ML20151U550

Forwards Response to 880608 Request for Addl Info Re Review of PGE-1012, Trojan Nuclear Plant Fire Protection Plan. W/Two Oversize Drawings

ML20151U550
Person / Time
Site:	Trojan File:Portland General Electric icon.png
Issue date:	08/12/1988
From:	Cockfield D PORTLAND GENERAL ELECTRIC CO.
To:	NRC OFFICE OF ADMINISTRATION & RESOURCES MANAGEMENT (ARM)
Shared Package
ML16342B474	List: ML20151U550
References
TAC-66379, NUDOCS 8808190169
Download: ML20151U550 (186)

Text

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asumes (3 g m comralsechiccompany David W. Cockfield Vice President, Nuclear August 12, 1988 Trojan Nuclear Plant Docket 50-344 License NPF-1 U.S. Nuclear Regulatory Commission ATTN: Document Control Desk Washington DC 20555

Dear Sirs:

Response to Request for Additional Information Trojan Fire Protection Plan (TAC No. 66379)

Attached is Portland General Electric Company's (PCE) responso to tho Nuclear Regulatory Commission request for additional information dated June 8, 1988, relativo to your review of PGE-1012. "Trojan Nuclear Plant Firo Protection Plan". Volumos 1 and II.

We would be pleased to discuss any questions or comments you may have regarding this information.

Sincerely,

/

Attachment c:

Mr. John B. Martin Regional Administrator, Region V U.S. Nuclear Regulatory Commission Mr. Bill Dixon State of Oregon Department of Enorgy Mr. R. C. Barc WRC Resident Inspector Trojan Nuclear Plant g

I I 8808190169 esost, I

fDR ADOCK 05000344 PDC O SW &cn Shet Ftmna C<er 97204 L_.

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Trojan Nuclear Plant Document Control Desk Docket 50-344 August 12, 1988 NPF-1 Page 1 of 5 PORTLAND GENERAL ELECTRIC COMPANY'S (PCE)

RESPONSE TO NUCLEAR RECULATORY COMMISSION (NRC) REQUEST FOR ADDITIONAL INFORMATION ON THC FIRE PROTECTION PLAN REVIEW 1.

Provide supporting documentetion which demonstrates that Penetra-tion 603A is a rated configuration. The type of documentation provided should be equivalent to that which is available for all rated penetrati)ns onsite.

Response

a.

Portions of Civil Fire Protection Files C-FP-1.1 (Attachment 2) and C-FP-1.3.3 (Attachment 3) are provided, along with Drawing C-7144 (Attachment 4), to demonstrate the adequacy of Penetration Seal No. 603 and similar seals.

Penetration Seal No. 603 is a nominal 9-3/4-inch-thick silicone foam see) of a large cable tray and conduit penetration through the east wall of the cable spreading room. The seal conforms to Detail 2 on Drawing C-7144.

The seal was installed as a 3-hour fire-rated seal during the 1979 upgrading of penetretion seals; however, American Nuclear Insurers (AN1) withdrew their accept-ance of 9-3/4-inch thick foam seals without permanent damming in a letter dated October 20, 1985.

Section 4.5.4 of PCF-1012 Volume I, provides additional details.

Items 4, 5 and 14 of File C-FP-1.1 contain evaluations of the applicability of test reports submitted to PCE by the seal vendor in 1979 as evidence of the quslification of the seal configuration as a 3-hcur-rated seal.

Item 14 of File C-FP-1..

contains the evaluation of a test (terminated at 2 hours2.314815e-5 days <br />5.555556e-4 hours <br />3.306878e-6 weeks <br />7.61e-7 months <br /> and 35 minutes) performed for ANI to represent a 9-inch-thick silicone foam seal without permanent damning.

The File C-FP-1.3.3 analyses provide a general fire hazards analysis for 9-3/4-inch thick silicone foam seals without permanent damming and a specific evaluation for four large silicone foam seals (including No. 603) in the east wall of the cable spreading room. These documents provide justifications for the acceptability of these seals being less than 3-hour ra *.e d.

b.

Portions of Filas C-FP-1.1 (Attachment 2), C-FP-1.2 (Attach-ment 5) and examples of specific penetration seal documentation (included in Attachment 5) are provided to demonstrate the adequacy of documentation which is available for penetration seals installed since 1986.

These seals are installed to L.

i Trojan Nuclear Plant Document Control Desk Docket 50-344 August 12, 1988 NPF-1 Page 2 of 5 details which are qualified to meet 3-hour fire-rated test reports.

The silicone foam used for these details is not the same as thattJsed for the foam seals installed before 1986.

File C-FP-1.2 contains evaluations and descriptions for records of all penetration seals. The example records are for Penetra-tion Seal No. 2017.

Items 15, 16, 18 and 20 of the File C-FP-1.1 contain evaluations of the applicability of test reports submitted to PCE by the seal vendor in 1986 as evidence of the qualification of the seal configuration as a 3-hour-rated seal.

2.

Provide the results of the analyses which demonstrates that the exterior boundaries of fire areas are either rated or that they have been evaluated to provide the necessary protection from exterior hazards.

Besponse:

Portions of Civil Fire Protection Files C-FP-1.3.1 (Attach-ment 6), C-FP-1.3.16 (Attachment 7) and C-FP-1.3.17 (Attach-ment 8) are provided to demonstrate the adequacy of exterior fire area boundaries. These ovaluations meet Section 3.1.3 of to NRC Generic Letter 86-10.

All exterior boundaries were addressed in the tables of File C-FP-1.3.1 which show that none of these boundaries are needed for separation of redundant safe shutdown systems.

Exterior Control Building boundaries and service water pump room walls are maintained as 3-hour-rated barriers. A portion of the west wall of the Turbine Building adjacent to the main trans-formers is 3-hour-rated and is evaluated in File C-FP-1.3.17 for any potential effect of a fire in the transformers on safety related systems in the Turbine Building.

Most other exterier boundaries are not fire-rated, but are maintained so that any fire protection which may be provided by the non-rated barrier is not degraded.

Since there are no sig-nificant fire hazards in the yard adjacent to these exterior boundaries, detailed fire hazards analysas have not been per-formed for these boundaries.

The amount of transient combust-ibles in the yard next to exterior boundaries of fire areas are controlled by Administrative Order (AO) 5, "Transient Combustible Program".

Trojan Nuclear Plant Document Control Desk Docket 50-344 August 12, 1988 NPF-1 Page 3 of 5 3.

Provide documentation which demonstrates that the cable wrap systems used in the Plant provido the proper rating in the configurations in which they are used.

Response

Portions of Civil Fire Protection Files C-FP-1.1 (Attachment 2) and C-FP-1.3.11 (Attachment 9) are provided to demonstrate the adequacy of the cable wrap systems.

The File C-FP-1.3.11 provides the general evaluation of the cabic wrap systems.

Items 24, 25, 36, 37 and 38 of File C-FP-1.1 contain evaluations of the applicability of test rwports submitted to PGE by the cable wrap vendor as evidence of the qualification of the cable wrap systems as a 3-hour rated.

4 Identify which National Fire Protection Association (NFPA) codos have been compared with current Plant design.

If code compliance evaluations have not been performed, indicate when they will be performed in the future.

Response

NFPA Codes NFPA-72D, "Proprietary Protective Signaling Systems",

NFPA-72E, "Automatic Fire Detectors", and to a limited extent, NFPA-20 "Centrifugal Fire Pumps", have been compared with cur-rent Plant design. Table 5-1 of PGE-1012, Volume I, provides a description and justification of deviations for these NFPA codes.

As a future activity, PCE intends to perform a code compliance evaluation of all NFPA codes applicable to the Trojan Nuclear Plant.

It is intended to start this review in late 1988 and to complete the review in 1989 5.

Provide a discuccion on how the various engineering cvaluations are referenced in PCE-1012 or other documents which would tie them into the Fire Protection Program. A flow chart of Fire Protection Pro-gram documents, including engineering evaluations, would be helpful.

Response

PGE-1012 currently references some entineering evaluations by file or report name. These references primarily include Civil Engineering evaluations, and to a more limited extent, other engineering evaluations and reports. PCE-1012 is currently being revised to include more references to Civil Engineering

Trojan Nuclear Plant Document Control Desk Docket 50-344 August 12, 1988 NPF-1 Page 4 of 5 evaluations, specifically by evaluation number and name.

How-ever, this revision does not include references for all ensi-neering evaluations, neither is there a flow chart available that provides this information.

PGE recognizes the importance of referencing engineering evalu-ations in PCE-1012 and intends to provide these references in a subsequent revision te PCE-1012 to be issued by December 31, 1988.

6.

Provide a discussion of how Trojan fire protection commitments are tracked and how it is ensured that all of these commitments are in PG E-1012.

Response

All PGE commitments pertaining to the operation of the Trojan Nuclear Plant, including fire protection commitments, are tracked by the Commitment Tracking List (CTL).

The CTL is a computer-based tracking system developed to provide a cocplete t

listing of internal and external PGE commitments for Trojan.

Use of the CTL is governed by Nuclear Division Procedure (NDP) 700-1, "Commitment Control System".

All changes to PCE-1012 are initiated, reviewed, and approved in accordance with NDP 700-2, "Control of the Trojan Operating License and Licensing Documents".

It is intended that all fire protection commitments be incorporated in PGE-1012.

The source of many fire protection commitments is PGE-1012 it-self. These types of commitments are tracked by the CTL and are retained in PGE-1012. Other commitments originate in PCE letter correspondence to the NRC.

The CTL is also used to track Ictter commitments and, together with the licensing document change process described above, ensure that these compitments are incorporated into PCE-1012, 7.

Provide evaluations regarding conformance to NRC Fire Protection criteria for each of the areas listed 'oelow.

Where multiple evalu-ations are within each category, only a single evaluation need be provided.

Fire Area Boundaries - C-FP-1.3.1 Penetration Seals With Less than 3-Hour Rating - C-FP-1.3.3 Upen Pipe Chase Between Al and A2 - C-FP-1.3.6 Fire Doors - C-FP-1.3.10 Transient Combustibles - C-FP-1,3.16 Train separation Barriers - C-FP-1,3.15

Trojan Nuclear Plant Document Control Desk Docket 50-344 August 12, 1988 WPF-1 Page 5 of 5

Response

The requested portions of the fire protection evaluations are provided in the attached as follows;

• Attachment 6 (C-FP-1.3.1)

. Attachment 3 (C-FP-1.3.3)

. Attachment 10 (C-FP-1.3.6) l l

• Attachment 11 (C-FP-1.3.10)

• Attachment 7 (C-FP-1.3.16)

• Attachment 12 (C-FP-1.3.15)

The completo fire protection files contain additional supporting information including such items as fire test reports, surveys and calculations.

File C-FP-1.3.10. "Fire Doors", is complete but is not yet approved.

This file is scheduled to be approved by September 1, 1988.

DRS/mr 2509W.888

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Trojan Nuclear Plant Document Control De.n Docket 50-344 August 12, 1988 License NPF-1 Page 1 of 15 FILE C-FP-1.1 ITEM NO 4

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CIVIL EVALUATION OF FIRE TEST FOR 9-3/4 INCH SILICONE FOAM SEAL BISCO 1064-10 6

• * * * * * * * * * * * * * * * * * * * * * * * * * * * * * * * * * *(* */ 2 0/ 7 9 )

f87 Chk By

-Date 88 By

._ Date r

Ir I i Description of test This tost was received from BISCO in 1979 as part of the Contract TF-004 upgrading of penetration seals.

It is maintained as evidence of the degree of fire protection provided by the 9-3/4 inch seals at Trojan.

Penetrat.on seal detail numbers 1, 2,

3, 4,

6 _,

7, 10, 16 and 18 as shown on drawing C-7144 are represented, at least to some degree, by this test.

This penetration seal test consisted of a 9-3/4 inch thick, Dow Corning 3-6548 silicone foam seal in a 7-3/4 inch gypsum board wall.

The penetration opening was built out to the full 9-3/4 inch thickness by framing with 1 inch 'M-Board' on each side.

There was no damming left in place on either side of the seal during the test.

The test specimen was tested in the vertical position.

The test was performed for 3 hours3.472222e-5 days <br />8.333333e-4 hours <br />4.960317e-6 weeks <br />1.1415e-6 months <br /> and a hose stream test was performed.

The 9-3/4 inch seal area in the test was 37-1/2 inches by 40 inches (10.4 square feet).

A letter from American Nuclear Insurers (ANI), dated 6/8/1979, however, stated that an area of 70 inches by 40 inches (19.4 square feet) would be acceptable.

Based on this interpretation, a maximum undivided area of 19 square feet was used for seal details numbers 1 and 2.

ANI withdrawal of acceptance 9

In a letter dated 10/20/1985, ANI withdrew their acceptance of Trojan's 9-3/4 inch thick seals without permanent damming.

This was based on a review of 1976 BISCO fire tests, and on results of a 1985 test of a 9 inch foam seal.

This test for 9-3/4 inch i

seals was not referenced by ANIt however, since the 1985 test ended by an actual burn-thru at about 2-1/2 hours, we are in agreement with ANI's interpretation.

For more information on the 1985 test, see item 14 of this file.

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Trojan Nuclear Plant Docunent Control Desk Dochet 50-344 August 12 1988 License NPF-1 Page 2 of 15 ConcluS19111

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The original use of the 19 square feet undivided area is i

questionable.

It is now our interpretation that the maximum undivided area for wall penetrations, should have been 10.4 square feet.

Tha larger undivided area together with the results of the 1985 test for ANI of the 9 inch seal lead us to the conclusion that 9-3/4 inch thick silicone foam seals without pericanent damming are not 3-hour rated.

5 File C-FP-1.3.3 contains detailed evaluations of 9-3/4 inch silicone foam seals for which ANI has withdrawn the 3-hr rating,and provides justifications for the acceptability of the fire protection provided by these seals, f

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Trojan Nuclear Plant Documant Control Desk Docket 50-344 August 12, 1988 License NPF-1 At ta c h::ent 2 Page 1 of 15

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I FILE C-FP-1.1 ITEM NO 5 CIVIL EVALUATION OF REPORT OF i

EQUIVALENCY OF ORIGINAL AND DC 3-6548 SILICONE FOAM BISCO REPORT (6/20/79)

By Date 3

Chk By El Date 1 f

j' " '

/,f Descriotion of test This report was received from BISCO in 1979 as part of the Contract TF-004 upgrading of penetration seals.

It is maintained as evidence of the degree of fire protection provided by the 9-3/4 inch silicone foam seals at Trojan.

Penetration seal detail numbers 1, 2, 3, 4,

6, 7,

10, 16 and 18 as shown on drawing C-7144 may be represented by this test in cases where upgrading of a seal was performed.by adding Dow Corning 3-6548 silicone foam to the originally installed SF-20 four component silicone foam.

The BISCO report compares the fire protection provided by the four component silicone foam installed during original construction and the Dow Corning 3-6548 silicone foam installed during the 1979 upgrading of penetration seals.

A letter from Dow Corning to BISCO dated 12/15/1977 documents compatibility where the two types are utilized in the same seal.

Conclusions The report and letter show that the two types of silicone foam are compatible.

The addition of Dow Corning 3-6548 to an existing SF-20 silicona foam seal should not change any conclusions based on fire tests that just use the Dow corning 3-6548 silicone foam.

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Trojen Nuclear Plant Docuntnt Control D:sk Docket 50-344 August 12. 1988 License NPF-1 Attcchment 2 Page 4 of 15 FILE C-FP-1.1 ITEM No 8 l

CIVIL EVALUATION OF FIRE TEST FOR DIVIDER BOARD USED IN SILICONE FOAM SEALS DISCO 0742-02 (8/11/77)

• • • • • • • • • • • • • • • • • • • • • • • • • • • • • • • • • • • • • • • • • • • • • • m*****************

By Date 3//0/86 Chk By _

Aw 4 Date __J 8f

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va Descrintion of test This test was received from BISCO in 1979 as part of the Contract TF-004 upgrading of penetration seals.

It is maintained as evidence of the degree of fire protection provided by the 9-3/4 inch Silicone Foam seals at Trojan where the area of the seal is reduced by dividing the seal with Marinite divider boards.

This configuration is used as per details 2 and 4 on drawing C-7144.

The test specimen was tested in the horizontal position.

The test was performed for 3 hours3.472222e-5 days <br />8.333333e-4 hours <br />4.960317e-6 weeks <br />1.1415e-6 months <br /> but a hose stream test was not performed.

The fire test was successful.

The test was performed using 3/a6 inch thich Transite shaetet however, 1/2 inch thick Marinite board is judged to be equivalent.

Conclusions The test documents the 3-hour fire-rated protection provided by the Silicone Foam seals with Marinite divider boards.

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Trojan Nuclear Plant Docuasnt Control Desk Docket 50-344 August 12 1988 License NPF-1 Attachssnt 2 Pago 5 of 15 PAGE 1 OF 1 i

FILE C-FP-1.1 ITEM NO 14 CIVIL EVALUATION OF FIRE TEST FOR 9-3/4 INCH SILICONE FCAM SEAL BISCO 748-183 (8/06/85)

By

__Datef 68 Chk By o>Date %

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Descriotion of test This test was received from American Nuclear Insurers (ANI) as documentation supporting their decision to withdraw its acceptance of the 9-3/4-inch thick BISCO SF-20 (Dow Corning 3-6548) silicone foam seals penetration seals without permanent damming.

This penetration seal test consisted of a 9-inch thick, BISCO SF-20 (Dow Corning 3-6548) silicone foam seal in a 30-inch by 30-inch opening in a 12-inch concrete slab.

There was no damming left in place on either side of the seal during the test.

The test specimen was tested in the horizontal position.

The test was terminated at 2-hours and 35-minutes because burn-thru occurred at that time.

No hose stream test was performed.

ANI withdrawal of accentance In a letter dated 10/20/1985, ANI withdrew their acceptance of Trojan's 9-3/4-inch thick seals without permanent damming.

This was based on a review of 1976 BISCO fire tests, and on results of this test of a 9-inch foam seal.

Conclusions 9-3/4-inch BISCO SF-20 (Dow Corning 3-6548) silicone foam seals without permanent damming are not 3-hch* fire-rated.

File C-FP-1.3.3 contains detailed evaluations of 9-3/4-inch silicone foam seals for which ANI has withdrawn the 3-hr rating, and provides justifications for the acceptability of the fire protection provided by these seals.

Trojan Nuclear Plant Documsnt Control Dask Docket 50-344 August 12 1988 License NPF-1 Attechment 2 Page 6 of 15 FILE C-FP-1.1 ITEM NO 15, CIVIL EVALUATION OF FIRE TEST FOR 7-1/2 INCH SE-FOAM SEAL BISCO 748-134 (5

• * * * * * * * * * * * * * * * * * * * * * * * * * * * * * * * * * * * */ 14 / 8 4 )

• • • • • • e***ut***************

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Descrintion of tett This test was received from BISCO in 1986 as part of the contract (NQ-00505) for training of PGE personnel for installation of bisco's Qualified penetration seals.

It is maintained as evidence of the degree of fire protection provided by the 7-1/2 inch.9E-FOAM seals at Trojan.

Penetration seal detail numbers 19, 20, 21, 22, 23, 24, 25, 26, 27, 31,32 and 33 as shown on drawing C-7144 are represented, at least to some degree, by this test.

This penetration seal test consisted of a penetration opening in a 12 inch thick concrete slab which was seeiled with two types of silicone foam separated by a divider board.

One half of the opening was sealed with 7-1/2 inch thick, HISCO SE-FOAM, and the other half with 9 inch thick BISCO SF-20 sjlicone foam.

There was no damming left in place on either side of the seal during the test.

The surface area of the SE-FOAM seal was 3.1 square feet.

The test specimen was tested in the horizontal position.

The test was performed for 3 hours3.472222e-5 days <br />8.333333e-4 hours <br />4.960317e-6 weeks <br />1.1415e-6 months <br /> and a hose stream test was performed.

Tests for both seals were successful.

This test demonstrates the equivalency of SE-FOAM and SF-20 silicone foam, conclusions This test demonstrates the 3-hour fire-rated protection provided by a 7-1/2 inch thick SE-FOAM seal with an area up to 3.1 square feet.

Trojan Nuclear Plant ttcument Control Desk Decket 50-344 August 12, 1988 License NPF-1 Page 7 o' 15 i

FILE C-FP-1.1 ITEM NO 16 CIVIL EVALUATION OF FIRE TEST FOR 7-1/2 INCH SE-FOAM SEAL BISCO 748-185 12

• • • • • • • • • • • • • • • • • • • • • • • • • • • • • • • • • • • (**/10/84)

By 7

Date ([f/67 Chk By

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Date 2 34 gg Descriotion of test This test was raceived from BISCO in 1986 as part of the contract (NQ-00505) for training of PGE personnel for installation of BISCO' Qualified penetration seals.

It is maintained as evi.

the degree of fire protection provided by the 7-1/2 inch,

mi sehls at Trojan.

Penetration seal detail numbers 20,

, 24, 26, 31 and 33 as shown on drawing C-7144 are represented, at least to some degree, by this test.

This penetration seal test consisted of a penetration opening in a 12 inch thick concrete slab which was sealed with 7-1/2 inch thick, BISCO SE-FOAM.

1 inch thick ceramic "M" Board damming was left in place on the bottom side of the seal.

The surface area of the SE-FOAM seal was 6.2 square feet.

A pipe was used as the penetrating item.

The test specimen was tested in the horizontal position.

The test was performed for 3 hours3.472222e-5 days <br />8.333333e-4 hours <br />4.960317e-6 weeks <br />1.1415e-6 months <br /> and a hose stream test was performed.

The test was successful.

_ Conclusions This test demonstrates the 3-hour fire-rated protection provided by a 7-1/2 inch thick SE-FOAM seal '. tith damming and with an area up to 6.2 square feet.

i Trojan Nuc1 car Plant Document Control Desk Docket 50-344 August 12, 1988 License NPF-1 At t ach:ne nt 2 Page 8 of 15 FILE C-FP-1.1 ITEM NO 18

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CIVIL EVALUATION OF FIRE TEST FOR 7-1/2 INCH SE-FOAM SEAL BISCO 748-180

• • • • • • • • • • • • • • • • • • • • • • • • • • • • • • • • • • • (12/17/84)

.S. ' '

Data M/ M b

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- 3 !f8 Oy A

Chk By M Date

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Description of test This test was received from BISCO in 1986 as part of the contract (NC-00505) for training of FGE personnel for installation of BISCO's Qualified penetration seals.

It 1F maintained as evidence of the degree of fire protection prcvided by the 7-1/2 inch SE-FOAM seals at Trojan.

Penetration coal detail nunbers 20 and 22 as shown on drawing C-7144 are represented by this test.

This penetration seal test consisted of a penetration opening in inch thick coacrete slab which was sealed with 7-1/2 inch a 12 thick, BISCO SE-FOAM.

1 inch thick ceramic "M" Board damming was left in place cc the bottom side of the seal.

The surface area of the SE-FOAM seal was 6.2 square feet.

Two cable trays were used as penetrating items.

The test specimen was tested in the horizontal position.

The test was performed for 3 hours3.472222e-5 days <br />8.333333e-4 hours <br />4.960317e-6 weeks <br />1.1415e-6 months <br /> and a hose stream test was performed.

The test was successful.

Conclus(olg This test demonstrates the 3-hour fire-rated protection provided by a 7-1/2 inch thick SE-FOAM seal with damming and with an area up to 6.A square feet.

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Trojan Nuclear Plant Document Control Desk Dochet 50-344 August 12, 1988 License NPP-1 Page 9 of 15

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ELLE C-PP-1.1 ITEM NO 20 CIVIL EVALUATION OF FIRE TEST FOR EMBEDDED CONDUIT SLEEVE SF-20 SILICONE FOAM SEAL MINIMUM 1/8 INCH GAP BISCO 748-79

• • • • • • • • • • • • • • • • • • • • • • • • • • • • • • • • • • • (5/31/83) 2!

{/67ChkBy Date By Date v/

7 DescriDtion of test This test was received from BISCO in 1986 as part of the contract (NQ-00505) for training of PGE personnel for installation of BISCO's Qualified penetration seals.

It is maintained as evidence of the degree of fire protection provided by a minimum 1/8 inch gap used in the 7-1/2 inch SE-FOAM seals at Trojan.

Minimum gaps allowed for penetration seal detail numbers 19, 20, 21, 22, 23, 24, 25,.26, 31,32 and 33 as shown on drawing C-7144 are represented by this test.

This penetration seal test consisted of 5 inch diameter rigid conduit sleeves embedded a concrete slab.

Embedded conduit

'C4' contained a 1-1/2 inch conduit placed within 1/8 inch of the edge of the 5 inch conduit and the annular space was filled with 9 inched of BISCO SF-20 silicone foam.

'M' Board damming was installed on the bottom side of the seal.

The test specimen was tr.sted in the horizontal position.

The test was performed for 3 hours3.472222e-5 days <br />8.333333e-4 hours <br />4.960317e-6 weeks <br />1.1415e-6 months <br /> and a hose stream test was performed.

The test was successful.

Conclusions This test demorstrates the 3-hour fire-rated protection provided by a silicone foam seal with a 1/8 inch gap between the edge of the penetration opening and the embedded conduit or pipe.

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Trojan Nuclear Plant Document Control Desk Docket 50-344 August 12, 1988 License NPF-1 Page 10 of 15

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FILE C-FP-1 1.

ITEM NO 24 CIVIL EVALUATION OF FIRE TEST FOR THERMO-LAG 330-1 1-HR RATED CABLE WRAP SYSTEM INDUSTRIAL TESTING LABORATORIES REPORT

• • • • • • • • • • • • • • • • • • • • • • • • • • • • • • • • • • • • • • • • • • NO 82-11-80 (11/82)

By

/1AA Date 8/82 Chk By -

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yy Descriotion of Test This test is maintained as evidence of the 1-hour fire-rating of the THERMO-LAG 330-1 cable wrap system using a nominal 0.5 inch thickness of THERMO-LAG.

The fire test was performed for 1 hour1.157407e-5 days <br />2.777778e-4 hours <br />1.653439e-6 weeks <br />3.805e-7 months <br /> followed by a hose stream tent.

The test was successful.

The THERMO-LAG materials were installed on the test articles by several methods including direct spray, brushing, rolling, troweling, caulking and prefabricated panels.

A ' repair' patch procedure is also documented by this test.

This file contains a copy of American Nuclear Insurers

' Acceptance of Testing' for a 1-hcur rating.

p_gnclusions The test qualifies the THERMO-LAG Subliming Coating System for 1-hour fire-rated protection of cable trays, conduits and pull boxes.

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Trojan Nuclear Plant Document Control Lesk Docket 50-344 August 12, 1988 License RPF-1 Page 11 of 15

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FILE C-FP-1.1 ITEM NO 25 CIVIL EVALUATION OF FIRE TEST FOR THERMO-LAG 330-1 3-HR RATED CABLE WRAP SYSTEM INDUSTRIAL TESTING LABORATORIES REPORT NO 82-

• • • • • • • • • • • • • • • • • • • • • • • • • • • • • • • • • • • • • • • • • • • • • • • • 11-81 (11/82)

By Date M/8/87 Chk By Date 3[//88 l'

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Descriotion of Test This test is maintained as evidence of the 3-hour fire-rating of the THERMO-LAG 330-1 cable wrap system using a nominal 1 inch thickness of THERE-LAG.

The fire test was performed for 3 hours3.472222e-5 days <br />8.333333e-4 hours <br />4.960317e-6 weeks <br />1.1415e-6 months <br /> followed by a hose stream test.

The test was successful.

The THERMO-LAG materials were installed on the test articles by several methods including direct spray, brushing, rolling, troweling, caulking and prefabricated panels.

A ' repair' patch procedure is also cocumented by this test.

This file contains a copy of American Nuclear Insurers

' Acceptance of Testing' for a 3-hour rating.

I Conclusions The test qualifies the THERMO-LAG Subliming Coating System for 3-hour fire-rated protection of cable trays, conduits and pull boxes.

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Trojan Nuclear Plant Document Control Desk Docket 50-344 August 12, 1988 o

License NPF-1 Attach ent 2 Page 12 of 15 PAGE 1 OF 1

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1 FILE C-FP.1.1 ITEM 36 CIVIL EVALUATION OF FIRE TEST FOR THERMO-LAG 330 1-HR RATED CABLE WRAP SYSTEM WITH UNISTRUT PROTRUDING THROUGH WRAP ENVEoOPE INDUSTRIAL TESTING LABORATORIES 8~-5-77

• * * * * * * * * * * * * * * * * * * * * * * * * * * * * * * * * * * * * * * * *RE PO RT N O.

By Date 3 M Chk By MI Date 8/3/6B Ql

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'f Descriotion of Testina The attached ITL Teut Report No. 87-5-77 documents the 1-hour fire-rating provided by a nominal 1/2-inch thickness of Thermo-lag 330 Cable Wrap System material when it is used to protect a cable tray that has a P-1000 unistrut protruding through the wrap envelope.

The test was conducted on a 12-inch X 4-inch ladder cable tray modified to include a 21-3/4-inch long L-shaped P-1000 unistrut section (cross sectional dimension of 1-5/8" X 1-5/8") welded to one side of the cable tray.

The tray was filled with 42 generic power and instrument cables.

Both the cable tray and the unistrut were wrapped uith a nominal 1/2-inch thickness of Tharmo-lag 330 prefabricated panel sections.

The unistrut was protected with the wrap out to a minimum distance of 9-inches from the cable tray wrap envelope.

The fire endurance and hose stream tests where conducted in accordance with the applicable sections of ASTM E-119 and ANI's Bulletin #5(79).

The Thermo-lag 330 cable wrap system pasged both the fire endurance and the hose stream tests.

5 Conclusions One-hour fire barrier protection is provided for a cable tray wrapped with a nominal 1/2-inch thickness of Thermo-lag 330 Cable Wrap System material, when all unistrut or similar commodities that protrude T.hrough the cable wrap envelope are also wrapped with a 1/2-inch thickness of the Thermo-lag wrap out to a distance of 9-inches from the outer edge of the cable tray wrap envelope.

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Trojan Nuclear Plant Document Control Desk Docket 50-344 August 12, 1988 License NPF-1 Page 13 of 15 PAGE 1 OF 2 FILE C-FP-1.1 ITEM 37 CIVIL EVALUATION OF FIRE TEST FOR THERMO-LAG 330 3-HR CABLE WRAP SYSTEM WITH UNISTRUT PROTRUDING THROUGH WRAP ENVELOPE INDUSTRIAL TESTING LABORATORIES REPORT

• • • • • • • • • • • • • • • • • • • • • • • • • • • • • • • • • • • • • • • • • • • • • • • NO. 84-12-181 Date 3/25[8E Chk By Date N3/8B By mAg(

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Description of Testina The attached ITL Test Report No. 84-12-181 documents the 3-hour fire-rating provided by a nominal 1-inch thickness of Thermo-lag 330 Cable Wrap System material when it is used to protect a cable tray that has a P-1000 unistrut protruding through the wrap envelope.

Tne test was conducted on a 12-inch X 4-inch ladder cable tray modified to include a 24-inch long L-shaped P-1000 unistrut section (cross-sectional dimension of 1-S/8" X 1-5/8") welded to one side of the cable tray.

The tray was filled with 142 generic power, control, and instrument cables to simulate a cable tray fill af 40%.

The cable tray was wrapped with a nominal 1-inch thickness of Thermo-lag 330 prefabricated panels sections using a 12-inch spacing instead of the normal 6-inch spacing for the stainless steel banding that hold the panels sections on the the tray.

The unistrut was wrapped with a 1.2-inch thickness of Thermo-lag 330-1 Subliming trowel grade material.

A 1.2-inch dry film thickness of the Thermo-lag Subliming trowel grade material is equivalent to using a nominal 1-inch thickness of the Thermo-lag 330 prefabricated panels.

The unistrut was protected with the wrap out to a minimum distance of 18-inches from the cable tray wrap envelope.

In addition, l

two different flared transition designs were installed at the junction of the cable tray wrap with the penetration through the concrete slab. A 1-inch nominal thickness of Thermo-lag 330 prefabricated panel sections were used to make the flared transition at the top junction, and a 1-inch thickness of l

Thermo-lag 330-1 Subliming trowel grade material was used to make the caulked-in flared transition at the bottom junction.

I i

l The 3-hour fire endurance and hose stream tests where L

conducted in accordance with the applicable sections of ASIM E-119 and ANI's Bulletin #5(79).

The Thermo-lag 330 Cable Wrap System pasged both the fire endurance and the hose stream tests.

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Trojan Nuclear Plant Document Control Desk Locket 50-344 August 12, 1988 License NPF-1 Page 14 of 15 PAGE 2 OF 2

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C-FP-1.1 Item 37 Conclusions Three-hour fire barrier protection is provided for a cable tray wrapped with a nominal 1-inch thickness of Thermo-lag Cable Wrap System material, when all unistrut or similar commodities that protrude through the cable wrap envelope are also wrapped with a nominal 1-inch thickness of the Thermo-lag wrap out to a distance of 18-inches from the outer edge of the cable tray wrap envelope.

Both flared transition designs do not allow the penetration of flame, smoke, or water and will not otherwise effect the integrity of the wrap system.

In addition, the integrity of the wrap system is not affected when the spacing between the mechanical ties are increased to a maximum distance of 12-inches.

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Trojan Nuclear Plant Document Control Desh Docket 50-344 August 12, 1988 License NPF-1 Page 15 of 15 PAGE 1 OF 1

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FILE C-FP-1.1 ITEM 38 CIVIL EVALUATION OF FIRE TEST FOR THERMO-LAG 330 3-HR CABLE WRAP SYSTEM FOR CONDUITS MOUNTED NEXT TO CONCRETE WALL INDUSTRIAL TESTING LABORATORIES REPORT NO. 84-1

• • • • • • • • • • • • • • • • • • • • • • • • • • • • • • • • • • • • • • • • • • • • • • • • • • • • • • • 2-294 By o Date I

Chk By Date 8/89 II I

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Descriotion of Testina The attached ITL Test Report No. 84-12-294 documents the 3-hour fire rating provided by a nominal 1-inch tnickness of Thermo-lag 330 Cable Wrap System material when it is used to protect electrical conduits that are mounted next to a concrete wall.

The test was conducted on two 4". diameter electrical conduits filled with cables to simulate a'40% fill.

One conduit was filled with 10 IEEE power, control, and instrument cables, and the other conduit was filled with 11 generic power, control, and instrument cables.

The conduits were mounted

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immediately adjacent to a concrete wall with just enough room between the conduits and the wall to permit passage of the stainless steel banding used to fasten the Thermo-lag wrap to the conduits.

The conduits were wrapped with Thermo-lag 330 preshaped conduit sections and prefabricated panel cap sections.

The Thermo-lag conduit sections were cut to fit flush with the surface of the concrete wall and banded at 6-inch intervals.

Thermo-lag Subliming trowel grade material was used to caulk all joints and transition areas between the preshaped conduit sections and the wall.

The 3-hour fire endurance and hose stream tests where cor. ducted in accordance with the applicable sections of ASTM E-119 and ANI's Bulletin #5(79).

The Thermo-lag Cable wrap System pas ed both the fire endurance and hose stream tests.

Conclusions Three-hour fire barrier protection is provided for conduits wrapped with a nominal 1-inch thickness of Thermo-lag Cable l

Wrap System material.

In addition, the integrity of the wrap system is not affected when the preshaped sections are cut to fit (1ush with a concrete wall and the joints are sealed with i

l Thermo-lag Subliming trowel grade material.

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Trojan Nuclear Plant Document Control Desk Docket 50-344 August 12, 1988 License NPF-1 Page 1 of 8 d-FP-/.3.3 PAGE 1 OF 3

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/7297 /

FIRE HAZARDS ANALYSIS OF 9 3/4 INCH SILICONE FOAM PENETRATION SEALS TROJAN NUCLEAR PLANT By Date I'N'h7 Chk By 2 Date l'M O GENERAL This is an in-depth evaluation of the use of certain existing 9-3/4 inch thick silicone foam seals for protection of penetrations through 3-hour fire-rated barriers.

ANI has withdrawn thei r 3-hour fire-reting for 9-3/4 inch, Ocw Corning 3-6S48 RTV sili cone f oam seal s wi thout permenent damming.

Previous evaluations were provided in attached memorandums TEB-28-EDM and TEB-42-86M.

The June 1986 OA Audit performed by TERA reported, however, that these Justifications were not adequate.

The audit report recommended that PGE perform an engineering evaluation of each area where such penetration seals are present.

The NRC GENERIC LETTER 86-10 and its attached "Interpretations" document allow evaluations which consider the effectiveness of the overall barrier where cortions of the fire area boundary do not totally conf orm to a 3-hr fire-rated configuration.

In compliance with this requirement the evaluations perf ormed herein will be retained and will be available for future NRC audits.

SCOPE

'A single evaluation is prepered to justify fire protection equivalent to a 3-hr rating for all of the small cable, conduit, pipe or instrument tube penetrations sealed with the 9-3/4 inch seals.

Separate fire ha:ards evaluations are, however, prepared for each large cable tray penetration or each group of cable tray penetrations in one fire barrier wall.

Evaluations f or cable tray penetrations through fire barrier floors are not required because these seals have permanent damming in place on the underside, and their ANI 3-hour fire-reting is retained.

Each evaluation determines if the existing protection is adequate or if upgrading of the seal (s) is required.

The following criteria is considered for each of these evaluations

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Trojan Nuclear Plant Document Control Desk Docket 50-344 August 12, 1988 License NPF-1 Page 2 of 8 PAGE 2 OF 3 n

CRITERION 1 Evaluate any potential, detrimental effects on the ability of the seal to maintain its integrity during a fire due to the configuration and size of the penetration seal.

CRITERION 2 Evaluate any potential, detrimental effects on the ability of the seal to maintain i ts integrity during a fire due to the configuration of the penetrating items (such as trays v,hich may not be supported close to the seal on both sides).

CRITERION 3 Compare the in place fire ha:ards with the fire endurance of the seal (s). Consider the amount of in place combustibles together with anticipated maximum transient combustibles and the contindity of combustibles to deveIop fire scenarios and to approximate fire severities.

Where the approximate fire hazard can be shown to be less severe than one half of the ANI tested exposure of about 2-1/2 hours, this can be used as justification to show the seals provide adequate fire protection.

The estimated fire severity for each location, as determined by this analysis, is based on data given in Chapter 8, Section 6 of the Fourteenth Edition of NFPA's "Fire Protection Handbook".

The loading (in BTU's/sq f t) i s di vi ded by 80,000 DTUs/sq f t/hr to obtain the approximate fire severity.

It i s r ecognized that, because of the different types and various arrangements of combustibles, thi s method does not yield fire severities which are directly comparable to tested fire endurances.

l However, use of this method as a means to compare the l

approximate fire severity to ons half of the tested fire endurance is considered reasonable.

CRITERION 4 Evaluate the ef f ects provided by any suppression and I

detection systems on one or both sides of the seal (s) in f

question.

CRI1ERION S l

Determine if the seal (s) are needed to provide pr otection of redundant safe shutdown equipment and/or cables.

If

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not, then a 3 hour3.472222e-5 days <br />8.333333e-4 hours <br />4.960317e-6 weeks <br />1.1415e-6 months <br /> rating is not required by Appendin R, i

and the seal may be judged to provide adequate protection.

Trojan Nuclear Plant Document Control Dask Docket 50-344 August 12, 1988 License NPF-1 Page 3 of 8 PAGE 3 OF 3

.s CRITERION 6 Where redundant safe shutdown equipment does exist on both sides of the seal, document the distances and intervening combustibles which exist between redur.iant safe shutdown equipment.

Determine if the existing configuration, together wi th the existing seals, provides protection from propagation of fire equivalent to that which would be provided by a 3 hour3.472222e-5 days <br />8.333333e-4 hours <br />4.960317e-6 weeks <br />1.1415e-6 months <br /> rated seal.

JUSTIFICATIONS Where justifications are documented f or continued rel:ance on tne 9-3/4 inch thick seals, they are much more detailed than were the previous evsluati ons.

Tne primary reason for the need for these evaluations is because fire test reports for these configurations were found to be inadequate.

For this reason, the determinations that these seals retain the ability to provide a certain degree of protection from propagation of a fire through the barrier are often based on judgements which are of necessity not completely backed up by hard test data.

The bases f or these determinations are theref ore reviewed by a qualified fare protectinn engineer; however, in the absence of formal acceptance, any of the judgements which are not backed I

up by firm test date will be subject to questioning by any

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future reviewer.

CONCLUSIONS One evaluation for 260 small silicone foam penetration seals is performed and eleven (11) evaluations of large cable tray per.atrat. ions at specific locations are documented.

For more detailed evaluation, see the specific fire ha:ard analysis applicable to the sehl in question.

The evaluations are all performed in accordance with the NRC guidance provided in Generic Letter 96-10 and demonstrate compliance with Appendix R Section III.G requirements for firei protection of safe shutdown capability.

Upgrading of any of the penetration seals is not being recommended because the upgraded seals would not significantly enhance fire protection of the safe shutdown capability.

Trojan Nuclear Plant Document Control Desk Docket 50-344 August 12, 1988 License NPF-1 Page 4 of 8 i

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Trojan Nuclear Plant Document Control Desk Docket 50-344 August 12, 1988 License NPF-1 Page 5 of 8 6 F/'-/.3. 3

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PAGE 1 OF 4

/ T297 7 FIRE HAZARDS ANALYSIS OF PENETRATIONS IN C7/A4 BOUNDARY BY

_ Date b/9-87 Chk By Date J -2.0-87 Four (4) large silicone f oam penetration seals of various sizes exist in the fire wall boundaries separating Fire Area C7 from Fire Area A4 The seal s are in a 2 f t.- 4 in. thick masonry wall fire barrier separating the Control Building 77 ft. Cable Spreading Room (Fire Area C7) from the 77 ft. Auxiliary Building Corridor (Fire Area A4).

These seals were installed by BISCO during the 1979 upgrading of fire-rated penetration seals.

The f ollowing evaluations are made in accordance with the referenced criterions in the general scope.

CRITERION 1 The silicone f oam seals range in size f rom about 5 square feet to about 77 square feet.

The largest undivided surface area of ar.y of the seal s is about 18.8 square feet.

This is less then the maximum area of 19.4 square feet approved by ANI for a vertical 9-3/4 inch seal in their letter to BISCO dated June 8, 1979, but is more than the actual tested area from Test Report 1064-10 of 10.4 square feet.

The larger area would be expected to have some detrimental effect on the ability of the seal to witnstand the hose stream test, but wc. tid not be expected to have much of an effect on a failure due to burn-thru such as that which was experienced at about 2-1/2 hours in the recent ANI test on a hori: ental 9 inch seal.

The actual effect of the large undivided seal area cannot be accurately quantified; however, since the seals are at least 3/4 inch thicker than the ANI tested seal and are in the vertical position rather than the hori: ental position, it in judged that the seals will provide about as much protection as the seal tested by ANI.

The seals are judged to provide fire protection approximately equivalent to 2-1/2 ho,urs of the standard fire curve.

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4 Trojen Nuclear Plant Ncument Control Desk Docket 50-344 August 12, 1988 License NPF-1 Page 6 of 8 PAGE 2 OF 4 i

CRITERION 2 The seals generally have tray supports at or near (within 1 ft.- 5 in.) the wall on one side of the seal.

This conforms closel y wi th tested configurations.

It is, therefore, judged that potential sagging of the trays would not have a detrimental effect on the fire endurance of these seals.

CRITERION 3 The in-situ combustible loading in the Auxiliary Building Corridor (Fire Area A4) next to Fire Area C7 has been determined to be approximately equivalent to 15 minutes of the standard fire curve.

The in-situ combustible loading in the Cable Spreading Room (Fire Area C7) has been determined to be approximately equivalent to i hour and 10 minutes.

An addi ti onal transi ent combustible loading might occur at some tic.e in the Auxiliary Building side of the barrier; however, the total combustible loading would be expected to remain bel ow an approximate, equivalsnt fire severity of less than 1/2 of the ANI tested exposure of 2-1/2 hours.

For this condition, the seal will provide adequate protection against fire propagation across the barrier.

k CRITERION 4 Fire protection f or the Auxiliary Building 77 f t.

elevation (Fire Area A4) is provided by an early warning fire detection system.

The corridor and valve galleries (common ceiling) arc provided with ioni:ation type smoke detectors that will detect invisible and visible particles (aerosols) of combustion.

In the unlikely event or an incipient type fire, the smoke detection will function, followed by transmission of a local fire alarm and alarm in the Control Room.

In addition to the smoke detection system, manual hose stations and portable fire extinguishers are also l

provided.

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J Trojan Nuclear Plant Document Control Desk Docket 50-344 August 12, 1988 License NPE-1 Page 7 of 8 FASE 3 OF 4 Active fire protection for the Control Building 77 ft.

elevation, Cable Spreading Room (Fire Area C7) is provided by an early warning fire detection system and deluge sprinkler systems.

Ionization type smoke detectors are located at the ceiling to detect invisible and visible particles (aerosols) of combustion.

In the unlikely event of a fire in the area, the smoke detection will function, f ollowed by trantmission of a local fire alarm and alarm in the Control Room.

Besides the fire detection system, the Cable Spreading Room has three (3) deluge sprinkler systems.

Each system protects about 1/3 of the ares in the Cabl e Spreading room.

Automatic actuation of each system is by a linear thermal detector (thermostatic cable) placed in or near cable trays.

The three systems are deluge systtms 20, 21 and 22.

The minimum design density is 0.15 GPM/5.F.

With two (2) systems f l owing simul taneousl y.

In additiol to the fire detection and f ire suppressi on systems, manual nose stations and portable fire extinguishers are also provided.

CRITERION 5 The attached electrical evaluation snows that the barrier in which these seals are installed is needed for separation of safe shutdown capability.

CRITERION 6 Although the evaluations of the seals in CRITERIONS 1 through 4 above show that any fire on one side of the barrier would be stopped i.t the barrier, the electrical branch has performed an attached evaluation of the consequences of a fire starting on either side and propagating through the barrier to the other side.

As shown, propagation of a fire through this boundary is not acceptable in order to comply with the intent of Appendix R section III.G.

Trojan Nuclear Plant Document Control Desk Docket 50-344 August 12, 1988 License NPF-1 Page 8 of 8 PAGE 4 OF 4 CONCLUSIONS The evaluations aoove are perf ormed in accordance with the NRC guidance provided in Generic Letter 86-10 to demonstrate compliance with the Appendix R section III. G requirements for fire protection of safe shutdown capability.

The evaluations contained in Criterions i through 3 show that the fire protection p,rovided by the C7/A4 fire wall boundary (including the evaluated seals) would prevent propagation across the boundary of a fire which consumes in-situ combustibles together with significant transient combustibles.

The wall alone is shown to provide protection equivalent to 2-1/2 hour protection which is more than double the fire severity which could be generated by consuming in-situ and expected transient combustibles.

This passive protection cannot be said to provide equivalent to 3 hour3.472222e-5 days <br />8.333333e-4 hours <br />4.960317e-6 weeks <br />1.1415e-6 months <br /> protection; however, the barrier, together with eni sting fire protect i on as shown in Criterion 4, would provide t he equi val ent to 3 hour3.472222e-5 days <br />8.333333e-4 hours <br />4.960317e-6 weeks <br />1.1415e-6 months <br /> protection.

Thi s eval uati on cl earl y shows th 't the existing fire protection (mainly automatic early warning fire detection in both areas, three deluge sprinkler systems in the Cable Spreading Room and the existing fire barrier between the fire areas) can provide adequate fire protection of the safe shutdown capability.

I Upgrading of the penetration seals in this wall is not being s

recommended oecause the upgraded seals would not significantly enhance fire protection of the safe shutdown capability.

Trojan Nuclear Plant Document Control Desk Docket 50-344 August 12 1988 License NPF-1 Page 1 of 10 1

FILE C-FP-1.2 e

PAGE 1 of 4 PENETRATION SEAL RECORDS By

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Date M7I/8% Chk By Date 3!?-9 #[

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I GENERAL The purpose of this evaluation is to describe the records which demonstrate the use of appropriate details and installation methods for fire-rated penetration seals.

The file contains information on the existing penetration sealc including historical information of seal installation and upgrading.

Accreditation records for recent BISCO penetration seals used in the plant are included.

The majority of approved details for each type of seal can be found on drawing C-7144.

Report No. FP-903 is a computerized list of penetration seals.

The report contains information on the seal number, seal type, seal location, seal design requirements, type of penetrating object and inspection requirements.

The report is used to generate a penetration inspection schedule for the 18 month inspection of seals in fire area boundaries protecting safety-rnlated systems.

Two other Civil fire protection evaluations contain additional information on penetration seals.

File C-FP-1.1 contains applicable fire tests reports for penetration seals.

Most penetration seals used at Trojan are 3-hour fire-rated.

File C-FP-1.3.3 contains detailed fire hazards analyses for penetration seals with lf/s than a 3-hour fire-rating.

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i Trojan Nuclear Plant Document Control Desk Dochet 50-344 August 12, 1988 License NPF-1

? age 2 of 10

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FILE C-FP-1.2 I

PAGE 2 of 4 Ouality Control (OC) Records Plant engineering maintains a file containing copies of most QC records pertaining to penetration seals.

This file makes it easier to demonstrate the proper installation of the seals, but it is not intended to contain all QC records for penetration seals.

Since a fire protection QA program was not required nor established until after Appendix A to Branch Technical Position (BTP) APCSB 9.5-1 was issued in 1976, no QC records are available for the seals installed during the original construction of the plant.

QC records for the 1979 and 1980 upgrading are located in the contract TF-004 file.

The QC records for new seals or upgraded seals installed by PGE are located in the plant's copy of the as-built package for the applicable modification.

IyPES OF SEALS The following types of fire-rated. seals are used in fire barriers at Trojan:

1.

BISCO four-part SF-20 silicone RTV foam or Dow Corning 3-6548 silicone RTV foam.

2.

BISCO SE-FOAM silicone RTV foam.

3.

Cellular concrete 4.

Portland cement grout.

5.

A combination of cellular concrete and silicone RTV foam.

6.

BISCO flexible boot seals.

7.

Seals in plaster wall barrier consisting of fireproof structural insulation board (Marinite) and ceramic fiber covered with a layer of Flamastic.

8.

Ceramic fiber and caulk.

9.

O-Z Gedney type fire seals.

10.

Nelson Electric's Multi-cable Transit seals.

11.

3M Putty.

12.

BISCO SF-60 silicone elastomer.

13.

CAFCO Deck-Shield C/F cementitious type fireproof coating.

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Trojan Nuclear Plant Document Control Desk Docket 50-344 August 12, 1988 License NPF-1 Page 3 of 10 I

FILE C-FP-1. 2 PAGE 3 of 4 HISTORY Original installations Many of the penetration seals which were installed during original construction have been upgraded or are in barriers which are not utilized as fire barriers.

However, some of the original penetration seals are still used in fire-rated barriers.

Some of the cable penetrations in the Control Room floor were sealed with cellular concrete.

These are still used as fire-rated seals and are sometimes used in combination with silicone foam added during upgrading of ceals.

Foam seals installed during original construction consisted of BISCO four-part SF-20 silicone RTV foam.

Many of these seals (including all large cable tray penetrations in fire barrier.s) were replaced or upgraded with Dow Corning 3-6548 two-part silicone RTV foam.

Details 6, 7 and 10 on drawing C-7144, which contain references to DC 3 6548, in some cases, still contain the original BISCO four-part SF-20 silicone RTV foam.

See item 5 of C-FP-1.1 for documentation of equivalency.

Grout seals, other than in the control room floor, which were installed during original construction consisted of portland cement grout or non-shrink portland cement grout.

These are still used as fire-rated barriers.

Upgrading in 1979 and 1980 and Modifications thru 1985 All of the large cable tray penetrations through 3-hour fire barriers (as defined in 1979 and many of the other seals in 3-hour fire barriers were) upgraded by BISCO in 1979 and 1980 under contract TF-004.

File C-FP-1.3.3 contains detailed fire hazards analyses for many of these penetration seals which were later determined to have less than a 3-hour fire-rating.

Details 1, 2,

3, 4,

6, 7,

10, 11, 16 and 18 on drawing C-7144 were used for this upgrading and in later modifications until 1986, however, these details are no longer being installed.

l BISCO procedures used for silicone foam seals installed by BISCO during the 1979 and 1980 upgrading (Contract TF-004) t and by PGE between 1980 and 1986 are contained in Vender Technical Manual No. NQ-00505-1.

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Trojan Nuclear Plant Document Control Desk I

Dochet 50-344 August 12, 1988 License NPF-1 Page 4 of 10 I

FILE C-FP-1. 2 PAGE 4 of 4 Upgrading in 1986 - 1987 and Modifications to Present Many penetration seals were installed in 1986 and 1987 in fire area boundaries creating new fire areas to address Appendix R requirements.

Installers, engineers and inspectors were trained to install BISCO penetration seals.

New seal details were added utilizing the BISCO SE-FOAM, and a formalized accreditation program was established for all BISCO penetration seals.

Documentation of training is located in File No. 86-15 in the QA vault at Trojan, under the name of each individual who took the training.

BISCO details and procedures used for silicone foam seals and flexible boot seals installed in 1986 or after can be found under Vender Technical Manual No. NQ-00505-1.

PGE Penetration Seal Fact sheets and BISCO Penetration Seal Approval sheets are in books 2 through 4 of this file.

A letter has been sent to American Nuclear Insurers requesting their concurrence with the use of several penetration seals which do not exactly conform with the BISCO details.

In all cases, these seals have been judged by PGE to be 3-hour fire-rated seals.

Trojan Nuclear Plant

' Document Control Desk Docket 50-344

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(BISCO) accredits that the above selected penetration seal design, when properly installed, utilizing the information and procediares that are referenced on this form will satisfy che criteria that is referenced on the corresponding PSFS.

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Trojan Nuclear Plant Document Control Desit Docket 30-344 August 12, 1988 License NPF-1 Page 1 of 33 CIVIL FIRE PROTECTION DOCUMENTATION COVEE SHEET TROJAN NUCLEAR PLANT FILE NO. C-FP-1.3.1 TITLE FIRE AREA BOUNRARIES ENGINEER M.

Gandert/ F.

Stumno CHECKED BY F.

Stumoc/ M.

Gandert DESCRIPTION This document provides detdiled evaluations for individual portions of fire area boundaries.

More description is provided in the following evaluation.

BASIP OR REFERENCES 1

National Fire Protection Association (NFPA) "Fire Protection Handbook" 14th ed.

2 Uniform Building Code (UBC) 3 Underwriters Laboratories Inc. (UL) "Fire Resistance Directory" dated January 1985 IRev l Description lBy IDatal Ckd!Datel App lDatel n

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Trojan Nuclear Plant Documsnt Control Desk Docket 50-344 Aug'is t 12, 1988 License NPF-1 Attaciunent 6 Page 2 of 3' PAGE 1 of 20 i

C-FP-1.3.1 FlLE C-FP-1.3.1 CIVIL EVALUATION OF PIRE AREA BOUNDARIES TROJAN NUCLEAR PLANT

• • • • • • • • • • • • • • • • • • • • • • • • • • • • • • • • • • • e****************************

By a

Date Yll/68 Chk By Dute7/fA/8[

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//

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GENERAL This is an in-depth evaluation of the fire protection provided by all Fir. Area boundaries.

The justification for adequate fire protet. ion provided by fire srea boundaries was init'. ally based on the general descriptions.'n section 2 of the Volume II of PGE-1012.

The June 1986 QA Audit performed bf TERA recommended, however, that fire area boundary evaluations be rewritten as fire hazard analyses with sufficient detail to accurately descru;e the fire area boundaries, com'm'.stible loadings, separation of redundant equipment, suppxession and detection iquipment in tha areas and any other pertinent mitigating factors.

This evaluation has been prepared and/or reviewed by an engineer, Fred Stumpp, who has over 16 years of experience, of which over 9 years has been in responsible charge of fire protect;on engineering work, and who meets the personnsi qualification requirements specified in paragraph C.1.a. (5),

Revision 2 of Branch Technical Position (BTP) CMEB 9.5-1.

SGQ2E Farfocm and document a detailed evaluation of the fire protection provided by the fira area boundaries.

The evaluation consists of a systematic review cf each individual portion o' fire area boundaries.

To be included is documentation or a reference to documentation which justifies the fire-rating of the barrier.

A detailed fire hazards analysis ann justification is also included or referenced for all barriers wh ?h are not shown to have a 3-hour fire-rating or which cannet rk 7wn to be equivalent to a 3-hour fire-rated barr' l

l i

Trojan Nuclear Plant Document Control Desk mchet 50-344 August 12, 1988 L.icense NPF-1 Page 3 of 33 PAGE 2 of 20 C-FP-1.3.1 There are various civil evaluation files which are referenced in this evaluation.

The main file which contains the test documentation is File C-FP-1.1.

File C-FP-1.1 contains civil l

evaluations of test documentation, qualification records, l

listing documentation, and various vendor brochures which are provided to document the fire rating of the fire barriers, fire-rated penetration seals, fireproof coatings, and fire-rated cable wraps.

The index in File C-FP-1.0 contains a listing by file number and title of all the other civil evaluations which are referenced in this evaluation.

This evaluation does not evaluate certain other features of the fire area boundary, i.e.,

fire doors and fire-rated penetration seals, that are an important part of the fire area boundary.

These items are evaluated in civil evaluations C-FP-1.3.3 and C-FP-1.3.10.

The following criteria is considered in this evaluation:

CRITERION 1 l

Prepara a detailed table listing the results of the review of all fire area boundaries.

Provide approprinte descriptions and references to applicable, general and/or specific evaluatione.

CRITERION 2 Prepara evalu ~. ions to justify each type of fire-rated barrier.

Pretare evaluations for each type of barrier which has been determined to provide protection equivalent to a rated barrier.

If this evaluation is contained in another evaluation package, it is to be referenced in the table described in CRITERION 1.

CRITERION 3 Where a fire hazards analysis is needed, compare the in-place fire hazards with a conservative estimate of the fire tol encs of the barrier.

Consider the amount of in-place combustibles together with anticipated maximum transient combustibics and tha continuity of combustibles to develop fira scenarios and to approximate fire severities.

If the approximate fire hazard can be shown to bs less severe than one half of the conservative estimate of the fire tolerance, this can be used as justification to show that the barrier provides adequate fire protection.

-_____________.----____________J

Trojan Nucicac Plant Document Control Desh Docket 50-344 August 12 1988 License NPF-1 Page 4 of 33 PAGE 3 of 20 C-FP-1.3.1 The estimated fire coverity for each location, as 3

determined by this analysis, is based on data given in Chapter 8, Section 6 of the Fourteenth Edition of NFPA's "Fire Protection Handbook".

It is recognized that, because of the different types and various arrangements of combustibles, this method does not yield fire severities which are directly comparable to tested fire tolerances.

However, use of this method as a means to compare the approximate fire severity to one half of a conservative estimate of the fire tolerance is considered reasonable.

CRITERION 4 Where a fire hazards analysis is needed, evaluate the effects of any suppression and detection systems provided on one or both sides of the barrier.

CRITERION 5 Where a fire hazards analysis is needed, determine-if the barrier is needed to provide protection ot' redundant safe shutdown equipment and/or cables.

If not, then a 3-hour rating is not required by Appendix R, and the barrier may be judged to provide adequate protection.

i CRITERION 6 i

Where a fire hszards analysis is needed, if redundant safe shutdown equipment does exist on both sides of the barrier, document the distances and latervening combustibles which exist between redundant safe shutdown equipment.

Determine if the configuration of the existing t

barrier provides protection from propagation of fire equ ? valent to that which would be provided by a 3-hour i

re' d barrier.

FIRE MAZ&BDS ANALYSIS AMD EVALUATION t

CRITERION 1

[

A detailed tabl3 (sheets 1 through 205) listing the review of individual elements for all fire area boundaries is attached to this evaluation.

The table is arranged by floor elevation, by fire area and by barrier loce, tion.

The listing of barriers is prepared in a continuous, systematic manner in order to avoid missing any fire t

barriers.

Trojan Nuclear Plant Document Control Desk Docket 50-344 August 12, 1988 License NPF-1 Page 5 of 33 PAGE 4 of 20 C-FP-1.3.1 The items in the table consist of the following:

IDENTIFICATION NUMBER - a simple number which allows cross-refera,cing to attached sketches. The sketches are generally mark-ups of portions of drawings C-2100 thru C-2104 showing either floors, walls or ceilings.

FLOOR ELEVATION - as shown en fire protection drawings C-2100 thru C-2104.

FIRE AREA (NEAR SIDE) - the fire area for which the barriers are being listed.

STAIR - area is within a stairway or elevator enclosure.

FIRE AREA (FAR SIDE) - fire area on opposite side of the barrier from the side for which barriers are being listed.

NONE - opposite side of slab or wall against the ground.

STAIR - opposite side of barrier is a stairway or elevator enclosure.

BARRIER IrOCATION - as seen from the listed fire area side FLR - floor slab EW - et.st wall SW - south wall WW - west wall NW - north wall CLG - ceiling slab ROCM NUMBER - room number or desctiption of area on the listed fire area side of the barrier.

f

Trojan lluclear Plant Eccument Control Desk Docket 50-344 August 12 1988 License NPF-1 Page 6 of 33 PAGE 5 of 20 C-FP-1.3.1 BIRRIER DESCRIPTION - the basic building material is described and the thickness of the barrier is given in inches.

The 8-inch masonry walls are actually 7-5/8-inches thick and the 14-inch masonry walls are actually 13-5/8-inches thick.

MAS. - represents masonry walls.

CONC. - represents reinforced concrete barriers.

CONC. AGAINST SOIL - represents A concrete barrier against existing soil PLASTER - represents plaster walls.

GYPSUM ~ represents gypsum board walls.

BARRIER FIRE-RATING - the fire-rating of the barrier detail in hours as listed by a nationally recognized laboratory's fire resistance directory or as listed in the Unifota Building Code table for fire-resistive periods.

Documentation regarding test reports, qualification records, and testad configurations may be found in civil evaluation File C-FP-1.1 3-HR hour fire-rated configuration EVALUATED EQUIVALENT RATING - an equivalent rating determined by a documented engineering evaluation which demonstrates that the existing configuration is capable of withstanding an equivalent ASTM E-119 fire exposure without structural failure of the barrier.

This is used where the barrier is not rated or where the fino protection capacity of the bartier can be shown to se greater than the actual rating.

APPX. R SAFE SHUTDOWN SEPARATION REQUIRID - is barrier needed for separation of safe shutdown equipment?

YES - safe shutdown equipment or cables may exist on both sides of barrier.

NO - scfe shutdown equipment or cables does not exist on both sides of the barrier.

ACCESS - barrier needed to provide protection of the access (usually stairways) to implement safe shutdown or post fire procedures.

Trojan Nuclear Plant Document Control Dask tecket 50-344 Au;ust 12, 1988 License NPF-1 Page 7 of 33 i

PAGE 6 of 20 l

C-FP-1.3.1 TRANS. COMB. - barrier is needed to provide protection of a fire area containing safe shutdown systems from a potentihl fire hazard in an adjacent area which may contain significant transient or insitu combustibles.

REFERENCE TO SPECIFIC EVALUATIONS - reference to where the general and specific evaluations and justifications can be found.

E# - references a specific evaluation or justification as decumented in CRITERION 2 in this evaluation.

TC-### - references the calculation which provides verification of the adequacy of the remaining structural capacity upon exposure to a fire.

C-FP-#.# - references a separate fire protection evaluation which is contained in the central file for fire protection documentation supporting our Appendix R Review and PGE-1012.

CRITERION 2 TdRU 6 Evaluations of fire barriers are presented below.

Some are general evaluations for numorous fire barriers in the plant, and some are specific to certain barriers.

The reference number for each evaluation is the number shown in the last item of the attached table of fire area boundaries.

E1 - BARRIERS AGAINST SOIL Concrete slabs and walls against existing soil are obviously not needed as fire rated barriers.

E2 - MASONRY WALLS Masonry walls used as fire barriers in the plant consist of single wythe walls, double wythe walls and compor.ite walls.

Single wythe walls are nomirv71y 8-inches and 12-inches thick with actual th!

1 esses of 7-5/8-incht, and 11-5/8-inches.

Double t

.2 walls are a minimum of 13-5/8-inches and composite walls are at least 20-inches thick with a center core of concrete between two wythes.

The masonry units consist of 2 cells with 1-1/2-inch thick face shells and 1-1/2-inch thick webs.

By design alA cells are filled with concrete.

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Trojan Nuclear Plant Document Control Desk Docket 50-344 August 12, 1988 License NPF-1 Pege 8 of 33 PAGE 7 of 20 i

C-FP-1.3.1 For fire protection purposes, since cells are filled, a nominal 8-inch thick single wythe wall can be considered equivalent to a 7-5/8-inch thick concrete wall.

This exceeds the UBC Table 43-B solid concrete thickness of 6-inches for a 3-hour rating.

Even where cells may not be filled, the concrete block can be considered equivalent to U. L. Design No. U907 for a 3-hour rating.

All other masonry walls provide more protection than the 8-inch single wythe walls; therefore, all masonry walls used as fire barriers l

are rated for 3-hours.

E3 - 6 INCH THICK CONCRETE WALLS (NEW)

Several 6-inch minimum thickness concrete walls were added by RDC 84-082 in order to upgrade fire barriers in the Auxiliary and I'uel Buildir.gs.

Drawings A-4001 and A-4002 WLich show typical details are attached.

Both the reinforcement and the thickness of-these walls meet the requirements for a 3-hour fire-rating as listed in U.B.C. Table No. 43-B for grade A concrete.

E4 FLOOR SLABS IN THE AUXILIARY AND FUEL BUILDINGS The concrete floor slabs used as fire area boundaries in the Auxiliary and Fuel Buildings were originally designed without any requirements to function as fire barriers.

Many of these slabs are supported by exposed or partially embedded structural steel members.

The configuration of these barriers is, therefore, generally not equivalent to a tested configuration.

Justification for considering these barriers equivalent to a rated barrier can be found in the civil evaluation C-FP-1.3.2, which justifies the structural steel supporting fire barriers in the Auxiliary and Fuel Buildings.

The STRUCTURAL STEEL ANALYSES show these barriers to be capable of maintaining structural integrity upon exposure to a 3-hour fire.

The barriers are therefore considered equivalent to a 3-hour fire-rated barrier.

Since those barriers are shown to be equivalent to or better than a rated 3-hour barrier, a fire hazards analysis is not performed for these barriers.

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Trojan Nuclear Plant Document Control Desh Docket 50-344 August 12, 1988 License NPF-1 Page 9 of 33 I

PAGE 8 of 20 C-FP-1.3.1 Eb - AUXILIARY BUILDING 6 INCH CONCRETE SLABS I

Several 6-inch thick concrete slabs are used as fire i

barriers in the Auxiliary and Fuel Buildings.

The slabs covered by this evaluation are supported by masonry walls or by fireproofed structural steel.

Both the reinforcement and the thickness of these slabr meet the requirements for a 3-hour firs-rating as listed in U.B.C. Table No. 43-C for normal weight concrete.

E6 - AUXILIARY BUILDING HOISTWAY COVER The hoistway cover at elevation 45-ft. consists of 5-inch thick lightweight concrete slabs used as a portion of the fire barrier between Fire Areas Al and A4.

Both the reinforcement and the thickness of these slabs meet the requirements for a 3-hour fire-rating as listed in U.B.C. Table No. 43-C for light weight concrete. See civil evalua' ion File C-FP-1.1, Item 43 for further discussion on the design of the 3-hour fire-rated hoistway cover.

E7 - CONCRETE ACCESS PLUGS Several removable concrete access plugs are in place in fire-rated slabs between fire areas.

The plugs are simply thick, precast slabs designed to cover the opening for access to equipment at floors below.

The plugs rest on a ledge on all sides of the access opening; therefore, gaps at the perimeter are not a problem.

Both the reinforcement and the thickness of these slabs meet the requirements for a 3-hour fire-rating as listed in U.B.C. Table No. 43-C for normal weight concrete.

If these plugs are removed, the barrier will be considered degraded.

Since these barriers are shown to be equivalent to a rated 3-hour barrier, a firre hazards analysis is not performed for these barriers.

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Trojan Nuc1 car Plant Document Control Desk Docket 50-366 August 12, 1988 License NPF-1 Page 10 of 33

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PAGE 9 of 20 C-FP-1.3.1 E8 - EXTERIOR CONCRETE AND MASONRY WALLS Concrete and masonry walls which furm the exterior I

boundaries of a fire area are of the same i

construction as described in evaluation E2 above which is, therefore, equivalent to a 3-hour fire-rating.

These walls do not provide fire separation of redundant trains of safe shutdown systems and are not defined as providing protection of safety-related equipment. Exterior walls not originally designated as fire-rated were not upgraded to a rated barrier status.

This means that penetration of these walls are not necessarily sealed with a rated seal and doors are not necessarily fire-rated; i.e.,

unrated doors to the exterior in stairways 3, 12, 20, and 36; various exterior doors in the Intake Structure, Turbine, Fuel, and Auxiliary Buildings; and the electrical penetration area.

Tnese walls provide some protection from any fire which might occur in the yard adjacent to the fire area; however, specific fire hazards analyses have not been performed.

The protection provided by these walls will not be degraded without adequate j

justification.

Some exterior masonry walls are covered by evaluation E2 instead of this evaluation because they are 3-hour fire-rated.

The Control Building exterior walls were I

originally designated as 3-hour fire-rated and are maintained as such.

Masonry walls adjacent to Fire Area El are evaluated as interior walls.

E9 - MASONRY WALLS FORMING STAIRWAY BOUNDARIES Masonry walls which form the boundaries of a stairway I

or elevator enclosure are shown as 2-hour fire-rated barriers on Drawings A-115 through A-118, but they are of the same construction as described in evaluation E2 above which is, therefore, equivalent to a 3-hour fire-rating.

These walls do not provide fire separation of redundant trains of safe shutdown systems; however, in the control, Auxiliary and Fuel Buildings, they are defined as necessary for protection of safety-related equipment because of their important function of providing access for fire fighting and for safe shutdown operation activities.

These walls meet all the requirements for a 3-hour fire-rating except that fire doors are original doors rated for 1-1/2 hours.

vrojjan IMichear Vhant Leocument Control Desk j

Docket 50-344 August 12, 1988 License NPF-1 Page 11 of 33 l

PAGE 10 of 20 i

C-FP-1.3.1 i

Since these barriers are shown to be 3-hour rated, and 1-1/2 hour doors were accepted as part of our original PGE-1012 submittal, a fire hazards analysis i

is not performed for these barriers, j

E10 - PRECAST CONCRETE EXTERIOR BOUNDARIES Precast concrete panels walls which form the exterior boundaries of a fire area are of 6-inch thick reinforced concrete construction.

The joints between panels generally are not sealed with a rated material and doors in the panels may not be fire-rated.

Therefore, these boundaries are not considered as fire-rated.

The precast walls do not provide fire separation of redundant trains of safe shutdown systems and are not defined as providing protection of safety-related equipment.

These walls provide some protection from any fire which might occur in the yard adjacent to the fire area; however, specific i

fire hazards analyses have not been performed.

The protection provided by these walls will not be degraded without adequate justification.

l Ell - OPEN AREA AT A1/A8 BOUNDARY The south and of the Containment piping penetration area in Fire Area A1, about 5 feet wide, from elevation 65-ft. to elevation 84-ft., is open to Fire Area A8 behind the spent fuel pool.

Fire Area A8 contains no safe shutdown systems and the portion of the area behind the spent fuel pool is a locked, unused space which is approximately 5 fest wide by 47 feet high by 50 feet long.

There are no combustibles in this portion of the area, and accumulation of transient combustibles is not likely.

Since there are no identified fire hazards and the boundary is not needed for separation of safe shutdown systems, a more detailed review of the situation is not needed.

E12 - KNOCKOUT PANELS l

Removable knockout panels, consisting of stacked precast concrete units, are provided for removal of i

major equipment and piping from pump rooms and pipeways during maintenance, ordinary fire doors are not used to protect these openings because the panels l

provide radiation shielding, missile protection, and in some cases, flood protection approximately equivalent to the adjacent walls.

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PAGE 11 of 20

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C-FP-1.3.1

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A typical knockout panel is comprised of 4-inch by 8-inch precast, reinforced concrete units which are placed in the opening so that the only continuous joints through the panels are at the top, bottom and sides.

The units are restrained from lateral P

movement by keeper plates attached to a 3/8-inch thick bent plate frame anchored to the masonry wall

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opening.

Unsealed gaps >1/8-inch are sealed with a fire-resistant sealant.

The minimum thickness of a panel is 12-inches, which is double that of concrete walls used for a 3-hour fire-rating.

h Since the structural integrity of the units during the fire exposure is not a concern, the panels are 5

judged to provide protection equivalent to a 3-hour fire-rated wall and certainly provide far more protection than would a standard 3-hour fire door in the opening.

Because the protection provided by these panels is shown to be equivalent to that provided by a 3-hoLr barrier, specific fire nazards analyses at each location is not performed.

When these knockout panels are removed, the barrier will be considerad as a degraded barrier until the panels are replaced and properly sealed.

E13 - EXTERIOR METAL SIDING WALLS

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Metal siding walls which form the exterior boundaries 1

of a fire area are non-firo-rated.

This does not include exterior metal siding walls which are used to enclose stairways.

These unrated metal siding walls do not provide fire separation of redundant trains of safe shutdown systems and are not defined as providing protection of safety-related equipment.

The metal siding walls provide some protection from any fire which might occur in the yard adjacent to the fire area; however, specific fire hazards analyses have not been performed.

The protection provided by these walls will not be degraded without adequate justification.

Metal siding walls adjacent to Fire Area El are not evaluated as exterior walls.

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Documsnt Control Deck Docket 50-344 August 12, 1988 License NPF-1 Page 13 of 33 PAGE 12 of 20 C-FP-1.3.1 2-HR FIREPROOFING OF STRUCTURAL STEEL E14 Where fireproofing of structural steel was provided during original construction, the fireproofing was generally 2-hour fire-rated.

This applies to structural steel in the Control Building, Diesel Generator structure, AFW Pump Enclosure and Lube Oil Storage Room.

The fireproofed steel contains unprotected attachments and small unprotected areas which were identified in nonconformance report NCR 84-26 and are addressed in section 2.3 of the Volume II of PGE-1012.

Thermal and structural analyses to justify the 2-hour rating of the existing configuration are provided in Appendix A to the Volume II of PGE-1012.

Fire hazards analyses contained in soction 2 of Volume II of PGE-1012 (and included as part of file C-FP-1.3.2) compare the in-place combustible loading to the protection provided by the 2-hour rated steel.

The thermal and structural analyses in Appendix A to Volume II of PGE-1012 show that the protection provided by the fully fireproofed condition for the 69 ft. slab in the Diesel Generator Structure is equivalent to 3-hour rated protection.

The upgrading per NCR 84-26 provides the fully fireproofed condition for the middle portion of the beams; therefore, this slab and rupporting beams provides 3-hour protection.

E15 - FCAM SEALS LESS THAN 3-HR RATED Barriers containing foam seals with less than a 3-hour fire-rating are evaluated in civil evaluation C-FP-1.3.3.

The equivalent fire-rating provided by the seal, together wi*ch other fire protection measures where applicable, was avaluated to vary from a minimum of 2-1/2-hour to a 3-hour rating.

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Trojan Nuclear Plant Document Control Desk Docket 50-344 August 12, 1988 License NPF-1 Page 14 of 33 PAGE 13 of 20 C-FP-1.3.1 J

E16 - RATED PROTECTION PROVIDED FOR FIRE IN AREA ABOVE Evaluations for floor slabs (supported by exposed structural steel) which form a fire area boundary protecting a safe shutdown area below from a non-safe shutdown area above are described in Appendix C to the Volume II of PGE-1012.

These slabs provide 3-hour rated protection of the safe shutdown area because the supporting steel is not exposed to high temperatures when the fire is located in the non-safe shutdown on the top side of the slab.

Because protection equvalent to 3-hours is provided for a fire above the slab, fire hazards analyses for specific locations are not needed.

E17 - BARRIERS WITH NON-RATED SEISMIC GAP SEALS 4

Barriers containing seismic gaps with no seal, seals 1

t which have no fire-rating,or seals that have less than 3-hour rating are evaluated in civil evaluation C-FP-1.3.9.

The seismic gaps at the Emergency Diesel Generator Structura and the Turbine Pedestal were identified by Nonconformance Report NCR 88-031.

These gaps are upgraded to a 3-hour fire-rated configuration.

E18 - METAL SIDING WALLS RATED FOR 1-HOUR These metal siding valls are H.H. Robertson 1-hour fire-rated metal siding walls, UL Design U617.

For more details see civil evaluation File C-FP-1.1, Item 40.

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[bcument Control Desk Docket 50-344 August 12 1908 License NPF-1 Page 15 of 33

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l PAGE 14 of 20 C-FP-1.3.1 l

E19 - UNRATED METAL SIDING WALLS AT ELEV 93-FT A6/El BOUNDARY l

A large portion of the Area A6/El boundary above elevation 93-ft (approximatcly 55 ft x 24 ft) is unrated metal siding.

Only Area El contains safe shutdown equipment (cables); therefore, A6/F.1 boundary is not needed to separate redundant safe shutdown equipment.

The safe shutdown cables in Area El are located under the elevation 92-ft 10-inch slab 4

at least 20 feet horizontally away from the metal siding A6/El boundary wall.

The only intervening i

i combustible located in the space between the wall and j

the safe shutdown cables is one 18"-wide cable tray.

This tray is 15 feet below the metal wall and is 4

covered with a metal cover in the area where it could i

be exposed to burning debris from Area A6; therefore, propagation of a fire from Area A6 to Area El safe shutdown cables is not credible.

For the above reasons, it is judged that the A6/El metal siding i

boundary provides adequate fire protection for the safe shutdown cables in Area El.

E20 - CONCRETE WALL AT T1/El BOUNDARY An 18-inch thick concrete wall separates Area El from 4

Area T1 between columns 65 and 74, with the top of concrete wall at elevation 84-ft 8-inch.

Except for some of the penetrations that are not sealed with 3-hour rated fire seals, the wall is a 3-hour rated a

fire barrier.

The unsealed main steam, feedwater, 1

and associated drain piping penetration openings are impractical to seal.

The combustible loading in Area El near these penetrations is insignificant, and there is a lack of a combustible continuity for i

propagation of fire from one area through these penetrations to the other area.

For the above l

reasons, it is judged that this concrete wall i

J separating Area El from Area T1 provides adequate fire separate protection to ensure safe shutdown of i

the plant.

E21 - UNSEALED PENETRATIONS AT AUX BLDG, ELEV 77-FT The wall between Pipeway 214 and the Domineralizar Compartments 215 that separates Fire Area Al from Fire Area A4 at elevatiors 77 has several unsealed J

penetrations.

Civil evaluation File C-FP-1,3.7 l

provides justification for these unsealed penetrations.

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Trojan Nuclear Plant Document Control Desk l

Docket 50-344 August 12. 1988 License NPF-1 Attachmer.t 6 Page 16 of 33 i

PAGE 15 of 20 C-FP-1.3.1 E22 - FILTER CELL CONCRETE PLUGS AT AUX BLDG ELEV 93-FT The filter cell concrete plugs are constructed as described in evaluation E7 and are considered 3-hour fire-rated, but the pluus muut be removed at times while the plant is still operating.

Justification for the plants continued operation while the plugs are removed is provided in civil evaluation File C-FP-1.3.8.

E23 - PLASTER WALL AT C2/C3 BOUNDARY A 3-hour fire-rated plaster wall separates Fire Area C2 from Fire Area C3, and all the penetrations are sealed with 3-hour fire-rated seals.

See civil evaluttions File C-FP-1.1, Items 9, 33, and 34; C-FP-1.3.4; and C-FP-1,3.5 for further details.

E24 - GYPSUM CORE PANELS (MEhALEDGE COREWALL) AT-C11/C12 DOUNDARY A 3-hour fire-rated gypsum core panel wall at elevation 105 is used to separate ? ire Area C11 from Fire Area C12.

For further details on the construction and rating of the wall, see civil evaluation Film C-FP-1.1, Item 27.

E25 - EXTERIOR PRECAST CONCRETE WALLS NEAR MAIN TRANSFORMER AREA The 6-inch thick precast concrete panel vall located at the vest wall of the Turbine Building betweer elevations 45-ft and 93-ft and columns 42 to 59 are 3-hour fire-rated, except for certain features that degrade the wall.

The f3re rating of the wall as-well-as the degrading features are discussed in detail in civil evaluation File C-FP-1.3.17.

E26 - NON-FIREPROOFED STRUCTUP.AL STEEL BEAMS 501 VRTING THE ELEVATION 69-PT SLAB IN THE TURBINE BLDG The elevation 69-ft slab located outside the switchgear room in the Turbine Building is a 8-inch thick concrete slab with the penetration openings sealed with 3-hour fire-rated seals.

The slag is not considered as a 3-hour fire barrier because the slab is supported by non-fireproofed structural steel be"as.

For a detailed discussion on the exposed t-

':tural steel beams, see civil evaluation File C-P-1.3.2.

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Trojan Nuclear Plant Emcument Control Desk Docket 50-344 August 12, 1988 License NPF-1 Page 17 of 33 PAGE 16 of 20 C-FP-1.3.1 E27 - FIRE AREA M6 UNRATED MANHO:.3 COVER The access opening from Fire Area T1 into the top of the manhole, Fire Area M6, is covered with an unrated, heavyweight cast-iron frame and cover.

TPere are vant holes in the cover.

A 6-inch high concrete curb is provided around the frame and cover, and the cover is fastened down with security bolts to prevent unauthorized access.

The curb is there to prevent pot?ntial spills of fuel oil and other combustit ' -

.tquids from entering the manhole.

Only Train A safe shutdown electrical cables are located in the manhole, Fire Area M6.

Other than the normal Train A and B Emergency Diesel Generator (EDG) air intakes, there are no other redundant safe shutdown equipment or electrical cables located in the N/S corridor of Fira Area T1, where the manhole access opening is located.

Alternate Train A EDG air intake is located in Fire Area T1 on the south side of the Train A EDG room far removed from the N/S l

corridor.

Permanent combustible loading in Fire Area T1 near the manhole is negligible, but there is a potential for transient combustibles being stored nearby for periods of time.

An automatic wet-pipe sprinkler system is provided for Fire Area T1 in the area adjacent to the manhole, and it provides additional protection for the manhole access opening.

It is judged that the cast-iron cover, concrete curb, and the automatic wet-pipe sprinkler system in Fire Area T1 provide adequate fire protection for the manhole, i

Fire Area M6, and the3e featuras are considerad adequate protection to prevent a fire in the N/S corridor from affectiny both trains of safe shutdown.

E28 - OPEN PIPE CHASE BETWEEli FIRE AREAS Al AND A2 An open RHR pipe chase 9xits between Fire Area Al and A2.

Justification for the open pipe chase is provided in civil evalcation C-FP-1.3.6 l

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Trojan Nuclear Plani.

Documsnt Control Dask Docket 50-344 August 12, 1988 License NPF-1 Page 18 of 33 PAGE 17 of 20 C-FP-1.3.1 E29 - CONTAINMENT AIR LOCK & HVAC OPENINGS A7/R1 The personnel Air lockr (elevation 58 ft. and 96 ft.)

are constructed of structural steel plate and contain a substantial door on each and of the air lock.

The doors are well supported and the air locks are embedded in the containment wall.

There are no gaps and no air transfer through the personnel air locks when the doors are closed.

The air locks are qualified for the integrated leak rate test pressure of 60 pai.

The combustible loading adjacent to each lock is low and the presance of significant transient combustibles during operation is unlikely.

In case of a fire in the vicinity of the personnel air locks, however, only one door of each lock could be affected.

The containment air purge supply and exhaust systems each have a penetration through the containment wall.

The penetrations are 54 inch diameter pipes and each have two containment isolation valves approximately 7 feet apart on either side of the containment wall.

These valves are ASME,Section II, Class 2, and by Technical Specification are not open unless the plant is s,but down.

There tre no combustibles between the valves, and the space between the valves would provide resistance to propagation of a fire.

This justification was originally included in Section 2.3.6 of Volume II of PGE-1012.

It is judged that the air locks and the HVAC containment penetrations will provide adequate protection from a fire which would be equivalent to that provided by a 3-hour fire-rated barrier.

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Trojan Nuclear Plant Docutant Control Dask tecket 50-344 August 12, 1988 License NPF-1 At tac knent 6 Page 19 of 3; PAGE 18 of 20 C-FP-1.3.1 E30 - CONTAINMENT EQUIPMENT HATCH A5/?1 The containment equipment hatch opening from the Fuel Building to the Containment is constructed of structural steel plate.

The cover is well supported and is secured to the containment wall.

The hatch cover and framing are qualified for the integrated leak rate test pressure of 60 psi.

There are no gaps and no air transfer through the hatchway when the cover is in place.

In addition, concrete shielding walls placed near the Fuel Building side of ths. steel cover and the lack of combustibles on the containment side of the plant during plant operation make a large exposure fire next to the cover very unlikely.

If, however, the hatch cover were exposed to a fire from either side, the steel would in any case retair sufficient strength for the cover and supporting frame to remain in place.

This justification was originally included in Section 2.3.1.5.2 of Volume II of PGE-1012.

It is judged that the equipment hatch will provide adequate protection from a firs which would be equivalent to that provided by a 3-hour fire-rated barrier.

E31 - HVAC OPENINGS THROUGH CONTROL BUILDING ROOF C13/Y1 The air supply and exhaust systems in Fire Area C13 utilize three concrete HVAC housings on the Control Building roof.

Each of these housings contain non-fire-rated openings.

Two of these housings co.itain large, louvered openings covered with 1/2 inch, 16 gage bird screen as shown on drawing M-254.

The other housing is covered by a thick steel plate and penetrated by two 14 inch diameter pipe wie!. intake about 80 feet to the north.

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Docket 50-344 Aigust 12. 1988 License NPF-1 Attachmsnt 6 Page 20 of 33 PAGE 19 of 20 C-FP-1.3.1 The only significant source of combustible material at the roof level is the hydrogen bulk storage tanks located within a three-sided dike area open only on the side away from the HVAC housings.

The exhaust housing for System No. CB-12 is about 20 feet south of dike arca and the intake housings for Systems CB-1, CB-5 and CB-10 are about 40 feet south of the dike area.

The 12 inch thick dike walls are higher than the top of the horizontally supported tanks, and will prevent tank movement in the direction of the housings in the event of tank failure.

The Control Building roof is comprised of built-up roofing applied over a concrete slab.

The roofing was installed to provide an Underwriter's Laboratories, Inc; Class A, roof assembly, and thus will inhibit propagation of a fire in the tank area to the HVAC housings.

This justification was originally included in Section 2.3.2.13.2 of Volume II of PGE-1012.

It is judged that the HVAC openings through the Control Building roof will provide adequate protection of systems in Fire Aron C13 from a fire on the roof.

E32 - METAL SIDING FORMING THE E1/T1 BOUNDARY A large portion of the Fire Area E1/T1 boundary consists of unrated me'.al siding.

This boundary is covered by an exemption request from Appendix R to 10CFR50.

There is no roof on the El side of the barrier to trap heat from a fire.

In addition, aut omatic wat pipe sprinkler systems have been l

inntalled at elevation 63 ft. and at elevation 93 ft.

on t.he T1 side a' the barrier in the area adjacent to the E1/T1 boundary.

l It is judged that the metal siding boundary together with the wet pipe sprinkler systems will provide l

adequate firr, protection to prevent propagation of a j

fire from one fire area to the other.

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Trojan Nuclear Plant Document Control Desk Docket 50-344 August 12, 1988 License NPF-1 Page 21 of 33 f

PAGE 20 of 20 C-FP-1.3.1 E33 - INTAKE STRUCTURE ROOP FVAC OPENINGS The air supply and exhaust systems for the Intake f

Structure utilize penetrations in the concrete roof slab which are not protected with fire-rated dampers.

Each of these penetrations have a 6 inch concrete curb surrounding the opening and a louvered j

housing that is supported on the curb and covers the opening.

There are no permanent combustibles located on the roof, and normally no transient combustibles stored on the roof, which is level with the yard at elevation 45 ft.

In addition, the barrier is not needed for separation of safe shutdown equipment per the requirements of Section III.g to Appendix R.

This justification was originally included in Section 2.3.4 of Volume II of PGE-1012.

It is judged that the HVAC openings through the Intake Structure roof will provide adeque.te protection of systems in Fire Areas II, I2 and 13 from a fire on the roof, h

CONCLUSIONS This evaluation demonstrates that specific portions of I

fire area boundaries in the Trojan Plant, along with the other plant fire protection features, provide adequate fire protection.

Cross reference to other applicable evaluations which apply to the specific fire barriers is also provided.

This evaluation, along with the referenced 1

evaluations, demonstrates compliance with the applicable requirements of Appendix A to the Branch Technical Position and also demonstrates compliance with the 1

applicable requirements of Appendix R to 10CFR$0 to I

protect safe shutdown equipment and electrical cables to 1

1 ensure safe shutdown of the plant.

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Trojan Nuclear Plant Neument Control Desk Docket 50-344 August 12, 1988 License NPF-1 Page 1 of 53 C-FP-1.3.16 Revision 1 PAGE 1 OF 53 FILE C-FP-1. 3.16 CIVIL EVALUATION OF THE TRANSIENT COMBUSTIBLE CONTROL PROGRAM TROJAN NUCLEAR PLANT By -

Date S

/F#

Cnk by N AA Date B//o/8B II l'

/

/

General This evaluation addresses the adequacy of combustible loading limits set forth in Procedure A0-10-5 Revision 0, "Transient Combustible Program" in controlling the increase the transient combustibles for certain areas of the plant.

Some fire hazard analyses of passive barriers which form fire area boundaries have taken credit for limited amounts of combustibles.

These fire hazard analyses were performed to the general guidance of NRC GENERIC LETTER 86-10 which allows consideration of the overall barrier where portions of the fire area boundary do not totally conform to a 3-hour fire-rated configuration.

Evaluations were also performed for structural integrity during a fire of portions of the structure which do not form part of a fire boundary, but its failure could affect safe shutdown equipment.

Many of these evaluations considerad a combustible loading equivalent to the etandard 3-hour curve; however, in some cases, the actual combustible loading of the arr'a or room was used.

The previous revision 0 of this evaluation documented civil engineering's recommendations and input to the draft of the new Transient Combustibles Program.

This revision 1 of the Civil evaluation documents the review of the revision 0 of the Transients Control Program.

The procedure was checked against the latest revision (Revision 4) of the combustible loading table FP-902.

Results of the review along with justifications on the adequacy of the program limits and/or recommendations, if necessary, are provided for each fire area.

Each fire hazard analysis, which uses a limitation on combustibles to justify adequate fire protection, is identified.

Trojan Nuclear Plant Document Control Desk Docket 50-344 August 12, 1988 License NPF-1 C

Page 2 of 53 C-FP-1.3.16 Revision 1 PAGE 2 OF 53 Where 3-hour rated or evaluated barriers are provided, this analysis places no speci*ic limits on storage of transient combustibles required to support the Civil fire hazards analyses.

In addition, where 3-hour barriers have structural steel fireproofed to a 2-hour rating, this analysis places no specific limits on storage of transient combustibles required to support the Civil fire hazards analyses.

The justification for these 2-hour rated barriers being treated the same as 3-hour rated barriers is that the 2-hour rated fireproofing of the structural steel was as provided during original construction and the barriers were included as firo-rated barriers which were identified in the original submittal of PGE-1012.

l The justification and re ammendations provided in this evaluation should be considered together with any fire protection engineering justifications and the modification, maintenance, and operation needs of the plant.

There may be other reasons not stated in this evaluation for requiring the control of the increase of transient com! estibles in a given fire area.

The limits set forth in the program for controlling the increane of transient combustibles was set an arbitrary level equivalent to no more thag)5 minutes of the standard fire curve (about 7,000 BTU /FT with no continuity of combustibles.

Using an arbitrary area of 20 feet by 20 feet, this gives and amount of combustibles equivalent to about 2,600,000 BTU's in any one location which is judged small encugh to not change the conclusions in any civil fire hazard analysis or evaluation.

~ ~ ~

~~ Trojan Wucidar Plant ~

~

~

~

~~

Document Con' trol Desk

~

~

~

~

Docket 50-344 August 12, 1988 License llPF-1 g

Page 3 of 53 C-FP-1.3.16 Revision 1 PAGE 3 OF 53 ALL FIRE AREAS Fire Hazard Analysis All Civil fire hazard analyses have been performed l

using the combustible loadings list on the Combustible Lodding Table FP-902. The table lists all combustibles (class

'A'

&'B') by room or area within a given fire area.

The table includes a 100%

increase in lube oil to account for transients brought in for maintenance purposes.

Any increases of more than 1 callon over the amount of Class

'B' combustibic or ficamable liquids listed in the table could affect the fire hazard analyses.

EE99IAM The Transient Combustible Program does not specifically control the increase of Class

'B' combustiblee and flammable liquids if they are stored in a combustible liquid storage locker.

This could allcw an unlimited increase of Class

'B' liquids to be brought into a given fire area.

Recommendation Revise the Transient Combustibles Program to control increases in the number of Class

'B' combustible liquid storage lockers.

The program should require that when combustible liquid storage lockers are added to a fire area, the combustible Loading Table FP-902 is revised to include an increase in the amount of combustibles equal to the capacity of the storage cabinet.

Also, revise the Transient Combustibles Program to limit increase of Class

'B' transient combustibles to 1 aallon over the amount shown in the combustible l

loading table in any one area or room, including outside areas like the Intake structure roof, power block building roofs. areas withir.10 feet of the exterior walls of buildings, and areas within 20 feet of the entrances to Manhole Nos. 3&4.

l

+

Trojan Nuclear Plant Document Control Desk Docket 50-344 August 12, 1988 License NPF-1 Ateachment 7 Page 4 of 53 C-FP-1.3.16 Revision 1 PAGE 4 OF 53 FIRE AREA A1 1.

Auxiliary Buildina Pineways. Pine Chases, and Filter Call.1 Fire Hazard Analysis Several fire hazard analyses have taken credit for little or no combustibles in the pipeways, pipe chases and filter cells (See Files C-FP-1.3.6, C-FP-1.3.7, and C-FP-1.3.8).

Additional amount of Class

'A' combustibles equivalent to 5 minutes of the standard fire curve, with no continuity of combustibles, can be added in any location without affecting existing fire hazard analyses.

ProatAE The Transient Combustible Program calls for controlled storage of Class'A' transient combuetibles at each elevation of Fira Area Alt however, the pipeways, pipe chases and filter cells are not specifically identified as controlled storage areas.

Recommendation The Transient Combustibles Program should be revised to more clearly indicate that combustibles added at l

these locations should be limited to no more than an equivalent of 5 minutes of the standard fire curve.

See recommendation above for additional control of class

'B' combustibles.

l l

1 1

i t

Trojan Nuclear Plant Document Control Desk Dochet 50-344 August 12, 1988 License NPF-1 t

Page 5 of $3 C-FP-1.3.16 Revision 1 PAGE 5 OF 53

2. Auxiliary Buildina Elevation 5-FT F_ ire Hazard Analva(g A fire hazard analysis (File C-FP-1.3.2) his been done to address exposed structural steel at the elevation 5-ft of the Auxiliary Building.

A fire on el.evation 5-ft which could effect exposed structural steel supporting non-fire barrier portions of the elevation 25-ft slab could result in some local degradation.

Any damage would, however, affect no safe shutdown systems not already affected by the fire.

Additional Class

'A' combustibles equivalent to 25 ninutes of the standard fire curve can be added in any of the rooms without affecting nny fire hazards analyses.

Although there has been a slight increase in the combustible loading equivalent to about 1 minute in the N/S Corridor (Room 137),

class

'A' combustibles equivalent to 45 minutes of the standard fire curve can be added in the corridor without affecting the analyses.

Program The Transient Combustible Program controls the increase of Class

'A' transient combustibles in these areas to an equivalent of 5 minutes of the i

standard fire curve.

Recom3mndation See page 3 for recommendation on additional control of claso

'B' combustibles.

I

3. Auxiliarv Buildina Elevation 25-PT Fire Hazard Analysis A fire hazard analysis (File C-FP-3. 3.2) has been performed to address exposed structural steel at the elevation ?5-ft level of the Auxiliary Building.

The elevation 45-ft slab above has been shown to have equivalent to a 3-hour fire rating.

l l

l

Trojan Nuclear Plant Mcument Control Desk Docket 50-344 August 12 1988 License NPF-1 Page 6 of 53 C-FP-1.3.16 Revision 1 PAGE 6 OF 53 Additional Class

'A' combustibles equivalent to 5 minutes of the standard fire curve can be added in the

'B' CCP room without affecting fire hazards analyses.

Although the combustible loading in the E/W and N/S Corridors Rooms (Rooms 157 & 158) has increased to an equivalent loading of about 2 to 4 minutes, Class

'A' combustibles equivalent to 85 minutes of the standard fire curve may be added in any of the other rooms without affecting fire hazard analyses.

Procram The Transient Combustible Program controls the increase of Class

'A' transient combustibles in these areas to an e sivalent of 5 minutes of the s

standard fire curve.

Recommendation See page 3 for recommendation on additional control of class

'B' combustibles.

4. The Pinina Facade Area Elevation 45 to 77-PT Fire Hazard Analvs(A A. A fire hazard analysis (File C-FP-1.3.9) of the seismic gap between the Piping Facade Area boundaries (walls and 93-ft slab) and the containment wall takes credit for the icw combustible loading in the area.

Additional Class

'A' combustibles equivalent to 5 minutes of the standard fire curve can be added at in both the 45 and 77-ft elevations of the Piping Facade Area near the containment wall without affecting fire hazard analyses.

r.__,,

Trojan Nuclear Plant Decument Control Desh Docket 50-344 August 12, 1988 License NPF-1 1

Page 7 of 53 C-FP-1.3.16 4

l Revision 1 PAGE 7 OF 53 l

B. A fire hazard analysis (File C-FP-1.3.2) has been performed to address exposed structural steel in the Piping Facade at elevations 45 and 77-ft.

Calculated fire tolerances of exposed structural steel in this area are as low as 15 to 25 minutes of

]

the standard fire curve.

A fire in the Facade Area which could effect exposed structural steel supporting non-fire barrier portions of the structure could result in some local degradation.

Safe shutdown piping for both trains is located in this area.

Although there has been a slight increase in the combustible loading equivalent to about 1 minute in the Boric Acid Evaporator And Gas Stripper Room (Room 216) at elevation 77-ft, additional Class

'A' combustibles equivalent to 10 minutes of the standard fire curve can be added in Piping Facade i

Area (except near the containment wall) without affecting fire hazards analyses.

Program The Transient combustible Program calls for controlled storage of Class'A' transient combustibles at elevations 45 ft. and 63 ft. of the Piping Facade in Fire Area Alt however, the elevation 75 ft. is not specifically identified as a controlled storage area.

l Recommendation

\\

The Transient combustibles Program should be revised to more clearly indicate that combustibles added at elevation 75 ft. in the Piping Facade should be limited to no more than an equivalent of 5 minutes i

of the standard fire curve.

l Also, see page 3 for recommendation on additional control of class

'B' combustibles.

I

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1 i

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Trojan Nuclear Plant

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Docket 50-344 August 12, 1988 License NPF-1 Page 8 of 53 C-FP-1.3.16 Revision 1 PAGE 8 OF 53 i

FIRE AREA A2

1. RHR Pume Room and Ploe Chase Fire Hazard Analysis i

A fire hazard analysis (File C-FP-1.3.6) has taken credit for little or no combustibles in the Pipe Chase, Room 147, above the

'A' RHR Pump Room (Room 125).

Additional Class

'A' combustibles equivalent to 5 minutes of the standard fire curve can be added in the

'A' RHR Pump Room and Pipe Chase without affecting fire hazard analyses.

Program The Transient Combustible Program controls the increase of Class

'A' transient combustibles to an equivalent of 5 minutes of the standard fire curve.

Recommendation See page 3 for recommendation on additional control of class

'B' combustibles.

2. Remainina Areas fire Hazard Analysis All barriers in the area are 3-hour rated or have been evaluated to be equivalent to a 3-hour rating.

In other than the RHR Room, no soecific limits on class

'A' combustibles were used in the fire hazard analyses.

Program The Transient combustible Program controls the increase of Class

'A' transient combustibles to an equivalent of 5 minutes of the standard fire curve all areas of Fire Area A2.

Trojaa Nuclear Plant Document Control Desk Docket 50-344 August 12, 1988 License NPF-1 Page 9 of 53 C-FP-1.3.16 Revision 1 PAGE 9 OF 53 Rgcommendation See page 3 for recommendation on additional control of class

'B' combustibles.

FIRE AREA A3

'A' CCP Room and Adiacent Picavay Fire Hazard Analysis A fire hazard analysis ( PGE 1012, Section 2.3.1.3 of Volume II) has taken credit for the low combustible loading in noth the

'A' CCP Room (Room 153) of Fire Area A3 and in the adjacent Pipeway at elevation 37-ft 6-in of Fire Area A1.

Additional Class

'A' combustibles equivalent to 5 minutes of the standard fire curve can be added in the CCP Room without affecting fire hazard analysis.

Procram The Transient Combustible Program controls the increase of Class'A' transient combustibles in the

'A' CCP Room to an equivalent of 5 minutes of the standard fire curve.

Recommendation l

See page 3 for recommendation on additional control of class

'B' combustibles.

{

Trojan Nuclear Plant Document Control Desk Docket 50-344 August 12, 1988 License NPF-1 Page 10 of 53 C-FP-1.3.16 Revision 1 PAGE 10 OF 53 FIRE ARIA A4 1.

Domineralizer calls and Valve ca11eries at Elevation 77-PT Fire Hazard Analysis A fire hazard analysis (File C-FP-1.3.7) has been performed to address the unsealed penetrations in the Domineralizer Cell (Room 215) walls at Fire Area A1/A4 boundary.

The analysis takes credit for limited amounts of combustibles in the Domineralizer Cells and the Adjacent Valve Galleries Room (Room 211).

Additional Class

'A' combustibles equivalent to 5 minutes of the standard fire curve can be added in the adjacent Valve Galleries on elevation 77-ft in the Auxiliary Building without affecting fire hazard analysis.

Program The Transient Combustible Program controls the increase of Class

'A' transient combustibles to an equivalent of 5 minutes of the standard fire curve.

Recommendation See page 3 for recommendation on additional control of class

'B' combustibles.

l

Trojan Nuclea? Plant Document Control Desh Docket 50-344 August 12, 1988 License NPF-1 Page 11 of 53 I

C-FP-1.3.16 Revision 1 PAGE 11 OF 53 2.

Elevation 45-Ft of the Auxiliary and Fuel Buildinas Fire Hazard Analy h A fire hazard analysis (File C-FP-1.3.2) has been performed to address exposed structural steel at the i

elevation 45-ft level of the ruel and Auxiliary-Building.

Both redundant trains of safe shutdown systems are located at this elevation.

Calculated fire tolerances of exposed columns and floor support beams supporting non-fire barrier portions of the structure in this location are as low as 25 to 50 minutes of the standard fire curvo.

A fire on elevation 45-ft large enough to effect exposed structural steel could result in collapse of portions of the structure.

The combustible loading in the E/W Corridor (Room 178) has increased by about 17 minutes, but most of it is located its the sprinklered area of the corridor.

Even with this increase, additional Class

'A' combustibles equivalent to 5 minutes of the standard fire curve can be added on elevation 45-f t in the Auxiliary and ruel Buildings in Fire Area A4 without affecting fire hazard analyses.

Storage of larger amounts of combustibles may be justified in a 6

sprinklered area just sist of the Dirty Waste Monitor Tank Room (DWMT).

Program The Transient Combustible Program controls the increase of Class

'A' combustibles in all the areas at elevation 45-ft of the two buildings.

An exception is erroneously identified as the area east of the Treated Waste Monitor Tank Room (TWMT).

Recommendation!

The program should be revised to exempt from controls the sprinklered area of Corridor 178 east of the DWNT instead of the area east of the TWMT.

Also, see page 3 for recommendation on additional control of class

'B' combustibles.

I 1

irojan Nucicar Plant Document Control Desk Docket 50-344 August 12 1988 Licence NPF-1 Page 12 of f3 ^

C-FP-1.3.16 Revision 1 PAGE 12 OF 53 2.

Elevation 61-Ft of the Auxiliary and Fuel Buildinas Elye Hazard Analysis A fire hazard analysis (File C-FP-1.3.2) has been performed to address exposed structural steel at the elevation 61-ft level of the Fuel and Auxiliary.

Building.

Calculated fire tolerances of exposed floor support beams supporting non-fire barrier portions of the structure in this location are as low as 15 to 30 minutes of the standard fire carve.

A fire on elevation 61-ft large enough to effect exposed structural steel could result in collapse of portions of the structure.

Although the combustible loading has increase to an equivalent of about 3 minutes in Corridor 257, additional Class

'A' combustibles equivalent to 5 minutes of the standard fire curve can be added on elevation 61-ft in the Auxiliary and Fuel Buildings in Fire Area A4 without affecting fire hazard analyses.

Program Except for the I & C Shop and Anti-C Storage Area in the Corridors 256 and 257, the Transient Combustible Progeam controls the increase of the Class

'A' transient combustibles to an equivalent of 5 minutes of the standard fire curve.

Recommendation Because a beam located at the ceiling of Corridor 256 has a calculated fire tolerance of 15 minutes, the program should be ravised to remove the exception for the I & C Shop.

Applying a 5 minute limitation to this area would still allow an increase of class

'A' combustibles of approximately 500 pounds of H/P materials in Corridor 256.

Also, see page 3 for recommendation on additional control of class

'B' combustibles.

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Docket 50-344 August f2 1988 License NPF-1 Page 13 of 53,

C-FP-1.3.16 Revision 1 PAGE 13 0F 53 j

3.

Elevation 77-Ft of the Auxiliary and Fuel buildina i

Fire Hazard Analysis A. A fire hazard analysis (File C-FP-1.3.2) has been performed to address exposed structural steel at the elevation 77-ft level of the Fuel and Auxiliary Building.

The 93-ft slab is needed for protection of safe shutdown systems in Fire Area A4 from a fire in the non-safe shutdown Fire Areas A5 and A6 above.

For a fire from above, the steel is protected by the slab and the barrier is 3-hour rated.

For a fire within Fire Area A4, the barrier was evaluated as steel supporting non-fire carrier portions of the structure.

Calculated fire tolerances of exposed floor rupport beams in this location are as low as 15 to 45 minutes of ths standard fire curve.

A fire on elevation 77-ft large enough to effect exposed structurel steel could result in collapse of portions of the structure.

There has been a slight increase in the combustible loading of about 1 minute in Rooms 269 and 270.

Even with the increase, additional Class

'A' combustibles equivalent to 5 minutes of the standard j

fire curve can be added on elevation 77-ft in the Auxiliary and Fuel Buildings in Fire Area A4 without i

affecting fire hazard analysis.

B. A fire hazard analysis (File C-FP-1.3.12) has been performed to address exposed structural supports above cable wraps at the alevation 77-ft level of the ruel Building.

This evaluation shows that the i

cable wraps will not be degraded from s potential failure of supports above the wraps due to temperatures generated by a fire consisting of i

insitu combustibles.

Calculated fire tolerances of exposed supports are less than 1-hour of the standard fire curve.

l Additional Class

'A' combustibles equivalent to S minutes of the standard fire curve can be added on elevation 77-ft in the Fuel Building in Fire Area A4 without affecting fire hazard analysis.

l l

Trojan Nuclear Plant Documsnt Control Desk Docket 50-344 August 12 1988 License NPF-1 Page 14 of 53 C-FP-1.3.16 Revision 1 PAGE 14 0F 53 l

Program The Transient combustible Program controls the increase of the Class

'A' transient combustibles to an equivalent of 5 minutes of the standard fire curve.

An exception is made for an anti-C storage area outside the NUT valve gallery.

Recommendations l

The program should be revised to remove the exception for the Anti-C storage in this area.

The i

5 mineAta limitation on the increase of transient l

combustibles would allow a increase of approximately 5u LBS of H/P materials above the 200 LBS listed in the combustible Loading Table for Room 269. This would allow enough leeway for Radcon to support plant maintenance projects while staying within the 5 minute limitation.

l l

Also, see page 3 for recommendation on additional i

control of class

'B' combustibles.

l l

l FIRE AREA A4a Elevation 61 and 77-Ft of the Auxiliary Buildina Fire Hazard Analysis A fire hazard analysis (File C-FP-1.3.2) has been performed to address orposed structural steel at the elevations 61-ft and 77-ft levels for Fire Area A4al however, specific fire tolerances of exposed steel supporting the 93-ft slab were not calculated.

The 93-ft slab is needed for protection of safe shutdown systems in Fire Area A4a from a fire in the non-safe shutdown Fire Area A6 above.

For a fire from above, the steel is protected by the slab and the barrier is 3-hour rated.

Based on a comparison of this configuration (partially embedded beams in a thick slab with a short span between masonry walls) to other calculations for similar configurations, the barrier should also be capable of withstanding a 3-hour exposure for a fire within Fire Area A4a.

Trojan Nucloer Plant Document Control Desk Docket 50-344 August 12, 19P8 License NPF-1 Page 15 of 53 C-FP-1.3.16 I

Revision 1 PAGE 15 OF 53 The fire hazard analyses for this fi'te area contains no soecific limits on class'A' combustibles.

Procram The Transient Combustible Program controls the increase of Class

'A' transient combustibles to an equivalent of 5 minutes of the standard fire curve.

Recommendation l

See page 3 for recommendation on additional control l

of class

'B' combustibles.

FIRE ARIA A5 Elevation 45 to 93-Ft of the Puel Buildinu Fire Hazard Analysis Fire Area A5 does not contain safe shutdown systems and was originally designated as a fire area in order to provide separation from safe shutdown areas because of the greater probability of transient combustibles be;,ng present in Fire Area A5.

A fire 1

hazard anal; fair (File C-FP-1.3.2) has been performed to addrast, axposed structural steel within Fire Area A5.

Calculated five tolerances of exposed columns supporting the 9tructure are as low as 20 to 30 i

minutes of the standard fire curve.

A fire near one of these columns on elevation 45-ft in the Train Bay or on the 93-ft level could result in collapse of portions of the structure.

Any damage would be expected to be confined to Fire Area A5, and the risk of damage of any safe shutdown systems in other fire areas would be very low.

The risk of some i

structural degradation in this non-safe shutdown area is considered acceptable.

),

fire hazard analysis, File C-FP-1.3.9, of the vanismic gap at the containment wall between the Fire Area Al and the fire areas above, takes credit for the low combustible loading in the area near the gap.

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Trajan Nuclear Plant Document Control Desk Docket 50-344 August 12, 1988 Licence NPT-1 Page 16 of 53 I

C-FP-1.3.16 i

Revision 1 PAGE 16 OF 53 Additional Class

'A' combustibles equivalent to 1_ minutes of the standard curve can be added in this area without affecting the fire hazard analysis.

i Proaram The Transient Combustible Program does not control the increase of Class'A' transient combustibles in this area.

l Recommendation

{

The Transient combustibles Program should require "controlled storage" of combustibles near the containaant wall.

See page 3 for recommendation on additional control of class

'B' combustibles.

FIRE ARIA A6

1. Elevation 93-Ft of the Auvi,11ary Buildina Fire Manard Analvmin l

Fire Area A6 does not contain safe shutdown systems and was originally designated as a fire area in order to provide separation from safe shutdown areas because of the greater probability of transient combustibles be,ng present in Fire Area A6.

A fire hazard analysis has been done to address exposed structural steel within Fire Area A6.

Calculated fire tolerances of exposed columns supporting the structure are as low as 20 to 30 minutes of the standard fire curve.

A fire near one of these columns on the 93-ft level could result in collapse i

of portions of the structure.

Any damage would be j

expected to be confined to Fire Area A6, and the l

risk of damage of any safe shutdown systems'in other fire areas would be vo n low.

The risk of some structural degradation in this non-safe shutdown i

area is considered acceptable.

Therefore, control of the storage of Class

'A' combustibles is not required.

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Trojan INelear Plant Document Control Desk N eket 50-344 August 12, 19G0 License NPF !

4 Page 17 of 53 C-FP-1.3.16 Revision 1 PAGE 17 or 53 1

Proarna Tne Transient Combustible Program does not control the increase of Class

'A' transient combustibles in I

this area.

RecommendatioD i

see page 3 for recommendation on addition control of class

'B' combustibles.

I 2.

Purae Exhaust Room at Elevation 93-FT Fire Harard Analvain A fire hazard analysis, File C-FP-1.3.9, of the seismic gap between the Purge Exhaust Room (Room 226) wall at Fire Area A6/El boundary and the dentainment wall takes credit for the low combustible loading in the room near the gap.

Additional Class

'A' combustibles equivalent to 3 minutta of the standard curve can be added in this i

room without affecting the fire hazard analysis.

Program The Transieht Combustible Program does not control the increase of Class

'A' transient combustibles in this room.

Egggmmandation The Transient Combustibles Program should require "controlled storage" of cembustibles near the containment wall.

Also, see page 3 for recommendation on additional control of class

'B' combustibles.

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Trojen Nuclear Plant Documsnt Control Desk Docket 50-344 August 12. 19G8 License NPF-1 Page la of 53 C-FP-1.3.16 Revision 1 PAGE 18 0F 53 FIRE AREA A7 i

Containment Access at Elevation 93-FT Fire Hazard Analysis Fire Area A7 does not contain safe shutdown systems.

The personnel air lock is not rated, but will provided protection equivalent to 3-hour.

A fire hazard analysis (File C-FP-1.3.9) has been performed to address the unrated seals in the seismic gaps between the floor, walls, and ceiling of the access and the containment wall.

The analysis takes credit for the low combustible loading in Fire Area A7 which can consists of to up 8 H/P material barrels at approximately 35 pounds each.

Additional Class

'A' combustibles equivalent to 10 minutes of the standard fire curve can be added in this area without affecting the fire hazard analysis.

Procrag The Transient combustible Program does not control the increase of Class

'A' transient combustibles in I

this area.

1 Recommendation 1

The program should be revised to limit the increase of Class

'A' transient combustibles to an equivalent of 5 minutes of the standard fire curve.

The limitation will allow approximately 3 H/P material barrels (in addition to the 8 H/P material barrels listed in the combustible loading table) to be added to the area without exceeding the limit.

This will allow Radcon enough leeway to stay within the limit while supporting any plant maintenance projects.

Also, see page 3 for recommendation on additional control of class

'B' combustibles.

Trojan Nuclear Plant Documsnt Control Desk Cucket 50-344 August 12. 1988 License NPF-1 Page 19 of 53 C-FP-1.3.16 Revision 1 l

PAGE 19 OF 33 l

FIRE AREA A8 Seent Fuel _ Pool Area Fire Hazard Analysis A fire hazard analysis (File C-FP-1.3.1) for the opening in the A1/A8 boundary has taken credit for the lack of combustibles in the locked area behind the Spent Fuel Pool in Fire Area A8.

No storage of combustibles should be allowed in the locked area behind the spent Fuel Pool.

No snacific limita Class

'A' combustibles were used in fire l,

hazard analysis for the remainder of the fire area.

1 Program 1

l The Transient Combustible Program controls the storage of Class

'A' transient combustibles in the i

locked area behind the Spent Fuel Pool.

l Recommendation See page 3 for recommendation on additional control of class

'B' combustibles.

FIRE ARIA C1 Elevation 45-Ft of the Contycl Buildina Fire Mazard Analysis A. Section 2.3.2.1.1 of voluna II of PGE-1011 sddresses the fireproofing of structural steel which provides at least a 2-hour fire-rated protection of steel supporting the 61-ft slab in addition to sprinkler system protection of the area.

B. A fire hasard analysis (File C-FP-1.3.3) has been performed to address a foam seal in the C1/T1 boundary.

No snacific limits of Class'A' combustibles were used in fire hazard analysis for this fire area.

Trojan hueloar Plant Document Control Desk Docket 50-364 August 12 1988 Licence NPF-1 Page 20 of 53 C-FP-1.3.16 Revision 1 PAGE 20 OF 53 Procram The Transient Combustible Program does not control the increase of Class

'A' transient combustibles in this area.

Recommendation l

See page 3 for recommendation on additional control of class

'B' combustibles.

FIRE AREA C2 Electrical Switchcear & Auxiliarv. Room at Elev. 614Ft of Control Buildina Fire Hazard Analysis A. Section 2.3.2.2.3 of volume II of PGE-1012 and ar, analysis by Wiss, Janney, Elstner Associates, Inc.

(WJE) addresses the fireproofing of structural steel which provides a 2-hour fire-rated protection of steel supporting the 77-ft slab.

B. A fire hazard analysis (File C-FP-1.3.3) has been performed to address foaa seals in the C2/A4a and C2/C6 boundaries.

Credit was taken for a reduced combustible loading v51ch is expected never to exceed 1/2 of the evaluated 2-1/2 hour rating of the foam seals.

Based on the analysis, additional Class'A' combustibles equivalent to 50 minutes of the standard fire curve can be added in any location without affecting this fire hazard analysis.

Trojan Nuclear Plant Document Control Desk Docket 50-344 August 12, 1988 License NPF-1 Page 21 of 53 C-FP-1.3.16 Revision 1 PAGE 21 OF 53 C.

Fire hazard analyses (Files C-FP-1.3.4 & C-FP-1.3.5) were performed to address the plaster wall barrier in the C2/C3 boundary.

Credit was taken for a reduced combustible loading which is expected never i

to exceed 1/ 2 of the lowest estimated equivalent i

rating of the wall of 1-1/2 hour.

A plaster wall I

assembly, similar to the wall used at Trojan, was fire tested in 1987 and it passed the 3-hour fire test.

The bus duct penetration was also upgraded to a 3-hour rdting in 1987.

Since the wall and bus duct penetration are now considered 3-hour fir 6-rated, the analysis is no longer applicable.

Procram The Transient combustible Program controls the increase of Class

'A' transient combustibles to an equivalent of 5 minutes of the standard fire curve.

Recommendation See page 3 for recommendation on additional control of class

'B' combustibles.

FIRE AREA C3 Electrical Auxiliary Room at Elev. 65-Ft of the Control Room Fire Hazard Analysis A.

Section 2.3.2.3.2 of volume II of PGE-1012 and an analysis by WJE addresses the fireproofing of structural steel which provides c 2-hour fire-rated protection of steel supporting the 77-ft slab.

No l

cpecific limits of Class'A' combustibles were used in fire hazard analysis for this fire area.

(

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Trojan Nuclear Plant Document Control Desk Docket 50-344 August 12, 1988 License NPF-1 Page 22 of 53 C-FP-1.3.16 Revision 1 PAGE 22 OF 53 B.

Fire hazard analyses (Files C-FP-1.3.4 & C-FP-1.3.5) were performed to address the plaster wall barrier in the C2/C3 boundary.

Credit was taken for a reduced combust'ble loading which is expected never to exceed 1/2 of the lowest estimated equivalent rating of the wall of 1-1/2 hour.

A plaster wall assembly, similar to the wall used at Trojan, was fire tested in 1987 and it pasted the 3-hour fire test.

The bus duct penetration was also upgraded to a 3-hour rating in 1987.

Since the wall and bus duct penetration are now considered 3-hour fire-rated, the analysis is no longer applicable.

Procram Although not specifically required by any Civil fire hazard analysis, the Transient combustible Program controls the increase of Class

'A' transient combustibles to an equivalent of 5 minutes of the standard fire curve.

BecommendatiGD See page 3 for recommendation on additional control of class

'B' combustibles.

FIRE AREA C4 Batterv Room

'B' at Elev. 65-Ft of the Control Buildino Fire Hazard Analysis Section 2.3.2.4.1 of volume II of PGE-1012 and an analysis by WJE addresses the fireproofing of structural steel which provides a 2-hour fire-rated protection of steel supporting the 77-ft slab.

No specific limits on class'A' combustibles were used in fire hazard analysis for this fire area.

l I

Trojan Nuclear Plant Document Control Desk Locket 50-344 August 12, 1988 License NPF-1 Page 23 of 53 C-FP-1.3.16 Revision 1 PAGE 23 OF 53 Procram 1

Although not specifically required by any Civil fire hazard analysis, the Transient Combustible Program controls the increase of Class

'A' transient combustibles to an equivalent of 5 minutes of the standard fire curve.

Recommendation See page 3 for recommendation on additional control of class

'B' combustibles.

FIRE AREA C5 Batterv Room

'A' at Elev 65-Ft of the Control Buildino Fire Hazard Analysis Section 2.3.2.5.1 of volume II of PGE-1012 and an analysis by WJE addresses the fireproofing of structural steel which provides a 2-hour fire-rated protection of steel supporting the 77-ft slab.

No specific limits on Class'A' combustibles were used in fire hazard analysis for this fire area.

Procram Although not specifically required by any Civil fire hazard analysis, the Transient Combustible Program controls the increase of Class'A' transient combustibles to an equivalent of 5 minutes of the standard fire curve.

Recommendation See page 3 for recommendation on additional control of class

'B' combustibles.

Trojan Nuclear Plant Document Control Desk Docket 50-344 August 12, 1988 License NPF-1 Page 24 of 53 C-F?-1.3.16 Revision 1 PAGE 24 OF 53 FIRE AREA C6 Mechanical Room at Elev, 61-Ft of the Control Building Fire Hazard Analysis A.

Section 2.3.2.6.2 of volume II of PGE-1012 and an analysis by WJE addresses the fireproofing of structural steel which provides a 2-hour fire-rated protection of steel supporting the 77-ft slab.

B. A fire hazard analysis (File C-FP-1.3.3) has been performed to address foam seals in the C6/El and C2/C6 boundaries.

Credit was taken for a reduced combustible loading which is expected never to exceed 1/2 of the evaluated 2-1/2 hour rating of the foam seals.

The combustible loading in this room has increased by approximately 6 minutes.

Even with the increase, additional Class

'A' combustibles equivalent to 50 minutes of the standard fire curve can be added in any location without affecting this fire hazard analysis.

Procram The Transient Combustible Program controls the increase of Class

'A' transient combustibles to an equivalent of 5 minutes of the standard fire curve.

Recommendation See page 3 for recommendation on additional control of class

'B' combustibles.

Trojan Nuclear Plant Document Control Desh Docket 50-344 August 12, 1988 License NPF-1 Page 25 of 53 C-FP-1.3.16 Revision 1 PAGE 25 OF 53 1

FIRE AREA C7 Cable Screadina Room at Elev. 77-Ft of the Control Blda.

Fire Hazard Analysis A.

Section 2.3.2.7.2 of volume II of PGE-1012 and an analysis by WJE addresses the fireproofing of strugtural steel which provides a 2-hour fire-rated protection of steel supporting the 93-ft slab.

B.

A fire hazard analysis (File C-FP-1.3.3) has been performed to address foam seals in the C7/A4, C7/T1, C7/C9 and C7/C8 boundaries.

Credit was taken for a reduced combustible loading which is expected never to exceed 1/2 of the evaluated 2-1/2 hour rating of the foam seals.

Additional Class

'A' combustibles equivalent to 5 minutes of the standard fire curve can be added in any location without affecting this fire hazard analysis.

Procram The Transient Combustible Program controls the increase of Class

'A' transient combustibles to an equivalent of 5 minutes of the standard fire curve.

Recommendation See page 3 for recommendation on additional control of class

'B' combustibles.

FIRE AREA C8 Mechanical Room at Elev. 77-Ft of the Control Buildina Fire Hazard Analysis l

A. Section 2.3.2.8.2 of volume II of PGE-1012 and an analysis by WJE addresses the fireproofing of structural steel which provides a 2-hour fire-rated l

protection of steel supporting the 93-ft slab.

l i

l

Trojan Nuclear Plant Document Control Desk Docket 50-344 August 12, 1988 License NPF-1 Page 26 of 53 C-FP-1.3.16 Revision 1 PAGE 26 OF 53 B. A. fire hazard analysis (File C-FP-1.3.3) has been performed to address foam seals in the C7/C8 and C8/El boundaries.

Credit was taken for a reduced combustible loading which is expected never to exceed 1/2 of the evaluated 2-1/2 hour rating of the foam seals.

Additional Class

'A' combustibles equivalent to 45 minutes of the standard fire curve can be added in any location without affecting this fire hazard analysis.

Procram The Transient combustible Program controls the increase of Class

'A' transient ccmbustibles to an equivalent of 5 minutes of the star.dard fire curve.

Recommendation See page 3 for recommendation on additional control of class

'B' combustibles.

FIRE AREA C9 Comeuter Room at Elev. 77-Ft of the Control Buildina Fire Hazard Analysis A. Section 2.3.2.9.2 of volume II of PGE-1012 and an analysis by WJE addresses the fireproofing of structural steel which provides a 2-hour fire-rated protection of steel supporting the 93-ft slab.

B.

A fire hazard analysis (File C-FP-1.3.3) has been performed to address foam seals in the C7/C9 boundary.

Credit was taken for a reduced combustible loading which is shown on the combustible loading table (FP-902) to be about 1/2 of the evaluated 2-1/2 hour rating of the foam seals.

Additional Class

'A' combustibles equivalent to 5 minutes of the standard fire curve can be added in any location without affecting this fire hazard analysis.

i l

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Trojan Nuclear Plant Document Control Desk Docket 50-344 August 12, 1988 License NPF-1 Page 27 of 53 C-FP-1.3.16 Revision 1 PAGE 27 OF 53 Procram The Transient Combustible Program controls the increase of Class

'A' transient combustibles to an equivalent of 5 minutes of the standard fire curve, Recommendatiqui See page 3 for recommendation on additional control of class

'B' combustibles.

FIRE AREA C10 Hallway at Flev. 77-Ft of the Control Buildina Fire Hazard Analysis Section 3.2.10.1 of volume II of PGE-1012 and an analysis by WJE addresses the fireproofing of structural steel which provides a 2-hour fire-rated protection of steel supporting the 93-ft slab.

Storage of combustibles in this area could affect access for fire fighting or emergency operations in the Cable Spreading Room.

Additional Class

'A' combustibles equivalent to 5 minutes of tha standard fire curve can be added in any location without affecting this fire hazard analysis.

Proaram The Transient Combustible Program controls the increase of Class

'A' transient combustibles to an equivalent of 5 minutes of the standard fire curve.

Recommendations See page 3 for recommendation on additional control of class

'B' combustibles.

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Trojan Nuclear Plant Document Control Desk Docket 50-344 August 12, 1988 License NPF-1 i

Page 28 of 53 C-FP-1.3.16 Revision 1 PAGE 28 OF 53 FIRE AREA C11 Control Room at Elev. 93-Ft of the Control Buildina Fire Hazard Analysis Section 2.3.2.11.1 of volume II of PGE-1012 and an analysis by WJE addresses the fireproofing of structural steel which provides a 2-hour fire-rated protection of steel supporting the roof slab.

Although analyses of the passive barriers give no reasons for recommending controlled storage, there are obviously good fire protection reasons for restricting the combustibles brought into the Control Room area to only that which is needed for the operations personnel to perform their job.

Procram The Transient combustible Program controls tne increase of Class

'A' transient combustibles to an equivalent of 5 minutes of the standard fire curve.

Recommendation See page 3 for recommendation on additional control of class

'B' combustibles.

FIRE AREA C12 Chemical Lab at Elev. 93-FT of the Control Buildina Fire Hazard Analysis Section 2.3.2.12.1 of volume II of PGE-1012 and an analysis by WJE addresses the fireproofing of structural steel which provides a 2-hour fire-rated protection of steel supporting the 105-ft. slab.

No_

specific limit on class

'A' combustibles were used in the analysis for this area.

Trojan Nuclear Plant Document Control Desk Decket 50-344 August 12, 1988 License NPF-1 Page 29 of 53 C-FP-1.3.16 Revision 1 PAGE 29 OF 53 Procram The Transient Combustible Program does not control Class

'A' transient combustibles in this area.

Escomnendation See page 3 for recommendation on additional control of class

'B' combustibles.

FIRE AREA C13 Mech. and H & V Eouio. Rooms at Elev. 105-Ft of the_

gentrol Buildine Fire Hazard Analysis Section 2.3.2.13.1 of volume II of PGE-1012 and an analysis by WJE addresses the fireproofing of structural steel which provides a 2-hour fire-rated protection of steel supporting the roof slab.

Although analyses of the passive barriers give no reasons for recommending controlled storage, there are obviously good fire protection reasons for controlling the storage of combustibles in the room which contains both trains of Control Room emergency ventilation.

Procram The Transient Combustible Program does not control Class

'A' transient combustibles in these rooms.

Recommendation Revise the program to control Class

'A' transient combustibles to an equivalent of 5 minutes of the standard fire curve.

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Trojan Nuclear Plant Document Control Desk Docket 50-344 August 12, 1988 License NPF-1 Attachnent 7 Page 30 of 53 C-FP-1.3.16 Revision 1 PAGE 30 OF 53 FIRE AREA C14 New Remote Shutdown Panel Room at Elev 45-ft of the Contre 1_

Bldc.

Fire Mazard Analysis The room contains the new remote shutdown panel C-160. The room is completely enclose by 3-hour fire barriers.

A fire in this room will only affect one train of safe shutdown.

A Halon System protects the equipment in this room.

Although there are no Civil fire hazard analysis for this area that takes credit for low amounts of combustibles, there should be a limit on increases of Class

'A' transient combustibles in the room because it contains safe shutdown equipment.

Procram The program does not control the increase of transient combustibles in this room.

Recommendation The program should be revised to control the increase of Class

'A' transient combustibles to an equivalent of 5 minutes of the standard fire curve.

Also, see page 3 for recommendation on additional control of class

'B' combustibles.

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Trojan Nuclear Plant Document Control Desk Docket 50-344 August 12, 1988 License NPF-1 Page 31 of 53 C-FP-1.3.16 Revision 1 PAGE 31 OF 53 FIRE AREA El Elect. Penetration Area and Main Steam Succort Struct.

Fire Hazard Analysis A.

Fire hazard analyses (TGE 1012, Section 2.3.3 of Volume II and File C-FP-1.3.18) have taken credit for the low combustible leading and a lack of continuity of combustibles in the areas adjacent to the E1/T1 boundary, the east wall of the Turbine Building.

Although the combustible loading hss increased by about 2 minutes in the electrical penetration area near the pressurizer switchgear, the combustible loading near the E1/T1 boundary is low or negligible and there is lack of continuity of combustible adjacent to the wall.

Additional class

'A' combustibles equivalent to 5 minutes of the standard fire curve can be added next to the E1/T1 boundary without affecting this fire hazard analyses.

B. A fire hazard analysis, File C-FP-1.3.18, has taken credit for negligible loading in the Main Steam Support Structure (MSSS) near the E1/Y1 boundary.

Additional Class

'A' combustibles equivalent to 5 minutes of the standard fire curve can be added in the MSSS without affecting '_ne fire hazard analysis.

C.

Fire hazard analyses (PGE 1012, Section 2.3.3 of Volume II and File C-FP--1.3.1) have taken credit for the low combustible loading and a lack of continuity of combustibles in the portion of the area adjacent to the metal wall forming part of the E1/A6 boundary above elevation 93-ft.

Additional Class

'A' j

combustibles equivalent to 5 minutes of the standard fire curve can be added in the area adjacent to Fire r

Area A6 without affecting this fire hazard analysis.

Trojan Nuclear Plant Document Control Desh Docket 50-344 August 12, 1988 License NPF-1 At ta ch:nent 7 Page 32 of 53 C-FP-1.3.16 Revision 1 PAGE 32 OF 53 D. A fire hazard analysis (File C-FP-1.3.2) has been performad to address exposed structural steel supporting the elevation 93-ft slab.

Calculated fire tolerances of exposed floor support beams supporting non-fire barrier portions of the structure in thi:s location are as low as 15 to 40 minutes of the standard fire curve.

Sinco a larae portion of Fire Area El is open to the atmosphere, a fire on elevation 45-ft, could not affect the exposed structurtl steel. Therefore, additional Class

'A' combustibles equivalent to 5 minutes of the standard fire curve can be added in the Electrical Penetration Area without affecting this fire hczard analysis.

E.

A fire hazard analysis (FGE 1012, Section 2.3.3.1.7 in Volume II) has taken credit for the low combustible loading and a lack of continuity of combustibles (other than the built-up roofing) in the portions of the Control, Aaxiliary, and Turbine Building roofs adjacent to Fire Area El.

Additional Class

'A' combustibles equivalent to 5 minu133 of the standard fire curve may be added on the roof of the buildings adjacent to Fire Area E1 without affecting this fire hazard analysis.

Procram The Transient Combustible Program controls the increase of Class

'A' transient combustibles in Fire Area El, but not on the roofs of the Control, Auxiliary, and Turbine Buildings Recommendati_on Revise the program to control the increase of Class l

'A' transient combustibles on the Control, Auxiliary, and Turbine Building roofs to an equivalent of 5 minutes of the standard fire curve.

l Also, sea page 3 for recommendation on additional l

control of class

'B' combustibles.

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Trojan Nuclear Plant Document Control Desk Docket 50-344 August 12, 1988 License NPF-1 Pege 33 of 53 0-FP-1.3.16 Revision 1 PAGE 33 OF 53 FIRE AREA Il Service Water Pumn Room at Elev 23-Ft i

Fire Hazard Analysis A fire hazard analysis (PGE 1012, Section 2.3.4 of Volume II) has taken credit for the low cembustible loading on the roof of the Intake Structure adjacent to unrated HVAC openings into the Service Water Pumps Room.

Additional Class

'A' combustibles equivalent to 5 minutes of the standard fire curve can be added on the roof of the Intal:e Structure without affecting this fire hazard analysis.

Procram The Transient Combustible Program does not control the increase of Class

'A' transient combustibles in the Service Water Pump Room or on the Intake Structure roof.

Recommendation Revise the program to control the increase of class

'A' transient combustibles in the Service Water Pump Room and on the Ini:ake Structure roof of Fire Area Y1 to an equivalent of 5 minutes of the standard fire curve.

Also, see page 3 for recommendation on additional control of class

'B' combustibles.

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Trojan Nuclear Plant Document Control Desk Docket 50-344 August 12, 1988 License NPF-1 Page 34 of 53 C-FP-1.3.16 Revision 1 PAGE 34 OF 53 FIRE AREA I2 Diesel-Driven Fire Pumo Room at Elev. 23-Ft Fire Hazard Analysis A. A fire: 3zard analysis (PGE 1012, Section 2.3.4 in Volume II) has taken credit for the low combustible loading on the roof of the Intake Structure adjacent i

to unrated HVAC openings into the Diesel-Driven Fire Pump Room.

Additional Class

'A' combustibles equivalent to 5 minutes of the standard fire curve can be added on the roof of the Intake Structure without affecting this fire hazard analysis.

B. A fire hazard analysis PGE 1012, SectiSn 2.3.4 of Volume II) has taken credit for the low combustible loading outside on the Intake Structure elevation 23-ft, deck adjacent to the unrated fire door into the Diesel-Driven Fire Pumps Room.

Additional Class

'A' combustibles equivalent to 5 minutes of the standard fire curve can be added on the 23-ft deck of the Intake Structure without affecting this fire hazard analysis.

Procram The Transient combustible Program does not control the increase of Class

'A' transient combustibles in the Diesel-Driven Fire Pump Room, the Intake Structure roof, and the 23-ft deck outside the Intake Structure.

Recommendation Revise the program to control the increase of Class

'A' transient combustibles in the Diesel-Driven Fire Pump Room, on the Intake Structure roof,and the 23-ft deck outside the Intake Structure to an equivalent of 5 minutes of the standard fire curve.

Also, see page 3 for recommendation on additional control of class

'B' combustibles.

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Trojan Nuclear Plant Document Control Desk Docket 50-344 August 12, 1988 License NPF-1 Page 35 of 53 C-FP-1.3.16 Revision 1 PAGE 35 0F 53 FIRE AREA I3 Electrical, Motor-Driven Fire Pumo Room at Elev 23-Ft Fire Hazard Analysis A. A fire hazard analysis (PGE 1012 Section 2.3.4 of Volume II) has taken credit for the low combustible loading on the roof of the Intake Structure adjacent to unrated HVAC openings into the Electrical Motor-Driven Fire Pump Rooms.

Additional Class

'A' combustibles equivalent to 5 minutes of the standard fire curve can be added on the roof of the Intake Structure without affecting this fire hazard analysis.

B. A fire hazard analysis (PGE 1012, Section 2.3.4 in Volume II) has taken credit for the low combustible loading outside on the Intake Structure elevation 23-ft deck adjacent to the unrated fire door into the Electric Motor-Driven Fire Pump Room.

Additional Class

'A' combustiblss equivalent to 5 minutes of the standard fire curve may be added on the 23-ft deck of the Intake Structure without affecting this fire hazard analysis.

Procram The Transient Combustible Program does not control the increase of Class

'A' transient combustibles in the Electrical Motor-Driven Fire Pump Room, the Intake Structure roof,and on the 23-ft deck outside the Intake Structure.

Recommendation Revir,e the program to control the increase of Class

'A' transient combustibles in the Electrical Motor-Driven Fire Pump Room, on the Intake Structure roof, and the 23-ft deck outside the Intake Structure to an equivalent of 5 minutes of the standard fire curve.

Also, see page 3 for recommendation on additional control of class

'B' combustibles.

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Trojan Nuclear Plant Document Control Desk Docket 50-344 August 12, 1988 License NPF-1 Page 36 of 53 C-FP-1.3.16 Revision 1 PAGE 36 OF 53 FIRE AREAS M3 and M4 Manhole Nos. 3 &4 in the Yard.

A fire hazard analysis (PGE 1012, Section 2.3.5 of Volume II) has taken credit for the low combustible loading in both of these manhales (containing redundant, safe shutdown, electrical cables) and in the yard adjacent to these manholes.

No storage of combustibles should be allowed in either of these manholes.

Additional Class

'A' combustibles equivalent to 5 minutes of the standard fire curve can be added in the yard adjacent to these manholes without affecting this fire hazard analysis.

Procrgy The Transient Combustible Program does not control the increase of Class

'A' transient combustibles inside the manholes or in the yard area adjacent to these two manholes.

Recommendation The program should be revised to not allow storage of combustibl6s in the manholes and to control the increase of Class

'A' transient combustibles in the yard area within 20 feet of the manholes to an equivalent of 5 minutes of the standard fire curve.

Also, see page 3 for recommendation on additional control of class

'B' combustibles.

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Trojan Nuclear Plant Document Control Desk Docket 50-344 August 12 1988 License NPF-1 Page 37 of 53 C-FP-1.3.16 Revision 1 PAGE 37 OF 53 FIRE AREA M6 Manhole No. 6 Fire Hazard Analysis Fire hazard analyses (PGE 1012, Section 2.3.5 of Volume II and File C-FP-1. 3.1) have taken credit for the low combustible loading in this manhole which contains one train of safe shutdown, electrical cables.

Storage of transient combustibles near the manhole are justified based on an automatic suppression system and curbs around the manhole access which prevent most potential spills of combustible 'siquids from entering the manhole.

No storage of combustibles should be allowed in the manhole.

No specific limits on Class

'A' combustibles were used in fire hazard analyses for combustibles in fire area Tl adjacent to the manhole.

Procram The Transient combuctible Program does not control Class

'A' transient combustibles inside the manhole or in the area adjacent to the manhole in Fire Area T1.

Recommendation The program should be revised to not allow any storage of combustibles in the manhole.

Trojan Nuclear Plant Document Control Desk Dochet 50-344 August 12, 1988 License NPF-1 Page 38 of 53 C-FP-1.3.16 Revision 1 PAGE 38 OF 53 FIRE AREA RL Containw.ent Building Fire Hazard Analysis Several fire hazard analyses (PGE 1012, Section 2.3.6 of Volume II and File C-FP-1.3.15) were performed for items within the containment Building.

No special credit was taken for low combustible loadings.

One train of safs shutdown cables has been wrapped with a 1-hour cable wrap system in certain areas of the containment.

This was done to meet the requirements for radiant energy heat shields.

Additional Class

'A' combustibles equivalent to 5 minutes to 50 minutes of the standard fire curve can be added at various locations in the Containment without affecting these fire hazard analyses.

Program The Transient Combustible Program controls the increase of Class

'A' transient combustibles to an equivalent of 5 minutes of the standard fire curve.

Recommendation See pago 3 for recommendation on additional control of class

'B' combustibles.

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Trojan Nuclear Plant Document Control Desk Docket 50-344 August 12, 1988 License NPF-1

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Page 39 of 53 C-FP-1.3.16 Revision 1 PAGE 39 OF 53 FIRE AREA T1 Main Area of the Turbine Buildina Fire Hazard Analysis A.

Fire hazard analyses (PGE 1012, Sections 2.3.3 and 2.3.7 of Volume II and File C-FP-1.3.18) for the E1/T1 and T1/Y1 boundaries (east exterior wall of the Turbine Building) have taken credic for a reduced combustible loading on the 45-ft, 63-ft, and 93-ft elevations of the Turbine Building adjacent to Fire Areas El and Y1.

Additional Class

'A' combustibles equivalent to 5 minutes of the standard fire curve can be added at elevations 45-ft, 63-ft, or 93-ft of the Turbine Building within 10 feet of the E1/T1 and T1/Y1 boundaries without affecting these fire hazard analyses.

B.

A fire hazard analysis (File C-FP-1.3.17) has been performed to address the non-rated features of the west exterior wall of the Turbine Building (Fire Area Boundary T1/Y1), near the main transformers.

The analysis takes credit for the low to moderate combustible loading in the condenser area south of the EDG Rooms and west of the hydrogen seal oil unit.

Although the combustible loading in that area has increased by approximately 6 minutes, additional Class

'A' combustibles equivalent to 5 minut33 of the standard fire curve can be added in this area and within 10 feet of the west exterior wall of the Turbine Building without affecting the fire hazard analysis.

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Trojan Nuclear Plant Document Control Desk Docket 50-344 August 12, 1988 License NPF-1

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Page 40 of 53 C-FP-1.3.16 Revision 1 PAGE 40 OF 53 C.

Fire hazard analyses were not performed to address the exposed structural steel supporting the exterior of the Turbine Building and the non-fire-rated barriers within the building.

It was determined that any structural degradation of the Turbine Building caused by a fire would not damage safe j

shutdown systems not already damaged by the fire.

Any damage would be expected to be confined to fire area T1, and the risk of damage of any safe shutdown systems in other fire areas would be very low.

The 1

risk of some structural degradation in this area is considered acceptable.

No specific limits on Class

'A' combustibles were used in fire hazard analyses for combustibles in the general Fire Area T1.

Procram The Transient Combustible Program controls the increase of Class

'A' transient combustibles within 10 feet of the east exterior wall (E1/T1 boundary) of the Turbine Building at elevations 63-ft and 93-ft.

It does not control the increase of Class

'A' transient combustibles in any other areas of Fire Area T1.

Recommendations Revise the program to control the increase of Class

'A' transient combustibles within lo feet of the east exterior wall (E1/T1 and E1/Y1 boundary) of the Turbine Building.

Also, revise the program to control the Class

'A' transient combustibles in the area west of the hydrogen seal oil unit and within 10 feet of the west exterior wall of the Turbine Building, from Door #116 to the south wall of Train

'A' EDG Room to an equivalent of 3 uinutes of the standard fire curve.

Also, see page 3 for recommendation on additional control of class

'B' combustibles.

Trojan Nuclear Plant Document Control Desk Docket 50-344 August 12 1988 License NPF-1 Page 41 of 53 C-FP-1.3.16 Revision 1 PAGE 41 OF 53 FIRE AREA T2 Diesel AFW Pumo Room at Elev. 45-PT Fire Hazard Analysis A.

Section 2.3.7.2.1 of volume II of PGE-1012 and an analysis by WJE addresses the fireproofing of structural steel which provides a 2-hour fire-rated protection of stac1 supporting a portion of the 63-ft slab.

A sprinkler system provides additional protection.

The combustion loading given in the combustible loading table includes a 100% increase in lubricating oil and is approximately equivalent to a 3-hour fire severity.

Although the combustible loading has increased by approximately 1 minute, additional Class

'A' combustibles equivalent to 5 minutes of the standard fire curve can be added in the Auxiliary Feedwater Diesel AFW Pump Room without affecting the fire hazard analysis.

B. A fire hazard analysis (File C-FP-1.3.3) has been done to address fotm seals in the Tl/T2, T2/T3 and T2/T4 boundaries.

No credit was taken for a reduced combustible loading.

The seals were evaluated to i

demonstrate equivalent to 3-hour protection.

No specific limits on class

'A' combustibles were used for this fire hazard analysin.

Procram The Transient Combustible Program controls the increase of class

'A' transient combustibles to an equivalent of 5 minutes of the standard fire curve.

Recommendations See page 3 for recommendation on additional control of class

'B' combustibles.

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Trojan Nuclear Plant Ebcument Control Desk Docket 50-344 August 12, 1988 License NPF-1 Page 42 of 53 C-FP-1.3.16 Revision 1 PAGE 42 OF 53 FIRE AREA T3 Turbine AFW Pumo Room at Elev. 45-FT Fire Hazard Analysis A.

Section 2.3.7.3.1 of volume II of PGE-1012 and an analysis by WJE addresses the fireproofing of structural steel which provides a 2-hour fire-rated protection of steel supporting a portion of the 63-ft slab.

A sprinkler system provides additional protection.

The combustion loading given in the combustible loading table includes a 100% increase in lubricating oil.

Additional Class

'A' combustibles equivalent to 75 minutes of the standard fire curve can be added in the Auxiliary Feedwater Turbine Pump Room without affecting this fire hazard analysis.

B. A fire hazard analysis (File C-FP-1.3.3) was done to address foam seals in the T2/T3 boundary.

No credit was taken for a reduced combustible loading.

The seals were evaluated to demonstrate equivalent to 3-hour protection.

No specific limits on Class

'A' combustibles were used for this fire hazard analysis.

Procram The Transient combustible Program controls the increase of Class

'A' transient combustibles to an equivalent of 5 minutes of the standard fire curve.

Recommendations See page 3 for recommendation on additional control of class

'B' combustibles.

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Trojan Nuclear Plant Document Control Desk Dochet 50-344 August 12, 1988 License NPF-1 Page 43 of 53 C-FP-1.3.16 Revision 1 PAGE 43 OF 53 FIRE AREA T4 Diesel AFW Pumo Control Panel Room at Elev. 45-Ft Fire Hazard Analysis There are no civil fire hazard analyses for fire area T4.

This area is being revised and the C-160 remote shutdown panel is being relocated to Fire Area C14.

There will still be some Train B safe shutdown cables and equipment in the :foom, including the diesel AFW pump control panel.

Proeiram The Transient Combustible Program controls the increase of Class

'A' transient combustibles to an equivalent of 5 minutes of the standard fire curve.

Recommendation See page 3 for recommendation on additional control of class

'B' combustibles.

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Trojan Nuclear Plant Document Control Desk Dochet 50-344 August 12, 1988 License NPF-1 Page 44 of 53 C-FP-1.3.16 Revision 1 PAGE 44 OF 53 FIRE ARFA TS Train B Emercency Diesel Generator Room at Elev. 45-Ft Fire Hazard Analysis A.

Section 2.3.7.5.1 of volume II of PGE-1012 and an analysis by WJE addresses the fireproofing of structural steel which provides a 2-hour fire-rated protection of steel supporting the 69-ft slab.

An additional fire hazards analysis (C-FP-1.3.2) has shown that the upgraded condition is evaluated to provice the equivalent of 3-hour fire-rated protection.

A sprinkler system provides additional protection.

The combustible loading given in the combustible loading table includes a 100% increase in lubricating oil and is approximately equivalent to a 3-hour fire severity.

Additional Class

'A' i

combustibles equivalent to 5 minutes of the standt.rd iire curve can be added in the Train

'B' Emergency

esel Generator Room (Room 86) without affecting y's fire hazard analysis.

B. A fire hazard analysis (File C-FP-1.3.9) has been performed to address the non-fire-rated seal in the seismic gap between the south wall and the turbine pedestal and the less-than 3-hour rated seal in the seismic gap between the ceiling and the turbine pedestal.

These seals are being upgraded to meet 3-hour fire-rated requirements.

No specific limits on Class

'A' combustibles were used in the fire hazard analynis.

Procram The Transient combustible Program controls the increase of Class

'A' transient combustibles to an equivalent of 5 minutes of the standard fire curve.

Recommendation See page 3 for recommendation on additional control of class

'B' combustibles.

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Trojan Nuclear Plant Document Control Desk Docket 50-344 August 12, 1988 License NPF-1 Page 45 of 53 C-FP-1.3.16 Revision 1 PAGE 45 OF 53 FIRE AREA T6 Train A Emeruency Diesel Generator Room at Elev. 45-FT Fire Hazard Analysis A.

Section 2.3.7.6.1 of volume II of PGE-1012 and an analysis by WJE addresses the fireproofing of structural steel which provides a 2-hour fire-rated protection of steel supporting the 69-ft slab.

A sprinkler system provides additional protection.

The combustible loading given in the combustible loading table includes a 100% increase in lubricating oil and is approximately equivalent to a 3-hour fire severity.

Additional class'A' combustibles equivalent to 5 minutes of the standard fire curve can be added in the Train

'A' Emergency Diesel Generator Room (Roou 85) without affecting this fire hazard analysis.

B. A fire hazard analysis (File C-FP-1.3.9) has been performed to address the non-fire-rated seal in the seismic gap between the south vall and the turbine pedestal and the less-than 3-hour rated seal in the seismic gap between the ceiling and the turbine pedestal.

These seals are being upgraded to meet 3-hour fire-rated requirements.

No specific limits on Class

'A' combustibles were used in the fire hazard analysis.

Procram The Transient combustible Program controls the increase of Class

'A' transient combustibles to an equivalent of 5 minutes of the standard fire curve.

Recommendation j

See page 3 for recommendation on additional control of class

'B' combustibles.

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Trojan Nuclear Plant Document Control Desk Docket 50-344 August 12, 1988 License NPF-1 Page 46 of 53 C-FP-1.3.16 Revision 1 PAGE 46 OF 53 FIRE AREA T7 Lube Oil Room at Elev. 45-Ft Fire Hazard Analysis Section 2.3.7.7.1 of volume II of PGE-1012 and an analysis by WJE addresses the fireproofing of structural steel which provides a 2-hour fire-rated protection of steel supporting a portion of the 63-ft slab.

A sprinkler system provides additional protection.

The combustible loading given in the combustible loading table indicates much more than a 3-hour fire severity.

Additional Class

'A' combustibles equivalent to 5 minutes of the standard fire curve can be added in the Lube 011 Room (Room

96) without affecting this fire hazard analysis.

Program The Transient combustible Program controls the increase of Class

'A' transient combustibles to an equivalent of 5 minutes of the standard fire curve.

Recommendation See page 3 for recommendation on additional control of class

'B' combustibles.

FIRE AREA T8 Train A Switchaear Room at Elev 63-Ft Fire Hazard Analysis A. Section 2.3.7.8.1 of volume II of e;E-1012 and an analysis by WJE addresses the fireproofing of structural steel which provides a 2-hour fire-rated protection of steel supporting the roof slab.

Additional Class

'A' combustibles equivalent to 90 minutes of the standard fire curve can be added in the Train

'A' Switchgear Room (Room 107) without affecting this fire hazard analysis.

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Trojan Nuclear Plant Document Control Desh Docket 50-344 August 12, 1988 License NPF-1 Page 47 of 53 C-FP-1.3.16 Revision 1 PAGE 47 OF 53 B. A fire hazard analysis (File C-FP-1.3.9) has been performed to address the non-rated seals in the seismic gaps between the south wall and roof, and the turbine pedestal.

The analysis also address the less-than 3-hour seals in the seismic gaps between the floor and the turbine pedestal.

These seals are being upgraded to meet 3-hour fire-rated requirements.

The analysis takes credit for the low combustible loading in the switchgear room.

Additional Class

'A' combustibles equivalent to 5-minutes of the standard fire curve can be added in the Train A Switchgear Room without affecting the analysis.

Procram The Transient Combustible Program controls the increase of Class

'A' transient combustibles to an equivalent of 5 minutes of the standard fire curve.

Recommendations See page 3 for recommendation on additional control of class

'B' combustibles.

FIRE AREA Y1 Yard Area Fire Hazard Analysis Several fire hazard analyses for the A4/Y1, El/Y1, II/Y1, I2/Y1, I3/Y1, M3/Y1, M4/Y1 and Tl/Y1 boundaries take credit for low combustible loading in the yard areas next to unrated boundaries for these fire areas (See Files C-FP-1.3.1, C-FP-1.3.3, C-FP-1.3.17, and C-FP-1.3.18 and Volume II of PGE 1012).

Trojan Nuclear Plant Document Control Desh Docket 50-344 August 12, 1988 License NPF-1 Page 48 of 53 C-FP-1.3.16 Revision 1 PAGE 48 OF 53 Procram The Transient Combustible Program controls the increase of Class

'A' transient combustibles to an equivalent of 5 minutes of the standard fire curve for outside areas within 10 feet of the walls of the buildings at the 45-ft elevation.

Also, It does not control the increase of Class

'A' transient combustibles for area near the Intake Structure.

Recommendation Revise the program to control the increase of Class

'A' transient combustibles for outside areas within 10 feet of the Intake Structure, including the roof, to an equivt. tent of 5 minutes of the standard fire curve.

In addition, the program should control the increase of transient combustibles for areas within 20 feet of the entrancaa to Manhole Nos. 3 & 4.

j Also, see page 3 for recommendation on additional control of class

'B' combustibles.

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Trojan Nuclear Plant Document Control Deck Docket 50-344 August 12, 1988 License NPF-1 Page 49 of 53 C-FP-1.3.16 Revision 1 PAGE 49 OF 53

SUMMARY

OF RECOMMENDATIONS The following list summarizes the recommendations for ravising the Transient combustible Program.

ALL FIRE AREAS Control increases of Class

'B' combustible and flammable liquids, including outside areas within 10 feet of the exterior wall of the power block buildings and Intake Structure and areas within 20 feet of the entrances to Manhole Nos. 3 & 4.

The addition of combustible liguids storage lockers should be added to the Combustible Loading Table, FP-902.

The increase in transient combustible or flamsable liquids should be limited to 1 gallon over the amount shown in the combustible Loading Table for any location.

Piceways at Elev 37-FT 9-IN and Above Fire Area Al Pipeways and pipe chases at various elevations from 37 ft. to 77 ft. in Fire Area Al should be specifically identified in the program as ' Controlled Areas".

ELEV 45 PT Fire Area A4 Correct the program to exempt the sprinklered area east of DWMT instead of area east of TWMT.

Fire Area C14 Add control of Class

'A' transient combustibles in the new Remote Shutdown Panel Room.

Trojan Nuclear Plant Document Control Desk Docket 50-344 August 12, 1988 License NPF-1 Page 50 of 53 C-FP-1.3.16 Revision 1 PAGE 50 OF 53 Fire Area T1

• Add control of Class

'A' transient combustibles in the areas west of the hydrogen seal oil unit.

Also add control of Class

'A' combustibles in areas within 10 feet of the west exterior wall of the Turbine Building from Door #116 south to the Train A EDG Room and areas within 10 feet of the east exterior wall of the Turbine Building.

Fire Area M6 Control storage of combustibles in this fire area.

Fire Area il Add control of class

'A' transient combustibles to areas within 20 feet of tne entrances to Manhole Nos.

3 and 4 ELEV 61-FT Fire Area A4 Remove the exception for the I & C Shop in corridor, Room 256.

ELEV 75-FT Fire Area Al The Piping Facade area at elevation 75 ft. should be specifically identified as a "Controlled Area".

ELEV 7_l-EI Fire Area Al Revise to correct description for elev. 77-ft of the Auxiliary Building to read Filter Cells, Pipevay and Hut Valve Gallery instead of Domin and HUT Valve Gallery.

i i

Trojan Nuclear Plant Document Control Desk Docket 50-344 August 12, 1988 License MPF-1 Page h85 !$.16 C

1 Revision 1 PAGE 51 OF 53 Fire Area A4 Remove the exception for the Anti-C Storage just outside the HUT Valve Gallery.

Fire Area A4a Revise to correct description for elev. 77-ft of the Auxiliary Building to read Filter Valve Gallery instead of Domin Valve Gallery.

ELEV 93-FT Fire Areas A5 & A6 Add control of Class

'A' transient combustibles in Purge Exhaust Unit Room (Room 226) near the Containment wall.

Fire Area A7 Add control of Class

'A' transisnt combustibles in the Containment Access (Room 225).

ELEV 105-FT Fire Area Cl3 Add control of Class

'A' transient combustibles to the Mech, and H & V Equipment Rooms.

l l

ROOF ELEV.

Add control of Class

'A' transient combustibles on the Auxiliary, control, and Turbine Building roofs.

INTAKE STRUCTURE l

Fire Area Il l

Add control of Class-'A' transient combustibles in this fire area.

l

[

Trojan Nuclear Plant Document Control Desk l

4 Docket 50-344 August 12, 1988 e

License NPF-1 Page 52 of 53 C-FP-1.2.16 Revision 1 PAGE Si OF 53 j

Fire Area I2 Add control of Class

'A' transient combustibles in this fire area.

Fire Area I3 Add control of Class'A' transient combustibles in this fire area.

OUTSIDE THE INTAKE STRUCTURE IN FIRE AREA Y1 Add control of transient combustible at the elevation 23-ft deck where the traveling screen are located and on the roof of the intake structure.

FIRE AREA M3 Add control of combustible storage in this fire area.

FIRE AREA M4 Add Control of combustible storage in this fire area.

i

Trojan Nuclear Plant Document Control Desk Dochet 50-344 August 12, 1988 o

License NPF-1 Page 53 of 53 C-FP-1.3.16 Revision 1 PAGE 53 OF 53 CONCLUSIONS Based primarily on civil fire hazards evaluations, the fire areas at each elevation of the plant have been divided into two general categories.

These are either "CONTROLLED STORAGE" or "NO CONTROL OF CLASS

'A' COMBUSTIBLES".

For "CONTROLLED STORAGE" locations, it was determined that additional combustibles approximately equivalent to 5 minutes of the standard fire curve in any location will not affect the conclusions in the civil fire hazards evaluations.

In order to address the needs of the plant for performance of modifications, maintenance or operations, this limit can, in many cases, be modified for specific locations by using the specific limit given herein or by performing further evaluations.

Recommended changes to Procedure AO-10-15, Revision 0, "Transient Combustible Program", are provided in the previous summary.

Incorporation of these changes will enhance the fire protection provided for the plant.

These recommendations will be given to the Plant fire protection group for their consideration in the next revision of the program.

If there are cases where the storage limits needed to support the civil evaluations and the fire protection engineering recommendations are too restrictive to meet plant needs, several options for rr,eolution exist.

Methods which may be appropriate in specific instances are:

Revise certain analyses to remove consacvatisms associated with the risks of storage of transient combustibles.

Perform modifications to enhance fire protection which would reduce the risks associated with storage of transient combust l,71es Issue administrative procedures which would reduce the I

risks associated with storage of transient I

combustibles.

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TrojanNucleahPlant Document Control Desh Docku 20-344 August 12. 1988 1

Licesise NPF-1 Page 1 of 15 FILE C-FP-1.3.17 PAGE 1 of 8

(

FIRE HAZARD ANALYSIS OF MAIN TRANSFORMER AREA TROJAN NUCLEAR PLANT 25!94 Chk By' i Date T/'2s/S6 By Date yI i

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o GENERAL This is an in-depth evaluation of the effectiveness of the fire protection features, including the fire area boundary separation between Fire Areas Y1 and T1, in preventing a fire involving the transformers located in the yard area (Fire Area Y1) from affecting safety-related/ safe shutdown equipment located in the turbine building (Fire Area T1).

The justification for the fire protection features was previously based on the fire protection program description in the Fire Protection Plan Report, PGE 1012,, Volume I, Section 4.1.7.

The June 1986 QA Audit performed by TERA recommended, however, that fire area boundary evaluations be rewritten as fire hazard analyses with sufficient detail to accurately describe the fire area boundaries, suppression and detection equipment in the areas and any other pertinent mitigating factors.

The NRC GENERIC LETTER 86-10 and its attached "Interpretations" document allow evaluations which consider the effectiveness of the overall barrier whare portions of the fire area boundary do not totally conform to a 3-hour fire-rated configuration.

In compliance with this requirement, the evaluations performed herein will be retained and will be available for future NRC audits.

This evaluation has been prepared by an engineer who has over 16 years of experience, of which over 9 years has been in responsible charge of fire protection engineering work, and who meets the personnel qualification requirements specified in paragraph C.1.a. (5), Revision 2 of Branch Technical Position (BTP) CMEB 9.5-1.

ECOPE Perform and document a detailed fire hazard analysis addressing the items described in the preceding palagraph to show that the protection provided is equivalent to a 3-hour rated fire barrier.

The following criteria is considered in this evaluation:

1 I

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Trojan Nuclear Plant Document Concrol Desk Docket 50-344 4

August 12, 1988 i

License NPP-1

' Page 2 of 15 FILE C-FP-1.3.17 PAGE 2 of 8 CRITERION 1 Compare'the fire protection features provided for the i

transformers against the guidelines of Appendix A to BTP APCSB 9.5-1.

CRITERION 2 1

4 Evaluate the adequacy of the fire protection to protect safety related equipment located in the turbine building from the effects of a transformer fire.

Prepare sketches showing the physical configuration of Fire Areas Y1 and T1, document the distance and intervening combustibles 1

which exist between the transformers and safety-related equipment, and document the path a transformer fire would need to take in order to effect safety-rated equipment.

)

i CRITERION 3 Evaluate the effects,1f any, of a transformer fire on t

meeting the Appendix R separation requirements for redundant safe shutdown equipment.

i CRITERION 4 4

Evaluate the effects of any fire protection or detection systems in the fire areas.

4 FIRE RAZARDS ANALYSIS AND EVALUATION j

CRITERION 1 Appendix A states that buildings containing safety-related i

systems and have openings in exterior walls closer than i

50-ft from flammable oil-filled ~ transformers should be protected from the effects of a fire by: (1) closing the opening with a three-hour fire resistive seals (2) constructing a three-hour fire barrier betwee.. the transformer and the walls or closing the opening and providing the capability to maintain a water curtain in case of a fire.

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FILE C-FP-1.3.17 PAGE 3 of 8 As stated in Amendment 3 of PGE 1012, Volume I, Section 4.1.7,the main and substation transformers are within 50-ft of the north end of the west wall of the turbine building.

The turbine building contains several safety-related areas: the emergency diesel generator (EDG)

(Fire Areas T5 and T6); the Train A ESF switchgear rooms room (Fire Area T8); Train A safety-related cable trays above the elevation 69-ft slab (Fire Area T1); and the diesel and turbine-driven auxiliary feedwater (AFW) pump rooms and AFW control panel room (Fire Areas T2, T3, and T4, respectively).

The turbine building wall in the area of the transformers is described as precast concrete fire panels rated at 4-hour with certain features that degrade the wall.

The above description of the west wall is not completely accurate.

The west wall near the transformers is not a 4-hour fire barrier, but per.UBC Table 43-B, it qualifies as a 3-hour fire barrier.

A's shown in Sketch No.

1, the exterior west wall of the turbine building between elevations 45-ft and 63-ft is made of 6-inch thick precast concrete panels with approximately 1/2-inch to 3/4-inch gaps between panels.

The gaps are sealed with a non-rated caulk.

The wall between elevation 63-ft and 93-ft, from column 41 to 8-feet-6-inches south of column 59, is composed of a metal siding over 6-inch thick precast concrete panels, with the gaps sealed with 3-hour rated grout.

All other areas of the west wall are made of non-rated metal siding.

The features which degrade the 3-hour wall in the area of the transformers are, a row of windows above elevation 93-ft (not rated), louvtr openings at elevation 45-ft (not rated), the isophase bus penetration at elevation 82-feet-6-inches which is sealed, with a 3/8-inch thick aluminum plate around the outside of the bus ducts (not rated), and the end point of the fire rated coacrete panels above elevation 63-ft about 8-feet-6-inches south of main transformer X02.

The railroad bay roll-up door is not a UL-labled 3-hour rated door because the size of the door exceeds the maximum size for which UL-labled doors are available.

The door supplier has l

provided a UL-Certicate of Inspection which states that except for being oversized, the door complies with all other requirements for design, materials and construction.

Doors 113 and 116 are 3-hour rated doors.

Trojan Nuclear Plant Document Control Desk Docket 50-344 August 12 1988 License NPF-1 Page 3 of 15

Trojan Nuclear Plant Document Control Desk Docket 50-344 August 12, 1988 License NPF-1 Page 4 of 15 FILE C-FP-1.3.17 PAGE 4 of 8 At the present time, the railroad bay roll-up door is not functional and the louvers have been replaced by flood doors (See Sketch No. 2) to meet Moderate Energy Line Break (MELB) concerns.

A new roll-up door has been ordered to replace the old roll-up door.

As shown in Sketch No.

3, the flood doors are not fire rated because they are constructed of a sheet metal skin wrapped around a wood and styrofoam core.

The doors are designed to open outward if a circulating water line break occurs, so that the effracts of flooding in the turbine building is minimized.

Criterion 2 All the safety-related equipment located near the west wall of the turbine building in the vicinity of th4 transformers are enclosed in 3-hour fire rated barriers, i.e. EDG rooms and Train A ESF switchgear room.

As shown on Sketch No.

4, the nearest' safety-related equipment or cables not enclosed in a 3-hour fire barrier are the cables located above and below the elevation 69-ft slab near the east wall of turbine building (Fire Area T1) and in manhole #5 (Fire Area M6).

Also the normal Trains A and B EDG air intakes are located on the east wall of the EDG B room (Fire Area TS). No safety-related equipment is located at elevation 93-ft and above (Fire Area T1).

The alternate air intake for the Train A EDG is located on the south Wall of EDG A room (Fire Area T6).

The main and substation transformers are about 10-ft and 27-ft, respectively, from the west wall of the turbine building.

The southern most edge of main transformer XO2 is about even with the start of the flood doors.

~

Substation transformer XO6 is about 30-ft from the southern end of the railroad bay roll-up door.

The top of the body of the main transformers are at about the same elevation (elevation 63-ft) where the second row of concrete panels begin, see Sketch No. 5 for details.

Each transformer sets on a concrete pad that is surrounded by a 4 to 5-ft wide concrete pit or trench that is filled with rock.

The trenches are provided with 12-inch underground drains that are piped to the oil-water separator, located west of the administration building.

The concrete trenches and drains are designed to contain and remove transformer oil and water spraying from one of the transformer deluge systems. This feature will remove large amounts of oil and water and help to lower the oil and water level in the trench below the rock surface; thus, reducing the quantity of oil available to feed the fire.

With less oil available to burn, the duration and intensity of the fire is minimized.

Trojsn Nuclear Plant Document Control Desk Docket 50-344 August 12 1988 License NPF-1 Page 5 of 15 FILE C-FP-1.3.17 PAGE 5 of 8 The 3-hour fire barriers between transformers are arranged such that a fire involving one transformer will not propagate to another transformer, nor will the fire be able to threaten both the railroad bay area (room no.84) and the condenser area south of EDG A room (room no.85) at the same time.

Each transformer is protected by an automatic deluge system which is actuated by heat actuation devices (HAD's).

There are hose stations in the turbine building and fire hydrants in the yard for manual fire fighting.

Also, the transformer area is loc ated in a highly visible area where plant personnel pass by.

A fire involving a transformer will be detected in a timely manner, allowing the deluge system and the fire brigade to fight and extinguish the fire.

To protect safety-related equipment from a transformer fire, the plant fire protection features would need to protect against the following situations (see Sketch Nos. 6 and 7):

1) A transformer fire propagating through the west wall of the turbine building, traveling through the railroad bay (room no. 84), and passing through the non-rated wall into the N/S corridor (room no. 83),

where the normal EDG air intakes and the steel manhole cover for manhole #6 are located.

2) A transformer fire propagating through the west wall of the turbine building and traveling east through the condenser area (room no. 87) to the area above and/or below the 69-ft slab, where the nearest safety-related equipment (cables) are located.

In the first situation, there are several fire protection and plant layout features which would prevent a transformer fire from affecting safety-related equipment.

Besides the trenches, deluge systems, distances between the transformers and the west wall of the railroad bay, and the manual fire fighting capabilities, the railroad bay is provided with an automatic wet-pipe sprinkler system (System BE).

Though the combustible loading is 2

high (160,000 BTU /FT, the sprinkler systeg is designed for an extra hazard density of 0.30 GPM/FT.

The east wall of the railroad bay is a cement plaster wall with one non-rated single 3-ft X 7-ft door and one non-rated roll-up door, both normally kept closed.

Gprinkler system BE also protects the N/S corridor (room no. 83).

Trojan Nuclear Plant Document Control Desk Ncket 50-344 August 12, 1988 License NPF-1 Page 6 of 15 FILE C-FP-1.3.17 PAGE 6 of 8 Thecop)ustibleloadingintheN/Scorridorislow(10,000 BTU /FT consisting mainly of cable trays. Manhole #6 is located below ground underneath the N Except for the steel manhole cover separ/S corridor.

ating the manhole from the N/S corridor, manhole #6 (Fire Area M6) is separated from all other areas of the plant by 3-hour fire barriers.

A curb is provided around the manhole cover to prevent liquid spills from entering the manhole.

In order for a transformer fire to affect any safety-related equipment, the fire must propagate a long distance past the transformer deluge system and trench, through a sprinklered area and a non-rated wall into the N/S corridor, which is also provided with a wet-pipe sprinkler system.

This situation is judged to not be a credible fire scenario.

For the second fire situation, there are also several fire protection and plant layout features which would prevent a transformer fire from affecting safety-related equipment in the turbine building.

Besides the trenches, the transformer deluge systems, the west wall, and manual fire fighting capabilities, there are long distances and many obstacles the fire must pass to reach the safety-related equipment (cables) located above and below the elevation 63-ft slab at the northeast and of the turbine building.

As described previously, a transformer fire will be detected in a timely manner so that the fire brigade can be dispatched to help extinguish the fire.

If the transformer fire were to breach the west wall of the turbine building, either through the non-rated penetrations, the non-rated caulk-filled gaps between the concrete panels, or via the flood doors openings, the fire brigade will be there to p', event the fire from spreading east towards the safety-related cables.

The amount of transformer oil that could enter the turbine building is limited by the number and size of any openings located in the west wall.

The only possible way the oil could enter the building is through the louver / flood door openings, but the amount of oil entering through these openings would be limited because of the nature, size, and location of the openings.

In addition, the flood doors are normally kept closed.

The door openings aro 2-feet-6-inches high and located just south of the transformers approximately 6-inches above the ground.

Any oil entering the building would be confined to an area near the west wall.

Most of the oil would flow down through the grating into the concrete pits located near the condensers.

Also, there are drains located in the area northeast of column 59.

The closest insitu

Trojan Nuclear Plant Document Cont [ol besk~

Mcket 50-344 August 12. '988 License NPF-1

~

Page 7 of 15 FILE C-FP-1. 3.17 PAGE 7 of 8 i

t i

e combustible located in the turbine building near the west wall are non-safety-related cable trays.

These cables i

trays do provide a path for the fire to propagate the i

approximately 50-ft east towards the safety-related cables, but the cables will not readily ignite unless the fire is close and intense enough to reach the cable trays.

Once the oil fire is extinguished, any cable fire that might be still burning would be a slow burning, low-heat producing fire, which would allow plenty of time for the fire brigade to extinguish the fire before the i

fire would reach the safety-related cables.

In addition, the area south of the EDG rooms is protected by two automaticwet-pipesprinklersystems(SystemsBEandGg.

Both are designed to provided a density of 0.30 GPM/FT.

These sprinkler systems will help control and extinguish any fire that might threaten the safety-related cables.

Considering all the fire protection features and obstacles a transformer fire has to overcome in order to affect i

safety-related equipment in the turbine building, the fire protection is judged equal to providing a 3-hout fire i

3 barrier at the west wall of the turbine building.

criterion 3 Some of the safety-related equipment / cables mention in the criterion 2 evaluation above (i.e., the safety-related a

cables located above and below the 69-ft slab, EDG normal I

air intakes, and cables in manhole #6) are alto safe j

shutdown equipment.

Since it has be demonstrated in the i

previous criterion evaluation that none of this safe shutdown equipment will be affected by a transformer fire, then the redundant shutdown equipment will be available to l

ensure safe shutdown of the plant.

Criterion 4 i

As previously discussed in criterion 2 evaluation above, each transformer is provided with automatic deluge system actuated by RAD's.

Also trenches are provided around each transformer to control and remove oil spills away from the transformer area and the west wall of the turbine building.

Automatic wet-pipe sprinkler systems BE and G are provided to protect the railroad bay, the N/S corridor, and the condenser area peuth of the EDG room; at elevation 45-ft.

Systga BE is designed to provided a density of 0.30 GPM/FT for the most remote 2500 FT of floor area, and Systos G is designed to provide a density of 0.30 GPM/FT' Jor the most remote 3,000 FT2 of floor area.

As baanup to the automatic sprinkler systems, hose stations and portable fire extinguishers are

Trojan Nuclear Plant Documsnt Control Dask Ncket 50-344 August 12. 1988 License NPF-1 Page 8 of 15 FILE C-FP-1.3.17 PAGE 8 of 8 located in the turbine building, and fire hydrants are located in the yard area near the transformers.

Except for the' railroad bay, the combustible idading in the above areas are low to moderate.

The railroad bay combustible loading is high.

Even when considering the high combustible loading in the railroad bay, the automatic and manual fire protection is adequate to protect safe-related/ safe shutdown equipment.

CONCLUSIONS The above evaluations show that it is extremely unlikely a transformer fire will propagate through the west wall of the turbine building to the areas where safety-related/ safe shutdown equipment is located.

the fire protection features provided will successfully prevent a transformer fire from affecting this equipment, thus, ensuring that safe shutdown systems will ro.. sin free of fire damage.

Since PGE 1012 Report has incorrectly stated that the west wall of the turbino building in the vicinity of the transformers is 4-hour rated, the following changes are recommended

1) Replace the non-rated caulk in the gaps, between the concrete panels at elevation 45-ft between column 41 to door 116, with 3-hour rated sealant ('

'ut).

2) Revise PGE 1012 to indicate that the wall

. 3-hour rated,not 4-hour, and reference this eveluation in the report.

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Trojen Nucioar Plant Document Control Dask Do(kot 50-344 August 12. 1900 License NPF-1 Page 1 of 5 PAGE 1 0F 5 s

C-FP-1.3.11 FILE C-FP-1.3.11 CIVIL EVALUATION OF THERMO-LAG 330 CABLE WRAP (FIRE BARRIER) SYSTEMS TROJAN NUCLEAR PIANT eeee******eeeeeeeeeeeeeeeeeeeeeeeeeeeeeeeeeeeeeeeeeeeeeeeeeeeeeee.

By 4Date 5/15df Chk By 3d1 Date 5/ 9/88 m_

II

/

/

GENERAL The purpose of this evaluation is to demonstrate the une of appropriate details and installation methods for cable wrap fire barriers.

NOTE:

This evaluation has been prepared by an engineer who has over 16 years of experience, of which over 9 years has been in responsible charge of fire protection engineering work, and who meets the personnel qualification, requirements specified in paragraph C.1.a.(5), Revision 2 of Branch Technical Position (BTP) CMEB 9.5-1.

l Thermo-.ag 330 Cable Wrap (Fire Barrier) Systems are used at l

Trojan to provide 1-hour ar.d 3-hour fire-rated harrier protection for conduits, cable trays, electrical pull-boxes, l

electrical terminal boxes, an HVAC fan, containment electrical cable penatration boxes, and associated supports.

As shown in the attached drawings and sketches, Thermo-lag l

wrap is installed in the Auxiliary, Fuel, control, containment, and Turbine Buildings, outside in the electrical penetration area, and in the Intake Structure.

The 3-hour fire-rated cable wraps are provided to meet the requirements of section III.G.2.a of Appendix R to 10CFR 50 to enclose one train of safe shutdown cables which are in the same fire area as the cables for the redundant train.

The 1-hour fire-rated cable wraps are provided to meet the requirements of Section III.G.c of Appendix R to 10CTR 50 (or as described in an exemption request) to protect one train of safe shutdown cabins which are in the same fire area as the cables for the redundant train, some 1-hour fire-rated cable wraps are provided to meet the requirements of Section III.G.2.f of Appendix R to 10CFR 50 for noncembustible radiant energy heat shields between redundant trains of safe shutdown cables inside the containment (See File C-FP-1.3.15).

Trojan Nucicar Plant Docu: nt Control Disk Docket 50-344 August 12, 1988 License NPF-1 Attechment 9 Page 2 of 5 PAGE 2 0F 5 i

C-FP-1.3.11 DETAILS Civil evaluations of the specific fire endurance and hose stream tests, including the test reports, which documents the 1-hour and 3-hour fire barrier protection provided by the Thermo-lag wrap are filed under File C-FP-1.1, Items 24, 25, 36, 37, and 38.

Because plant conditions are not always conducive to installing the Thermo-lag wrap to the exact tested configuration, variations from the exact tested configurations were sometimes necessary, but the wrap installations were designed using engineering judgement to best fit the tested configurations.

The variations were either discussed with the manufacturer and/or American Nuclear Insurers (ANI), or justified by PGE Engineering, to ensure that the installed configuration could be considered either as 1-hour or 3-hour fire barriers.

Miscellaneous correspondence with the manufacturer and ANI, Field Change Notices, and Nonconformance Report documentation are attached.

INSTALLATION REOUIREMENTS The Thermo-lag wrap is installed per attached Thermal Science, Inc. (TSI) Thermo-lag 330 F ce Barrier System Insta11atior Precedure Manual.

Typical details are shown on drawing C-2l\\SO.

SUPPORTS Supports are ertpped with Thermo-lag as necessary to ensure that the ptrticular itsm wrapped would not collapse due to e fire.

The supports for 3-hour fire-rated wraps are wrapped.

In some casos the supports for 1-hour fire-rated wraps are not fully wrapped.

In these cases, the support is wrapped in the vicinity of the cable wrap to prevent excessive heat from being transmitted through the support steel, to the wrapped cables.

Calculations have been performed to show that the structural integrity of the supports would be maintained during exposure to a 1-hour fire.

Copies of these calculations are attached.

The supports are also checked to make sure they can handle the additional weight of the Thermo-lag wrap during all design conditions, including seismic loads.

Trojan Nuclear Plant Documont Control D2sk Docket 50-344 August 12, 1900 1,1conse NPF-1 Page 3 of 5 PAGE 3 OF 5 C-Fp-1.3.11 OTHER DESIGN CONDITIONS l

In some of areas, the Thermo-lag wrap may be subjected to

(

radiation, Loss of Coolant Accident (LOCA) conditions, and outdoor weather.

Where the wrap is exposed to rain, Thermo-lag 350 Two Part Spill Resistant Topcoat was applied to the exterior surfaces of the Thermo-lag wrap.

Studies and tests have been conducted on the Thermo-lag wrap and it has been shown that the wrap's ability to perform as a 1-hour or 3-hour fire barrier is not affected by these conditions.

Documentation on the studies and tests are attached.

Checks are made to ensure that the Thermo-lag wrap will not affect the performance of the item being wrapped.

The ampacity is checked by electrical branch to ensure that the Thermo-lag does not derate the electrical cables below the required am evaluation.pacity.

This check is not part of this 1

PENETRATING CONDUIT 1

Conduits which penetrate the Thermo-lag wrap envelope around cable trays, terminal boxes, and pull-boxes are not required i

to be internally sealed.

Internal conduit seals have not been discuused in any of the referenced documentation; however, this evaluation addresses the possibility that some smoke and hot gases could enter the wrapped item via a penetrating conduit.

Conduits which penetrate the wrap are also wrapped with tha Thermo-lag material out to a minimum distance of 18-inches i

from the outer surface of the wrap envelope.

Conduits that penetrate the Thermo-lag wrap envelope are not normally open at the end opposite the one penetrating the wrap, or if it is, the open and of the conduit is far removed from the Thermo-lag wrap.

The cables within the wrap envelope are 1

not, therefore, exposed directly to smoke and hot gases traveling from a fire through an open conduit.

The EMT conduits which penetrate the wraps will withstand a fire without losing structural integrityt however, the air and cables inside the exposed portion of the conduit would become hot during a fire.

It is judged that there would not be enough heat transmitted by heated cables and air inside the conduits to have a significant effect on the protection provided by the cable wrap.

ITEMS ABOVE CABLE WRAPS t

This matter is addressed in File C-FP-1.3.12.

I

Trojan Nuclear Plant Docusant Control Dask Dockst 50-344 August 12, 1980 License NPF-1 Attachm3nt 9 Page 4 of 5 l

PAGE 4 0F 5 C-FP-1,3.11 i

CONCLUSIONS In all cases, the Thermo-lag cable wrap installed at Trojan provides 1-hour and 3-hour fire barrier protection to ensure thht the item wrapped will not be adversely affected by a fire.

Using Thermo-lag Cable Wrap Systems is an acceptable method for protecting safe shutdown cables and electrical boxes from the affects of a fire, and the wrap provides an adequate method for meeting the requirements of Appendix R to 10CFR 50 for separation of redundant safe shutdown trains in the same Fire Area.

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Trojan Nuclear Plant Docu2cnt Control Desk

. Docket 50-344 August 12. 1988 j

License NPF-1 Pago 5 of 5 PAGE 5 OF 5 C-FP-1.3.11 J

I i

LIST OF ATTACMMENTS_

1.

Thermal Science, Inc. (TSI) Technical Note 20684, 4

Revision 3, Thermo-lag 330 Fire Barrier System Installation Procedure Manual-Nuclear Plant Application.

Industrial Testing Laboratories Report No. 82-355-F-1, 2.

Ampacity Test for 600-volt Power Cables in an Open Top Cable Tray Protected by the Thermo-lag 330-1 Subliming Coating Envelope System, s

3.

Southwest Research Institute Report No. 01-6763-202, Fire Resistance of Irradiated Thermo-lag 330-1, 4.

TSI Technical Note 10280, Kvaluation of the Weathering Characteristics of Thermo-lag 330-1 Subliming Compound As Applied to Metal substrates.

5.

TSI's "LOCA Qualification Summary" of Thermo-lag 330-1 Subliming Fire Barrier System Material.

6.

TSI Technical Note 71880, Thermo-lag Subliming Compounds Reference List of Selected Approvals from Independent j

Testing and Underwriting Agencies.

7.

Miscellaneous Correspondence, Field Change Notices, and Nonconformance Report Documentation.

I 8.

Drawings and sketches of Thermo-lag cable. Wrap installations at Trojan.

9.

Calculation Nos. TC-259 and TC-311.

1 1

]

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Trojan Nuclear Plant Documant Control Desk Docket $0-344 August 17 1988 License NPF-1 0 Pare 1 of 11 FILE C-FP-1.3.6 PAGE 1 of 5 FIRE HAZARDS ANALYSIS OF OPEN PIPE CHASE BETWEEN FIRE AREAS Al AND A2 TROJAN NUCLEAR PLANT

• • • eeeeeeeeeeeeeeeeeeeeeeeeee******eeeeeeeeeeeeeeeeeeeeeeeeeense Date d d M By

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GENERAL This is an in-depth evaluation of the fire protection provided by the open RHR pipe chases between fire areas Al and A2.

The justification for the open chase between fire areas was previously based on the general description in section 2.3.1.2.2 of the Appendix R Review Report.

The June 1986 QA Audit performed by TERA recommended, however, that fire area boundary evaluations be rewritten as fire hazard analyses with sufficient detail to accurately describe the fire area boundaries, combustible loadings, separation of redundant equipment, suppression and detection equipment in the areas and any other pertinent mitigating factors.

The NRC GENERIC LETTER 86-10 and its attached "Interpretations" document allow evaluations which consider the effectiveness of the overall barrier where portions of the fire area boundary do not totally conform to a 3-hour fire-rated configuration.

In compliance with this requirement, the evaluations performed i

herein will be retained and will be available for future NRC audits.

This evaluation was primarily prepared by Civil Engineeringt however, input for fire detection and suppression was provided by R. J. O'Laughlin of Professional Loss Control (PLC).

The fire protection engineer review of this evaluation was also performed by Mr. O'laughlin.

Electrical Engineering provided an attached evaluation of safe shutdown equipment and cables in the vicinity of the fire area boundary.

4 4

i

Trojen Nuclear Plant Document Control Desk Docket 50-344 August 12, 1988 License NPF-1 0 E

FILE C FP-1. 3. 6 PAGE 2 of 5 SCOPE Perforr and document a detailed fire hazards analysis addressing the items described in the preceding paragraph to show that the adequate protection is provided so that a single fire will not propagate from safe shutdown equipment in one area to redundant safe shutdown equipment in the other area.

This may be done by demonstrating that the existing condition is equivalent to the protection which would be provided by a 3-hour rated barrier alone.

The following criteria are considered in this evaluation:

CRITERION 1 Describe the need for separation of safe shutdown systens to meet requirements of Appendix R.

CRITERION 2 Prepare sketches showing the physical configuration of the pipe chases and document the distances and intervening combustibles which exist between the redundant safe shutdown equipment or cables.

Document a fire hazards analysis to compare the protection provided to that which would be provided by a 3-hour fire rated barrier.

CRITERION 3 Evaluate the effects of any the detection systems in the area.

FIRE HAZARDS ANALYSIS AND EVALUATION CRITERION 1 The attached electrical evaluation shows that adequate fire protection is required to prevent a fire from propagating from an RHR system in either fire area to the RHR system on thu opposite side of the pipe chase wall.

Protection is also required from a fire originating in the pipe penetration area at elevation 57 ft. and propagating down both pipe chases to the RNR pump rcoms below.

CRITERION 2 Redundant RHR eqJipment and cables are contained in the adjacent RHR rooms at elevation 5 ft. in the Auxiliary Building.

The RHR rooms are in separate fire areas Al and A2 with boundaries meeting the requirements for a 3-hour fire-rating except for open vertical pipe chases which connect the areas.

The attached sketches (sheets A-1 thru A-6) show the configuration of the open pipe chasis.

TrO an~ Nuclear Plant Documsnt Cont rol Desk Docket 50-344 August 12. 1988 License NPF-1 At t ac hrne nt 10 Paac 3 of 11 i

FILE C-FP-1. 3. 6 PAGE 3 of 5 l

Redundant safe shutdown pipe and valves are also located in the pipe penetration areas (rooms 185a & 185b) at elevation $7 ft.

As described in section 3.3.1 of volume 4

II of PGE 1012, fire damage to water-filled pipe and valves is not considered probable.

This is especially j

true in this area because of the low combustible loading.

The pipe chase divider wall is a nominal 14 inch thick masonry wall of 3-hour fire-rated construction.

The wall is continuous from elevation 5 ft. to elevation 57 ft.

All penetrations through the divider vall up to elevation 49 ft. are sealed with 3-hour rated penetration seals.

Two open pipe penetrations exist in the top 12 ft. of the wall.

The divider wall, therefore, provides equivalent to a 3-hour fire-rated protection from propagation of a fire between the RHR rooms or between the adjacent vertical pipe chases.

The insitu combustibles loading in the RF" rooms is shown to be very low (less than 6000 BTU's per oguare foot), and there are no in-situ combustibles in the vertical pipe chases.

Transient combustibles in the pipe chases could consist of possibly a small amount of scaffolding material or radcon material.

If a fire were to exist in either of the RHR rooms, a small amount of smoke and hot gasses would be expected to rise up the open pipe chase into the upper elevations of Fire Area Alt however, the fire would not be expected to propagate up through the chase.

The insitu combustible loading in the two pipe penetration areas (rms 189a and 189b) is 3500 BTUs/SQ FT and 2200 i

BTUs/SQ FT, respectively.

Some amounts of transient j

combustibles (scaffolding & radeon materials) may be present in the pipeways south of the radiation barrier fence.

If a fire were to start in the pipe penetration areas at elevation 57 ft., the fire would be confined to I

the areas south of the radiation barrier fence.

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Trojan Nuclear Plant Document Control Desk Docket 50-344 August 12, 1988 License NPF-1 0 Page 4 of 11 FILE C-FP-1.3.6 PAGE 4 of 5 For a fire to propagate from one RHR pump room to the other, it would have to rise from the top of the RHR room up 34 feet through the pipe chase on one side and then back down 34 feet through the pipe chase on the other side to the top of the other RHR room.

The lack of combustibles in the chases, the distance a fire would have to propagate and the configuration of the chases is judged to make this scenario for fire propagation not credible.

For a fire to propagate from the pipe penetration area to the RHR pump rooms, it would have to travel through the radiation barrier fence and down both pipe chases to e: 2 vatic n 5 f t.

below.

All of the combustible material in the pipe penetration areas is either setting on grating approximately 4 to 5 feet south of the fence or located off the grating several feet south of the fence.

The lack of combustibles in the pipe chase areas north of the fence and the fact that the closest combustibles (radcon material) are setting on the grating away from the fence, makes the propagation of a fire from the pipe penetration area to the RHR pump rooms not a credible fire event.

The configuration between fire ar"'s Al and A2, therefo e, provides protection against a fire ;ropagating from safe shutdown equipment in one arca to redundant safe shutdown equipment in the other area which is equivalent to the protection thich would be provided by a 3-hour rated barrier alone.

CRITERION 3 Fire protection for each RHR room consists of an early warning smoke detection system.

Each room is provided with one ionization type smoke detector that will detect invisible and visible particles (aerosols) of combustion.

Area coverage for each detector is approximately 350 sq.

ft.

The smoke detectors are on separate initiating device

(

circuits which connect to the same zone panel, KZ1u6-13.

These circuits are electrically monitored for a single ground fault and open circuit conditions.

In addition to the smoke detection system in the RHR pump rooms, these fire areas are provided with manual hose l

ststions and portable fire extinguishers.

Based on the small amount of combustible material in the RHR rooms and I

pipe penetration areas, the fire protection is adequate to l

protect safe shutdown equipment.

l 1

Trojan Nuclear Plant Document Control Desk Docket 50-344 August 12, 1988 License NPF-1 0 l

Page 5 of 11 FILE C-FP-1.3.6 l

PAGE 5 of 5 l

C @ CLUSIONS i

The above evaluation shows that fire propagation up and down through the open RHR pipe chases between fire areas Al and A2 is not credible.

The fire protection is, therefore, equivalent to that which would be provided by 3-hour fire-rated barriers required by Appendix R.

Although a fire-rated barrier in the pipe chase is possible, it is considered undesirable because it would affect HVAC in the area and access to the pipe chase.

Since a new fire barrier in the chase would not enhance the fire separation between areas, no modifications are planned and the existing condition is considered acceptable.

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Trojan Nuclear Plant Document Control Desk Docket 50-344 August 12, 1988 License NPF-1 1 Page 1 of 25 C-FP-1.3.10, PART 1 I

PAGE 1 OF 3 FILE C-FP-1.3.10, PART 1 CIVIL EVALUATION OF FIRE DOOR INSTALLATIONS TROJAN NUCLEAR

• • • • • • • • • • • • • • • • • • • • • • • • • • • • • • • • • • • • • • • PLANT

• • • • • • • • • • • • • • • • • • w********

M A Date w3Me8 By Ch u y Date it

//

GENERAL The purpose of this evaluation (Part 3) is to document the in-depth evaluation of Trojan fire door installations with respect to the requirements of NFPA 80-1979.

Two memorandums, MRG-9-87M and MRG-10-87M, contain previously documented deviations from NFPA-80 requirements, and are included as part of this evaluation.

Part 2 of the evaluation addresses the criteria used for the Plant's fire door inspection and maintenance program used to ensure the fire doors are maintained within acceptable criterir.

Three-hour and one and one-half hour fire doors are installed in fire barriers that are provided to meet the requirements of Appendix A to Branch Technical Position (BTP) APCSB 9.5-1 and Appendix R to 10CFR 50.

There is one 3/4-hour fira door for the CVCS Conc. Pump Room (Room 266), but this deor is not required to meet Appendix A or Appendix R.

The NRC GENERIC LETTER 86-10 and its attached "Interpretations" allow evaluations which consider the effectiveness of the overall barrier where portions of the fire area boundary do not totally conform to a 3-hour fire-rated configuration.

In compliance with this requirement, the evaluation performed herein will be retained and will be available for future NRC audits.

The original comprehensive evaluation / survey of fire door installations was done in 1984.

The evaluation was done by NPE Civil Branch engineers and Professional Lons Control, Inc. (PLC) personnel, and the results were evaluated by a qualified fire protection engineer, Robert J. O'Laughlin of PLC.

Trojan Nuclear Plant Document Control Desk Docket 50-344 August 12, 1988 License NPF-1 1 Page 2 of 25

?

C-FP-1.3.10, PART 1 i

PAGE 2 OF 3 i

SCOPE Discuss the requirements for Trojan fire doors.

Document the comprehensive survey and evaluation of the fire door installations that was done in 1984 including evaluations in NCR 84-44.

Include memorandums, MRG-9-87M and MRG-10-87M, which contain resolutions of the deviations from NFFA 80-1979, including the justifications for deviations which were judged acceptable to leave "as-is".

EVALUATION Recuirements for Troian fire doors Volume I of PGE-1012 addresses compliance with the guidelines of Appendix A to Branch Technical Position BTP APCSB 9.5-1, which requires fire doors to comply with NFPA 80, "Fire Doors and Windows".

An exception to the BTP was taken in that doors are not locked or alarmed for fire protection purposes.

Doors are rated equivalent to the barrier rating except that PGF-1012 states that stairwell acceos doors are 1-1/2 hour fire-rated.

For information, a copy of NFPA 80 - 1979 is attached under Tab 5, and a copy of UL 63 -1976 is under Tab 6. As backup to this evaluation, work sheets and marked-up copies of i

docunents related to door requirements are attached under Tab 8.

j Original fire doors were required to be labeled (by Underwriters' Laboratories Inc.) and were installed to the i

requirements of the F04 contr&ct.

Doors added to barriers being upgraded to fire barriers have been specified to be labeled, 3-hour fira-rated decrs, i

Efra Door Survav/ Evaluation to NFPA 80 A comprehensive survey and evaluation of the fire door installations at Trojan with respect to the requirements of NFPA 80-1979 was done in 1984.

All deviations from NFPA 80 were documented, evaluated, and resolved in NCR 84-044.

The deviations were resolved by modifications, as appropriate, or by engineering evaluations.

For those deviations that were judged to not affect the door's function as a fire door, justifications were provided for using the door "as-is".

The results of the evaluation, including all the resolutions and justifications were evaluated by a qualified fire protection engineer, Robert J. O'Laughlin of PLC.

As backup to this evaluation, the survey results are included undet-Tab 3, and the NCR 84-44 with the fire protection engineer review documentation is attached under Tab 4.

l

Trojan Nuclear Plant Document Control Desk Docket 50-344 August 12, 1988 License NPF-1 1 Page 3 of 25 C-FP-1.3.10, PART 1 PAGE 3 OF 3 Clarifications of AcceDtable Fire Door Conditions Some conditions which may deviate from NFPA 80 requirements have been determined to be acceptable for fire doors in the plant.

Memorandums MRG-9-87M and MRG-10-87M provide clarification and justification of these conditions.

These memorandums are attached to, and are considered as an integral part of this evaluation.

The signatures on this evaluation indicate acceptance and review of the criteria contained in these memos.

By resolving the deviations to NFPA 80, the fire rating of the doors is maintained.

The existing fire doors will provide the necessary fire protection desired os part of those fire barriors used to meet the requirements of Appendix A and Appendix R.

Fire Door Maintenance Procram Maintenance Procedure HP-12-9, (Revision 0 is attached under Tab ?), provides instructions for inspection of plant fire doors to verify that the doors and associated equipment operato properly and still meet tha requirements of NFPA 80.

The enginearing evaluation of this procedure is provided in PART 2 of this evaluation.,

CONCLUSION The fire doors at Trojan are shown to meet the intent of NFPA 80.

The doors are properly mair.tained, and qualify as rated fire doors in fire barriers that are used to meet the requirements of Appendix A to the BTP and Appendix R to 10CFRSO.

I

Trojan Nuclear Plant Document Control Desh g.t Dochet 50-344 August 12, 1988 License NPF-1 1 Page 4 of 25 Page 1 MEMO 1

To:

R. Q. Reinhardt MRG-9-87M FROM:

M. Gandert DATE:

September 22, 1987

SUBJECT:

TROJAN NUCLEAR PLANT Requirements for Fire Doors A memo (CHB-124-87) to the Plant Review Board, describes several fire door problems which have recently been identified.

Identification of problems with fire doors is not a new issue.

In 1984 many problems were identified and resolved by NPE as documented in nonconformance report NCR 84-44.

There may be several reasons for identification of the recent problems.

First, plant personnel are taking a more active roll in compliance with fire protection requirements.

Second, it is aifficult to determine which requirements should be applied to fire doors at Trejan.

Third, people make different interpretations of the requirements.

Fourth, it is often difficult to maintain and upgrade fire doors while meeting differing and sometimes contradictory requirements for access, security and fire protection.

This memo provides clarification of the requirements to be used by PGE for swinging, hollow metal fire doors at Trojan.

It is intended to promote consistent and uniform quality in fire doors without having to replace dcor assemblies unnecessarily.

The guidance provided herein can be used in maintaining and upgrading Trojan fire doors and in evalukting when a fire door can be considered in compliance with the requirements.

The general design requirements for fire doors can be found in PGE-1012 "Fire Protection Planh and in NPE-1 "Fire procaction Design Bases as follows:

Section 4.1.9 of Volume I of PGE-1012 states that fire barriers are evaluated in accordance with guidelines of Appendix A to Branch Technical Position APCSB 9.5-1.

Guideline D.1(j) of the BTP states in part, Door openings should be protected with equivalent rated doors, frames and hardware that have been tested and approved by a nationally recognized laboratory......

(Refer to NFPA 80, ' Fire Doors and Windows.')

Trojan Nuclear Plant Document Control Desh Docket 50-344 August 12, 1988 License NPF-1 1 Page 5 of 25 j

Page 2 Doors shall be Section 2.1.3.3.2 of NPE-1 states in part, installed in accordance with NFPA 80.

Doors are to be installed I

in accordance with their listings, using listed hardware and door frames."

"..... A detailed Section 2.1.3.3.3 of NPE-1 states in part, review of existing plant fire doors was conducted as part of the Appendix R evaluation.

Where door installations deviated from NFPA 80, the deviations were justified or the doors were upgraded."

From the above listed design requirements, it can be seen that, while Trojan fire doors are intended to meet NFPA 80 guidance, verbatim compliance with the NFPA 80 standard is not required.

Plant requirements for doors, including numerous security requirements, make strict compliance with NFPA 80 difficult and impractical.

Therefare, minor deviations from the NFPA requirements which can be judged not to have a significant effect on the fire-rating of the door are allowed.

The evaluations for these minor deviations are documented in generic or specific evaluations.

Many of these minor deviations were previously identified by

$onconformance report (NCR) number 84-44.

The attachments to the

.<CR contain justifications for the use-as-is dispositions.

Deviations from the requirements for fire door assemblies which have been determined to be acceptable in certain cases are as follows:

1.

NO DOOR LABEL Condition Fire door does not have a nationally recognized laboratory label (such as a UL label) attached.

Acelication Applies to fire door number 89 does not have a label per NCR 84-44.

Applies to fire doors 148, 156, 179, 181, 186, 187, 190, 194, j

200, 359, 360, 427, 428 and 429 Which were originally tagged l

with mylar labels were permanently tagged per NCR 86-001.

l Acceptance Door number 89 with a missing label was accepted by NCR 84-44.

All new fire doors are required to be labeled.

Trojan Nuclear Plant Document Control Desk Docket 50-344 August 12, 1988 License NPF-1 1 Page 6 of 25 Page 3 i

Justification A complete fire door survey was performed in 1984.

Fire doors which were not originally constructed as fire doors have been replaced with labeled fire doors.

Any door used as a fire door which had been determined to be designed and constructed as a fire door but which no longer had a label attached was accepted

)

as a qualified fire door.

If a label is found to be missing from an existing fire door other than the doors described above, Nuclear Plant Engineering should be asked to perform an evaluation.

2.

NO DOOR FRAME LABEL condition Fire door frame does not have a nationally recognized laboratory label (such as a UL label) attached.

Application Applies to fire door numbers 41, 42, 45, 61, 62, 63, 64, 91, 116 and 170 have missing frama Itbels ptr NCR 8 4-44.

Applies to fire door frames 148, 176, 179, 181, 186, 187, 190, 194, 200, 359, 360, 427, 428 and 429 which were originally tagged with mylar labels were permanently tagged per NCR 86-001.

Aggentance Door numbers 41, 42, 45, 61, 62, 63, 64, 91, 116 and 170 with missing frame labels were accepted by NCR 84-44.

All new fire door frames are required to be labeled.

Ingtification A complete fire door survey was performed in 1984.

Justification for the acceptability of certain existing frames I

was documented by a qualified fire protection engineer from l

Professional Loss Control, Inc. (PLC) by comparison of construction details for unlabeled frames with that specified in i

i UL 63 and by consideration of the combustible loading in the fire areas protected by the doors.

If a label is found to be missing from an existing fire door frame other than the frames described above, Nuclear Plant Engineering should be asked to perform an evaluation.

t l

l i

_ _ _ _ _.,... _. _ _ _. _.. ~ _. _. _, _ _ _,.. _.. _ _ _ _ _ _.. _ _ _ _ _ _, _

Troje.n Nuclear Plant Document Control Desk Docket 50-344 August 12, 1988 License NPF-1 1 Page 7 of 25 Page 4 3.

NO CLOSING DEVICE LISTING MARK Condition During the 1984 fire door survey, it was determined that door closers do not have nationally recognized laboratory listing marks.

Apolication Applies to all new and existing fire door closers.

Accentance Unlisted door closers are acceptable.

Zugrification Justification for the acceptability of unlisted door closers was documented in NCR 84-44 by a qualified fire protection engineer from PLC.

The justification was based on the closers needing to be operable to assure that the door is closed prior to the initiation of a fire, but that it is not needed during the fire.

Proper operation of the closers is verified by the periodic inspection of the doors.

4.

HOLES IN FIRE DOORS Conditi D 2

Small holes exist in many fire doors.

Aeolicability Applies to any fire doors with small holes in the door skin.

Doors known to have small cover plates welded to the door skin are 41, 45, 64, 89, 163, 196 and 288.

Acceetability small holes may be filled with rivets or screws.

Larger holes may be covered with a No. 16 gauge plate continuously welded to the door.

The maximum plate size is arbitrarily datermined to be equivalent to a 3-1/2 inch square plate with a minimum 1/2 inch overlap of the hole.

Trojan Nuclear Plant Document Control Desk Docket 50-344 August 12, 1988 License NPF-1 1 Page 8 of 25 Page 5 Existing fire doors (doors 52 and 53 per NCR 87-204) which have had plates attached which are larger than that equivalent to a 3-1/2 inch s,quare plate should be replaced with new fire doors.

Unfilled or uncovered holes in a fire door are not acceptable.

Justification Justification for the acceptability of the method of filling or covering small holes wss documented in NCR 84-44 including a review by a qualified fire protection engineer from PLC.

These methods were accepted as industry standards in maintaining fire door assemblies, and have been accepted by a documented Underwriters Laboratory investigation for at least one other nuclear plant.

These methods of repair are judged not to adversely affect the structural response of the fire doors to a fire condition.

Larger plates (such as those on doors 52 and 53 per NCR 87-204) are judged to have a possible, small effect on the structural response of the door to a fire, and the doors should be replaced to prevent criticism by reviewers of our fire protection program.

In the interim period this potential detrimental effect is not judged to be of sufficient significance to declare the door as a nonfunctional fire door.

5.

HOLES IN FIRE COOR TRAMES C2ndition Small holes exist in many fire door frames.

Conduits penetratt fire door frames.

Anolicability Applics to any fire doors with small holes in the fire door frame and to any conduit penetration of one side of a fire door frame.

Doors known to have small cover platts welded to the door frame are 108, 163 and 170.

Acceotance Small holes may be filled with rivets or screws are acceptable.

Larger holes may be covered with a No. 16 gauge plate continuously welded to the door frame.

The maximum plate size is arbitrarily determined to be equivalent to a 3-1/2 inch square plate with a minimum 1/2 inch overlap of the hole.

Holes up to 1 inch in diameter for grouting of the frame are acceptable i

Trojan Nuclear Plant Document Control Desk Docket 50-344 August 12, 1988 License NPF-1 1 Page 9 of 25 Page 6 l

Conduit penetrations of one side of the fire door frame are acceptable.

1 Unfilled or uncovered holes in a fire door frame are unacceptable.

Penetration of both sides of a fire door frame by a conduit is unacceptable.

Justification 1

Justification for the acceptability of methods of filling or covering small holes was documented in NCR 84-44 including a review by a qualified fire protection engineer from PLC.

These methods were accepted as industry standards in maintaining fire door assemblies, and have been accepted by a documented Underwriters Laboratory investigation for at least one other nuclear plant.

These methods of repair are judged not to adversely affect the structural response of the fire doors or frames to a fire condition.

6.

GAPS BETWEEN 000R AND TRAME Condition The clearance between the door and the frame or between the edges of doors in pairs is sometjass more than the 1/8 inch maximum gap specified in section 2-5.4 of NFPA 40.

Aeolicability l

Applies to any fire doors with gaps between the door and the frame or between the edges of doors in pairs which exceeds the 1/8 inch inch requirement by no more than 1/16 inch.

t

&gesetance Allow an additional 1/16 inch tolerance on one side of the door t

only, for the measured clearance between the door and the frame i

or between the edges of doors in pairs.

The maximum allowable gap would then be 3/16 inch.

This additional tolerance should not be applied where it could reduce the embedmont of the latch l

throw into the strike plate below that obtained by subtracting l

the allowable 1/8 inch gap from the required latch throw.

l l

l l

I

Trojan Nuclear Plant Document Control Desk Dochet 50-344 August 12 1988 License NPF-1 1 Page 10 of 25 Page 7 Justification The additional tolerance for gaps is justified because the additional 1/16 inch of gap would have an insignificant effect on the ability of the door to prevent propagation of a fire through the door opening.

It is not uncommon to find as-supplied door / frame gap dimensions of 3/16 inch; therefore, some additional tolerance is neaded to successfully install new labeled fire doors.

The additio..a1 tolerance is is a reasonable and acceptable application of the NFPA requirement.

7.

LATCH THROW MEASUREMENTS Cpndition Some doors, for which a 3/4 inch latch throw is specified, have measured latch throws which are slightly less than 3/4 inch.

Latch assemblies with specified 3/4 inch throws were installed resulting in some cases with measured latch throws of 11/16 inch.

Aeolicability Any fire doors which have labels 6pecifying latch throws of 3/4 inch.

Acceptance A minimum latch throw of 11/16 inch is acceptable for fire doors with labels specifying 3/4 inch latch throws.

Justificat12D The length of the latch threw obviously has a significant effect on the ability of a fire door to remain closed during a fire; however, this slight reduction of 1/16 inch in measured latch throw can be justified.

First, Table 2-8B of NFPA 80 specifies a minimum latch throw of 1/2 inch for fire doors where the label does not specify the required latch throw.

Second, since the construction of doors requiring the 3/4 inch throws is similar to those requiring only 1/2 inch throws, it is evident that the 11/16 inch dimension provides a margin of safety against the door opening during a fire which is greater than that provided by doors requiring 1/2 inch throws.

The additional tolerance is is a reasonable and acceptable application of the NFPA requirement.

Trojan Nuclear Plant Document Control Desk Dochet 50-344 August 12, 1988 License NPF-1 1 Page 11 of 25 Page 8 8.

SIGNS ATTACHED TO DOORS Condition Many signs are attached to fire doors.

NFPA SO permits the use of small signs installed on the door to indicate the function, use or location of the door.

The standard does not specify the maximum size, the material or the method of attachment of signs.

Acclicability Applies to all fire doors.

Acceptance Existing signs on doors are acceptable.

New installation of signs should be restricted to signs of a noncombustible material attached to the door with adhesive or glue.

Large metalic signs or signs which add a considerable amount of combustible material to the door should not be allowed.

dyptification Installation of all existing signs has been determined to be acceptable as documented in NCR 84~44.

Signs which add a considerable amount of combustible material to the door might become an ignition source on the side of the door oposiste of the fire.

Very large metal signs might affect the structural response of a door to a fire.

9.

HARDWARE Condition Hardware may be installed on a fire door which has not been properly prepared by the door manufacturer.

Hardware is changed or added on certain fire doors to meet security and other requirements.

Anolicability Applies to any fire door upon which hardware is changed or added.

4

.. _ _. _ _ _.. _ _ -. _ _ _ ~,

Trojan Nuclear Plant Document Control Desk Docket 50-344 August 12 1988 License NPF-1 1 Page 12 of 25 Page 9 Acceotance Installation of surface mounted hardware not required to hold the door in position during a fire (door position indicators, pull handles, push plates, latch for security only, etc.) on doors for which special reinforcements have not been made by the door manufacturer is acceptabla.

Installation of any hardware used to hold the door in position during a fire (hinges, locks and latches, strike plates, flush bolts, electric strikas, etc.) on doors or frames for which cutouts and reinforcements have not been properly made by the door manufacturer is not acceptable.

Installation of fire exit hardware on deors which are not labeled "Fire Door to be Equipped with Fire Exit Hardware" or on doors for which cutouts and reinforcements have not been properly made by the door manufacturer is not acceptable.

Justification Hardware needed to hold the door in position during a fire which is not installed per the manufacturer's tested condition could have a significent effect on the respense of the door to a fire.

Surface mounted hardware which is not needed to hold the door in position during a fire could have only a minor effect on the responsa of the door to a fire.

Since this hardware is usuelly needed for security or access reasons, its installation is justified.

c:

T.

E.

Bushnell S.

G. Hillier E.

L. Cavis A. N. Roller R.

P. Sheppard C.

H.

Brown i

D.

D. Wheeler P. A. Morton G.

G.

Bair i

A. J.

Sanchez D. R. Swanson W.

L. Kershul T.

L. Warnick 1

\\

Trojan Nucicar Plant Documant Control Desk Docket 50-344 August 12, 1988 License NPF-1 1 E

FILE C fh-1.3$10, PART 2 PAGE 1 OF 4 CIVIL JUSTIFICATION OF ACCEPTANCE CRITERIA FOR DOOR INSPECTIONS TROJAN NUCLEAR PLANT BY b

DATE ?/3/8% CHK BY DATE GENERAL This evaluation (Part 2) documents engineering's evaluation and justification of inspection criteria and acceptance criteria for fire-rated doors.

The Trojan Plant Maintenance Procedure MP-12-9 gives requirements for door inspections.

The June 1986 QA Audit performed by TERA Corporation reported, however, that requirements of the procedure were not adequate.

The audit report recommended that the proc'edure be revised to include more specific acceptance criteria such as minimum gap between door and frame or sill, latch throw, acceptable damage linits, etc.

The procedure ( MP-12-9) for door inspections has been revised per fire protection engineering recommendations provided by R.

O'Laughlin of Professional Loss Control (PLC).

Comments J.

from various PGE departments are also incorporated, as appropriate.

The evaluation of Revision 8 of the procedure, contained herein, was prepared by Civil Engineering.

E92E Document justifications for criteria contained in the procedure, MP-12-9, which result from interpretations of, or deviations from, NFPA 80 "Standard for Fire Doors and Windows".

Consider the applicability of previously documented justifications as documented in Part 1 of this evaluation.

Address any audit recommendations for criteria to be contained in the procedure.

l Irojan Nuclear Plant Docume nt Control Desh l

Docket 50-344 August 12, 1988 License NPF-1 1 Page 14 of 25 FILE C-FP-1.3.10, PART 2 PAGE 2 CF 4 i

1 EVALUATIONS 1-Requirement:

Per NFPA 80, the clearance between the doGr and the frame and between meeting edges of doors swinging in pairs shall not exceed 1/8 inch.

As justified in Part 1 of this evaluation an additional 1/16 inch (3/16 inch gap) is allowed except where it could reduce the embedment of the latch throw into the strike plate.

Recommedations:

The June 1986 QA Audit recommended that the clearance measurements associated with the fire doors be included as part of the inspecrion procedure.

MP-12-9 Acceptance criteria:

The procedure, revision 8, allows a gap 3/16 inch between the door and the frame and between meeting edges of doors swinging in pairs.

There is no requirement to inspect these gaps after the initial installation inspection.

Justification:

The justification for the allowable 3/16 inch clearance is contained in Part 1 (MRG-9-87M).

The inspection criteria for Mp-12-9 is based on the standards set forth in NFPA 80.

However, NFPA 80 does not address details concerning the methods used in the inspections such as methods of taking measurements and measurement tolerances.

Although engineering has agreed with the audit recommendation that fire door gaps be periodically measured, the periodic measurements are not specifically required.

Undetected, out of tolerance, gaps are judged not to significantly degrade the function of a fire door as long as the embedment of the latch throw is not reduced below the requirements.

2-Requirement:

Per NFPA 80, the throw of single point latch bolts shall not be less than the minimum shown on the fire door label.

If the minimum throw is not shown on the label, or the door does not have a label, the minimum throw shall be as required in table 2-8B.

Trojan Nuclear Plant Document Control Desh Docket 50-344 August 12, 1988 License NPF-1 1 Page 15 of 25 FILE C-FP-1. 3.10, PART 2 PAGE 3 OF 4 MP-12-9 Acceptance criteria:

The procedure allows a minimum of 11/16 inch throw for doors having labels which indicate a minimum 3/4 inch latch throw.

A 1/2 inch throw is required on other doors.

The measurement of the latch throw is included in the periodic inspections Recommendations:

The June 1986 QA Audit recommended that the clearance measurements associated with the fire doors be included as part of the inspection procedure.

This recommendation is complied with.

Justification:

The 11/16 inch throw, for doors having labels which indicate a minimum 3/4 inch latch throw, is justified in Part 1 of this evaluation (.1RG-9-87M).

3-Requirement:

Numerous deviations from NFPA 80 guidance were originally identified in NCR 84-44 and addressed in Part 1 (MRG-9-87M) of this evaluation.

MP-12-9 Acceptance criteria:

The procedure has been revised to include the acceptable deviations addressed in Part 1 (MRG-9-87M) of this evaluation.

Justification:

Justifications are contained in Part 1 of this evaluation.

CONCLUSIONS The Maintenance procedure is adequate to assure that fire doors are properly maintained and qualify as rated fire doors.

It is engineering's opinion that future auditors may still recommend that additional inspections, such as measurements of clearances be performed.

Trojan Nuclear Plant Document Control Desk Docket 50-344 August 12, 1988

,( LA's License NPF-1 1 Page 16 of 25 Page 1

.EMO TO:

R. Q. Reinhardt MRG-10-87M FROM:

M. Gandert 7

DATE:

October 5, 1987

SUBJECT:

TROJAN NUCLEAR PLANT Requirements for Fire Doors M mo MRG-9-87M was recently written to provide clarification of the requirements to be used by PGE for swinging, hollow metal fire doors at Trojan.

Per your request, this memo supplements the pravious m2mo to provide additional clarification on the acceptability of holes in fire doors and frames.

The acceptablo repair methods for small holas in fire doors or "ramas given in Memo MRG-9-87M applies to holes resulting from amage or from change out of hardware or signs.

Small holes left in the door or frame by the manufacturer for other than hardware nounting do not need to be repaired.

These consist of small holcs in the door jamb for small rubber bumpers, small holes in the top or bottom channels or other small holes which conform to the tested configuration of the door.

ct T.

E.

Bushnell S.

G.

Hillier E.

L. Davis A.

N.

Roller R.

P. Sheppard C.

H. Brown D.

D. Wheeler P. A. Morton G.

G.

Bair A. J. Sanchez D.

R. Swanson W.

L. Korshul T.

L. Warnick i

I

Trojan Nuclear Plant Document Control Desk Docket 50-344 August 12 1988

, 's N License NPF-1 Atiachment 11 Page 17 of 25 Page 1 TEMO To:

R. Q. Reinhardt MRG-9-87M FROM:

M.

Gandert DATE:

September 22, 1987

SUBJECT:

TROJAN NUCLEAR PLANT Requirements for Fire Doors A memo (CHB-124-87) to the Plant Review Board, describes several fire door problems which have recently been identified.

Identification of problems with fire doors is not a new issue.

In 1984 many problems were identified and resolved by NPE as documented in nonconformance report NCR 84-44.

There may be soveral reasons for identification of the recent problems.

First, plant personnel are taking a more active roll in ompliance with fire protection requirements.

Second, it is

.ifficult to determine which requirements should be applied to fire doors at Trojan.

Third, people make different interpretations of the requirements.

Fourth, it is often difficult to maintrain and upgrade fire doors while meeting differing and sometimes contradictory requirements for access, security and fire protection.

This memo provides clarification of the requirements to be used by PGE for swinging, hollow metal fire doors at Trojan.

It is intended to promote consistant and uniform quality in fire doors without i

having to replace door assemblies unnecessarily.

The guidance provided herein can be used in maintaining and upgrading Trojan fire doors and in evaluating when a fire door can be considered in compliance with the requirements.

The general design requirements for fire doors can be found in PGE-1012 "Fire Protection Plan" and in NPE-1 "Fire protection Design B2ses as follows:

Section 4.1.9 of Volume I of PGE-1012 states that fire barriers are evaluated in accordance with guidelines of Appendix A to Branch Technical Position APCSB 9.5-1.

Guideline D.l(j) of the BTP states in part, Door openings should be protected with equivalent rated doors, frames and hardware that have been tested and approved by a nationally recognized laboratory......

(Refer to NFPA 80, ' Fire Doors and Windows.')

Trojan Nuclear Plant Document Control Desk Docket 50-346 August 12, 1988 License NPF-1 1 Page 18 of 25 Page 2 Section 2.1.3.3.2 of NPE-1 states in part, Doors shall be installed in accordance with NFPA 80.

Doors are to be installed in accordance with their listings, using listed hardware and door frames."

Section 2.1.3.3.3 of NPE-1 states in part,

"..... A detailed review of existing plant fire doors was conducted as part of the Appendix R evaluation.

Where door installations deviated from NFPA 80, the deviations were justified or the doors were upgraded."

From the above listed design requirements, it can be seen that, while Trojan fire doors are intended to meet NFPA 80 guidance, verbatim compliance with the NFPA 80 standard is not required.

Plant requirements for doors, including numerous security requirements, make strict compliance with NFPA 80 difficult and impractical.

Therefore, minor deviations from the HFPA requirements which can be judged not to have a significant effect on the fire-rating of the door are allowed.

The evaluations for these minor deviations are documented in generic or specific evaluations.

Many of these minor deviations were preaviously identified by

'onconformance report (NCR) number 84-44.

The attachments to the

..CR contain justifications for the use-as-is dispositions.

Deviations from the requirements for fire door assemblies which have been determined to be acceptable in certain casos era as follows:

1.

NO DOOR LABEL Condition Fire door does not have a nationally recognized laboratory label (such as a UL label) attached.

Apolication Applies to fire door number 89 does not have a label per NCR 84-44.

Applies to fire doors 148, 156, 179, 181, 186, 187, 190, 194, 200, 359, 360, 427, 428 and 429 which were originally tagged with mylar labels were permanently tagged per NCR 86-001.

Accentance Door number 89 with a missing label was accepted by NCR 84-44.

All new fire doors are required to be labeled.

l

• Trojan Nuclear Plant Document Control Desh Dochet 50-344 August 12 1988 License NPF-1 1 Page 19 of 25 Page 3 Justification A complete fire door survey was performed in 1984.

Fire doors which were not originally constructed as fire doors have been replaced with labeled fire doors.

Any door used as a fire door which had been determined to be designed and constructed as a fire door but which no longer had a label attached was accepted as a qualified fire door.

If a label is found to be missing from an existing fire door other than the doors described above, Nuclear Plant Engineering should be asked to perform an evaluation.

3.

NO DOOR FRAME LABEL Condition Fire door frame does not have a nationally recognized laboratory label (such as a UL label) attached.

Aeolication i

Applies to fire door numbers 41, 42, 45, 61, 62, 63, 64, 91, 116 and 170 have missing frame labels per NCR 84-44.

Applies to fire door frames 148, 156, 179, 181, 186, 187, 190, 194, 200, 359, 360, 427, 428 and 429 which were originally tagged with mylar labels were permanently tagged per NCR 86-001.

AcceDtance Door numbers 41, 42, 45, 61, 62, 63, 64, 91, 116 and 170 with missing frame labels were accepted by NCR 84-44.

All new fire door frames are required to be labeled.

f Justification l

A complete fire door survey was performed in 1984.

I Justification for the acceptability of certain existing frames 1

was documented by a qualified fire protection engineer from Professional Loss Control, Inc. (PLC) by comparison of construction det:41s for unlabeled frames with that specified in 4

UL 63 and by cersi9' ration of the combustible loading in the fire areas proto=% iby the doors.

4 If a label is found to be missing from an existing fire door frame other than the frames described above, Nuclear Plant Engineering should be asked to perform an evaluation.

Trojan Nuclear Picnt Document Control Desk

' Docket 50-344 August 12, 1988 License NPF-1 1 Page 20 of 25 Page 4 3.

NO CLOSING DEVICE LISTING MARK Condition During the 1984 fire door survey, it was determined that door closers do not have nationally recognized laboratory listing marks.

Aeolication Applies to all new and existir.g fire door closers.

Acceotance Unlisted door closers are acceptable.

1 Justification Justification for the acceptability of unlisted door closers was documented in NCR 84-44 by a qualified fire prote: tion engineer from PLC.

The justification was based on the closers needing to be operable to assure that the door is closed prior to the i

initiation of a fire, but that it is not needed during the t

fire.

Proper operation of the closers is verified by the periodic inurection of the doors.

4.

HOLES IN FIRE DOORS Condition Small holes exist in many fire doors.

Acolicability Applies to any fire doors with small holes in the door skin.

Doors known to have small cover plates welded to the door skin are 41, 45, 64, 89, 163, 196 and 288.

Accentability I

Small holes may be filled with rivets or screws.

Larger holes may be cov ced with a No. 16 gauge plate continuously welded to the door.

The maximum plat 6 size is arbitrarily determined to be equivalent to a 3-1/2 inch square plate with a minimum 1/2 inch overlap of the hole.

Trojan Nuclear Plant Document Control Desk Docket 50-344 August 12, 1988 License NPF-1 1 Page 21 ef 25 Page 5 Existing fire doors (doors 52 and 53 per NCR 87-204) which have had plates attached which are larger than that equivalent to a 3-1/2 inch square plate chould be replaced with new fire doors.

Unfilled or uncovered holes in a fire door are not acceptable.

Justification Justification for the acceptabiliti of the method of filling or covering small holes was documented in NCR 84-44 including a review by a qualified fire protection engineer from PLC.

These methods were accerted as industry standards in maintaining fire door assemblies, and have been accepted by a documented Underwriters Laboratory investigation for at least one other nuclear plant.

These mathods of repair are judged not to adversely affect the structural response of the fira doors to a fire condition.

Larger plates (such as those on doors 52 and 53 per NCR 87-204) are judged to have a possible, small effect oc, the structural response of the door to a fire, and the doors should be replaced to prevent criticism by reviewers of our fire protection

prograu, In the interim period this potential detrimental effect is not judged to be of sufficient significance to declare the door as a nonfunctional fire door.

5.

HOLES IN FIRE DOOR FRAMES Condition Small holes exist in many fire door frames.

Conduits penetrate fire door frames.

Aeolicability Applies to any fire doors with small holes in the fire door frame and to any conduit penetration of one side of a fire door frame.

Doors known to have small cover plates welded to the door f ame are 108, 163 and 170.

Acaeotance Small holes may be filled with rivets or screws are acceptable.

Larger holes may be covered with a No. 16 gauge plate continuously welded to the door frame.

The maximum plate size is arbitrarily determined to be equivalent to a 3-1/2 inch square plate with a minim.tm 1/2 inch overlap of the hole.

Holes up to 1 inch in diameter for grouting of the frame are i

acceptable

l Trojan Nuclear Plant Document Control Desh

'Dochet 50-346 August 12, 1988 License NPF-1 1 Page 22 of 25 Page 6 Conduit penetrations of one side of the fire door frams are t

acceptable.

t Unfilled or uncovered holes in a fire door frame are unacceptable.

Penetration of both sides of a fire door frame by a conduit is i

unacceptable.

Justification s

Justification for the acceptability of methods of filling or l

covering small holes was documented in NCR 84-44 including a review by a qualified fire protection engineer from PLC.

These methods were accepted as industry standards in maintaining fire

~l door assemblies, and have been accepted by a documented Underwriters Laboratory investigation for at least one other nuclear plant.

These methods of repair are judged not to adversely affect the structural response of the fire doors or l

frames to a fire condition.

i j

6.

GAPS BETWEEN DOOR AND TRAME l

Condition The clearance between the door and the frame or between the edges of doors in pairs is sometimes more than the 1/8 inch maximum gap specified in section 2-5.4 of NFPA 80.

Amelicability l

Applies to any fire doors with gaps between the door and the l

frame or between the edges of doors in pairs which exceeds the j

1/8 inch inch requirement by no more than 1/16 inch.

l l

Acceptance Allow an additional 1/16 inch tolerance on one side of the door only, for the measured clearance between.the door and the frame or between the edges of doors in pairs.

The ma::imum allowable gap would then be 3/16 inch.

This additional tolerance should not be applied where it could reduce the embeument of the latch throw into the strike plate below that obtained by subtracting the allowable 1/8 inch gap from the required latch throw.

t i

i

l

, Trojan Nuclear Plant Document Control Desh Docket 50-344 August 12, 1988 License NPF-1 1 Page 23 of 25 Page 7 Justification The. additional tolerance for gaps is justified because the additional 1/16 inch of gap would have an insignificant effect on the ability of the door to prevent propagation of a fire through the door opening.

It is not uncommon to find as-supplied door / frame gap dimensions of 3/16 inch; therefore, some additional tolerance is needed to successfully install new labeled fire doors.

The additional tolerance is is a reasonable and acceptable application of the MFPA requirement.

7.

LATCH THROW MEASUREMENTS Condition some doors, for which a 3/4 inch latch throw is specified, have measured latch throws which are slightly less than 3/4 inch.

Latch assemblies with specified 3/4 inch throws were installed resulting in some cases with measured latch throws of 11/16 inch.

Aeolicability Any fire doors which have labels specifying latch throws of 3/4 inch.

Acceptance A minimum latch throw of 11/16 inch is acceptable for fira doors with labels specifying 3/4 inch latch throws.

Justification The length of the latch throw obviously has a significant et'fect on the ability of a fire door to remain closed during a fire; however, this slight reduction of 1/16 inch in measured latch throw can be justified.

First, Table 2-8B of NFPA 80 specifies a minimum latch throw cf 1/2 inch for fire doors where the label does not specify the required latch throw.

Second, since the construction of doors requiring the 3/4 inch throws is similar to those requiring only 1/2 inch throws, it is evident that the 11/16 inch dimension provides a margin of safety against the door opening during a fire which is greater than that provided by doors requiring 1/2 inch throws.

The additional tolerance is is a reasonable and acceptable application of the NFPA requirement.

, Trojan Nuclear Plant Document Control Desk Docket 50-344 August 12, 1988 License NPF-1 1 Page 24 of 25 Page 8 8.

SIGNS ATTACHED TO DOORS c_ondition Many signs are attached to fire doors.

NFPA 80 permits the use of small signs installed on the door to indicate the function, use or location of the door.

The standard does not specify the maximum size, the material or the method of attachment of signs.

Acelicability Applies to all fire doors.

Accentance Existing signs on doors are acceptable.

New installation of signs should be restricted to signs of a noncombustible material attached to the door with adhesive or glue.

Large metalic signs or signs which add a considerable amount of combustible material to the door should not be allowed.

Justification Installation of all existing signs has been determined to be acceptable as documented in NCR 84-44.

Signs which add a considerable amount of combustible material to the door might become an ignitien source on the side of the door oposiste of the fire.

Very large metal signs might affect the structural response of a door to a fire.

9.

HARDWARE Condition Hardware may be installed on a fire door which has not been properly prepared by the door manufacturer.

Hardware is changed or added on certain fire doors to meet security and other requirements.

Acelicability Applies to any fire door upon which hardware is changed or added.

=.

, Trojan Nuclear Plant Document Control Desk Dochet 50-344 August 12, 1988 License NPF-1

. 1 Page 25 of 25 Page 9 Acceotance Installation of surface mounted hardware not required to hold the. door in position during a fire (door position indicators, pull handles, push plates, latch for security only, etc.)

on doors for which special reinforcements have not been made by the door manufacturer is acceptable.

Installation of any hardware used to hold the dcor in position during a fire (hinges, locks and latches, strike plates, flush bolts, electric strikes, etc.) on doors or frames for which cutouts and reinforcements have not been properly made by the door manufacturer is not acceptable.

Installation of fire exit hardware on doors which are not labeled "Fire Door to be Equipped with Fire Exit Hardware" or on doors for which cutouts and reinforcements have not been properly made by the door manufacturer is not acceptable.

Justification Hardware needed to hold the door in position during a fire which is not installed per the manufacturer's tested condition could have a significant effect on the response of the door to a fire.

Surface mounted hardware whien is not needed to hold the door in position during a fire could have only a minor effect on the response of the door to a fire.

Since this hardware is usually needed for security or access reasons, its installation is justified.

c:

T. E. E92shnell S.

G. Hillier E. L. Davis A. N. Roller R.

P. Sheppard C. H. Brown D. D. Wheeler P. A. Morton G.

G.

Bair A. J. Sanchez D. R. Swanson W.

L. Xershul T.

L. Warnick

Trojan Nuclear Plant Document Control Desk Docket 50-344 August 12, 1988 License NPF-1 2 Page 1 of 4 PAGE 1 OF 4 FILE C-FP-1.3.15 CIVIL EVALUATION OF TRAIN SEPARATION BARRIERS TROJAN NUCLEAR PLANT Date 0 k hl[

Chk By ' l '

M Date S/8/ N By Wf I i

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General This evaluation addresses the construction and fire protection aspects of the electrical train separation (radiant energy heat shield) barriers discussed in Section 4.5 in Volume I of PGE 1012.

This evaluation does not address the criteria used to determine when and where the barriers are installed, or whether Trojan meets the electrical train separation criteria specified in PGE 1012 for all casos or areas of the plant.

The determination of when and where the barriers are needed is done by the Electrical Branch of Nuclear Plant Engineering.

NOTE:

This evaluation has been prepared by an engineer who has over 16 years of experience, of which ever 9 years has been in responsible charge of fire protection engineering work, and who meets the personnel qualification requirements specified in paragraph C.1.a.(5), Revision 2 of Branch Technical Position (BTP) CMIB 9.5-1.

As stated in PGE 1012, electrical train separation barriers are installed to provide horizontal and vertical separation of redundant safe shutdown or safety-related cables in trays that do not meet the minimum separation distance criterie.

In addition, the barriers are provided to protect redundant safety-related or safe shutdown cables in cases where cable trays or conduits pass over an open cable tray or stacks of trays, and a localized fire could possibly affect redundant safety-related cables at the crossover or by propagation, via a tray, affact redundant safety-related cables located elsewhere.

The locations of the barriers are shown on attached drawings.

Trojan Nuclear Plant Document Control Desk Docket 50-344 August 12, 1988 License NPF-1 2 Page 2 of 4 PAGE 2 OF 4 C-FP-1.3.15 The electrical train separation barriers can not be judged, by themselves, as adequate for providing complete protection for the redundant safety-related cables in a fire area.

The barriers are only one of many fire protection features the plant has to prevent a fire from affecting redundent safety-related cables.

The adequacy of the barriers to protect the cables in one given fire area, should ba judged together with all the other plant safety and fire protection features.

There are three styles of electrical train separation barriers provided at Trojan: The Marinite barriers, the Thermo-lag barriers, and the Kaowool barriers.

Typical details of the barriers are shown on drawings C-2200 Sheets 1 and 2 and C-2221-1.

Marinite Barriers As described in PGE 1012, the first style electrical train separation barrier is constructed of 1\\2-inch thick Marinite 36 panels.

Flamemastic 71A, and its replacement, Flamemastic 77, flame retardant coating is used to cover the fasteners and to fill-in the joints.

Since Marinite 36 panels are no longer available, Marinite XL and the newer Marinite I panels have been used when modifications or repairs to the barriers are needed.

The construction of the Marinite barriers may not be a tested configuration per the fire endurance test requirements of ASTM E-119, but it does afford some protection of electrical cables because of their location, configuration, and the fire resistive properties of the materials used to construct the barriers.

The barriers are judged to be adequate in providing protection for radiant energy heat produced by a small localized fire and in helping to preventing the fire from spreading, via cable trays, to other cables, possibly affecting redundant safe shutdown or safety-related cables.

For further discussions on the physical and fire resistive properties of the Marinite barrier materials, see File j

i C-FP-1.1, Item 22.

Thermo-laa Barriers The second style of electrical train separation barriers, which have been installed in the containment, utilizes the Thermo-lag 330 Fire Barrier (Cable Wrap) System prefabricated panels and shapes to wrap the cable trays, conduits, and pull-boxes.

All the Thermo-lag wraps located in the containment are installed to function as electrical train separation (radiant energy heat shields) barriers per the i

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Trojan Nuclear Plant Document Control Desk 0

Docket 50-344 August 12 1988 t

License NPF-1 2 Page 3 of 4 PAGE 3 OF 4 C-FP-1.3.15 i

requirements of Section G.2.f of Appendix R to 10CFR 50.

The i

Thermo-lag prefabricated panels and shapes are a nominal 1\\2-inch thick and are installed per the Thermo-lag installation procedure to provide up to a 1-hour fire barrier protection.

The Thermo-lag wrap provides considerable protection for cables against the affects of a fire, and the wrap has passed a 1-hour fire endurance test per ASTM E-119.

The Thermo-lag barriers more than satisfy the commitments i

specified in PGE 1012.

For further discussions on Thermo-lag cable wrap, see File C-FP-1.3.11.

Ceramic Blanket Barriers The third style of electrical train separation barriers utilizes two 1-inch thick layers of Kaowool ceremic blanket wrapped around a cable tray or conduit and held in place with 4

1\\2-inch wide stainless steel straps.

The Kaowool wrap is installed in the Turbine Building and the Intake Structure, t

i and the installation details and location of the wrap are shown on drawings C-2210-2 and C-2221-1.

The Kaowool wrap i

systeu has been subjected to a fire endurance test per ASTM E-119.

A hose stream test was not conducted.

The wrap was able to protect the cables for more than one hour before the cables failed to function.

The fire endurance test report, j

including civil's evaluation of the test, are in File C-FP-1.1, Iter 26.

Although the Kaowool wrap may deviate from the tested configuration due to structural interferences, the Kaowool barriers more than satisfy the commitments specified in PGE 1012 for train separation barriers.

i Conclusion i

i The electrical train separation barriers installed at Trojan meet the commitments specified in PGE 1012.

The barriers will j

4 i

provided some protection for safety-related cables against l

radiant energy heat generated from a small localized fire, and they will help prevent the fire from affecting redundant safety-related cables in the same fire area.

The barriers are just one of many fire protection and plant safety features

{

that are provided, and all these features, together with the barriers, ensure the a single fire in one fire area will not L

prevent safe shutdown of the plant.

I i

i I

i a

i i

Trojan Nuclear Plant Document Control Desk Docket 50-344 August 12, 1988 License NPF-1 2 Page 4 of 4 PAGE 4 OF 4 C-FP-1.3.15 LIST OF ATTACHED DRAWINGS 1.

Drawing C-2200, Sh 1 of 2, Rev 0 2.

Drawing C-2200, Sh 2 of 2, Rev 0 3.

Drawing C-2201-2, Rev 0 4.

Drawing C-2202-1, Rev 0 5.

Drawing C-2204-1, Rev 1 6.

Drawing C-2204-2, Rev 1 7.

Drawing C-2204-3, Rev 1 8.

Drawing C-2205-1, Rev 1 9.

Drawing C-2205-2, Rev 1 10.

Drawing C-2206-2, Rev 2 11.

Drawing C-2206-3, Rev 0 12.

Drawing C-2210-2, Rev 0 13.

Drawing C-2210-4, Rev 0 14.

Drawing C-2213-2, Sh 2 of 3, Rev 3 15.

Drawing C-2213-3, Rev 2 16.

Drawing C-2221-1, Rev 2 17.

Drawing C-2230, Rev 0 i

OVERSIZE DOCUMENT PAGE PULLED 1

SEE APERTURE CARDS NUMBER OF OVERSIZE PAGES FILMED ON APERTURE CARDS APERTURE CARD /HARD COPY AVAILABLE FROM RECORD SERVICES BRANCH FTS 492-8989

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