Sub 01 012

SUBSTATION FIRE PROTECTION POLICY SUB-01-012
Issue No. 3
1. SCOPE
This document defines the policy for the protection of persons and property against fire in all SP
Energy Networks (SPEN) Substations.
2. ISSUE RECORD
This is a Controlled document. The current version of Controlled and Reference documents is held
on the Energy Networks Document Library.
It is your responsibility to ensure you work to the current version.
Issue Date Issue No. Author Amendment Details

September 2013 1 John Russell Initial issue:
October 2015 2 Lee Speakman Updates including revision to fire
resistance, fire detection and fire risk
assessment requirements.
October 2018 3 Mark Stewart Minor wording only
3. ISSUE AUTHORITY
Author Owner Issue Authority

Mark Stewart David Neilson Jim McOmish
Civil Asset Manager SPD Distribution Network Head of Distribution Networks
Manager
Malcolm Bebbington
SPM Distribution Network
Manager
Date: ...2/10/18......................
4. REVIEW
This is a Controlled document and shall be reviewed as dictated by business / legislative change but
at a period of no greater than 3 years from the last issue date.
5. DISTRIBUTION
This document is not part of a Manual maintained by Document Control and does not have a
maintained distribution list.
© SP Power Systems Limited Page 1 of 21

Issue No. 3
6. CONTENTS
1. SCOPE ....................................................................................................................................... 1
2. ISSUE RECORD ........................................................................................................................ 1
3. ISSUE AUTHORITY .................................................................................................................. 1
4. REVIEW ..................................................................................................................................... 1
5. DISTRIBUTION.......................................................................................................................... 1
6. CONTENTS ............................................................................................................................... 2
7. GUIDANCE DOCUMENTS ........................................................................................................ 4
8. RELATED DOCUMENTS .......................................................................................................... 4
9. DEFINITIONS ............................................................................................................................ 4
10. INTRODUCTION........................................................................................................................ 5
10.1 Risks Arising from Fire .............................................................................................. 6
11. CIVIL/BUILDING REQUIREMENTS ......................................................................................... 7
11.1 Access/Egress – New Substations ........................................................................... 7
11.2 Signage & Emergency Lighting ................................................................................. 7
11.2.1 Escape distances .......................................................................................................... 8
11.2.2 Special Provisions for Switchrooms .............................................................................. 8
11.2.3 Special Provisions for Indoor Secondary Substations .................................................. 8
11.3 Segregation/Separation .............................................................................................. 8
11.3.1 General ......................................................................................................................... 8
11.3.2 Containerised Switchgear ............................................................................................. 9
11.3.3 Indoor Transformers (Freestanding & Embedded Substations) ................................... 9
11.3.4 Outdoor Transformers ................................................................................................... 9
11.4 Distance to Public Areas .......................................................................................... 10
11.5 Cables (Cableways/Trenches) ................................................................................. 10
11.6 Doors .......................................................................................................................... 10
11.7 Fire Barriers (Enclosures, Firewalls, etc.) .............................................................. 10
11.8 Fire Detection and Warning Systems ..................................................................... 11
11.9 Safety Protection....................................................................................................... 11
11.10 Protection of Assets ............................................................................................. 11
11.11 Active Fire Suppression Systems ....................................................................... 11
11.11.1 Life protection ........................................................................................................ 11
11.11.2 Protection of Assets .............................................................................................. 11
12. PROVISION OF FIRE PROTECTION MEASURES ................................................................ 12
13. PROVISION OF PORTABLE EXTINGUISHERS .................................................................... 12
14. SPECIFIC GUIDANCE FOR SUBSTATIONS LOCATED IN CUSTOMERS' BUILDINGS .... 12
14.1 General ....................................................................................................................... 12
14.2 Special provisions for new and existing sites ....................................................... 12
14.3 Transformers ............................................................................................................. 13
14.4 Cables (Cableways/Trenches) ................................................................................. 13

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14.5 Building Shell ............................................................................................................ 13

14.6 Fire Risk Survey ........................................................................................................ 14
14.7 Categorising Risk...................................................................................................... 14
15. FIRE RISK SURVEY MITIGATION MEASURES .................................................................... 14
15.1 High Risk Locations.................................................................................................. 14
15.2 Higher than Normal Risk .......................................................................................... 15
15.3 Protection Measures ................................................................................................. 15
16. FIRE RISK ASSESSMENT...................................................................................................... 16
16.1 Overview .................................................................................................................... 16
Output...................................................................................................................................... 16
17. APPENDIX 1 ............................................................................................................................ 17
18. APPENDIX 2 ............................................................................................................................ 19
18.1 Further Guidance on Output of Fire Risk Assessment (PAS79) .......................... 19
18.1.1 Overall Classification................................................................................................... 19
18.1.2 Likelihood of Fire ......................................................................................................... 20
18.1.3 Consequence of fire .................................................................................................... 21

Issue No. 3
7. GUIDANCE DOCUMENTS
BSEN 61396-1 Power installations exceeding 1kV a.c. – Part 1: Common rules
Build Regs 2000 Part B of Building Regulations (Fire Safety)
8. RELATED DOCUMENTS
SP Energy Networks Documents
SUB-03-017 General Specification for the Civil Engineering and Building Design and
Construction of Secondary Substations
Construction of Primary Substations
Construction of 132kV Grid Substations
Other Documents
BS 5499 Fire Safety Signage
BS 5266 Fire Emergency Escape Lighting
BS 5839 Fire Detection & Alarm Systems for Buildings
9. DEFINITIONS
For the purpose of this document, the following definitions apply:

Issue No. 3
Active Fire Protection Manual or Automatic Fire Fighting Equipment such as extinguishers,
foam systems, gaseous agents and automatic fire/smoke detection.
Basement Substation A substation in the basement of a third party building.
Confined Space Defined by Section 1(2) of the Confined Spaces Regulations 1997.
Embedded Substation A substation incorporated within a third party building, with either
internal or external access.
Escape Route The area between items of plant and the vicinity of the exit door.
High Fire Spread Risk A Substation at which a fire occurring internally may spread to
adjoining property, or cause damage by smoke contamination
(Basement/Embedded Substation).
Intumescent Intumescent materials are substances that expand when exposed to

heat, increasing in volume to provide a barrier to prevent spread of
fire.
Passive Fire Protection Protection integrated into the core of the building to prevent fire
spread through doors, walls and floors.
Reasonable Place of Safety A protected stairway enclosure (a storey exit), a separate fire
compartment where there is a final exit to a total place of safety; or
the nearest available final exit.
Relevant Authority Defined by The Regulatory Reform (Fire Safety) Order 2005
(England & Wales) and the Fire (Scotland) Act 2005.
Relevant Persons Defined by The Regulatory Reform (Fire Safety) Order 2005
(England & Wales) and the Fire (Scotland) Act 2005.
Underground Substation A substation below ground level, not within a building.
10. INTRODUCTION
The Electricity Safety, Quality and Continuity Regulations 2002 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)).

Issue No. 3
The Regulatory Reform (Fire Safety) Order 2005 (England & Wales), and The Fire (Scotland) Act
2005 states "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".
This document sets out the overarching policy that SP Energy Networks will follow in compliance with
fire safety legislation at substations. IEC 61936-1 will provide guidance and the policy 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.
 To minimise the risk of smoke or fire damage to third parties.
This policy sets down the guidelines to be used to both limit the risk of fire arising, and in the
application of protective measures to minimise the impact from fire in substations. SP Energy
Networks generic civil engineering and building design and construction specifications give further
detail.
This policy applies to all existing sites, new sites, and sites where replacements works are being
carried out, except where specifically excluded.
Where appropriate, communications shall be established with the Relevant Authority in order to co-
ordinate measures to mitigate the risk from fire.
10.1 Risks Arising from Fire
All electrical equipment in operational sites is periodically maintained and inspected in accordance
with SP Energy Networks policies and hence the risk of fire from equipment malfunction is minimal. A
fire within a substation or operational site may develop in a number of ways:
 Act of arson or wilful interference from third parties.
 Interference from wildlife, flora or fauna.
 Fault arising from poor condition or faulty electrical equipment such as transformers,
switchgear, power cables, portable equipment and LVAC systems such as lighting or heating.
 Spread of fire to substation through convection, conduction, radiation or direct contact with
fire from a neighbouring property, or within the same building in the case of embedded
substations.
 From work related activities from ‘hot work’ within the substation such as use of gas torch to
break down cable boxes or;
 From an act of negligence such as an inappropriately discarded cigarette or from cooking in

the case of substations with mess facilities.

Issue No. 3
A fire may affect the company and third parties in a number of ways:
 Health & Safety: Whilst most operational sites are unmanned for a majority of the time a fire
could cause serious injury or loss of life to staff or members of the public. This level of risk is
increased in embedded substations, which may share space with office blocks, shops and
buildings designed to provide sleeping accommodation such as hotels and hostels.
 Property: There is a risk fire and smoke could spread to adjacent properties or within the
building for embedded substations.
 Performance: Whilst the network is designed to minimise the impact of a single loss of
transformer or bus section, however if the fire is allowed to spread to the adjacent apparatus,
significant CI & CML penalties may be incurred. In addition significant time scale required to
repair a fire damaged substation could cause significant operational issues and intolerable
network risks until work is completed.
 Environment: A fire could cause the significant release of substances such as insulating
mineral oil and SF6 (sulphur hexafluoride, a potent greenhouse gas) into the environment.
Whilst most Primary & Grid transformers are bunded to contain lost oil, oil filled switchgear
and 11kV transformers typically not. This risk is increased where a loss of insulating oil could
affect a nearby watercourse or wildlife.
 Reputation: SP Energy Networks operates a number of substations within listed buildings; a

fire could result in the irreplaceable loss of the building.
11. CIVIL/BUILDING REQUIREMENTS
11.1 Access/Egress – New Substations
No new substations shall be constructed in basement locations, or so embedded within customer’s

property that access/egress cannot be achieved by way of the public highway
The preferred and optimum location for a substation is freestanding, with access at ground level
from/off the public highway.
Access and egress to and from a substation may be subject to local building regulations, but shall
provide staff with a safe means of escape.
Entry shall be by personnel door only – trap doors, manholes and/or ladders are not acceptable as a
means of access/egress.
The escape route shall have minimum clearance width of 900mm, and the minimum width and height
of doors which may form part of this escape route shall be not less than 750mm and 2000mm
respectively.
A “Panic Bar” or similar exit mechanism shall be fitted to all external emergency exit doors, which
shall open in the direction of emergency escape.
11.2 Signage & Emergency Lighting
Exit Signage and Emergency lighting shall be installed in accordance with the below table.

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Substation Type Emergency Signage / Lighting

Secondary – Freestanding None – One door to exit visible at all times
Secondary – Embedded with Access Internally Self-contained Emergency Lighting and Luminous Signage
Secondary – Embedded with Direct Access from ground level only None – One door to exit visible at all times
Primaries – Luminous Signage
Primary/Grid/Transmission – Freestanding Grid/Transmission: Self-contained Emergency Lighting and Luminous
Signage
Primary/Grid/Transmission – Embedded
: Self-contained Emergency Lighting and Luminous Signage
Substations where staff are likely to be present for more than 30
Self-contained Emergency Lighting and Luminous Signage
days annually apart from major plant works
Exit Signage shall be installed in accordance with BS5499 and Emergency Lighting in accordance
with BS5266.
11.2.1 Escape distances
Emergency escape routes shall not exceed distances set in Part B of the Building Regulations 2000
(section 3, horizontal escape, section 4 vertical escape). Maximum travel distances to a reasonable
place of safety are outlined in the table below:-
Room Type Containing Building Regulations Purpose Travel Distance - One Direction Travel Distance - One or
Group Only (m) More Direction (m)
Oil filled plant/ Purpose Group 7 – Place of
9 18
generator/battery room special fire hazard
Purpose Group 6 – Industrial,
Other rooms 25 45
normal risk
11.2.2 Special Provisions for Switchrooms
In accordance with established practices, rooms enclosing switchboards in excess of 6m in length

shall have a minimum of two exit doors, opening outwards, on or at opposite ends of the switch room.
If the switchboard/room is on high level; a staircase/exit on or at opposite ends of switch room, shall
be available.
11.2.3 Special Provisions for Indoor Secondary Substations
In accordance with established practices, where any internal dimension exceeds 6m, a second means
of escape will be provided for secondary substations.
11.3 Segregation/Separation
11.3.1 General
Unless otherwise stated in section 11.3.3 below, substation buildings shall be fully compartmented
construction as per Part B of building regulations with minimum REI60 construction where R is the
load bearing capacity, E is the fire integrity and I is the thermal insulation and 60 is the time in minutes
each element is required to withstand.
This includes below floor trenches and ducts passing between rooms, such that spread of fire to other
internal areas shall not occur for a period commensurate with the compartment fire resistance
requirements.
In exceptional circumstances this requirement can be relaxed on a case by case basis. For example
non-load bearing escape routes can be reduced to 30 minute construction if the load bearing structure
of the building remains at 60 minute construction.

Issue No. 3
Transformers located indoors operating at a primary voltage of 33kV and above shall be segregated
from all other areas of the substation e.g. switchroom, protection systems, telecommunications and
batteries.
It is permissible for indoor secondary distribution substations to have transformers and switchgear
located in the same fire compartment. For higher voltage substations the equipment should be
separated by a fire resistant wall.
11.3.2 Containerised Switchgear
Typically containerised substations house SF6 switchgear only, along with ancillary panels. The
container is not considered to pose a significant fire risk provided it is not located within 1 metre from
the substation site boundary.
The container should have a minimum fire rating of 60 minutes, and any fire rating requirement
greater than 60 minutes shall be on a risk basis.
11.3.3 Indoor Transformers (Freestanding & Embedded Substations)
Transformers shall not be embedded within a customer building unless there is no other reasonably
practicable detached freestanding alternative available.
Where it is necessary to embed transformers within a customer building or SP Energy Networks

owned substation, these shall be located within rooms that provide a fire resistance period as per
table 1.
The management of oil containment will require to be carefully considered when housing transformers
indoors, and the method adopted will largely depend on the constraints of the site.
Note where one or more transformers are installed indoors the segregation distances between
transformers stated in section 11.3.4 apply. Where separation distances cannot be met installation of
a fire barrier between assets shall be considered.
11kV Mineral Oil

Transformer
11kV Midel 33kV Mineral Oil >= 132kV Mineral Oil
Plant type
Transformer Transformer Transformer
33kV Midel
Transformer
Existing Build
Enclosure/Compartment 60 60 120 120
Fire Resistance (REI)
New Build Sites
Enclosure/Compartment 120 120 240 240
Fire Resistance (REI)
TABLE 1
11.3.4 Outdoor Transformers
Transformers ( ≥33kV ) located outdoors, shall be located within a concrete or other Energy Networks
approved oil containment bund and, where no space constraints apply, shall be separated from other
oil containing plant, buildings, containerised switchrooms and public areas.
The minimum segregation distances required for oil filled transformers to other transformers and third
party buildings are illustrated in the table below.
Transformer Liquid Volume Typical Transformer Clearance from bund to other

Type (litres) Type transformer or non- Clearance to combustible2
combustible building1 surface building1 surface (m)
(m)2
Oil Insulated < 1000 Secondary 1.2 3
Transformers 1000 - < 2000 Secondary 3 7.5

Issue No. 3
(O Class e.g. 2000 - < 20000 Primary 5 10

Mineral Oil) 20000 - < 45000 Grid 10 20
> 45000 Grid 15 30
Transformer Type Clearance to building surfaces or adjacent transformers

Less flammable liquid Insulated Horizontal (m) Vertical (m)
Transformers (K class e.g. MIDELⓇ 0.9
1.5
7131) – with enhanced protection1
1
Distance to building includes SP Energy Networks substation buildings and third party buildings.
2
A combustible building is defined as one that is made predominately of a combustible material such as timber.
3
It is noted particularly in typical primary substation the distances to SP Energy Networks operated buildings are difficult to
achieve due to space constraints. It is also good operational practice to have an access door to the compound from the
substation building. Where this is required a 60 minute fire door can be installed on a risk assessed basis.
TABLE 2
Where it is not possible to allow for adequate clearance to other plant and third party buildings as
indicated in the table above, a 240 minute fire-resistant barrier (enclosure or separating wall) shall be
provided.
Where the fire risk is significantly high, for example next to a petrol filling station, hotel or critical
infrastructure etc. the distances quoted above may be required to be increased or a fire
wall/enclosure should be considered.
11.4 Distance to Public Areas
Whilst there is no minimum distance to public spaces for transformer and switchgear, a fire risk survey
for the site should be calculated and mitigation measures carried out in accordance with section 15 of
this document. Such mitigation measures may include the installation of a fire wall or enclosure.
11.5 Cables (Cableways/Trenches)
Cables contained in trenches or ducts within a building may assist the spread of smoke and fire and
should be effectively sealed to prevent the spread to adjoining areas.
In all cases, trenches containing power cables should be filled with sand, and compacted and finished
with a sand/cement screed of minimum 50mm thickness.
11.6 Doors
All fire resisting doors, their frames and fittings should have a fire rating commensurate with the
associated rating for the room to which they provide access, with a minimum rating of 60 minutes.
The width and height of doors which may be used as a means of escape shall be not less than
750mm and 2000mm respectively.
Where installed, emergency exit/panic bar doors shall open outwards and lead to a place of safety.
11.7 Fire Barriers (Enclosures, Firewalls, etc.)
Where required, fire barriers shall provide 240 minute fire resistance.
Fire barrier walls shall extend for a distance of at least 2m on either side of oil containing parts or
explosion vents, or shall alternatively incorporate appropriately designed return walls.
Fire barrier walls shall extend for a distance of at least 1m above oil containing parts or explosion
vents, however, electrical clearances shall not be prejudiced.

Issue No. 3
11.8 Fire Detection and Warning Systems
11.9 Safety Protection
The main purpose of Automatic Fire Detection and Alarm systems is to provide sufficient early
warning to enable staff to egress the building to a place of safely before exit routes become filled with
combustion products such as noxious gas and smoke.
In complex buildings such as large office blocks and warehouses a fire could develop in another area
which may remain undetected by staff until the fire is sufficiently well developed to compromise
escape routes. In such cases automatic fire detection systems are installed in rooms and escape
routes (typically corridors). This shall provide sufficient early warning to enable staff to egress before
smoke fills them and renders them unusable.
Freestanding Transmission/Grid/Primary/Secondary substations are considered simple buildings such

that a fire would be easily recognisable in the early stages of development and a direct egress path to
a place of safety could be taken. In addition these sites are typically unmanned therefore an
automatic fire detection and/or manual alarm system is not typically required. Upon discovery of
a fire staff can raise the alarm by shouting “FIRE FIRE”.
Substation Type Fire Detection Requirements

Secondary – Freestanding None
Secondary – Embedded with Access Internally Extend customers system inside substation
Extend customers system inside substation subject joint agreement
Secondary – Embedded with Direct Access from ground level only
with customer
Primary/Grid/Tran – Freestanding None
Standalone system – linked to customers
Primary/Grid/Tran – Embedded
Level as required by FRA
Substations where staff are likely to be present for more than 30
Standalone system – Level as required by FRA
days annually apart from major plant works
Fire Detection & Alarm Systems shall be installed in accordance with the requirements of BS5839
To ensure the specification meets requirements, no fire detection or warning system shall be installed
into substations without prior approval of Corporate Security.
11.10 Protection of Assets
For strategic purposes at network critical sites and/or substations contained in remote or listed
buildings, fire detection systems may provide early indication to the control room that the site is at
risk. Resources could be dispatched earlier to deal with the fire, limiting the damage. Such sites will
be identified by the asset manager through the use of an appropriate risk assessment methodology.
11.11 Active Fire Suppression Systems
11.11.1 Life protection
Active fire suppression systems are not the preferred method of protecting life; this should generally
be achieved with fire detection and passive control measures. They may however be used to mitigate
in such cases where adequate compartmentalisation or segregation cannot be achieved.
11.11.2 Protection of Assets
Active fire protection systems may be installed in certain circumstances to protect assets and/or
buildings. The preferred method of protection assets is through physical segregation and installation
of fire barriers. Additional investment can be justified through cost benefit analysis.

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12. PROVISION OF FIRE PROTECTION MEASURES
A site specific SP Energy Networks Fire Risk Survey (Appendix 1) shall be completed for all
substation sites, taking into account the substation location and possible impact on the surroundings
of a fire.
Subject to segregation requirements above and the result of the Fire Risk Survey, where it is
reasonably practicable, SP Energy Networks will install passive and/or active fire protection
measures.
The site risk will be re-assessed periodically or following material changes to the substation plant or
surrounding area.
13. PROVISION OF PORTABLE EXTINGUISHERS
Substations that are permanently manned shall have fixed firefighting points installed.
Fixed firefighting points shall not be installed in unmanned substations.
Personnel working in unmanned substations shall ensure that they have a suitable portable
extinguisher available in the event fire starts as a result of their work activities.
14. SPECIFIC GUIDANCE FOR SUBSTATIONS LOCATED IN CUSTOMERS' BUILDINGS
14.1 General
The preferred and optimum location for a substation is freestanding with access at ground level from
the public highway, and every effort shall be made to comply with this requirement in order to design
out risk with respect to disruptive failure and associated fire/fire spread.
No new substations shall be constructed in basement locations, or so embedded within customer’s

property that access/egress cannot be achieved by way of the public highway.
Although substation plant is extremely reliable and the probability of a disruptive failure is very low, a
fireball may be produced when this condition occurs and considerable heat and smoke can be
generated as a result. In the limited instances where there is a compelling reason that it is not
practicable to provide a free-standing building, location of a non-standard substation that is integral
within other buildings may be necessary and this is acceptable in principle to SP Energy Networks.
Designers shall ensure that the nature of the design and construction is such that progressive
collapse or fire spread does not ensue in the event of a disruptive plant failure.
14.2 Special provisions for new and existing sites
Although there are no specific statutory requirements for fire detection and suppression systems to be
installed in substations, when the substation is embedded within, or adjoined to a customer’s building,
it shall be categorised as a “potential” High Fire Spread Risk.
In all High Fire Spread Risk locations identified during the Fire Risk Survey, all necessary measures
to limit the fire risk to an acceptable level shall be completed.
For new/proposed sites a Fire Risk Survey shall be completed prior to commencement of works.
SP Energy Networks will co-operate and co-ordinate with the customer/building owner to agree each
party's responsibility for deploying Fire Protection measures.
In all embedded substations the customer/building owner shall be responsible for the installation and
maintenance of any fire extinguishing/detection equipment that they request to be installed within the

Issue No. 3
substation where SP Energy Networks do not consider it to be reasonably practicable. This obligation
shall be recorded in a site specific Fire Safety Risk Assessment.
14.3 Transformers
Transformers are a potentially significant source of combustible material.
An option to minimise the associated risks of secondary oil filled power transformers within existing
embedded basement substations would be either to replace the existing transformer with a less
flammable insulating fluid unit, e.g. MidelⓇ (Synthetic Ester Insulant), or to retro-fill the existing
transformer with less flammable insulating fluid, replacing the conventional insulating (mineral) oil.
(MidelⓇ is more difficult to ignite than mineral oil; produces only approximately 30% smoke density
and all combustion products are non-toxic)
For high loaded substations that have ventilation problems (leading to high ambient temperatures), a
solution may be to have the existing transformers replaced with extra-low-loss units.
14.4 Cables (Cableways/Trenches)
In order to minimise the effects of fire within a customer owned/publicly occupied building (High Fire
Spread Risk), low smoke zero halogen (LSOH) sheathed cables shall be used in all new “embedded”
substations.
In all cases, trenches containing power cables should be filled with sand, and compacted and finished
with a sand/cement screed of minimum 50mm thickness.
14.5 Building Shell
The substation compartment (including doors) shall have a minimum 60 minute fire resistance, this
may require to be increased depending upon the equipment type.
The substation walls, floor and roof shall be constructed of non-combustible materials and in such a
manner as to prevent the ingress of water, sealed against the entry of gas and the egress of oil.
Drainage pipes, access covers, or other services should not be within, or routed through the
substation.
Cables contained in trenches or ducts and mutual walls should be sealed, and ventilation
arrangements shall not allow the passage of smoke and fumes to adjoining premises.
Should wall vents to adjoining properties exist these should be sealed, however, if deemed
necessary, they shall be fitted with an Intumescent Fire Block or similar device that will operate in the
event of fire and ensure there is minimal spread of smoke and fumes. The vent shall have a fire rating
consistent with the requirements of the compartment.
Where smoke damage is anticipated to be considerably high or where the substation is located on a
major egress route a fast acting electrically activated smoke damper shall be fitted instead of a slower
acting intumescent device.
(Fire ventilators permit a free air flow and can be fitted within fire doors and walls whilst maintaining
the integrity of the fire compartment).

Issue No. 3
14.6 Fire Risk Survey
An SP Energy Networks Fire Risk Survey (Appendix 1) shall be completed for every substation site.
This primarily determines the level of risk to public, staff and third party property from the effects of
fire and does not consider internal asset and network risk.
The purpose of this assessment is to enable the effective prioritisation of future fire risk reduction
programmes and serve as a guide to the type of mitigation measures that are typically required for
existing and new sites.
This process is not to be confused with a Fire Risk Assessment which is required at all sites where
more than five people are likely to be present at any one time e.g. embedded substations.
14.7 Categorising Risk
On completion of the SP Energy Networks Fire Risk Survey, every substation shall be scored in each
of the following four category areas.
1. The likelihood of members of the public being in the vicinity/close proximity.

2. The substation type and location with respect to property types and public areas.
3. The transformer, plant, and insulant type.
4. The access/egress arrangements for members of staff/contractors.
The sum of the scores from each category, shall determine the overall site risk:
High: Where a score of 100 or greater is achieved, the substation will be deemed
High Risk and remedial fire mitigation measures shall be instigated to reduce
the risk of fire to an acceptable level.
Higher than Normal: A score above 75 and below 100 will place the substation in a Higher than
Normal Risk category, and remedial measures shall be implemented to
reduce the risk where reasonably practicable.
Normal: A score above 50 and up to 75 will place the substation in a Normal Risk
category and no further fire risk mitigation measures beyond adequate
compartmentalisation for embedded substation is required.
Lower than Normal: Where a score of 50 or less is achieved, the substation shall be deemed a
Lower than Normal risk category and no further fire mitigation measures
beyond adequate compartmentalisation for embedded substation is required.
15. FIRE RISK SURVEY MITIGATION MEASURES
SP Energy Networks shall reduce the site risk to the lowest level reasonably practicable. Normal
Risk shall be the highest acceptable level. The Fire Risk Survey shall take into account its location
and the possible impact on the surroundings of a fire in the substation.
In new sites, where reasonably practicable, “Preventative” measures shall be “built-in” at the design
stage and inspection, maintenance policies and procedures shall ensure ongoing compliance.
15.1 High Risk Locations
The decision on what fire mitigation measures are to be installed in any substation sites that are
deemed to be High Risk will depend on the specific risk defined for that substation.
High risk locations generally will be basement or embedded substations i.e. High Fire Spread Risk.

Issue No. 3
In sites where a High Risk has been identified, the construction/installation of the following Passive
Fire Protection measures shall be considered in the first instance:
i. Retro-filling or replacement of existing oil filled transformers with a synthetic “Ester” insulant,
the provision of transformer oil containment, and/or the replacement of oil filled switchgear
with gas or vacuum equipment.
ii. Replacement of existing cables oil of low smoke zero halogen (LSOH) cables in embedded
locations.
iii. The fitting of fire doors/seals, sealing of cable-trenches and the installation of intumescent
vents (or similar) shall be installed to limit the spread of fire or smoke.
iv. The installation of Fire/Smoke detection devices in the substation incorporated, in conjunction
with the building owner, into the building fire protection scheme.
In certain situations the provision of Active Fire Protection measures may be appropriate. A fire
extinguishing system of either inert gas, e.g. Inergen, or water deluge system may be required where
the Fire Risk Survey has identified a requirement, and Passive Fire Protection measures alone are
not sufficient to mitigate the fire risk to an acceptable level.
In new sites, the customer/building owner may request that some form of active fire extinguishing
system, or automatic fire/smoke detection device be installed within the substation and incorporated
into the building fire protection scheme. In this case, the customer/building owner will be responsible
for the installation and maintenance of any fire extinguishing/detection equipment that they have
requested be installed.
15.2 Higher than Normal Risk
The installation of effective Passive Fire Protection measures shall, where reasonably practicable, be
adopted in all Higher than Normal Risk locations, this includes:
i. Retro-fitting fire barrier enclosures or screen walls to transformers.
ii. Installing below-ground oil containment equipment to transformers at new sites e.g.
‘moated’ type bund or catchment tanks.
iii. Retro-filling or replacement of existing oil filled transformers with a synthetic “Ester”
insulant.
15.3 Protection Measures
The application of both Passive and Active Fire Protection measures will have a positive effect on
reducing the risk assessment score of substations.
For control measures to be effective they must be complete, e.g. a fire door on its own would not
effectively serve its purpose of containment if vents or unsealed cable ducts allowed the spread of
smoke and fire to adjacent rooms.
The table below gives examples of how, the application of effective control measures impact on the
site Fire Risk Survey score, to determine the overall “Substation Fire Risk” value.
Type Description Score

Embedded or Attached Intumescent door seals and vents with sealed cable -30
trenches/entries (Effective Passive Measures in Place)
Freestanding Fire barrier enclosures/screen walls installed -20
Freestanding Below ground oil containment to transformers -20

Issue No. 3
Embedded Active Fire Extinguishing System Installed -40

Embedded Automatic Fire/Smoke Detection in Place -30
Attached Active Fire Extinguishing System Installed -20
Attached Automatic Fire/Smoke Detection in Place -10
Freestanding Active Fire Extinguishing System Installed -10
16. FIRE RISK ASSESSMENT
16.1 Overview
Fire Risk Assessment in terms of the Regulatory Reform (Fire Safety) Order 2005 (England & Wales)
and the Fire (Scotland) Act 2005 (See Section 15) shall be completed for all freestanding and shared
sites where 5 or more people are likely to be present within any part of the building at one time.
This will be identified through routine inspections and recorded in the asset register. The fire risk
assessment shall be conducted by a suitably trained, knowledgeable and competent person
appointed by SP Energy Networks. It shall be carried out in accordance with PAS79 methodology.
By the nature of this statement all embedded and attached substations shall require a Fire Risk
Assessment. A schedule of FRA dates and findings shall be made available to corporate security for
auditing purposes.
Fire risk assessments shall be reviewed every five years or when there is a significant change of use
or layout of the building, or there has been an incident on site. For embedded substations such
changes will be notified by the customer or substation inspector.
The basic fire safety features will be routinely monitored by substation inspectors at not less than
annually in accordance with ASSET-01-021.
Substation Type Fire Risk Assessment Frequency

Requirements
None – Routine inspection / maintenance to N/A
Secondary – Freestanding
minimise fire likelihood risk
Secondary – Embedded with Access Internally PAS79 5 years
Secondary – Embedded with Direct Access from ground 5 years

PAS79
level only
None – Routine inspection / maintenance to N/A
Primary/Grid/Transmission – Freestanding
minimise fire likelihood risk
Primary/Grid/Transmission – Embedded 5 Years
PAS79
Substations where staff are likely to be present for more 5 Years
PAS79
than 30 days annually apart from major plant works
Output
The fire risk assessment will provide an overall classification relating to the level of risk imposed on
the site. This is based on a matrix which defines the likelihood of a fire occurring and the expected
consequences should a fire occur.
In addition the fire risk assessment may stipulate additional fire safety precautions to reduce the risk
to life in case of fire. For example, measures to reduce the risk and spread of fire, means of escape,
fire-fighting equipment, fire detection and warning, instruction and training. SP Energy Networks must
implement such actions within the timescales outlined in order to comply with the requirements of fire
safety legislation.
Further guidance on the risk assessment process can be found in the appendix 2 of this document.

Issue No. 3
17. APPENDIX 1
SP Energy Networks Fire Risk Survey
Select the most appropriate description from each of the 4 Categories (1 selection per category) to derive
substation risk.
Site Information Zone Score

Weighting
Category 1 – Public
Public continually within *close proximity of plant/transformers. 40
Public regularly within *close proximity of plant/transformers. 30
Public occasionally within *close proximity of plant/transformers. 20
Public not within *close proximity of plant/transformers. 0
*Close Proximity of Plant/Transformers = Grid s/stn 20 m, Primary s/stn10m & Secondary s/stn 5m.

Issue No. 3
Category 2 – Property/Location
Embedded Substation
High Occupancy Customer Building.

Embedded S/Stn – entry from within third party building (i.e. Basement) 40
Embedded S/Stn – entry external to building 40
Low Occupancy Customer Building.

Embedded S/Stn – entry from within third party building (i.e. Basement) 35
Embedded S/Stn – entry external to building 35
Outdoor Transformer/Plant
Dense Residential/ High Occupancy Retail/ Industrial or Commercial Properties.
Grid S/Stn – outdoor Transformers/Plant < 10 metres to public area 30

Primary S/Stn – outdoor Transformers/Plant < 5 metres to public area 30
Secondary S/Stn – outdoor Transformers/Plant < 2.5 metres to public area 30
Residential, Retail, Industrial or Commercial Properties.
Grid S/Stn – outdoor Transformers/Plant < 10 metres to public area 25

Primary S/Stn – outdoor Transformers/Plant < 5 metres to public area 25
Secondary S/Stn – outdoor Transformers/Plant < 2.5 metres to public area 25
Grid S/Stn – outdoor Transformers/Plant >10 < 20 metres to public area 25

Primary S/Stn – outdoor Transformers/Plant >5 < 10 metres to public area 25
Secondary S/Stn – outdoor Transformers/Plant >2.5 < 7.5 metres to public area 25

Secondary S/Stn – outdoor Transformers/Plant >2.5 < 7.5 metres to public area 20
Secondary S/Stn – outdoor Transformers/Plant >7.5 < 20 metres to public area 20
Site Information Zone Score

Weighting
Secondary S/Stn – outdoor Transformers/Plant >7.5 < 20 metres to public area 15
Grid S/Stn – outdoor Transformers/Plant > 100 metres to public area 10

Primary S/Stn – outdoor Transformers/Plant > 50 metres to public area 10
Secondary S/Stn – outdoor Transformers/Plant > 20 metres to public area 10

Issue No. 3
Grid S/Stn – outdoor Transformers/Plant > 100 metres to public area 5

Primary S/Stn – outdoor Transformers/Plant > 50 metres to public area 5
Secondary S/Stn – outdoor Transformers/Plant > 20 metres to public area 5
Indoor Transformer/Plant
Grid S/Stn – Transformers/Plant inside substation building/enclosure 25

Primary S/Stn – Transformers/Plant inside substation building/enclosure 25
Secondary S/Stn – Transformers/Plant inside substation building/enclosure 25
Grid S/Stn – Transformers/Plant inside substation building/enclosure 20

Primary S/Stn – Transformers/Plant inside substation building/enclosure 20
Secondary S/Stn – Transformers/Plant inside substation building/enclosure 20
Category 3 – Substation Plant
Oil Filled Transformer 30
Oil Filled Plant 20
Synthetic Ester Insulant, (MidelⓇ) filled Transformer 10
No Oil/ MidelⓇ filled equipment 5
Category 3 - *Select the highest plant value only, i.e. Midel Transformer with Oil Switch = 20.
Category 4 – Substation Access/Egress

Where the substation is a Confined Space 50
Access/egress arrangements unsatisfactory 25
Access/egress (via extended route to a place of safety) 15
Safe access/egress (leading via a safe route to a place of safety) 5
Safe access/egress (leading directly to a place of safety) 0
Fire Risk Survey Total
Value of Control Measures Implemented (See 16.3)
Substation Fire Risk Total
18. APPENDIX 2
18.1 Further Guidance on Output of Fire Risk Assessment (PAS79)
18.1.1 Overall Classification
The overall classification is a function of the likelihood and consequence of a fire, both of which are
explained in further detail in the next section. It is expected due to the unmanned nature of most SP
Energy Networks substation and low history of fire events the overall risk will be most substations will
be Tolerable or Trivial.

Issue No. 3
Figure 1 – FIRE RISK ASSESSMENT – PAS79
Classifications are as follows:-
Trivial: No action is required and no detailed records need be kept.
Tolerable No major additional controls required. However, there may be a need for consideration of
improvements that involve minor or limited cost.
Moderate: It is essential that efforts are made to reduce the risk. Risk reduction measures should be
implemented within a defined time period. Where moderate risk is associated with consequences that
constitute extreme harm, further assessment may be required to establish more precisely the
likelihood of harm as a basis for determining the priority for improved control measures.
Substantial: Considerable resources may have to be allocated to reduce the risk. If the building is
unoccupied, it should not be occupied until the risk has been reduced. If the building is occupied,
urgent action should be taken.
Intolerable Building (or relevant area) should not be occupied until the risk is reduced.
18.1.2 Likelihood of Fire
The likelihood of a fire is derived by qualitative assessment of the sources of ignition and ensuring
adequate control measures are in place such as plant/electrical maintenance regimes, smoking
prohibition, portable heaters, good housekeeping and use of cooking facilities.
Classifications are as follows:-
Low: Unusually low likelihood of a fire as a result of negligible potential sources of ignition.
Medium: Normal fire hazards (e.g. potential ignition sources) for this type of occupancy, with fire
hazards generally subject to appropriate controls (other than minor shortcomings).
High: Lack of adequate controls applied to one or more significant fire hazards, resulting in significant
increase in likelihood of fire.
For SP Energy Networks substations the potential sources of ignition is expected to be low in most
cases. This is subject to carrying out appropriate periodic control measures such as:-
 Visual inspections including thermography

 Maintenance of plant and protection systems
 Partial discharge testing of plant
 Dissolved Gas Analysis of Transformers
 Oil testing (moisture, acidity, breakdown voltage)
 Security upgrades to reduce the likelihood of vandalism
 No-smoking policy
 Adequate control for onsite hot works

Issue No. 3
Note this does not mean SP Energy Networks should not make reasonable improvements to reduce
the likelihood of fires occurring at substations.
For further comparison the rate of fires per SP Energy Networks substation vs. the number of fires in
domestic and commercial premises in 2013/14 is provided in table 3. A fire in an 11kV substation is
10 times less likely than a dwelling and 30 times less likely than a retail, industrial or commercial
property.
Annual Fires Dwellings Retail/Industrial/ SPEN – 11kV

Restaurants Substation
1 2 3
Number of fire 13/14 39,600 7,700 4.8
Number of/premises (estimate) 26,000,000 1,800,000 30,000
Annual Fire Rate 0.0015 0.0043 0.0002
Annual Fire Rate 1 in ….. 657 234 6250
TABLE 3
18.1.3 Consequence of fire
The consequence of a fire is derived by qualitative assessment of how quickly occupants can egress
in the event of a fire and what measures are in place to control the spread of a fire throughout the
building. Items taken into consideration include, travel distances, access routes, signage/emergency
lighting, fire detection and suppression systems.
Classification is as follows:-
Slight harm: Outbreak of fire unlikely to result in serious injury or death of any occupant (other than
an occupant sleeping in a bedroom in which a fire occurs).
Moderate harm: Outbreak of fire could result in injury of one or more occupants, but it is unlikely to
involve multiple fatalities.
Extreme harm: Significant potential for serious injury or death of one or more occupants.
Due to the low occupancy count and simple nature of freestanding unmanned substations it is
expected that most of these types of substations will have a risk of slight harm except for embedded
substations where the occupant risk is significant higher. This risk can be controlled by ensuring
adequate compartmentalisation of the site and cooperation with the building owner.
1
https://www.gov.uk/government/uploads/system/uploads/attachment_data/file/410287/Fire_Statistics_Great_Britain_2013-14___PDF_Version_.pdf
2
https://www.gov.uk/government/uploads/system/uploads/attachment_data/file/410287/Fire_Statistics_Great_Britain_2013-14___PDF_Version_.pdf
3
Data from HSE Regulation 31 events for 11kV substation plant from 2010-2015, includes vandalism and instances where substation has been isolated due to third
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What are the civil/building requirements for new substations mentioned in the document?

What are the civil/building requirements for new substations mentioned in the document?

What factors are considered when assessing the consequence of a fire?

What factors are considered when assessing the consequence of a fire?

SUBSTATION FIRE PROTECTION POLICY SUB-01-012

It is your responsibility to ensure you work to the current version.

Issue Date Issue No. Author Amendment Details

Author Owner Issue Authority

© SP Power Systems Limited Page 1 of 21

© SP Power Systems Limited Page 2 of 21

14.5 Building Shell ............................................................................................................ 13

© SP Power Systems Limited Page 3 of 21

Build Regs 2000 Part B of Building Regulations (Fire Safety)

SP Energy Networks Documents

BS 5499 Fire Safety Signage

BS 5266 Fire Emergency Escape Lighting

BS 5839 Fire Detection & Alarm Systems for Buildings

For the purpose of this document, the following definitions apply:

© SP Power Systems Limited Page 4 of 21

Basement Substation A substation in the basement of a third party building.

Intumescent Intumescent materials are substances that expand when exposed to

Underground Substation A substation below ground level, not within a building.

© SP Power Systems Limited Page 5 of 21

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

10.1 Risks Arising from Fire

 Act of arson or wilful interference from third parties.

 Interference from wildlife, flora or fauna.

 From an act of negligence such as an inappropriately discarded cigarette or from cooking in

© SP Power Systems Limited Page 6 of 21

 Reputation: SP Energy Networks operates a number of substations within listed buildings; a

11. CIVIL/BUILDING REQUIREMENTS

11.1 Access/Egress – New Substations

No new substations shall be constructed in basement locations, or so embedded within customer’s

11.2 Signage & Emergency Lighting

© SP Power Systems Limited Page 7 of 21

Substation Type Emergency Signage / Lighting

11.2.1 Escape distances

11.2.2 Special Provisions for Switchrooms

In accordance with established practices, rooms enclosing switchboards in excess of 6m in length

11.2.3 Special Provisions for Indoor Secondary Substations

© SP Power Systems Limited Page 8 of 21

11.3.2 Containerised Switchgear

11.3.3 Indoor Transformers (Freestanding & Embedded Substations)

Where it is necessary to embed transformers within a customer building or SP Energy Networks

11kV Mineral Oil

11.3.4 Outdoor Transformers

Transformer Liquid Volume Typical Transformer Clearance from bund to other

© SP Power Systems Limited Page 9 of 21

(O Class e.g. 2000 - < 20000 Primary 5 10

Transformer Type Clearance to building surfaces or adjacent transformers

11.4 Distance to Public Areas

11.5 Cables (Cableways/Trenches)

11.7 Fire Barriers (Enclosures, Firewalls, etc.)

© SP Power Systems Limited Page 10 of 21

11.8 Fire Detection and Warning Systems

11.9 Safety Protection

Freestanding Transmission/Grid/Primary/Secondary substations are considered simple buildings such

Substation Type Fire Detection Requirements

11.10 Protection of Assets