A Pilot Plant Evaluation Using NFPA-805 Performance-Based Standard For Fire Protection For Light Water Reactor Electric Generating Plants

A Pilot Plant Evaluation Using NFPA-805,
"Performance-Based Standard for Fire

Protection for Light Water Reactor Electric
Generating Plants"
Technical Report
A Pilot Plant Evaluation Using
NFPA-805, “Performance-Based
Standard for Fire Protection for
Light Water Reactor Electric
Generating Plants”
1001442
Final Report, May 2001
EPRI Project Manager

R. Kassawara
EPRI • 3412 Hillview Avenue, Palo Alto, California 94304 • PO Box 10412, Palo Alto, California 94303 • USA
800.313.3774 • 650.855.2121 • askepri@epri.com • www.epri.com
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CITATIONS
This report was prepared by
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4920 El Camino Real
Los Altos, CA 94022
Principal Investigator
B. Najafi (SAIC)
D. Shumaker (PSEG Nuclear)
E. Kleinsorg (The Kleinsorg Group)
F. Joglar-Billoch (SAIC)
A. Ratchford (RDS)
This report describes research sponsored by EPRI.
The report is a corporate document that should be cited in the literature in the following manner:
A Pilot Plant Evaluation Using NFPA-805, “Performance-Based Standard for Fire Protection
for Light Water Reactor Electric Generating Plants”, EPRI, Palo Alto, CA: 2001. 1001442.
iii
REPORT SUMMARY
The National Fire Protection Association (NFPA) has developed NFPA 805, “Performance-
Based Standard for Fire Protection for Light Water Reactor Electric Generating Plants,” which
will be published in Spring of 2001. EPRI has performed a pilot evaluation of this Standard at
the Salem Generating Station. This report presents the results of that evaluation.
Background
In 1997, NFPA began an effort to develop a performance-based standard for light water reactor
electric generating plants (NFPA 805). During the same year, the Nuclear Regulatory
Commission (NRC) staff proposed developing a risk-informed and performance-based (RI/PB)
fire protection rule. In response, the commission directed the staff to work with NFPA on a risk-
informed and performance-based consensus standard. The NFPA 805 Standard was completed
and approved by the NFPA membership for publication. NRC is evaluating the option of
endorsing this Standard as a voluntary alternative to the existing fire protection regulation.
Objectives
• To evaluate the usefulness of NFPA 805 for nuclear power plant applications.
• To benchmark the general usefulness of RI/PB methods for fire protection applications, which
may help utilities make informed decisions on how the Standard can be used at their sites.
Approach
The primary focus of the pilot evaluation was to test the NFPA 805 process and its
implementation, rather than to perform detailed evaluations of specific plant conditions and
issues.
The pilot evaluation examined the steps outlined in the Standard by implementing each step at
the pilot plant. Different steps in the Standard were examined with varying levels of detail to
ensure that project resources were properly focused to meet the objectives. Accordingly, the
pilot examination focused on the steps of the Standard involving fundamental fire protection
program and design elements, engineering analysis, and risk-informed change evaluation.
Results
The pilot evaluation resulted in the following conclusions and recommendations:
• The Standard is not a truly performance-based approach; rather, it is a combination of
prescriptive and performance-based elements. The Standard does provide the framework
required to implement such a hybrid approach.
v
• Current state-of-the-art methods can support implementation of the Standard’s approach
within their limitations.
• Guidance for using the Standard will be a key in its cost-effective implementation. Without
such guidance, the Standard will be impractical for most potential users and can produce
varying and potentially unreliable conclusions.
• The Standard contains requirements beyond the current fire protection regulations, which
could be impractical for existing plants to implement. These conflicts should be resolved by
clearly recognizing that these requirements should not result in backfit to existing plants.
• Using the Standard in part or as the licensing basis for the plant introduces cost elements in
both directions (additions and reductions). The net effect on cost is highly dependent on the
individual plant’s fire protection program and design, the plant’s existing fire protection
license condition, and the manner in which the Standard is used.
EPRI Perspective
Development of NFPA 805 has been a significant undertaking. The Standard has been produced
with significant contributions by all segments of the nuclear industry, and even though it is not
truly performance-based, it is a significant step in that direction.
Keywords
Fire
Fire protection
Fire safety
Risk-informed fire protection
Performance-based fire protection
Nuclear power
Fire PRA (probabilistic risk assessment)
National fire protection association
NFPA standard
vi
ABSTRACT
In 1997, the National Fire Protection Association (NFPA) began an effort to develop a
Performance-Based Standard for Light Water Reactor Electric Generating Plants (NFPA 805).
During the same year, the NRC staff proposed development of a Risk-Informed and
Performance-Based fire protection rule. In response, the commission directed the staff to work
with the NFPA on a Risk-Informed and Performance-Based consensus Standard. The NFPA
committee, with wide support from utility fire protection engineers, NRC staff and other industry
experts, completed the Standard that was approved for publication by the NFPA membership on
November 15, 2000. This Standard breaks new ground in the application of risk information and
performance bases to fire protection at nuclear plants, but because it is intrinsically different than
the current prescriptive criteria, it requires a technical and operational validation.
This Pilot Evaluation was initiated to evaluate the NFPA 805 Standard and its usefulness for
nuclear power plant applications and also provided a benchmark of the general usefulness of
RI/PB methods for fire protection applications.
This Pilot Evaluation led to the following conclusions:

• The approach of NFPA 805 in not entirely performance-based , but instead defines and
describes a Hybrid approach that is a mix of prescriptive and performance-based methods
and tools to evaluate a fire protection program. The Standard provides the framework
required to implement this Hybrid approach.
• The current state-of-the-art tools and methods can support implementation of a performance-
based approach within limitations.
• Even with considerable information in the Appendices, a large number of questions
concerning use of the Standard remain. Without guidance to address these questions, use of
the Standard will be impractical for most potential users and can produce varying and
potentially unreliable conclusions.
• During the Pilot Evaluation, the team identified new requirements from the current fire
protection regulations that could be impractical for existing plants to implement. While these
requirement may relatively easily be incorporated into a new plant, they may be incorporated
into an existing plant with great difficulty. These conflicts should be resolved by clearly
recognizing that these requirements should not result in backfit of existing plants.
• Use of the Standard in part or as the licensing basis for the plant introduces cost elements in
both directions. Use of the Standard as the licensing basis is expected to introduce
significant new costs for many programs as the result of the requirements in Chapter 3. On
the other hand, some of current requirements in Appendix R, e.g., III.G, J and O, can be
addressed by using a performance-based Approach. The net effect on cost is dependent on
vii
the individual plant’s fire protection program and design, the plant’s existing fire protection
license condition, and the manner in which the Standard is utilized.
viii
ACKNOWLEDGMENTS
Authors of this project would like to acknowledge the support provided by the Public Service
Electric and Gas (PSEG-Nuclear) and the staff at the Salem Nuclear Generating Station. Special
thanks goes to Mr. Wei He who provided the technical support and review needed for the
success of this project and Mr. Rich Alpert (Triad) who supported review of the Salem fire
protection program.
The authors would also like to acknowledge the contributions made by Dr. Robert J. Budnitz
(Future Resources Associates, Inc.) , Mr. Keith Parkinson (Nexus Technical Services Corp.) and
Dr. Fredrick W. Mowrer (University of Maryland) who reviewed and provided valuable
comments on this report.
This work was performed under a Tailored-Collaboration project that benefited from financial
contributions from EPRI-member utilities.
ix
CONTENTS
1 BACKGROUND................................................................................................................... 1-1
2 OBJECTIVES ...................................................................................................................... 2-1
3 SCOPE ................................................................................................................................ 3-1

3.1 NFPA 805 Approach ................................................................................................. 3-1
3.2 Other Elements of the Standard ................................................................................ 3-2
3.3 NFPA 805 as an Alternate Fire Protection Licensing Basis ....................................... 3-2
4 EXAMINATION APPROACH AND RESULTS..................................................................... 4-1

4.1 Fire Areas and Associated Fire Hazards ................................................................... 4-2
4.1.1 1FA-AB-100C – Reactor Plant Auxiliary Equipment Area ................................. 4-2
4.1.2 1FA-AB-64A – 4160V Switchgear Room .......................................................... 4-2
4.2 Performance Criteria ................................................................................................. 4-3
4.3 Identification of Applicable Structures, Systems, and Components ........................... 4-4
4.3.1 Fire Area 1FA-AB-100C – Reactor Plant Auxiliary Equipment Area.................. 4-4
4.3.2 Fire Area 1FA-AB-64A – 4160V Switchgear Room........................................... 4-5
4.4 Selection of Deterministic or Performance-Based Approach ..................................... 4-5
4.5 Performance-based Engineering Analyses................................................................ 4-5
4.5.1 Fire Modeling.................................................................................................... 4-6
4.5.1.1 Defining Fire Scenarios .............................................................................. 4-6
4.5.1.2 Evaluation of Fire Scenarios....................................................................... 4-7
4.5.2 Risk Evaluation................................................................................................. 4-8
4.5.2.1 Core Damage Frequency (CDF)................................................................. 4-8
4.5.2.2 Large Early Release Frequency (LERF) ..................................................... 4-8
4.6 Risk Informed Change Evaluation ............................................................................. 4-9
4.6.1 Change Analysis Cases...................................................................................4-10
4.6.1.1 Fire Area 1FA-AB-100C – Reactor Plant Auxiliary Equipment Area...........4-11
xi
Case 1—Baseline................................................................................................4-11
Case 2—Compliance...........................................................................................4-11
Case 3 – Partial Upgrade ....................................................................................4-11
4.6.1.2 Fire Area 1FA-AB-64A – 4160V Switchgear Room....................................4-12
Case 1 – Baseline ...............................................................................................4-12
Case 2 – Compliance ..........................................................................................4-12
Case 3 – Installation of an Automatic Sprinkler System .......................................4-12
4.6.2 Bundling ..........................................................................................................4-12
4.6.3 Defense-in-Depth and Safety Margin...............................................................4-13
4.6.4 Integrated Decision-Making .............................................................................4-14
4.7 Monitoring ................................................................................................................4-15
4.8 Program Documentation, Configuration Control, and Quality ...................................4-16
5 EXAMINATION OF THE OTHER ELEMENTS OF THE STANDARD.................................. 5-1

5.1 Fundamental Fire Protection Program and Design Elements .................................... 5-1
5.1.1 Review Methodology ........................................................................................ 5-1
5.1.2 Review Results................................................................................................. 5-2
5.2 Fire Protection for Non-Power Operation .................................................................. 5-3
5.2.1 Review Methodology ........................................................................................ 5-3
5.2.2 Review Results................................................................................................. 5-3
5.3 Non fuel damage Radioactive Release ..................................................................... 5-6
5.3.1 Methodology Review ........................................................................................ 5-6
5.3.2 Review Results................................................................................................. 5-6
6 NFPA-805 AS AN ALTERNATIVE LICENSING BASIS ...................................................... 6-1

6.1 Adoption of the Standard........................................................................................... 6-1
6.2 Use of the Standard to support Exemption/Deviation Requests ................................ 6-1
7 CONCLUSIONS AND RECOMMENDATIONS .................................................................... 7-1

7.1 Conclusions .............................................................................................................. 7-1
7.2 Recommendations .................................................................................................... 7-2
7.3 Observations............................................................................................................. 7-3
8 REFERENCES .................................................................................................................... 8-1
xii
A TECHNICAL ISSUES.......................................................................................................... A-1
B REVIEW OF “FUNDAMENTAL FIRE PROTECTION PROGRAM AND DESIGN

ELEMENT”............................................................................................................................. B-1
C FIRE MODELING ................................................................................................................ C-1

C.1 Defining Fire Scenarios ........................................................................................ C-1
C.1.1 Fire Area 1FA-AB-64A – 4160V Switchgear Room........................................... C-1
C.1.2 Fire Area 1FA-AB-100C – Reactor Plant Auxiliary Equipment Area.................. C-3
C.1.3 Transient Fire Scenario .................................................................................... C-5
C.2 Selection of Fire Models ....................................................................................... C-7
C.3 Analysis................................................................................................................ C-7
C.3.1 Unit 1 4 KV Switchgear Room .......................................................................... C-7
C.3.2 Unit 1 Reactor Plant Auxiliary Equipment Area: MCC Fire................................ C-9
C.3.3 Unit 1 Reactor Plant Auxiliary Equipment Area: Transient Fire ....................... C-10
C.4 Observations and Insights .................................................................................. C-11
D CHANGE ANALYSIS.......................................................................................................... D-1

D.1 Risk Calculation.................................................................................................... D-2
D.2 Assessment of Defense-in-Depth and Safety Margin............................................ D-3
D.2.1 Examination of elements of Defense-in-Depth.................................................. D-3
D.2.2 Examination of the Safety Margin ..................................................................... D-4
D.3 Plant Change Evaluation ...................................................................................... D-5
D.4 Observations and Insights .................................................................................... D-5
xiii
LIST OF FIGURES
Figure 3-1 NFPA 805 Methodology (NFPA 805 [Ref. 2] Figure 2-2) ........................................ 3-3
Figure 3-2 Engineering Analysis in Support of NFPA 805 (NFPA 805 [Ref. 2], Figure 2-3) ..... 3-4
Figure 4-1 Integrated Decision-Making Process.....................................................................4-15
Figure C-1 Configuration of the 4.16KV Switchgear Fire ......................................................... C-2
Figure C-2 MCC Fire Scenario in Fire Area 1FA-AB-100C...................................................... C-4
Figure C-3 Transient Fire Scenario in Fire Area 1FA-AB-100C ............................................... C-6
xv
LIST OF TABLES
Table 4-1 Steps in the NFPA-805 [Ref. 2] and Appropriate Section in the Pilot
Evaluation Report............................................................................................................ 4-1
Table 4-2 Sample Table for Assessing Alternatives ..............................................................4-14
Table A-1 Discussion of the Technical Topics........................................................................ A-2
Table B-1 Results of the Review of “Fundamental Fire Protection Program and Design
Element” at the Pilot Plant ............................................................................................... B-2
Table C-1 Summary of the Features of the Selected Fire Models ........................................ C-12
Table C-2 Fire Modeling Results for Scenario 1: Switchgear Room, Switchgear Fire........... C-14
Table C-3 Fire Modeling Results for Scenario 2: MCC Room, MCC Fire.............................. C-15
Table C-4 Fire Modeling Results for Scenario 3: MCC Room, Transient Fire....................... C-16
Table D-1 Risk Calculation Summary for the Baseline Case .................................................. D-7
Table D-2 Risk Calculation Summary for the Alternative Design Case................................... D-9
xvii
1
BACKGROUND
In 1997, the National Fire Protection Association (NFPA) began an effort to develop a
Performance-Based Standard for Light Water Reactor Electric Generating Plants (NFPA 805).
During the same year, the NRC staff proposed development of a Risk-Informed and
Performance-Based fire protection rule. In response, the commission directed the staff to work
with the NFPA on a Risk-Informed and Performance-Based consensus Standard. This Standard,
when completed, could be endorsed by the NRC as a voluntary alternative to the existing fire
protection regulation.
The NFPA Technical Committee, with wide support from utility fire protection engineers, NRC
staff and other industry experts, developed and issued NFPA 805. The Standard was approved
for publication by the NFPA membership on November 15, 2000. This Standard breaks new
ground in the application of risk information and performance based evaluation of fire protection
at nuclear power plants. Because the approach taken in NFPA 805 is intrinsically different than
the current prescriptive criteria, it requires technical and operational validation.
Public Service Electric and Gas (PSEG-Nuclear) volunteered the Salem Generating Station
(SGS) as the pilot plant for evaluation of the NFPA 805 Standard. At the time of the pilot study,
Salem used approximately 20,000 feet of Electrical Raceway Fire Barrier Systems (ERFBS) to
protect electrical raceways from postulated fires [Ref. 1]. The fire rating of the installed fire
wrap material was under review. As part of this comprehensive review, PSEG-Nuclear was
considering the use of Risk Informed/Performance Based methods (NFPA 805) to evaluate the
need to perform plant modifications considering the safety benefit of various modifications in
relation to cost.
The Pilot Evaluation at Salem included an assessment of Electrical Raceway Fire Barrier
Systems (EFRBS) to provide representative and appropriate examples for examining use of the
Engineering Analyses (Section of NFPA 805). From an industry perspective, the evaluations
performed considering the ERFBS issues at Salem were considered representative and
appropriate examples to examine use of the Engineering Analyses sections of the NFPA 805.
1-1
2
OBJECTIVES
The principal objective of the NFPA 805 Pilot Evaluation was to evaluate whether the NFPA
805 provided the framework for a performance-based approach to fire protection and was
practical and cost-effective for use in nuclear power industry. The pilot program was also
intended to examine general use of RI/PB methods for fire protection applications. The results
may help utilities make informed decisions on use of the Standard at their sites.
In general, the objective of the pilot project focuses on examining whether the process defined in
the Standard can work rather than examining the methods and technical bases for the quantitative
results.
In going through the process, these principal questions were being investigated.
Does the Standard Provide the Framework Necessary to Implement A Performance-Based

Fire Protection Program?
The NFPA 805 provides general steps for a performance-based approach to fire protection at
commercial nuclear power plants. A specific objective of this project was to determine if all the
necessary steps have been identified and described such that a user can follow to the end results.
This evaluation did not verify if the Standard is complete in fulfilling its intended scope of
specifying “…the minimum fire protection requirements for existing light water nuclear power
plants during all phases of plant operation, including shutdown, degraded conditions, and
decommissioning.”
Is the Standard Practical?
Use of the Standard (in part or as the licensing basis for the plant) may require plant design and
operational changes to adhere to the “Fundamental Fire Protection Program and Design
Element” (Chapter 3) and will require methods and tools to conduct Engineering Evaluations in
support of deterministic and/or performance-based Approach (Sections 2 and 4). The pilot
project investigated whether such requirements can be met in a practical way. For example, are
there requirements in Chapter 3 that can not be satisfied within the current plant design or can
current fire modeling or risk analysis technology support the Engineering Evaluation
requirements of the Standard.
Can the Standard be Used in a Cost-effective Way?
This objective requires that we understand the costs associated with use of the Standard, in part
or as a plant’s licensing basis, and whether these costs make use of the standard prohibitive.
2-1
3
SCOPE
3.1 NFPA 805 Approach
The primary focus of the Pilot Evaluation was to test the NFPA 805 process, rather than perform
detailed evaluations of specific plant conditions and issues. Calculations performed as part of
this evaluation are intended to gain insights into the use of NFPA 805 and do not represent the
pilot plant’s fire protection program and/or fire risk.
To accomplish the objectives stated in Section 2, the Pilot Evaluation assessed the NFPA 805
process as summarized in Figures 3-1 and 3-2 of this report (Figures 2-2 and 2-3 in Ref. 2).
Figure 3-1 shows the general NFPA 805 approach, while Figure 3-2 shows the basic steps of the
engineering analyses needed in support of the NFPA 805.
The general NFPA 805 approach is provided in Section 2-2 of the Standard. The approach
requires the following steps:
a) Establish the fundamental fire protection program (Chapter 3 of the Standard).
b) Identify fire areas and associated fire hazards.
c) Identify the performance criteria that apply to each fire area (Section 1-5 of the Standard).
d) Identify systems, structures, and components (SSCs) in each fire area to which the
performance criteria apply.
e) Select the deterministic and/or performance-based approach for the performance criteria
(Chapter 4 of the Standard).
f) When applying a deterministic approach, demonstrate compliance with the deterministic

requirements (Chapter 4 of the Standard).
g) When applying a performance-based approach, perform engineering analyses to demonstrate

that performance-based requirements are satisfied. These analyses shall include, for example,
engineering evaluations, probabilistic safety assessments, or fire modeling calculations
(Section 2-3 of the Standard).
h) Perform the plant change evaluation that demonstrates that changes in risk, defense-in-depth,
and safety margins are acceptable (Section 2-3.4 of the Standard). If any one of these is
unacceptable, additional fire protection features or other alternatives shall be implemented.
3-1
Scope
i) For the resulting plant fire protection program, provide adequate documentation, ensure the
quality of the analyses, and maintain configuration control of the resulting plant design and
operation (Section 2-6 of the Standard).
j) Develop a monitoring program to monitor plant performance as it applies to fire risk. This
program shall provide feedback for adjusting the fire protection program, as necessary
(Section 2-5 of the Standard).”
The Pilot Evaluation was conducted by following this process. These steps were examined at
differing levels of detail. The objective was to concentrate on the areas that were considered to
be most critical in the use of the Standard. In particular, a substantial amount of the Pilot
Evaluation effort was expended in examination of fundamental fire protection requirements
(Chapter 3), fire modeling and change analysis.
Section 4 of this report addresses examination of the steps (b) through (j) in the general
approach. The “Fundamental Fire Protection Program and Design Elements” in the standard
(step (a) above) is unique in that it introduces a prescriptive element in a performance-based
standard. A detailed review of the fire protection program at the pilot plant was performed
against these requirements. Results of this review is documented in Section 5 and Appendix B
of this report.
3.2 Other Elements of the Standard
The Pilot study performed specific evaluations of other elements of the Standard. The elements
that were reviewed are those that are considered additional or new requirements from the current
fire protection regulations. The primary focus of these reviews was to determine the practicality
and cost-effectiveness of implementation if a plant were to adopt the new standard. Specifically,
this evaluation addressed the fundamental fire protection program, additional fire protection
features that would need to be provided for SSCs important to non-power operation and non-fuel
damage radioactive release. These are referred to as “Other Elements of the Standard.” Section 5
of this report provides the results of the evaluation of the other elements of the Standard.
The Life Safety and Business Interruption goals were not addressed. Fire Protection During
Decommissioning and Permanent Shutdown (Chapter 5 of NFPA 805) was also not within the
scope of the Pilot Evaluation.
3.3 NFPA 805 as an Alternate Fire Protection Licensing Basis
The Pilot Evaluation includes an assessment of the impact of adopting NFPA 805 as an
alternative licensing basis or using NFPA 805 methods to support specific changes to an existing
licensing basis. This assessment is provided in Section 6 of this report.
3-2
Scope
Establish Mandatory Fire

Protection Elements
(Chapter 3)
Identify Fire Hazards
Nuclear Safety
Identify Performance Life Safety
Criteria to be Examined Property Damage/Business Interruption
(Chapter 1) Radiation Release
Identify Structures, Systems

or Components (SSCs) that
Apply to Criteria
Deterministic Approach Performance Based Approach
Maintain Compliance with Existing Evaluate Ability to Satisfy

Plant License Basis Performance Requirement
(10CFR50 App R, Approved Exemptions, (Chapter 4)
Engineering Evaluations)
Performance Basis
Deterministic Basis
Engineering
Verify Deterministic Requirements are Met Equivalency Define Fire Scenarios and Design Basis for each
fire area being considered. Evaluate using, e.g.,
NO
Evaluations
(Chapter 4)
•Fire Modeling to Quantify the Fire Risk and
Margin of Safety
•PSA to Examine Impact on Overall Plant Risk
Risk-Informed Change Evaluation

Feedback
Evaluate Risk Impact of Changes to the
Approved Design Basis
Is Change
Acceptable?
Examples:
YES
Design basis documents
Documentation and Configuration Fire hazards analysis
Control Nuclear safety capability assessment
Supporting engineering calculations
Probabilistic safety analysis
Risk-informed change evaluations
Establish Monitoring Program
Figure 3-1
NFPA 805 Methodology (NFPA 805 [Ref. 2] Figure 2-2)
3-3
Scope
Performance-Based Approach
Evaluate Ability to satisfy performance requirements
(Chapter 4)
Engineering Analysis
QUALITATIVE Quantitative Probabilistic safety

assessment and
techniques
Fire Hazard Assessment
Evaluate Evaluate Consider

Step 1 Step 2 fire protection Step 3
fire exposure alternatives
features to prevent
damage
Identify fire protection Effectiveness of fire protection Consider other equipment or

objectives, equipment to features to satisfy performance methods to meat perfor-
protect (e.g., from nuclear requirements, fire barriers, mance requirements (e.g., Step 1
safety analysis) acceptable suppression, detection, manual reducing combustibles or
fire damage and spread. response, prevention method. potential ignition sources).
Identify combustible type, Will fire protection feature(s) Consider additional or

quantity, location, function prior to damage alternative fire protection
concentration, and threshold to satisfy features. Step 2
combustible characteristics. performance requirements?
Identify potential ignition Are fire protection systems Consider deterministic

sources, ignition energy, designed and installed per approach.
and frequency, industry and national standards?
plant specific fire history.
Consider area configuration, Availability of systems,

geometry, separation, regular testing and
intervening combustibles, maintenance programs.
air flow.
Define limiting fire scenarios Can
performance
requirements be Next Step
No
satisfied for these fire
scenarios?
Yes
Figure 3-2
Engineering Analysis in Support of NFPA 805 (NFPA 805 [Ref. 2], Figure 2-3)
3-4
4
EXAMINATION APPROACH AND RESULTS
This section contains examination of the steps outlined in figures 2-2 and 2-3 of the standard
with the exception of the “Fundamental Fire Protection Program and Design Elements.”
Evaluation of this step is documented separately in section 5.1 of this report.
As stated in the scope section, the primary focus of the NFPA 805 Pilot Evaluation was an
integrated assessment of the significant sections of NFPA 805. To accomplish this PSEG-
Nuclear volunteered the Salem Generating Station (SGS) to be a pilot plant.
PSEG-Nuclear has undertaken a comprehensive effort to resolve Electrical Raceway Fire Barrier
Systems (ERFBS) qualification issues at Salem. The pilot considered opportunities for the use
of the NFPA 805 risk informed/performance based (RI/PB) methods to review plant
configuration and identify the modifications that are cost beneficial with respect to the plant risk
(safety) benefit. Two fire areas were analyzed using the techniques of NFPA 805 as part of this
pilot evaluation.
The table below identifies the steps outlined in the risk-informed/performance-based method of
NFPA 805 and the section of this report that discusses the pilot activities.
Table 4-1
Steps in the NFPA-805 [Ref. 2] and Appropriate Section in the Pilot Evaluation Report
NFPA Chapter 2 Approach Pilot Evaluation
Identify fire areas and associated fire hazards Section 4.1
Identify the performance criteria that apply to each fire area (NFPA Section 1-5). Section 4.2
Identify systems, structures, and components (SSCs) in each fire area to which Section 4.3
the performance criteria apply.
Select the Deterministic and/or performance-based approach for the performance Section 4.4
criteria (See NFPA Section 4).
When applying a deterministic approach, demonstrate compliance with the Section 4.4
deterministic requirements (See NFPA Section 4).
When applying a performance-based approach, perform engineering analyses to Section 4.5

demonstrate that performance-based requirements are satisfied. These analyses
shall include, for example, engineering evaluations, probabilistic safety
assessments and fire modeling calculations (see NFPA Section 2-3).
4-1
Examination Approach and Results
NFPA Chapter 2 Approach Pilot Evaluation
Perform the plant change evaluation that demonstrates that changes in risk, Section 4.6
defense-in-depth and safety margins are acceptable (see Section 2-3.4). If any
one of these is unacceptable, additional fire protection features or other
alternatives shall be implemented.
Develop a monitoring program to monitor plant performance as it applies to fire Section 4.7
risk. This program shall provide feedback for adjusting the fire protection
program, as necessary (Section 2-9).
For the resulting plant fire protection program, provide adequate documentation, Section 4.8
ensure the quality of the analyses, and maintain configuration control of the
resulting plant design and operation (see Section 2-5).”
4.1 Fire Areas and Associated Fire Hazards
Two fire areas were selected for the Pilot Evaluation. They were selected on the basis of:
• Known issues related to ERFBS that allow for beneficial engineering analysis, particularly
fire modeling and risk evaluation
• Diversity of combustible loading between the two areas
• Diversity of fire hazards between the two areas
• Diversity of detection and suppression systems between the two areas
• Applicability of the areas as generic examples
Description of the selected fire areas and associated fire hazards are provided below.
4.1.1 1FA-AB-100C – Reactor Plant Auxiliary Equipment Area
This Fire Area is located in the Auxiliary Building at the 100’ Elevation. This area contains
demineralizers, filters, and pumps for the Chemical and Volume Control System and Waste
Disposal Systems. ERFBS is provided on raceways in the fire area, primarily for Train A and
Train C equipment. Train B raceways are unprotected in the area. This fire area is provided
with detection in the area of major hazards. An automatic suppression in not provided.
It is expected that the installed ERFBS in this Fire Area has fire resistance that ranges from 15
to 45 minutes.
4.1.2 1FA-AB-64A – 4160V Switchgear Room
The 4160V Switchgear Room is located on elevation 64’ in the Auxiliary Building. It contains
the 4160V Vital Buses 1A, 1B, and 1C, as well as 560-Volt Control Rod Drive Motor-Generator
Sets, Exhaust Fans, 208/120-Volt LGT Bus, 1C 460-Volt Vital Bus Extension and Inverters.
Partial height Marinite Walls (approximately 15’ in height) are provided to separate the
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redundant switchgear. The 4160V Switchgear Room is provided with area-wide detection and a
manually actuated Carbon Dioxide total flooding system.
A ERFBS is provided for electrical raceways within the switchgear room, , when located above
opposite division switchgear, and when the raceway establishes a fire propagation path between
redundant trains.
The 4160V Switchgear Room has an approved exemption from Section III.G.2 of Appendix R,
in that complete protection of redundant trains of safe shutdown equipment (the 4160V
Switchgear) is not provided with a 1-hour barrier and that an automatic suppression system is not
provided.
The installed ERFBS in this Fire Area a fire resistance that ranges from approximately 15 to 45
minutes.
4.2 Performance Criteria
The NFPA 805 requires that each fire area be examined against the Nuclear Safety, Radioactive
Release, Life Safety, and Plant Damage/Business Interruption performance criteria (established
in section 1-5 of the standard).
This Evaluation piloted the nuclear safety and radioactive release performance objectives and
criteria. While a full change analysis was not completed, the attributes of the standard were
piloted to gain understanding of potential pitfalls in use of the standard. An evaluation of the
radioactive release aspects of NFPA 805 is provided in Section 5.3 of this report. Evaluation of
life safety and plant damage/business interruption objectives are outside of the scope of this Pilot
Evaluation.
The following are the nuclear safety goals, objectives, and performance criteria from NFPA 805:
“1-3.1 Nuclear Safety Goal. The nuclear safety goal is to provide reasonable assurance
that a fire during any operational mode and plant configuration will not prevent the plant
from achieving and maintaining the fuel in a safe and stable condition.”
“1-4.1 Nuclear Safety Objectives. In the event of a fire during any operational mode
and plant configuration, the plant shall be as follows:
a) Reactivity Control. Capable of rapidly achieving and maintaining subcritical

conditions.
b) Fuel Cooling. Capable of achieving and maintaining decay heat removal and
inventory control functions.
c) Fission Product Boundary. Capable of preventing fuel clad damage so that the
primary containment boundary is not challenged.”
“1-5.1 Nuclear Safety Performance Criteria. Fire protection features shall be capable
of providing reasonable assurance that, in the event of fire, the plant is not placed in an
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unrecoverable condition. To demonstrate this, the following performance criteria shall be

met:
a) Reactivity Control. Shall be capable of inserting negative reactivity to achieve

and maintain subcritical conditions. Negative reactivity inserting shall occur
rapidly enough such that fuel design limits are not exceeded.
b) Inventory and Pressure Control. With fuel in the reactor vessel, head on and
tensioned, inventory and pressure control shall be capable of controlling coolant
level such that subcooling is maintained for a PWR and shall be capable of
maintaining or rapidly restoring reactor water level above top of active fuel for a
BWR, such that fuel clad damage as a result of a fire is prevented.
c) Decay Heat Removal. Shall be capable of removing sufficient heat from the
reactor core or spent fuel such that fuel is maintained in a safe and stable
condition.
d) Vital Auxiliaries. Shall be capable of providing the necessary auxiliary support

equipment and systems to assure that the systems required under (a), (b), (c), and
(e) are capable of performing their required nuclear safety function
e) Process Monitoring. Shall be capable of providing the necessary indication to

assure the criteria addressed in (a) through (d) have been achieved and are being
maintained.”
The nuclear safety performance objectives and criteria are very similar to the deterministic
performance goals of 10 CFR 50, Appendix R, Section III.L, with slight variations based on fires
originating in different operating modes. Note that fires originating in low-power operation were
not part of the change analysis (i.e., impact of the change on fire risk during low-power
operations was not evaluated) but were considered and examined as part of the Pilot Evaluation
discussed in Section 5.2 of this report.
4.3 Identification of Applicable Structures, Systems, and Components
In this step of the NFPA 805 process the equipment within the Fire Areas of concern that is
required to meet the performance criteria must be identified. This step identifies the critical
targets (i.e., equipment, cables) within the Fire Area that must remain functional during and after
a fire in order to satisfy the performance criteria. Specifically, this step identifies the specific
targets to be evaluated for post-fire availability, and their locations for evaluation using
deterministic or performance-based techniques.
4.3.1 Fire Area 1FA-AB-100C – Reactor Plant Auxiliary Equipment Area
ERFBS are provided in the area for Train A, B, and C emergency power cables. The protected
cable trays traverse east-west across the length of the fire area. The protection for these cable
trays is the majority of the ERFBS provided in this area.
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Throughout most of the fire area, it must be shown that both Train “A” and Train “C” power
cables/circuits remain free of fire damage. The cable trays containing these divisions run east-
west and have north-south separation throughout the fire area.
Two of three 4kV divisions of power are required to support Appendix R safe shutdown
requirements, therefore loss of any 2 of the 3 4kV buses would not be acceptable.
4.3.2 Fire Area 1FA-AB-64A – 4160V Switchgear Room
Division A cables are enclosed in ERFBS where they pass the Division B and C Switchgear.
Division B cables are enclosed in ERFBS where they pass the Division A and C Switchgear. In
addition, cables which could be intervening combustibles between the A and B Switchgear and
between the B and C Switchgear are enclosed in ERFBS.
Due to the lack of redundant safe shutdown systems or equipment outside of this fire area and
the adverse consequences of an unmitigated fire in this area, a large portion of the ERFBS in this
area cannot be eliminated with a deterministic approach as part of the Fire Barrier Reduction
Project. All three divisions of emergency power are located in this area. An unmitigated fire in
this area would result in a loss of all vital ac power, regardless of whether the vital buses were
being supplied by offsite power or the emergency diesel generators. Two of three 4kV divisions
of power are required to support Appendix R safe shutdown requirements, therefore loss of any 2
of the 3 4kV buses would not be acceptable.
4.4 Selection of Deterministic or Performance-Based Approach
The purpose of this step in NFPA 805 is to select, based on the information gathered in the
previous steps, either the deterministic or performance-based approach for meeting the
performance criteria. In a full scale adoption of NFPA 805 as an alternate licensing basis, it is
expected that a combination of approaches would be used for a given fire area.
The deterministic criteria for nuclear safety closely resemble Appendix R separation criteria,
with provisions for the use of existing engineering equivalency evaluations, such as Generic
Letter 86-10 evaluations. Since the deterministic approach is presently employed the two fire
areas are assessed using the performance-based approach.
4.5 Performance-based Engineering Analyses
The next step in the NFPA 805 process is to perform the engineering analyses to determine if the
performance criteria are met.
NFPA 805 defines Performance-based approach as:
“A performance-based approach relies upon measurable (or calculable) outcomes

(i.e., performance results) to be met but provides more flexibility as to the means
of meeting those outcomes. A performance-based approach is one that establishes
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performance and results as the primary basis for decision-making and

incorporates the following attributes: (1) Measurable or calculable parameters
exist to monitor the system, including facility performance; (2) Objective criteria
to assess performance are established based on risk insights, deterministic
analyses, and/or performance history; (3) Plant operators have the flexibility to
determine how to meet established performance criteria in ways that will
encourage and reward improved outcomes; and (4) A framework exists in which
the failure to meet a performance criteria, while undesirable, will not in and of
itself constitute or result in an immediate safety concern.”
4.5.1 Fire Modeling
4.5.1.1 Defining Fire Scenarios
The purpose of this step was to initially define the fire scenario, based upon insights associated
with the location of critical equipment needed for plant safe shutdown within the area, potential
fire hazards within the area, and fire protection systems and features and strategies within the
area.
NFPA 805 – Sections 2-3.1.3, 2-3.1.4 and Appendix C Section C-3 outline the requirements for
defining the fire scenarios. Fire scenario refers only to the quantitative input to and output from
fire modeling calculations. Depending on the particular fire model utilized, input included the
following:
a) Physical values related to the enclosure geometry and boundary characteristics
b) Nature and location of ignition sources
c) Fuel arrays (initial combustible and intermediate combustibles)
d) Heat release and fire growth rates
e) Ventilation conditions
f) Target locations and damage characteristics
g) Detection and suppression device location and operating characteristics
h) Other data required for the model calculations
Several fire scenarios were selected for this Pilot Evaluation. These fire scenarios where
selected to best meet the objectives of this project and are not intended to represent a complete
set of all scenarios with potential risk significance at Salem.
The following fire scenarios were selected to exercise the Standard.
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1. An electrical fire in the 4KV switchgear in Unit 1 Switchgear Room to examine impact on the
safe shutdown division protected by the degraded ERFBS. This scenario requires ignition of
the secondary combustibles to pose a threat to the protected train located in the room.
2. An electrical fire in an MCC in Unit 1 Auxiliary Equipment Room. This fire area is
comprised of multiple open compartments and involves ignition and propagation of fire in
overhead trays (some involving combustible wrap material).
3. A transient fire in the Unit 1 Auxiliary Equipment Room near the entrance to the Diesel
Generator Room. The fire source is a lubricating oil spill with potential target wrapped in
different material (FS-195 and EM-50) overhead.
Both Maximum Expected (MEFS) and Limiting (LFS) conditions were defined for each of these
fire scenario. Guidance for selection of fire scenarios, available in other references such as EPRI
FIVE [Ref. 3] and Fire PRA Implementation Guide [Ref. 4] were used. The LFSs were defined
by identifying the input parameter(s) in the fire scenario that could result in unfavorable
conditions with respect to the performance criteria with lowest margin. Identification of the
input parameter(s) that could introduce the least margin requires understanding of the fire
scenario characteristics, i.e., which parameter has the most impact on obtaining unfavorable
results and technical bases that supports the input parameter (i.e., degree of confidence). Fire
size and severity may be the likely factor in many fire scenarios, but depending on the scenario,
other parameters, such as flame spread, may provide the limiting margin.
Description of the selected fire scenarios is detailed in Appendix C. Section C.1 provides the
description of the MEFS, while description of the LFS is provided in section C.3 where
evaluation of these fire scenarios is documented.
4.5.1.2 Evaluation of Fire Scenarios
These scenarios were modeled, as appropriate for the different change analysis cases developed
in Section 4.6.1.
Evaluation of the fire scenarios was conducted along the following steps:
Selection of fire modeling codes. In general, the guidance in Section C-2 of NFPA 805 was
followed for selection of an appropriate model. However, the selection of the codes was, for the
most part, driven by the ability to conduct the evaluation within the allowed resource and time-
frame and meet the project objectives. Use of any field or computational fluid dynamic (CFD)
model was not considered for this reason.
Four zone models, FIVE [Ref. 5], CFAST [Ref. 6], COMPBRN-IIIe [Ref. 7] and MAGIC
[Ref.8] were selected based on:
• Technical capabilities and limitations (i.e., room geometry limitations, modeling of forced
ventilation, modeling of suppression, propagation of uncertainties)
• Ability to calculate the desired end result (i.e., detector activation, hot gas layer temperature,
flame height)
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Establishment of appropriate protocol for use of the code. To gain the insights into use of
fire modeling while using multiple models, it was necessary to establish a consistent set of rules
that are followed when exercising the code. These rules are intended to ensure that:
• Appropriate and consistent input data is used, and
• Interpretation of the results is consistent with the code capabilities and limitations.
Evaluation. The fire models were used to determine the consequence of the fire scenarios
including target damage information and performance of the suppression/detection systems. The
target damage (i.e., affected equipment) was then provided as input to the risk evaluation in
Section 4.5.2 and detailed in Appendix D.
4.5.2 Risk Evaluation
The purpose of this step was to quantitatively assess fire risk by evaluating Core Damage
Frequency (CDF) and Large Early Release Frequency (LERF) for the scenarios in the change
analysis.
4.5.2.1 Core Damage Frequency (CDF)
Cases and fire scenarios for the two Fire Areas were evaluated to determine Core Damage
Frequency (CDF). The CDF was calculated using the best available information from the Salem
fire IPEEE [Ref. 9, 10], with adjustments made based on additional insights gained during the
Pilot Evaluation and engineering judgment. Train-level conditional core damage probabilities
(CCDPs) were used in these calculations based on the cable routing from the IPEEE.
4.5.2.2 Large Early Release Frequency (LERF)
Cases and fire scenarios for the two Fire Areas were evaluated to determine Large Early Release
Frequency (LERF). No established industry methods exist for evaluating the effects of fire on
LERF. The following approach was developed and used in the Pilot Evaluation.
A number of factors contribute to the frequency of a Large Early Release (LERF) based on the
magnitude/characteristics and timing of the release. The plant damage sequence (based on
availability of core and containment mitigating functions) and plant’s evacuation strategy (in part
based on plant’s location and siting) influence the likelihood of a large early release. At times,
early is defined based on the time between an evacuation is declared and containment failure
occurs.
The approach used in this Pilot Evaluation to determine the LERF was as follows. This
approach was used to determine the potential for LER from each fire scenarios, based on the
resulting plant damage sequence (PDS).
First, core damage sequences that are followed by an early breach of containment integrity such
as containment isolation failure or interfacing systems Loss of Coolant Accident (LOCA) can
lead to LER. Susceptibility of these systems/functions to the fire scenario was examined. If the
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fire scenario could lead to failure of these functions (e.g., failure of the high/low pressure
interface valves), the LERF was conservatively assumed equal to the CDF for the fire scenario.
Otherwise, random (i.e., independent) failure of these functions was considered to be
insignificant and was not figured into the risk-informed decision-making.
Second, the evacuation strategy for the site was reviewed to determine the timing and criteria for
evacuation. The fire scenario PDS was then evaluated against the criteria to determine if it can
lead to containment failure within the criteria defined as LER. For example, if the evacuation
strategy defined any release within 6 hours of declaring an evacuation as LER and the PDS can
not result in containment failure within this time frame, an early release was not considered
probable and no LERF was calculated. PDSs can lead to a LER through containment over-
pressurization only if the timing between fuel damage and containment failure is short.
Following is a discussion of PDSs and how they were evaluated to determine potential for early
containment over-pressurization failure.
Loss of Coolant Accidents (LOCAs) – The only LOCAs that can be introduced as the result of
a fire are; spurious opening of PORV(s)/SRV(s), Reactor Coolant Pump (RCP) or Reactor Feed
Pump (RFP) seal LOCA, or Interfacing Systems LOCA.
Anticipated Transient Without Scram (ATWS) – Generally fire-induced failure of the reactor
protection system is an unlikely event, as it requires several spurious operations occurring
simultaneously.
4.6 Risk Informed Change Evaluation
The Change Analysis is a key element in the Standard, since the analysis could be used at a
nuclear power plant for items such as:
• Evaluation of proposed plant modification or program changes on plant fire risk
• Evaluation of identified non-conforming or degraded conditions on plant fire risk
The Change Analysis included clear identification of the “before” and “after” configurations,
evaluation of the proposed changes on risk, safety margin, and defense-in-depth, and an
integrated evaluation of the information to facilitate the decision making process.
Specific guidance and requirements are provided in Section 2-3.4 of NFPA 805 on the plant
change evaluation process (referred to in this report as “Change Analysis” and shown in Figure 1
as “Risk Informed Change Evaluation”). Additional guidance on change analysis is provided in
Appendices A and D of NFPA 805. Section 2-3.4 of NFPA 805 states:
“2-3.4* Plant Change Evaluation. A plant change evaluation shall be performed to

ensure that a change to a previously approved fire protection program is acceptable. The
evaluation process shall consist of an integrated assessment of the acceptability of risk,
defense-in-depth, and safety margins. The impact of the proposed change shall be
monitored (see Section 2-5).
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2-3.4.1* Risk Acceptance Criteria. The change in public health risk from any plant
change shall be acceptable to the AHJ. CDF and LERF shall be used to determine the
acceptability of the change.
When more than one change is proposed, additional requirements shall apply. If previous
changes have increased risk, but have met the acceptance criteria, the cumulative effect
of those changes shall be evaluated. If more than one plant change is combined into a
group for the purposes of evaluating acceptable risk, the evaluation of each individual
change shall be made available for review by the AHJ along with the evaluation of
combined changes.
2-3.4.2* Defense-in-Depth. The plant change evaluation shall ensure that the philosophy
of defense-in-depth is maintained, relative to fire protection (see Section 1-2) and nuclear
safety. The deterministic approach for meeting the performance criteria shall be deemed
to satisfy this defense-in-depth requirement.
2-3.4.3* Safety Margins. The plant change evaluation shall ensure that sufficient safety
margins are maintained. The deterministic approach for meeting the performance criteria
shall be deemed to satisfy this safety margins requirement.”
4.6.1 Change Analysis Cases
The purpose of this step is to define cases to be reviewed during the change analysis. This
involved definition of baseline cases in order to perform an assessment of the impact of proposed
changes. Clear definition of the baseline is important, since proposed changes are compared to
the baseline in order to determine acceptability.
The baseline case may be one that reflects current plant configuration. If the current plant
configuration differs from the approved licensing basis, possibly as the result of degradation in
fire protection features, the baseline may be selected as the approved licensing basis. Another
approach may consider use of Appendix R compliance as a baseline case. This would allow
changes within a Fire Area or group of Fire Areas to be evaluated against the risk associated with
compliance with Appendix R criteria.
Following determination of the baseline, alternative strategies (changes from the baseline) were
defined to compensate for potentially degraded conditions. These changes were assessed for
impact on the baseline risk identified above. These changes can be analyzed individually or in
groups, depending on the similarity of the changes and appropriateness of the grouping of
changes. In order to provide an effective exercise of the process, the Pilot Evaluation was
limited to three cases for two separate fire areas. These cases were the baseline case (approved
licensing basis), an Appendix R compliance case (compliance with the most practical
compliance option within Appendix R), and an alternative that was different than the baseline
and Appendix R compliance cases. These cases were selected, in part, to gain insights into the
relative risks associated with an approved licensing basis (an approved Appendix R exemption),
compliance with Appendix R criteria, and a potentially cost effective alternative.
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Note that this step in the NFPA 805 approach, in all likelihood, may be defined earlier in the
process, in order to facilitate prior steps in the approach (such as identification of applicable
structures, systems, and components and performance-based analyses).
The following change analysis cases at Salem were considered as part of the NFPA 805 Pilot
Evaluation:
Fire Area Case 1 -Baseline Case 2 Case 3

1FA-AB-100C – Reactor Baseline (Approved Compliance with Partial Upgrade of Fire
Plant Auxiliary Licensing Basis) Section III.G.2 of Wrap within the fire
Equipment Area Appendix R area
1FA-AB-64A – 4160V Baseline (Approved Compliance with Installation of
Switchgear Room Licensing Basis) Section III.G.1.a of Automatic Sprinkler
Appendix R System in the fire area
4.6.1.1 Fire Area 1FA-AB-100C – Reactor Plant Auxiliary Equipment Area
Case 1—Baseline
For the purposes of the Pilot Evaluation, the baseline case was assumed to be the approved
licensing basis. For Fire Area 1FA-AB-100C, this was an approved exemption from Section
III.G.2 of Appendix R. The specific statement in the exemption for this Fire Area is “Protection
of redundant cables will be provided by enclosing cables associated with one safe shutdown path
in a 1-hour rated fire barrier.” This was interpreted to mean the protection of the Train A and C
raceways with 1-hour ERFBS. Train B raceways were assumed to be unprotected. A list of
unprotected equipment is provided in Appendix D. Partial detection is provided, but no
suppression is provided.
Case 2—Compliance
The most practical Appendix R compliance option related to the configuration is 1 hour
protection for the Train A and Train C raceways, and no protection for the Train B raceways.
This is the same configuration as in the baseline case. However, for the compliance case, area
wide detection and suppression was included in the evaluation, as required by Section III.G.2.c
of Appendix R.
Case 3 – Partial Upgrade
This scenario consisted of the current plant configuration (fire wrap providing its as built fire
resistance, partial detection, with no suppression) with selected upgrades to fire wrap to ensure
the protection of the Train A and Train C raceways in the area.
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4.6.1.2 Fire Area 1FA-AB-64A – 4160V Switchgear Room
Case 1 – Baseline
For the purposes of the Pilot Evaluation, the baseline case was assumed to be the approved
licensing basis. For Fire Area 1FA-AB-64A, this was an approved exemption from Section
III.G.2 of Appendix R. The specific statement in the exemption is:
“…Specifically, Fire Areas 1&2FA-AB-64A are protected by manually released CO2

systems. In addition, redundant equipment is separated by partial 1-hour barriers.”
In addition:
“Protection for cables associated with one safe shutdown path will be provided by 1-hour
barriers when the cables leave the protection provided by the partial height Marinite
walls. Separation of divisions will be maintained by enclosing cables when they pass
through or over opposite division areas. Additionally, intervening combustibles between
the redundant switchgear sets will be eliminated by enclosing them in 1-hour rated
barriers. If a fire were to occur in the 4160V Switchgear Rooms, it would be rapidly
detected by the area-wide detection system. The manual CO2 system would be operated
by personnel responding to the fire notification. The system of Marinite walls and partial
1-hour barriers will maintain one division free of fire damage until the fire is
extinguished.”
The baseline case was considered to be a loss of a single 4160V Division of power, with the
remaining two divisions of power remaining free of damage.
Case 2 – Compliance
There was not a practical Appendix R compliance option to consider as a solution, due to the
configuration of the room and presence of all three divisions of vital switchgear within the room.
The closest configuration to compliance in this area would be extension of the Marinite walls to
form separation of the redundant switchgear.
Case 3 – Installation of an Automatic Sprinkler System
The installation of an automatic sprinkler system in the area was the third case. Case 3
considered the automatic sprinkler system, in conjunction with the as-installed degraded ERFBS
and other fire protection features installed in the area.
4.6.2 Bundling
Risk-informed decision-making requires evaluation of risk estimates before and after a change.
The scope of the estimated risk, however, may vary in several respect.
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Multiple changes. If multiple changes, previous or as part of the current examination, is

implemented, the risk estimates shall reflect cumulative impact of all changes combined unless
the risk is reduced or the change is considered insignificant for each plant change.
Fire vs. Total Risk. There are two of concerns. One is use of appropriate risk acceptance
criteria and the other is the ability to combine risk estimates that may have been derived with
considerably different level of robustness. The risk acceptance criteria documented in
Regulatory Guide 1.174 [Ref. 11] (figures 3 and 4) does not split into various initiators. Use of
these criteria for fire risk requires adjustment to develop separate fire-induced risk acceptance
criteria.
Fire Area vs. Plant Risk. The main body of the standard does not provide any rules as to
whether a change analysis shall be applied to a single fire area or the entire plant. If total plant
fire risk is used to determine acceptability of a change, increased risk in one fire area may be
offset by reduction in fire risk in another. Guidance for when and how changes are to be bundled
across fire areas is critical to risk-informed fire protection decision-making.
4.6.3 Defense-in-Depth and Safety Margin
The Defense-in-Depth elements (prevention, growth, and nuclear safety) were evaluated to
ensure that the change maintained a reasonable balance between all elements of the Defense-in-
Depth (DiD), without too much reliance being placed on an individual element.
A systematic approach was used to examine the impact of the change on various elements of
DiD. If the change weakens one element of defense in depth, a discussion should be provided to
demonstrate that the element of defense is not completely eliminated by the change.
In the example table below, alternative plant changes under consideration are represented by the
designators P1 (change 1 associated with Prevention), P1+G1 (change 1 associated with
Prevention and a measure associate with Growth), NS1 (change 1 associated with Nuclear
Safety). The current plant licensing basis was used as a baseline for assessing change.
The arrows in the table below are samples of a qualitative method to assess various plant changes
and their impact on various elements of Defense-In-Depth, change in risk, and risk acceptance
criteria. For example, a down arrow indicates that an expected reduction in risk could be
attributed to the change, an up arrow for a expected increase in risk, and a sideways arrows
indicating no expected change in risk. The last column should present discussion of the
proposed plant change against fire risk acceptance criteria.
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Table 4-2
Sample Table for Assessing Alternatives
1
Case Prevention Growth Nuclear 'Risk Fire Risk
Safety Acceptance
Criteria
Baseline 0 0 0 0
Alternative 1 (P1) p ↔ n ↔
Alternative 2 (P1+G1) p p ↔ p
Alternative 3 (NS1) ↔ ↔ p p
P, G and N refer to the elements of Defense-in-Depth, (i.e., fire Prevention, fire Growth/Damage, and Nuclear
Safety, respectively)
4.6.4 Integrated Decision-Making
The purpose of this task was to assess how the information obtained in the previous tasks would
be utilized in the decision-making process. The guidance contained in Section 2 of RG 1.174
[Ref. 11] was utilized.
In implementing risk-informed decision-making, changes are expected to meet a set of key

principles. These principles, as discussed in RG 1.174 [Ref. 11], are:
a) The proposed change either meets the current regulation or is related to a requested
exemption or rule change.
b) The proposed change is consistent with the defense-in-depth philosophy.
c) The proposed change maintains sufficient safety margins.
d) When proposed changes result in an increase in core damage frequency and/or risk, the
increases should be small and consistent with the intent of the Commission’s Safety Goal
Policy Statement
e) The impact of the proposed change should be monitored using performance measurement
strategies.
Each of these principles was considered in the risk-informed, integrated decision-making

process, as illustrated in Figure below (Figure 1, Reg. Guide 1.174).
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Change is consistent
with defense-in-depth
philosophy
Licensing
Basis Change maintains
sufficient Safety
Margin
Integrated
Decision-Making
Use performance- Proposed increases in CDF

measure strategies to and/or risk are small and
monitor the change are consistent with the
commissions Safety Goal
Policy Statement (RG 1.174)
Figure 4-1
Integrated Decision-Making Process
4.7 Monitoring
Monitoring is considered a key attribute of risk-informed decision-making, and is addressed in

NFPA 805 in several places, including:
• Section 2-2.8 of the Standard states that “A monitoring program shall be established to assess
the performance of the fire protection program in meeting the performance criteria
established in this Standard.”
• Section 2-3.4, in discussion of the Plant Change Evaluation, states that “The impact of the
proposed change shall be monitored (see Section 2-5).”
• Section 2-5 states that “A monitoring program shall be established to ensure that the
availability and reliability of the fire protection systems and features are maintained and to
assess the performance of the fire protection program in meeting the performance criteria.
Monitoring shall ensure that the assumptions in the engineering analysis remain valid.” This
includes establishing acceptable levels of availability, reliability, and performance, as well as
establishing methods of monitoring these levels.
Additional guidance is provided in Appendix A of the Standard [Ref. 2] , including reference to

the Maintenance Rule and Regulatory Guide 1.174 [Ref. 11] for examples and guidance on
monitoring. Appendix A, Section A-2.5 states that “Assumptions that are not subject to change
do not need to be monitored. The level of monitoring of assumptions should be commensurate
with their risk significance.”
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The change analysis was reviewed to identify items that may require monitoring, based upon the
guidance provided in NFPA 805 and Regulatory Guide 1.174. The review was done to identify if
the particular items (i.e., detection, suppression equipment, limitation on combustible loading,
credited safe shutdown equipment) are under a current monitoring program and whether the
program is appropriate, based upon the guidance in the Standard and judgment. The review also
examined whether monitoring would place additional burden on a plant that elects to use NFPA
805 methods, either due to adoption of the Standard or use of its methods in support of its current
licensing basis.
Our review concluded that, with the exception of the fire PSA, the current monitoring program
captures the attributes of the fire protection features credited. However, need for inclusion of
additional equipment in the monitoring program is anticipated. In addition, some level of
training on the importance of monitoring and the basis it provides for the performance-based
analysis is appropriate.
4.8 Program Documentation, Configuration Control, and Quality
Guidance and requirements are provided in NFPA 805 and its appendices on documentation,
configuration control and quality requirements, including the following:
• Section 2-2.7 states that “The fire protection program documentation shall be developed and
maintained in such a manner that facility design and procedural changes that might affect the
fire protection engineering analysis assumptions can be identified and analyzed.”
• Section 2-3.3.3 states that “The PSA approach, methods, and data shall be acceptable to the
AHJ. They shall be appropriate for the nature and scope of the change being evaluated, be
based on the as-built and as-operated and maintained plant, and reflect the operating
experience at the plant.” Clarification in Appendix A, Section A-2-3.3.3 states “The quality
of the PSA analysis needs to be good enough to confidently determine that the proposed
change is acceptable. Appendix D describes the fire PSA methods, tools, and data that are
adequate for the evaluation of the fire risk impact for many changes. Note that some change
evaluations can require analyses that go beyond this guidance.”
• Section 2-6 of the Standard addresses program documentation, configuration control, and
quality. It includes general information regarding clear definition of assumptions and results,
as well as ensuring design basis documents are maintained up to date. Specific requirements
are provided regarding independent verification of analyses, calculations, or models,
verification and validation of models and methods, limitations of use, qualification of users,
and uncertainty analyses.
This task of the Pilot Evaluation considered the change evaluations in Task 2 and reviewed
potentially affected documentation and documentation that may need to be established to support
an evaluation using NFPA 805 methods. This effort focused primarily on items that may
currently not meet the requirements and guidance contained in NFPA 805, such as a fire risk
analysis, which may or may not reflect the as-built configuration of the plant. This review looked
into the level of effort or quality that would be needed to support various levels of analyses using
NFPA 805 methods (i.e., an updated Fire PSA may not be required for limited scope risk
assessments). Particular attention was paid to quality assurance requirements and guidance
4-16
outlined in NFPA 805 for Fire PSAs, since additional requirements could result in substantial
industry effort and resistance in the use of the Standard. The review also looked into the level of
documentation that would be appropriate for fire modeling calculations.
Uncertainty Analysis
The purpose of an uncertainty analysis is to consider the significance of uncertainty in the data,
model, and other analysis tools in the interpretation of the findings.
The issue of the degree of uncertainty that can be tolerated for regulatory purposes in PSAs
should cover and approach to treatment of uncertainty that:
• Address parametric uncertainty and any explicit model uncertainties in the assessment of
mean values;
• Identify sources of uncertainty related to modeling and perform sensitivity studies to evaluate
the impact of using alternate models for the principal implicit model uncertainties; and
• Identify the sources of uncertainty related to incompleteness and use quantitative analyses or
qualitative analyses as necessary to explore the impact of incompleteness as appropriate to
the decision and the acceptance guidelines.
For “very small” CDF/LERF increases, the uncertainty analysis would be limited to that
associated with the changes in CDF and LERF and the use of sensitivity analysis to test the
changes in CDF and LERF against the acceptance guidelines. For larger CDF/LERF increases,
uncertainty and sensitivity analysis would also apply to the baseline CDF and LERF.
The pilot project did not examine use of the uncertainty methods in implementing the Standard.
This was done primarily due to time and resource limitations. However, currently methods exist
that can help to identify and quantify uncertainty in fire propagation, damage and risk estimate.
Several fire modeling codes, e.g., COMBPRN-IIIe and MAGIC, provide methods for
propagation of uncertainties in calculation of the consequences of a fire scenario. Propagation of
uncertainties in risk models has existed for years. The main issue still remains defining the
sources of uncertainty and assigning a distribution with adequate technical basis tied to relevant
evidence.
A combination of applying these methods, sensitivity analyses and quantification of margin of

safety should be used to provide the level of confidence necessary for decision making.
Scope, Level of Detail, and Quality of the PSA
The purpose of this step was to assess the requirements and guidance provided in NFPA 805, RG
1.174, and other industry documents against the PSA used in the Pilot Evaluation to see how its
scope, level of detail, and quality compare to industry Standards.
Guidance and requirements are provided in NFPA 805 and its appendices on documentation,
configuration control and quality requirements, including the following:
4-17
Section 2-2.7 states: “The fire protection program documentation shall be developed and
maintained in such a manner that facility design and procedural changes that might affect the fire
protection engineering analysis assumptions can be identified and analyzed.”
Section 2-3.3.3 states: “The PSA approach, methods, and data shall be acceptable to the AHJ.
They shall be appropriate for the nature and scope of the change being evaluated, be based on the
as-built and as-operated and maintained plant, and reflect the operating experience at the plant.”
Clarification in Appendix A, Section A-2-3.3.3 states “The quality of the PSA analysis needs to
be good enough to confidently determine that the proposed change is acceptable. Appendix D
describes the fire PSA methods, tools, and data that are adequate for the evaluation of the fire
risk impact for many changes. Note that some change evaluations can require analyses that go
beyond this guidance.”
Section 2-6 of the Standard addresses program documentation, configuration control, and
quality. It includes general information regarding clear definition of assumptions and results, as
well as ensuring design basis documents are maintained up to date. Specific requirements are
provided regarding independent verification of analyses, calculations, or models, verification and
validation of models and methods, limitations of use, qualification of users, and uncertainty
analyses.
As part of this task, potentially affected existing documentation and those that currently are not
maintained as part of the plant design basis or licensing documentation but may need to be
maintained to support an NFPA 805 were reviewed. This effort focused primarily on items that
may currently not meet the requirements and guidance contained in NFPA 805, such as a fire
risk analysis, which may or may not reflect the as-built configuration of the plant. This review
considered what levels of effort or quality would be needed to support various levels of analyses
using NFPA 805 methods (i.e., an updated Fire PSA may not be required for limited scope risk
assessments). Particular attention was paid to quality assurance requirements and guidance
outlined in NFPA 805 for Fire PSAs, since additional requirements could result in substantial
industry effort and resistance in the use of the Standard. The review also considered what levels
of documentation would be appropriate for fire modeling calculations.
4-18
5
EXAMINATION OF THE OTHER ELEMENTS OF THE
STANDARD
The focus of this task was to gain insights on other elements of the Standard that may not be
directly associated with the change analysis, but may require consideration when utilizing NFPA
805 methods. The examination of the other elements of the Standard also provided input into the
discussion of the licensing basis alternatives for the adoption of NFPA 805. Of particular
interest in this task were elements of a fire protection program that may not have been addressed
explicitly in past NRC requirements, or that may not have the level of background
documentation typically associated with an Appendix R post-fire safe shutdown analysis. The
intent of this task was not to actually perform the analysis to address other aspects of the
Standard, but rather to gain insights into available plant information to support the analysis,
methods to perform the analysis, level of effort expected to perform the analysis, and expected
results. Aspects of the Standard to be reviewed include:
• Determination of a typical power plants compliance with the Fundamental Fire Protection
Program and Design Elements (NFPA 805 Chapter 3)
• Determination of fire protection systems and features necessary to meet the performance
criteria associated with non power operation aspects of the nuclear safety criteria (NFPA 805
Chapter 4.1)
• Determination of fire protection systems and features necessary to meet the performance
criteria associated with non fuel damage aspects of the radioactive release criteria (NFPA
805 Chapter 4.2)
5.1 Fundamental Fire Protection Program and Design Elements
5.1.1 Review Methodology
The purpose of the “Fundamental Program” chapter in NFPA 805 was that each power plant
would meet a minimum set of design and programmatic standards. Once that minimum set of
standards had been met, a licensee would be able to use performance based risk informed
techniques to demonstrate compliance with the various performance criteria.
The intent of the review of the Fundamental Fire Protection Program and Design Elements
chapter of NFPA 805 (Chapter 3) was not to perform a detailed item-by-item conformance
review of the pilot plant against the Standard. Instead, this review provides a benchmark of how
a typical plant may align with elements of the Standard that are more prescriptive in nature. This
review may be valuable for a plant considering the cost associated with adoption of the Standard.
5-1
Examination of the Other Elements of the Standard
5.1.2 Review Results
Appendix B contains the results of the detailed review of Chapter 3 of NFPA 805 - November
2000 ROP in a tabular format. As part of the Pilot Evaluation, each section of the Standard was
reviewed against the approved Fire Protection Program at Salem Generating Station. For those
items that are not currently met, an assessment was made as to whether a “previously approved
alternative” existed (NFPA 805 Section 3-1). If a “previously approved alternative” did not
exist, then a level of effort estimate to meet the new requirements was provided.
The following issues were identified:

• Floor Finishes. NFPA 101 only requires Class I interior floor finishes in corridors and exists
in occupancies where occupants are immobile or have security measures allowed that restrict
freedom of movement. This requirement is overly restrictive. A comment was submitted to
revise language.
• Outdoor high pressure flammable gas storage containers. Many utilities currently use
earthen walls or blast shields in lieu of orienting the long axis away from buildings. A
comment was submitted to allow the use of blast walls or earthen berms.
• Diesel Fire Pumps. The existing wording requires that all electric fire pumps need to be
seismic Category I Class IE electric motor driven fire pumps. This is in excess of any
previous NRC requirements relative to fire pump system design. A comment was submitted
to revise language.
• Separation of Fire Pumps. On multiple plant sites, it may be possible to interconnect the fire
pumping systems such that one plants fire pumps can provide adequate pressure and flow to
the opposite plants fire suppression systems. In this case, a fire in one plant’s pump house
will not render the fire suppression systems inoperable because these systems can be aligned
to the opposite plant’s fire water supply system. A comment was submitted to and an
exception to allow for this type of arrangement.
• Seismic design of Fire Water Supply. The requirement for standpipes functioning in the
event of a safe shutdown earthquake was never applied to plants operating or issued
construction permits prior to July 1, 1976. The current wording in the standard would
impose new requirements on BTP 9-5.1, Appendix A plants. A comment was submitted to
add an exception to allow the exemption from this section for plants previously approved.
• OS&Y valve requirements. The requirement that the control valve be an OS&Y gate valve is
too specific. The critical requirement should be that the valve is listed and that the valve is of
the indicating type. A comment was submitted to allow for the use of appropriately listed
valves.
• Internal Conduit Seals. An internal conduit research program was conducted in the late
1980’s that demonstrated internal conduits do not require seals to meet a three hour fire
resistance rating when certain condition exist. The fire test performed for the Conduit Fire
Protection Research Program is entitled “Conduit Seal Fire Tests of 101 Electrical Conduit
Penetrations”. This test was performed at Construction Technology Laboratories and many
plants have applied the results of this document. The standard should allow for the use of
qualified fire tests to determine whether an internal fire seal is necessary. A comment was
submitted to allow for the use of this test program.
5-2
• Structural Fire Proofing. The proposed standard does not address structural steel forming a
part of or supporting fire barriers. It is well understood that the viability of fire barriers is
critically dependent of the protection of structural steel forming a part of the barrier or
supporting the barrier. A comment was submitted to add Section 3-11.5 to address the
omission in the current standard.
5.2 Fire Protection for Non-Power Operation
5.2.1 Review Methodology
A review was performed of the guidance in NFPA 805 Appendix B (Section B-6, Special
Considerations for Non-Power Operational Modes) and Appendix D (Section D-4, Shutdown
Fire PSA) to determine the potential impact on a utility adopting NFPA 805. The qualitative
evaluation performed included the following:
Task 1 Review the existing plant outage processes and procedures to understand how fire
safety integrates into an outage safety plan
Task 2 Estimate the amount of analysis (equipment and cable identification, cable routing, fire
area analysis) required to identify and understand the effects of fire on equipment not
bounded by the Appendix R safe shutdown analysis.
Task 3 Identify any potential shutdown cooling (RHR) related vulnerabilities that could have
greater impact if a fire were to originate while shutdown rather than at power.
Task 4 Review the Fire PSA and IPE to gain any insights into events originating while
shutdown.
Task 5 Review the current NFPA 805 wording to identify discrepancies and/or clarifications.
The results of this review are presented in the following section.
Task 1 – Review the existing plant outage processes and procedures to understand how fire
safety integrates into an outage safety plan
Salem’s outage planning and management process is governed by two primary procedures:
• NC.OM-AP.ZZ-0001 “Outage Risk Assessment” [Ref. 12]
• NC.NA-AP.ZZ-0055 “Outage Management Program” {Ref. 13]
These procedures do address fire protection in the following manner:
5-3
• NC.OM-AP.ZZ-0001 “Outage Risk Assessment” Attachment 4
“Salem Shut Down Risk Assessment Review Guidelines”
“1.10 Fire Protection

1.10.1 All scheduled outage hot work should be reviewed to ensure that Fire
Protection measures, including Contingency plans, are adequate.
1.10.2 Special emphasis should be given to hot work in areas that contain
equipment required for maintenance of Key Safety Functions (i.e., decay
heat removal.
1.10.3 At least one Diesel Driven Fire Pump should be maintained
AVAILABLE.
1.10.4 Fire Pump cross-connect should be maintained AVAILABLE.”
• NC.NA-AP.ZZ-0055 “Outage Management Program” [Ref. 13]

“5.2.6.A Operator training should provide knowledge of the applicable shutdown
safety issues including loss of decay heat removal, inventory control,
electrical power availability, reactivity control, containment control, spent
fuel cooling, fire protection, control air, service water and vital support
systems…”
“5.3.6.B Review and plan for fire impairments and confined space entries, to
prevent manpower concerns for fire protection due to lack of notice and
multiple requests for confined space entry surveys”
These procedures adequately address the “classical” fire protection issues such as impairments,
hot work permits, and confined space entries. Although the Outage Risk Management Procedure
refers to “special emphasis” on hot work in areas containing equipment required for maintenance
of Key Safety Functions, the location of all the components and cabling necessary for the
maintenance of the key safety functions is not readily available.
To incorporate fire risk into the current procedures would require a minimal amount of effort.
Eighty hours has been estimated for this task.
Task 2 - Estimate the amount of analysis (equipment and cable identification, cable routing, fire
area analysis) required to identify and understand the effects of fire on equipment not bounded
by the Appendix R safe shutdown analysis.
The following plant documents were reviewed to determine the equipment credited for
maintenance of key safety functions:
• S1.OP-AB.RHR-0002 “Loss of RHR at Reduced Inventory” [Ref. 14]

• S1.OP-AB.RHR-0002 “Loss of RHR” [Ref. 15]
• S1.OP-AB.SF-0001 “Loss of Spent Fuel Pool Cooling” [Ref. 16]
• S1.OP-AB.FUEL-0002 “Loss of Refueling Cavity or Spent Fuel Pool Level” [Ref. 17]
5-4
• Salem Outage Management Engineering Document ZZ-ORAM [Ref. 18]
This list of equipment was then compared to the current Appendix R Safe Shutdown Equipment
List and Logics:
• VP2505-SSA “Salem Generating Station Safe Shutdown Compliance Assessment” [Ref. 19]
• Drawings 605416 through 605457 Safe Shutdown Logics [Ref. 20]
The results of the review indicate that a number of existing Appendix R components would
require an additional level of analysis and that a number of new components would require
analysis to determine where they may be susceptible to fire damage. Specifically, the following
was estimated:
• Twenty-four components may require additional analysis to account for “required” changes
in position.
• Thirty components and the appropriate circuits would need to be added to the analysis.
Approximately 600 hours was estimated for this task.
Task 3 Identify any potential shutdown cooling (RHR) related vulnerabilities that could have
greater impact if a fire were to originate while shutdown rather than at power.
The current safe shutdown analysis [Ref. 21] does not credit any cold shutdown repairs, only
manual actions. Therefore there is no additional impact on other modes of operation based upon
the current Appendix R analysis at the Pilot Plant.
However, other plants would need to determine if repairs were credited for cold shutdown as the
time available to implement those repairs may not exist during certain shutdown modes of
operation.
Task 4 Review the Fire PSA and IPE to gain any insights into events originating while
shutdown.
Salem does not have a PSA that addresses shutdown.
Task 5 Review the current NFPA 805 wording to identify discrepancies and/or clarifications.
During the Pilot the following issues/concerns with the current NFPA 805 wording were
identified:
• Section 1-5.1(b) Inventory Control – This section does not apply to non-power modes.
• Would a plant have to perform a change analysis if implementing “non-power” modes
• The changes made to differentiate between high and low risk evolutions does not eliminate
significant analysis. It seems to only apply to spent fuel pool cooling.
5-5
5.3 Non fuel damage Radioactive Release
5.3.1 Methodology Review
A review was performed of the NFPA 805 non-fuel radioactive release goals, objectives, and
criteria (Sections 1-3.2, 1-4.2, 1-5.2, 4-2, and A-4-2). A qualitative evaluation was performed
that:
• Reviewed plant documentation and discussed with plant staff areas of the plant where
potential non-fuel radioactive release could occur as a direct result of fire or subsequent fire
suppression activities. Guidance and clarification provided in Appendix A, Section A-4-2 of
the Standard were used.
• Plant design features were evaluated in areas that could potentially result in a radioactive
release. The evaluation considered source limitation and containment.
• Appendix A, Section A-2-6.1.2 of the Standard, in a discussion of the fire protection design
basis documentation, states that the documentation should include a listing and “description
and location of any equipment, including cabling between equipment, necessary to prevent
release of radioactive containment.” The need for identifying cables and level of effort
anticipated was reviewed to assess the practicality of this section of the Standard.
The results of this review are provided in the following section.
Three findings resulted from the qualitative review.

• Guidance is required for the implementation of NFPA 805 requirements.
NFPA 805 as written allows for either protection of vulnerable components (maintaining
containment) or limitation of source term as acceptable methods of meeting the Radioactive
Release Criteria. There are liquid and gaseous radwaste systems at Salem. These systems
and associated cabling are currently not identified as equipment requiring fire protection
features and therefore have not been located by fire area. There are also solid radwaste
storage areas. All of the locations have not been provided with suppression and/or detection.
Calculations estimating the amount of radioactivity that may be released as a result of a fire
have not been performed. Guidance should be provided to outline methodologies acceptable
to the AHJ.
• The current nuclear safety criterion for inventory and pressure control is not applicable to
states when the head is off or the fuel is in the spent fuel pool. A comment was submitted to
clarify the requirement.
• The current Radioactive Release Performance Criteria is not applicable to all types of
releases. A more appropriate method of identifying the limits would be to reference
10CFR20. A comment was submitted to revise the language.
5-6
6
NFPA-805 AS AN ALTERNATIVE LICENSING BASIS
As discussed at numerous Industry meetings the current version of NFPA 805 is a significant
step forward from the prescriptive requirements of 10CFR50 [Ref. 22] towards a more risk-
informed, performance-based standard. Also discussed at various forums was the NRC’s
intention to permit licensees the option to:
• Adopt NFPA 805 as a new licensing basis
• Maintain the existing licensing bases without changes
• Maintain the existing licensing bases, but allow the use of tools from NFPA 805 to support
exemption or deviation requests.
However, even with all these discussions many issues remain to be resolved before practical
implementation of the standard can begin. The logical place to resolve these issues would be in
an “Implementation Guide”.
This section provides a list of those licensing issues that arose out of discussions with the pilot
plant and other industry representatives and are programmatic in nature.
6.1 Adoption of the Standard
If a utility adopts NFPA 805 in whole the following issues require resolution:
• Interpretation of previously approved fire protection features and the acceptability of past
approval (BTP 9.5.1 SERs, GL 86-10 evaluations, etc.) for meeting the fundamental program
requirements in Chapter 3 of the Standard.
• Impact of NFPA 805 monitoring, documentation, and configuration control requirements,
etc.
• Significance of PSA updates or upgrades that may be required to adopt the Standard or use
NFPA 805 methods.
• There would appear to be the need to perform an analysis of those issues not previously
addressed (other modes of operation and radioactive release), however would there be a need
for some other type of resubmittal for issues previously addressed?
6.2 Use of the Standard to support Exemption/Deviation Requests
This appears to be the more likely and most cost effective use of the standard. Based upon the
pilot plant evaluation of the degraded wrap material the methods outlined in the standard have
6-1
NFPA-805 as an Alternative Licensing Basis
merit. However resolution of the following issues may affect that cost effectiveness of the
standards use in this fashion:
• Interpretation of the role of Chapter 3 of NFPA 805 when using the Standard to support a
plant’s current licensing basis.
• The necessity of addressing radioactive release due to fire when using the Standard to
support a plant’s current licensing basis.
• The necessity of addressing fire originating during non-power operation when using the
Standard to support a plant’s current licensing basis.
• The necessity of addressing life safety aspects of the standard when using the Standard to
support a plant’s current licensing basis.
6-2
7
CONCLUSIONS AND RECOMMENDATIONS
This section contains discussion of the results of the exercise of the NFPA 805 Standard at the
pilot plant. These results are presented as Conclusions, response to the objectives that we set out
to accomplish, and Recommendations, which could help to accomplish the primary goal of
ensuring the usefulness of NFPA 805 and RI/PB methods in general for fire protection
applications. A list of key observations is presented at the end of this section that may be
helpful to the users of the Standard.
In June of 2000, the project team submitted comments to the NFPA 805 technical committee
based on the lessons learned from this pilot evaluation. Those comments, for the most part,
reflected the conclusions presented here. The final draft of the NFPA 805 was approved for
publication in November of 2000.
7.1 Conclusions
It is the conclusion of this pilot project that NFPA 805 contains the steps necessary to start and
implement a performance-based fire protection program with the following caveats.
• The NFPA 805 Standard does not set forth an entirely performance-based approach to fire
protection, but instead defines and describes a Hybrid approach that is a mix of prescriptive
and performance-based. The Hybrid approach is embedded throughout the Standard and is
not limited to prescriptive requirements in Chapter 3, “Fundamental Fire Protection Program
and Design Elements.”
• The Standard provides the framework required to implement this Hybrid approach.
• The current state-of-the-art tools and methods can support implementation of a performance-
based approach within limitations. It is critical that the limitations are understood and
defensible decisions are made within the framework of the performance-based or Hybrid
approaches.
• Even with considerable information in the Appendices, a large number of questions of how
to use the Standard remain. Without guidance that address such specifics, use of the
Standard will be impractical for most potential users and can produce varying and potentially
unreliable conclusions.
• During the Pilot Evaluation, the team identified requirements within NFPA 805 which are
different than those of the current fire protection regulations. These could make the
Standard impractical for existing plants to implement. While none of the requirements in
Chapter 3 are physically or programmatically impossible, the cost associated with
implementing these requirements, without demonstrated safety benefit, could make
7-1
Conclusions and Recommendations
implementation of the Standard cost prohibitive for most facilities. These conflicts should be
resolved by clearly recognizing that these requirements should not result in backfits to the
existing plants. These requirement may relatively easily be incorporated into a new plant
(even though not applicable to NFPA 805).
• Use of the Standard in part or as the licensing basis for the plant introduces cost elements in
both directions. On one hand, use of the Standard as the licensing basis is expected to
introduce significant new costs for many programs as the result of the requirements in
Chapter 3. We should point out that this report identifies these new requirements and is not a
judgment on their value to fire safety. On the other hand, some of current requirements in
Appendix R, e.g., III.G, J and O, are not required under the Fundamental Fire Protection
Program and Design Element ( Chapter 3) and can be addressed using a performance-based
Approach. The net effect on cost is dependent on the individual plant’s fire protection
program and design, the plant’s existing fire protection license condition, and the manner in
which the Standard is utilized.
We believe that the above conclusions remain, for the most part, valid within the limited scope of
this pilot evaluation. Implementation of Life Safety and Plant Damage/Business Interruption
goals and objectives and the requirements for Fire Protection During Decommissioning and
Permanent Shutdown could introduce technical and programmatic challenges that have not been
identified by this evaluation.
7.2 Recommendations
Most of the conclusions and the lessons learned can be addressed in an Implementation Guide
for the Standard. Such a Guide should cover the following topics:
• Interpretation of previously approved fire protection features and the acceptability of past
approval (BTP 9.5.1 SERs, GL 86-10 evaluations, etc.) for meeting the fundamental program
requirements in Chapter 3 of the Standard.
• Interpretation of the role of Chapter 3 of NFPA 805 [Ref. 2] when using the Standard to
support a plant’s current licensing basis (use of NFPA 805 methods to support an exemption
or GL 86-10 evaluation).
• Fire Modeling:
− How to define fire scenarios based on operating experience and fire tests,
− When and how to define Limiting Fire Scenarios, i.e., which of the critical
parametere(s) need to be varied to define the appropriate LFS.
− How to establish whether appropriate fire modeling codes are used for the
scenario,
− When and how a quantitative evaluation of the uncertainties in the fire modeling
is to be performed.
− How the results of fire modeling are interpreted and used in making decisions,
e.g., when and how a LFS is used in evaluating performance.
7-2
• Fire Risk Evaluations

− Fire PSA Quality. Some definition of what are attributes of an acceptable fire
PSA is needed to help control the cost associated with performing these
engineering evaluations. While the standard does point out that the quality
required of a fire PSA needs to remain consistent with the plant change being
proposed, it does not describe what that quality entails.
− Maintenance of a Fire PSA - The standard requires that an engineering evaluation
performed in support of a change to a licensing basis is maintained consistent
with other Fire Protection Program Design Basis Documentation. There is no
precedent in what that documentation entails in case of a Fire PSA. For example,
how much of an Internal Events PSA will become part of the Fire Protection
Program Design Basis Documentation and needs to be maintained.
− Bundling – Should the plant change be evaluated on the basis of: a) single fire
area vs. total plant risk or b) fire risk vs. all risk.
− Fire Risk Acceptance Criteria – Implementation of the plant change analysis
requires a fire risk acceptance criteria. The standard only says that such criteria
shall be acceptable to AHJ.
• The necessity of addressing radioactive release due to fire when using the Standard to
• The necessity of addressing fire originating during non-power operation when using the
Standard to support a plant’s current licensing basis (use of NFPA 805 methods to support an
exemption or GL 86-10 evaluation).
• The necessity of addressing life safety aspects of the standard when using the Standard to
7.3 Observations
In the coarse of the Pilot Project a number of issues became evident. Even though these issues
do not directly reflect on the Standard they do require consideration if the Standard is to be used.
These may be addressed either in a Guide for implementation of the standard or elsewhere as
appropriate. Following is a list of these observations.
• While conducting a plant change evaluation, determination of baseline condition is not

always straight forward. This may be represented by the plant’s approved licensing basis,
current licensing basis or one of the compliance strategies. In addition, identifying what is a
plant’s approved licensing basis can present challenges.
• Bundling of changes is an issue. If changes could be “grouped” or “bundled”, this could
potentially allow changes that collectively reduce risk to be made without detailed
calculations or analysis per RG 1.174. For example, a degradation in one fire area can be
7-3
compensated by reduction in risk in another fire area or a degradation to fire risk and be
compensated with reduction in internal events or seismic risk.
• Determination of Large Early Release Frequency (LERF) with respect to fire does not have
precedent.
• Appendix R safe shutdown analyses and Fire PSAs can vary in the way they treat spurious
operation of equipment. This was not explored in great detail during the Pilot Evaluation
since other efforts, notably work by the NRC, NEI, and EPRI, are underway. Once this
effort is completed, an attempt to provide a tie between NFPA 805 methods and the
information provided in NEI 00-01 is needed.
• It appears that implementation of the standard at existing plants could introduce requirements
for new exemptions. The present language of the standard does not allow the use of
deterministic approaches for fire areas that rely on manual action for fire safe shutdown.
• Meeting the performance criteria in a deterministic manner does not always correlate to
lower risk than a performance based option.
• A tie between the NFPA 805 and the Significance Determination Process (SDP) methods
will help improve usefulness of the Standard.
7-4
8
REFERENCES
1. Salem Electrical Raceway Fire Barrier System Project, Appendix R Fire Area Compliance
Report, Revision 0, July 15, 1999
2. NFPA 805, “Performance-Based Standard for Fire Protection for Light Water Reactor
Electric Generating Plants,” Version 7.0, November 1999.
3. Electric Power Research Institute, TR-100370, Fire-Induced Vulnerability Evaluation

(FIVE), 1992.
4. Electric Power Research Institute, TR-105928, “Fire PRA Implementation Guide,”

December 1995.
5. Electric Power Research Institute, TR-100443, “Methods for Quantitative Fire Hazard
Analysis,” May 1992.
6. National Institute of Standards and Technology (NIST), “A User’s Guide for FAST:
Engineering Tools for Estimating Fire Growth and Smoke Transport,” January 2000.
7. Electric Power Research Institute, “COMPBRN-IIIe: An Interactive Computer Code for

Fire Risk Analysis,” NP-7282, May 1991.
8. Electricite de France, Report HT-31/99/007/A “MAGIC Software Version 3.4.1:

Mathematical Model,” April 1999.
9. PSE&G VTD No. 320758-01, “Salem Generation Station, Individual Plant Examination for
External Events, January 1996.
10. Review of the Submittal in Response to U.S. NRC Generic Letter 88-20, Supplement 4:
“Individual Plant Examination – External Events”, Revision 1, USNRC W6733
11. Regulatory Guide 1.174, “An Approach for Using Probabilistic risk Assessment In risk-
Informed Decisions on Plant-Specific Changes to the Licensing Basis” July 1998.
12. NC.OM-AP.ZZ-0001 “Outage Risk Assessment”
13. NC.NA-AP.ZZ-0055 “Outage Management Program”
14. S1.OP-AB.RHR-0002 “Loss of RHR at Reduced Inventory”
15. S1.OP-AB.RHR-0002 “Loss of RHR”
8-1
References
16. S1.OP-AB.SF-0001 “Loss of Spent Fuel Pool Cooling”
17. S1.OP-AB.FUEL-0002 “Loss of Refueling Cavity or Spent Fuel Pool Level”
18. Salem Outage Management Engineering Document ZZ-ORAM
19. VP2505-SSA “Salem Generating Station Safe Shutdown Compliance Assessment”
20. Drawings 605416 through 605457 Safe Shutdown Logics
21. DE-PS.ZZ-0001(Q)-A3-SSA, Revision 4, 3/1/99, Salem Safe Shutdown Analysis
22. 10 CFR 50, Appendix R, “Fire Protection Program for Nuclear Power Facilities Operating
Prior to January 1, 1979, Sections III.G, J, L, and O.”
23. Electric Power Research Institute, SU-105928, Guidance for Development of Response to
Generic Request for Additional Information on Fire Individual Plant Examination for
External Events (IPEEE),” March 2000.
24. NSAC-179L, “Automatic and Manual Suppression Reliability Data for Nuclear Power
Plant Fire Risk Analysis,” February 1994.
25. Appendix A to Branch Technical Position BTP APCSB 9.5-1, “Guidelines for Fire
Protection for Nuclear Power Plants Docketed Prior to July 1, 1976.”
26. Generic Letter 86-10, Supplement 1, “Fire Endurance Test Acceptance Criteria for Fire
Barrier Systems Used to Separate Redundant Safe Shutdown Trains within the Same Fire
Area,”
8-2
A
TECHNICAL ISSUES
At the start of the pilot evaluation project a list of the potential technical and programmatic
issues was prepared. These issues were examined for their relevance to this evaluation and
implementation of NFPA 805. The following Table contains review of the technical issues
related to implementation of NFPA 805 and the resolution strategy in the pilot project.
Each item is discussed with insights relative to the Salem Fire IPEEE [Ref. 9], Appendix R
analysis, and the NFPA 805 methodology [Ref. 2].
The table presents a collection of notes and working discussions that may be of value to users of
the NFPA 805.
A-1
Technical Issues
Table A-1
Discussion of the Technical Topics
Technical Issue NFPA 805 Pilot

Baseline and ∆Risk The change analysis requires that criteria for defining ∆Risk and its basis be established. In this
evaluation, ∆Risk is defined as the difference between the Baseline (i.e., the current Licensing Basis or
acceptable Regulatory compliance method), and where Compliance is restored within Reg. Guide
1.174 guidelines or alternate acceptable approach.
Bundling An important premise of risk-informed decision making is the ability to focus resources on areas most
important to safety. Safety margin and defense-in-depth examinations are safeguards to provide
confidence in the decision in the face of uncertainties.
Examination of acceptable ∆Risk should consider total plant risk due to fire for all compartments and
all changes, unless the change results in reduction or negligible change in risk. This pilot evaluation
was limited to selected fire areas and potential plant changes.
Total plant risk due to (internal and external events) may need to be considered if the change shows an
increase in risk. The scope of this evaluation, however, was limited to calculation of fire induced risk
only.
Safety margin and Defense in Depth Per NFPA 805, Reg. Guide 1.174 guidance will be used.
In addition, selection of maximum expected and limiting scenario to examine safety margin in fire
modeling.
Over-reliance on programmatic activities to compensate for weakness in plant design should be

avoided.
Mode of operation at start of fire A qualitative examination of the impact of a proposed change is appropriate to determine if the change
poses an added threat during shutdown operation. For example if a new sprinkler system is proposed
the post modification fire scenarios (with lower rated ERFBS and automatic suppression) should
demonstrate equivalent or reduced risk than the pre modification condition (with 1 hour ERFBS and
not automatic suppression) during shutdown operations.
End State When calculating risk, the PRA assumption of 24-hour mission time and hot shutdown was used. For
assessing whether or not the nuclear safety criteria of NFPA 805 has been satisfied, “Safe and Stable
Condition” was used.
A-2
Technical Issues

Performance for core uncovery. When calculating risk, any system that is demonstrated to be free of fire damage can be used to control
coolant level such that subcooling is maintained for a PWR and reactor coolant level is maintained or
rapidly restored above the top of active fuel for BWR.
For assessing whether or not the nuclear safety criteria of the NFPA 805 have been satisfied, the
deterministic nuclear safety criteria was used.
Circuit Analysis – a.k.a. Circuit NFPA 805 requirements remain consistent with Appendix R. The Standard allows “other risk
Selection informed methods acceptable to the AHJ can be used to refine the circuit analysis or its assumptions on
circuit failure modes”.
Circuit failure mode and likelihood Impact on the ∆Risk needs to be addressed. Demonstrate that the change does not create circuit failure
modes and likelihood in addition to the base strategy.
Circuit Analysis – a.k.a. Circuit The method should follow the industry approach under development by NEI. This approach is focused
Selection on selected equipment pairs and their risk significance. Probability of hot short is to be developed by
an expert panel.
Resulting in spurious operation and
subsequent probability of a spurious Another method, used in a few of the IPEEEs (not Salem), is to assign a hot short probability to all
event. equipment susceptible to a fire induced circuit failure/fault, i.e., MOV, AOV, pump etc. Equipment
types are reviewed to eliminate those that will not lead to spurious operation, e.g., normally energized
circuits. The value of 0.1 is considered appropriate for probability of a spurious operation and will be
used pending new research to support a different probability number.
Circuit Analysis – Spurious Spurious operation assessed – any and all one at a time. NFPA 805 allows “other risk informed
actuations methods acceptable to the AHJ can be used to refine the circuit analysis or its assumptions on circuit
failure modes”
Manual actions, PSA & Post-fire safe When recovery actions are credited in the performance based approach, their potential risk is evaluated
shutdown. Including, time available using appropriate Human Reliability Analysis (HRA) methods.
for recovery.
Applicability of Fire model(s) Use of FIVE [Ref. 5], CFAST [Ref. 6], MAGIC [Ref. 8] and COMPBRN-IIIe [Ref. 7] was
investigated.
A-3
Technical Issues

Fire size - Expected Electrical cabinets HRR and high energy cabinets per Generic RAI Guidance [Ref. 23]. The pilot
assumptions are consistent with the HRR review for high energy.
Oil fire HRR and duration should use the same, i.e., Salem IPEEE, which is consistent with the Fire
PRA Guide [Ref. 23]. Size of an unconfined spill should be considered (in addition to FIVE model) as
one of parameters when defining limiting fire scenario.
Maximum expected transient fire scenario HRR and model, i.e., exposure and location, should be
specific to the area considering both the hazards and targets in the room. The maximum expected
transient load should include transients from potential maintenance activities and their worst case
location, combustible load and likelihood of ignition. The limiting transient fire scenario uses these
variables to test the limit at which the performance criteria is not met, e.g., the location and
combustible load that causes damage to critical targets.
Detection and suppression analysis - Use of reliability data in NSAC-179L [Ref. 24] is appropriate. System unavailability is specific to the
Fire protection system plant and should be verified with plant experience. High unavailability (compared to the system
reliability/availability reliability of 1-5%) should be accounted for in addition to this data. For example, if the system is out
of service 3-4 days a year on a consistent basis, this adds another 1E-2 to the value in NSAC-179L for
system (2-5E-2).
Detection and suppression analysis - Fire modeling was used to check activation and timing of detection/suppression. Effectiveness was
Suppression effectiveness (automatic, assumed if the system was designed, installed, and maintained to applicable industry codes. The
manual) system was then credited if activated and effective.
Detection and suppression analysis - The unavailability of the suppression function should include any change that is the result of
Effect of (long term) compensatory compensatory measure in effect at the time, e.g., suppression system inoperable.
measures on suppression
Detection and suppression analysis - See note above for suppression effectiveness.
Scenario-specific detection and
suppression analysis
Detection and suppression analysis - See note above for suppression effectiveness.
Adequacy of detection time data
Damage criteria Thermal damage criteria developed in EPRI’s Fire PRA Implementation Guide and its Supplement for
Generic RAI Guidance were used in this Pilot Evaluation.
A-4
Technical Issues

Wrap Performance As tested via independent testing laboratory, the fire resistance of 3M FS-195 ranged from 10 to 18
minutes and for 3M-E50 ranged from 35 to 60 minutes. This testing was performed using the ASTM-
E-119 time vs. temperature exposure and the acceptance criteria established in Generic Letter 86-10
Supplement 1. The performance under Maximum Expected and Limiting fire exposure may be
different.
Impact of fires on operator The guidance in the Generic RAI [Ref. 23] may be used when bounding HEPs are used during
performance - Fire scenario cognitive screening. Use of the screening HEPs should be justified by demonstrating that certain attributes are
impact met that includes appropriate procedures and training.
For post fire actions credited, careful examination of what the operators need to do, the procedures and
training in place to ensure that these actions are done should be discussed. The current HRA methods
(e.g., ATHEANA) have been primarily implemented in non-fire risk models. However, use of these
methods to quantify the post fire HEPs are OK with appropriate selection of performance shaping
factor under fire condition.
Impact of fires on operator If the fire brigade is expected to provide post fire manual safe shutdown actions, the dependency
performance - Role of fire brigade in between safe shutdown Human Error Probabilities (HEPs) and Manual Suppression should be
plant response discussed.
Availability of safe shutdown It is normal practice in PSA to account for unavailability of equipment credited for accident mitigation.
equipment Similar considerations apply to equipment credited for post fire safety shutdown.
Flammable gas lines Consistent with the IPEEE approach, i.e., consideration only under seismic condition needed.
Analysis of main control room fires – In Pilot Project – generic guidance for a utility using NFPA 805 you must be addressed. Use Generic
Control circuit interactions RAI Guidance [Ref. 23] if needed including potential fires in the Main Control Room that can fail
circuits before transfer that can not be recovered from the ASP after the transfer.
Impact of fires on operator The guidance in the Generic RAI [Ref. 23] may be used when bounding HEPs are used during
performance - Fire scenario cognitive screening. Use of the screening HEPs should be justified by demonstrating that certain attributes are
impact met that include appropriate procedures and training.
For post fire actions credited, careful examination of what the operators need to do, the procedures and
training in place to ensure that these actions are done should be discussed. The current HRA methods
(e.g., ATHEANA) have been primarily implemented in non-fire risk models. However, use of these
methods to quantify the post fire HEPs is OK with appropriate selection of performance shaping factor
under fire condition.
Impact of fires on operator If the fire brigade is expected to provide post fire manual safe shutdown actions, the dependency
performance - Role of fire brigade in between safe shutdown HEPs and Manual Suppression should be discussed.
plant response
A-5
Technical Issues

Availability of safe shutdown PSA considerations are appropriate.
equipment
Flammable gas lines Consistent with the IPEEE approach, i.e., consideration only under seismic condition needed.
Analysis of main control room fires – In Pilot Project – generic guidance for a utility using NFPA 805 you must be addressed. Use Generic
Control circuit interactions RAI Guidance [Ref. 23] if needed including potential fires in the Main Control Room that can fail
circuits before transfer and cannot be recovered from the alternate shutdown panel (ASP) after the
transfer.
Analysis of main control room fires – Probability of control room abandonment due to habitability can be developed based on 15 minutes
Probability of control room (anticipated time from fire detection to control room abandonment) with in-cabinet detectors and 7
abandonment minutes without it. The curve in Appendix M of the EPRI Fire PRA Guide is appropriate for
determination of probability.
Analysis of main control room fires – See Generic RAI discussion for partitioning to other rooms in the Control Area such as Relay Rooms.
Partitioning of control room
frequency
Barrier performance analysis tools A fire barrier (including the doors, dampers and sealed penetrations) is effective if rated and qualified.
The rating should be verified against fire severity and location. Un-rated barriers are effective if
concrete walls. Un-rated doors, dampers or penetrations should be either justified as equivalent to a
rating or evaluated for possible fire propagation across the un-rated barrier.
Barrier qualification Effective if rated and qualified.
Fire barrier reliability analysis - Effective if rated and qualified. Reliability/unavailability may be quantified using method in the PRA
Adequacy of data for active and Guide and NUREG-4840.
passive barriers
Containment fires Need to be addressed if baseline risk is used to evaluate the change in risk or the change affects the
SSD system/circuits in the containment. Deterministic (Appendix R) information should be used to
assess system/circuits in the containment, e.g., PORV, process instrumentation, RHR circuits or
pressurizer circuits that may cause Spurious SI if damaged by fire.
A combination of the review of the historical data, general location of the identified circuits (e.g., on
the walls and away from the RCPs and other hazards) and a scoping evaluation of containment heat up
can be used as the basis to determine if the risk associated with containment fires requires evaluation .
Containment Performance Systems and circuits needed for containment performance are not included in the nuclear safety
criteria.
Containment performance is examined by evaluation of Large Early Release Frequency (LERF)

associated with risk significant fire scenarios.
A-6
Technical Issues

Configuration management If using NFPA 805, the analysis and documentation that supports it should be maintained and readily
retrievable.
Monitoring The Pilot Evaluation did not examine possible technical issues that may arise from monitoring of
additional fire protection equipment and features.
Fundamental Fire Protection Program Not required if NFPA 805 techniques issued under the existing plant licensing basis, e.g., to justify
and Design Elements deviations/exemptions.
Radioactive Release Performance The performance criteria for non-fuel damage events, radioactive release was qualitatively assessed in
Criteria the Pilot.
Life Safety Performance Criteria Not reviewed in the Pilot Evaluation.
Property Damage and Business Not reviewed in the Pilot Evaluation.
Interruption Performance Criteria
Decommissioning and Not reviewed in the Pilot Evaluation.
decontamination
A-7
B
REVIEW OF “FUNDAMENTAL FIRE PROTECTION
PROGRAM AND DESIGN ELEMENT”
The Fundamental Fire Protection Program and Design Element requirements described in
Chapter 3 of the NFPA 805 were reviewed against the fire protection program elements at the
pilot plant to determine . Results of that review are provided below. This table contains the
requirement and if and how the pilot plant meets these requirements. Where indicated comments
were submitted to the NFPA committee.
B-1
Review of “Fundamental Fire Protection Program and Design Element”
Table B-1
Results of the Review of “Fundamental Fire Protection Program and Design Element” at the Pilot Plant
NFPA 805 Chapter 3 Fundamentals Salem Compliance Statement Comments
3.2 Fire Protection Plan

3.2.1 Intent. A site-wide fire protection plan shall be established. This Comply. None.
plan shall document management policy and program direction and shall
define the responsibilities of those individuals responsible for the plan’s
implementation. This section establishes the criteria for an integrated
combination of components, procedures, and personnel to implement all
fire protection program activities.
3.2.2* Management Policy Direction and Responsibility. A policy Comply. None.
document shall be prepared that defines management authority and
responsibilities and establishes the general policy for the site fire
protection program.
3.2.2.1* The policy document shall designate the senior management Comply. None.
position with immediate authority and responsibility for the fire
protection program.
3.2.2.2* The policy document shall designate a position responsible for Comply. None.
the daily administration and coordination of the fire protection program
and its implementation.
3.2.2.3* The policy document shall define the fire protection interfaces Comply. None.
with other organizations and assign responsibilities for the coordination
of activities. In addition, this policy document shall identify the various
plant positions having the authority for implementing the various areas
of the fire protection program.
3.2.2.4* The policy document shall identify the appropriate AHJ for the Comply assuming the AHJ is the None.
various areas of the fire protection program. utility personnel responsible for
implementation for the program
3.2.3* Procedures. Procedures shall be established for implementation Comply. The standard requires that a limit on
of the fire protection program. In addition to procedures that might be impairment duration be established.
required by other sections of the standard, the procedures to accomplish However, the user is allowed to
the following shall be established: determine the appropriate limit.
(1)* Inspection, testing, and maintenance for fire protection systems and
B-2
features credited by the fire protection program

(2)* Compensatory actions implemented when fire protection systems
and other systems credited by the fire protection program and this
standard cannot perform their intended function and limits on
impairment duration
(3)* Reviews of fire protection program–related performance and trends
(4) Reviews of physical plant modifications and procedure
changes for impact on the fire protection program
(5) Long-term maintenance and configuration of the fire protection
program
(6) Emergency response procedures for the plant industrial fire brigade
3-3 Prevention. A fire prevention program with the goal of preventing a Comply. None.
fire from starting shall be established, documented, and implemented as
part of the fire protection program. The two basic components of the fire
prevention program shall consist of both the following:
1) Prevention of fires and fire spread by controls on operational

activities,
2) Design controls that restrict the use of combustible materials.
The design control requirements listed in the remainder of this section

shall be provided as described.
3.3.1 Fire Prevention for Operational Activities. The fire prevention Comply. None.
program activities shall consist of the necessary elements to address the
control of ignition sources and the use of transient combustible materials
during all aspects of plant operations. The fire prevention program shall
focus on the human and programmatic elements necessary to prevent
fires from starting or, should a fire start, to keep the fire as small as
possible.
3.3.1.1 General Fire Prevention Activities. The fire prevention Comply. None.
activities shall include but not be limited to the following program
elements:
(1) Training on fire safety information for all employees and contractors
B-3
including, as a minimum, familiarization with plant fire prevention

procedures, fire reporting, and plant emergency alarms
(2)* Documented plant inspections including provisions for corrective
actions for conditions where unanalyzed fire hazards are identified
(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
3.3.1.2* Control of Combustible Materials. Procedures for the control Comply. Elements 3 through 6 do not limit
of general housekeeping practices and the control of transient control of combustible to the power
combustibles shall be developed and implemented. These procedures block.
shall include but not be limited to the following program elements:
(1)* Wood used within the power block shall be listed pressure-
impregnated or coated with a listed fire-retardant application.
Exception: Cribbing timbers 6 in. by 6 in. (15.2 cm by 15.2 cm) or

larger shall not be required to be fire-retardant treated.
(2) Plastic sheeting materials used in the power block shall be fire-
retardant types that have passed NFPA 701, Standard Methods of
Fire Tests for Flame Propagation of Textiles and Films, large-scale
tests, or equivalent.
(3) Waste, debris, scrap, packing materials, or other combustibles shall
be removed from an area immediately following the completion of
work or at the end of the shift, whichever comes first.
(4)* Combustible storage or staging areas shall be designated and limits
shall be established on the types and quantities of stored materials.
(5)* Controls on use and storage of flammable and combustible liquids
shall be in accordance with NFPA 30, Flammable and Combustible
Liquids Code, or other applicable NFPA standards.
(6)* Controls on use and storage of flammable gases shall be in
accordance with applicable NFPA standards.
3.3.1.3 Control of Ignition Sources.
B-4
3.3.1.3.1* A hot work safety procedure shall be developed, implemented, Comply. None.
and periodically updated as necessary in accordance with NFPA 51B,
Standard for Fire Prevention During Welding, Cutting, and Other Hot
work, and NFPA 241, Standard for Safeguarding Construction,
Alteration, and Demolition Operations.
3.3.1.3.2. Smoking and other possible sources of ignition shall be Comply. None.
restricted to properly designated and supervised safe areas of the plant.
3.3.1.3.3 Open flames or combustion-generated smoke shall not be Comply. None.
permitted for leak or air flow testing.
3.3.1.3.4* Plant administrative procedure shall control the use of Comply. None.
portable electrical heaters in the plant. Portable fuel-fired heaters shall
not be permitted in plant areas containing equipment important to
nuclear safety or where there is a potential for radiological releases
resulting from a fire.
3.3.2 Structural. Walls, floors, and components required to maintain Comply. None.
structural integrity shall be of noncombustible construction, as defined in
NFPA 220, Standard on Types of Building Construction.
3.3.3 Interior Finishes. Interior wall or ceiling finish classification shall Salem has deviation(s) to the Class I interior finishes for floors is a
be in accordance with NFPA 101®, Life Safety Code®, requirements for guidelines of Appendix A to BTP new requirement.
Class A materials. Interior floor finishes shall be in accordance with 9.5-1 for the Control Room.
Following comment was submitted to
NFPA 101 requirements for Class I interior floor finishes.
the Technical Committee:
Interior wall or ceiling finish
classification shall be in accordance
with NFPA 101®, Life Safety Code®,
requirements for Class A materials.
Interior floor finishes in corridors and
exits shall be in accordance with
NFPA 101 requirements for Class I or
Class II interior floor finishes. Interior
floor finishes for the Control Room
shall be in accordance with NFPA
101®, requirements for Class I interior
B-5
floor finishes.
Exception: For areas protected by
automatic sprinklers, there is no limit
on interior floor finish.
3.3.4 Insulation Materials. Thermal insulation materials, radiation Comply. This requirement prohibits use of some
shielding materials, ventilation duct materials, and soundproofing UL listed products. For example,
materials shall be noncombustible or limited combustible. Thermo-Lag 330-1 is UL listed as a 3-
hour rated steel encapsulation (UL
design X611) but does not meet this
requirement.
3.3.5 Electrical.
3.3.5.1 Wiring above suspended ceiling shall be kept to a minimum. Do not comply. This is a new This is a new requirement. Cables
Where installed, electrical wiring shall be listed for plenum use, routed in requirement and is not discussed routed above control room ceilings are
armored cable, routed in metallic conduit, or routed in cable trays with in Salem licensing documents. generally not plenum rated, not routed
solid metal top and bottom covers. IEEE 383 rated cable was required in armor metal jacket, not routed in
and installed in the plant. Wiring metallic conduit, or not routed in cable
installed above ceiling in the trays covered (top & bottom) with
Control Room as well as other solid metal top and bottom covers.
areas of the plant is not listed for Some plants only put line detection in
plenum use or routed in conduit or the cable tray.
trays with metal covers. BTP 9.5-1 Appendix A [Ref. 25] is
less restrictive: “D.2.(j) Existing
cabling installed in concealed floor
and ceiling spaces should be protected
with an automatic total flooding halon
system.”
3.3.5.2 Only metal tray and metal conduits shall be used for electrical Comply, with the exception of Many plants use plastic conduit or duct
raceways. Thin wall metallic tubing shall not be used for power, core duct used in concrete walls. (core duct) inside walls. The chlorides
instrumentation, or control cables. Flexible metallic conduits shall only It is assumed that the scope of this in the concrete could degrade
be used in short lengths to connect components. section was does not include embedded metal conduits.
plastic conduit/core duct
embedded in concrete walls.
3.3.5.3* Electric cable construction shall comply with a flame Comply under exception None.
B-6
propagation test as acceptable to the AHJ. allowance.
Exception: Existing cable in place prior to the adoption of this standard

shall be permitted to remain as is.
3.3.6 Roofs. Metal roof deck construction shall be designed and Comply. Safety related buildings This is more restrictive than current
installed so the roofing system will not sustain a self-propagating fire on at Salem are not constructed with requirements. BTP 9.5-1 Appendix A,
the underside of the deck when the deck is heated by a fire inside the metal roof decks. Metal roof Section D.1(e) guidance is less
building. Roof coverings shall be Class A as determined by tests decks in non-safety related restrictive: "Metal deck roof
described in NFPA 256, Standard Method of Fire Tests of Roof buildings meet guidelines of construction should be noncombustible
Coverings. Appendix A to BTP 9.5-1 and listed as "acceptable for fire" in
(noncombustible or listed as Class the UL Building Materials Directory,
I by FM). or listed as Class I in the Factory
Mutual System Approval Guide". If a
metal deck meets BTP guideline, can it
also meet the new requirement?
3.3.7 Bulk Flammable Gas Storage. Bulk compressed or cryogenic Comply. BTP 9.5-1 Appendix A, Section D.2(b)
flammable gas storage shall not be permitted inside structures housing refers to bulk storage of compressed or
systems, equipment, or components important to nuclear safety. cryogenic gases only.
3.3.7.1 Storage of flammable gas shall be located outdoors, or in Comply. None.
separate detached buildings, so that a fire or explosion will not adversely
impact systems, equipment, or components important to nuclear safety.
NFPA 50A, Standard for Gaseous Hydrogen Systems at Consumer Sites,
shall be followed for hydrogen storage.
3.3.7.2 Outdoor high-pressure flammable gas storage containers shall be Comply. Should allow for blast wall design or
located so that the long axis is not pointed at buildings. missile projection calculation if
pointed at buildings. The intent of the
requirement is to ensure that a high-
pressure container does not become a
projectile and damage a building.
There are many engineering methods
to ensure that the high-pressure
container does not become a projectile
other than pointing it away from
buildings. Consideration should be
B-7
limited to Safety Related Buildings.

3.3.7.3 Flammable gas storage cylinders not required for normal Comply. None.
operation shall be isolated from the system.
3.3.8 Bulk Storage of Flammable and Combustible Liquids. Bulk Comply. None.
storage of flammable and combustible liquids shall not be permitted
inside structures containing systems, equipment, or components
important to nuclear safety. As a minimum, storage and use shall comply
with NFPA 30, Flammable and Combustible Liquids Code.
3.3.9* Transformers. Where provided, transformer oil collection basins Comply. This is not a specific requirement in
and drain paths shall be periodically inspected to ensure that they are free BTP 9.5-1 or NUREG 0800.
of debris and capable of performing their design function.
3.3.10* Hot Pipes and Surfaces. Combustible liquids, including high Comply. None.
flashpoint lubricating oils, shall be kept from coming in contact with hot
pipes and surfaces, including insulated pipes and surfaces.
Administrative controls shall require the prompt cleanup of oil on
insulation.
3.3.11 Electrical Equipment. Adequate clearance, free of combustible Comply. None.
material, shall be maintained around energized electrical equipment.
3.3.12* Reactor Coolant Pumps. For facilities with non-inerted Comply. For plants licensed under BTP 9.5-1
containments, reactor coolant pumps with an external lubrication system without inerted containment collection
shall be provided with an oil collection system. The oil collection system of RCP lube oil was a backfit under
shall be designed and installed such that leakage from the oil system is 10CFR50 Appendix R, Section III.O
safely contained or off normal conditions such as accident conditions or
earthquakes. All of the following shall apply:
(1) The oil collection system for each reactor coolant pump shall be
capable of collecting lubricating oil from all potential pressurized
and nonpressurized leakage sites in each reactor coolant pump oil
system.
(2) Leakage shall be collected and drained to a vented closed container
that can hold the inventory of the reactor coolant pump lubricating
oil system.
(3) A flame arrestor is required in the vent if the flash point
characteristics of the oil presents the hazard of a fire flashback.
B-8
(4) Leakage points on a reactor coolant pump motor to be protected shall

include, but not be limited to, the lift pump and piping, overflow
lines, oil cooler, oil fill and drain lines and plugs, flanged
connections on oil lines, and the oil reservoirs, where such features
exist on the reactor coolant pumps.
(5) The collection basin drain line to the collection tank shall be large
enough to accommodate the largest potential oil leak such that oil
leakage does not overflow the basin.
3.4 Industrial Fire Brigade.
3.4.1 On-Site Fire-Fighting Capability. All of the following Comply. None.
requirements shall apply:
(a) A fully staffed, trained, and equipped fire-fighting force shall be
available at all times to control and extinguish all fires on site. This force
shall have a minimum complement of five persons on duty and shall
conform with the following NFPA standards as applicable:
(1) NFPA 600, Standard on Industrial Fire Brigades (interior structural
fire fighting)
(2) NFPA 1500, Standard on Fire Department Occupational Safety and
Health Programs
(3) NFPA 1582, Standard on Medical Requirements for Fire Fighters
and Information for Fire Department Physicians
(b)* Industrial fire brigade members shall have no other assigned normal Comply. Salem has dedicated fire None.
plant duties that would prevent immediate response to a fire or other department onsite
emergency as required.
(c) During every shift, the brigade leader and at least two brigade Comply. Salem has dedicated fire None.
members shall have sufficient training and knowledge of nuclear safety department onsite
systems to understand the effects of fire and fire suppressants on nuclear
safety performance criteria.
Exception to (c): Sufficient training and knowledge shall be permitted to
be provided by an operations advisor dedicated to industrial fire brigade
support.
(d)* The industrial fire brigade shall be notified immediately upon Comply. Salem has dedicated fire None.
verification of a fire. department onsite
(e) Each industrial fire brigade member shall pass an annual physical Comply. Salem has dedicated fire None.
B-9
examination to determine that he or she can perform the strenuous department onsite
activity required during manual fire-fighting operations. The physical
examination shall determine the ability of each member to use
respiratory protection equipment.
3.4.2* Pre-fire Plans. Current and detailed pre-fire plans shall be Comply. None.
available to the industrial fire brigade for all areas in which a fire could
jeopardize the ability to meet the performance criteria described in
Section 1-5.
3.4.2.1* The plans shall detail the fire area configuration and fire Comply. None.
hazards to be encountered in the fire area, along with any nuclear safety
components and fire protection systems and features that are present.
3.4.2.2 Pre-fire plans shall be reviewed and updated as necessary. Comply. None.
3.4.2.3* Pre-fire plans shall be available in the control room and made Comply. None.
available to the plant industrial fire brigade.
3.4.2.4* Pre-fire plans shall address coordination with other plant groups Comply. None.
during fire emergencies.
3.4.3 Training and Drills. Industrial fire brigade members and other Comply. None.
plant personnel who would respond to a fire in conjunction with the
brigade shall be provided with training commensurate with their
emergency responsibilities.
(a) Plant Industrial Fire Brigade Training. All of the following

requirements shall apply:
(1) Plant industrial fire brigade members shall receive training consistent
with the requirements contained in NFPA 600, Standard on
Industrial Fire Brigades, or NFPA 1500, Standard on Fire
Department Occupational Safety and Health Program, as
appropriate.
(2) Industrial fire brigade members shall be given quarterly training and
practice in fire fighting, including radioactivity and health physics
considerations, to ensure that each member is thoroughly familiar
with the steps to be taken in the event of a fire.
(3) A written program shall detail the industrial fire brigade training
B-10
program.
(4) Written records that include, but are not limited to, initial industrial
fire brigade classroom and hands-on training, refresher training,
special training schools attended, drill attendance records, and
leadership training for industrial fire brigades shall be maintained for
each industrial fire brigade member.
(b) Training for Non-Fire Brigade Personnel. Plant personnel that Comply. None.
respond with the industrial fire brigade shall be trained as to their
responsibilities, potential hazards to be encountered, and interfacing with
the industrial fire brigade.
(c)* Drills. All of the following requirements shall apply: Comply. None.
(1) Drills shall be conducted quarterly for each shift to test the response
capability of the industrial fire brigade.
(2) Industrial fire brigade drills shall be developed to test and challenge
industrial fire brigade response, including brigade performance as a
team, proper use of equipment, effective use of pre-fire plans, and
coordination with other groups. These drills shall evaluate the
industrial fire brigade’s abilities to react, respond, and demonstrate
proper fire-fighting techniques to control and extinguish the fire and
smoke conditions being simulated by the drill scenario.
(3) Industrial fire brigade drills shall be conducted in various plant areas,
especially in those areas identified to be essential to plant operation
and to contain significant fire hazards.
(4) Drill records shall be maintained detailing the drill scenario,
industrial fire brigade member response, and ability of the industrial
fire brigade to perform as a team.
(5) A critique shall be held and documented after each drill.
3.4.4 Fire-Fighting Equipment. Protective clothing, respiratory Comply. None.
protective equipment, radiation monitoring equipment, personal
dosimeters, and fire suppression equipment such as hoses, nozzles, fire
extinguishers, and other needed equipment shall be provided for the
industrial fire brigade. This equipment shall conform with the applicable
NFPA standards.
B-11
3.4.5 Off-Site Fire Department Interface.

3.4.5.1 Mutual Aid Agreement. Off-site fire authorities shall be offered Comply. Salem has dedicated fire None.
a plan for their interface during fires and related emergencies on site. department onsite. Local
ordinance limits off-site fire
fighters from entering RCA.
3.4.5.2* Site-Specific Training. Fire fighters from the off-site fire Comply. None.
authorities who are expected to respond to a fire at the plant shall be
offered site-specific training and shall be invited to participate in a drill
at least annually.
3.4.5.3* Security and Radiation Protection. Plant security and Comply. Salem has dedicated fire None.
radiation protection plans shall address off-site fire authority response. department onsite. Local
ordinance limits off-site fire
fighters from entering RCA.
3.4.6* Communications. An effective emergency communications Comply. None.
capability shall be provided for the industrial fire brigade.
3.5 Water Supply.
3.5.1 A fire protection water supply of adequate reliability, quantity, and Comply with paragraph (a) None.
duration shall be provided by one of the two following methods:
(a) Provide a fire protection water supply of not less than two separate
300,000-gal (1,135,500-L) supplies.
(b) Calculate the fire flow rate for 2 hours. This fire flow rate shall be
based on 500 gpm (1892.5 L/min) for manual hose streams plus the
largest design demand of any sprinkler or fixed water spray system(s) in
the power block as determined in accordance with NFPA 13, Standard
for the Installation of Sprinkler Systems, or NFPA 15, Standard for
Water Spray Fixed Systems for Fire Protection. The fire water supply
shall be capable of delivering this design demand with the hydraulically
least demanding portion of fire main loop out of service.
3.5.2* The tanks shall be interconnected such that fire pumps can take Comply without use of exception None.
suction from either or both. A failure in one tank or its piping shall not allowance.
allow both tanks to drain. The tanks shall be designed in accordance with
NFPA 22, Standard for Water Tanks for Private Fire Protection.
B-12
Exception No. 1: Water storage tanks shall not be required when fire
pumps are able to take suction from a large body of water (such as a
lake), provided each fire pump has its own suction and both suctions and
pumps are adequately separated.
Exception No. 2: Cooling tower basins shall be an acceptable water
source for fire pumps when the volume is sufficient for both purposes
and water quality is consistent with the demands of the fire service.
3.5.3* Fire pumps, designed and installed in accordance with NFPA 20, Do not comply. Deviation to the None.
Standard for the Installation of Stationary Pumps for Fire Protection, requirements of NFPA 20 for
shall be provided to ensure that 100 percent of the required flow rate and piping arrangement was evaluated
pressure are available assuming failure of the largest pump or pump as acceptable. This evaluation
power source. was not formally reviewed or
accepted by the NRC.
3.5.4 At least one diesel engine–driven fire pump or two more seismic Comply, two 100% diesel engine- This is a new requirement. The
Category I Class IE electric motor-driven fire pumps connected to driven fire pumps provided. existing wording implies that all
redundant Class IE emergency power buses capable of providing 100 electric fire pumps need to be seismic
percent of the required flow rate and pressure shall be provided. Category I Class IE electric motor
driven fire pumps. This is in excess of
any previous NRC requirements
relative to fire pump system design.
Following comment was submitted to
the Technical Committee:
A sufficient number of pumps shall be

provided to ensure that 100% of the
required flow rate and pressure will be
available assuming failure of the
largest pump or loss of offsite power
(e.g., three 50% pumps or two 100%
pumps). This can be accomplished by
providing either:
(a) Electric motor driven fire pump(s)
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and diesel-driven fire pump(s), or

(b) Two or more seismic Category I
Class IE electric motor-driven fire
pumps connected to redundant
Class IE emergency power buses.
3.5.5 Each pump and its driver and controls shall be separated from the Comply under previously The requirement for separation from
remaining fire pumps and from the rest of the plant by rated fire barriers. approved configuration allowance, the rest of the plant by rated fire
room is provided with automatic barriers is more restrictive than current
wet-pipe sprinkler system and NRC documents, as it does not allow
floor drains, and pumps are for spatial separation of buildings.
mounted on pedestals. This has Appendix A to BTP 9.5-1 states the
been evaluated as equivalent to following:
separating pumps, and was
accepted by the NRC. E.2 (c.) Pumps and drivers should be
located in rooms separated from the
Requirement to separate the remaining pumps and equipment by a
pumps from the rest of the plant is minimum three-hour firewall.
a new requirement and was not
contained in Salem licensing Exception: Where system pressure and
documentation. Do not comply flow requirements can be provided by
with this requirement but have remote located redundant fire pumps,
significant separation. the requirement for firewalls shall not
apply.
3.5.6 Fire pumps shall be provided with automatic start and manual stop Comply. Manual start is also None.
only. provided.
3.5.7 Individual fire pump connections to the yard fire main loop shall Comply None.
be provided and separated with sectionalizing valves between
connections.
3.5.8 A method of automatic pressure maintenance of the fire protection Comply. Salem design provides None.
water system shall be provided independent of the fire pumps. jockey pump.
3.5.9 Means shall be provided to immediately notify the control room, Comply None.
or other suitable constantly attended location, of operation of fire pumps.
3.5.10 An underground yard fire main loop, designed and installed in Comply. None.
B-14
accordance with NFPA 24, Standard for the Installation of Private Fire
Service Mains and their Appurtenances, shall be installed to furnish
anticipated water requirements.
3.5.11 Means shall be provided to isolate portions of the yard fire main Comply. None.
loop for maintenance or repair without simultaneously shutting off the
supply to both fixed fire suppression systems and fire hose stations
provided for manual backup. Sprinkler systems and manual hose station
standpipes shall be connected to the plant fire protection water main so
that a single active failure or a crack to the water supply piping to these
systems can be isolated so as not to impair both the primary and backup
fire suppression systems.
3.5.12 Threads compatible with those used by local fire departments Comply without exception None.
shall be provided on all hydrants, hose couplings, and standpipe risers. allowance.
Exception: Fire departments shall be permitted to be provided with

adapters that allow interconnection between plant equipment and the
fire department equipment if adequate training and procedures are
provided.
3.5.13 Headers fed from each end shall be permitted inside buildings to Comply. ANSI B31.1 None.
supply both sprinkler and standpipe systems, provided steel piping and requirement is not applicable as
fittings meeting the requirements of ANSI B31.1, Code for Power standpipe system is not
Piping, are used for the headers (up to and including the first valve) seismically analyzed.
supplying the sprinkler systems where such headers are part of the
seismically analyzed hose standpipe system. Where provided, such
headers are considered an extension of the yard main system. Each
sprinkler and standpipe system shall be equipped with an outside screw
and yoke (OS&Y) gate valve or other approved shutoff valve.
3.5.14* All fire protection water supply and fire suppression system Comply. None.
control valves shall be under a periodic inspection program and shall be
supervised by one of the following methods:
(a) Electrical supervision with audible and visual signals in the main
control room or other suitable constantly attended location.
(b) Locking valves in their normal position. Keys shall be made available
only to authorized personnel.
B-15
(c) Sealing valves in their normal positions. This option shall be utilized
only where valves are located within fenced areas or under the direct
control of the owner/operator.
3.5.15 Hydrants shall be installed approximately every 250 ft (76 m) Comply as previously approved More restrictive than NFPA 24.
apart on the yard main system. A hose house equipped with hose and configuration, as hydrants are NFPA 24 has no minimum distance
combination nozzle and other auxiliary equipment specified in NFPA 24, spaced every 300 to 400 feet. requirement, only that they be spaced
Standard for the Installation of Private Fire Service Mains and Their Hose houses were removed and in a manner that the needed flow be
Appurtenances, shall be provided at intervals of not more than 1000 ft equipment placed on mobile delivered through hose lines to all
(305 m) along the yard main system. apparatus as allowed in exception. exterior sides of any important
No specific reference to hydrant structure. Guideline in BTP 9.5-1
Exception: Mobile means of providing hose and associated equipment, spacing is contained in Appendix A, Section E.2(g) is:
such as hose carts or trucks, shall be permitted in lieu of hose houses. Supplement 4 to the Salem SER
Where provided, such mobile equipment shall be equivalent to the (NUREG-0517), however, SER C.2(g) Outside manual hose
equipment supplied by three hose houses. states design criteria and bases for installation should be sufficient to
water supply system are reach any location with an effective
acceptable. hose stream. To accomplish this
hydrants should be installed
approximately every 250 feet on the
yard main system. … A hose house,
equipped with hose and combination
nozzle, and other auxiliary equipment
recommended in NFPA 24, "Outside
Protection", should be provided as
needed but at least every 1,000 feet.
3.5.16* The fire protection water supply system shall be dedicated for General compliance, system may None.
fire protection use only. be used in emergency for feed
water.
Exception No. 1: Fire protection water supply systems shall be permitted
to be used to provide backup to nuclear safety systems provided the fire
protection water supply systems are designed and maintained to deliver
the combined fire and nuclear safety flow demands for the duration
specified by the applicable analysis.
Exception No. 2: Fire protection water storage can be provided by plant
B-16
systems serving other functions provided the storage has a dedicated

capacity capable of providing the maximum fire protection demand for
the specified duration as determined in this section.
3.6 Standpipe and Hose Stations.
3.6.1 For all power block buildings, Class III standpipe and hose Class III standpipe reference is a New requirement. Previous NRC
systems shall be installed in accordance with NFPA 14, Standard for the new requirement. Comply as documents do not specify the class of
Installation of Standpipe and Hose Systems. configuration was previously standpipe required.
approved. Standpipe is designed Not all plants have standpipes
as a Class II system. designed as Class III systems. A Class
III system is for Fire Department and
Occupant Usage.
3.6.2 A capability shall be provided to assure an adequate water flow Comply. Analysis was performed None.
rate and nozzle pressure for all hose stations. This capability includes the where additional lengths of hose
provision of hose station pressure reducers where necessary for the are required.
safety of plant industrial fire brigade members and off-site fire
department personnel.
3.6.3 The proper type of hose nozzle to be supplied to each power block Comply. None.
area shall be based on the area fire hazards. The usual combination
spray/straight stream nozzle shall not be used in areas where the straight
stream can cause unacceptable damage or present an electrical hazard to
fire-fighting personnel. Listed electrically safe fixed fog nozzles shall be
provided at locations where high-voltage shock hazards exist. All hose
nozzles shall have shutoff capability and be able to control water flow
from full open to full closed.
3.6.4 Provisions shall be made to supply water at least to standpipes and Do not comply. This is a new Even though this does not pose a
hose stations for manual fire suppression in all areas containing systems requirement and was not contained problem at Salem under the exception.
and components needed to perform the nuclear safety functions in the in Salem licensing documentation. This will present a new requirement
event of a safe shutdown earthquake (SSE). Salem, however, can comply with for most plants. Appendix A to BTP
Exception: For existing plants that are not capable of meeting this exception allowance. 9.5-1 [Ref. 25] section E..3(d) does not
requirement, provisions to restore a water supply and distribution system provide guidance in for plants which
for manual fire fighting purposes shall be made. This provisional manual construction permits were issued prior
fire-fighting standpipe/hose station system shall be capable of providing to July 1, 1976, and operating plants
manual fire fighting protection to the various plant locations important relative to SSE for hose stations.
B-17
to supporting and maintaining the nuclear safety function. The

provisions for establishing this provisional system shall be pre-planned
and be capable of being implemented in a timely manner following a
SSE.
3.6.5 Where the seismic required hose stations are cross-connected to Not applicable since Salem hose See comment under 3.6.4.
essential seismic non-fire protection water supply systems, the fire flow stations are not seismically
shall not degrade the essential water system requirement. designed.
3.7.1 Fire Extinguishers. Where provided, fire extinguishers of the Comply. None.
appropriate number, size, and type shall be provided in accordance with
NFPA 10, Standard for Portable Fire Extinguishers. Extinguishers shall
be permitted to be positioned outside of fire areas due to radiological
conditions.
3.8 Fire Alarm and Detection Systems.
3.8.1 Fire Alarm. Alarm initiating devices shall be installed in Comply as configuration was None.
®
accordance with NFPA 72, National Fire Alarm Code . Alarm previously approved by the NRC.
annunciation shall allow the proprietary alarm system to transmit fire- NFPA 72D was used during
related alarms, supervisory signals, and trouble signals to the control design and installation at Salem as
room or other constantly attended location from which required guidance document. Detection
notifications and response can be initiated. Personnel assigned to the system was accepted by the NRC.
proprietary alarm station shall be permitted to have other duties. The
following fire-related signals shall be transmitted:
(1) Actuation of any fire detection device

(2) Actuation of any fixed fire suppression system
(3) Actuation of any manual fire alarm station
(4) Starting of any fire pump
(5) Actuation of any fire protection supervisory device
(6) Indication of alarm system trouble condition
3.8.1.1 Means shall be provided to allow a person observing a fire at any Comply. Plant telephone and page None.
location in the plant to quickly and reliably communicate to the control systems are provided.
room or other suitable constantly attended location.
3.8.1.2 Means shall be provided to promptly notify the following of any Comply. Control Room, through None.
fire emergency in such a way as to allow them to determine an plant page system, will initiate
appropriate course of action: notification.
B-18
(1) General site population in all occupied areas.

(2) Members of the industrial fire brigade and other groups supporting
fire emergency response.
(3) Off-site fire emergency response agencies. Two independent means
shall be available (e.g., telephone and radio) for notification of off-site
emergency services.
3.8.2 Detection. If automatic fire detection is required to meet the Comply as the installed None.
performance or deterministic requirements of Chapter 4, then these configuration was previously
devices shall be installed in accordance with NFPA 72, National Fire approved by the NRC. NFPA
Alarm Code, and its applicable appendixes. 72D was used during design and
installation at Salem as guidance
document. Detection systems
were accepted by the NRC.
3.9 Automatic and Manual Water-Based Fire Suppression Systems.
3.9.1* If an automatic or manual water-based fire suppression system is Comply. Systems were designed None.
required to meet the performance or deterministic requirements of and installed in accordance with
Chapter 4, then the system shall be installed in accordance with the NFPA 13 and 15.
appropriate NFPA standards including:
(1) NFPA 13, Standard for the Installation of Sprinkler Systems

(2) NFPA 15, Standard for Water Spray Fixed Systems for Fire
Protection
(3) NFPA 750, Standard on Water Mist Fire Protection Systems
(4) NFPA 16, Standard for the Installation of Foam-Water Sprinkler and
Foam-Water Spray Systems
3.9.2 Each system shall be equipped with a water flow alarm. Comply. None.
3.9.3 All alarms from fire suppression systems shall annunciate in the Comply. None.
control room or other suitable constantly attended location.
3.9.4 Diesel-driven fire pumps shall be protected by automatic Comply. This is a new requirement.
sprinklers.
3.9.5 Each system shall be equipped with an OS&Y gate valve or other Comply. None.
approved shutoff valve.
3.9.6 All valves controlling water-based fire suppression systems Comply. None.
B-19
required to meet the performance or deterministic requirements of

Chapter 4 shall be supervised as described in 3.5.14.
3.10 Gaseous Fire Suppression Systems.
3.10.1 If an automatic total flooding and local application gaseous fire Comply. None.
suppression system is required to meet the performance or deterministic
requirements of Chapter 4, then the system shall be designed and
installed in accordance with the following applicable NFPA codes:
(1) NFPA 12, Standard on Carbon Dioxide Extinguishing Systems

(2) NFPA 12A, Standard on Halon 1301 Fire Extinguishing Systems
(3) NFPA 2001, Standard on Clean Agent Fire Extinguishing Systems
3.10.2 Operation of gaseous fire suppression systems shall annunciate Comply. None.
and alarm in the control room or other constantly attended location
identified.
3.10.3 Ventilation system design shall take into account prevention from Comply. Existing configuration Confinement of radioactive
over-pressurization during agent injection, adequate sealing to prevent was previously approved by the contaminants may not have been
loss of agent, and confinement of radioactive contaminants. NRC. Confinement of radioactive considered during the original design
contaminants may not have been of gaseous systems since this was not a
considered. Confinement of requirement in the NFPA standards or
radioactive contaminants is a new Salem licensing documents when the
requirement and was not contained systems were designed and installed.
in Salem licensing documents.
CO2 systems accepted by the
NRC.
3.10.4* In any area required to be protected by both primary and backup Not applicable, no areas in the None.
gaseous fire suppression systems, a single active failure or a crack in any plant have both primary and
pipe in the fire suppression system shall not impair both the primary and backup gaseous suppression
backup fire suppression capability. systems
3.10.5 Provisions for locally disarming automatic gaseous suppression Comply. Key lockout is provided None.
systems shall be secured and under strict administrative control. on CO2 systems.
3.10.6* Total flooding carbon dioxide systems shall not be used in Comply None.
normally occupied areas.
3.10.7 Automatic total flooding carbon dioxide systems shall be Comply under previously New requirement. Previous NRC
equipped with an audible pre-discharge alarm and discharge delay approved configuration allowance. documents do not contain specific
B-20
sufficient to permit egress of personnel. The carbon dioxide system shall Reference to odorizer is new reference to odorizers. Not all plants
be provided with an odorizer. requirement and was not contained have systems with an odorizer.
in Salem licensing documents. 13
and 60-second delay, and audio
and visual alarms provided.
Systems do not contain an
odorizer. CO2 systems accepted
by the NRC.
3.10.8 Positive mechanical means shall be provided to lock out total Comply. None.
flooding carbon dioxide systems during work in the protected space.
3.10.9 The possibility of secondary thermal shock (cooling) damage Comply. Cooling affect of CO2 None
shall be considered during the design of any gaseous fire suppression was demonstrated as acceptable
system, but particularly with carbon dioxide. during discharge test of each
system.
3.10.10 Particular attention shall be given to corrosive characteristics of Comply. This was demonstrated None.
agent decomposition products on safety systems. as acceptable during discharge test
of each system.
3.11 Passive Fire Protection Features. This section shall be used to No requirement in this paragraph. None.
determine the design and installation requirements for passive protection
features. Passive fire protection features include wall, ceiling, and floor
assemblies, fire doors, fire dampers, and through fire barrier penetration
seals. Passive fire protection features also include electrical raceway fire
barrier systems (ERFBS) that are provided to protect cables and
electrical components and equipment from the effects of fire.
3.11.1 Building Separation. Each major building within the power Comply. None.
block shall be separated from the others by barriers having a designated
fire resistance rating of 3 hours or by open space of at least 50 ft or space
that meets the requirements of NFPA 80A, Recommended Practice for
Protection of Buildings From Exterior Fire Exposure.
Exception: Where a performance-based analysis determines the

adequacy of building separation, the requirements of 3.11.1 shall not
apply.
3.11.2 Fire Barriers. Fire barriers required by Chapter 4 shall include a Comply This requirement does not allow
B-21
specific fire-resistance rating. Fire barriers shall be designed and evaluation of barrier elements such as
installed to meet the specific fire-resistance rating using assemblies structural steel. Many plants do not
qualified by fire tests. The qualification fire tests shall be in accordance coat structural steel based on analyses
with NFPA 251, Standard Methods of Tests of Fire Endurance of concluding that the steel will not reach
o
Building Construction and Materials, or ASTM E 119, Standard Test 1100 F during the design fire.
Methods for Fire Tests of Building Construction and Materials.
3.11.3* Fire Barrier Penetrations. Penetrations in fire barriers shall be Comply under exception None.
provided with listed fire-rated door assemblies or listed rated fire allowance and previously
dampers having a fire-resistance rating consistent with the designated approved exemptions.
fire-resistance rating of the barrier as determined by the performance
requirements established by Chapter 4. (See 3.11.4 for penetration seals
for through penetration fire stops.) Passive fire protection devices such
as doors and dampers shall conform with the following NFPA standards,
as applicable:
(1) NFPA 80, Standard for Fire Doors and Fire Windows
(2) NFPA 90A, Standard for the Installation of Air-Conditioning
and Ventilating Systems
(3) NFPA 101, Life Safety Code
Exception: Where fire area boundaries are not wall-to-wall, floor-to-

ceiling boundaries with all penetrations sealed to the fire rating required
of the boundaries, a performance-based analysis shall be required to
assess the adequacy of fire barrier forming the fire boundary to
determine if the barrier will withstand the fire effects of the hazards in
the area. Openings in fire barriers shall be permitted to be protected by
other means as acceptable to the AHJ.
3.11.4* Through Penetration Fire Stops. Through penetration fire Comply. Comment was submitted to the
stops for penetrations such as pipes, conduits, bus ducts, cables, wires, technical committee.
pneumatic tubes and ducts, and similar building service equipment that
pass through fire barriers shall be protected as follows: An internal conduit research program
was conducted in the late 80’s that
(a) The annular space between the penetrating item and the through demonstrated internal conduit seals
opening in the fire barrier shall be filled with a qualified fire-resistive were not necessary in a number of
B-22
penetration seal assembly capable of maintaining the fire resistance of situations:

the fire barrier. The assembly shall be qualified by tests in accordance
with a fire test protocol acceptable to the AHJ or be protected by a listed Conduits that terminate in junction
fire-rated device for the specified fire-resistive period. boxes or other noncombustible
(b) Conduits shall be provided with an internal fire seal that has an closure need no additional sealing.
equivalent fire-resistive rating to that of the fire barrier through opening Conduits that run through an area
fire stop and shall be permitted to be installed on either side of the barrier but do not terminate in that area
in a location that is as close to the barrier as possible. need not be sealed in that area.
Open conduits smaller than 2”
Exception: Openings inside conduit 4 in. (10.2 cm) or less in diameter diameter that terminate 1 foot or
shall be sealed at the fire barrier with a fire-rated internal seal unless greater from the barrier need not
the conduit extends greater than 5 ft (1.5 m) on each side of the fire be sealed.
barrier. In this case the conduit opening shall be provided with Open conduits of 2” diameter that
noncombustible material to prevent the passage of smoke and hot gases. terminates 3 feet or greater from
The fill depth of the material packed to a depth of 2 in. (5.1 cm) shall the barrier need not be sealed.
constitute an acceptable smoke and hot gas seal in this application. Open conduits larger than 2”
diameter was not specifically
tested in the program. Based on
internal conduit temperature
measurements in 3”, 4” and 6”
closed conduits, it can be
concluded that fire will not
propagate through larger conduits
with a cable fill of 40% or more,
that terminate 3 feet or greater
from the barrier.
The fire test performed for the Conduit
Fire Protection Research Program is
entitled “Conduit Seal Fire Test of
one-hundred one electrical conduit
penetrations” performed at
Construction Technology Laboratories
with the Report Submitted December
1986. Utility funding and participation
B-23
included over 25 utilities.

Therefore, qualified fire test should be
allowed to determine whether an
internal fire seal is necessary.
3.11.5* Electrical Raceway Fire Barrier Systems (ERFBS). ERFBS Design basis compliance – Comment was submitted to the
required by Chapter 4 shall be capable of resisting the fire effects of the ongoing project to upgrade technical committee.
hazards in the area. ERFBS shall be tested in accordance with and shall ERFBS to meet 1-hour
meet the acceptance criteria of NRC Generic Letter 86-10, Supplement requirement. Plants with ERFBS installed prior to
1, “Fire Endurance Test Acceptance Criteria For Fire Barrier Systems the issuance of Generic Letter 86-10
Used to Separate Safe Shutdown Trains Within the Same Fire Area.” used testing based on continuity. The
The ERFBS needs to adequately address the design requirements and NRC never specified their desire
limitations of supports and intervening items and their impact on the fire relative to ERFBS until Generic Letter
barrier system rating. The fire barrier system’s ability to maintain the 86-10 and 86-10, Supplement 1 [Ref.
required nuclear safety circuits free of fire damage for a specific thermal 26]. A more appropriate word would
exposure, barrier design, raceway size and type, cable size, fill, and type be "accepted" to grandfather those
shall be demonstrated. configurations that were accepted
based on.
Exception No. 1: When the temperatures inside the fire barrier system
exceed the maximum temperature allowed by the acceptance criteria of
Generic Letter 86-10, “Fire Endurance Acceptance Test Criteria for
Fire Barrier Systems Used to Separate Redundant Safe Shutdown Trains
Within the Same Fire Area”, Supplement 1, functionality of the cable at
the these elevated temperatures shall be demonstrated. Qualification
demonstration of these cables shall be performed in accordance with the
electrical testing requirements of Generic Letter 86-10, Supplement 1,
Attachment 1, “Attachment Methods for Demonstrating Functionality of
Cables Protected by Raceway Fire Barrier Systems During and After
Fire Endurance Test Exposure.”
Exception No. 2: ERFBS systems employed prior to the issuance of

Generic Letter-86-10 Supplement 1 are acceptable providing that the
system successfully met the limiting end point temperature requirements
as specified by the AHJ at the time of acceptance.
B-24
C
FIRE MODELING
The role of fire modeling in the standard is described in sections 2-3.1 and 4-1.4.1. These
sections, for the most part, describe selection of fire scenarios and selection of appropriate fire
models. Appendix C provides limited guidance in use of fire modeling in nuclear power plant
fire hazard assessment. This Appendix provides discussion of the fire scenarios selected and
evaluation of these fire scenarios using selected fire models.
The objectives of this exercise is to examine NFPA 805, Performance-Based Standard for Fire
Protection for Light Water Reactor Electric Generating Plants for the following:
• Can the use of fire modeling as is discussed in the main body of the standard be
implemented?
• Does Appendix C provide adequate guidance for implementing what the main body requires?
As part of this exercise, fire models were used to estimate the Maximum Expected Fire Scenario
(MEFS) and Limiting Fire Scenarios (LFS) if no damage detected by the MEFS for each of the
fire scenarios. This is not a validation of specific fire modeling tools, i.e., accuracy of their
prediction.
Three steps were followed in this examination:
a) Selection and definition of fire scenarios.
b) Mathematical modeling of the selected scenarios using 4 different fire models: FIVE [Ref.
5], COMPBRN-IIIe [Ref. 7], MAGIC [Ref. 8] and CFAST [Ref. 6].
c) Evaluation and discussion of the modeling results.
C.1 Defining Fire Scenarios
C.1.1 Fire Area 1FA-AB-64A – 4160V Switchgear Room
Salem fire IPEEE [Ref. 9] concluded the switchgear and transient fires as contributors to fire risk
in this room. Therefore, a fire occurring in the 4.16KV switchgear 1B was selected as the
scenario to analyze in this location. Figure C-1 shows a pictorial representation of the 4.16KV
switchgear 1B fire scenario.
C-1
Fire Modeling
18.5 m
Smoke detector
Exposed cable
Target: FS-195 tray
1.22 m
3.05 m 5.47 m 0.61 m

4.57 m
Overhead tray
partially wrapped
in FS-195
5.18 m
1.52 m
2.44 m
3.66 m 4KV Switchgear cabinet 1B

T amb = 20 °C
Figure C-1
Configuration of the 4.16KV Switchgear Fire
The scenario depicted above includes a fire at the top of the switchgear cabinet, a cable tray
above the cabinet, a FS-195 protected cable tray target and a smoke detector located at the
ceiling above the cabinet. The fire simulation is expected to:
1. Estimate the time to ignition of the FS-195 partially protected cable tray above the fire.
2. Estimate the time to fire detection.
3. Estimate the time to damage of the FS-195 protected target.
Assumptions:
1. The thermal properties of the target are not considered. Therefore, the target temperature is
assumed similar to the predicted gas temperature at the same location.
2. The response of the smoke detector is modeled as a heat sensitive device using an activation
temperature of 30° C. Detector actuation will occur when the ceiling jet temperature at the
location of the detector reaches 30° C.
The following list provides the technical description of the scenario.
C-2
Fire Modeling
Enclosure:
• Size: 26.5 m long, 18.5 m wide, 6.1 m high
• Boundary materials: Floor, ceiling and walls- concrete
• Natural ventilation: All doors are closed. Only leakage paths are assumed in the simulation.
• Mechanical ventilation: 10 air changes per hour
Fire Source:
• Initial fire intensity on the switchgear cabinet: 100 kW, steady
• Fire location: Center of room. Elevation: 2.44 m (Top of the switchgear cabinet)
Target:
• FS-195:
➟ Activation temperature: 117 °C,
➟ Damage temperature: 260 °C
➟ Peak heat release rate: 166.3 kW/m²
• Unprotected cables:
➟ Ignition temperature: 370 °C
• Location relative to cabinet fire: X = 3.96 m, Y = 0 m, Z = 2.13 m. According to these
coordinates, the target is expected to be located in the smoke layer.
Smoke Detection
• Radial distance from centerline of fire plume: 4.0 m
• Activation temperature of 30 °C.
C.1.2 Fire Area 1FA-AB-100C – Reactor Plant Auxiliary Equipment Area
Two fire scenarios were selected in this fire area after walkdown. These scenarios were selected
to provide the ability to test various elements of the standard related to scenario selection and fire
modeling. Figure C-2 shows a pictorial representation of the MCC fire scenario.
This scenario includes a fire at the top of the MCC cabinet, a cable tray above the cabinet, a FS-
195 protected cable tray target and a smoke detector located at the ceiling above the cabinet. The
purpose of the simulation is to:
1. Estimate time to ignition of cable tray
2. Estimate flame propagation time over cable trays
3. Estimate time to fire detection
4. Estimate time to damage of FS-195 protected target
C-3
Fire Modeling
18.5 m
1.21 m Smoke detector
Target:
FS-195
1.5 m
45 °
6.1 m
3.34 m
2.43 m 3m 3.05 m
2.43 m
MCC cabinet
T amb = 20 °C
Figure C-2
MCC Fire Scenario in Fire Area 1FA-AB-100C
Enclosure:
• Size: 21.3 m x 1.52 m x 6.1 m
• Boundary materials: Floor, ceiling, walls- concrete
• Natural ventilation: Open door: 2 m x 2.4 m
• Mechanical ventilation: 10 Air changes per hour
Fire Source:
• Initial fire intensity: 100 kW, steady
• Fire location: Center of room. Elevation: 2.44 m
Target:
• FS-195 & EM-50:
ß Activation temperature: 117 °C
ß Damage temperature: 250 °C
ß Peak heat release rate: 166.3 kW/m²
C-4
Fire Modeling

• Location relative to the fire: X = 6 m, Y = 0 m, Z = 2.43 m. If the fire is able to spread
throughout the cable tray, it will be located 1.2 m aside of the target.
Smoke Detection
Flame Spread
Given that the fire is assumed to start at the center of the cabinet, flame spread will need to occur
for 1.5 m across the horizontal tray and 1 m across the 45° inclined tray. At the end of the flame
spread process the fire will be located 1.2 m besides the target. Following these considerations,
the time to target damage is estimated based on the times to cable tray ignition and flame spread
across the trays. This is, while the flames are spreading throughout the cabinet, the fire is
generating smoke layer temperatures that will increase the surface temperature of the target.
Therefore, the time to flame spread is necessary to predict the smoke layer temperature at the
target up to the point when the fire is besides it.
Based on EPRI NP-7332, flame spread along a horizontal cable tray occurs at about 8.5x10-4 m/s
(10ft/hr). Therefore, for a horizontal spread of 1.5 m, 1764 sec (30 min) is expected.
There are no experimental observations for flame spread across 45° inclined cable trays.
However, the velocity of the flame spread is assumed to be within a horizontal and a vertical
spread. This assumption is based on the fact that the amount of material being heated by the heat
flux generated by flames is shorter than in a completely vertical setup and longer than a
horizontal one. For this analysis, the flame spread across the inclined cable tray will be assumed
as twice as fast as the horizontal spread. Based on this assumption, the time for flame spread
across the inclined tray is 1176 sec (20 min).
Based on these time calculations, a fire is expected to be burning for around 50 min after the
cable tray is ignited.
At the same time, given the elevation of the fire, it is expected to be immersed in the smoke layer
and therefore, its heat release rate may be affected.
C.1.3 Transient Fire Scenario

Figure C-3 shows a pictorial representation of the Transient fire scenario.
The scenario includes a fire ignited on an oil spill below a FS-195 protected cable tray target, an
EM-50 protected cable tray target and a smoke detector located at the ceiling above the fire. The
purpose of the simulation is to:
1. Estimate time to damage of the EM-50 protected cables
2. Estimate time to damage of the FS-195 protected cables
C-5
Fire Modeling
3. Estimate time to fire detection
0.2 m
Target
FS-195
Target
EM-50
5.48 m 6.1 m
4.57 m
10 m
10.6 m
Figure C-3
Transient Fire Scenario in Fire Area 1FA-AB-100C
Enclosure:
• Enclosure size: 10.66 m x 1.52 m x 6.1 m
• Boundary materials: Floor, ceiling, walls - concrete
• Natural ventilation: Open doors: 1.22 m x 4.7 m, and 0.91 m x 2 m
• Mechanical ventilation: No mechanical ventilation
Fire Source:
• Initial fire intensity: 458 kW
• Fire location: Center of room. Elevation: 0 m
• One gallon of lubricating oil (125700 BTU)
Target:
• FS-195 & EM-50:
➟ Activation temperature: 117 °C
C-6
Fire Modeling
➟ Damage temperature: 260 °C

➟ Peak heat release rate: 166.3 kW/m²
Smoke Detection
C.2 Selection of Fire Models
Appendix C of the standard provides a list of currently available fire modeling tools. An
appropriate fire model for a specific application depends on the parameters to estimate. For
example, some parameters are easily estimated using hand calculations. At the same time, these
hand calculations are usually built in functions in more sophisticated models, such as zone
models. Therefore, the selection of the appropriate model is critical in order to reduce the level
of effort and time without sacrificing the accuracy of the prediction.
The main interest in this exercise is to obtain time-to-damage and time-to-detector actuation.
Careful analysis of the scenarios suggests that some targets are located within the fire plume, and
others are located in the smoke layer. As a consequence, both correlations to estimate plume
temperature and zone models to estimate smoke layer temperature are appropriate choices. This
exercise did not attempt to examine use of more sophisticated Computational Fluid Dynamic
(CFD) models.
Specifically, four fire zone models were selected for this examination. These models were
selected based on the following:
1. Capabilities of supporting the specific application including:
a. Determining the effectiveness of ERFBS,
b. Determine fire generated conditions in enclosures with mechanical ventilation
2. The models represent a range quasi-steady state and transient scenarios.
C.3 Analysis
The results of the evaluation of the fire scenarios are summarized in tables C-2, C-3 and C-4 for
the three scenarios described in section C.1. The following discussion and conclusions were
suggested by those results.
C.3.1 Unit 1 4 KV Switchgear Room
This scenarios was defined earlier in section C.1.1
C-7
Fire Modeling
Licensed Condition - The Maximum Expected Fire Scenario was defined as a steady 100kW
fire on the top of the switchgear cabinet. All four fire models (FIVE, MAGIC, COMPBRNIII
and CFAST) predict no ignition of the overhead tray and damage to the target with conditions
reflecting the approved license condition, i.e., 1-hour fire rating for FS-195 and EM-50 and non-
combustible FS-195 (referred to as Baseline).
Limiting Fire Scenario was calculated as 200, 178, 150 and 250kW in the switchgear by
MAGIC, CFAST, FIVE and COMPBRN-IIIe respectively and a 4-12 MW fire in the overhead
cable tray(s) to cause damage to the target, i.e., division 1C cable tray wrapped in FS-195. Even
though a 150-250KW fire in the switchgear is not inconceivable, a 4-12MW cable fire requires
significant spread in the overhead trays and as much as 40 minutes to reach damage temperature
of 700oF (371oC). CFAST and MAGIC show that fires of significantly smaller size are expected
to be oxygen constrained, i.e., the natural ventilation in the room may not capable of sustaining a
4-12 MW fire if its immersed in the smoke layer. However, a strong air injection from a
mechanical ventilation system could supply enough oxygen to sustain the fire.
Tested Condition - With reduced fire rating for FS-195 and EM-50 and combustible FS-195
(referred to as Tested Case), the MEFS (100kW switchgear fire) would reach FS-195
damage/ignition temperature of 260oC (500oF) on the cable tray running 5 ft above the
Switchgear. Assuming ignition of the cable within the activated FS-195, the fire in the overhead
tray causes activation of the FS-195 on the target tray and subsequent damage to the cables
inside it (division 1C circuits). Time to ignition of the cables inside the FS-195 in the overhead
tray and time to damage of the cables inside the FS-195 in the target tray was calculated on the
basis that once the temperature on the surface of the FS-195 reached its damage temperature, the
cable inside will have protection for 15 minutes (tested fire rating of the FS-195) before ignition
of the enclosed cable. Therefore,
Time to damage = t1 + t2 + t3 + t4
With:
t1 = Time to damage of the overhead FS-195 ≈ 0
t2 = Time to ignition of the overhead cables inside FS-195 ≈ 15 min
t3 = Time to reach activation of FS-195 on the target ≈ 3 to 15 min
t4 = Time to damage of the target cables inside the FS-195 ≈ 15 min
The value of 0 minutes estimated for the parameter t1 above was obtained from a correlation for
plume temperature with a steady heat release rate as input. The value of 3 to 15 minutes
estimated for the parameter t3 was obtained from different zone model estimations of smoke
layer temperatures. Based on these approach, target damage is expected in around 33 to 45
minutes.
No LFS was defined based on the switchgear fire size since the 100 kW switchgear fire is
capable of causing damage/ignition of the cable tray above based on at least two of the four zone
models. At the same time, fire in the order of 1 to 8 MW is needed in the cable tray(s) to
produce damaging temperatures at the target. The likelihood of observing these fire sized in the
cable tray will depend of both the mass of the fuel and the oxygen available in the enclosure. In
C-8
Fire Modeling
terms of mass, and assuming that the cable jacket is PVC, a fire of around 92 kW/m2 (based on a
combustion efficiency of 0.35) is expected [Ref. 3]. In this specific scenario, the surface area of
the entire cable tray above the switchgear is 4.1m2, resulting in a 380 kW fire. Ignition and
burning of 2.5 to 20 times the mass of cables located directly above the switchgear is needed to
produce the HRR that can damage the designated target. In terms of oxygen, large openings or a
strong fresh air injection system in the enclosure may provide enough oxygen to sustain such
burning.
Smoke detector response in this scenario is in the order of seconds.
In conclusion, a 200 kW switchgear fire can cause ignition of the cable tray directly above the
o o
fire if damage/ignition temperatures are in the order of 260 C to 370 C (baseline and tested
conditions). In case of the baseline, a large cable fire, on the order of 4-12 MW is needed to
cause damage within 2-30 minutes. A fire of this size requires considerable mass of cable to
burn and all models predict that such fire will be constrained by the amount of oxygen available.
In the case of degraded barrier, a smaller cable fire 1-8MW is needed to cause damage. This size
cable fire requires amount of cable beyond what is directly above the switchgear which means
significant flame propagation and time for this propagation. Both Baseline and Tested condition
result in no damage resulting from the MEFS. However, the considerable margin that existed in
the Baseline Case has been reduced in the Tested Condition. With considerable fire propagation
in the cable trays (LFS), the time to reach damage temperatures at the target location with the
Tested Conditions is predicted by 3 of the four models (except FIVE) to be on the order of 10-15
minutes. This time does not include the flame spread time in the overhead cable trays needed to
cause the critical cable heat release rate. With the tested fire rating of 10-15 minutes for the FS-
195, the time before damage to the protected train occurs is estimated to be 20-30 minutes.
C.3.2 Unit 1 Reactor Plant Auxiliary Equipment Area: MCC Fire
Two fire scenarios were selected in this fire area, an MCC and a transient fire. Description of the
MCC fire scenario is provided in section C.1.2. Following is a summary of the analysis of these
scenarios.
Licensed Condition - The MEFS for the MCC fire (steady 100kW) causes ignition of the
exposed overhead cable tray located 0.6m (2ft) above the MCC. The fire scenario then turns into
o
a cable fire in the overhead tray and propagation through the 45 incline and into the cable tray
located in parallel to the target tray wrapped in FS-195 that contains circuits of the protected
division.
With fire spread rate of 10 ft/hour in a horizontal cable tray (EPRI-NP-7332), the time for the
fire to spread to the cable tray adjacent to the target is calculated to be 50 minutes. The modeling
effort in this scenario does not attempt to predict flame spread and fire growth in a
comprehensive way. Mathematical modeling of this phenomena is still beyond state of the art.
The time and fire intensity estimates only provide a sense of scale about the response time in the
scenario.
o
Fires within 1 and 2 MW in the overhead cable tray are required to reach 260°C (700 F Baseline)
at the target. Both FIVE and CFAST show that fires higher than 150KW inside the upper smoke
C-9
Fire Modeling
layer in the location of the MCC and in the overhead tray are expected to be oxygen constrained.
Time to reach damage temperature, however, is affected by how fast the fire spreads in the cable
trays (assuming availability of oxygen) which can vary from 0 (assuming instantaneous fire
spread) to 50 minutes or more. Therefore in this case, the LFS may be defined as a 100KW MCC
fire that causes a 1-2 MW cable fire in the overhead trays reaching damage temperatures at the
target in 3-20 minutes based on different fire models in addition to the flame spread time (50
minutes). This scenario provides considerable margin due to the constraints on available oxygen
to maintain a large elevated fire or fast flame spread rate needed to cause damage.
In terms of mass, again we assume PVC cables. This type of cable will generate 92kW/m2 .
This number is based on a combustion efficiency of 0.35. In this specific scenario, the cable tray
directly above the MCC is ~2m2, resulting in a fire of 184 kW if entire length of the tray above
the MCC is ignited. For a damaging fire, ignition of 4 to 12 times as much cable is needed. This
can result if the fire spreads through the incline and into the horizontal tray next to the target.
The time to reach damage temperature at the target will therefore depend on the flame spread and
fire growth on the tray. With a flame spread rate of 10 ft/hour in horizontal trays, the time to
damage for the LFS is estimated at ~2 hours (50 minutes for fire spread in the cable trays + 3-20
o
minutes to reach 370 C at the target based on various fire models + 60 minutes fire rating of the
ERFBS).
Tested Condition - Using similar assumption with respect to the cable ignition and damage
inside FS-195, i.e., activated FS-195 provides protection equal to its reduced fire rating. The
time to reach damaging temperature at the target is estimated at 80 to 500 seconds for tested
case. With flame spread rate of 10 linear ft/hr in horizontal trays, the time to damage for the LFS
is estimated to be ~1 hour (50 minutes for fire spread in the cable trays + 1-8 minutes to reach
o
260 C at the target based on various fire models + 15 minutes fire rating of the ERFBS).
In this scenario, smoke detector response is in the order of seconds.
In summary, a 100 KW fire in the MCC (MEFS) will ignite overhead trays but will be
constrained by available oxygen to reach 370 oC (700oF) temperature at the target location. An
elevated fire will rapidly be immersed in the smoke layer, affecting the oxygen entrained to the
reaction. A 0.5MW to 2.2 MW (depending on different fire models) cable fire is needed to reach
damage temperatures at the target location. According to the analysis presented above, the cable
tray could have the capacity of generating fires of about 500 kW. In contrast to the fire in the
switchgear room, in this case the overhead tray will ignite due to its proximity to the fire.
Therefore, any automatic or manual response may encounter a multiple fire scenario to deal with.
At the same time, suppression activities may have enough time to prevent damage in the selected
target based on how fast the fire spreads in the overhead tray, including the incline section.
However, it is important to point out that this factor, flame spread rate in the trays, is not the
result of change in the ERFBS performance.
C.3.3 Unit 1 Reactor Plant Auxiliary Equipment Area: Transient Fire
Description of the transient fire scenario is provided in section C.1.3.
C-10
Fire Modeling
Licensed Condition- The MEFS was assumed with a 1 gallon lube oil spill over a 3.5 ft2 area
(428KW heat release rate). No damage to either of the wrapped divisions was calculated by any
o o
of the fire models. The fire size required to produce 360 C (700 F) temperature at the FS-195
wrapped (higher) cable tray was predicted between 0.8-3MW (LFS). The broad range of
estimated fire sizes are due to the effects a hot smoke layer can have on the plume temperatures.
The manner in which this effect reflected in the different models is different. FIVE for example,
sums the plume temperature to the smoke layer temperature. For that reason fire sizes estimated
with this model are lower than using a direct calculation from a correlation. In this specific
scenario, COMPBRN-IIIe and FIVE suggest limiting fire sizes that are very similar to the one
generated by the oil spill. Therefore the EM-50 protected tray is likely to be damaged by the
fire.
Tested Condition – With combustible FS-195 and reduced fire rating, the MEFS will reach
260oC (500 oF) at the location of the FS-195 wrapped tray according to COMPBRN-IIIe only.
Time to damage follows timing of the HRR.
In summary, the transient fire scenario does not result in damaging temperature at the target
unless a larger fire (500kW-3MW) is postulated. There is little difference in the LFS between
Baseline and Tested conditions. The timing if the damage is driven by the reduced fire rating of
the ERFBS.
C.4 Observations and Insights
In general the standard provides adequate information necessary to follow the process of
defining and evaluating fire scenarios in support of a performance-based approach. The standard
does not and was not intended to provide as a Guide (or a how-to book) for fire modeling.
Numerous other references provide such guidance such as SFPE handbook and “SFPE
Engineering Guide to Performance-Based Fire Protection”. Nevertheless, an Implementation
Guide is needed to set more specific criteria for fire modeling. Such Guidance should include
but not be limited to:
• How to define fire scenarios based on operating experience and fire tests,
• When and how to define Limiting Fire Scenarios, i.e., which of the critical parametere(s)
need to be varied to define the appropriate LFS.
• How to establish whether appropriate fire modeling codes are used for the scenario,
• When and how a quantitative evaluation of the uncertainties in the fire modeling is to be
performed.
• How the results of fire modeling are interpreted and used in making decisions, e.g., when and
how a LFS is used in evaluating performance.
C-11
Fire Modeling
Table C-1
Summary of the Features of the Selected Fire Models
Model FIVE [Ref. 5] COMBRN IIIe [Ref. 7] CFAST [Ref. 6] MAGIC [Ref. 8]
General Features
Type of model Quasi-steady zone Quasi-steady zone Transient zone Transient Zone
Number of layers 1 1–2 2 2
Compartments 1 1 30 24
Floors 1 1 30 24
Vents Wall (1) Wall (1) Wall (4/room), Floor (1), Wall, floor or ceiling with a
Ceiling (1) limit of 30.
Number of fires Multiple Multiple Multiple Multiple
Ignition of secondary fuels No Yes Yes Yes.
Plume/ceiling jet sublayer Yes Yes/plume only Yes
Mechanical ventilation Yes Yes Yes Yes
Targets Yes Yes Yes Yes
Uncertainty Analysis No Yes No No
Fire Sources
Types 1. Gas 1. Gas 1. Gas 1. Gas
2. Pool 2. Pool
3. Solid 3. Solid
Combustion factors 1. O2 constrained O2 constrained 1. O2 constrained 1. O2 constrained in the
(optional) (optional) plume computation
2. Yields specified 2. Yields specified 2. Burning at the opening
if O2 available
Other factors 1. Secondary ignition 1. Secondary ignition 1. Secondary ignition
2. Radiation 2. Combustible
enhancement consumption
3. Mixing of combustible
Fire Plumes
Types Axisymmetric Axisymmetric (Zukoski) Axisymmetric 1. Axisymmetric
(Heskestad) (McCaffrey) (McCaffrey)
2. Linear (Zukoski)
Modification factors 1. Wall / corner 1. Wall / corner 1. Wall / corner 1. Wall / corner
2. Doorway tilt
Ceiling Jets
C-12
Fire Modeling
Model FIVE [Ref. 5] COMBRN IIIe [Ref. 7] CFAST [Ref. 6] MAGIC [Ref. 8]
Types 1. Unconfined N/A Unconfined for detection 1. Unconfined (Cooper
(Alpert) modified)
2. Confined 2. Confined (Cooper
(Delichatsios) modified)
Vents
Types Wall Wall Wall / Floor / ceiling Wall / Floor / ceiling
Method Bernoulli / orifice Bernoulli / orifice Bernoulli / orifice Bernoulli / orifice
Cooper model for
horizontal openings
Modification factors Flow coefficient Flow coefficient Shear Flow coefficient Flow coefficient
mixing Shear mixing Shear mixing
Stack effect Stack effect
Wind effect Plume effect
Bi-directional in
floor/ceiling opening
Mechanical Ventilation
Types Injection Extraction Injection Extraction Injection Extraction Injection Extraction
Method Volumetric flow Volumetric flow Fan/duct network (triple Fan (pressure/flow model)
connection)
Boundary Heat Loss
Method Heat loss factor 1-D conduction 1-D conduction 1-D conduction multi-layer
model
Boundary conditions N/A Radiative Radiative Radiative
Convective Convective Convective
(Floor / ceiling) (all walls)
Equipment heat loss No Yes Yes (Targets) Yes. Radiation
absorption.
Targets
Types 1. Thermally thick 1. Thermally thick 1. Thermally thick 1. Thermally thick
2. Thermally thin 2. Thermally thin 2. Thermally thin 2. Thermally
3. Everything between
Heating Radiative Radiative Radiative Radiative
Convective Convective Convective Convective
Damage criteria Temperature Temperature Temperature Temperature
Heat flux Heat flux
Flux-time product Thermal detector
behavior.
C-13
Fire Modeling
Table C-2
Fire Modeling Results for Scenario 1: Switchgear Room, Switchgear Fire
Baseline 1 Case 1 2
COMPBRN-
COMPBRN-
MAGIC
MAGIC
CFAST
CFAST
FIVE
FIVE
IIIe
IIIe
Results
Maximum Expect Fire Scenario (MEFS). Fixed HRR of 100 kW.

Ignition of overhead tray [Yes or No] No No No No No Yes Yes No
Time to ignition of the overhead No No No No No No
cable tray [sec] N/A N/A
Damage Damage Damage Damage Damage Damage
Time to target damage [sec] No No

N/A N/A N/A N/A N/A N/A
Damage Damage
Time to detector actuation [sec] < 20 <20 <20 N/A < 20 <20 <20 N/A
Limiting Fire Scenario
Switchgear HRR [kW] (Critical). 250 178 150 250 150 100 100 250
Time to ignition of the overhead tray
N/A N/A N/A 5 N/A N/A N/A 5
[sec]
Cable tray HRR [kW]
10000 12000 12000 3800 4000 6000 8000 1000
(Critical).
Time to target damage [sec] 300 >1800 135 500 400 >1000 160 500
Time to detector actuation [sec] <20 <20 <20 N/A <20 <20 <20 N/A
Notes:
o o
1 Both FS-195 and EM-50 ERFBS are non-combustible and provides 1-hour fire rating. Cable ignition at 700 F (371 C).
2 FS-195 is combustible and provides 15 minutes fire rating. EM-50 is non-combustible with fire rating of 45 minutes.
C-14
Fire Modeling
Table C-3
Fire Modeling Results for Scenario 2: MCC Room, MCC Fire
Baseline 1 Case 1 2
COMPBRN-IIIe
COMPBRN-IIIe
MAGIC
MAGIC
CFAST
CFAST
FIVE
FIVE
Results
Maximum Expect Fire Scenario (MEFS). Fixed HRR of 100 kW.

Ignition of the overhead tray [Yes or
Yes Yes Yes Yes Yes Yes Yes Yes
No]
Time to ignition of the overhead
0 0 0 0 0 0 0 0
cable tray [sec]
Time to flame spread on trays 50 min (Hand Calculation)
No No No No No No No
Time to target damage [min] 30-50 min
Damage Damage Damage Damage Damage Damage Damage
Limiting Fire Scenario
HRR [kW] on cable tray (critical) 1800 2200 800 1500 1400 1500 550 1000
Time to target damage [sec] 200 1300 N/A 450 100 80 N/A 500
Notes:
o o
C-15
Fire Modeling
Table C-4
Fire Modeling Results for Scenario 3: MCC Room, Transient Fire
Baseline 1 Case 1 2 (Damage Temperature = 260°C)
COMPBRN-
COMPBRN-
MAGIC
CFAST
MAGIC
CFAST
FIVE
FIVE
IIIe
IIIe
Results
Maximum Expect Fire Scenario (MEFS). Fixed HRR of 428 kW until 1 gallon (125,700 Btu of lubricating oil) is burned.
Ignition of overhead tray [Yes or No] No No No No No No No No
No No No No No No No
Time to target damage [sec] EM-50 No Damage
Damage Damage Damage Damage Damage Damage Damage
Time to target damage [sec] FS-195 No No No No No No No No
Limiting Fire Scenario.
Transient HRR [kW] (Critical). EM-
3000 2776 800 500 1700 1600 700 500
50
Time to target damage [sec] EM-50 N/A N/A 60 N/A N/A N/A 80 N/A
Transient HRR [kW] (Critical). FS-
4000 4400 1000 600 2000 2500 900 600
195
Time to target damage [sec] FS-195 N/A N/A 60 N/A N/A N/A 75 N/A
Notes:
o o
C-16
D
CHANGE ANALYSIS
The NFPA 805 standard requires that in the event of a change to a previously approved fire
protection program a risk-informed plant change evaluation be performed. The evaluation is to
be used in an integrated assessment that includes risk, defense-in-depth and safety margin to
determine acceptability of the change.
The process of the change analysis was examined in this pilot effort through the following steps:
1. Defining Cases - Three cases where defined to represent varying states of the fire protection
program elements. These include the previously approved condition (Baseline) the current
condition which has been determined after testing of the installed ERFBS, and one
alternative design modification, i.e., installation of automatic suppression system
(Alternative). The Baseline and the Alternative cases were evaluated in the examination of
the Change Analysis.
2. Defining Scope of the Risk Model – In the interest of time and to meet the objectives of this
project, representative sample of the total plant fire risk model was selected. For the
purposes of this examination, plant risk was represented through examination of two fire
areas (unit 1 4.16 KV Switchgear Room (1FA-AB-64A) and Auxiliary Building Equipment
Room (1FA-AB-100C)). Fire risk was represented by a fire in the 4KV switchgear 1B in the
4KV switchgear room and fires in an MCC and a transient fire in the auxiliary building
equipment room.
3. Calculation of CDF and LERF - Using PSA methods, tools and data and estimate of CDF
and LERF were developed for the cases defined in step 1. These estimates were developed
using calculated values in the Salem fire IPEEE [Ref. 9, 10]. No detailed calculations were
done to confirm these values and when use of additional numbers became necessary, they
were estimated by extrapolation of existing values. The objective of this project is to
examine the process and not to derive actual risk estimates or evaluate strategies. For this
reason, this examination focuses on CDF and does not provide quantitative values for Large
Early Release Frequency (LERF). Methods are available for estimating LERF once plant
damage sequences are known.
4. Assessment of Defense-in-Depth and Safety Margin – Each element of DiD was examined
qualitatively to determine the impact due to the change. Safety margin was determined, in
part, from the Limiting Fire Scenario.
5. Integrated Assessment – Finally, the change was evaluated using the approach discussed in
section 4.6.4.
D-1
Change Analysis
D.1 Risk Calculation
This section describes development of the risk information for the Baseline (Approved License
Condition) and the Alternative Design Modification cases.
For the purposes of the Pilot Evaluation, the Baseline case was assumed to be the approved
licensing basis, i.e., one hour protection by the wrap (which is non-combustible) and manually
operated CO2 system. The calculation is summarized in table D-1. The Alternative Design
Modification case is based on the actual fire rating and combustibility data for the wrap material
and installation of an automatic CO2 system in the Switchgear Room, sprinkler system in fire
area 100C to protect the division 1C cable tray against an MCC fire and no protection against the
transient fire scenario. This calculation is summarized in table D-2
Fire Frequency – Fire frequencies used in this analysis for the selected fire scenarios are based
on the Salem Fire IPEEE [Ref. 9, 10]. This calculation uses the Fire Induced Vulnerability
Evaluation (FIVE) methodology [Ref. 3] for calculation of the fire frequency.
Fire Severity – A fire severity of 0.12 is used for an electrical cabinet fire outside the control
room (per Fire PRA Guide). The transient fire uses floor area ratio as a means of determining
critical location were the damage defined by the fire scenario is credible. Value of the floor area
ratio was obtained from the Salem Fire IPEEE.
Fire size and propagation – Appendix C of this document discusses the fire modeling. This
appendix contains the process of defining fire scenarios, selection of the fire models and
evaluation of the selected fire scenarios. The evaluation was done to calculate time-to-damage
and time-to-detector actuation using input data from actual plant configuration and information
from other sources to form the basis for the Maximum Expected Fire Scenario (MEFS). The fire
modeling also defined the Limiting Fire Scenarios (LFS) when the MEFS did not cause damage
to the designated target. In the Baseline case the fire modeling evaluated the conditions
reflecting non-combustible ERFBS with 1-hour fire rating. The fire modeling also evaluated As-
Tested condition where the FS-195 is combustible and the fire rating of the ERFBS is less than 1
hour according to the tests conducted by PSEG-Nuclear. The results of this modeling are
summarized in tables C-2 through C-4.
Fire Prevention – The information on the time-to-damage and time-to-detector actuation from
fire modeling was used to determine availability of suppression before damage occurs.
Effectiveness of suppression was determined based on compliance with appropriate codes. For
this evaluation, it was assumed that suppression systems credited for the selected scenarios meet
the applicable codes. These systems were not reviewed at the pilot plant for code compliance.
Suppression was then credited if available and effective.
The reliability of the manual CO2 system in the 4KV switchgear room was calculated based on
available time from fire modeling (Time to damage – Time to detector actuation) and random
failures of a CO2 system (0.05 based on FIVE). Unavailability of the CO2 system was verified
based on Salem impairment records to check system unavailability in excess of 55 days per year.
Manual suppression by the fire brigade in the MCC and transient fire scenarios were calculated
D-2
Change Analysis
based on the model described in Appendix K of the EPRI Fire PRA Implementation Guide [Ref.
4].
Conditional Core Damage Probability – Following conditional core damage probabilities were
used for this evaluation. These values are based on existing calculations from 1995 Salem Fire
IPEEE [Ref. 9, 10] and were selected for demonstration purposes only.
Plant Damage State CCDP

Turbine trip with PCS unavailable/non-recoverable. All divisions available 1.1E-5
Loss of division 1B only 1.8E-2
LOOP and loss of division 1A 4.6E-2
LOOP and loss of division 1C 5.3E-2
LOOP and loss of divisions 1A and 1C 3.1E-1
LOOP and loss of all three divisions (use of Gas Turbine) 3.1E-1
Core Damage Frequency – Tables D-1 and D-2 provide a summary of CDF calculations for the
selected fire scenarios and fire areas.
D.2 Assessment of Defense-in-Depth and Safety Margin
A deterministic examination of the DiD and Safety Margin was done as prescribed in sections 2-
3.4.2 and 2-3.4.3 of the standard.
D.2.1 Examination of elements of Defense-in-Depth
Fire Prevention – No new source of fire has been introduced in any of the fire areas (64A and
100C). Therefore, this element of defense-in-depth remains the same through the change.
Fire Mitigation - A combustible barrier material in the form of FS-195 introduces means of
propagating the fire. However, addition of automatic CO2 in the Switchgear room (64A) and
partial sprinkler system to protect against the MCC fire scenario in 100C will provide adequate
mitigation against the fire scenarios identified. Addition of an area-wide sprinkle system in fire
area 100C does not provide mitigation against the transient fire scenario.
Nuclear Safety – Degraded ERFBS (10-45 minutes versus 1 hour fire rating) provides less
protection against fire damage. Use of offsite power or other non-safe shutdown systems could
improve the nuclear safety if demonstrated to be free of fire damage for the fire scenarios
identified.
Prevention Mitigation Nuclear Safety
Combustible FS-195 Degraded ERFBS fire rating
Improved suppression Use of other non-SSD systems
D-3
Change Analysis
The change maintains the philosophy of DiD since:

• The change preserve a balance among DiD elements by addressing degradation in each
element with enhancement directed at the same element.
• The change does not impact the balance among prevention of core damage, prevention of
containment failure, and consequence mitigation.
• Degradation in a plant design is replaced with a design modification avoiding reliance on
programmatic activities instead.
• system redundancy, independence, and diversity are preserved commensurate with the
expected frequency, and consequences of challenges to the system and uncertainties (e.g., no
risk outliers)
• The change does not introduce dependencies that reduce system redundancies and diversity.
In fact use of new systems, if free of fire damage, improve diversity.
• The Alternative introduces separate changes to elements of DiD, i.e., suppression systems to
enhance mitigation and use of non-SSD systems to improve Nuclear Safety preserving the
independence of the elements of DiD.
D.2.2 Examination of the Safety Margin
The standard requires that and plant change analysis maintains sufficient safety margin. The
standard does not provide any guidance for this assessment. Regulatory Guide 1.174 presents on
set of criteria for such assessment that is shown here.
“An acceptable set of guidelines for making that assessment are summarized below.
Other equivalent acceptance guidelines may also be used. Sufficient safety margins are
maintained if:
• codes and standards or alternatives approved for use by the NRC are met
• safety analysis acceptance criteria in the current licensing basis (e.g., FSAR,
supporting analyses) are met, or proposed revisions provide sufficient margin to
account for analysis and data uncertainty.”
For the purposes of this examination assessment of Safety Margin was done primarily on the
basis of the margin between the Maximum Expected and Limiting fire scenarios.
In case of the Switchgear room fire, the margin provided by the initiating fire is not substantial
(100KW MEFS and 130-175KW LFS) however, violating the performance criteria requires a
sizable secondary cable fire that grows to 8-10MW. Fires higher than 1 MW are expected to be
oxygen constrained.
In the MCC fire scenario, the critical parameter driving the limiting fire scenario is the size of the
secondary cable fire and flame spread rate in the trays. The fire size, that impacts the extend of
damage to safe shutdown circuits, is expected to be oxygen constrained. Flame spread rate
impacts the timing of the damage. Considerably higher flame spread rate (than the expect value
D-4
Change Analysis
of 10 ft/hr) is required to reduce time-to-damage to where the Plant Change (partial sprinkler
system) will be ineffective (10-25 second time-to-detector actuation).
Considerable margin exists between the MEFS (428KW) and LFS (2350-4000KW) in case of
the transient fire scenario in the 100C fire area.
D.3 Plant Change Evaluation
The standard requires that a proposed Plant Change be evaluated taking into account
acceptability of risk, defense-in-depth and safety margins. The change in risk should be
acceptable to AHJ.
The change in risk, defense-in-depth and safety margin associated with the Alternative Design
Modification are discussed in sections D.1, and D.2. With the Alternative Design the fire risk
(represented by CDF here but the standard requires CDF and LERF) will increase by 3E-7/rxyr
from 3.0E-6/rxyr to 3.3E-6/rxyr. Using the Regulatory Guide risk acceptance criteria (Figure 3),
this plant change falls into Region III as an acceptable change in risk. Following is how this
change in risk is characterized in RG 1.174:
-6
“When the calculated increase in CDF is very small, which is taken as being less than 10
per reactor year, the change will be considered regardless of whether there is a
calculation of the total CDF (Region III). While there is no requirement to calculate the
total CDF, should there be an indication that the CDF may be considerably higher than
-4
10 per reactor year, the focus should be on finding ways to decrease rather than increase
it. Such an indication would result, for example, if: (1) the contribution to CDF
calculated from a limited scope analysis, such as the IPE, and, if appropriate the IPEEE,
-4
significantly exceeds 10 ; (2) there has been an identification of a potential vulnerability
from a margins type analysis; or (3) historical experience at the plant in question has
indicated a potential safety concern.”
D.4 Observations and Insights
The main body of the standard describes how Fire Risk Evaluations and Plant Change Analysis
shall be used. Appendix D provides high level guidance for conducting such engineering
evaluations. However, a number of insights were obtained trying to actually conduct a Plant
Change Analysis. The insights, for the most part points to the need for establishing some criteria
for what is an acceptable method, quality and results. Most of these can be addressed in an
Implementation Guide.
Following are some of the observations and insights from exercising the plant change analysis
sections of the standard some of these may be addressed in an Implementation Guide others
however, may depend on the individual plant and other conditions that preclude generic
guidelines.
• Fire PSA Quality. Some definition of what are attributes of an acceptable fire PSA is needed
to help control the cost associated with performing these engineering evaluations. While the
D-5
Change Analysis
standard does point out that the quality required of a fire PSA needs to remain consistent with
the plant change being proposed, it was does not describe what that quality entails.
• Maintenance of a Fire PSA - The standard requires that an engineering evaluation performed
in support of a change to a licensing basis is maintained consistent with other Fire Protection
Program Design Basis Documentation. There is no precedent in what that documentation
entails in case of a Fire PSA. For example, how much of an Internal Events PSA will
become part of the Fire Protection Program Design Basis Documentation and needs to be
maintained.
• Bundling – Should the plant change be evaluated on the basis of: a) single fire area vs. total
plant risk or b) fire risk vs. all risk.
• Fire Risk Acceptance Criteria – Implementation of the plant change analysis requires a fire
risk acceptance criteria. The standard only says that such criteria shall be acceptable to AHJ.
D-6
Table D-1
Risk Calculation Summary for the Baseline Case
Severity Factor
Fire Frequency
detection (sec)
damage (min)
or Floor Area
Source Type
NSP (fs/ma)
Description
Equipment
Fire Zone
Impacted
Scenario
NSP(as)
NSP(fb)
Time to
Time to
CCDP
Ratio
Zone
CDF
Scenario Description
Unit 1 1.7E-06
1FA-AB-64A Unit 1 4.16KV Switchgear Room 1.4E-06
1FA-AB-64A Unit 1 4.16KV 64A- Fire in the 4KV switchgear 1B with Electrical 6.3E-04 0.12 <20 No Loss of 4KV bus 1.8E-02 1.4E-06
Switchgear 805-1 successful suppression (Manual CO2 Cabinet division 1B.
Room system). Maximum Expected at 100KW.
1FA-AB-64A Unit 1 4.16KV 64A- Fire in the 4KV switchgear 1B with failure Electrical 6.3E-04 0.12 <20 No Loss of 4KV bus 1.8E-02 (1)
Switchgear 805-2 of the manual CO2 system. Cabinet division 1B.
Room
1FA-AB-100C Reactor Plant Auxiliary Equipment Area el. 100' 3.2E-07
1FA-AB-100C Reactor Plant 100C- Fire in the MCC with successful Fixed 6.3E-04 0.12 <20 N/A 1.0 Damage limited to the 1.1E-05 8.5E-10
Auxiliary 805-1 suppression (brigade). Maximum MCC and overhead
Equipment Expected at 100KW. tray. Turbine trip with
Area el. 100' PCS unavailable/non-
recoverable. All
divisions available
1FA-AB-100C Reactor Plant 100C- Fire in the MCC with no suppression Fixed 6.3E-04 0.12 <20 110 0.01 LOOP and loss of 5.3E-02 4.0E-08
Auxiliary 805-2 (brigade). (2) division 1C. (3)
Equipment
Area el. 100'
1FA-AB-100C Reactor Plant 100C- Transient fire in the entrance to the DG Transient 1.1E-02 8.1E-04 <20 N/A 0.9 Turbine trip with PCS 1.1E-05 1.0E-10
Auxiliary 805-3 rooms where divisions A and C cross. unavailable/non-
Equipment Maximum Expected modeled as a 1 recoverable. All
Area el. 100' gallon of lube oil (for the DG) spill. divisions available.
Successful suppression by the fire
brigade.
1FA-AB-100C Reactor Plant 100C- Transient fire in the entrance to the DG Transient 1.1E-02 8.1E-04 <20 No 0.1 Loss of division 1A 3.1E-01 2.8E-07
Auxiliary 805-4 rooms where divisions A and C cross. (4) and 1C with LOOP.
Equipment Maximum Expected modeled as a 1
Area el. 100' gallon of lube oil (for the DG) spill.
Failure of suppression within 60 minutes
(Designed fire rating of FS-195 and EM-
50).
D-7
Change Analysis
Notes:
1. No damage to the protected train was predicted from the fire modeling (with no suppression). See the results of fire modeling in Appendix C.
2. Non-suppression probability of 0.01 within 2 hours is used based on the cable fire suppression model in Appendix K of EPRI’s Fire PRA
3. The MEFS did not result in damage to the target in the Baseline conditions due to oxygen limitations to sustain an elevated 1-2 MW cable fire
(see section C.3.2). The risk is calculated based on the LFS. The risk associated with the MEFS will be negligible.
4. Non-suppression probability of 0.1 for pump fires within 60 minutes (protection provided by the ERFBS) from Appendix K of the EPRI’s Fire
PRA Implementation Guide.
D-8
Change Analysis
Table D-2
Risk Calculation Summary for the Alternative Design Case
Severity Factor
Fire Frequency
detection (sec)
damage (min)
or Floor Area
Source Type
NSP (fs/ma)
Description
Equipment
Fire Zone
Impacted
Scenario
NSP(as)
NSP(fb)
Time to
Time to
CCDP
Ratio
Zone
CDF
Scenario Description
Unit 1 3.5E-06
1FA-AB-64A Unit 1 4.16KV Switchgear Room 2.5E-06
1FA-AB-64A Unit 1 4.16KV 64A- Fire in the 4KV switchgear 1B with successful Electrical 6.3E-04 0.12 <20 N/A 0.95 Loss of 4KV bus 1.8E-02 1.3E-06
Switchgear 805-1 suppression (Manual CO2 system). Maximum Cabinet division 1B. (1)
Room Expected at 100KW.
1FA-AB-64A Unit 1 4.16KV 64A- Fire in the 4KV switchgear 1B with failure of the Electrical 6.3E-04 0.12 <20 33-45 0.05 Loss of offsite power 3.1E-01 1.2E-06
Switchgear 805-2 manual CO2 system. Cabinet and all three 4KV
Room buses.
1FA-AB-100C Reactor Plant Auxiliary Equipment Area el. 100' 1.0E-06
1FA-AB-100C Reactor Plant 100C- Fire in the MCC with successful suppression Fixed 6.3E-04 0.12 <20 N/A 0.9 Damage limited to the 1.1E-05 7.8E-10
Auxiliary 805-1 (brigade). Maximum Expected at 100KW. MCC and overhead
Equipment tray. Turbine trip with
Area el. 100' PCS unavailable/non-
recoverable. All
divisions available
1FA-AB-100C Reactor Plant 100C- Fire in the MCC with no suppression (brigade). Fixed 6.3E-04 0.12 <20 66-73 0.1 LOOP and loss of 5.3E-02 4.0E-07
Auxiliary 805-2 (2) division 1C. (3)
Equipment
Area el. 100'
1FA-AB-100C Reactor Plant 100C- Transient fire in the entrance to the DG rooms Transient 1.1E-02 8.1E-04 <20 15 1 Turbine trip with PCS 1.1E-05 1.0E-10
Auxiliary 805-3 where divisions A and C cross. Maximum unavailable/non-
Equipment Expected modeled as a 1 gallon of lube oil (for recoverable. All
Area el. 100' the DG) spill. Successful suppression by the fire divisions available
brigade.
1FA-AB-100C Reactor Plant 100C- Transient fire in the entrance to the DG rooms Transient 1.1E-02 8.1E-04 <20 15 0.44 Loss of division 1A 4.6E-02 1.8E-07
Auxiliary 805-4 where divisions A and C cross. Maximum (4) (wrapped in FS-195)
Equipment Expected modeled as a 1 gallon of lube oil (for with LOOP.
Area el. 100' the DG) spill. Failure of suppression within 15
minutes (Tested fire rating of FS-195).
1FA-AB-100C Reactor Plant 100C- Transient fire in the entrance to the DG rooms Transient 1.10E-02 8.1E-04 <20 45 0.15 Loss of division 1A 3.1E-01 4.1E-07
Auxiliary 805-4 where divisions A and C cross. Maximum (4) (FS-195) and 1C (EM-
Equipment Expected modeled as a 1 gallon of lube oil (for 50) with LOOP.
Area el. 100' the DG) spill. Failure of suppression within 45
minutes (tested fire rating of the EM-50).
D-9
Change Analysis
Notes:
1. No damage to the protected train was predicted from the MEFS with tested conditions (See the results of fire modeling in Appendix C). The
risk is calculated for the LFS, which requires an oxygen constrained 1-8 MW (based on the fire model used) cable fire.
2. Non-suppression probability of 0.1 within 1 hours is used based on the cable fire suppression model in Appendix K of EPRI’s Fire PRA
3. The MEFS did not result in damage to the target in the tested (degraded) conditions due to oxygen limitations to sustain an elevated 0.5-1.5
MW cable fire (see section C.3.2). The risk is calculated based on the LFS. The risk associated with the MEFS will be negligible since no
damage is predicted.
4. The non-suppression probabilities are based on suppression model from Appendix K of the EPRI’s Fire PRA Implementation Guide for
pump fires within 15 and 45 minutes respectively.
D-10
Target: About EPRI
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A Pilot Plant Evaluation Using NFPA-805 Performance-Based Standard For Fire Protection For Light Water Reactor Electric Generating Plants

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A Pilot Plant Evaluation Using NFPA-805,

"Performance-Based Standard for Fire

Final Report, May 2001

EPRI Project Manager

(A) MAKES ANY WARRANTY OR REPRESENTATION WHATSOEVER, EXPRESS OR IMPLIED, (I)

(B) ASSUMES RESPONSIBILITY FOR ANY DAMAGES OR OTHER LIABILITY WHATSOEVER

ORGANIZATION(S) THAT PREPARED THIS DOCUMENT

Science Applications International Corporation

This report was prepared by

Science Applications International Corporation

This report describes research sponsored by EPRI.

This Pilot Evaluation led to the following conclusions:

2 OBJECTIVES ...................................................................................................................... 2-1

3 SCOPE ................................................................................................................................ 3-1

4 EXAMINATION APPROACH AND RESULTS..................................................................... 4-1

5 EXAMINATION OF THE OTHER ELEMENTS OF THE STANDARD.................................. 5-1

6 NFPA-805 AS AN ALTERNATIVE LICENSING BASIS ...................................................... 6-1

7 CONCLUSIONS AND RECOMMENDATIONS .................................................................... 7-1

8 REFERENCES .................................................................................................................... 8-1

B REVIEW OF “FUNDAMENTAL FIRE PROTECTION PROGRAM AND DESIGN

C FIRE MODELING ................................................................................................................ C-1

D CHANGE ANALYSIS.......................................................................................................... D-1

Does the Standard Provide the Framework Necessary to Implement A Performance-Based

Is the Standard Practical?

Can the Standard be Used in a Cost-effective Way?

3.1 NFPA 805 Approach

a) Establish the fundamental fire protection program (Chapter 3 of the Standard).

b) Identify fire areas and associated fire hazards.

f) When applying a deterministic approach, demonstrate compliance with the deterministic

g) When applying a performance-based approach, perform engineering analyses to demonstrate

3.2 Other Elements of the Standard

3.3 NFPA 805 as an Alternate Fire Protection Licensing Basis

Establish Mandatory Fire

Identify Fire Hazards

Identify Structures, Systems

Deterministic Approach Performance Based Approach

Maintain Compliance with Existing Evaluate Ability to Satisfy

•PSA to Examine Impact on Overall Plant Risk

Risk-Informed Change Evaluation

QUALITATIVE Quantitative Probabilistic safety

Fire Hazard Assessment

Evaluate Evaluate Consider

Identify fire protection Effectiveness of fire protection Consider other equipment or

Identify combustible type, Will fire protection feature(s) Consider additional or

Identify potential ignition Are fire protection systems Consider deterministic

Consider area configuration, Availability of systems,

Define limiting fire scenarios Can

NFPA Chapter 2 Approach Pilot Evaluation

Identify fire areas and associated fire hazards Section 4.1

When applying a performance-based approach, perform engineering analyses to Section 4.5

NFPA Chapter 2 Approach Pilot Evaluation

4.1 Fire Areas and Associated Fire Hazards

4.1.1 1FA-AB-100C – Reactor Plant Auxiliary Equipment Area

4.1.2 1FA-AB-64A – 4160V Switchgear Room

4.2 Performance Criteria

a) Reactivity Control. Capable of rapidly achieving and maintaining subcritical

unrecoverable condition. To demonstrate this, the following performance criteria shall be

a) Reactivity Control. Shall be capable of inserting negative reactivity to achieve

d) Vital Auxiliaries. Shall be capable of providing the necessary auxiliary support

e) Process Monitoring. Shall be capable of providing the necessary indication to

4.3 Identification of Applicable Structures, Systems, and Components

4.3.1 Fire Area 1FA-AB-100C – Reactor Plant Auxiliary Equipment Area

4.3.2 Fire Area 1FA-AB-64A – 4160V Switchgear Room