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
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
-:
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
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
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
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
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
and all major fuel
facility licensees.
ON : Operating License
- Construction Permit
I
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NUCLEAR REGULATORY COMAISSION
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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