•: ,: APR 1 7 1992

FINAL REPORT

of the

SPECIAL REVIEW TEAM FOR

THE REVIEW OF THIERMO-LAG FIRE BARRIER PERFORMANCE

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~FINAL REPORT

of te

SPECIAL REVIEW TEAM FOR

THE REVIEW OF TIHERMO-LAG FIRE BARRIER PERFORMANCE,

TABLE OF CONTENTS

WCU•TIVE SU1ONARY............................................................ 1

Findingp................................................ ............... 1

Safety Significance...........................1

Recommendations........................................................ 2

Review Status..........................2

BACKGRtOUND................. ,...... ............................................. 4

• ..... •: !.•..• ... E.stablishuent of .Special-Review Tesa.................4 "-

i!i' : Previously Identified Fire Barrier-Concerrns.. ................. ,....,.;..7 i=3

Cocuin .* . .*-.. . . .;. . .:.+.;..S.*• .....-. "....14•

PCA RVB T W CI VITIES. •CONCERNS.MI .TECMNICAL •ISSUES .......... ;,:16 .. •+:

Scpefmviv . ....... ................. ..... ......... 16 I

" it~vle olFir •-ndurace Tes.Reports..............................

October 1989 GSU Fire Test Fajicre ................ 19

Industrial Testing Laboratories, Incorporated Tests ............... 21

Construction Technology Laboratories, Incorporated Tests .......... 25

Application of Fire Endurance Test Results............................. 27

Review of Ampacity Derating Test Repcrts................29

SAFETY SIGNIFICANCE.................... ... .... "............................... 31

Fire Protection............................. -....................... 31

Ampacity Derating............................34

CONCLUSIONS............................. . ................... :. ... .'......... 35.

RECOMMENDATIONS................................... , ................... :..... 36

APPENDIX A LIST OF ATTACHMENTS

APPENDIX B ACRONYMS AND INITIALISMS
EXECLUTIVE SUM4MARY

Many U.S. Nuclear Regulatory Commission (NRC) licensees use the Thermo-Lag 330-I (Thermo-Lag) fire barrier system, to meet the NRC's requirements for the protection of safe

shutdown equipment. In response to industry operating experience and allegations regarding

the use of Thermo-Lag, the Director of the Office of Nuclear Reactor Regulation (NRR)

established a special review team to determine-whether or not the operating experience and

allegations had generic applicability and to. assess the safety significance of any identified

concerns. The purpose of this report is to document the results of the review completed by the special review team.

The special review team reviewed the NRC s requirements and guidance regarding fire

barriers; reviewed docket informaticn for six operating reactors and information provided voluntarily by three licensees; reviewed vendor supplied documentation and fire endurance

• :. .- and ampacity derating test reports; and visited five operating .reactors...:

.:•:;-" :-:Based on uts review, the special review tea concluided that: """""! :-

:":' •:';'* T":i'he fire resistance ratings an the ampaity derating factors for the Thernmo- ' -- • ..::i:•

:Lag 330-1 fire barrier system are indetermninate.

•:.::i•!::::-•i:.a: :!:•!:•:::Some licensees have- not•.adeuatly .reviewed .and evaluated the fire endurance test : ,?:::..:-:i.:!~.;•-

:'!•.!i!!.ii•= i-:;.;::::•:r iesults .and the ampacity. derating test reslultsu.sed a .the licensing basis .for their. -i!: ::. r : .•" ::"7 :••iii~•:!:i•-::•~i.• : , Therm[• o-Lagl bairs. 'to deterine. ,the viiyO tl tt ad l plcblt fte .::! ::•). i:!S

:•i•=:•:.•:•::::::•S:. ,, me li:.!cens.es have not. adequatey rcviewed the Tro-_Lag fire barrers installedm•. in .• :.:.;-.,~ ... •.:...••- ,;... ...... : th...leir. plants to ensure that they meet NRC requirements and guidance, .such as, that ......... .• -.... provided in Generic Letter 816 l0, lmplementation of Fire Protection Requirements,"

April 24, 1986.

* Some licensees used inadequate or incomplete installation procedures during the

construction of their Thermo- Lag barriers.

Safety Signific~ance

Although the special review team considers the fire resistance ratings ot the Therrno(-l.ag tire

barners indeterminate, there is evidence thet the barrners will provi•de some le',el of fire

protection. In addition, most fire areas haase low, fuel loads, controlled ignition source ',, and

are equipped wi•th other passive and acti'.e fire protection features. to alert and assist plant

operators in the event of a fire. Therefore, the review, team considers the relative safets,

significance of the fire barrier concern~s to b* low,

Ampacity derating calculations based on noncon~servative derating factors could result in the

installation of undersized cables and r-acewav oserfilling. flis could cause higher than

,1
design cables. operating Design temperatures within dhe raceways thereby rn~ucing dhe design life of the changes may be required to extend cable life and to restore safety margins. The special review team did not identify any immediate public health and safety concerns

regarding the ampacity derating issues, but recommends that the licensees and, the NRC staff

ass¢i the safety significance of any plant-specific ampacity dentfing issues that are identified

during follow up reviews of the generic concerns.

Based on its findings regarding the use of Thermo-Lag fire barriers by the commercial

nuclear power industry and the relative safety significance of the findings, the special review

team recommended to the Director, NRR, that the NRC:

* Advise industry ut the staffs concerns regarding Thermio-Lag fire barriers through the ucler Utlt Mngmn.adRsuce.oni .. (NUMARC),

0::,e. ::: Provide the industry with the= results of the team's plant site visits and the specific

:i:!-,i : •-::::::••concerns and technical i ssue regarding ThemoLag that were identified by the . .... /

informationf neeedby the staff to veri'fy compliance with the Nra 's reuirement,. :: : ::::

* Review the. lic.nsees corectve ct.n.pan for reovn . any plant-splecific: :Thenno -•

Its review. TheT team disu•e th techica ad-safety concerns it identified while..... , performing its special review assignment. The team provided a draft generic letter to

attendees of the meeting. The draft generic letter was placed in die NRC public document

room with the team's nmeting minutes.'

The review team's trip reports were placed in the NRC publi' document room on

March 18, 1992.2 This report documents additional technical issues and concerns identified

by the review team while performing its review assignment

Memorandum from F.J. Miraglia, NRR, to T.E. Murley, NRR, "Minutes - Meeting

Between the Special Review Team for the Review of Thermo-Lag Fire Barrier Performance

and NUMARC," February. 13, 199.2.

2 Letter from A. Thadani, NRR, to A. Marion. NUMARC, March 18, 1992..
The specia reie team has satisf'ie its charte and has t'ansferre the recmaining actvties to the NRR line organization. Ths actvities include, for example, finalizing the generic lette" prpoe by the special reie team, working with NUMARC and industry to resolve

generic tec.hnical and safety issues, and reviewing corrective action plans for resolving any,

plan t-spcfic issues.

iiii •••• i !1'• •i • b • • • * • • • i  ̧. ' '-' .. . .. 

".' . • " . . .h ̧
BACKGROUND

The Thermo-Lag 330-1 (Thermo-Lag) fire barrier system is available from its manufacturer

and supplier, Thermal Science, Incorporated (TSI, the vendor), St. Louis, Missouri, with fire

resistance ratings of 1 hour and 3 hours. The NRC licensees use Thermo-Lag fire barriers to

satisfy the INRC's requirements and guidance for protecting safe shutdown equiPment from

fire and to achieve physical ineenec of electric systems.

F~ptablishment of Special Review Team

Gulf States Utilities (GSU), the licensee for River Bend Station (RBS), informed the NRC of Thermo-Lag fire barrier installation problems• and of the failure of an "as-designed"

Thermo-Lag fire barrier during a 3-hour fire endurance test conducted by the Southwest .. Research Institute (SwRI).' Later, GSU reported additional discrepancies in the installation .... °••..•:..:of .ThtenmoLag fire barriers at RBS.' .In addition, in February 1991, the NRC received•

!i.:i May 1991, the staff visited RB to review with GSU the circumstances surrounding the ':!: ... "

i",.]failed retest and the installation discrpancies.. The staff found that the results of the SwRI ::•

fireendmocetes raised cocensrearing the ability-of Thermno-Lag to provide a.• fire:i:;• ..

In espnslet th RBS ositingesxperiengier anfomd algtospT.il the Mrleye tiecmtaior,.....

I|

'GSU Licensee Event Report (LER) 89-009, "In~equate Thermo-Lag Coverings as

Fire Bar'rier.Per T.S. 7 .7.7.a," April 17, 1989.

' Letters from J.E. Booker, GSU, to U.S. NRC, D1cember 20, 1989 and

January 9, 1990.

s GSU LER 90-003, "Inadequate Thermo-Lag Fire Barrier Envelopes. Surrounding Safe

Shutdown Circuits Per T.S. 3/4.7.7," March 8, 1990 and Rev. 1, July 12, 1990, Rev. 2,

February 4, 1991, and Rev. 3, June 28, 1991" and GSU LER 91-008, "Lack of Fire Wrap - Inadequate Fire Barrier Caused by lnconsistency in Desigai Bases Documentation,"

May 15, 1991.

6Appendix VII to letter from R. Feldman, TSI. to F.J. Miraglia, NRR,

October 5, 1991.
two conduits are protected with Thermo-Lag fire barriers a, Monticello. Conversely, Texas

Utilities Electric Co~mpany (TUi) has installed more than 20,000 square feet of Therino-Lag

in Comanche Peak Steam Electric Station (CPSES), Unit 1.

While conducting its special review assignment, the team identified 49 test reports that

document the results of tire endurance tests conducted to determine or evaluate the fire

:. resistance of Thermo-Lag fire barriers installed on electrical raceways. These tests, which

were performed by various spontsors betweent February 1981, and December 1990, are

identified in Attachment 2. Of these 49 fire tests, the team found that the NRC staff

reviewed four fire endurance test report for Thermo-Lag fire barriers during plant licensing

activities. These licensing reviews are discussed below.

•,i;•.;:: ,lour 1-h fire endurance tet onuce by SwRI for CPSES in September 1981l.. Based on its i.•';•':

"'••:•:i"u.e to mec h •rqurements of Apenix Rto 10 CFR artm O and was, threore,., • .•:

the secn an thrdtests reviwd~o bye staf were submitted byPensylve anias sucr as

Lgth acourany (Pthe iunac 1982m Aerature sotaff andethed thepsea of The rmoer barirsa

Cples, usdL nfor med srn thestfo ispeintenti toemerateres.EThtestaf als fots tehial base

SwR inaln Rheprt~ .0-4 a Fire barriers catiSunqTestnfa S rtemEectric Statiope (SSyteUnit

L.oetter, from RL. Thed teso barrie deig R.J hayh sTeaff acepted fonratn C ompanyyo

-Decefibergls 1981 a, . esaffonth eofteTe oagarircep ,bt

i o ept terfo N.W.g Curtis, PP&d euetedA tchaencer, sNRR, test ua' to de9 ns2at

aTerhca NoL ubte822a1 TEninern Test rpRteo uport t- dOine cHanue ASTM E-af FrevSmlation

Filtye Fire Test wasllowried bn th Shport Te Watedwos srm AStr elm tmpac Thestaff foassnd

thbe accracy ofd the furnac temperat" une otoladth8ye1. tenmbro

thrmcupe ue frmesuig et pcie tempeature. The staf als foun tha th

'! ~ ~'SwI• Re..o..t "3-6491, "FrQulfcto Tes of. a:' 'Prote.tive"Envelope Sytm"... ".".""i

' "Otoer7 1981."""' "'•'""i•
application procedure used for the test specimen was not clearly specified and that the test results did not provide adequate assurance that the proposed cable wrap was tested in the asinstalled configuration. Finally, the staff was concerned that adequate quality assurance

procedures were not followed in the preparation of the test assembly, during the conduct of

the test, and during the preparation of the test report. On these bases, the staff concluded

that the test was xot performed in accordance with American Society for Testing and

Materials (ASTM) Standard El 19, "Standard for Fire Resistance of Building Materials," and,

therefore, was not acceptable." Later, PP&L submitted a report for a 1-hour fire

endurance test conducted at SwR! for PP&L to justify the proposed design change.' 2 This

SwRI test showed that conduits protected by the proposed method provided a 1-hour fire

rating. However, the cable tray and air drop barriers failed to meet the temperature rise

acceptance criteria. The staff accepted this test for conduit fire barriers at SSES, but not for

cable trays or air drops."3

?:•The fourth report involving Thermo-Lag fire barriers that was reviewed by the staff was a ' . ,

•.ii, -3-hour fire endurance test submitted by Washington Public Power Supply System (WPPSS). . : .-

documene ,test of specimens assembled using the vendor~s direct sray application..metho..iil -,iiii !•!

Howeve, with the excpto ofSE, :Unitl1 and. limited applications at :WNP2, the rev•.iew :i i••!ii:i!

Mot fth hem-Lg ie arir intle in th fied are constructed of prefabricatedii.!•'ii~~!i]!i

ThemoLa pael 30. ad rehaed onui.sct.n ththvebee cut :to size and ,i••••::•-':

,ndviUal. ~NR, SfetyEautionset r Repor Reited trow gdetheOpraion ofL Suserialna MStea

the tric testin Unpits identiid b, thUreG-07team douplment 3,e Jeults of2 test 9invlig. h

tyespor nta-l6, QaificatiHon Fire Thest reort ProtecaipeaEnoeloe b besen. reviewe by9the

" U.S. NRC, "Safety Evaluation Report Related to the Operation or Susquehanna Steam

Electric Station, Units I and 2,' NUREG-0776, Supplement 3,Jl 92,Nv br192 pg 9-2.

I4 TLRettort fro2-5-C3ti55BL,'ht-ou A.irhe Edrncer TResAguts Tem-and 25, 3S0R1

Repormin 01763oQaifiainFrneg Envelope faPoetv Sysem.frWPSNcla rjcs J " Augst8982

'• U.S. NRC, "Safety Evaluation Report Related to the Operation of WPSuSuean Steam

Project No. 2,' NUJREG-0892, Supplement 3, May 1983. pg 9-3.,
Previously Identified Fire Darrier Concerns

While conducting its review, the special review team found that both the NRC and industry have addressed prior concerns regarding fire barrier testing and installation. Examples of

these concerns are discussed below.

In SECY 83-269, "Fire Protection Rule for Future Plants,' July 5, 1983, the staff" informed

the Commission of generic issues arising from its review of almost 600 requests for

exemptions from the requirements of Appendix R to 10 CFR Part S0. These issues included

problems encountered with the testing and installation of fire rated cable wraps. The staff

reported that although the materials performed adequately in laboratory test furnaces, field

,installations introduced uncertainties due to variations in the training and abilities of

installation personnel. The staff considered these uncertainties to be of marginal safety

significance. The staff also reported that same facilities had installed fire barriers without a ::

i :i-basis for their fire rating .such as an Underwriters Laboratories, Incorporated (UL) listing or -.,• ti••esting conducted by a nationally recognized testing laboratory for the configurations instaflld , ,•. aiii!-)n the plant..The NqRC informed the industry of these problems in Office of Inspection and.i.;i/: ! ••.

•i!i•Enf-orcement (olr) Information Notice (I) 84-09, 'Lessons L.earne •From HRCInspections .i/•,i••.

!•Fi of Proecio Safe Shutdown "Sy.stems •(0 cFR 0o, Appendix. R),, :Februaty 1t3, 1984. " ,. -. ,-/i!•:i

Th!eINstitd:'A oreofth s faities ispectd, fnireF barriers wreinstled without basis :., ••,••

- f= a!or t-hor fire ra (suchause ring UL lisigotestine g conliduted byaate ipoely nal recogiz ntsed

tes5n taor1-intoe for te confinguraThoe lienstaeslvedi thelats Fiss e byarierovinstalld topla een

thme ofrequireet ofaSecior nd by. oulfyApnixg othe st havi e snucharanetisscndute.a T

Dinrlnyain986rAhpendi, aR pnsp ftion ofdulNP2 annualsiaffefoind that lienseepf for WP

elendtrioa d~efiieis roeedwith : Thermo-Lag fire narie protecteding acoetyrdanced wthble

trayted c~fgrThe .licensee l resolvedehe defets--inadi uateb chronducgthicng ad s ona thfide ri

duia7 Inspectio n sReo 50-39 t 7 theAri f 17,f •19ha87.og ednat ae~hsdw

drus WPPS E 104,"ndqaeFre ProtectionwithThermo-Lag) prtecion of Divish i ~aafe 11vde So a

aShurt3-our fire De b troz ncause ~the Icnseea ppla ienad thseto. m Aterial mpoprl an9i9 utete

configration. Prlmnr:eulso et onutdbh liene iniaetatte1hu

.'picati"n may prvdea3 .t, o 50miut irrtig Th.-hu aplcto may. prvd
of the cable tray and an incomplete transition between a prefabricated Thermo-Lag panel and

a Thermo-Lag spray application--to installation errors and inadequate inspection practices.

In another example of a plant specific problem, CPSES originally built its Thermo-Lag fire

barriers using panels that had been site-fabricated by the CPSES constructor. Subsequently,

the licensee identified deficiencies in the thicknesses of these panels during inspections of the

installed fire barriers."9 The licensee removed about 12,000 square feet of the sitefabricated Thermo-Lag panels and replaced them with panels manufactured by the vendor.

Although not directly related to the Thermo-Lag fire barrier issues, the special review team

noted that the NRC recently addressed similar concerns regarding penetration seai design,

qualification testing, and documentation. The team found that the operating experience

discussed in the information notices issued regarding these concerns•) provided insights into

the implementation of the NRC's requirements and guidance for the protection of safe

.. :shutdown capability and qualification fire testing. . .

::ii-lle Wh:?i, conducting its reie-w assignment, the speial .review team reviewedl nine test: reports ' . : : ::

.::••:- •:!iithat document thereults of, tests conducted to deltermine the ampacity dentling factors for ... . :. :.:•il

vari•:!:•+:! ous hemoLag :fire barirs Thes test .reports are identified in Attacwhment 3. . ., :::: :.::(

-actors th"t were : dterminWed .• by tetig. ":For eaple;, t.e vendor pro'..vi~ded test reports to"-: , .!i.-::•':::::.!io

,! : licenseesthatdocmet amp.ctydetig factrs for cable trays that range from7 perc~ent to.ii",i:::i:::::'

28i~.-•i:: percensi, t, for 1i-hour bariers- andfrm 16 pecet.to 31 pe~rcent for 3-hour barrier., ,By /-,•".i:!:i ••-i; :

-i•~!!:i:•Reports 82-'355-C, 82-355-F, and •82355•Fl..iThe r-eview team ialso found that an ampacity • -.:-,-!:i':•",i( :

derating test conducted at SwRI yielded ainpacity derating factor of 37 percent for a i-hour

barrer.

The special review team also found that the staff and the licensees have previously addressed

concerns regarding ampacity derating. For example, in 1986, NRC inspected the Minnesota

* "Letter-from W.J. Cahill, TU Electric, to U.S. NR('. October 1". 1989.

SIN 88-04, 'Inadequate Qualification and Documentation of Fire Barrer Penetration

Seals," February 5. 1988; IN 88-04, Supplement 1. "Inadequate Qualification and

Documentation of Fire Barrier Penetration Seals," August 9, 1988; ,id IN 88-Sb, "Po~ential

•Problems with Silicone Foam Fire Bamner Penetration Seals," August.-, 1988.

21 UL Project 86NK23826, File R6802, 'Special Serx ices Investigation of Ampacity •

Deratings for Power Cables in Steel Conduits and in Open Ladder Cable Trays with FieldApplied Enclosures," ianuary 27,-1987..
Mining and Manufacturing Company (3M), Saint Paul, Minnesota,• to reviw the circumstances suroding concerns identified during an NRC inspection at Fort Calhoun

Station.z The NiRC concerns were: (I) Omaha Public Power District (OPPO), the

licensee for Fort Calhoun Station, dil not verify the validity of the amr•'ity denating values

supplied to them by 3M, and (2) OPPD or other NRC licensees could misintepret the

dentxing values because of the way they were presented by 3M. After the vendor inspection,

3M informed its nuclear customers that its ainpacity denating information should be used only

to assess the general impact of 3" "' fire protective envelope systems with respect to

ampacity denting and that amp• .

1 critical situations must be evaluated by performing

actual tests.

K ,:•:• ...""- -,.••, 

') .- = , • : , .:{; -" ; "•• •= :•-ir :" -i '- : • " ' ." " . ',- -=-

, . ,, .:. - : •, 2 - •= . ' ,, - - . .-.. " . , . , . . : • : • , " : ' . . . . .

Ilispection. Report 99901038/85-01, March 11, 1986.

23 lnspecr.•A Report 50-285i85-22, December 13. 1985.
NRC REUIEMN• AND GUIDANCE

While conducting its review, the special review team reviewed the NRC's requirements and

guidance regarding fire barriers and arnpacity derating. and the documents that provide the

bases for the requirements and guidance. The following discussions provide an overview of

the current requirements and guidance regarding fire barriers. They do not contain any new

requirmets or staff positions.

Federal R~egisr, Volume 45, Number 105. "Fire Protection Program for Nuclear Power

Plants Operating Prior to January 1, 1979," May 29.- 1980, and Generic Letter (GL) 86- 10.

"Implementation of Fire Protection Requirements," April 24, 1986, contain detailed

discussions of the NRC's fire protection requirements and guidance. (The NRC's

requirements and guidelines for fire barriers are contained in a variety of NRC documents.

The extent to which these requirements and guidelines apply to a specific plant depends on

iv:.-plant age, li!censee commitments, the NRC safety evaluation reports and suppiemets for_ the . "i?

General Desig. n Criterion (DCc) 3, Tire protecton.,"of Appenix A,. "Genera Design ..- =:.

•••i:.•"Criteria for NTuclear Power Plants,'. to Title .10 of• the.$. :Code of Feleral Regadations, Part -..=....:.-.• i•:•,.50(10 CFR Par 50). s tateshatstrctues ,systems. and compents important to safty• shalll..! :..: ii:•ii!

prgasto 'ifyGD :•:3"Foloing .( a major .fire at the Browns Ferry, Nuclear Staton on...;: "-•-: Mar. 22!:!,,975 tb.NRC evlute the eed for improving thefire prteton ;programs: at:i:;:ii:•::

aly neary p90 o stoerain plantsFolwn this ivaluaetidont, NCise the oguidalnes fnBTor •:S

.5Imple Apntixg AD toiBrnhTPA cSB n5ica Positi r, .D uilayad eu~ oe oversilcn• oaop

Syblstems aw (prop se)drule ucdlear Go patfire foer protection, fetor Nc .ear PowerePan

protect~g ioan," (O CR~r r50ct8) ind Appendix A to BTP ACIR Part50, " uidelPotione frogra F"

Proretonf Nuclear Power FilteOperantsn okedPrior to Ja uly•.I 19,76." These prpse minclude

gUidanc for, iRe borrerandapoetions ofelaed trioal BronstFeructFions." UEByebrarly 19807 otoeaigpat hdipeetdms fth udlnsi T PS

.10
requirements for the unresolved issues.' On February 17, 1981, 10 CFR 50.48 and Appendix R t0.1!0 CFR Pant 50 became effective.•

Section 50.48 requires that each nuclear power plant licensed to operate before

January 1, 1979, meet the requirements of Section [IIIG, "Fire protection of safe shutdown

capability," of Appendix R to 10 CFR Part 30 even if the NRC had previously approved

alternative fire protection features in these areas. in a separate action the Commission

required that all plants to receive their operating license after January 1, 1979, also satisfy

specific requirements of Appendix R to 10 CFR Part 50, including Section ilI.G.

The objective of Section 1f.G of Appendix R is to ensure that at least one means of

achieving and maintaining safe shutdown conditions will remain available during and after

any postulated fire in the plant. Liesees can satisfy Section IlIG by separating one safe

shutdown train from its redundant train with fire-rated barriers. The fire resistance rating

required of the barrier, either 1 hour or 3 hours, depends on the other fire protection features

provided in the fire area. Many NRC licensees use raceway protective envelopes, such as

Thermo-Lag fire barriers, to satisfy the separation requirements of Section lIIG of - -,- -ii.ii/•:'A ppendi RI 1oCFto Pai 50. -. .. .... " .•.fi!

The ,NRC has provided guidance for implementingisfir Ce protction requirements through ... i :ii!•i

regulatory guides, stndr review .plans, branch technical positions, and generic letters. •- .. .. •...

,•-'.?.././BTIP Chemical Engineung Branch (CMEB) 9.5-1, "Guidelines .for Fire Protection For .. -=. .,_•:•

• .i:! •!9Nuclear Power Pl~ats,, July1981L, included the acceptance criteria identified in a number of i. ~:i.--."-•

In:•:tese dcuentrs, including Appendix R to 10 CF Part 50. BItn' CMEB 9.5.1 states: "This ::.l:

dolowumnt suppmisionmentegltryGde17inetmning o sttsffApedir the iproecettion for

Meaye Mach0, 1984, ayo the ie torfor sxc hedp eraiens (EOf dreg tedN wo RR tsos witaih th fie

aprotectson poicy stering theompiteeentFS).tio orevhew NRfire protction resuuirements.r

zsU Fire .NC Protection Gru'UProgra follwn erNucary Power, inlants Oemnratin which

U. S. NRC, "Fire Protection Program forOprtg Nuclear Power Plants,"OpeeratigPirt

SA group formedl in 1980 to participate in fire protection matters and composedt of 27•

nuclear utilities.

11.
consistent FPPSC was 

levels of fite protection safety at all plants.' One of the issues reviewed by the| the adequacy of the NRC guidance to the industry. In its final report,2' the

FPPSC concluded that the NRC had provided adequate technical guidance to the industry.

but that there were areas where confusion could arise. The FPPSC concluded that new

guidance was not neeed and recommended that the existing guidance be brought together in

one generic letter and that the Standard Review Plan, technical specifications, and licenses be

made consistent. Following comment by the program offices and the regions, the EDO

directed in December 1984. that the FPPSC report be issued to the utilities and to the public for comment. " Comments were received from individual utilities, NUFPG, and

consultants. The F'PPSC updated its recommendations to reflect resolution of the

comments," the recommendations were reviewed and approved by the Committee for the

Review of Generic Requirements (CRGR)," and the EDO recommended to the Commission

that the generic letter proposed by the FPPSC be issued." The Commission accepted the

EDO's recommendation on March 7, 1986.'u The generic letter proposed by the FPPSC

was issued as Generic Letter 86-10. "Implernentation of Fire Protection Requirements," on

April 24, 1986. The detailed guidance provided to the utilities by die staff during the -. : .. :regional workshops was appended to GL 86-10...

The special review team found the outcome of this review of the NRC's fire protection ).!

-~~requirements and guidance significant to its own review effort for a number of reasons. •. ). . •-::•Firs, the staff had completed a thorough review of the NRC's fire protection requirements . - .. ":

•:::i:,) i:.!.-:and guidance with Commission involvement and approval; second, the review concluded that :-:!:

::the NRC had provided adequate technical guidance to the industry; third, the staff uniformly . ..- d::isse:id mi'nated its inteprttions of the ,requircments and guidance to the industry; fourth, the :::i ! ::i!:.).i-:-

"•Memorandum from W.i. Voilcer, EDOS. to HR. Denton, -NRR, Ma 3l, 1

September. 13, 1984.

•4 emranumfrom hik olcyca) P.. Steain C'tlommJte. Aton W-),Lic

Mach~e 7, 1986

.. .L85. FiePoeto tein 1omt2 eot Jnay9 95n U.S..
• • staff solicited comments from the public and the industry; and lastly, the staff received only one editorial comment on its a ceptance criteia for fire banriers," which it incorporated

into GL 86-1O.•

The NRC provided its technical basis fo requiring 3-hour fire barriers in the Fede~ral

Rrgiter noice that issuedl10CFR 50:4•and Appendix Rto 10CFR Part5O. TheCNRC

stated that although nuclear power plants have low fire loads, the potential consequences of

fire are serious. Therefore, :3 hours was selected as the minimum frie resistance rating for

fire barriers used, to separate redundant safe shutdown systems. Where plant conditions

preclude the installation ofta 3-hour fire barrier, the NRC considers a I-hour frie barrier with

automatic frie detection and suppresson systems to be equivalent to a 3-hour fire barrier.

Thrfore, fire barriers relied upon to protect shutdown systems need to have a fire

resistance rating of either 1 hour or 3 hours. The NRC also noted that fire barriers are rated.

for fire resistance by being exposed to the standard test fire defined by ASTM El 19,

:•. Standard for Fire Reistance of Building Materials. BTP APCB 9.5-1 and Appendix A to ... ii'R-TPii} IL:•I APCSB •n9.S-l refernc NF•PA S$ndr 251" and defnel fir rating as: "the endurance

:,:,)"*?•i•period of a fire barrier or str~xuctr; it defines the period of resistance to a standard fire

}..-/, ',exposure beor the :fi~rs cr•itica point,,if behvior is observeId.e'

smeutation needed to verify the fire•, bare rtn and the evaluation of deviations :::•.•

raigof eac fire btt used to satisf the NRCs$ requirements should be determined by a ,•

stanardfire enurancetsL Thi stndr,,STM £19 or NPpA 251, sp~ciie •that a test : :i

tpecmpereture sent°Fatief the cognningction fore teith afie resuting is5 deird asod mateias

tmperthodre rsterby ioensisnsed eause thefiraea ire, berrerpsd funactionar topestefrve.th

~ ~1beNRecmenatpies ofthe Fire25 Prtctionc Picy teel o rcering Com irte ba0R2irstoeec6.a

'Section~av 3.2sh "Frra2e s~ tualification, of itls un'ex2pos surface0 Aorel t4han8

250 aioa F i e irbo roieitia Asmociatur. tisognerFAll trt g"dad that Stheambadenthd airir

Temeratur is 75Butihebeining n Mat ofsrto fieri test. The rde sucltin 325M col9ad sid efrne

insoe NCY-53 ncl Eud ocure9 Sern omte eouino oments.o h

' .} ' •.• • . *:•i•:

13
integrity of the cables and keep them free of fire damage. GL 86-10 stated that cables thai begin to degrade at 450 OF will be free of fire damage at 325 OF.

GL 86-10 also stated that to verify the fire resistance rating of the fire barrier, the licensees

-should have the design description of the barrier, and the report that documented that a test

assembly passed a standard fire endurance test. According to the tes standard, the test

assembly should represent materials, method of assembly, dimensions, and configuration for

which a fire resistance rating is desired. Construction variations may substantially change

the performance characteristics of the assembly. Therefore, to ensure that the fire barriers

can provide the level of fire protection required, the licensees should either install barriers

that replicate the configurations that were tested or justify that fire barriers that deviate from

the tested configurations provide an equivalent level of protection. in Section 3.2.2,

"Deviations from Tested Configurations,' of Enclosure 2 to GL 86-10, the staff identified

•five criteria that should be met by the licensees where exact replication of tested

configurations for cable tray and conduit barriers cannot be achieved in the field. The

criteria addressed the continuity of the barrier material, the thickness of the barrier, the

-nature of the support assembly, the end use of the fire barrie, and the review of the .:-.iii::

:• :- .configurations by a qualified fire protection engineer. Section C, .'Documentation Required '

calcula.tiaons,- nede demonstrate complac with Appendix R. • .. •..::::!,

GDC17,"Eectri: poer systems,. :of Appendix A t10CRPart SO, states: ,'The safet

ifuncio for each[ (electric powerji system :shall be to :provide .sufficient capacity and capability-:., .•i• •.:

Ixwer cbes enlosed in letical ra.ewys usinlg the ampac ~t'y dnng factors for .the .•:: :•:-!.i~~i••i

i•mateia uroning the cables, scascbLe ay,.coduit, o duc..ans. Cbl, .

systems," requm that protec sy4m.3t ~Stion h eureet e forthEE2 indteInstitues th

"••Nuclear ftower Generating Stations,'"(IEEE-279). Scin43o EE29ietfe h

requirement for derating of components.

BTP APCSB 9.5-I and Appendix A to BTP APCSB 9.5-1 state: "Possible cable derating

.owing to use of (fire retardant coatingsl must be considered during design." In addition,

Section 8.3.1l, "A-C Power.Systems (Onsite)." of NUREG-0800, Standard .Review Plan."

Revision 2, July 1981, states: "PSB (Power Systems Branch) will review cable derating and

raceway till to ensure compliance with accepted industry' practices."

Conclusio

In the. review team's judgeme~nt, the staff provided adequate technical guidance regarding fire

barriers to the industry and took appropriate actions, such as holding meetings and issuing

information notices and generic letters, where confusion could arise. The team. found,..

" 14
bowevu, U• th gidince may met have ben impemnted by the licesms anaway tha

15
:i: " " SPECIAL REVIEW TEAM ACTIVITIES, CONCERNS, AND TECHNICAL ISSUES

Scon~e o Rviw

The special review team focused on the following generic safety issues regarding the use of

Thermo-Lag barriers by the industry:-

* Will Thermo-Lag tire barriers provide a rated fire barrier when installed in

accordance with the tested configurations and the vendor's installation procedures?

* Have the licensees evaluated the fire endurance and ampacity derating test results used

as the licensing basis for Thermo-Lag barriers to determine the validity of the tests

•.. and the applicability of the test results to the plant designs?

* Have the licensees evaluated the ThroLag barrier configurations installed in their

plants to ensure that they meet the applicable NRC requirements and guidance.?

=,•:•,)'ave *)~. H: the licensees instle their Thermno-Lag fire barriers properly?-•"

* Have:i[.i.'i(! i theliceseesreieedthe revised ampacity derating factors-for Thermo-Lag. *

f:([hat t~~ were prvddby the vendora to determine whether or not they were applicable i

(Atachjt ), NP2(Atachent6).thePerry Nuclear ipoePlant (PNPP), and SSES [

~ (ttchmnt7);reieed nfrmaio prviedvoluntarily by the licensees for the Palo ~~i~ :

•' Mailgrazn from R. Feldman, TSI, to U. S. NRC, October 2, 1986.

"Memorandum from L.R. Plisco and K.S West, NRR to F.J. Miraglia, NRR,

October 31, 1991.'. •

•4o Memorandum from L.R. Plisco and K.W. West, NRR to F.J. Miraglia, NRR,

December 24, 1991.

~' Memorandum from L.R. Plisco and K.S. West, NRR, to F.J. Miraglia, NRR,

December 11, 1991.

42 Memorandum from L.R.• Plisco and K.S. West, NRR, to F.J. Miraglia, NRR,

December 18, 1991.

16
and the Callaway Plant" to review licensee fire barrier procurement and installation specifications and procedures, and to observe designs and field installations of Thermo-Lag

fire barriers. (The review team's trip reports were placed in the NRC's public document

room on March 18, 1992.+') •-

lNRC Meetlng with TS!

During its review, the special review team developed questions regarding Thermo-Lag tire

barrier compnets and materials, barrier installation methods, and fire endurance and

ampacity derating test procedures and results which it submitted to the vendor."5 The

vendor answered the questions,". and, on October 17, 1991, met with the staff to discuss its

response and other technical issues arising during the review.47 Following the meeting, the

review team issued follow-up questionsTM which the vendor also answered."•

Vendor hnspection or TSI

The special review team requested a vendor inspection of TSI and assisted the vendor : :.;!

i~i.i:••:+•+.i:-.inspectors prepare for the inspection and develop the inspection plan. The vendor inspection, ".,•+:•.!

F i~i? i:.which was conducted December 16 through 20, 1991, consisted of an examination of : '•;

•o-•!."•procedures and records, interviews with personnel, and observations by the inspectors. The ._:+,

m!•i,.nspecrs found that the vendor's QA program (1) did not specify a requirement for." . -:-.i!•:

i!:i•measuinug the :minimum thickness and maximum weight of prefabricated panels and conduit :iYi

:;•sectionsand ({2) did not specify adequate cmontro over fire endurance tests. The inspectors - i :: +. - •:•••found that fire endurance test reports issued by Inusral Testin~g Laboratories, Incorporated .:/

•(ITL) were actually ywrittenb the vendor adrpre the results of tests performed by the :•_•,:

" 3•. .3 . . .' • +' ; • F '' " '/ . " : .

.... • ,iXI, nO m frmL. bc:n .. et NR o:.MagiNR, &

"sLetters from F.J. Miraglia, NRR, to R. Feldman, "TSI, September 10, 1991 (Accession

Number 9203180415) and September 18, 1991 (Accession Number 9203180424).

46Letters from R. Feldman, TSI, •to F.J. Miraglia. NRR, September 12, 1991 and

October 5, 1991..

'~Official Transcript of Proceedings, ,Meeting with Thermal Science. Inc., to Discuss

Issues Involving Thermo-Lag 330," October 17, 1991. (Accession Number 9202050305.)

"•Letters from F.J. Miraglia, NRR to0R. Feldman, TSI, October 31, 1991 (Accession

Numbers 9203180429 and 9203190253).

',+ Letters from R. Feldman, TSI, to F.J. Miraglia, NRR, November 8, 1991,

November 12, 1991, and December 3, 1991.

17 .
:•:vendor of specimens constructed by the vendor. The inspecton report was issued March 26, l992s° with two Notices of Nonconformance.

The special revew team reviewed the RBS operating experience and SwRI Draft Report

01-2702, "Three-Hour Qualification Test on Two Protective Envelope Systems for Class lE

Electrical Circuits and Five Penetration Seals," May 1991. The team then prepared

IN 91-47, "Failure of ThrmoLag Fire Barrier Matrtial To Pass Fire Endurance Test,'

which was issued by the NRC on August 6, 1991. This information notice alerted NRC

licensees to a number of Thermo-Lag fire barrier design and installation deficiencies

identified by GSU at RBS.

While reviewing IN 91-47, the Cleveland Electric Illuminating Company (CEI), the licensee

for PNPP, found discrepancies in the installation of Thermo-Lag fire barriers that could

adversely affect the safe shutdown capability at PNPP. Specifically, CEI found that the

• disane between mechanical fasteners exceeded the vendor's recommendations." On_'

Novem-... ber 19, 1991,rmembers of the special review team visited PNPP to review the issue . .... wi th:CEJ and observe :the as-built The ,oLag fire bariers.Y.. -•-•--

Duini,.:• g the vis, to PNPP an the.four ioteplants,the team identified a number ofThrm~o-:" "..

:!!i•.Lg fire barrier installatin :problems andl concers. Iln addition, during the meeting of ?::i~•i

•iii.;October 17, 1991, the vendor informed the NRC thatits. installation procedures did not ,-.':..•... .:_:.

•:iDeficienc :iesinte roeursfor Ilnstalling TeroLag F'tre Barrier Materials," to inform ifii.:il, i%'•

th .RClcnse.o. h obere isaaion polems, (These installation issues are •:•:

detailmedt INho179,oin 2a thncin bofd thpefOctobere 17,ew) 19meTinadihe tcncdassac team's 

tr.Inprepotsiond, lwort~ not22/1-1 ripeaed Mnrthi r6,port.)

s' CEI LER 91-020, 'Cable Tray Raceways Found to be Impaired as a Fire Barrier

Adversely Affecting Safe Shutdown Requirements," November 19, 1991.

"• Memorandum from L.R. Plisco and K.S. West, NRR, to F.J. Miraglia,, NRR,

December 18, 1991.

53 Official Transcript of Proceedings, "Meeting with Thermal Science, Inc., tO Discuss

Issues Involving Thermo-Lag 330,' October 17, 1991, pp. 155-159.

~18
I

contractor, National Institute of Standards and Technology (NiS'g), provided technical input to the team's reie of seven of the test repo~rts.

The rev'iewv tam identified cocen regarding compliance with NRC requirements and

guidance, compliance with ASTM El119, and adherence to good engineering practice. The

tearn's specific cocrs involved test procedures, test facilities, test equipment and

personnel, methods of asse.mbly, quality assurance, and acceptanc~e criteria. Based on its

reviews of the test reports, the team concluded that many of the tests did not met NRC

• requirements and guidance and, therefore, may not provide adequate technical bases for

estblishing the fire resistance ratings of Thermo-lag fire barriers.

In addition, the team is concerned that for the test reports it reviewed, the process used to

determine the fire resistance ratings of the Thermo-I.ag fire barriers deviated from good

engineering prctces. ASTIM El 19 fire endurance tests conducted to determine the fire

resistance rtring of an assembly differ from other types of qualification tests. For example,

the fire barrier assembly does not come manufactured from the vendor (such as a fire door

:.,.. assembly), nor is it a matter of assembling component parts together in the field. ,Instlead, .:.:

::killed s ' crafts personnel have to be instructed and trained how to construt a rated assembly

:,:::::using variety of component-pans for a range of config~urations. The fire resistance of the : -

fatnr pca, atee loaion, andamyriadof odier constrction details._ Therefore, for ,:/,:::-::•

as emle reqruirig a ,t-zed design," testing laboratories clearly document the design to be : :•i:.

Ti s uau!wO ~~ wste ge(ometrty) h €mon,...

pspcife contrutio details suc as :minimum meas, remeni., locations of- .:::::":-:.i::

copetandmethod of aseby. :J•r the team's judeet, ,the lackof a •well• • :' •/ i.

OnampOctofbse ci6f98,SR]prorei3hu fire endurance ocrsietfeesin ythe reviewlewam follo

(Adirofthisna testinraisses corern detaildingI 14,i adeqnac the Throf-the rf Ocbler 17,199

have thi s ie thl tes~tri relrtplae ntheNR ubi document room. ) jpo

On• October26f1t9 SRep perfo1202 Trmed -Hour Qufireaedurnc Test of av~ cablectiayan

supplortproteteds byr Cas IhEroa firebarieal frcut aSd Thve tesetrpratio shows, that the1

19
I

i~•'After IN 91-47 was issued1 the vendor, in letters to licensee fire protection engiees and the NRC," stated that the October 1989, SwRI fire endurnce test was not a valid test .

because of installation deficiencies. The vendor believes that the Therrno-L~ag-protected test

assembly failed and collapsed because the seam at the interface of the Thermo-Lag and

~Promat interface, which covered the cable tray support, separated wnder fire exposure and

~allowed fire gases to enter the interior of the cable tray.

The test assembly consisted of two 30-inch-wide aluminum ladder back cable trays spaced

~about 4 1/2-feet apart and supported by a U-shaped tube steel support. Each troy began 12

• inches above the surface of a concrete test slab, extended downward through the slab to a

900 bend, continued horizontally for 4 inches to another 900 bend, and extended upward

through the slab for 12 inches. The bottom of the horizontal section of each tray was 36

inches below the inside surface of the slab. A common support was anchored to the

underside of the test slab and supported both trays at the bottoms of the trays. Each cable

.tray was filled with about 12 percent cable fill, with a single No. 8 AWG bare copper wire

,installed in the center of the tray.

, remaningpmortos of the vertial runs were unprotected and were exposed to th fur -naceii•:

firei].) The two dissmilar fire barrie nmatias met near the ener• of the horizonta poroni ,•:ii,,

of. the: suppor, The •deails of th... ae .. esg werenorertd

' "~ 'O T be7,91the review team trsoaisculed thetsolr wit th vndo intrviewe the Octobemployee99

mei.Tevedrinformed the thietasbywscn team that rve truct intcodneswth reeied 1at ands 

photogaphsofthelesti pfdr secmn osun '131certife nthallers hand nthateve the test w spcnde ien,

did wi nt essthews, nd thadnt G a revidwed soh e test dapot. Duin the v eetndo , ads th c

metn.Tevendor informed the th etfie revewfea that ithin ad rateceve intest deaueta a disii e 

•7 Letter from R. Feldman, TSI, to F.J. Miraglia, NRR, October 5. 1991.

20

t

iI
U

fir barrier mateials pnacting the cable tray support separated under fire exposure thereby

allowing flames to enter the cable tray. s .

The review team performed an independent evaluation of SwRI Draft Report 01-2702. NIST

provided technical input to the team. The review team reviewed the temperatures recorded

at locations on the bare copper wire adjacent to thermocouple (TC) 82 (located inside the

Thermo-Lag-prtce tray on the bare copper conductor in the horizontal portion of the

tray), as well as tempeaue along the horizontal support between the insulation interface

and the center of the cable tray.

Temperatures recorded at points along the copper wire adjacent to TC 82 ('Tc 81 and TC 83)

do not show evidence of impinging furnace gases before or at the time of excess temperature

at TC 82. Although it is possible that a narrow jet of furnace gases entered the cable tray and struck TC 82 but not TC 83, which was closer to the interface of the Thermo-Lag and

Promat fire barrier materials, the more plausible explanation of the temperature recorded

during the test is that the Thermo-Lag material enclosing the tray failed in the area of TC 82

indpedet of any failure at the intrfrtace of the materials. .

'.' The ,eview t.... concluded that th vdo's expana... of.he.e. falr is possible.i:+'i

H!i:..owever, based on its inrves with GSU and the vendor, and its independent review of "-

the ~iu•.reportand test the thwmocouple temperaure data, the team concluded that th SwRI test •: :'•• spcmnfailed due to a failure of the ThroLag material enclosing the cable tray, ; ",!:•i

ineedn of any failure oth aealprotecting the try support. This finding ;i::•++

cotrbue to th review tm's cncuion tht the fire resistance ratings for Themo-ag .. i:i~•:.•+ einet.miat .. Adiknlqulfcto . tetn issues and concerns that reinforced this . .-- •:!•-J

s t.. . .......-

dicse eo. +NIST p""ddtchi~ nu to the team's review of four of the ITh "

ITL Tests - Common Comcerns

r The review team is concerned that ITL may not have the skills or technical expertise needed

i to perform ASTM El 19 fire endurance tests. The team found, for example, that although

ITL is listed in the ASTM-published directory of U.S. tksung laboratories,'• ITL does not

identify expertise in tire endurance testing in its listing+

u' Official Transcript of Proceedings, "Meeting with Thermal Science, Inc., to Discuss

sDirectory of Testing Laboraiories, 1991 edition, ASTM, Philadelphia, PA.

21

I
The ITL test reports indicate that the tests were controlled and supervsed by ITL, but the temfound that ITL may not have partcipated in the prprton or approval of the test

plans, the design or construction (including inspection) of the test specimens, the installation

'of the thermocouples, or the operation of the test equipment, which is located at the vendor's

facility. ITL's role appears to have been limited to witnessing data acquisition. During the

December 1991 vendor inspection of TSI, an ITL representative that was involved with

several of the fire endurance tests informed the vendor inspectors that he did not compare the

test specimens' dimensions against the test plans or the daily work sheets, and did not review

calibration records for the test instrumentation. The ITL representative stated that his role in

the tests ended when the raw test data (thermocouple temperature strip charts) were

collncted. The inspectors found that the vendor drafted and prepared the test reports,

including the raw data, for ITL's signature. The ITL representative informed the vendor

inspectors that his review of the test reports .prepared by the vendor was minimal and did not

include comparisons of the repo~rted data against the acquired raw data. (Detailed discussion

nf 1TI.'_ ml. in th.e T•I tire •ulmraneeP teI thai were nnyente'4 at IT! les_ am includedi in

Section 3.7, "Qualification Type Testing," and Section 3.8, "Industrial Testing Laboratory ...... -Role," of NRC Inspection Report 99901226/91-01, which was issued on March 26, 1992.) ..-. i!~ii

:•i!ii'~ii•'•.iii:JT•. ll did not specify whthror not the thermocoupie assemblies or the placement of the .. ..!..iii~ii

!•!ii••/ .••!i•Thermocoupls,"-of ASTM El 19 specifies that furnace thermocouples use No. 18 gage -" •i!i!,._•:

÷ ;•..•-":'• . .:.Cbromel-AdumeI wires .and that they be enclosed in standard weight iron, steel, .or Inconel . ."":

::;' :• ther-mocot.apici• Section 4 ahso-specifies the guidelines for the locatio0ns of furnace ::.".'.-.. . •!•:::

• ,••:, thermocouples::• • .,-!TL"referred to usng shielded Chromel/Mlumel.terocules for : '::.::•:, mntrnfractejeare.Tervetemicocreththeueof incorrect :

therocople asemlieso •i:mWprop placmet of.th terocuples coud affect the :control.•:•,•:•i

of te hefae biit es an tomantinth stndrdtie-em eratrecurve- specified by. •. ..'•: ii

ASTM~l9.~........... . . .

the construction and location of the thermoc'ouples used to monitor the test specimen

temperatures, Errors could aise if the thermocouples were shielded or too thick.

In addition, the ITL test reports typically state that "thermoeouples were used to rneasue the cable surface temperatures." GL 86-10 (Enclosure2., page 8) states that "transmission of

heat through the barrier shall not have been such as to raise the temperature on its wu,.xposed

surface more that 250 0F above its initial temperature." The review team is concerned that

the method used by ITL to measure test specimen temperatures does not appear to meet

either ASTM El119 or the guidance in GL 86-10. -

It appears that ITL has misinterpreted the ASTM El 19 standard-time temperature curvie, in addition, the requirements of Section 5.3 of ASTM El 19 are incorrectly summarized in the

ITL test reports. This section requires not that the temperature be between the standard

curve and 10 percent below as stated in the ITL reports but, rather, that the area under the

22

'. . . . . . . , ' • , , . ,, . , ." , . ". . ,, ,,. • . , -. . .

. . ,. : . , . .. . .' .. , - , ,' '. , -, : . .- . ... .- .,' : "
time-temperature curve be as close as possible to the standard, within prescribed symmetric

plus-or-minus Ii •ut.

The ITL. reports reviewed by the review team do not make the test data corrections specified

in ASTM El 19. Section 6, "Report of Results," of ASTM El 19 describes a mandatory

correction for fire endurance tests of 30 minutes or over and Section 6.4 gives an equation

that is used to adjust the time to failure positively or negatively, depending on whether the

furnace temperatures were excessive or insufficient.

The ITL reports document fire endurance tests of fire barrier test specimens that are atypical

of the installed configurations observed by the review team. The configuration of each cable

tray test specimen reviewed by the team was a tight U-shaped assembly laid on its side. The

assemblies were cantilevered from the front face of the furnace and inclined downward. The

far end of each assembly, near the bend of the "U," was supported by a knife-edge type of

support that appeared to be resting on the furnace floor. (Reference, for example, Figure 5,

'General Arrangement of a Test Article in the Test Furnace," of ITL Report 87-5-77,

SRevision 1, June 29, 1987.) This test assembly configuration is atypical of the .: i:-•

ii:: •i:ii•-c"onfi.gurations observed by the special review team during its plant site visits in terms of both . ,.:ii•!*i

i:!::':i:•the, layout of the tray and the method Of support. In the team's opinion, the IT!. test -

;!-•,• shall betruly-rereenative of the constructon for which classification is desired.'. . .. ':-,•::i-,i:

range .of configurtinsfor .which fire rssac ratins wer needed., The ability of a fre :i..:::i::i•- . barier .tolimit heat trnsfer into the barrier enclosure during epour to the standard test -.:•• •.•i

ASTME119 -states that 'thetes spcme shall-be trul rpreenatveof th constrcton for": ,

which classification is desired a,..o materials, workmanship, and details such as dimensions

of parts." Therefore, in the review team's judgement, tests of representative cable tray sizes

and configurations should have been conducted to determine the fire resistance ratings for the

range of possible field configurations.

The ITL reports do not include dimensioned drawings of the test specimens. Section X3.3,

"Description of Test Assembly,' of ASTM El 19 provides guidance on the reporting of the

description of the test assemblies. The sole test assembly descriptions provided by FIT[. are

thermocouple location drawings and, in some cases, photographs.

23
ITL Te4st- Tts-Snedfk Concerto

In addition to the aforementioned common concerns, which the review team found with all of the rrL reports it reviewed, the team found test specific concerns. Examples of these

concerns are presented below.

fTL R 82-3-2.• This report presented the results obtained from a 3-hour fire

endurance test of the Thermo-Lag fire wall system. The test assembly consisted of a 3 foot

by 3 foot section of expanded metal protected on both sides by Thermo-Lag material and

stesskin. Section 14, 'Size of Sample," of ASTM El 19 specifies that for walls, the area

exposed to fire shall be not less than 100 square feet with neither dimension less than 9 feet.

The specimen tested by the vendor does not meet the ASTM criteria for walls and, therefore,

does not meet NRC guidance.

ITL Report 82-Il-80O" and ITL Report 82-11-817Y The vendor informed the review team

during the October 17, 1991, meeting that the cure time for the Thermo-Lag 330-1 material

is 30 days 0t The team found that some of the specimens tested under these two tests did .... ,,..... not cure for 30 days prior to the tests. For example, the On-Site Applied Chronological Log .... ,,;

•!:::i.: '~'Sheets: for.Report 82-I 1-SO indicated that a finish conting of ThroLag 330-1 was applied. ...:::

... ::••TestSpe=cimen o 20 on August 24,.-1982. The test .was conducted 16 days :later on •.../ ::!

Septe•mber-9, 1982.. Finish coatings applied to Test .Speimens 4 and 6 also cured for only • ..... :::,: 24: and 2 :days, iepetvely, bfore their tests, . ::•-:,

:•:: :; •Howvr a.. technical basis ifor thifs statement m provided incither of the .test . ' -•'•:.

AWall, Reison She Mparh 109812. uut2,98)frTstpcmn10o ea

Con-1-1 tatnng'esec thatbAle firotlaerped w ere attahedbo-lacig w30 th tubieming C atn

" ITL Report 82-11-80, "TOre Hour Fire Endurance Tests Conducted on Test Articles

:Containing 'Generic' Cables Protected with the Thermo-Lag 330-1 Subliming Coating

Envelope System,' November 1982.

OffiTl Reprancit 821181 PTroeeHuires "Endurance Thermas Sciendcted onTesto Ariscless

Issues Involving Thermo-Lag 330," October 17, 1991, pg 51.

24"
I

photograph oa m• pe58 of this report (Figure 16B) shows wha appears to show this lacing technique. Aplpendix 9 of this te report states that the materials were installed in

accordance wilh TSI's Nuclear QA Manual and QC Operating Procedures Manual.

However, these documents (Appendix !, Section 4, of the test report) do not specify this

assembly metod.

ITh Report 84-12-181." One of the objectives of this test (page 4) was to demonstrate that

the use of 12 inch spacing of mechanical ties comprised of either stainless steel tie wires or

stainless banding wifl perform satisfactorily. Page 1 of the report stated tha the tie wires

and banding were installed alternately at 12 inch intervals. It is thE review team's judgement that a successful test of this configuration would, demonstrate that the alternating zonfiguration performs satisfactorily, but would not prove that either wires or bands could be

used to fasten the panel sections.

in the team's view, to meet the stal~ed test objective, either' two complete tests should have

been conducted or, as a minimum, one entire half of the test assembly should have been

equipped with wires ties and the othr half with bandls. In addition, the team did not find •!i• .... ,;-,;: thii s~!!:;i fastening-meho (alternating bands and tie wires) used at any of thc five plants it ""1 ..

jj Another objecieof rTL Test 34-12-181 :was to demonstrate that a P1000 unistrut l ithat ;( -"' Ji:

penerats a hemLag fire barrie Will not degrade the barrie if the unistrut is prote .cted/

enclosure.- A 24 inhlnt of unirtwas welde to one sid of the cal tray. With the " exceptionf a four tch stt,.heunistnawas prtce within th Tero-a cale try "Jii: i!;:l•*! lirebrier . h reie .i tam's judg..meo •tha his arageet w nonconservtv i i

" ITL Report 84-12-181, "Three Hour Fire "Endurance Test Conducted on a Ladder

Cable Tray with a P1000 Unistrut Attachment and Transition Section Protected with the

Thermo-Lag 330 Fire Barrier•System," Revision 2. lune 1985.

65CTL Report 240056 824-63, Revision 1, "Fire Test on Aluminum Ladder Back Tray

Protected by Thermo-Lag Prefabricated Panels in a Steoel Bulkhead," October 1989.

~'CTL Report 240056-824 824-59, Revision 1., "Fire Test on Aluminum Ladder Back

Cable Tray Protected by Thermo-Lag Prefabricated Panels for Gulf States Utilities,"

October 1989. ,

• 25

t

I

I.
K::

enduanc tests of 30-inch wide aluminum cable trays. The vendor provided these two CL-T

test reports and CrL Report 240056-824 824-77,0 which documents a third test of a

30-inch wide cable tray fire barrier, to the special review team during the October 17, 1991

meeting." The review team reviewed these three tests and identified the concerns discussed

below. (NIST provided input to the team's review of CmT Reports 240056-824 824-63,

Revision 1, and 240056-824 824-59, Revision 1.)

The method for determining the thicknesses of the barrier materials is not reported. The

hand-wnitten log sheets in the report appendices indicate that the vendor made the

measurements. it does not appear that CTL verified the barrier thicknesses. it also appears

that the discussions of thicknesses of the Thermo-Lag materials were revised. For example,

~Crl. Report 240056 824-63 (page 6) states: "The electrical protect,,e envelope system

consisted of 1-ira. minimum thickness (measured thickness 1-1/2 in.) THERMO-LAG

Prefabricated Panels." Revision 1 to the report (page 6) states: "Their thickness was I in.

and 1-1/2 in. maximum.' Neither description is consistent with the measured thicknesses

listed in the ior' sheets.

..erm.o.... weelctdina rac with Seton5 ofisthre equlib9uand the:. NRC•

guidance pr.ovidheyeda in GL 86-10.,,;ii

Mossture conasructnth tetscimeansa a lono eotd

Thepo~rts. Selakoa viu, Potservtioanondisetionin l of TequrZ Sections46. of ASTM El 19.

spcninuousy th onieto the vim sub conditione untf they te taseien. monythr qingibarhppnum.t

Aspdiscussed indicaed previoussevtions thevet.r no e tuh e rbervaiews can duinclu defreape ieWe h peie tre Os o fh serions re 3f30-1 m ateralsn in3o frays dh 

Th6s ieuet frCTL Report-2200056-824-834-asconstrucesd on Aluipadr1 Ba 19k C ande They

firetectdd by Thero-zaw Prconruc ted Pninedaslate" NonemAer14 1989. ytetoe

'ai fofitcial s irnsicaritp of t Proceed ings, I #Metn oft T1hermaScieneLn. t d maeialwsus ooe 

Issu t In tes ol duct ofietssThercrrin cobr1,191 o he'hro-Lag ah e pr, , ft ,abnctd pael

I

I

26
and similar events. This information provides insights regarding the nature of the specimen's performnc.

The reports indicate that the test specimen fire barriers were constructed in accordance with

TSI Technical Note 20684, "Thermo-Lag 330 Fire Barrier System Installation Procedures

Manual Power Generating Plant Applications," (Tech Note 20684). However, construction

of the specimens appears to have deviated from the methods specified in Tech Note 20684 in

a direction that would enhance the fire performance of the test assemblies. For example, the

Daily Work Sheets included with the reports indicate that "stainless steel bands.., made use

of corner L angles." These pieces are not specified in Tech Note 20684. in addition, Tech

Note 20684, Section II, Paragraph 1.1.4 specifies a m2ximum spacing of 12 inches. The

distances between the bands is not exnlicitlv renonrte in the bodies nf the test ru'nirf•

. . . . . . 4. . . . . . . . . . .. . .• -I M . . . . . . - w - - . • w However, photographs included with the reports indicate that band spacing may have been

less than 12 inches. The Daily Work Sheets state that "stainless steel banding was used

within two inches on both sides of all seams," and that spacing is 12 inches maximum and a

minimum of 6 inches. The Daily Work Sheets also indicate that "stress skin was used across

.. •L.., the seams." These installation details are not specified in Tech Note 20684, and are not . . ,:;;i:.i:..:•:.i•...:..-typical of the field,, installations observed by the review team during its plant site visits,. . -

•.l•!::<!i, i•"Moreover, ,the test reports do not include any discussions of these deviations from the .:"

<.-.:>-:• vendor's instalaion procedures, including their probable effect on the fire performance the"

k(i -•,• <'design impoeets tha may have enhanced the fire performance of th test assemblies.•{ii... :>i~;

Thcuenredvin teamis conestredorthwaot Ucondued maccoran i ed wiReoth A24T2 "Thre Hour

therefore, does not meet NRC guidance for fire barriers. The review team did not find any

ASTIM El 19 fire endurance test that were conducted on walls or large enclosures. However,

a number of sites visited by the review teamn have walls and large enclosures constructed of

Thermo-Lag panels.

1

Methods of Assembly -

During its site visits, the review team learned that several licensees, for example, GSU and

Uonor Electric Company, used ITL Reports 82-1 1-80 and 82-1 1-81 as the technical bases for

SOfficial"Transcript of Proceedings, "Meeting with Thermal Science, Inc., to Discuss

Issues Involving Thermor-Lag 330," October 17, 1991. Attachment 6.

27
installing Thermo-Lag fire barriers in its plants to meet NRC requirements. The application methods reported for the test specimens tested in these two tests included direct application

techniques such as brushing and spraying trowel grade Thernio-Lag material directly onto

stress skin that had been formed around the raceway. However, these licensees have

installed Thermo-Lag fire barriers constructed of prefabricated panels and preshaped conduit

sections. The direct application of trowel grade material differs from the prefabricated panel

application most notably in that the barriers applied using direct application methods do not

have joints. The barriers constructed of panel and conduit sections do have joints. In the

review team's judgement, the use of direct application test results to support prefabricated

panel configurations does not meet ASTM El 19 criteria that the test specimen be

representative of the construction for which a fire rating is desired, and, therefore, does not

meet NRC guidelines.

The test specimens tested in ITL Reports 82-1I1-80 and 82-11 i-81 used a cure accelerator.

However, the licensees did not use this material during the construction of their Thermo-Lag

fire barriers, and did not evaluate the differences between the as-built and the tested

• ~configurations.

•iii~i•.i::i, lThe review team is concerned that other licensees have used these ITL tests as its technical ..

;i:.: . .bases for installing Thermo-Lag fire barriers. The review team ,believes that this shows that"

ii~i:i~-.:!:.i.,some .licensees may not •have adequately reviewed .the fire endurance .test results to determine-- .

,/, :, their applicability tothe plaintdesigns. . : . .-. : •• :i

::,•.•__Extrapolation of Test Resutsi" ": :-'",:.. ...

Dui.;,ii ngzts plant site visits,, the review team o0bservedcable trays up to-36 incheS wide .. : . ••...•

iprotected with Tero-a fire barriers. iHowever,• of the49 fire-tests •identified by the:ii-.• :;*:•,.•!iif:i

reiiew team only four involved cable trays wi•derii thn1 inches. iiThese we.ethe (ktober!•.~i•i;i:.i!;

199 e pefome t a AiR n the d thnd s reeCns t esltsiisuse proou Tevli ously.8) 'Altog tte t ...

discussed in the previous section, the review team believes that these additional details may

have improved the fire performance of the CTL test specimens.

Following the CTL tests, the vendor issued new procedures for installing Thermo-Lag fire

barriers on alwumnwn cable trays. These pro.cedures"' include some of the assembly details

employed for the CTL test specimens that arc not Sp•ccitied in Tech Note 2Ot.84, including

the. installation of stainless steel bands within 2 ifl.hes of all Joints. (tie wires do not appear to

be an option) arid the w~rapping of butt joints wi•th stress skin ,ind trovwel grade Thermo:lag

material.

• TSI Technical Note 20684 Al., "'lhermo-Lag 330J lire Barrier System Installation

Procedures for Aluminum Cable Trays - Power (Gener-ting Applications." (October 198g.

"8"
~~The review team is concerned that these details specified in Tech Note 20684-AL may be • needed to ensure the integrity of the fire barrier because of the width of the cable tray, not

because the tray is made of aluminum. If, if fact, the fire barrier construction details

specified in Tech Note 20684-AL are needed to ensure the integrity of fire barriers on wider

trays, regardless of tray material, then the fire barriers installed by the licensees without

these construction features may not provide the level of fire resistance intended by the

licensees.

-iIn•h.u•

To prevent heat transfer into the fire barrier that could damage protected components, the=

vendor's generic installation procedure recommends that all penetrations. into the fire barrier

system be fire protected to the same level of fire resistance as the raceway for a distance of

18 inches, minimum, as measured from the outer surface of the fire barrier, covering all

continuous paths.71 This is commonly referred to this as "the 18-inch rule.'

,The review team is concerned that ITL Report 84-12-181, 'Three Hour Fire Endurance Test :...

:•...Protected with the Thermo-Lag 330 fire Barrier System,' .Revision 2, June 1985, is being i :

i~i:.team believes that the design of= the test specimen• configuration was not representative of~i!;...

•qical typ-:.-i fire :barrier penetrations and,"therefort' was not suitable :for dmnsrtng that heat •:•

" woul not beI "TraserredLa into tpclbarrier Ssem nvlps thrug entationPredes anratectoedfr"

only 18-nces.

T SI Tpe hnreiewl Ntea 1e11e1, "ngineearcyeaing tesotso (Amtachmy ent 3)r a6d foundowe

Cale TInstalermoLag 330e Fire Barergt SysTem Installation Proectedue Manual Pirowerg

330-1 Subliming Coating Envelope System," November 1981.

SUL Test 86NK23826, "Special Services Investigation of Amipacity Ratings for Power

Cables in Steel Conduits and in Open Ladder Cable Trays with Field Applied Enclosures,"

January 21, 1987. ... .

•' ITL Report 82-5-355F, "Ampacity Derating Test for 1000 Volt Power Cables in a

Ladder Cable Tray. Protected With a Three Hour Rated Design of Thermo-Lag 330-1

Subliming Coating Envelope System," July 1982.

' 29
:to 31 percent7 ' for 3-hour barriers. In addition, ampacity de:ating tests of Thermo-Lag materials conducted for 3M"' found the ampacity derating to be 37 percent for a 1-hour

Thermo-Lag tire barrier. The review team noted similar inconsistencies in the ampacity

derating factors for Thermo-Lag conduit fire barriers.

By Mailgram of October 2, 1986, the vendor informed the NRC of the results of ampacity

derating tests performed at the UL. The ampacity derating factors obtained from the UL

tests (UL Project 86NK23826, File R6802, January 1987) exceeded those previously reported

by the vendor (for example, ITL Reports 82-355-C, 82-355-F, and 82-355-Fl). The vendor

informed the NRC that the UL test results were sent to its customers,

During its plant site visits, the licensees for C"SES and PNPP informed the review team that it had received the vendor's Mailgram and had considered the new ampacity derating

information into the plant designs. However, several licensees, for example, GSU and

WPPSS, informed the review team that it had no record of having received the Mailgram.

•Therefore, some licensees that use Thermo-Lag fire barriers (for fire protection and for

electrical separation) have not determined if the derating factors derived from the UL test

appy to O terplan.t designs.. _-.i:•i./ . s ... ,-. -•

mateial, conducormteil n size, cable loading,thle, number of cables in a group,

'S

~3826 do not apply to Wi

does not include sufficieui

~ting cable performance.

~and

also

wp~

additional cable derating without adversely

The review team identified ampacity derating as a generic concern. The review team is •concerned about the inconsistencies in the derating test results and that some licensees have

not adequately reviewed the ampacity derating test results to determine the validity of the

tests and the applicability of the test results to their plant designs.

's SwRl Project 01-8818-208/209-a, "Ampacity Derating of Fire Protected Cables in Cable Trays Using a One-Hour Subliming, Rigid Board Provided by 3M• Incorporated,"

August 11, 1986.

76 IPCEA-NEMA Standard Publication entitled "Ampacities - Cables in Open-top Cable Trays;" (IPCEA Publication P-54-440, Second Ed1itiOn; NEMA Publication WC 51-1975).

30
I

'ii:,SAFETY SIGNIFICANCE

The licensees use the defensr--in-depth concept of echelons of safety systems to achieve the

high degree of safety required for nuclear power plants. This concept is also applicable to

nuclear power plant fire safety. The defense-in-depth principle applied to the fire protection

program is aimed at achieving an adequate balance in preventing fires from starting,

detecting and suppressing fires quickly to limit damage, and designing plant safety systems so

that a fire that starts in spite of the fire prevention program will not prevent essential plant

safety functions from being performed. No one or these echelons can be perfect or complete

by itsalf, but each echelon should meet certain minimum requirements. However,

strengt~ening any one echelon can compensate in some measure for weaknesses, known or

unknowz., in the others.

In the Federal Reg~ter notice that issued the proposed Appendix R to 10 CFR Pail 50,"

:::• iii~iii• the NRC stated: "The phenomenon of fire is believed to be sufficiently well undrto to i ! -iii•- i•:permit evaluation of existing and potential fire hazards and probable extent of damage should !):,i:I:

:•i:•i::" a f:•-:iafre occur.. Such :evaluations are useful in .assessing the possible consequences of.-fire in a."-'!.. :i.

i~:: •!•!:.give. n area.i•V m Howeve, the phenomnson of fire is so unpredictable in occurrnc and : •--.:-.

ii•:.::development .that. measuresto prevent _unacceptable consequece may not be omitted on the .:""-+

:'":;.-::basis of low .probability of occurrence., The minimum fire protection requirements for "," :. ...

... i. . un c ep a l conse uences of flre. - . ... .. . :- .. ..... .. ., : . ..... ,

The.rina. objectve, of the fire: prte'toprogrm .is tomiimzaboth. the. pr:- ilty an

fires aigtin eecapbltysol cu.Teeo th pvied en roguthe peededto dtecit tnd sxtpnress fireswt

eampages pprv i h enes d etermasivee an deqactive fire protection ofaporpuiate s~afety sytnsd n

orea witoy onasisepowthe effects ofnh l potlante area whreathve ptemintiainfirngdtae mabiiy sjoafely a shuonhafe plant and minimizt e raimary ivean ofrelse pro t, he environsist ofnfire event

Thbariabes~ usfied tutematictfiree levet on anresupotestion sysems.d Also a baeupr aueaincude:

of aFire. idn n iehzrs

SU. S. NRC, "Fire Protection Program for Nuclear Powe~r Plants Operating Prior to

January 1, 1979," Federal Register, Vol. 45, No. 105, May 29, 1980, pp. 36082-36090. "

.... 31

1
:":i* Automatic fire detection and suppr•ession capability.

* .Layout and configurations-of safety trains.

* Reliance on fire barriers including, the quality of the materials and system, and the

quality of the instllaio.

* 1Fire area construction (walls, floor, ceiling, dimensions, volume, ventilation, and

S congestion).-

* Location and type of manual fire fighting equipment and accessibility for manual fire

fighting.

* Potential disabling effects of fire suppression systems on shutdown capability.

* Avwi~ability of oxygen (for example, inected containment).

n teAssmptoun of t thbe insultionlad oirhrrers comusble maeriomals.itne.Th olwn

dupingato the nRCureviw of the lenesfi protectdeuiomnt adoitsmrelthve imotaffevauted thfese.

Factriabesg insr th aseactholeur at licensee rv ide puti andeqatc -b-ae fprtcin.aIysis. aee on

th ER a ttdlcnesrqet Spionll.fi. xemptions from o o R.We Appndix n ri fasyte

requweusiaed has approed, daevshatiownis sprtdfrom safgisreudanteh straiffb pefre l-ho

firaluatedn aM rrrantd atoeexmation ard deviations based onuppressind canailytiesar

insalldSection lll.G.2.c pofiie Appendi fR eautis met.eIpthioense han been-2 giraned

exemtio frmthreuirmcent1 fi roie aumnts omatc Irdetectio evaldofuppresso ~ systnentended t~he alitytcuieves safe shutdoweas largelyR dpanend emntons biiyom fr the

epndntonr thre naturier tofmiti the protected qupetraind itsrelat ive iampoge.nce to sfrety

32
adversely affectd.

• Exemption from Section llI.G.2.a of Appendix R. When one train of a system

required to achieve safe shutdown is separated from its redundant train by a 3--hour

fire razed barrier, Section ll.G.2.a of Appendix R is satisfied. Automatic fire

:. detection and suppresion capabilities are not required. Therefore, the ability to

achieve safe shutdown is dependent on the 3-hour tire barrier to maintain one train

free of fire damage.

The technical bases for approving this type of exemption may have included fire test

results that, in combination with a fire hazards analysis, demonstrated reasonable

assurance that safe shutdown could be. chieved if a fire barrier of less than 3-hours

fire resistance is installed. If the fire test results are not valid, then the fire hazards

' ........... analysis would not be valid and the level of fire protection needed top• safe

shutdown capability may not be provided.

:,.: I:e , •Exemptio from Section fl.G.2.c of Appni R. :When one train of a systm ::

'":::: "• •:: 'to req~imuired achieve safe shutdown as sepaate fro its, redundant tra by a 1-hour ? :. ::-! i•:•

Scinm.G.2.c of ApedxR ismLI h icense has bengranted an... ... :

exmtinfrmth rvieeihr uomtcfire detecton or .• -. "-.-. ...

:,.,daesso suppri]• systems, thet aility to aci safe shutdoeneisodepenedento actuatin,

• " t hmeaue instale-d sstemanda• tihe1-houmr, fre barre-or t he dain ationone tranfeeo firerin

damair e. Ihe the harts t resuvlts areleotvald,3h the a leeloipotcionm f ede eitopatce.

•ftnfrfiebrirusdtseaaerddatsafe capability ma-not shutdown bebaoeid

wih Cuomplanic ithm Section 1and supesof . systemsx ae to1 cnsid arted bqiasedt to invalud

fire svietuton fire the resistane euieeo barrierdpn onrte s evapuated seeity oft

presting fuiro yexaprosing athes speieniyo a ts fire. whos seveityiolloas actial vularyinge

teperanture Wourdhvete stnardc slome-temperature crvse--for the drtionofth fire n lratiopng

required. Tuhe NRas ostnscearvpantfivearaafly selctve-luopa te mini mum ocr reis inoe ance

raigfr theirea barriers usdnot sepbarltate redudntir safue shutdoe sysems. (o1- houer. barrerss

w ith autoatch fire detaetion and suplytopressi nsytem acredil calngierdeuvlt to 3-hncea ouer

pln iebarriers.)thoghThe tetsadrdaiiesfirtne fire svrityng by subecTinmoLg the barrierst a re o

~rpdtmeatr iei acnie paeta o3lyegls thets pcmn.l nata

" fire situation,. th ierssac eurdo barie deed on the e... pect....: d seve."rity.: of the '... -.. fire to which itmybeepsd.Tpcl"ula """ '"' " p"n fir loads• are" noti'" grea enough" " to 

prdceafieapracig.h.sv..y.fatetf.e .naditon .. actua nuclear' power .. '.......

plant fir would hav a muc slower. tempetur rise. tha tes . fire. large.. .n open.
i-!i!!-:considered indeteminate, the special review team believes the barriers will provide some

level of fire protection. In addition, most plant ara have controlled ignition sources, which

helps reduce the occurrences of fires and are equipped with other passive and active fire

protection features, and ar continuously occupied by plant operators, security, and other

personnel, which contributes to early fire detection and suppression activities.

Cables enclosed in electrical raceways are derated dsing the ampacity denating factors for the

materials surrounding the cables, for example, cable trays, conduits, or duct banks, to ensure

that systems provide sufficient capacity and capability to perform their intended safety

functions. Cables enclosed in raceways protected by fire barrier materiais require additional

de-nting because of the insulating effect of the tire barrier materials. Cable clerating

calculations that are based on inaccurate or nonconservative derating factors could result in

the installation of undersized cables and raceway overfilling. This could cause higher than

design operating temperatures within the raceways thereby reducing the expected design h8.•

Fof the cables. In ext~rem cases, cable jacket insulation failures could occur. The-refore, ... :.;iundersized., safety-reae cables reduce plant safety margins, If inaccurate or

•÷ :.•,:._ .,nonconservative deratig .factors are used by the licensees for the electrical system design-.i.-!

1<"::> basis, design changes could be required to extend cable life and to restore safety margins. - :.:

•,?.-:. .. The, special review temn did-not identify any immediate public health and safety concerns , :: .:,•.•,,: ,.rqarding the ainpacty derazing issues during its review. The review team recommends that --. =, ,:::?.!i~ii) .. i.the licensees and the NRC staff assess the safety si~gnifiane of any plant-specific issues that ""•'":

-- 'I- , - I -, - ,- . - :• , ' ,.- , ., . : - : : % :..': .•:-

34
'•U" CONCLUSIONS

The special review team found the following regarding the use of Thermo-Lag by the

licensees"

* The fire resistance ratings and the anmpecity derating factors for the

Thro-Lag 330-1 fire barrier system are indeterminate.

* Some licensees have not adequately reviewed and evaluated the fire endurance

test results and the ainpacity derating test results used as the licensing basis for

their Trhermo-Lag fire barriers to determine the validity of the tests and the

applicability of the test results to their plant designs.

* Some licensees have not adequately reviewed the Thermo-Lag fire barriers

installed in their plants to ensure that they meet NRC requirements and

guidance, such as that provided in Generic Letter 86-10, "Implementation of

:,•:i: ~Fire Protection Requirements," April 24, 1986 . .. :

• *;,::'• Some licensees used inadequate or'incomplete installation procedures during . .. +i •i;'

.•.••- the'• "+•,,';""'- cntr -cti ,n ' + f "-':. T h .ei nn - L ag'•,+•-.0 ba rir.•' '.•,;,.]+'"', ;.: '. :•v''S .',• ...i " ". . ._.,,: .-$ ', .?,,'

' , ,,9 - 9 ',-•.+ ' '.. , ' .--. ,," ' • , :,, 'c r • .','. ,.,-,9+ 9,".::• 9,'.: 

35
•-::. 'RECOMMENDATIONS

Based on its findings regarding the use of Thermo-Lag fire barriers by the commercial

nuclear power in•dustry and the relative safety significance of the findings, the special review

team recommne to the Director, NRR, that the NRC:

:*.Advise industry of the staff's concerns regarding Thermo-Lag fire barriers through

." the Nuclear Utilities Management and Resources Council,

* Provide the industry with the results of the team's plant site visits and the specific

concerns and technical issues regarding Thermo-Lag barriers that were identified by

the review team,

* Issue a generic letter that discusses the concerns and requires the licensees to provide

• information needed by the staff to verify compliance with the NRC's requirements,

"•::-'::: "" * _"Review the licese' corrective action plans for resolving any plant-specific Thermo- ' - .? Lag fire barrier-design,.evaluation, and installation issues. ;'""•

> Q. -- ".*:,,• , :• .& ? ; i• / '' .,:::: :, • .' : '" ?, " . .. :- . .i : " :.. ' ' ' ; .. .. -. :. . . " :. ,i :: •

., , : . , : : .• ! S '. , , : , . - ' : / : :' . . , : . . .: . - - : : ., : . . , ; , . ,.. .. . . • - .2., .. . .- " . .

36
APPENDIX A

LIST OF ATIFACHMENTS

I°

2.

3.

4.

5.

6.

Nuclear Power Plants Identified by TSI as Using Therrno-Lag 330-1 Fire Barriers.

Fire Endurance Test Reports Involving Thermo-Lag 330-1 Fire Barrier Systems.

Ampacizy Derating Test Reports Involving Thermo-Lag 330-1 Fire Barrier Systems.

River Bend History and Documentation Reviewed by Special Review Team.

Comanche Peak History and Documentation Reviewed by Special Review Team.

WNP2 History anti Documentation Reviewed by Special Review Team.

• • •r" 4"k "7. Susqehnn History and Documentation Reviewed by Special Review Team. '"::::

-. ,. •, . , ' -,, 'p. .

N";: . : • + . " ': " " " - 'h -- ---. " ""

• " A-I

..:" .', ..." • . .. . . .,. , • • .. :. . : ,;:
'4

ACRONYMS AND I[NJTIALISIMS

3M Minnesota Mining and Manufacturing Company

AN! American Nuclear Insurers

APCSB Auxiliary and Power Conversion Systems Branch

APS Arizona Public Service

ASTM American Society for Testing and Materials

BTP? Branch Technical Position

CE! Cleveland Electric Illuminating Company

SCFR U.S. Code of Federal Regulations :i::"'•5CMEB •Chemical Eniern Branch .. . • .- " i - ••ji ::CP-•SES Comance Peak Ste Electric Station ::'• ~•: i :

VCR Cetnvniain onditioningpo n i 

CRG Cnormatione-NorthReiew fGnrcRqieet

ITL . Indstrucia Testinlg Laborator,,Incorp y norated t

EMA Nxectione DErectoria MnfoOeactrr soitions

NFPAP Ntina Fire Protection Aoiystesn ommitton

IST Naional Iae nst~ ritueo ReotadrsndTholg

NRAC HU.ing vucentieglationadary Conditsionin

NRRA Naticeona Nuleiar ManuacturRerslassoion i

B-i
- NUFFO Nuclear Utility Fire Protection Group NUMARC Nuclear Utilities Managemenqt and Resources Council

OIE Office of Inspection and Enforcement

OPPD Omaha P•zblic Power District

PNPP Perry Nuclear Power Plant

PP&L. Pennsylvania Power & Light Company

PSB Poe Systems Branch

QA Quality Assurance

QC Quality Control

RBS River Bend Station

SAIC Science Applications International Corporation

SER Safety Evaluation Rejxx•t-_ .•.-: . _:• '-.; -. • :•.- -. 2. .. .. ,."..-"

SS.RSuppemenal S fety Evalatio R 'eporti•:,i. _:-•,., ,:.:•.••,:.. ,. .. •..,••=:..

SSS uquhan Sta Elct Statio

S 'wR.I Sothe In....tit-.e .Research 
ATTACHMENT 1

NUCLFAR R)WER PLANTS IDENTIFIED BY Th!

AS USING TiHERMO.-LAG 330-1 FIRE BARRIERS'

Arkansas Nuclear One Hatch San Onofre Beaver Valley Indian Point Sequoyah

Braidwood LaSalle Shearon Ha:

Browns Ferry Limerick Shorehain

Brunswick Maine Yankee South Texai

Byron Millstone Summer

Callaway Nine Mile Point Surry

Clinton North Anna SusquehannF

,Comanche Peak Oyster Creek Three Mile

D.C.Cook Palisades Tir'jan

.,:.-- -Cooper Palo Verde ',.Tii-key Poii

::.ii'-:4,• ,Crystal River .... Peach Bottom .. .. /Vermont Y•

. i..: . iDavis-Besse Perry .. -vogtle

."Diablo Canyon Prairie Island : W 2

:•:i'Duan Arnold :. .,Rancho Seeo .. ,,.:, .Watts Bar

.-_, " •Fernu ..- :' . River. Bend ,7. ::i-):: ._,W olf Creek

-: Gr" and: G- ulf """ ' St""""" ... i "u -•-":-"•5-.in Z 

.; ": /• i • -:' ": : •5 " .' . ;:a..,'/..:'> .: ,:" ,•, : . 'F:;.7 . : / ; -• - ." :-:.: ,-, , • " -. '

• •?.:: : ,; :',.• !? ::' ;:. :.,• . -•::g .'i.• •.•::. ":/ > :, F-.. I'- -": :•-.-.'. /

•/,; ":! :/ " :,:.2. " : " ::'•:,: " ',. g '•'.:.,' ,".:.'•:.": :.', •::r: ? ',ii-,• ; ": .. ;•' .. " " : ' "--' -F.

ms

Islanc

tit

inkee

- F F ,

F. F i !iAppendix VIII to letter

October 5, 1991. from R. Feldman, TSI. to F.J. Miraglja, NRR,
. . ,

ATTACHMENT 2

FIRE ENDURANCE TEST REPORTS INVOLVING

THERMO-LAG 330-1 FIRE BARRIER SYSTEMS

This attachment lists the fire endurance test reports involving Therrmo-Lag 330-1 fire barrier

systems that were identified by the special review team. The reports shown in bold typeface

were reviewed, by the review team.

ThLAhREPOR

February 13, 1981, June 6, 1981, These tests were included with TSI Technical

and June 7, 1981 Note 90181. August 1981

(1-hr cable trays and conduits)

April 27, 1961 -. TI .Technical Note 5275-1, June 1961 ....,•i

•i.::"i, ":-._ , . .. . (1-hr conduit_ for SSES) ' , :!

April 28,- 1961 131 Tec!h nicabl Ntea fo 232.1) , Jun 1981. and•i:,•i,

-.. ... 182S, ,lime . 982 '-ITLReportun 182,S3B ul 92-

(3-hr cable trys forSWSP2)

Augustw 10 1982 SwRI Report 03-6413, Ocutoe 271982

(1-hr cable tray and conduits suomtte oNC

Setma 1 er -28, 1962 ITL Report 82-11-80S, JNoembr1962

(5Ignrc"tss -hr cable trays and frWP conduits )

Juep18-25, 1962 ITL Report 82-11-351, Julybe 1962

Octobr 12,1982(5 "generic" tests. 1-hr cable trays and conduits)

2-I
November 1932 ITL Report 82-11!-240

(1-br conduit for WNP2)

Ocgtober 22, 1962 rrL Report 32-11-241, November 1962

(1-hr conduit)

June 1, 1963 1TL Report 83-5-472A,.July 1933

(1l-hr cable tray)

June 7, 1963 NTL Report 53-5-472, Rev. 1, September" 1963

(1-hr cable tray)

July 1984 ITL Reor 84-6-109

December 13, 19S04 rrL Report 34-12-151, Rev. 2, June 1965

(for 18 ndie frod barrier pentrayo)

Apne 1985 rl'FL Report 85-4-2357 Re.

(3-hr fodirewl)

June 18,985 - SRIT Rpor~jt 85-630-283(C?102

O3rctoberu31 19th (pexi-lantkneallt inovn

Tbel-hr conduit) a 

.i '-. .

• . , . A . ..- - A> : "

J.e185. .1.2-33, Re. 1
Mardi 10-17, 1966

June 13, 1986

Aupust 19, 1986

August 1986

Sepemuber 17, 198

3M (1-hr Test 86-42 and 86-43, March 21, 1986 side-by-side baseline test wI3m Intmrm)

3M Test 86-73 (P.1-10), undated

(I-hr combined Interam/fThcrno-Lag side-by-side and interface tess)

3M Test 86-92 (P3-16) (Twin Cities Testing D414186.lllg), October 1986 (3-br Intefanlthmo-lag interface test for wPPsS)

ITL Report 86-8-207

(I hr conduit)

3M Test 56-102 (P3-21), undated

•(1-br lnteram/Thermo-Lag side-by-side and

.. ..October.21,IJ~i ,m•-,:,•:•. :-,-•,:.,••..3M Test 86-112 (PJ-24A), October 1986 .r"."'. ":•'.:

•......(1-hr IonteaufieroL ntrae

March 31, 1987

April 1, 1987

April 13, 1987

ITL Report 57-3-6506, April 1987 (3-hr conduits, WNP2 in-situ low pressure extrusion application technique),

ITL Report 87-4-3, April 1987

(I-hr conduits, WNP2 in-situ low pressure extrusion application technique)

Warnock-liersey International Report WHI-495-PSV-0543, undated

(I-hr boxed conduit penetrated by pipe for APS).

2-3
May 7, 16

May 7, 19871Th Report 87-5-77,

Rev. I, June 1967

March 9, 1968

July 30, 1988

April 14, 1989

ITL Report 87-3-76, June 1987 (Repeat of 3M Test 86-92, 3-hr Interam/llermoLag interface test)

(1-hr cable tray w/unistrut protected for 9 inchtes

from barrier penetration)

Raw data frot FITL test, no test report

prepared (3-hr cable tray, RES "as-installed')

ITL Report 88-07-5962, September 29, 1988

(3-hr cable tray, RBS "as-instaIled')

CTh Report 240056-824/246,

September 1989 and Rev. 1, October 1989

(3-hr Al cable tray)

May 5,1919 CTL Report 240056424/524-59, August 1969

and Rev. 1, October 1989

(3-hr Al cable tray)

May 5,1 CTh Report 240056424/524.75,

November 1989 (3-hr cable tray)

May 5, 196.9 - - cm Report 240056424/524-77,

November 1989 (3-hiAl cable tray)

A Oetober 26,190 SwRI Report 01-2702, May 1991 (Thial Draft) (3-hrMcabletrayforGSlJ~

1%

~ovftwer 20 , WL, F~eIlmlnaI7 Draft Test Rqxwt, .-FI-.~ ,~ ~Dwmber 18,1990 January 1991 (1-hr and 3-hr in-situ and upgrade I'

tests for RBS)

2-4
ATTACHMENT 3

AMPACITY DERATING TEST REPORTS INVOLVING

ThERMO-LAG 330-1 FIRE BARRIER SYSTEMS

This attachment lists the ampacity derating test reports involving Therino-Lag 330-1 tire

barrier systems that were reviewed by the special review team.

These tests were conducted by ITL, TSI, ULJL and SwRI. The table includes the test report

number, date of test report, description of the test, and the ampacity derating factors reported

in the report. A consensus ampacity derating test standard does not exist. Therefore, the

results of the individual tests should not be compared without a detailed review of the test

article configuration.

R~QBLNQ~

DERATING

DATE TEST DESCRIPT~ION EACTOR L%

ThI Technical Note 09/81 14 steel cable tray

92981 ' 600 volt power cable

210' IOOAWGO.562D

2820' #10 AWG 0.215 IJ

TSI Technical Note 02/85 (Rev 5) 1-hr 2 'steel conduit

111781 - 11/81(Orig) 600 volt power cable

21'#OOAWG,0.562D

1TL82 355-Fl Ol/85(Revl) 1-brsolidbottomtny 07/82(Orig) 600 volt power cables

)

)

16.15

16.86

17.68

•.1000 volt power cable ....

1485' #08 AWG 0.286" D

870' #04 AWG 0.377" D

300' #2/0 AWG 0.617" D

[TL 82-5-355F 07/82 3-hr ladder back tray 1000 volt power cable

- 1485' #8 AWG 0.286" D

870' #4 AWG 0.377" D

300' #2/0 AWG 0.617" D

3-1

16. 15

16.86

17.68

• .:, • • " .',' ., " . i. , ,. • . , • .. "' :" : ".'..i' .'• -• ."
DESCRIPTION

DE.RATINO

ITL 84-3-273A

rrL 54-10-5

SwRi rl

01-8818-20S/209a

(3M P1-19)

03844

10/84

3-rladder beck bUy 10(X0 volt power cables

1483'MJAWGO0.Z86 D

870' 14 AWG 0.377" D

300' I2I0 AWGO0.617" D

3-hr 2" steel codut

600 volt power cable

21' 50 AWO 0.62" D

1-hr 24" steel ladder beck

truy

D6 AWG 0.T7 D

20.•5

19.24

20.07

9.72

SW. ?~~l 1-hr' 4" td conduit 116AWG 0.75" D

134r W Mi beck uay

i ul prow cabb

WUtlAWO 1"

37.4

1.27

28.04

31.15

I 0

3-2
ATTACRMENT 4

RIVER BEND HISTORY AND DOCUMENTATION

REVIEWED BY SPECIAL REVIEW TEAM

(Docket No. 30-458)

June 30, 1982 GSU submitted comparison of fire protection program to Appendix R

with FSAR amendment.

April 6, 1983 Draft SER on fire protection. Safe shutdown and fire barriers

remained open items.

May 1984 Safety Evaluation Report (NUREG-0989) issued. Safe shutdown still

under review. Page 9-42 stated that all cable trays are steel

construction.

.,••:ii! . " !August •..•:•.:'ii•. 9, 1984 :"•••TSI letter to Stone anid Webster provided 1-hour, 3-hour, ampacity , ; ." :•

:-.- •-,•..:, ?I:: ::•i. -:,i_/..i :i: ,:•d erating , and seism ic qualification in fo r m ..ation . ,

Septemberi• 24:, 1984 First purchas order for T sI from Gsu. -:. .. :•• "': ;'":¢ '

- :iiApril 4, 1;985 --- Oniii- te audit of fie poteto by NRR. Fire barrier wrap installation' i:;: i:

Ma.0.8.3hu.qaiiato et of as,-installed" internal and external

ProalmatumcReondut seals-10t9db, G SU cncRIe bya thisrotest anoded .

concusi. (Terience tha doer -L poetns not av enued rpwt uire tes

3-oa iretain flex o conduitit ity.) tainsel odceda wIb

June120, r95 Jn 8 95 etrrnwtot hrole eerneSR rjc

teet.RfeneSRPrj*Report 01-8303-040c,,AJulyt Poae 1985 and eotCP19b

Nrovaem eotCP-0 ,Otber 1985.(Acrigt 31, 

Jul 185 2, Prosumitec tepor SwRReport 01-805concluded that toi test provi

maintainfypendx conduviationtegrity.)m onutes

4-1
August 1985 SSER 3 issued. Deviation granted for sealing inside aluminum conduits based on SwRI test report submitted to NRC on July 26, 1985. Also

granted deviation on delay of installation of fire wrap on spent fuel

cooling system and service water.

February 23, 198"7 Condition Report 87-0236 initiated following review of February 3 1987, surveillance iest results. Sixty percent of the

barriers failed the acceptance criteria. This CR suereddby

CR 87-0236A.

March 12, 1987 Condition Report 87-0236A initiated. Identified specific ci-amples of deficient fire barriers. Cracks, wear conditions, unsealed joints,

unprotected supports, and 18 inch criteria not met. Breakdown of

vendor QC inspection program identified as root cause.

March 25, 1987 LEE 87-005 submitted by GSU. Described fire barrier deficiencies, .='r•,"•t"",,) "" ."." .q" q• tincluding incomplete construction, found during surveillance test :.+:•://

,ii:,:!:/i:iii:!~i![+!i~•:'i ii:•,•/Tecrh Spec 3/4.7.7. GSU committed to make 100 percent visual : /" •!•iii'

triiggie yTS nMy 81,1987.-.r !+i

Jun 3 CodiionRoas 8769 ite. ... Inspection reuie by. . +-++,

CR.8723.Aand ER,8-005 oundremo...o nbsfrom Tlem•

Lag panels during installation. This resulted in gaps in stress skin

where ribs were cut.

July 13, 1987 Condition Report 87-0745 initiated. Inspections required by CR 87-0236A and LER 87-005 found stress skin and ribs removed

from fire barriers. During discussions with GSU, TSI stated th~at

removal would have little or no effect.

July 24, 1987 GSU issued purchase order (7-ON-72055) to TSI to conduct 3-hour fire

endurance tests with stress skin removed.

August 20, 1987 TSI prepared engineering test plan for 3-hour fire endurance test for GSU.

4-2
I.•nuary 6. 1988

i~mnuary 19, 19SJ8

January 22, 1988

February 1, 1988

CdiinReport 88-0012 initiated. During installation of additional cables, conmbo! building cable try found to have stress skin and ribs

GSU letter to TSI asked for confirmation that use of 1-hour ThermoLag panel is accptale with ribs and stress skin removed. (GSU

reeecdCR 88-0012.)

TS1 letter to G3SU submitted ITL Report 82-I 1-24! (direct spray

application on conduit) and ITL Report 83-5-472A (direct spray, etc. to

cable tray) to justify installation of 1-hour barriers without stress skin.

GJSU provided comments on test plan to TSI. GSU stated that

aclqancc criteria should be 325 °F above ambient. (MNRC criteria is

250 "F above ambient.)

: February 4, 1988 Interim disposition prepared by GSU for CRt 88-0012. Stated that "as- :i i)!.i!i[[ .,i!.•.i~f[i-.if•i~i(:.•h:it-alled'"• ,;il 1-hour barriers wer 'qualified for use asi'bsdo I.

:.'% S i•:<i•:-•!?:•i•-:.i~.-> .•i,:.:':•_:.• iiJanua .22,-19818 letter. .See Augus 29, 1990. .• " . - ./ -. i:,,..;•

Feray818 eiinIt 5 etpa o -orts...

VS ~J protection program.

"April21!, 1988 Internal GSU 'memo addressed results of March 1988 fire protection

prga audit. The effectiveness of fire -barrier inspection surveillance

test procedure (STP) was questioned (pg 8). LER 88-009 is

June 22, 1988 Revision 1I to TS! test plan for 3-hour test.

July 22, 1988 CR 88-0594 initiated..

July 29, 1988 3-hour fire test conducted on "as-installed" configuration (12-inch wide steel tray, stress skin and ribs removed) at TSI for GSU. Test

specimen failed on temperature, circuit integrity, and structurally.

Reference ITI. Report 88-07-5982, September 29, 1988..

4-3

. ......... . ,• •" . ! • :. .:::! . . • ....
Jully 29, 1988

October 11, 1988

December 12, 1988

January 1989

February 3, 1989

Condition Reports 88-0607 and 88-0608 initiated. Addressed 3-hour •test failure at TSI.

T'SI letter to GSU transmitted final test report ITL 88-07-5982,

September 29, 1988. 325 0F exceeded at 90 minutes•, circuit integrity

failed at 115 minutes.

SwRI letter to GSU transmitted Addendum i to proposal for 3-hour fire

endurance tests of "as-installed" and proposed "repaired"

configurations.

GSU initiated test program with SwRI to qualify "as-installed" ThermoLag fire barrers.

GSU letter informed T'SI of plans to conduct fire tests at SwRI during March 1989 and provided copy of SwRI test plan.

March 3,1989 1'S! letter to GSU discussed developmental tests of proposed design modifications conducted at TSI and tests scheduled for April 1989 at - CFL. TSI offered to exchange new 3-hour panels for used RBS

materials and stated that tests at SwE! would not be cost effective.

J*tter acknowledged prerequisites of government regulatory agencies,

not required and are Icr - UUI~UWI WWj~E3Wr~ IU~43UIUJJI~1U5 aiu

,> information purposes only. 1'

Spring 1989 GSU~ttejatSwflIonbo1dinfavoroftestin~withTSI.

I- March 16,1989 Cc~nOioon RepoTt 89-0204 initIated. Stress skin and ribs found

, +, .. ;.

~sstbetest. LERI

April 7, 1989 T'S! letter to GSU provided details of upcoming (May 5, 1989) tests at CiT.

April. 14, 1989 3-hour fire test conducted at CTL on 30-inci•~ wide aluminum cable

tray. Test passed. Rig constructed by TSI. CTL witnessed installation.

Reference CTL Report 824-63 and Revision 1.

April 17, 1989 LER 89-009 submitted to NRC describing removal of ribs and stress skin from 1-hour Therrmo-Lag fire barriers during construction. Fire•

watches established. 100 percent inspection planned.

4-4

, .'. ..
May 5, 19819 3-hown fire aiduruice tests conducted at CTL] on as-designed" 30-inch wide aluminum cable trays. GSU witnessed initial cnsmtrction of

article at TSI. Test passed. However, GSU questioned application of

extra coating on test article by TSI, which GSU could not reproduce.

Referece CT'L Reports 824-39 and 124-77.

Summer 1989

August 1989

Otbr12, 1989

October 13, 1989

October 23, 1919

Octoer• 26, 19W9

Additional questions rase by GSU on original qualification of hermo-Lag.

GSU re-estblished test program with SwRI.

RBS QC: issud memo describing constuction of I-hour and 3-hour fire

barrier tes ase•e for Octobe 1989 tests at SwRJ. i-hour baraier

had fiks and sresms skin removed, 3-hour brier' was "as-4esigned."

GSU letter invited TSI to inspect cable tray test aseale prior to

Octberm 26, 19W9 fire enduranc tests at SwRI.

13 rsliter ismfmsd OSU that they wild ut insiect at iclesr at

SwlU.

Hlow' flaw I of 30-indi wide "s.deigas" aluminum ruble tray ametlat SwL. Prmalt adTem o-Lgmed. GSU anarcm

tro umicr, Themo..l failed at stdo snotm mid sroy mdits i. km

ear hoelw. (Flil qxan kmie seof Apisl 1•2.)

rsuatEml

11m44 ~

October 31, 1989 TSI litter to OSU transmitted CI1L Report 824-39 (05103189 test) and C epr • 824-43 (04/14/89 test). Stated thickness of panels was

1.230 inch +/- 0.250. Enclosed Tech Note 20684, Revision V with

addendum (Trech Note 20684-AL) for aluminum cable trays.

November 8, 1989 TSI met with GSU to review SwRI test results.

November 9, 1989 GSU letter informed TSI of October 26, 1989 test results at SwRI and asked for evaluation. Letter states thai thermocouple data for 1-hour

and 3-hour SwRJ tests were previously submitted to TSI.

4-5
November 9, 1989

November 10, 1989

T'SI letter to GSU discussed test results. TSI$ chaimed that Thermo- Lag/Proato interface and incorrect installation (gap widths, stress skin

separation) caused the October 1989 SwRI test failure. TSI concluded

that test was not valid.

GSU memorandum summarized November 10, 1989 meeting at RBS

with T'SI to discuss test failures. GSU memo stated that Part 21

reportability was being evaluated.

November 14, 1989 TSI letter to GSU confirmed plan for plant walkdowns by T'SI.

November 17, 1989

December 7, 1989

GSU letter to T'S! provided construction details of fire barriers installed at RBS for T'S! review.

GSU met with T'SI at RBS to discuss corrective actions for

CR 89-1144.

December" 7, 1989 : TSI letter to GSU discussed Upgrades and qualification testing>

i!December 18,S: 1989 SI lete toGsu prvie meing summary frm Deeber 7, 1989

metig.PrviedTS popse upgrade •:':state an that: ampacity?••....

:i•ili;::

watch status. October 1989 SwRI test results still under evaluation by

GSU. Committed to update report by March 31, 1990.

January 11, 1990 GSU letter to TS! stated that October 26, 1989 test failure would have occurred on tray without barrier interface problem. Also questioned

gap widths and joint sealing.

January 26, 1990 NRC Safe shutdown inspection.(90-02) at RBS. Violation identified concerning.FHA requirement-not implemented by procedure.

February 7, 1990 Condition Report 90-0095 initiated. Thermo-L~ag fire barriers in pipe tunnel found to have surface cracks on visual inspection. Fire watches

established. Cracks to be patched.,

4-6
February 8, 1990

March 8, 1990

March 9, 1990

March 19, 1990

April 1990.

Condition Reports 90-0101 and 90-0106 initiated. During surveillance inspection, deficiencies (small holes, cracks and unfilled seams) were

found in Thermo-Lag fire barriers.

LER 90-003 submitted. Stated that surveillances conducted in February

identified barrier deficiencies. References CRs 90-0094, 90-0095, 90-

0101, and 90-0106. Committed to supplemental response to this LER

and the January 9, 1990 Informational Report by July 15, 1990.

GSU met with TSI at RBS to discuss tests required to qualify "asinstalled" barriers and potential repairs and upgrades.

TSI telecopied preliminary test procedure for November 1990 and

December 1990 tests to GSU for comment. (No copy.)

Test plan completed by TSI.

ii•;i-:•,..:::July 12, 1990 '..:•LER.9-03 Rev. I submitted to NRC. Stated that 1-hour and 3-hour . •¢ :;•.; ::./%:,:.::• .. i /:,:,•:firetests are planned to (1) evaluate "as installed" barrers and .. i!

-:: .- •-'•:'•i:!.~i:;:- ;ii:, i:-:i. ,•.,(2) develop repair methods, . •. i . i.!

;i~,i.iJuly 17, 1990 Gii~i~!!su issued puchseorder (90,-0-70456) to TSI t conduct 1-hour and .-. i•!il!

Augus 20, 1;990 .•III!GSU"andTSI agree onschedule for construction and testing (for -i_,':.! i,.iiii,••!.

•.!• !::•!!,iI, '- i : '•,", iiNovember.1990.and Diecembroa :1990 tests at TSI). • . ?i('•- -{;;:-ii•

3 4

letter.

September 10, 1990

November 19, 1990

December 18, 1990

GSU QC inspector arrived at TSI facilities to examine and monitor installation of test articles for 11/90 and 12/90 tests at TSI.

1-hour and 3-hour fire test program started at TSI facilities on "asinstalled" and "upgraded" barrier configurations.

Testing completed at TSI. 1-hour and 3-hour "as-installed" conduits

and cable trays failed. Some "upgrades" (addition of 1/4-inch thick

panels) passed based on GSU acceptance criteria. However, the 3-hour

cable tray upgrade failed.

4-7
,December 22, 1990 IT'L letter to GSU summarizing results of November 1990 and December 1990 tests performed by ITL at TSI lab.

February 4, 1991 LER 90-003 Rev. 2 submitted to NRC. Discussed ITL/JISI November and December 1990 fire tests. "As-installed" 1-hour and 3-hour tests

failed. Additional 1-hour and 3-hour tests of "upgraded" configurations

•passed (according to GSU criteria) except for 3-hour cable tray.

April 26, 1991 Internal RES memo provided information necessary to evaluate methods for installing fire baruiers.

May 15, 1991 LER 91-008 submitted to NRC. Fire wrap was not installed on electrical cables per the FHA since plant startup. Found in response to

review of FPHA by contractor following up January 1990 NRC

inspection. Corrective action not yet determined. References NRC

Inspection Reor 50-458/90-02.

May 24, 1991 SwRI letter to GSU transmitted draft final report 01-2702 for

October 26, 1989 3-hour fire test to GSU for comment.

June 26,1991 OSU letter to Swrtl provided comments on SwRI '~c~mua-~,us.

June 28, 1991 LU 90.003 Rev. 3 submitted to NRC. Acceptable upgrade for 3-hour

cable tu~y protection has not been found. Several alternatives being

explored by (35U. Fire watches remain in place. Committed to.

suWlemental tesponse by December 31, 1991. C','

August 6, 1991 information Notice 91-47, Failure of fliermo-Lq Fire Barrier 1. - ~ ~ IU r5.Fu~~wuUdIJL~ st,* i~i~i.

"C CV '*.CS,~1

"*

.J~C,.CV. ~ .. ;i-5.2C ."~ .L ~ ~ .j

(Th&s~ua1 revieW seam reviewed addItiot~aI documentim WG i~D~ 51w ~itinng its .t~

Octbb~1991 visit mat are n~ here~)

4-8

... .. • • . . . / . .: , .. . .: ". .•, , . , .. .. ... • . . .
ATTACHMENT 5

COMANCHE PEAK HISTORY AND DOCUMENTATION

REVIEWED BY SPECIAL REVIEW TEAM

(Docket No. 50-445

September 17, 1981 One hour fire endurance test conducted at SwRI. Test assembly built- b',v TSI. AN! standard used. 18" cable trays. Passed based on circuit

integrity. Highest cable surface temperature 260 °F. Air drop reached

554 OF.

October 27, 1981 Test report SwRl Project 03-6491, "Fire Qualification Test of a Protective Envelope System.'

,October 29, 1981 Copy of SwR! test report hand delivered to NRC.

• November 16, 1981 NRC memorandum from Johnston to Tedesco approving SwRI test

!• .~!-::?-Li.';I::i:T•-/:/.::+.:was and deliv~erd on ober 29, 1981, and reuesting NRC.. to./,i+•::.. i:i7i!

"ectember 7, 1981 TehiadvlainRpr or PESfrete proetecto prga +

TestAepI .69 S Poec 

September 15, 1989 TU verbally notified NRC concerning 50.55e on Thermo-Lag.

October 12, 1989 TU letter to. NRC issuing 10CFRS0.55e on site fabricated Thermo-Lag panels. Site fabricated Thermo-Lag panels were found with localized

dry film, thickness of less than 1/2 inch. Also seams and joints were

found less than 1/2 inch.

TSI letter to TU stating that localized, thickness variations to 3/8 inch

are acceptable for less than 2 % of the panel. October 26, 1989

5-1

i.ii! : •/:i": '.
?4ovcaba 3, 1969

Deebr1, 1989

January 3-30, 1990

May 17, 1990

June 1, 1990

July 13, 1990

Jul 20, 1990

TSI acIiefor 'e-- to TU sMting that kx~lized thickness variations are conduits.

NRC Inspection Report 89-71 which discusses Thermo-Lag thickness

•NRC Inpcl 9o.05 codce. Reviewed Therm-Lag allegations associaed with receipt inspcin.

Civil Pnaulty issued cocrnn ThemoLa.

TU response to Civil Peaulty.

TU letter to Rtegion IV discussing acceptance criteria for Thermo-Lag

-5el.

Region IV letter to TU acknowledging July 13, 1990, letter.

(Then Mvw1991 . ui s~vt lte w -

visi tim uiewe e at adioa listed hiem.) documnts at te= CPSES siWe durin its

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" ,L''.' 1 j, ;/-A.% -

ATTACHMENT 6

WNZHISTORY AND D)OCUMENTATION REVIEWED BY SPECIAL REVIEW TEAM

(Docket No. 5(0-397)

December 28, 1981

May 17-28, 1982

June 18-25, 1982

Letter from WPPSS to NRC summarizing telecon of December 11, 1981 between NRC, WNP2, Bechtel, and Burns & Roe

on 3-hour barriers.

I-hour fire endurance test conducted at TSI. ITL Report 82-5-355A.

Temperature reached 32SF, however TSI indicated acceptance of

barrier because no loss of circuit integrity occurred.

3-hour fire endurance test conducted at TSI. ITL Report 82-5-355B.

According to report, all configurations passed circuit integrity and

temperature.

•io.).!. Septe:.i::i mber 20, 1982 WN. • submitted iTL• Report 82-5-355A for NRC. review. Results of :•~~•!•::

October , i]19822 WNP2 response to NR0 Cquestio~ns of September 30, 1982. 1-: ,:.i-,1i:.7!.:,"i':i!:7"•,

" :December 27', 1982 Draft-SER on fire protection." "

April 26, 1983

May 1983

June 7, 1983

January 17, 1984

Revision II to TSI! Engineering Test Plan for direct spray on cable tray.

SSER #3 issued for WNP2. Page 9-3 approved the 3-hour TSI

Thermto-Lag as fire rated barrier. States that material is .capable of

limiting temperature rise to not more than 250 0F above ambient.

ITL Test 83-5-472 conducted for 1-hour direct application method.

Draft SSER on fire protection.

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March 3--7, 1986

April 15, 1986

May 9, 1986

July 29, 1986

August 19, 1986

Fire protection inspection (86-05). Unresolved items identified concerning protection of cable tray supports, intervening combustibles

not covered, and unwrapped cable trays.

Enforcement Conference on fire protection.

Letrto RV from WNP2 responding to enforcement conference on

Thermo-lag installation on supports. States problem was judgmental

error.

WNP2 letter revising commitment to correct cable tray support

protection to be completed in August 1986.

3-hour fire endurance test of 3M/IrsI interface conducted at 3M. TSI

failed 325 °F. Installed by certified installers.

•i• September 23, 1986 Revision I to TSI Engineering Test Plan for 3-hour "In-situ" test of

October ~..•'•8, 1i986 •:.WNl2 determined that cable denting calculations for service water did - :..:/.•'.:~!

•,,• •. !•,•iT!il.,:/./.:•::7: . :1/not consideer routing .in duct banks (LErR 86-003). Further review. i:-. .!.•>.

:.!{?i!:.--;q:P5•#:•!:,.ii .-•,.- 7•-• identifed "rhermo-la not taken into account. 31.5 percent derating :..: :: i.:'-•i•l

•{. i~ iJanuary: i12-1-i"5" 1987.Fire Prtcionnsecion~i• (87-02).:: Ampacity reviewed and .1closed:.:]7iiii "-,:!}{' -:{ i~"

•!7••~i5••!}••!%•=7•7>i•):-. vaiu`wuua7o•.u ing-appli cation method of "rhermo.-lag in untested,">•!l.{.< ZCiSVi'!]£

.. ."March 31, 1987 3-hour fire endurance test of 2' conduit with Thermo-Lag applied by

extrusion. Conduit failed temperature and circuit continuity.

April 1, 1987

April 13, 1987

May 7, 1987

1-hour fire endurance test of 4" conduit with Thermo-Lag applied by extrusion.

WNP2 submittal of Fire Protection Re-evaluation. Discusses Thermolag fire barrier adequacy. States that fire tests to be conducted by April

1987 of untested configurations. Also states ampacity issued closed,

but discusses 9.4 percent and 17.7 percent derating.

3M/TSI interface conducted by TSI for WNP2.

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"-:• June 6-10, 1988 , ire protecton inspection (88-i6). Closes intervening combustible 'i

-•- ~issue based on ThI letter.

February 14, 1990 SAIC technical evaluation report on WNP2 re-evaluation of fire

protection program.

March 28, 1991 Application deficiencies noted on Throlag barrers. Inadequate

thickness and incomplete transition from spray to board.

August 23, 1991 Letter to J. Kittler front TSI responding to Information Notice 91-47.

(The special review team reviewed additional documents at the WNPY2 site during its

November 1991 site visit that are not listed here.)

• • : •, • ..• • •- - ;., , .• .:..:• ,:. :. •---. :..,, . .• .-; • :.":: '::.._ . .: : ': •,. .: :: , ::.." ., .•- .,• • :• : .• ,, •: . . "• .•:,• . ..: .;.:--: . ii :• .. : .:' . ';..: .

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mm• M

sUsQUEANA HIsTORY AND Doc UMENTAToN

REVIEWED BY SPECIAL REVIEW TEAM

(Docket No. 30-387)

/ March 25, 1981 Meeting between NRC staff and PP&L to discuss fire protection issues.

March 26, 1981 SER input, with several open items, including the battery room.

•March 26, 1981 Licen.see letter committing to install 2-hour fire rated ceiling and 2-hour

enclosure in battery room.

April 15, 1981 SSER with only open item being alternate shutdown system.

• June 19, 1981 Licensee informed NRC of testing of Quelcor cable wrap in July 1981.

Ocee 6,191 UeselttrsbitdtwO test reports-for cable wrap material. .•i••..

ii:••;ii:•-i~i,; I ncluded!! Api ,1981 and AugUst 1981. TSl test reports.• i... . .. •:/!•,•,

!i•':•:!•: !prpgram including a 1-hour rate~d ,cable wrap •for battr room and ,: i/• •!•:iiiii'i!I

remot shutow anele with oan• maulsppeso uly band deeton.• ••

Lethe renfaerened previousendCeacceptaaone ofromanhe Peako barern

March 11 1982lMwein beween the NCal staff wand ins Ltole W disus Febracyp 9,198

sumateral. as a t -orreqbuested oyohen w TIts installeddffety. euta 

(ue11)and Behelistalliation procedure..

June 9, 1982 Liesee prvde P S letterJne ,9,982, inrosponsal bto NReCied

qunstaionso testso automaicetted on Malgy stem198.TIrpotreie"o

.oret.om.nte.er.s

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._! .... . ... I ... ... -- . ....... ... ..

.June 28, 1982 SSER stating that TSI tests submitted by PP&L were not performed in accordan~c with adequate QA procedures and therefore not acceptable..

The application procedure was also not clearly specified. Problems

were noted with the accuracy of the furnace temperature control and

thermocouples. The licensee should conduc an ASTM E-1 19 test at "an

approved testing laboratory," or install automatic fire extinguishing

system.

Licensee committed to perform a 1-hour test of TSI material using the

Comanche Peak test procedure. Material to be installed per PP&L

procedures submitted on May 12, 1982.

July 6, 1982

July 23, 1982 Licensee submitted copy of Test Specification.

August 25, 1982 Licensee submitted test report from SWRI. Test conducted on August 10, 1982.

A•ugust ,31,1982i•, -Licensee committed to ,modify tlhe instl~lation of cable wrap on cable ..-... , •i,::'!!iZ.`•/•/.•`:•••:-:•!i!:trays by adding fierglass armoring in accordance with TSI Technical ':'

Noe811 Reisio Auus , 1981.s 92 et:.'-" :•• '•

was only acete for conduit. Th cable trays exeee 32SF criltei, .::.•'•-,..

C'PSES -suibmittal Of October 27, 198 ,.aid was referenced. . .,:/-: •. ."•" '

4. . ... . .. ... •: . , ./ • . :~: il• ..

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