Fire Protection Program Self Assessment

The primary objective of the NRC’s Triennial Inspection of Fire Protection Programs (Inspection Procedure 71111.05) is to assess the plant’s readiness to respond to a postulated fire event, and to assess plant staff capability and performance of various organizations in maintaining the fire protection program and 10 CFR 50 Appendix R compliance. Also, in performing the FPFI, an examination of organizational interfaces among technical disciplines is performed to ensure that appropriate controls are in place and that effective program implementation is being provided.

The NRC has conducted inspection of Fire Protection Programs at various utilities. Tri-En played an integral part in supporting Northern States Power Company in the preparation and successful NRC audit at their Prairie Island Nuclear Generating Plant and Salem Generating Stations during the pilot program for Fire Protection Functional Inspection in 1998 and 1999. Tri-En Corporation engineers have since supported various nuclear facilities in reviewing their fire protection program in preparation for the NRC Triennial Inspections. Through this experience and shared experiences throughout the industry, Tri-En has gained a wealth of knowledge which can help you.

Fire Protection Program Objectives

The primary objectives of an adequate Fire Protection Program is to assess the capability of a utility's program to satisfy the following criterion (10CFR50, Appendix A, General Design Criterion 3):

• Prevent fires from starting,
• Detect, rapidly control and promptly extinguish fires that do occur,
• Ensure that fires will not prevent essential plant functions from being performed (e.g. achieve and maintain post-fire safe shutdown),
• Conduct effective post-fire safe shutdown and fire protection program configuration management activities, and

Secondary objectives of a self-assessment are to assess the potential for and the likely effects of:

• Event initiated fires
• Fire induced reactor transients
• Seismic fire interaction
• Fire induced release of radioactive materials.

Risk Insights

The Fire Protection Program should consider the use of risk insights to:

• Assess the capability of existing fire protection features, administrative controls, systems, equipment, personnel, and emergency response procedures to mitigate the adverse effects of fires and explosions on structures, systems and components important to safety.
• Evaluate the capability to achieve and maintain safe shutdown conditions during and after a fire;
• Evaluate how the defense-in-depth principles were applied to plant-specific configurations and identify fire event sequences (vulnerabilities) of potential high safety significance; and
• Verify that the current fire protection plan conforms to the NRC-approved licensing and design basis, and that suitable design controls are in place to ensure the approved configuration is appropriately maintained over the life of the plant.

Self-Assessment Requirements Overview

Fire Protection Program

• Fire Protection Program Administration
• Licensing and Design Bases
• Organization and Management Oversight
• Fire Protection Procedures
• Administrative Controls
• General Employee and Fire Watch Training

Fire Brigade Training and Equipment

• Fire Brigade and Fire Response
• Fire Brigade composition, notification and availability, and shift staffing for fire events.
• Offsite Agreements

Fire Protection Systems and Features

• Licensing and Design Bases
• Fire Detection and Alarm Systems
• Fixed and Automatic Fire Suppression Equipment and Systems
• Manual Fire Suppression Equipment and Systems
• Fire Barriers

Reactor Coolant Pump Oil Collection Systems

Post-fire Safe Shutdown Capability

• Licensing and Design Bases
• Fire Hazards Analysis
• Safe Shutdown Analysis
• Post-fire Safe Shutdown Areas and Systems Selection
• Hot and Cold Shutdown Procedures and Equipment, Cold Shutdown Repairs, and Shutdown Safety
• Electrical System Protection

• Power, Control and Indication Cable Separation and Protection
• Alternative/Dedicated Safe Shutdown Panel Electrical Independence and Isolation
• Associated Circuits Analyse

• Post-fire Safe Shutdown Capability Implementation

• Methods of Redundant Train and Alternative/Dedicated Safe Shutdown Implementation
• Electrical Loads Management
• Human Factors and Manning
• Control System Interactions/Control Location Transfers

• Fire Protection and Post-fire Safe Shutdown Program Management and Configuration Control
• Fire Protection and Post-fire Safe Shutdown Management Processes

• Quality Assurance/Quality Control Audits
• Surveillance Testing and Maintenance Program
• Operability Assessments and Compensatory Measures

• Fire Protection and Post-fire Safe Shutdown Configuration Control

• Process
• Design Reviews and Modification Packages
• Review Committee Actions
• FSAR Updates

• Potential Fire Related Vulnerabilities

• Event Based Fires
• Fire Induced Plant Transients
• Seismic/Fire Interactions
• Fire Induced Release of Radioactive Materials