United States Nuclear Regulatory Commission - Protecting People and the Environment

Information Notice No. 88-04: 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


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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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
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                                   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 
          250�F above ambient during the test or 325�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 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

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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 30� 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 15� 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).
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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.

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                             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 
Page Last Reviewed/Updated Tuesday, November 12, 2013