legal and safety – fire protection

Legal and Safety – Fire Protection ED2 Engineering Justification Paper

ED2-NLR(A)-SPEN-003-SAF-EJP

Issue Date Comments

Issue 0.1 March 2021 Issued for SRG

Issue 0.2 April 2021 Revised to incorporate review comments

Issue 1 30th June 2021 Draft Submission

Issue 2 30th November 2021 Final Submission

Scheme Name RIIO ED2 – CV14 – Legal and Safety – Fire Protection

PCFM Cost Type Non-Load Related – Other

Activity Fire Protection

Primary Investment Driver

Legal requirement to comply with ESQCR and Fire Safety Regulations

Reference ED2-NLR(A)-SPEN-003-SAF-EJP

Output Type Fire Protection

Cost SPD £6.591m SPM £7.245m

Delivery Year 2023-2028

Reporting Table CV14

Outputs included in ED1 Yes/No

Business Plan Section Ensure a Safe and Reliable Electricity Supply

Primary Annex Annex 4A.18 Legal and Safety (CV14) Strategy

Spend Apportionment ED1 ED2 ED3

£m £13.836m £m

ED2-NLR(A)-SPEN-003-SAF-EJP – CV14 Legal and Safety – Fire Protection

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Technical Governance Process

Project Scope Development IP1(S)

To be completed by the Service Provider or Asset Management. The completed form, together with an accompanying report, should be endorsed by the appropriate sponsor and submitted for approval.

IP1 – To request project inclusion in the investment plan and to undertake project design work or request a modification to an existing project IP1(S) – Confirms project need case and provides an initial view of the Project Scope IP2 – Technical/Engineering approval for major system projects by the System Review Group (SRG)

IP2(C) – a Codicil or Supplement to a related IP2 paper. Commonly used where approval is required at more than one SRG, typically connection projects which require connection works at differing voltage levels and when those differing voltage levels are governed by two separate System Review Groups. IP2(R) – Restricted Technical/Engineering approval for projects such as asset refurbishment or replacement projects which are essentially on a like-for-like basis and not

requiring a full IP2 IP3 – Financial Authorisation document (for schemes > £100k prime) IP4 – Application for variation of project due to change in cost or scope

PART A – PROJECT INFORMATION

Project Title: RIIO ED2- CV14 – Legal and Safety - Fire Protection

Project Reference: ED2-NLR(A)-SPEN-003-SAF-EJP

Decision Required: To give concept approval for the CV14 – Legal & Safety – Fire Protection Strategy

within the RIIO-ED2 price control period.

Summary of Business Need:

SPEN are legally required to comply with the ESQCR and Fire Safety Regulations as set out in Section 2.1 to carry out a fire

risk assessment at each substation, review risk assessment regularly, and undertake measures to reduce the fire risk from

substations as far as reasonably practicable.

Summary of Project Scope, Change in Scope or Change in Timing:

Undertake an extensive programme of FRAs at all our substation locations, a dedicated programme to close out actions

raised during FRAs will continue from that ongoing in RIIO-ED1 and targeted investment shall be undertaken at our 132kV

& 33kV grid substations to install or update fire detection systems to meet current policy and regulations.

Expenditure Forecast (in 2020/21 Prices)

Recommended Scheme Investment Profile Total

(£m)

Incidence (£m)

2023/2

4

2024/2

5

2025/2

6

2026/2

7

2027/2

8

CV14 – Fire Protection (SPM) 7.060 1.846 1.840 1.860 0.774 0.741

CV14 – Associated Pension Costs (SPM) 0.184 0.051 0.048 0.048 0.020 0.018

SPM Subtotal 7.245

CV14 – Fire Protection (SPD) 6.472 1.787 1.787 1.787 0.555 0.555

CV14 – Associated Pension Costs (SPD) 0.119 0.034 0.033 0.033 0.010 0.009

SPD Subtotal 6.591

This Proposal 13.836

PART B – PROJECT SUBMISSION

Proposed by David Cupples Signature Date: 30/11/2021

Endorsed by Matthew Jones Signature

Date: 30/11/2021

PART C – PROJECT APPROVAL

Approved by Malcolm Bebbington Signature

Date: 30/11/2021


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Contents Contents ....................................................................................................................................................................... 2

1. Introduction ........................................................................................................................................................ 1

2. Background Information .................................................................................................................................. 1

3. Needs Case ......................................................................................................................................................... 3

4. Optioneering ...................................................................................................................................................... 4

5. Detailed Analysis ................................................................................................................................................ 5

6. Deliverability and Risk ...................................................................................................................................... 6

7. Future Pathways – Net Zero .......................................................................................................................... 9

8. Conclusion ........................................................................................................................................................ 10


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1. Introduction SP Distribution and SP Manweb are legally required to comply with the current regulation for fire

safety in the design, construction and operation of our substations and network assets. This paper

covers the fire risk management strategy in relation to our substations at HV, EHV and 132kV within

the RIIO-ED2 Submission.

It is proposed within RIIO-ED2 to undertake an extensive programme of Fire Risk Assessments at all

our substation locations including repeat visits for those identified as being high risk. A dedicated

programme to close out actions raised during FRAs will continue from that ongoing in RIIO-ED1.

Targeted investment shall be undertaken at our 132kV & 33kV grid substations to install or update

fire detection systems to meet current policy and regulations.

Costs and volumes relating to fire protection works being undertaken as part of 132kV named

projects are excluded from this paper. More details can be found in the following engineering

justification papers;

- ED2-NLR(A)-SPM-003-TX-EJP Colwyn Bay 132kV Grid Transformers T1 & T2 Replacement

- ED2-NLR(A)-SPM-008-TX-EJP Rock Ferry 132kV Grid Transformers Modernisation

2. Background Information

2.1. Regulatory Requirements The Electricity Safety, Quality and Continuity Regulations (ESQCR) state “Every generator and

distributor shall, for every substation which he owns or operates, take all reasonable precautions to

minimise the risk of fire associated with the equipment” (regulation 11 (d)).

The Regulatory Reform (Fire Safety) Order 2005 (England & Wales), and The Fire (Scotland) Act

2005 state "Each employer shall ensure, so far as is reasonably practicable, the safety of the

employer's employees in respect of harm caused by fire in the workplace".

SP Distribution and SP Manweb have a legal requirement, as set out in The Regulatory Reform (Fire

Safety) Order 2005 (England & Wales), and The Fire (Scotland) Act 2005, to carry out fire risk

assessments (FRAs) on all places of work. FRAs should be reviewed regularly, even if the site is

unmanned. Therefore, all SP Energy Network substations fall within the requirements of these

regulations.

2.2. SP Energy Networks Policy SP Energy Networks’ (SPEN) Substation Fire Protection Policy (SUB-01-012 Issue 3, 2018) sets out

the overarching guidance that we require to follow to ensure compliance with fire safety legislation

at substations. SUB-01-012 contains the guidelines to minimise the impact from fire in a substation

and is underpinned by the following principles.

• To avoid or reduce as far as is reasonably practicable the incidence of outbreak of fire.

• To avoid or minimise the risk of injury to members of staff/contractors and the public.

• To avoid or minimise the risk of damage to property.

• To minimise the risk of fire spreading to other plant.

• To ensure that the safety of staff/personnel is provided for in the design stage.


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• To minimise the risk of smoke or fire damage to third parties.

SUB-01-02 also sets out SPEN’s strategy for fire risk assessment (FRA) at substations in line with the

regulatory requirement for all workplaces, and the frequency of review. The policy is currently

under review pending completion of the Fire Risk Satellite Survey described in Section 3.3.

2.3. ED1 Activity Within RIIO-ED1 a targeted programme at our highest risk substations has been progressing,

carrying out fire risk assessments and any remedial actions to reduce the risk from fire to an

acceptable level. The targeted substations are predominantly embedded, and basement substations

located within or adjacent to third party buildings. This work is ongoing with an expected increase in

FRA volumes being delivered in the remaining years of the RIIO-ED1 Price Control.

SPEN have an ongoing Fire Risk Satellite Survey project being undertaken by our specialist Fire

Consultants. This project covers all SPEN’s ground mounted substation locations within the SP

Distribution and SP Manweb licence areas. The aim of the project is to develop sufficient data on the

full substation fleet to prioritise the FRA programme and develop the frequency of review based on

the known factors which affect fire risk based on the substation type, design and age.

Figure 1 and Figure 2 below provide a summary view of performance to date within RIIO-ED1,

forecast costs and volumes for the remaining 2 years, and forecast cost and volumes for RIIO-ED2

preferred option for fire protection detailed within this paper.

Figure 1- Summary of SPM ED1 to ED2 CV14 Fire Protection


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Figure 2 - Summary of SPD ED1 to ED2 CV14 Fire Protection

2.4. Common Findings and Typical Interventions for Fire Protection As part of ongoing FRAs at existing substations we have identified some defects (non-compliances)

on a regular basis. These include;

• Lack of compartmentation where fire could spread to other parts of substation or even

third-party buildings;

• Lack of emergency lighting and signage;

• Unknown assets such as CO2 suppression systems (often unclear if live or

decommissioned);

• Poor maintenance of existing fire detection and suppressions systems;

• Lack of fire detection and alarm systems;

• Lack of certification and maintenance of fire doors;

• Lack of compartmentation in cable troughs / trenches.

The type of interventions required at each substation vary dependant on several factors that

determine the fire risk to both the network, people and property. The following interventions may

be carried out where required to reduce the risk from fire as far as reasonably practicable;

• Installation / refurbishment of passive measures;

• Installation of new / upgrade of existing fire detection systems;

• Installation of new / upgrade of existing emergency lighting systems;

• Installation of new / upgrade of existing emergency signage.

All works are carried out to bring substations into compliance with SPEN’s Substation Protection

Fire Policy SUB-01-012 and the relevant legislation.

3. Needs Case Within SPD and SPM licence areas, the electricity network and substations were first constructed in

the 1930s, with major expansion of the network in the 1960s and 1970s and would have complied

with the UK fire legislation at the time.


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SPEN are legally required to comply with the ESQCR and Fire Safety Regulations as set out in

Section 2.1 to carry out a fire risk assessment at each substation, review risk assessment regularly,

and undertake measures to reduce the fire risk from substations as far as reasonably practicable.

Failure to manage fire risk in relation to substation assets could result in exposing the business and

network to several risks including;

• Serious injury or death of personnel, contractors and public;

• damage to or pollution of the surrounding environment;

• impact business continuity (loss of supply);

• impact business reputation

• damage to heritage;

• financial impact;

• operational impact;

• regulatory compliance;

• and legislative compliance.

The findings from the initial targeted FRA programme and satellite survey ongoing in RIIO-ED1 have

identified that an extensive programme for FRAs to cover all substation locations is required to

ensure compliance with legislation. In addition to the FRAs, a programme of clearing actions

identified is required to enable the reduction of risk from fire as far as reasonably practicable.

A review of all grid and primary substations was undertaken by ScottishPower Corporate Fire and

Security and identified the requirement for works to improve fire detection, primarily in our 132kV

and 33kV Grid substations in SPM and SPD respectively. Therefore, a programme of new installation

and upgrade of systems is required to be commenced in RIIO-ED2 to bring substations in line with

policy and improve overall compliance with current regulations.

4. Optioneering Option Status Reason for Rejection

1 Do Nothing Rejected This option would result in SPD and SPM not complying with current fire legislation. Therefore, this option was rejected.

2 Undertake FRAs at all substations, Close out FRA actions, and upgrade of substation fire systems

Adopted Considered as the “do minimum” option to ensure compliance with ESQCR and fire legislations.

Table 1 Investment Options


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5. Detailed Analysis

5.1. Option 2 – Undertake FRAs, Action close-out and Fire Systems Upgrade (Do

minimum option) This option has been presented as the only option available as failure to invest in fire protection

would result in SPEN not complying with current fire safety regulations and ESQCR as summarised

in Section 2.1. This proposal is deemed as the ‘do minimum’ investment to ensure SP Energy

Networks meet our regulatory and legislative requirements.

This proposed strategy has been developed in consultation with ScottishPower Corporate Fire and

Security. The strategy is formed by three main programmes of work as set out below;

1. Fire Risk Assessments to be carried out at all SPD and SPM substation locations in

accordance with the current fire safety regulations. This includes repeat visits in accordance

with guidance for regular review. Frequency of re-visit is dependent on fire risk at each

substation. All FRAs shall be collated and stored in a cloud-based management system with a

user interface to allow efficient management of all data and actions.

2. Programme of work to close out of actions raised during FRAs to ensure fire risk at each

location is reduced as far as reasonably practicable. Programme will be targeted towards

actioning sites with highest risk first.

3. Upgrade of fire detection systems at our higher voltage sites alongside the site security

upgrades proposed within the Site Security EJP (ED2-NLR(A)-SPEN-002-SAF-EJP). This

programme of work consists primarily of installation or upgrade of fire detections systems at

our 132kV Substations in SPM and 33kV Grid Substations in SPD.

5.2. Options Technical Summary Table # Option Technical Summary

2 Undertake FRAs at all

substations, Close out FRA

actions, and upgrade of

substation fire systems

Undertake an extensive programme of FRAs at all our substation

locations. A dedicated programme to close out actions raised during

FRAs will continue from that ongoing in RIIO-ED1. Targeted

investment shall be undertaken at our 132kV & 33kV grid substations

to install or update fire detection systems to meet current policy and

regulations. Table 2 Options Technical Summary

5.3. Options Cost Summary Table The below tables outline the costs associated with option considered.

Option CV Cost Breakdown RIIO ED2

Total (£m)

Option 2

(Adopted)

CV14 Fire Protection (SPM) 7.245

CV14 Fire Protection (SPD) 6.591 Table 3 Cost Summary Table

The costs for the proposed option have been developed in consultation with ScottishPower

Corporate Fire and Security who have engaged with their framework Fire Consultant to develop

unit costs for fire risk assessments and guide unit costs for action close-out at substations. Further


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to this, costs have been developed for fire detection upgrade at our grid and primary substation

locations, where required, based on actual costs from RIIO-ED1 framework and outcome of a site

assessment by SP Corporate Fire and Security. Table 4 - Unit Cost Summary provides a breakdown

of unit costs used to develop the overall plan.

Activity Voltage Proposed Unit

Cost (£)

Fire Risk Assessment – 1st Visit HV £195.76

Fire Risk Assessment – 2nd Visit HV £307.95

Fire Risk Assessment Primary £587.42

Fire Risk Assessment Grid £840.08

Fire Action Close Out (Average) HV £625.00

Fire Action Close Out (Average) Primary £5000.00

Fire Systems New / Upgrade Primary £500

Fire Systems New / Upgrade (Average) Grid (33kV) £14,700.00

Fire Systems New / Upgrade (Average) Grid (132kV) £39,728.26 Table 4 - Unit Cost Summary

In developing the RIIO-ED2 volumes some rates of interventions for certain activities were

calculated based on available corporate data and interpolation from the ongoing fire risk satellite

survey.

It has been proposed that all Grid, Primary and Secondary substations shall receive a fire risk

assessment during the RIIO-ED2 period.

A further 8% of secondaries in both SPD and SPM shall receive a second visit based on the expected

substations into the higher risk categories after the first FRA. Following on from this costs and

volumes have being included to close out actions based on the average at 50% (4% of total) of higher

risk secondary substation sites.

At Primary level costs and volumes based on the average unit cost have been included to close out

FRA actions at 5% of the total number of sites in both SPD and SPM. In addition, costs and volumes

to cover the installation of a single fire detection point aligned with the proposed RIIO-ED2 site

security upgrades at 50% of sites in each licence have been included.

At SPD Grid Substations (33kV) costs and volumes have been included for fire detection system

upgrades aligned with the proposed RIIO-ED2 site security upgrades at 50% of all sites.

At SPM Grid Substations (132kV) costs and volumes have been included for fire detection system

upgrades aligned with the proposed RIIO-ED2 site security upgrades at 33% of sites.

Refer to ED2-NLR(A)-SPEN-002-SAF-EJP - CV14 Site Security EJP for further details on our site

security installations proposed within RIIO-ED2.

6. Deliverability and Risk

6.1. Preferred Option The preferred option for Fire Protection in RIIO-ED2 is Option 2 and shall be to undertake an

extensive programme of Fire Risk Assessments at all our substation locations including repeat visits

for those identified as being high risk. A dedicated programme to close out actions raised during


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FRAs will continue from that ongoing in RIIO-ED1. Targeted investment shall be undertaken at our

132kV & 33kV grid substations to install or update fire detection systems to meet current policy and

regulations.

Where other works including plant refurbishment, retrofit and replacement shall be undertaken

within RIIO-ED2 any fire actions / fire detection works shall be aligned with the proposed works.

6.2. Expenditure & Delivery Profile The total proposed expenditure of £13.820m across RIIO-ED2 is presented in the below table

followed by the delivery profile in volumes. It is proposed that all initial FRAs are completed over

Years 1, 2 & 3 which sees costs and volumes drop significantly in years 4 & 5.

CV Activity 23/24

(£m)

24/25

(£m)

25/26

(£m)

26/27

(£m)

27/28

(£m)

Total

(£m)

SPM CV14 Fire Protection 1.846 1.840 1.860 0.774 0.741 7.060

CV14 Associated Pension Costs 0.051 0.048 0.048 0.020 0.018 0.184

SPD CV14 Fire Protection 1.787 1.787 1.787 0.555 0.555 6.472

CV14 Associated Pension Costs 0.034 0.033 0.033 0.010 0.009 0.119

Table 5 Summary of Expenditure Profile

CV Activity 23/24

(Vol)

24/25

(Vol)

25/26

(Vol)

26/27

(Vol)

27/28

(Vol)

Total

(Vol)

SPM CV14 Fire Protection 5,970 5,969 5,969 906 904 19,718

SPD CV14 Fire Protection 7,124 7,124 7,124 1,033 1,033 23,438

Table 6 - Summary of Delivery Profile

6.3. Risk Within our Fire Protection programme we are proposing to undertake a significant increase in fire

risk assessment in comparison to volumes delivered to date. This programme shall be delivered

using a framework contractor (Specialist Fire Consultant) working for ScottishPower Corporate Fire

and Security department. Our current contractor has proven track record of completing similar

volumes of risk assessments within the utility sector and therefore see no major risks to delivering

the programme.

Delivery of actions resulting from the fire risk assessment process shall be delivered using our

exiting framework contractors. There are no significant risks foreseen including when taking account

of the increase in volumes.

Within RIIO-ED2 we are proposing to install fire detection systems primarily at our 132kV & 33kV

grid substations. This work will be carried out by ScottishPower Corporate Fire and Security using

established framework contractors.

The necessary planning shall be undertaken to ensure delivery of proposed volumes in all

programmes and mitigate any risks.

6.4. SP Manweb Company Specific Factors As a result of the unique interconnected design of our network within SP Manweb license area costs

relating to CV14 – Fire Protection works at our 33kV and HV substations have been accounted for

within our company specific factors. It has been determined that £0.61m of our CV14 – Fire


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Protection and associated volumes, are as a result of the SP Manweb network design. Refer to

Annex 4A.25 - SP Manweb Company Specific Factors for further details.

6.5. Stakeholder Engagement We have undertaken significant stakeholder engagement as part of our plan development and have

sought feedback from a range of stakeholders. Following this engagement, we have developed the

below commitments for RIIO-ED2 which are relevant to this paper:

• Integrated Substation Safety - We will improve fire safety at over 1,000 substations

integrated in third party buildings, through a prioritised, risk-based investment programme

during RIIO-ED2.

o Stakeholder feedback phase 3, S3.9 - 58% of stakeholders strongly agreed and 25%

agreed that this commitment is ambitious enough. Further 17% of stakeholders felt

neutral and none disagreed.

o Customer feedback phase 3. C3.9 – There was 97.6% acceptability for this

commitment.

Below is a summary of key relevant outcomes from stakeholder engagement for this programme of

works. The views of the stakeholders can be explored in more detail in Annex 3.1: Co-creating our

RIIO-ED2 business plan with our stakeholders, and in Annex 4A.18: Legal and Safety (CV14)

Strategy.

Customer Feedback

• “Network resilience, not having a power cut” was ranked the second most important

priority by both domestic and commercial customers.

Investing in network asset risk, resilience and reliability is key to reducing the likelihood of

customers experiencing an interruption. This programme of works supports this by maintaining our

assets linked to fire protection which in turn protects our network assets from external fire risk.

Manufacturers

• Manufacturers provided the following views:

o Modernisation is essential to ensuring network resilience;

o Given customers’ increasing reliance on electricity, it is important to have a focus on

reducing fault rates as well as reducing the extent of impact of faults on customers;

o Increasing grid dynamic response capabilities has allowed many utilities worldwide to

improve existing infrastructure performance and quality of supply.

This programme of works will improve network resilience / reduce the impact of faults / improve

network dynamic operability by keeping our civil assets and buildings in good condition which in turn

protect, support and extend the life of our electrical assets.

Energy Consultants

• Energy consultants agreed that SP Energy Networks should continue to utilise proven

interventions on network assets, and there has been clear support for SP Energy Networks

to continue investing in network resilience [to reduce faults].


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This EJP sets out a range of proven interventions including fire containment and detection. SP Energy

Networks have also sought to adopt proven innovative solutions to provide more cost-efficient

delivery.

Local Governments

• Local governments agreed with SP Energy Networks’ approach of managing risk by focusing

on replacing and modernising the poorest condition & highest risk assets.

This paper sets out how SP Energy Networks are intervening by reducing fire risk at our highest

priority assets.

7. Future Pathways – Net Zero

7.1. Primary Economic Driver The key driver for this proposal is to improve the fire safety of our network in compliance with the

relevant legislations and regulations.

7.2. Pathways and End Points The fire risk management of our substations is a necessary requirement to maintain the safety,

resilience and reliability of the distribution network under all decarbonisation pathways. As society

continues to decarbonise and the role of the network becomes more critical to customers, it is

increasingly critical that fire safety of our network is maintained and improved.

7.3. Asset Stranding Risks There is not considered to be any asset stranding risk associated with this programme. All Primary

and Grid sites are intended to be occupied for the forecast asset life.

7.4. Losses / Sensitivity to Carbon Prices It has not been necessary to consider losses of carbon pricing as part of this investment programme.

7.5. Future Asset Utilisation This is not applicable to substation fire protection.

7.6. Whole Systems Benefits Whole system solutions have been considered as part of this proposal. No alternatives have been

identified that could be provided through a whole systems solution. The completion of this scheme

will maintain the integrity of the distribution network and its enduring ability to facilitate wider

whole system benefits.

7.7. Environment and Sustainability

Operational and embodied carbon emissions The Fire Protection programme has the potential to result in embodied carbon from the delivery of

interventions required. There is unlikely to be any impact on SPEN’s Business Carbon Footprint

(BCF).


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Supply chain sustainability For us to take full account of the sustainability impacts associated of the Fire Protection programme,

we need access to reliable data from our suppliers. The need for carbon and other sustainability

credentials to be provided now forms part of our wider sustainable procurement policy.

Resource use and waste Potential interventions may result in the consumption of resources and the generation of waste

materials.

Where waste is produced it will be managed in accordance with the waste hierarchy which ranks

waste management options according to what is best for the environment. The waste hierarchy gives

top priority to preventing waste in the first instance, then preparing for re-use, recycling, recovery,

and last of all disposal (e.g. landfill).

Biodiversity/ natural capital Due to the nature of the proposed interventions, it is unlikely that there will be any impact in

relation to biodiversity and natural capital.

Preventing pollution Due to the nature of the proposed interventions, it is unlikely that there will be any impact in

relation to pollution.

Visual amenity Due to the nature of the proposed interventions, it is unlikely that there will be any impact in

relation to visual amenity.

Climate change resilience Due to the nature of the proposed interventions, it is unlikely that there will be any impacts in

relation to future changes in climate. There may in fact be some benefit in the measures proposed as

these may reduce fire risk from overheating as a result of increased temperatures caused by climate

change.

8. Conclusion SPD and SPM propose to undertake a comprehensive programme of fire risk assessments, actions

close out, and fire systems installation and upgrade to ensure the risk from fire to the network,

persons and property is reduced as far as reasonably practicable.

Predicted costs: £ 13.836m (£7.245m – SPM, £6.591m - SPD)

• Timing of investment: 2023 – 2028

• Volumes: 43,156 (19,718 No SPM, 23,438 No SPD)

legal and safety – fire protection

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