ML20003G518

Informs of Possible Nonconformance Re Installation of Rated Fire Penetration Seals at Facility.Chemtrol CT-800/GE RTV 6428 Silicone Does Not Meet ASTM E-119 Stds

ML20003G518
Person / Time
Site:	Vermont Yankee
Issue date:	11/03/1980
From:	Shute S CHEMTROL CORP.
To:	Grier B NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION I)
Shared Package
ML20003G516	List: ML20003G518 ML20003G521 ML20003G523 ML20003G527
References
NUDOCS 8104290738
Download: ML20003G518 (3)

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a hemtral orporetion Area Code 713/469-9680 P. O. Box 38556 Houston, Texas 77088 TWX: 910 8816223 A

V November 3, 1980 United States Nuclear Regulatory Commission 631 Park Avenue King of Prussia, PA. 19406 Attn: Mr. Boyce Grier Director, Region I Re: Fire Penetration Seals Vermont Yankee Nuclear Power Station

Dear Mr. Grier:

Chemtrol Corporation Quality Assurance Department feels it necessary at this time to inform you of a possible Non-Conformance per our installation of rated fire penetration seals at Vermont Yankee Nuclear Generating Station located in Vernon, Vermont. The following sequence of events should explain why we feel the possibility of a Non-Conformance may exist and the circumstances which have lead us to this final submission.

On September 10, 1979 Chemtrol Corporation arrived in Vernon, Vermont in order to install three hour rated fire penetration seals as contracted by Vermont Yankee Nuclear Power Corporation. Chemtrol's FC-225 Design Systems Specification Manual requires that our systems be installed utilizing CHEMTROL CT-18/Dow Corning 3-6548 RTV Silicone r'oam and CHEMTROL CT-900/Dow Corning Sylgard 170 Elastomer which we have tested and worked with for over five years.

It was requested of Chemtrol, however, to utilize General Electric RTV Silicone Foam and Elastomers for this job because the General Electric tested system required a lesser depth of fill and the engineering personnel at Vermont Yankee were very concerned about the amount of material used versus cable derating factors. The project began with a verbal agreement from General Electric Company to allow Chemtrol to install their tested systems, which does have American Nuclear Insurers acceptance. (See Exhibit A)

American Nuclear Insurers were advised of this arrangement and were given by Chemtrol typical details of the seals to t

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be installed per the General Electric accepted system and were later provided with an entire engineering package, including all Quality Control documentation (by Chemtrol) of the penetrations that were sealed. They were not provided, however, with a written statement from the General Electric Company stating that they would indeed back-up their own designed systems as installed by Chemtrol.

This, to say the least, put Chemtrol in a bind. The legal department at General Electric decided that it was too much of a risk to acknowledge their own test results, the job at Vermont Yankee was complete, American Nuclear Insurers would not issue Verv>nt Yankee an acceptance for the penetration seals installed, and Vermont Yankee would therefore not totally pay Chemtrol for the work performed.

Chemtrol Corporation did manage to get General Electric to allow American Nuclear Insurers to utilize their fire test report in making an engineering judgement for a portion of the seals installed by signing a hold harmless agreement between Vermont Yankee, General Electric and Chemtrol. (See Exhibit B) Chemtrol in conjunction with General Electric ran a fire test qualifying the control room seal installed at Vermont Yankee for which General Electric was given American Nuclear Insurers acceptance. (See Exhibit C)

The only real solution to this problem was for Chemtrol to perform qualifying fire tests typical of the seals installed at Vermont Yankee and therefore gaining acceptances from American Nuclear Insurers for General Electric Silicone Foam and Elastomer. Thus it would become a part of our own sealing system. Chemtrol did exactly that.

Chemtrol submitted fire test procedures to American Nuclear Insurers, which met with their acceptance (See Exhibit D).

The test configurations were designed so that the sealing depth of materials was the same as those already successfully tested by General Electric at Underwriters Laboratories.

On October 27, 1980 Chemtrol performed a fire test on CHEMTROL CT-800/GE RTV 6428 Silicone per ASTM E 119 standards. The test was performed at Portland Cement Association in Skokie, Illinois, and at one hour and thirty-one minutes the test was terminated as a failure.

(See Exhibit E) At one hour and twenty three minutes all but approximately 1/2 inch of the General Electric RTV 6428 Silicone had burned away.

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Chemtrol Corporation has run many fire tests in its histcry but has never observed a silicone elastomeric material to burn as much as this material.

On October 28, 1980 Chemtrol performed a fire test on CHEMTROL CT-19/GE 850 RTV Silicone which was quite successful.

The problem is that approximately 75% of the penetration seals installed at Vermont Yankee utilized GE RTV 6428 Silicone and after seeing the performance of this material as exposed to ASTM criteria Chemtrol questions the validity of the original fire test performed by General Electric.

Chemtrol is in the process of having the tested material analyzed so that we may be able to determine if there has been a change in formulation. We see no advantage in running another test on this material at this time.

Chemtrol is very concerned about the seals installed at Vermont Yankee and we understand that a non-conformance may be in order. Chemtrol is not, however, willing to accept liability for the penetration seals installed if the information presented to us by General Electric on their material is by any means incorrect.

Please advise as to what the next step should be. If I can provide you with any further information, please do not hesitate to call myself or Mr. Jim Young, President and CEO of Chemtrol Corporation.

l Sincerely, CHEMTROL CORPORATION 9

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Scott Shute Q.A. Manager SS/bk Enc.

cc: J. Young-Chemtrol Corp.

R. Fleming-Chemtrol Corp.

V. Cataldo-Chemtrol Corp.

W. Bornhoeft-American Nuclear Insurers W. Wittmer-Vermont Yankee Nuclear Power Corporation B. Nelson-General Electric Silicone Products Division q

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