Fire Protection
Lindy Hughes
Fleet Fire Protection Program Engineer
Southern Nuclear Operating Company
June 4, 2013
Fire Protection
Under Deterministic Program
 Reg Guide 1.189 was developed to provide a comprehensive
fire protection guidance document and to identify the scope
and depth of fire protection that the NRC would consider
acceptable for nuclear power plants
Fire Protection
Configuration Management
 Qualified personnel review new designs and plant
modifications, including fire protection systems, must be
reviewed to ensure inclusion of appropriate fire protection
requirements
Fire Protection
Configuration Management
 Instructions and procedures for design, installation,
inspection, test, maintenance, modification, and
administrative controls must be reviewed to ensure proper
FP requirements are addressed, including
– Control of ignition sources and combustibles
– Provisions for backup fire protection capability
– Disablement of FP system
– Restrictions on material substitutions
Fire Protection Configuration
Management Under NFPA 805
 NEI 04-02 provides guidance for implementing the
requirements of NFPA 805
Fire Protection Configuration
Management Under NFPA 805
 Plant Change Evaluation
 Shall be performed to ensure that a change to a previously
approved fire protection program element is acceptable
 Process shall consist of an integrated assessment of the
acceptability of risk, defense-in-depth, and safety margins
 Impact of proposed change shall be monitored
Risk Acceptance
 Change in public health risk from any plant change shall be
acceptable to AHJ
 CDF and LERF shall be used to determine acceptability
Defense in Depth
 Plant change evaluation shall ensure philosophy of defense-in-
depth is maintained, relative to fire protection and nuclear
safety
Defense in Depth for Fire Protection
 Prevent fires from starting
 Rapidly detect, control, and extinguish fires that do occur
 Provide protection for structures, systems, and components
important to safety so that a fire that is not promptly
extinguished will not prevent the safe shutdown of the plant
Defense in Depth for Nuclear Safety
 Prevent core damage
 Prevent containment failure
 Mitigate consequences
Safety Margins
 Plant change evaluation shall ensure sufficient safety margins
are maintained
Fire Protection Configuration
Management Under NFPA 805
 The fire prevention activities shall include but not be limited
to the following program elements:
(3) Administrative controls addressing the review of plant
modifications and maintenance to ensure that both fire
hazards and the impact on plant fire protection systems and
features are minimized
Fire Protection Configuration
Management Under NFPA 805
 Monitoring Program
 Ensures availability and reliability of FP systems and features are
maintained
 Assesses performance of FP program in meeting performance
criteria
 Ensures assumptions in engineering analysis remain valid
Fire PRA
 Fire PRAs do not always use traditional fire area boundaries
when developing Physical Analysis Units (PAUs)
 Non fire rated boundaries can be credited
 Modified or new equipment / components can introduce
new ignition sources or hazards
Fire PRA
 Fire PRAs in finalization and/or development for all SNC
operating units
 During development of Fire PRA, freeze date for each plant
state is applied
 Potential impacts to Fire PRAs must be documented for
post-freeze date
 Screening being added to Fire Protection checklist