Information Notice 1988-04, Inadequate Qualification and Documentation of Fire Barrier Penetration Seals
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
SEALS
Addressees
All holders of operating
licenses or construction
permits for nuclear power reactors.
Purpose
- This notice is to alert addressees
that some installed
seal designs may not be adequately
qualified
for the design rating of the penetrated
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
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
seals were not being met in all aspects. The review included:
evaluations
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
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
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
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
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
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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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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