Protecting People and the EnvironmentUNITED STATES NUCLEAR REGULATORY COMMISSION
UNITED STATES
NUCLEAR REGULATORY COMMISSION
OFFICE OF NUCLEAR REACTOR REGULATION
WASHINGTON, D.C. 20555
February 5, 1988
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 procedures 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 weaknesses 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
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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 10 CFR 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 evaluation 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.
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February 5, 1988
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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
. Attachment 1
IN 88-04
February 5, 1988
Page 1 of 3
APPENDIX A
SUMMARY OF EXISTING STAFF GUIDANCE RELATED
TO FIRE BARRIER PENETRATION SEALS
A. General Considerations Concerning the Use of Test Results To Qualify Fire
Barrier Penetration Seal Designs 1
The (fire barrier seal) test specimen shall be truly representative of
the construction for which classification is desired, as to materials,
workmanship, 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 ingredients used in the test specimen shall be determined
and recorded. 2
B. Seal Acceptance Criteria
1. The fire resistance rating of the penetration seal should be equiva-
lent to the rating of the barrier in which it is installed. 3
2. The fire resistance rating of the penetration seal should be deter-
mined by a standard fire test (i.e., ASTM E-814, ASTM E-119 or
IEEE-634). 4
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
250øF above ambient during the test or 325øF 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 the effects of a hose stream, as stipulated in the
standard test method. 5
4. The seals should be installed by qualified individuals. 6
5. Appropriate quality assurance/quality control methods should be in
force. 7
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. 8
. Attachment 1
IN 88-04
February 5, 1988
Page 2 of 3
C. Hose Stream Testing 9
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 30ø 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 15ø 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 10
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
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Page 3 of 3
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.
. Attachment 2
IN 88-04
February 5, 1988
Page 1 of 1
LIST OF RECENTLY ISSUED
NRC INFORMATION NOTICES
_____________________________________________________________________________
Information Date of
Notice No._____Subject_______________________Issuance_______Issued to________
88-03 Cracks in Shroud Support 2/2/88 All holders of OLs
Access Hole Cover Welds 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
Failure or CPs for nuclear
power reactors.
86-81, Broken External Closure 1/11/88 All holders of OLs
Supp. 1 Springs on Atwood & Morrill or CPs for nuclear
Main Steam Isolation Valves power reactors.
87-67 Lessons Learned from 12/31/87 All holders of OLs
Regional Inspections of or CPs for nuclear
Licensee Actions in Response power reactors.
to IE Bulletin 80-11
87-66 Inappropriate Application 12/31/87 All holders of OLs
of Commercial-Grade or CPs for nuclear
Components power reactors.
87-28, Air Systems Problems at 12/28/87 All holders of OLs
Supp. 1 U.S. Light 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.
_____________________________________________________________________________
OL = Operating License
CP = Construction Permit
