire test, then the licensees
in force pending final resolution of the issue. Final resolution may include


have considered
replacing existing penetration seals with fully qualified seals, qualifying


the seals degraded and have imple-mented compensatory
in-plant seal assemblies by supplemental fire tests, and justifying in-plant


measures, such as fire watch patrols, per the appropriate
configuration by fire hazards/safe shutdown analysis.


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


specifications
been used for evaluating the qualification adequacy of fire barrier penetration


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


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


These measures remain in force pending final resolution
If you have questions about this matter, please contact one of the technical


of the issue. Final resolution
contacts listed below or the Regional Administrator of the appropriate NRC


may include replacing
regional office.


existing penetration
a~r'es E. Ross ,Director


seals with fully qualified
Division of Operational Events Assessment


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
Office of Nuclear Reactor Regulation


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


the Use of Test Results To Qualify Fire Barrier Penetration
(301) 492-0979 Attachments:
1. Appendix A - Summary of Existing Staff


Seal Designs The (fire barrier seal) test specimen shall be truly representative
Guidance Related to Fire Barrier


of the construction
Penetration Seals


for which classification
2. List of Recently Issued NRC Information Notices


is desired, as to materials, work-manship, and details such as dimensions
Attachment 1 IN 88-04 February 5, 1988 APPENDIX A


of parts, and shall be built under conditions
SUMMARY OF EXISTING STAFF GUIDANCE RELATED


representative
TO FIRE BARRIER PENETRATION SEALS


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


as practically
Barrier Penetration Seal Designs


applied in building construction
The (fire barrier seal) test specimen shall be truly representative of the


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


The physical properties
conditions representative of those obtaining as practically applied in


of the materials
building construction and operation. The physical properties of the


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


used in the test specimen shall be determined
and recorded.


and recorded.B. Seal Acceptance
===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.


Criteria 1. The fire resistance
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


rating of the penetration
IEEE-634).


seal should bS equiva-lent to the rating of the barrier in which it is installed.
3.  The test should be conducted by an independent, recognized testing


2. The fire resistance
authority. The tested assembly should be representative of in-plant


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


seal should be deter-mined by a 4 standard fire test (i.e., ASTM E-814, ASTM E-119 or IEEE-634).
at representative locations on the cold side of the tested assembly


3. The test should be conducted
(including the interface of seal material and through penetrations).


by an independent, recognized
The cold-side temperature should not exceed 2500 F above ambient during


testing authority.
the test or 325 0 F maximum, although higher temperatures at through


The tested assembly should be representative
penetrations are permitted when justified in terms of cable insulation


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


The exposure fire should correspond
test, nor the passage of hot gases sufficient to ignite cotton waste


to at least the time-temperature
material. The assembly should withstand t e effects of a hose stream, as stipulated in the standard test method.


curve of ASTM E-119. Thermocouples
4.   The seals should be installed by qualified individuals.6
  5.  Appropyiate quality assurance/quality control methods should be in


should be positioned
force.


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


locations
or pressure differentials should be qualified by test to maintain the


on the cold side of the tested assembly (including
barrier integrity under such conditions.


the interface
Attachment 1 IN 88-04 February 5, 1988 C.  Hose Stream Testing9
      1.  Hose stream testing is a requirement for all fire barrier penetration


of seal material and through penetrations).
seal qualification testing, regardless of whether the penetration


The cold-side
seal is for a wall or a ceiling or a floor.


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


should not exceed 250 0 F above ambient during the test or 325 0 F maximum, although higher temperatures
successfully withstood the fire endurance test requirements.


at through penetrations
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


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


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


in terms of cable insulation
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


ignitability.
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.


There should be no burn-through
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


of the seal during the test, nor the passage of hot gases sufficient
testing, the fire barrier penetration seal should remain intact and


to ignite cotton waste material.
should not allow a projection of water beyond the unexposed surface.


The assembly should withstand
===D.  Deviations10===
    Deviations from NRC requirements or accepted industry standards for fire


t e effects of a hose stream, as stipulated
barrier penetration seals should be technically substantiated as part of


in the standard test method.4. The seals should be installed
the review and approval of the fire protection plan or in other separate


by qualified
formal correspondence. Supplemental guidance is provided in Generic


individuals.
Letter 86-10.


6 5. Appropyiate
References


quality assurance/quality
1.  "The design of fire barriers for horizontal and vertical cable trays


control methods should be in force.6. Fire barrier penetrations
should, as a minimum, meet the requirements of ASTM E-119, Fire Test


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


isolation or pressure differentials
"Penetration seal designs shall utilize only noncombustible materials and


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


by test to maintain the barrier integrity
barriers." (Section III.M of Appendix R to 10 CFR Part 50).


under such conditions.
"The penetration qualification tests should use the time temperature


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


1 IN 88-04 February 5, 1988 C. Hose Stream Testing9 1. Hose stream testing is a requirement
9.5-1).


for all fire barrier penetration
-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.


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


testing, regardless
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.


of whether the penetration
7.  Ibidem.


seal is for a wall or a ceiling or a floor.2. Hose stream testing should be performed
8.  Section C.5.a.(3) of BTP CMEB 9.5-1.


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


that have successfully
9.5-1.


withstood
10. Generic Letter 86-10.


the fire endurance
r


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


3. The hose stream shall be delivered
LIST Of RECENTLY ISSUED


in one of the following
NRC INFORMATION NOTICES


ways: a 1-1/2-inch
Lntonuatlol                                  Dats of


nozzle set at a discharge
Notice No.    SubJect                        Issuance    Issued to


angle of 300 with a nozzle pressure of 75 psi and a minimum discharge
88-03          Cracks in Shroud Support      2/2/88      All holders of OLs


of 75 gpm with the tip of the nozzle a maximum of 5 ft from the exposed face; a 1-1/2-inch
Access Hole Cover WVlds                    or CPs for BWRs.


nozzle set at a discharge
88.02          Lost or Stolen Gauges,        2/2/88      All NRClicensees


angle of 150 with a nozzle pressure of 75 psi and a minimum discharge
authorized to possess


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


national stan-dard playpipe equipped with 1-1/8-inch
specific or general


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
license.


in ASTM E-119 for fire barriers.
88.01          Safety Injection Pipe          1/27/88    All holders of OLs


During hose stream testing, the fire barrier penetration
Failusror                                      CPs for nuclear


seal should remain intact and should not allow a projection
power reactors.


of water beyond the unexposed
86-81,        Broken External Closure        1/11/88    All holders of OMs


surface.D. Deviations
Supp. 1        Springs on Atwood & Iorrill              or CPs for nuclear


1 0 Deviations
main Steam Isolation Valves              power reactors.


from NRC requirements
87-67          Lessons Learned from           12/31/87  All holders of OLs


or accepted industry standards
Reional Inspections of                    or CPs for nuclear


for fire barrier penetration
Licenses Action$ ia Response              power reactors.


seals should be technically
to It Bolletin


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


as part of the review and approval of the fire protection
of Cofher1i1-l6rads                      or CPs for nuclear


plan or in other separate formal correspondence.
Components                                powr reacton.


Supplemental
87-28,          Alp Systems Probie    at      12/28/87    All holders of Ms


guidance is provided in Generic Letter 86-10.References
Supp. 1        U.S. 1ight Water Reactors                or CPs for nuclear


1. "The design of fire barriers for horizontal
power reactors.


and vertical cable trays should, as a minimum, meet the requirements
87-65          Plant Operation Beyond        12/23/87    All holders of OLs


of ASTM E-119, Fire Test of Building Construction
Analyzed Conditions                      or CPs for nuclear


and Materials, including
power reactors.


the hose stream test."[Section D.3.(d) of Appendix A to BTP APCSB 9.5-1]."Penetration
87-64          Conviction for Falsification  12/22/87    All nuclear power


seal designs shall utilize only noncombustible
of Security Training Records              reactor facilities


materials
holding an OL or CP


and shall be qualified
and all major fuel


by tests that are comparable
facility licensees.


to tests used to rate fire barriers." (Section III.M of Appendix R to 10 CFR Part 50)."The penetration
ON: Operating License


qualification
CP


tests should use the time temperature
* Construction Permit


exposure curve specified
UNITED STATES                                                                                  FIRST CLASS MAIL


by ASTM E-119." (Section C.5.a. of BTP CMEB 9.5-1).
NUCLEAR REGULATORY COMAISSION                                                                          POSTAGE 6 FEES PAID


-Attachment
USNRC


1 IN 88-04 February 5, 1988 2. ASTM E-119, "Fire Test of Building Construction
WASHINGTON, D.C. 20555 PERMIT No. 0-E7 OFFICIAL BUSINESS


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


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)
DIV OF INFO SUP SVCS
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
MICROGRAPHICS SPECIALIST


NOTICES Lntonuatlol
RECORDS SERVICES BRANCH


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
042 WASHINGTON                                DC 20555


to possess gauges under a specific or general license.88.01 Safety Injection
IN 88-04 February 5, 1988 Appendix A contains a summary of various technical considerations that have


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
been used for evaluating the qualification adequacy of fire barrier penetration


Valves power reactors.87-67 Lessons Learned from 12/31/87 All holders of OLs Reional Inspections
seal designs and installations, associated testing, and test data.


of or CPs for nuclear Licenses Action$ ia Response power reactors.to It Bolletin a0> -87-65 Inappropriate
No specific action or written response is required by this information notice.


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


12/31/87 All holders of OLs of Cofher1i1-l6rads
contacts listed below or the Regional Administrator of the appropriate NRC


or CPs for nuclear Components
regional office.


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
Charles E. Rossi, Director


Beyond 12/23/87 All holders of OLs Analyzed Conditions
Division of Operational Events Assessment


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
Office of Nuclear Reactor Regulation


Technical
Technical Contact(s):    Dennis Kubicki, NRR


Contact(s):
(301) 492-0825 Joseph Petrosino, NRR
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
(301) 492-0979 Attachments:
1. Appendix A - Summary of Existing Staff


Notices*Transmitted
Guidance Related to Fire Barrier


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
Penetration Seals


RJKiessel 01/14/88*VIB:DRIS:NRR
2. List of Recently Issued NRC Information Notices


JPetrosino
*Transmitted by memo to C. E. Rossi from J. G. Partlow dated 12/21/87 IC        "    m-a      -044 %i'
*SEE PREVIOUS CONCURRENCES                                          *      4
*PPMB:ARM      *C/OGCB:DOEA:NR      R    R


12/15/87 CONCURRENCES
===TechEd          CHBerlinger        a===
01/15/88        01/21/88          0245-/88
*OGCB:DOEA:NRFt *D/DEST:NRR      *ADT/DEST:NRR    *D/DRIS:NRR    *DD/DRIS:NRR


4 **C/OGCB:DOEA:NR
RJKiessel      LShao            JRichardson      JGPartlow      BKGrimes


R R CHBerlinger
01/14/88        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


a 01/21/88 0245-/88 t *D/DEST:NRR
JPetrosino      EBaker            JStone          DKubicki      CMcCracken


*ADT/DEST:NRR
12/15/87        12/15/87          12/18/87        12/16/87      12/16/87


*D/DRIS:NRR
IN 88-XX


*DD/DRIS:NRR
January XX, 1988 Appendix A contains a summary of various technical considerations that have


LShao JRichardson
been used for evaluating the qualification adequacy of fire barrier penetration


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


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


===EBaker JStone DKubicki CMcCracken===
If you have questions about this matter, please contact the Regional Adminis- trator of the appropriate NRC regional office or this office.
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
Charles E. Rossi, Director


that have been used for evaluating
Division of Operational Events Assessment


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
Office of Nuclear Reactor Regulation


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


CERossi 01/1</88 01/ /88 01/ /88 OGCB:DOEA:  
(301) 492-4316 Attachments:
V *D/DEST:NRR
1. Appendix A - Summary of Existing Staff


*ADT/DEST:NRR
Guidance Related to Fire Barrier


*D/DRIS:NRR
Penetration Seals


*DD/DRIS:NRR
2. List of Recently Issued NRR Information Notices


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


IjNA LShao JRlchardson
PPMB:ARM        C/OGCB: DOEA:NRR D/DOEA:NRR


JGPartlow
===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


BKGrimes O1/ll/88 12/17/87 12/16/87 12/16/87 12/16/87*VIB:DRIS:NRR
RJKiessel IjNA LShao              JRlchardson      JGPartlow    BKGrimes


*ASC/VIB:DRIS:NRR*AC/VIB:DRIS:NRR*ECEB:DEST:NRR*BC/ECEB:DEST:NRR
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
JPetrosino     EBaker            JStone            DKubicki      CMcCracken


===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}}

Revision as of 02:45, 24 November 2019

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 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 a4 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 2500 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. 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 I :

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 NRClicensees

authorized to possess

gauges under a

specific or general

license.

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

Failusror 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 Probie 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

UNITED STATES FIRST CLASS MAIL

NUCLEAR REGULATORY COMAISSION POSTAGE 6 FEES PAID

USNRC

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

PENALTY FOR PRIVATE USE $300

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 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.

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 CONCURRENCES * 4
  • PPMB:ARM *C/OGCB:DOEA:NR R R

TechEd CHBerlinger a

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

01/14/88 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

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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