Information Notice 1988-04, Inadequate Qualification and Documentation of Fire Barrier Penetration Seals
UNITED STATESNUCLEAR REGULATORY COMMISSIONOFFICE OF NUCLEAR REACTOR REGULATIONWASHINGTON, D.C. 20555February 5, 1988NRC INFORMATION NOTICE NO. 88-04: INADEQUATE QUALIFICATION AND DOCUMENTATIONOF FIRE BARRIER PENETRATION SEALS
Addressees
- All holders of operating licenses or construction permits for nuclear powerreactors.
Purpose
- This notice is to alert addressees that some installed fire barrier penetrationseal designs may not be adequately qualified for the design rating of thepenetrated fire barriers. It is expected that recipients will review thisinformation for applicability and consider actions, if appropriate, to precludea similar problem and correct existing problems at their facilities.However, suggestions contained in this information notice do not constitute newNRC requirements; therefore, no specific action or written response is required.
Description of Circumstances
- The NRC has been reviewing fire barrier penetration seal designs installed inseveral nuclear power plants. The reviews focused on whether the installedconfiguration 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 forfire barrier penetration seals were not being met in all aspects. The reviewincluded: 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; andinspections 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 tofire barrier penetration seal design qualification.The staff identified instances where installed fire barrier penetration sealdesigns could not be verified as qualified for the design rating of the pene-trated fire barrier. In some cases,-test qualification documentation was not8802020228 IN 88-04 -:February 5, 1988 available. In other cases, qualification test documentation was available butincomplete or inadequate because all qualification requirements had not beensatisfied or the installed seal design configuration or design parameters weresignificantly different from the tested seal.The NRC review also has identified a current practice that can affect thequalification status of installed seals. Plant modifications are being madethat require running new cable and conduits through existing penetration seals.These modifications are generally being made without an associated technicalreview to ensure that the resulting penetration seal design configuration ordesign parameters are consistent with those validated by initial qualificationtests. Over a period of time, numerous minor modifications to the same areacould 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 Ato 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 guidelinesare applicable to a specific plant depends on plant age, commitments establishedby the licensee in developing the fire protection plan, the staff safety evalua-tion reports (SERs) and supplements, and the license conditions pertaining tofire protection.The goal is to provide a fire barrier penetration seal that will remain inplace and retain its integrity when subjected to an exposure fire, and subse-quently, a fire suppressing agent. This will provide reasonable assurance thatthe effects of a fire are limited to discrete fire areas and that one divisionof safe-shutdown-related systems will remain free of fire damage.A number of licensees have conducted a comprehensive.assessment of the adequacyof in-plant fire barrier penetration seals. Their efforts began by determiningwhich specific NRC guidelines/requirements apply and which specific commitmentswere made to respond to those guidelines or requirements. Typically, in-plantseal assemblies were surveyed to catalogue the various types of existing sealconfigurations. Finally, the documentation was analyzed to confirm thatin-plant designs were fully qualified by a fire test and were installed in aproper 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 firetest, then the licensees have considered the seals degraded and have imple-mented compensatory measures, such as fire watch patrols, per the appropriatetechnical specifications or administrative procedures. These measures remainin force pending final resolution of the issue. Final resolution may includereplacing existing penetration seals with fully qualified seals, qualifyingin-plant seal assemblies by supplemental fire tests, and justifying in-plantconfiguration by fire hazards/safe shutdown analysis.
IN 88-04February 5, 1988 Appendix A contains a summary of various technical considerations that havebeen used for evaluating the qualification adequacy of fire barrier penetrationseal 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 technicalcontacts listed below or the Regional Administrator of the appropriate NRCregional office.a~r'es E. Ross ,DirectorDivision of Operational Events AssessmentOffice of Nuclear Reactor RegulationTechnical Contact(s): Dennis Kubicki, NRR(301) 492-0825Joseph Petrosino, NRR(301) 492-0979Attachments:1. Appendix A -Summary of Existing StaffGuidance Related to Fire BarrierPenetration Seals2. List of Recently Issued NRC Information Notices
Attachment 1IN 88-04February 5, 1988 APPENDIX ASUMMARY OF EXISTING STAFF GUIDANCE RELATEDTO FIRE BARRIER PENETRATION SEALSA. General Considerations Concerninq the Use of Test Results To Qualify FireBarrier Penetration Seal DesignsThe (fire barrier seal) test specimen shall be truly representative of theconstruction for which classification is desired, as to materials, work-manship, and details such as dimensions of parts, and shall be built underconditions representative of those obtaining as practically applied inbuilding construction and operation. The physical properties of thematerials and2ingredients used in the test specimen shall be determinedand recorded.B. Seal Acceptance Criteria1. 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 orIEEE-634).3. The test should be conducted by an independent, recognized testingauthority. The tested assembly should be representative of in-plantassemblies. The exposure fire should correspond to at least the time-temperature curve of ASTM E-119. Thermocouples should be positionedat 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 duringthe test or 3250F maximum, although higher temperatures at throughpenetrations are permitted when justified in terms of cable insulationignitability. There should be no burn-through of the seal during thetest, nor the passage of hot gases sufficient to ignite cotton wastematerial. 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.65. Appropyiate quality assurance/quality control methods should be inforce.6. Fire barrier penetrations that must maintain environmental isolationor pressure differentials should be qualified by test to maintain thebarrier integrity under such conditions.
Attachment 1IN 88-04February 5, 1988 C. Hose Stream Testing91. Hose stream testing is a requirement for all fire barrier penetrationseal qualification testing, regardless of whether the penetrationseal is for a wall or a ceiling or a floor.2. Hose stream testing should be performed on tested specimens that havesuccessfully 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 nozzlepressure of 75 psi and a minimum discharge of 75 gpm with the tipof the nozzle a maximum of 5 ft from the exposed face; a 1-1/2-inchnozzle set at a discharge angle of 150 with a nozzle pressure of 75psi and a minimum discharge of 75 gpm with the tip of the nozzle amaximum 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 streamtesting, the fire barrier penetration seal should remain intact andshould not allow a projection of water beyond the unexposed surface.D. Deviations10Deviations from NRC requirements or accepted industry standards for firebarrier penetration seals should be technically substantiated as part ofthe review and approval of the fire protection plan or in other separateformal correspondence. Supplemental guidance is provided in GenericLetter 86-10.References1. "The design of fire barriers for horizontal and vertical cable traysshould, as a minimum, meet the requirements of ASTM E-119, Fire Testof 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 andshall be qualified by tests that are comparable to tests used to rate firebarriers." (Section III.M of Appendix R to 10 CFR Part 50)."The penetration qualification tests should use the time temperatureexposure curve specified by ASTM E-119." (Section C.5.a. of BTP CMEB9.5-1).
-Attachment 1IN 88-04February 5, 1988 . 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 CMEB9.5-1.10. Generic Letter 86-10.r
A ment 2February S. 1988Pige 1 of ILIST Of RECENTLY ISSUEDNRC INFORMATION NOTICESLntonuatlol Dats ofNotice No. SubJect Issuance Issued to88-03 Cracks in Shroud Support 2/2/88 All holders of OLsAccess Hole Cover WVlds or CPs for BWRs.88.02 Lost or Stolen Gauges, 2/2/88 All NRC licenseesauthorized to possessgauges under aspecific or generallicense.88.01 Safety Injection Pipe 1/27/88 All holders of OLsFailus ror CPs for nuclearpower reactors.86-81, Broken External Closure 1/11/88 All holders of OMsSupp. 1 Springs on Atwood & Iorrill or CPs for nuclearmain Steam Isolation Valves power reactors.87-67 Lessons Learned from 12/31/87 All holders of OLsReional Inspections of or CPs for nuclearLicenses Action$ ia Response power reactors.to It Bolletin a0> -87-65 Inappropriate Application 12/31/87 All holders of OLsof Cofher1i1-l6rads or CPs for nuclearComponents powr reacton.87-28, Alp Systems Probi e at 12/28/87 All holders of MsSupp. 1 U.S. 1ight Water Reactors or CPs for nuclearpower reactors.87-65 Plant Operation Beyond 12/23/87 All holders of OLsAnalyzed Conditions or CPs for nuclearpower reactors.87-64 Conviction for Falsification 12/22/87 All nuclear powerof Security Training Records reactor facilitiesholding an OL or CPand all major fuelfacility licensees.ON : Operating LicenseCP
- Construction PermitI :UNITED STATESNUCLEAR REGULATORY COMAISSIONWASHINGTON, D.C. 20555OFFICIAL BUSINESSPENALTY FOR PRIVATE USE $300FIRST CLASS MAILPOSTAGE 6 FEES PAIDUSNRCPERMIT No. 0-E7120555026886 1 1CO1CY1FB11S1US NRC-OARM-IRMDIV OF INFO SUP SVCSMICROGRAPHICS SPECIALISTRECORDS SERVICES BRANCH042WASHINGTON DC 20555 IN 88-04February 5, 988Appendix A contains a summary of various technical considerations that havebeen used for evaluating the qualification adequacy of fire barrier penetrationseal designs and installations, associated testing, and test data.No specific action orIf you have questionscontacts listed belowregional office.written response is required by this information notice.about this matter, please contact one of the technicalor the Regional Administrator of the appropriate NRCCharles E. Rossi, DirectorDivision of Operational Events AssessmentOffice of Nuclear Reactor RegulationTechnical Contact(s):Dennis Kubicki, NRR(301) 492-0825Joseph Petrosino, NRR(301) 492-0979Attachments:1. Appendix A -Summary of Existing StaffGuidance Related to Fire BarrierPenetration Seals2. List of Recently Issued NRC Information Notices*Transmitted by memo to C. E. Rossi from J. G.Partlow dated 12/21/87IC " m-a -044 %i'*SEE PREVIOUS*PPMB:ARMTechEd01/15/88*OGCB:DOEA:NRFRJKiessel01/14/88*VIB:DRIS:NRRJPetrosino12/15/87CONCURRENCES 4 **C/OGCB:DOEA:NR R RCHBerlinger a01/21/88 0245-/88t *D/DEST:NRR *ADT/DEST:NRR *D/DRIS:NRR *DD/DRIS:NRRLShao JRichardson JGPartlow BKGrimes12/17/87 12/16/87 12/16/87 12/16/87*ASC/VIB:DRIS:NRR*AC/VIB:DRIS:NRR*ECEB:DEST:NRR*BC/ECEB:DEST:NRREBaker JStone DKubicki CMcCracken12/15/87 12/18/87 12/16/87 12/16/87 IN 88-XXJanuary XX, 1988 Appendix A contains a summary of various technical considerations that havebeen used for evaluating the qualification adequacy of fire barrier penetrationseal 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, DirectorDivision of Operational Events AssessmentOffice of Nuclear Reactor RegulationTechnical Contact(s): Dennis Kubicki, NRR(301) 492-9424Joseph Petrosino, NRR(301) 492-4316Attachments:1. Appendix A -Summary of Existing StaffGuidance Related to Fire BarrierPenetration Seals2. List of Recently Issued NRR Information Notices*Transmitted by memo to C. E. Rossi from J. G. Partlow dated 12/21/87*SEE PREVIOUS CONCURRENCESPPMB:ARM C/OGCB: DOEA:NRR D/DOEA:NRRTechEdM CHBerlinger CERossi01/1</88 01/ /88 01/ /88OGCB:DOEA: V *D/DEST:NRR *ADT/DEST:NRR *D/DRIS:NRR *DD/DRIS:NRRRJKiessel IjNA LShao JRlchardson JGPartlow BKGrimesO1/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:NRRJPetrosino EBaker JStone DKubicki CMcCracken12/15/87 12/15/87 12/18/87 12/16/87 12/16/87