1. Fire Hazards Analysis the ORNL Approach Jeff Sipes Fire Protection Engineer April 17, 2007

2. O AK R IDGE N ATIONAL L ABORATORY U. S. D EPARTMENT OF E NERGY 2 April 2007 The Problem  From 1991 to 2004  FHAs had become the catch-all repository to document fire protection issues  FHAs had become approval type documents  FHA size increased significantly  Annual cost to update/maintain FHAs increased  FHA evaluated risk via recommendations  The FHA and DSA were regularly  not consistent and  sometimes conflicting

3. O AK R IDGE N ATIONAL L ABORATORY U. S. D EPARTMENT OF E NERGY 3 April 2007 FHAs and DSAs Section 4.16 of the Implementation Guide It is recognized, however, that because an FHA is based on the premise that a fire will occur and considers fire safety issues (property loss and program discontinuity potential) that are not normally considered in the SAR, the conclusions of the FHA may be more conservative than would normally be developed by a SAR alone. Nevertheless, the FHA and its conclusions should be addressed in the facility SAR…

4. O AK R IDGE N ATIONAL L ABORATORY U. S. D EPARTMENT OF E NERGY 4 April 2007  Does Anyone know  The first official direction for FHAs at DOE facilities? History of FHAs

5. O AK R IDGE N ATIONAL L ABORATORY U. S. D EPARTMENT OF E NERGY 5 April 2007 5480.7 Fire Protection (May 1991) Fire Hazards Analyses. The purpose of a fire hazards analysis (FHA) is to comprehensively assess the risk from fire within individual fire areas in a DOE facility in relation to existing or proposed fire protection so as to ascertain whether the objectives of Chapter I, Section 4, are met. An FHA shall be performed for new facilities (as directed by DOE 6430.1A), for new and existing nuclear facilities, or as directed by the AHJ. An FHA shall contain, but not be limited to, the following elements: (1) Description of construction. (2) Essential safety class equipment. (3) Fire protection features. (4) Description of fire hazards. (5) Life safety considerations. (6) Critical process equipment. (7) High value property. (8) Damage potential: Maximum Credible Fire Loss (MCFL) and Maximum Possible Fire Loss (MPFL). (9) Fire Department/Brigade response. (10) Recovery potential. (11) Potential for a toxic, biological and/or radiation incident due to a fire. (12) Emergency planning. (13) Security & Safeguards considerations related to fire protection. (14) Natural hazards (earthquake, flood, wind) impact on fire safety. (15) Exposure fire potential, including the potential for fire spread between fire areas. An FHA shall be performed under the direction of a qualified fire protection engineer.

6. O AK R IDGE N ATIONAL L ABORATORY U. S. D EPARTMENT OF E NERGY 6 April 2007 Memorandum on Guidance on Performance of FHAs  Memorandum  From Joseph E. Fitzgerald, Jr  November 7, 1991  Provided interim guidance on the development of FHAs  Term “Comprehensively and qualitatively”  Level of detail is directly related to facility complexity and potential risk

7. O AK R IDGE N ATIONAL L ABORATORY U. S. D EPARTMENT OF E NERGY 7 April 2007 5480.7A Fire Protection (2-17-93) Fire Hazards Analyses. The purpose of a fire hazards analysis (FHA) is to comprehensively assess the risk from fire within individual fire areas in a DOE facility in relation to existing or proposed fire protection so as to ascertain whether the objectives of paragraph 4, are met. A graded FHA, that reflects the risks from fire in a facility, shall be performed for new facilities as directed by DOE 6430.1A, for nuclear facilities where safety analysis are required by DOE 5480.23, and as directed by the PSO. A Safety Analysis Report (SAR) that address the following elements will satisfy the requirement for an FHA. A graded FHA shall contain, but not be limited to, the following elements: (a) Description of construction. (b) Protection of essential safety class equipment. (c) Fire protection features. (d) Description of fire hazards. (e) Life safety considerations. (f) Critical process equipment. (g) High value property. (h) Damage potential: Maximum Credible Fire Loss (MCFL) and Maximum Possible Fire Loss (MPFL). (i) Fire Department/Brigade response. (j) Recovery potential. (l) Potential for a toxic, biological and/or radiation incident due to a fire. (m) Emergency planning. (n) Security considerations related to fire protection. (o) Natural hazards (earthquake, flood, wind) impact on fire safety. (p) Exposure fire potential, including the potential for fire spread between fire areas. An FHA shall be performed under the direction of a qualified fire protection engineer.

8. O AK R IDGE N ATIONAL L ABORATORY U. S. D EPARTMENT OF E NERGY 8 April 2007 420.1 Facility Safety (10-13-95) Fire hazards analysis (FHA) for all nuclear facilities, significant new facilities and facilities that represent unique or significant fire safety risks. The FHA shall be developed using a graded approach. The conclusions for the FHA shall be incorporated in the Safety Analysis Report (SAR) Accident Analysis and shall be integrated into design basis and beyond design basis accident conclusions. Implementation Guide for use with DOE Orders 420.1 and 440.1 Fire Safety Program. Section 4 Fire hazards Analyses 16 paragraphs of direction for FHAs

9. O AK R IDGE N ATIONAL L ABORATORY U. S. D EPARTMENT OF E NERGY 9 April 2007 420.1A Facility Safety (5-2-02) Fire hazards analysis (FHA) for all nuclear facilities, significant new facilities and facilities that represent unique or significant fire safety risks. The FHA shall be developed using a graded approach. The conclusions for the FHA shall be incorporated in the Safety Analysis Report (SAR) Accident Analysis and shall be integrated into design basis and beyond design basis accident conclusions.

10. O AK R IDGE N ATIONAL L ABORATORY U. S. D EPARTMENT OF E NERGY 10 April 2007 New Approach (at least for ORNL)  Back to the basics  Comprehensively assess the risk from fire within individual fire areas  FHA shall be developed using a graded approach  Conclusions for the FHA shall be carried forward incorporated in the Safety Analysis Report (SAR) Accident Analysis

11. O AK R IDGE N ATIONAL L ABORATORY U. S. D EPARTMENT OF E NERGY 11 April 2007 Step 1: Remove Unnecessary Data  Transient Facility Data  System Descriptive Data  Calculations and Secondary Assessments  Duplicative information REASON: The above information can fluctuate without impacting the FHA Conclusions

12. O AK R IDGE N ATIONAL L ABORATORY U. S. D EPARTMENT OF E NERGY 12 April 2007 Transient Facility Data Eliminated data/descriptions which:  Were not fixed and could be modified without a work control document  Examples include:  Office layout  Room contents  Identification of portable equipment  This information was moved to a routine assessment type document and updated at least annually

13. O AK R IDGE N ATIONAL L ABORATORY U. S. D EPARTMENT OF E NERGY 13 April 2007 System Design Descriptions Targeted System Designed Descriptions  Automatic Suppression Systems  Fire Barrier Systems  Manual Fire Protection  Fire Detection and Alarm Systems  Egress Systems  Initially, this data was moved to an FHA Appendix pending the SDD Development  Develop SDDs using DOE-STD-3024

14. O AK R IDGE N ATIONAL L ABORATORY U. S. D EPARTMENT OF E NERGY 14 April 2007 Calculations & Secondary Assessments  Exposure Protection Assessment  Lightning Protection Assessment  Underground Water System Assessment  Wildland Fire Exposure Assessment  Any applicable fire modeling  Moved to Fire Protection Assessment/Calculation  Receives the same rigor of a design calculation

15. O AK R IDGE N ATIONAL L ABORATORY U. S. D EPARTMENT OF E NERGY 15 April 2007 Duplicative Information  Thoroughly scanned the document to remove information stated in multiple sections of the FHA.  All information was given a “primary home” in the document.  Secondary uses of that data was by reference

16. O AK R IDGE N ATIONAL L ABORATORY U. S. D EPARTMENT OF E NERGY 16 April 2007 Step 2: Restructure the FHA LIST OF ILLUSTRATIONS LIST OF ACRONYMS 1.0 INTRODUCTION 2.0 CONSTRUCTION AND FACILITY USE 3.0 FIRE PROTECTION 4.0 FIRE HAZARDS 5.0 LIFE SAFETY CONSIDERATIONS 6.0 FACILITY EQUIPMENT/ PROGRAM PRESERVATION 7.0 PROGRAM DOCUMENTATION 8.0 CONCLUSIONS 9.0 ADMINISTRATIVE CONTROLS/APPROVALS REFERENCES APPENDICES (as necessary) Currently holding system data until SDDs are developed

17. O AK R IDGE N ATIONAL L ABORATORY U. S. D EPARTMENT OF E NERGY 17 April 2007 Step 3: Production  Produce FHA using the MSWord Manual Publishing tools  Document & Sub-document  Section Control and Change Tracking  Use conclusions from the supporting documents in the FHA  Place all documents under the appropriate configuration management process

18. O AK R IDGE N ATIONAL L ABORATORY U. S. D EPARTMENT OF E NERGY 18 April 2007 Step 4: Develop Update Tools  Change Tracking  Need a process that ensures changes are tracked and the FHA is reviewed for impacts  ORNL FHA Screening Review  FPE Approval Form  ORNL SAR review/Screening Process

19. O AK R IDGE N ATIONAL L ABORATORY U. S. D EPARTMENT OF E NERGY 19 April 2007 Benefits of the change  FHAs which  better assess the risks  analyze field conditions  are bounding  are easier to maintain  Contain the DSA fire analysis  consistent with the DSA  FHAs which are Less Costly, both: Financially Personnel time  FHAs that are Up-to-Date, Living Documents

20. O AK R IDGE N ATIONAL L ABORATORY U. S. D EPARTMENT OF E NERGY 20 April 2007 Trade-offs  FHAs are no longer “one-stop-shop” documents  Changes to conclusions of input documents required a change to the FHA  Can seem complicated to manage multiple documents  A larger number of smaller documents under configuration management Actually: Initial data indicates the FHAs are easier to manage and easier to update.