D O C U M E N T A T I O N I N F O R M A T I O N S E R V I C E S

2. FHA / DSA Integration Why Integrate? FHA / DSA Process Relationships FHA Requirements and Criteria FHA Content and Structure FHA / DSA Integration Summary Statements Paths Forward Experience

3. FHA / DSA Integration Compliance with Requirements DOE-O-420.1B – Required Element of a Fire Protection Program: “FHA conclusions incorporated into the DSA and integrated into design basis and beyond design basis accident conditions.” Completeness of Analysis FHAs must include: Code Compliance Reviews (prescriptive requirements) Program Evaluations (programmatic requirements) Damage Analysis (scenario-based analysis) DSAs must be based on: Hazard Analysis of all fires Accident Analysis of design basis fires Eliminate Discrepancies Between Documents FHA & DSA will analyze the same events (fire with rad. / chem. consequences) FHA & DSA analysis of the same event will have the same conclusions Note here that the FHA has three distinct areas of analysis (prescriptive, programmatic, and scenario-based). Only the scenario-based analysis interfaces directly with the DSA. Note here that the FHA has three distinct areas of analysis (prescriptive, programmatic, and scenario-based). Only the scenario-based analysis interfaces directly with the DSA.

4. Requirements Section II.3.b. requires a documented fire protection program that includes: (5) Fire hazard analyses (FHAs) for: hazard category 1, 2 and 3 nuclear facilities, significant new facilities (as determined by the AHJ) and facilities that represent unique fire safety risks. The FHAs must be— (a) performed under the direction of a qualified fire protection engineer; (b) reviewed every 3 years; and (c) revised when— 1. changes to the annual DSA updates impact the contents in the FHA, 2. a modification adds a significant new fire safety risk, or 3. the 3 year review identifies the need for changes. (6) FHA conclusions incorporated into the DSA and integrated into design basis and beyond design basis accident conditions. Note in item 5 the FHA requirements tied to DSA: Required for HC 1,2,3 facilities Revised when DSA update impacts FHA. Item 6 is the regulatory driver for the entire enhanced integration schemeNote in item 5 the FHA requirements tied to DSA: Required for HC 1,2,3 facilities Revised when DSA update impacts FHA. Item 6 is the regulatory driver for the entire enhanced integration scheme

5. FHA Requirements FHA Required for: Hazard Category 1, 2, and 3 Nuclear Facilities high-hazard facilities significant new facilities facilities that store or process significant quantities of hazardous materials Purpose of FHA: The purpose of an FHA is to conduct a comprehensive, qualitative assessment of the risk from fire within individual fire areas in a DOE facility to ascertain whether the DOE fire safety objectives of DOE O 420.1B are met. This should include an assessment of the risk from fire and related hazards (wildland fire exposure, direct flame impingement, hot gases, smoke migration, fire-fighting water damage, etc.) in relation to existing or proposed fire safety features to ensure that the facility can be safely controlled and stabilized during and after a fire. Another DOE FHA criteria document with safety interface specified.Another DOE FHA criteria document with safety interface specified.

6. FHA Content and Structure Description of construction Description of critical process equipment Description of high-value property Description of fire hazards Description of operations Potential for a toxic, biological and/or radiological incident due to a fire Natural hazards (earthquake, flood, wind, lightning, and wildland fire) impact on fire safety Damage potential: Include both the Maximum Possible Fire Loss (MPFL) as defined in DOE-STD-1066-99 and the DSA of the design basis fire scenario These are the elements required by the DOE Guide to be in an FHA. The red text indicates those element that have or can have direct interface with the DSA. The blue item is a special case of interface discussed on the next slide. These are the elements required by the DOE Guide to be in an FHA. The red text indicates those element that have or can have direct interface with the DSA. The blue item is a special case of interface discussed on the next slide.

7. The FHA is required to evaluate fire impact to Safety Class and Safety Significant Equipment List of equipment is obtained from CHA or DSA(should be FHA’s only reference to DSA). Equipment is identified in FHA. List is to be all-inclusive(i.e., NOT restricted to SC/SS equipment credited for fire/fire-related events). Evaluation is similar to safe shutdown analysis in commercial nuclear Industry. This identification, evaluation, and conclusions are unrelated to CHA or DSA development FHA Content and Structure This is a separate fire scenario-driven evaluation intended to assess the vulnerability of selected controls to related and unrelated fire events.This is a separate fire scenario-driven evaluation intended to assess the vulnerability of selected controls to related and unrelated fire events.

8. Disparate Development It was not uncommon for the FHA to simply refer to the DSA for evaluation of fire-induced radiological release.It was not uncommon for the FHA to simply refer to the DSA for evaluation of fire-induced radiological release.

9. Integrated Development Note the direction of information required to meet 420.1BNote the direction of information required to meet 420.1B

10. FHA/DSA Integration Model Note HA and FHA processes are very similar Note: FHA’s scenario-based analysis must evaluate damages with respect to several thresholds: Dollar loss Production loss Impact to SC / SS equipment Environmental impact Chemical/radiological release (this is the direct interface with the DSA) The left side of this slide has the two analysis efforts not directly related to DSAs, plus the scenario-based elements that are also not related to DSAs. The key scenario-based elements related to FHA/DSA interface are the lime colored boxes in the middle. Note the frequent opportunity for consistency and communication (grey arrows). Note the flow of information FROM the FHA TO the DSA, not the reverse.Note HA and FHA processes are very similar Note: FHA’s scenario-based analysis must evaluate damages with respect to several thresholds: Dollar loss Production loss Impact to SC / SS equipment Environmental impact Chemical/radiological release (this is the direct interface with the DSA) The left side of this slide has the two analysis efforts not directly related to DSAs, plus the scenario-based elements that are also not related to DSAs. The key scenario-based elements related to FHA/DSA interface are the lime colored boxes in the middle. Note the frequent opportunity for consistency and communication (grey arrows). Note the flow of information FROM the FHA TO the DSA, not the reverse.

11. Fire Accident Analysis Note this is a two step process per 3009. We’ve found the key is WHO does the first step. It should be the FHA author. Or he should at least be directly involved.Note this is a two step process per 3009. We’ve found the key is WHO does the first step. It should be the FHA author. Or he should at least be directly involved.

12. FHA Content and Structure This slide really is intended to tell the FHA author how to write a fire scenario in the FHA. It is helpful for safety folks to know that the FHA Provides the technical basis for what the fire does (Damage Estimate, DR) Is required to define consequence in relation to “stuff” other than rad/chemit is rare when this can’t be done in a single fire scenario evaluation May not have scenario descriptions that line up exactly with CHA eventshowever there should be no inconsistencies Should provide a list of “candidate controls” that lines up with the CHA. IS a qualitative AA for fire. This slide really is intended to tell the FHA author how to write a fire scenario in the FHA. It is helpful for safety folks to know that the FHA Provides the technical basis for what the fire does (Damage Estimate, DR) Is required to define consequence in relation to “stuff” other than rad/chemit is rare when this can’t be done in a single fire scenario evaluation May not have scenario descriptions that line up exactly with CHA eventshowever there should be no inconsistencies Should provide a list of “candidate controls” that lines up with the CHA. IS a qualitative AA for fire.

13. FHA / DSA Integration The dashed blue FHA line is to indicate the FHA author’s participation in the CHA meetings. Note the direction of information flow to the DSA/TSR.The dashed blue FHA line is to indicate the FHA author’s participation in the CHA meetings. Note the direction of information flow to the DSA/TSR.

14. Example 1

15. What Does This Mean? The FPE must be in attendance for CHA meetings where fire and fire-related events are discussed. The FPE should be invited to all CHA meetings. The CHA and FHA authors need to communicate on: Events Consequences Available Controls Credited Controls The DSA must draw conclusions from the FHA for fire and fire-related event consequences. Planning for FHA development must be incorporated in DSA schedule. DOE Order compliance is expected now.

16. Integrated FHA / DSA Development The FHA is a qualitative fire accident analysis (needs qualitative dose input). The FHA incorporates quantitative fire accident analysis into FHA. The FHA documents the FP engineering basis for defining postulated fire events (aligned with the CHA) to support the DSA. The FHA author must write the scenario discussion in a manner that lends to understanding / interpretation by the CHA/DSA author. The CHA/DSA author must accurately capture the conclusions of the FHA and select controls appropriate for reducing consequences of each scenario. The FHA author must verify, for credited controls, that the selected items are sufficient to achieve the stated reduction in consequences.

17. Integrated FHA / DSA Development Management Commitment to achieve compliance with DOE O 420.1B. Understanding and communication is key to integration. FHA author must participate in CHA and understand CHA methodologies. CHA/DSA authors must rely on FHA for fire damage estimates. Procedure Changes may be needed: FHA must be structured to support DSA FHA is design basis document for fire and the “holder” of all fire analyses FHA conclusions must be written to align with CHA CHA must be written to align with FHA Training may be required: FHA authors CHA / DSA authors

18. Integrated FHA / DSA Development Management Commitment to achieve integration. Integration is hard to achieve; There are ample opportunities to avoid integration Management’s commitment at SRS has substantially streamlined implementation Understanding and communication is key to integration. FPE staff briefings on safety basis methodology and Safety staff briefings on FHA methodology has increased awareness, and emphasized management support. FHA author is required to actively participate in CHA. Quantitative fire AA must be fed through the FHA to the DSA. CHA/DSA authors must rely on FHA for fire damage estimates. Procedure Changes / Training FHA writer’s guide being revised to enhance integration FPE training on CHA processes, and AA methods being developed.

19. Integrated FHA / DSA Development Some Results More realistic fire scenarios are being developed in the FHA resulting in significant reduction of mitigated and unmitigated consequences K- & L-Area moderator storage. H-Canyon shipping/receiving of DOT Type B containers. F- & H-Canyon TRU Waste Remediation (ARRA) 235-F D&D (ARRA) F/H Laboratory full facility fire scenario FPE staff is becoming much more engaged in facility safety basis development. Overlap of fire protection and safety basis control sets is yielding more realistic facility risk perspectives over multiple consequence parameters. Overlap bullet is about for example: crediting a fire barrier to limit fire size for MAR reduction also reduces maximum dollar loss values even where a barrier is not needed for that purpose. The reverse can also be true.Overlap bullet is about for example: crediting a fire barrier to limit fire size for MAR reduction also reduces maximum dollar loss values even where a barrier is not needed for that purpose. The reverse can also be true.

20. Questions and Contact Information Questions / Comments; Contact Information: Andrew Vincent Manager, Nuclear Safety Program, SRNS andrew.vincent@srs.gov 803-557-9989 Jay Lavender Manager, Analytical Support, SRNS jay.lavender@srs.gov 803-557-8147 Acknowledgements: Ray Sprankle Manager, Fire Protection Services, RSL Safety Corp ray.sprankle@srs.gov 803-557-9470