FIRE PROTECTION DESIGN CRITERIA - TVSFPE · 7.5 Fire-fighting Activities ... 8 FIRE PROTECTION...

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DRAFT DOE-STD-1066-99 (September 2010) Editor’s Note: Need DOE Tech Standard “Tool Kit disk” for Cover and Concluding Material templates NOT MEASUREMENT SENSITIVE DOE-STD-1066-10 September 2010 Superseding DOE-STD-1066-99 DOE STANDARD FIRE PROTECTION DESIGN CRITERIA U.S. Department of Energy AREA FIRP Washington, DC 20585 DISTRIBUTION STATEMENT. Approved for public release; distribution is unlimited.

Transcript of FIRE PROTECTION DESIGN CRITERIA - TVSFPE · 7.5 Fire-fighting Activities ... 8 FIRE PROTECTION...

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DRAFT DOE-STD-1066-99 (September 2010)

Editor’s Note: Need DOE Tech Standard “Tool Kit disk” for Cover and Concluding Material templates

NOT MEASUREMENT SENSITIVE

DOE-STD-1066-10 September 2010

Superseding

DOE-STD-1066-99

DOE STANDARD

FIRE PROTECTION DESIGN CRITERIA

U.S. Department of Energy AREA FIRP Washington, DC 20585

DISTRIBUTION STATEMENT. Approved for public release; distribution is unlimited.

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FOREWORD

DOE-STD-1066 was originally a repository for requirements that were in DOE O 6430.1A, General Design Criteria, and DOE Order 5480.7A, Fire Protection. These Orders were abolished in an initiative to eliminate prescriptive requirements and replace them with goals. DOE-STD-1066 also contains criteria to address DNFSB concerns over such issues as fire protection of HEPA filters and seismic criteria for sprinkler systems.

In 2010, several additional fire protection guidance directives were abolished and their contents added to DOE STD-1066:

• DOE-STD-1088, Fire Protection for Relocatable Structures; • DOE G 420.1-3, Implementation Guide for DOE Fire Protection and Emergency

Services Programs for Use with DOE O 420.1B, Facility Safety; and • DOE G 450-1.4 IMPLEMENTATION GUIDE WILDLAND FIRE MANAGEMENT

PROGRAM for Use with DOE 450.1, Environmental Protection Program;

This Department of Energy Standard is approved for use by all DOE elements and their contractors.

DOE Standards are part of the DOE Directives System and are issued to provide supplemental guidance regarding the Department's expectations for fulfilling its requirements as contained in rules, Orders, and notices. The Standards provide acceptable methods for implementing these requirements. Beneficial comments (recommendations, additions, deletions) and any pertinent data that may improve this document should be sent to the name and address below by letter or by using the self-addressed Document Improvement Proposal (DOE F 1300.3) appearing at the end of this document.

Office of Environment, Safety and Health Office of Nuclear Safety Policy and Assistance

U.S. Department of Energy 19901 Germantown Road

Germantown, MD 20874-1290

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TABLE OF CONTENTS

1  SCOPE .................................................................................................................................. 1 

2  PURPOSE ............................................................................................................................. 1 

3  OBJECTIVES ........................................................................................................................ 2 

4  REFERENCED CRITERIA .................................................................................................... 3 

5  DEFINITIONS ........................................................................................................................ 3 

6  FIRE PROTECTION PROGRAM .......................................................................................... 9 

6.1  General ........................................................................................................................... 9 

6.2  National Standards ......................................................................................................... 9 

6.3  Fire Protection Policy Statement .................................................................................. 10 

6.4  Authority Having Jurisdiction ........................................................................................ 10 

6.5  Fire Protection Staff ...................................................................................................... 11 

6.6  Fire Protection Program Documentation ...................................................................... 12 

6.7  Inspection, Testing and Maintenance ........................................................................... 12 

6.8  Fire Hazards Analysis ................................................................................................... 13 

6.9  D&D Facilities ............................................................................................................... 18 

6.10  Fire Protection Assessments ........................................................................................ 21 

6.11  Corrective Action .......................................................................................................... 24 

6.12  Exemptions Variances & Equivalencies (Approved Requirement Relief) ..................... 24 

7  EMERGENCY RESPONDER GUIDANCE .......................................................................... 29 

7.1  Fire Department Resources ......................................................................................... 30 

7.2  Staff .............................................................................................................................. 31 

7.3  Training and Drills ......................................................................................................... 31 

7.4  Pre-Incident Fire Activities ............................................................................................ 32 

7.5  Fire-fighting Activities involving special hazards .......................................................... 32 

7.6  Baseline Needs Assessment ........................................................................................ 32 

8  FIRE PROTECTION DESIGN GUIDANCE ......................................................................... 34 

8.1  Protection to Limit Loss Potential ................................................................................. 35 

8.2  New Facility Design Requirements ............................................................................... 36 

9  WATER SUPPLY AND DISTRIBUTION SYSTEMS ........................................................... 37 

9.1  Demand ........................................................................................................................ 37 

9.2  System Arrangement .................................................................................................... 38 

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10  AUTOMATIC SPRINKLER SYSTEMS ............................................................................ 39 

10.1  General Application ...................................................................................................... 41 

10.2  Seismic Criteria ............................................................................................................ 41 

11  FIRE ALARM SYSTEMS ................................................................................................. 41 

11.1  General Application ...................................................................................................... 42 

11.2  Alarm Actuating Devices .............................................................................................. 42 

11.3  Alarm System Extensions ............................................................................................. 42 

12  STRUCTURAL FIRE PROTECTION CRITERIA.............................................................. 42 

12.1  General ......................................................................................................................... 42 

12.2  Fire Barriers .................................................................................................................. 43 

12.3  Flame Spread ............................................................................................................... 43 

12.4  Roofing Systems .......................................................................................................... 44 

12.5  Penetrations ................................................................................................................. 44 

12.6  Carpets and Rugs ......................................................................................................... 44 

13  LIFE SAFETY ................................................................................................................... 45 

14  ELECTRICAL EQUIPMENT ............................................................................................. 46 

15  GENERAL PROCESS HAZARD FIRE PROTECTION .................................................... 46 

16  SPECIAL HAZARDS ........................................................................................................ 47 

16.1  Plutonium Processing and Handling Facilities (PPHF) ................................................. 47 

16.2  Plutonium Storage Facilities (PSF) ............................................................................... 48 

16.3  Enriched Uranium Storage Facilities (EUSF) ............................................................... 48 

16.4  Uranium Processing and Handling Facilities ................................................................ 48 

16.5  Reprocessing Facilities ................................................................................................. 48 

16.6  Uranium Conversion and Recovery Facilities ............................................................... 49 

17  NUCLEAR FILTER PLENUM FIRE PROTECTION ......................................................... 49 

17.1  Purpose and Scope ...................................................................................................... 49 

17.2  Filter Plenum Construction ........................................................................................... 50 

17.3  Location of Final Filter Plenum Ventilation System Equipment .................................... 50 

17.4  Protection of Openings in Fire Rated Construction ...................................................... 51 

17.5  Materials and Special Hazards Inside Plenums ........................................................... 52 

17.6  Prefilters, Duct Entrance Filters, and Fire Screens ...................................................... 53 

18  Detection Systems ........................................................................................................... 54 

18.1  Detectors ...................................................................................................................... 54 

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18.2  Deluge Spray Suppression Systems ............................................................................ 55 

18.3  Design of Automatic Deluge and Water Spray Systems .............................................. 56 

18.4  Design of Manual Spray Systems ................................................................................ 57 

18.5  Water Supply Guidelines .............................................................................................. 57 

18.6  Special System Guidelines ........................................................................................... 58 

18.7  Fire Hazard Analysis .................................................................................................... 59 

19  GLOVEBOX FIRE PROTECTION ................................................................................... 59 

19.1  Scope ........................................................................................................................... 59 

19.2  Glovebox Construction ................................................................................................. 60 

19.3  Automatic Fire Suppression/Inerting Systems .............................................................. 62 

19.4  Automatic Fire Suppression Systems ........................................................................... 63 

19.5  Manual Fire Suppression .............................................................................................. 65 

19.6  Fire Detection Systems ................................................................................................ 66 

19.7  Glovebox Ventilation ..................................................................................................... 66 

20  Safety Classification Fire Protection Systems .................................................................. 67 

20.1  Wet Pipe Automatic Sprinkler Installations ................................................................... 67 

20.2  Water Supply ................................................................................................................ 69 

20.3  Fire Barriers .................................................................................................................. 71 

21  Relocatable Structures ..................................................................................................... 73 

21.1  General ......................................................................................................................... 73 

21.2  Location Restrictions .................................................................................................... 76 

21.3  Occupancy Considerations ........................................................................................... 77 

21.4  Fire Protection Requirements ....................................................................................... 78 

22  Wildland Fire Management .............................................................................................. 79 

22.1  Wildland/Urban Interface .............................................................................................. 80 

22.2  Wildland Fire Prevention .............................................................................................. 81 

22.3  Preparedness Actions .................................................................................................. 82 

22.4  Wildland Fuels Management ........................................................................................ 84

Appendices

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1 SCOPE The provisions of this Standard apply to the following:

1. All departmental elements as identified in the scope of DOE O 420.1 B, Facility Safety, and its respective Contractor Requirements Document (CRD); DOE 440.1 B, Worker Protection Management Program for DOE (Including the National Nuclear Security Administration) Federal Employees; and, 10 CFR Part 851, Worker Safety and Health Programs

2. The purchase and lease, as well as the design and construction, of all DOE facilities erected, modified, or renovated after the effective date of this Standard on or off a DOE site after the effective date of this Standard. This standard may not apply to non-government facilities or to facilities of other agencies on DOE sites where fire protection requirements are enforced by other Government agencies.

Where criteria differ for new and existing installations, the term “new” means any installation after the date of the predecessor directive in which the “new” guidance first appeared. In other words, it is not acceptable to omit a feature during construction and then justify omission because the installation is existing. Furthermore, a feature may not be removed or disabled after the facility or installation becomes operational.

Unless specifically required by a DOE contract, directive, or regulation, provisions of this standard provides guidance on acceptable methods that must be considered to meet DOE requirements. Nothing in this Standard is intended to limit the application of other fire protection methods when unique situations or hazards warrant an alternate approach. Any alternate approach should provide a level of safety equal to that achieved by conformance with this Standard. Such alternate approaches must be documented approved by the Authority Having Jurisdiction (AHJ), after consultation with a qualified fire protection engineer.

2 PURPOSE The purpose of this Standard is to facilitate implementation of requirements in Department of Energy (DOE) Order (O) 420.1, Facility Safety, by providing supplementary information that describes an acceptable approach to meet the DOE O 420.1B requirements for Fire Protection Programs. This document also addresses, in part and where appropriate, the relationship of fire protection requirements in DOE O 420.1B and the following DOE documents:

10 CFR Part 851, Worker Safety and Health Program DOE O 440.1B, Worker Protection Program for DOE (Including the National Nuclear Security Administration) Federal Employees

DOE Guide (G) 440.1 8, Implementing Guide for Use with 10 CFR Part 851, Worker Safety and Health Programs

DOE O 151.1C, Comprehensive Emergency Management System

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These additional documents are available at the DOE Fire Protection Website: (http://www.hss.energy.gov/nuclearsafety/nsea/fire//) and/or at the DOE Directives Website (http://www.directives.doe.gov/) and/or at the DOE Technical Standards Website (http://www.hss.energy.gov/nuclearsafety/techstds/)

3 OBJECTIVES FIRE PROTECTION GOALS- - DOE O 420.1B establishes facility and programmatic safety requirements for a comprehensive fire protection program for DOE sites, facilities, and

(1) minimize the potential for occurrence of a fire or related event, i.e, prevent fires and related accidents;

(2) minimize fires that cause an unacceptable onsite or offsite release of hazardous or radiological material that could impact the health and safety of employees, the public, or the environment, i.e. if a fire occurs, limit its growth to a size that does not challenge thresholds;

(3) minimize unacceptable interruption of DOE missions, especially vital DOE programs as a result of fire and related hazards, i.e. provide sufficient barriers to prevent loss of essential production or analysis capability, failure to meet compliance agreements, Congressional mandates, WIPP delivery schedules, etc;

(4) minimize property loss from fire exceeding limits established by DOE; and

(5) minimize fire damage to safety basis credited process controls and safety systems structures and components (as documented by appropriate safety analysis)

FIRE PROTECTION PROGRAM – DOE O 420.1X requires a comprehensive fire protection program. Comprehensive fire safety and emergency response programs at DOE sites and facilities include, but are not limited to,

1. appropriate policies, requirements, technical criteria, analyses, administrative procedures, and related documentation.

2. adequately designed, installed and maintained fire safety systems, hardware, structural features, and related devices

3. access to fully capable emergency response forces with trained personnel and adequate apparatus and equipment that enable these forces to respond in a timely and effective manner. Where the l emergency response capability is deemed insufficient, appropriate compensatory measures are implemented to address baseline needs.

4. The professional staff, general worker population, student interns and visiting scientist and researchers at these sites and facilities are appropriately trained on the fire hazards and related conditions that they are likely to encounter. The visiting public is provided with escorts and safety briefings when exposed to fire and safety hazards to which the generally public is not typically exposed.

5. A staff of qualified and experienced fire safety professionals.

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Additional guidance on how to meet DOE expectations for the above-referenced programs is delineated below. This guidance supplements general industry criteria, and contractual obligations. This additional guidance is referenced to the specific sections of the DOE O 420.1X where additional guidance was deemed warranted by DOE and DOE contractor fire safety professionals.

4 REFERENCED CRITERIA DOE facilities and their associated fire protection features are subject to the applicable sections of the current editions of the criteria listed below:

Federal Criteria

DOE Requirements

• Department of Energy (DOE) Order (O) 420.1, Facility Safety

DOE Guidelines

Other Criteria

National Fire Protection Association (NFPA)

• NFPA 1710, Standard for the Organization and Deployment of Fire Suppression Operations, Emergency Medical Operations, and Special Operations to the Public by Career Fire Departments

• NFPA 801 • NFPA 30, Flammable and Combustible Liquids Code • NFPA Standard 1143, Wildland Fire Management

International Building Code

Referenced Standards

• DOE-STD-1088-95 • DOE-STD-1137-2007, Fire Protection Engineering Functional Area Qualification

Standard

5 DEFINITIONS Acceptable - When applied to fire safety, "acceptable" is a level of protection which the Authority Having Jurisdiction, after consultation with the cognizant DOE fire protection engineer(s), considers sufficient to achieve the fire and life safety objectives defined in DOE Orders. In some instances, it is a level of protection necessary to meet a code or standard. In other

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instances, it is a level of protection that deviates (plus or minus) from a code or standard as necessary and yet adequately protects against the inherent fire hazards.

Adsorber Systems - A system for removing gases or vapors from air by means of preferential physical condensation and retention of molecules on a solid surface. Adsorbers used in nuclear applications are often impregnated with chemicals to increase their activity for organic radioactive iodine compounds.

Authority Having Jurisdiction (AHJ) - The decision making authority in matters concerning fire protection. The DOE Head of Field Organization or designee is the final AHJ unless otherwise directed by the Cognizant Secretarial Officer (DOE O 420.1B. 5. d. (10). Routine AHJ functions which do not involve deviation from codes, standards, guides, or other requirements may be delegated to qualified contractors.

Building Code Official (BCO) - The decision making authority in matters concerning the building code. The DOE Head of Field Organization or designee is the final BCO unless otherwise directed by the Cognizant Secretarial Officer.

Code of Record – The installation requirements (code or standard) in effect at the time a facility or item of equiptment was designed and constructed.

Combustible Liquid - Any liquid that has a closed cup flash point at or above 100°F (37.8°C), as determined by the test procedures and apparatus set forth in Section 4.4 of NFPA 30, Flammable and Combustible Liquids Code. Combustible liquids are classified according to Section 4.3 of NFPA 30.

Combustible Material - Any material that will ignite and burn. Any material that does not meet the definition of "noncombustible" as contained in this Standard is considered combustible. The term combustible is not related to flame spread rating. Combustible materials as defined in NFPA 101 includes a material that, in the form in which it is used and under the conditions anticipated, will ignite and burn; a material that does not meet the definition of noncombustible or limited-combustible.

Criticality Incident - The release of energy as a result of accidentally producing a self-sustaining or divergent neutron chain reaction.

Deep Bed Fiberglass Filter - A ventilation filter made of deep beds of compacted fiberglass contained in stainless steel boxes having opaque sides and perforated screens at the top and bottom for the removal of particulate matter.

Deep Bed Sand Filter - Particulate filter constructed of deep beds of rock, gravel, and sand, formed in layers graded with about two to one variation in granule size from layer to layer.

Demister - A device used to protect the final filter in an air cleaning system from entrained moisture in the air.

Documented Safety Analysis – An analysis of the extent to which a nuclear facility can be operated safely with respect to workers, the public, and the environment, including a description

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of the conditions, safe boundaries, and hazard controls that provide the basis for ensuring safety (10 CFR 830.3).

Duct Entrance Filter - A type of pre-filter unit installed at the exhaust duct entrance(s) to prevent entrance and accumulation of combustible or flammable dusts and/or residues inside the exhaust ducts.

(Note: This is a concern of particular interest to the nuclear industry because radioactive and other substances tend to deposit or "plate out" on ducts. Dust accumulation on interior duct surfaces can spread fires directly to the final exhaust plenum filters.)

Emergency Services Organization – The site fire department, brigade, or other organization that performs any or all of the following functions:

• Fire Suppression • Hazardous Material (HAZMAT) Response • Emergency Medical Services • Technical Rescue • Confined Space Entry • Training • Off-site Assistance to Other Emergency Services Organizations (Mutual Aid) • Inspection, Testing and Maintenance of Fire Protection Equipment or Apparatus • Facility Fire Prevention and Life Safety Inspections

Exhaust Plenum Final Filter - The final High Efficiency Particulate Air filter unit in a set of filters arranged in a series for ventilation and effluent discharge in an air cleaning system.

Fire - Unplanned destructive burning, including explosions (detonation or deflagration), as manifested by any or all of the following: light, flame, heat or smoke. Fire does not include the following unless they cause a fire or occur as a consequence of a fire: lightning or electrical discharge, rupture of a pressure vessel not caused by internal combustion, detonation of munitions, or overheat [without damage to initiating material.]

Fire Area - A location bounded by construction having a minimum fire resistance rating of 2 hours with openings protected by appropriately fire-rated doors, windows, dampers, or penetration seals. The boundaries of exterior fire areas (yard areas) or other locations that represent unique conditions should be as determined by the cognizant fire protection engineer (contractor or DOE). (When relocatable structures are grouped and are not separated as directed in this standard, they should be considered as being part of the same fire area. (Extracted from DOE-STD-1088-95)

Fire Barrier - A fire resistance-rated vertical or horizontal assembly of materials designed to restrict the spread of fire in which openings and penetrations are protected. [NFPA 801, Section 3.3.7 and International Building Code Section 702.1] NOTE: Fire barriers may be structural bearing or non-bearing (walls, ceilings, floors) or non-structural (e.g. cable tray or duct wrap fire barriers).

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Fire Loss - The dollar cost of restoring damaged property to its pre-fire condition. When determining loss, the estimated damage to the facility and contents should include replacement cost, less salvage value. Fire loss should exclude the costs for: property scheduled for demolition; and decommissioned property not carried on books as a value. Fire loss should include the cost of:

• Replacement cost of building and building systems or contents within the damaged area

• Replacement cost of contents • Cost of lost time (considered mission interruption costs) including maintained payroll

and purchase of alternative production • Cost of decontamination and environmental clean-up • Exposure damage to other buildings, structures and property • Costs for re-establishing operations; e.g., redesign approval and start-up • Indirect costs of fire extinguishment (such as fire department equipment)

Fire Protection – A broad term which encompasses the aspects of fire and life safety, concerned with minimizing the direct and indirect consequences of fire and other perils, such as explosions and natural phenomenon events as they relate to fire. Aspects of fire protection include, but are not limited to, fire suppression and detection systems, fire water systems and emergency process safety control systems, building construction and fixed building features such as fire doors, fire walls and barriers, and fire dampers. Also included are the fire department and emergency response forces.

Fire Protection Assessment – A formal documented review conducted by DOE or Contractors in accordance with DOE requirements that examine the essential fire protection elements as they relate to a specific facility or overall fire protection program.

Fire Protection Engineer - A graduate of an accredited engineering curriculum and having completed not less than 4 years of engineering practice, 3 of which shall have been in responsible charge of diverse fire protection engineering work. If not such a graduate, a qualified engineer shall either: demonstrate a knowledge of the principles of engineering and have completed not less than 6 years engineering practice, 3 of which shall have been in responsible charge of diverse fire protection engineering projects; be a registered professional engineer in fire protection; or meet the requirements for a Grade 11 or higher Fire Protection Engineer as defined by the Office of Personnel Management.

Fire Protection System - Any system designed to detect contain or extinguish a fire, limit the extent of fire damage and enhance life safety. (These include: Automatic suppression systems, such as fire sprinklers, foam, gaseous, explosion suppression, or other specialized extinguishing systems plus appropriate alarms. An adequate supply, storage, and distribution system is an essential element. Automatic fire detection, occupant warning, manual fire alarm, and fire alarm reporting systems . Fire barrier systems or combinations of physical separation and barriers for outdoor locations. (Extracted from DOE-STD-1088-95 NOTE: this is the same as Redundant Fire Protection System described below)

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Fire Prevention – The process of managing and regulating potential fire hazards (fuels and heat energy sources) and the mechanisms that bring them together to either eliminate the hazard(s) or reduce the risk associated with the hazard(s).

Fire Resistance Rating - The time, in minutes or hours, that materials or assemblies have withstood a fire exposure as determined by a fire test or methods based on tests [NFPA 221, Section 3.3.6]. The fire test exposure is established in accordance with test procedures of NFPA 251, ASTM E 119 and ANSI/UL 263 are similar to NFPA 251. Recognized methods based on tests (using exposure and acceptance criteria of ASTM E 119) are prescriptive designs and/or calculation methods documented in the building code, Section 719, American Iron and Steel Institute Fire Resistance Design Guide and Fire Resistance Ratings of Load Bearing Steel Stud Walls with Gypsum Wallboard Protection, Gypsum Wallboard Association’s Fire Resistance Design Manual, FM Global Property Loss Prevention Data Sheets, and American Society of Civil Engineers/Society of Fire Protection Engineers Standard Calculation Method for Structural Fire Protection.

Fire Screen - An item of equipment installed ahead of all HEPA filter banks intended to reduce glowing/burning ember products from reaching final (HEPA) filters.

Flammable Liquid - Any liquid that has a closed cup flash point below 100°F (37.8°C), as determined by the test procedures and apparatus set forth in Section 4.4 of NFPA 30, Flammable and Combustible Liquids Code, and a Reid vapor pressure that does not exceed an absolute pressure of 40 psi (76 kPa) at 100°F (37.8°C), as determined by ASTM D 323, Standard Test Method for Vapor Pressure of Petroleum Products (Reid Method). Flammable liquids are classified according to Section 4.3 of NFPA 30.

Flame Spread Rating - Flame spread rating is a numerical classification determined by the test method in ASTM E-84, which indexes the relative burning behavior of a material by quantifying the spread of flame of a test specimen. The surface burning characteristic of a material is not a measure of fire resistance or combustibility.

Glovebox - A sealed enclosure with viewing windows designed to separate the space in the enclosure from its surroundings and in which all items in the enclosure are handled using gloves that are sealed to the enclosure walls.

High Efficiency Metal Fiber (HEMF) Filter - A reusable metal filter composed of fine sintered stainless steel fibers together with a stainless steel wire and metal support housing and pleated to enhance strength, surface area, and particle holding capacity.

High Protected Risk (HPR) - HPR is a fire insurance term that if achieved gives the best insurance rate for that class of business. As DOE is self insured, maintaining the HPR level of best of insurance provides for the best fire protection features and implies that the facility will have the lowest possible fire looses. One method to achieve and maintain the HPR status is to use the FM Global Loss Prevention Data Sheets in the design, construction, and operations of a facility. The use of FM Global Data Sheets to achieve HPR in design, construction, and operations goes beyond the use of the Data Sheets that relate to fire protection systems.

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Limited Supply Suppression System - A system installed in accordance with the applicable NFPA Standards and having a limited quantity of suppression agent. These systems typically include carbon dioxide, dry chemical, other gaseous agents, or water.

Listed/Approved - Equipment or materials that have been tested, passed, and are included in a current list published by a nationally recognized testing laboratory which is concerned with product evaluation and is acceptable to the AHJ. The laboratory maintains periodic inspection of production of listed equipment or materials. Such lists state either that the equipment or material meets appropriate standards or has been tested and found suitable for use in a specified manner. This definition applies to products which are Underwriter's Laboratories (UL) listed or Factory Mutual (FM) approved.

Maximum Possible Fire Loss (MPFL) - The value of property, excluding land value, within a fire area, unless a fire hazards analysis demonstrates a lesser (or greater) loss potential. This assumes the failure of both automatic fire suppression systems and manual fire fighting efforts.

Noncombustible - A material that in the form in which it is used and under the conditions anticipated will not ignite, burn, support combustion, or release flammable vapors when subjected to fire or heat, as determined by ASTM Standard E-136.

Occupancy - The purpose for which a building, or portion thereof, is used or intended to be used. For DOE facilities, the occupancy classification for purposes of determining construction, protection and area limitations should be as determined under the provisions of the [International Building Code unless otherwise specified by the AHJ.

Prefilter - A filter that is located upstream from another filter. Prefilters, or roughing filters, remove and/or reduce the amount of large particles that could reduce the life of the next-in-line or final filters.

Pre- Fire Plan – A document owned and developed by a fire department which provides information to responding personnel that will help them safely and effectively manage emergencies with available resources at a specific facility or area.

Pyrophoric Material - A material capable of igniting spontaneously in air at normal temperatures.

Qualified Fire Protection Engineer – A fire protection engineer who has completed the criteria in DOE-STD-1137.

Redundant Fire Protection System - A fire protection system that is designed and installed to function in the event of the failure of a primary fire protection system.

Relocatable Structure - Manufactured structures, mobile homes, trailers, semi-trailers, modular type structures, factory assembled structures, cargo containers, hazardous materials or flammable liquid storage containers, air supported/inflated structures, tent/membrane and cloth/rib structures. This term does not apply to trailers and cargo containers that are being

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used in the transportation mode for conveying materials while onsite, or to prefabricated buildings that are permanently located, such as "Butler" or "Strand Steel" buildings. Structures not specifically identified herein should be referred to the AHJ for categorization.

Smoke Developed Rating - Smoke developed rating is a numerical classification determined by ASTM E-84, which indexes the smoke generation rate of a given material to those of two standard materials (inorganic reinforced cement board and select grade red oak).

6 FIRE PROTECTION PROGRAM

6.1 General DOE and contractor fire safety programs include all activities pertaining to fire hazards and related perils including: emergency services, operations and maintenance activities such as hot work or combustible material handling or storage; construction activities related to fire safety; installation and testing of fire protection systems; water supply and distribution systems; fire safety training; assessments; facility and site walk downs; and other fire protection activities that are not explicitly identified here.

Contractors can achieve and maintain a comprehensive site and facility fire protection program through implementation of applicable industry codes and standards (principally from the NFPA), as modified by DOE fire safety criteria. Site and facility fire protection programs are characterized by defense-in-depth. This means that adequate safety is assured by reliance on multiple levels of fire protection (fire safety policies, administrative procedures, active and, passive fire safety features, trained people, and an adequate emergency response capability, among other possible facets). Additionally, the long-term adequacy of site and facility fire safety programs require routine self-assessments of all aspects of the contractor’s fire protection program. A corrective action program that facilitates the prioritization and timely remediation of all fire protection and emergency response deficiencies is required for a fire protection program to be successful in the long term. Deficiency discovery and resolution must include appropriate notification, reporting, tracking to closure, and trending of findings.

Subcontractors can achieve compliance with DOE fire safety objectives through an established and appropriately documented relationship with a prime contractor’s fire protection and emergency response program. In any case, the prime contractor’s fire protection program requirements must flow down to all sub-contractors.

6.2 National Standards DOE O 420.1X reflects Public Law 100-678, as codified in 40 USC 3312, which requires acquisition, construction, and alteration of federal facilities to meet the latest edition of the national model building code as well as national standards for electrical, fire and life safety. National codes and standards provide minimum criteria which may not be sufficient for hazardous or high value facilities or for users that place a premium on safety or loss control. Beginning with the Manhattan Project, Departmental facilities were also required to meet “Highly Protected Risk” criteria. Highly Protected Risk (HPR) is an insurance industry term applied to property that qualifies for coverage by insurers such as FM Global (formerly called Factory Mutual) that limit their underwriting to the best-protected class of risk where they provide

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superior fire protection engineering oversight while charging substantially lower premiums. (Insurance companies provided the leadership to develop the fire and building codes and are a major enforcer of fire protection in the private sector, so insurance terminology is often used in the field of fire protection.) HPR criteria can be found on the FM Global web site. Examples fire protection features or activities that may be found at qualifying as HPR includes, but is not limited to redundant water supplies, enhanced fire protection system inspection, testing & maintenance programs, applying recommendations from Factory Mutual Data Sheets to the protection of building and process hazards and associated equipment, etc.

The National Fire Codes are comprised of over 200 codes and standards. In addition, ASTM and other organizations promulgate national standards for fire protection. DOE regulations and directives require use of “applicable” fire standards. The applicable standards are generally a small subset of the total which may vary significantly from facility to facility, depending on the use and hazards. Applicability can usually be determined by an “applicability” statement at the beginning of each standard. Needless to say, a subject matter expert familiar with the complete set of codes and standards should be consulted in selecting what is applicable for a specific facility as well as any time the use, contents, occupancy, or processes are changed.

National codes and standards focus primarily on safety rather than functionality and must be supplemented by complete specifications to assure fully functional facilities and systems. The development of this Standard reflects the fact that national consensus standards and other design criteria do not comprehensively or, in some cases, adequately address special or unique fire protection issues at DOE facilities.

6.3 Fire Protection Policy Statement The intent of documenting policy statements is to have the uppermost levels of DOE and Contractor management state in writing their fire protection program expectations. Such policy statements should not conflict with regulatory, DOE, or contractual obligations. For site emergency services organizations, this policy statement should include fundamental statements regarding the level of service that DOE expects and the level of capability that the contractors intend to provide. (For example: “DOE expects that the site fire department will maintain a capability to provide Advanced Life Support, as defined in the State of…” or “…will provide an emergency services capability that fully conforms with the requirements of the State of…, DOE directives, and NFPA codes and standards, unless explicit relief has been granted by DOE.”)

6.4 Authority Having Jurisdiction Section 5d(10) of DOE O 420.1B assigns the responsibilities for the AHJ, in most cases, to the DOE heads of field elements under advisement of a qualified fire protection engineer as the subject matter expert (SME). The AHJ may designate a contractor as the site’s Fire Marshall to act as his representative for routine activities such as: issuing of permits; reviewing and approving construction documents and shop drawings (new construction, modification, or renovation); accepting fire protection equipment, materials, installation, and operational procedures (fire system inspection and testing), interpretation of building codes or standards; and other activities that require AHJ approval. Fire Marshall activities, inclusive of this authority, should be well documented and available for AHJ review, including documents submitted to DOE/NNSA for Government review and approval. The DOE/NNSA retains the right to override

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decisions of the Contractor’s Fire Marshal, including the interpretation and application of DOE Orders, Guides, Standards, and mandatory codes and standards. In addition, this approval authority does not extend to the DOE/NNSA’s approval of exemptions and equivalencies to DOE Orders, DOE Standards, and mandatory codes and standards such as those promulgated by the National Fire Protection Association.

For the purposes of enforcing the adopted building code at sites, the Head of the DOE Field element is designated as the Building Official. The DOE Head of the Field element may delegate to the contactor in writing responsibility for decisions on diminutive issues, but not the responsibility for approving exemptions and variances to Building Code requirements.

6.5 Fire Protection Staff A sufficient number of qualified fire safety professionals (fire protection engineers, fire department management personnel, firefighters and technicians) should be on staff to develop, implement and maintain the fire protection and emergency response program. Staffing levels for the Contractor’s fire protection program should be based on a "work load analysis" or similar analysis that provides a technical basis for the fire safety staff. Staffing for the fire department should be based upon conclusions reached in the Baseline Needs Assessment (BNA) required by DOE-O-420,1B.

Established industry criteria, such as those promulgated by the NFPA, as supplemented by DOE fire safety criteria, should be the basis for site and facility fire safety and emergency response training and qualifications. Emergency services organization officers and personnel may additionally meet the minimum requirements for training and certifications as established by the state or local jurisdiction, as an alternative to DOE directives or applicable NFPA standards, provided those state and local requirements are substantially equivalent and approved by the AHJ. (Although State and local requirements do not apply on Federal reservations, it may be selectively desirable to apply them to facilitate mutual assistance agreements with nearby jurisdictions.)

Sites should provide appropriate support or oversight personnel when using off-site fire departments, brigades and fire protection engineering support contractors as well as escorts for access to areas with classified material. Where reliance is placed on off-site fire brigades or fire departments for fire suppression, efforts should be made to obtain suitable clearances for fire response personnel in order to avoid delays in fire department response, and associated consequences (e.g., loss of life, injury, increased fire damage) that may result as a result of delayed response.

An appropriate level of individualized safety and health training is expected to be provided to all workers including sub-contractors, visiting scientist and summer interns, and emergency responders in accordance with the provisions of 10 CFR Part 851 and the incorporated training requirements of 29 CFR 1910 and 1926. Particular attention is directed at the HAZWOPER training requirements. Such training and familiarization also applies, as appropriate, to managers and decision makers to the extent that they are involved in directing the actions of their subordinates in the face of known fire hazards and in conjunction with hazardous materials incidents and fires. Certain DOE personnel, including NNSA fire protection engineers are

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required to complete and maintain the Technical Qualifications Program (TQP) for Fire Protection Engineer.

All DOE Federal and contractor employees should be provided with a basic level of fire safety training and response to emergency training initially, with refresher training provided in conjunction with other general federal and contractor training programs. (This can include the distribution of printed matter and public address announcements.) It is important that the level of training provided match the level of the individual’s responsibility.

Members of the public should be provided with suitable orientation on the fire hazards (if any) that they may encounter while on site and the appropriate personal response, including escape and notification, if they should find themselves in an emergency situation. Where escorting is required, the responsibility (briefing escortees, dos and don’ts, pointing out evacuation routes and muster areas, etc.) of the escort should be clearly defined.

6.6 Fire Protection Program Documentation The program should be completely documented. This includes a description of applicable fire safety requirements in contracts and leases, where appropriate. Documentation should also include a description of the fire protection organization and its roles and responsibilities in relation to other organizational entities. Training and qualification records of individuals having fire protection program responsibilities shall be readily available and in an auditable form. Appropriate fire protection documentation includes copies of all fire hazard analyses (FHAs) and at least the two most recent facility assessment reports in a continually updated filing system. FHAs and facility assessment reports may be combined, provided that they address all essential elements as defined below. Facility documentation should also include copies of any exemptions, equivalencies or deviations that have been approved by DOE.

The Contractor’s fire protection program must include oversight of fire protection aspects of new construction, facility modifications, the installation of potentially hazardous operations and experiments. In order to avoid project delays and last minute change requests this involvement must be early and beginning at project conception. For large projects it may be beneficial to establish a fire protection working group composed of DOE and Contractor fire protection engineers, safety basis representatives, responsible design engineers, operations personnel and others as may be appropriate. Such working groups can be successful in resolving fire protection challenges, ensuring that issues do not become side-tracked, identifying early the possible need for exemptions or equivalencies, and most important avoiding costly delays in design or construction. Construction projects should feature a file in which all significant decisions and reports concerning fire protection can be found. Supporting documents in this file should be maintained for future reference.

6.7 Inspection, Testing and Maintenance The inspection, testing and maintenance (ITM) program for fire protection features, apparatus and equipment should be based on industry standards, such as those established by the NFPA unless an alternative has been approved by the AHJ. The IT&M program must include a fire protection system impairments program, which at a minimum should consist of the process for approving and initiating impairments, the tracking of impairments, reporting to DOE when

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impairments exceed DOE Site Office established criteria, as well as appropriate record (date, location, nature of impairment, corrective action taken, closure date, etc.). The organizations responsible for ITM of fire protection features should maintain system inspection and test records according to Section 11.4 of DOE Administrative Records Schedule 18, “Security, Emergency Planning and Safety Records” or, if not specifically addressed in the Schedule 18 document, for a minimum of three review cycles. In addition, responsible authorities should retain records of all ITM procedures for as long as such equipment remains in service.

6.8 Fire Hazards Analysis The purpose of an FHA is to conduct a comprehensive, qualitative assessment of the risk from fire 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. In accordance with the "graded approach" concept, the level of detail necessary for an acceptable FHA is directly related to the complexity of the facility and the potential risk to the public and facility operators. A FHA for a fully compliant facility can be relatively brief but deviations from codes, standards or directives require documentation that may substantially increase the level of detail. The FHAs and facility assessment reports may be combined, provided that they address all essential elements. To facilitate the development of graded fire hazards analyses, the DOE Fire Protection Web Site contains copies of "models" of separate and combined FHAs and assessment reports. These models are located at the following URL: http://www.hss.energy.gov/nuclearsafety/nsea/fire//models/models.html

An FHA is required for all Hazard Category 1, 2 and 3 nuclear facilities (as defined in DOE Standard 1027), high-hazard facilities as determined by the AHJ, significant new facilities, and when required by the DOE Field Element. This requirement includes planned facilities as well as renovations to existing facilities as determined necessary by the AHJ. NFPA 801 also requires a graded FHA for radiological facilities that exceed the thresholds in 10 CFR Part 30. Examples of facilities not generally requiring an FHA include small utility buildings, trailers, and small office buildings. For new construction and major facility modifications where an FHA does not already exist, development of a design analysis is acceptable.

An analysis of planned facilities requiring an FHA should begin early in the development phase to ensure that an acceptable level of protection is being incorporated in the evolving design, including building placement, height, area per floor, emergency access, construction materials, fire areas, and other fire related details. This project or preliminary FHA (typically called a PFHA) should be updated whenever significant changes occur and should form the basis for post-construction FHA. The analysis shall also support the conclusions of a preliminary Documented Safety Analysis (DSA) where required. For significant new facilities that are not considered hazardous, the PFHA serves to guide the construction process and provide historic documentation but post construction FHA reviews and revisions are not required.

[A Fire Protection Design Analysis should be developed for all major new projects, Hazard Category 1, 2 & 3 nuclear facilities, radiological facilities, high hazard and explosive facilities, or

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when directed by DOE. The analysis should address the following topics 1) Introduction, 2) General Information (document and memo references, drawing references, definitions, and applicable DOE Orders & standards, and mandatory codes and standards, 3) Building details (property values, estimated fire loss potential, construction, detailed description of occupancy, process & other hazards, description of safety class or safety significant systems, utilities, exposure hazards, building specific fire protection features, proposed fire protection upgrades if applicable, post fire recovery plan, and life safety) 4) relevant site-wide fire protection systems (water supply & distribution system, fire alarm reporting system, fire protection system IT&M including record keeping, impairment control, fire department services, other emergency management operations, and security and safeguards considerations, 5) verification that the design complies with the objectives of DOE Order 420.1B, including sub-elements 6) fire protection system requirements, 7) compensatory and/or fire safety measures required during the construction phase, 8) fire control measures, 8) the need to a higher standard of fire protection in order to meet HPR, Safety Basis or other identified special needs, recommendations to address deficiencies in the design or construction process, and 9) a description of the use and associated hazard of each room or area when appropriate.]

The FHA must be performed under the direction of a qualified fire protection engineer (Reference DOE-STD-1137-2007, Fire Protection Engineering Functional Area Qualification Standard.) This should include directing all of the technical aspects of an FHA’s development including support from emergency services, systems, electrical, and mechanical engineers, as well as operations staff as needed. DOE-STD-1137 applies to Federal personnel and builds upon prerequisite OPM standards and professional engineering registration criteria. If adapted for use by contractor fire protection engineering staff, OPM and PE criteria should be included.

An FHA should contain, but not be limited to, a conservative assessment of the following fire safety issues:

a) Order, code & standard drivers b) Description of mission and associated hazards c) Description of construction d) Description of critical process equipment e) Description of high-value property f) Description of fire hazards g) Description of operations h) Potential for a toxic, biological and/or radiological incident due to a fire i) Natural hazards (earthquake, flood, wind, lightning, and wildland fire) impact on fire

safety j) Damage potential: Include both the Maximum Possible Fire Loss (MPFL) and Maximum

Probable Fire Loss, including the basis for the conclusions

DSA design basis fire scenario

a) Fire protection features, including special fire protection features, and fire protection features classified as Safety Class or Safety Significant.

b) Protection of essential safety class systems

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c) Life safety analysis d) Emergency planning e) Fire Department/Brigade response (may be discussed and evaluated in a stand-alone

site wide document) f) Recovery potential g) Security and Safeguards considerations related to fire protection h) Exposure fire potential and the potential for fire spread between two fire areas i) Effect of significant fire safety deficiencies on fire risk j) Environmental impacts from a fire including suppression system run-off considerations

A graded approach may omit some of these topics but it should be clear that omission was intentional.

The FHA should evaluate the consequences of a single, worst-case automatic fire protection system malfunction; eg., failure of detection system used to activate a pre-action type sprinkler system, and transmit an alarm to the site emergency response force; or the failure of a valve in the underground main that could impair multiple systems, either in the same building or in adjacent buildings evaluated as an exposure.

The FHA must address findings, and where appropriate provide a path forward for resolving the finding. It is recommended the FHA in addition to discussions of findings and recommendation found within the body of the report provide a listing of findings and associated recommendations in table format. This is to avoid the potential for findings and associated recommendations to become lost. A distinction should be made between mandatory recommendations including those listed as general industry practice and those proposed as a matter of preference.

The focus of the Fire Hazards Analysis should be the individual fire areas that comprise the facility. A fire area is defined as a location bounded by fire-rated construction, having a minimum fire resistance rating of two hours, with openings protected by equivalently-rated fire doors, dampers or penetration seals. It cannot be assumed that a two hour rated boundary is sufficient to contain a worst case fire. Compliance with the building code may require 3- or 4-hour rated free-standing boundaries, without openings, designed to prevent failure in the event the structure on either side collapses. The boundaries of exterior fire areas (yard areas) should be as determined by the AHJ or delegated authority. Where a facility is not subdivided by fire-rated construction, the fire area should be defined by the exterior walls and roof of the facility. In production facilities, conveyor and trolley systems may pass through credited fire walls or barriers. In some instances the design and operation of the equipment may preclude the use of fire dampers and similar devices. Such installations in new construction may require fire testing and taking credit for all features (non-rated fire dampers, metal construction, the use of fire rated glass in addition to confinement control glass, etc.) of the conveyor/trolley design that will impede fire spread from one fire area to the adjacent fire area.

In determining the adequacy of fire rated construction, especially where the facility structure or confinement system is being credited with preventing or limiting a radiological release, it is important to fully estimate fire load within the facility, including transient, process equipment and facility construction materials that are combustible. Example, a large process piping system

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constructed of plastic piping could result in a large fire load, one which might challenge one or two hour fire rated construction.

An important element of an acceptable FHA for nuclear facilities is an inventory of all safety class and safety significant systems within the fire area that are susceptible to fire damage.

All credible fire-related failure modes of safety systems should be considered. It should be noted that such systems may be active or passive. In the case of certain passive safety class or safety significant systems the need for fire protection may not be required. This can arise in the case of concrete vehicle barrier systems, or drainage systems. Such systems would generally be immune from fire damage by the nature of their construction, and thus would not require protection by an active fire suppression system. The analysis must determine whether fire can have a credible impact on the safety class or safety significant system such that the systems credited safety function is compromised.

Fire propagation and the potential for fire-induced radiological dispersal through the facility should be considered. These effects should be considered for the normal operating mode of the air distribution system as well as alternate modes, such as shutdown, that may result from the fire. In nuclear and radiological facilities ventilation (air flow) is from the least contaminated to the most contaminated areas. In large facilities this could represent a challenge for emergency responders should the fire originate in a lower contaminated area. Consideration should be given as to whether such an event could compromise fire fighter response, or would the facility’s layout permit alternate avenues to gain access to the fire area

While not usually needed, a tool that may be used in the development of an FHA is a fire model, such as those developed by the National Institute of Standards and Technology, as applied by qualified fire protection engineers, and approved for DOE use as a Toolbox code. This includes the CFAST Fire Model and other models in the following web site: http://www.hss.energy.gov/csa/csp/sqa/. All assumptions used in a model should be listed in the FHA and limiting conditions of operation or specific administrative controls established to assure that these assumptions produce reasonably conservative results . Also note that small variations in an assumption can have a major impact on the outcome. For example, assuming a door is closed might reduce fire intensity by half, but there is no assurance that the door will remain closed throughout the life of the facility. Because of their limitations and potential for errors The use of fire, models to estimate the potential effects of fire in nuclear, radiological, high hazard and other facilities which potential offsite and worker consequences should be limited to persons highly qualified in the model’s use. Results or outputs from the model should be approved by a qualified fire protection engineer who is knowledgeable on the use of the model. . In all cases the output of the model should be compared with expected fire dynamics. Where the model’s output does not match normally expected fire dynamics, the models output should be suspect.

As a general rule, nuclear, radiological, high hazard, explosive, and certain other facilities may require a higher standard of fire protection than that normally accepted for general industry, and in some cases above that considered acceptable for HPR facilities, including the use of safety class and safety significant fire protection systems.

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The analysis may rely on actual fire testing or historical data on fire events both inside and outside the DOE Complex, provided that adequate documentation of such information is available for the AHJ’s review.

The quantity and associated hazards of flammable liquids and gasses and combustible liquids gasses and other materials may be found within the fire area should be factored into the analyses. Consideration should also be given to the presence of transient combustibles associated with storage and maintenance activities. , When conditions prevent employment of normal fire protection features such as automatic sprinklers, noncombustible construction, and fire resistant boundaries, the FHA should quantify fixed combustibles and their locations and determine limits and locations of transient combustibles. These limits are usually enforced through formal combustible loading programs with permits for each combustible material brought into the area. Averaging combustible loading throughout a space as a means to characterize the fire severity is not considered an acceptable technique since localized severity, vulnerability, and combustible loading may vary significantly from the average.

FHAs for high-bay locations should consider the effects of smoke/hot gas stratification that may occur at some intermediate point below the roof or ceiling as well as the potential for delayed sprinkler response. Similarly, the effect of smoke movement through doors and dampers held open by fusible links should be addressed.

FHA Incorporation: The FHA, including all assumptions, should be documented. When both an FHA and a safety basis document (BIO, DSA, or SAD) are developed for a facility, the developmental effort should be coordinated to the maximum extent possible to avoid duplication of effort. It is recognized, however, that because an FHA is based on the premise that a fire will occur and considers a variety of fire issues (property loss and program interruption potential) that are not normally considered in the DSA, the conclusions of the FHA may be more for the facility as a whole while the DSA may be more conservative for a specific process. For example, the FHA may assume that building sprinklers are sufficient for fixed and transient combustibles but the DSA may rely on combustible controls to limit fire exposure in a specific area. Nevertheless, the FHA and its conclusions should be addressed in the facility DSA in such a manner as to reflect all relevant fire safety objectives as defined in Chapter II, Section 1 of DOE O 420.1B. As a general rule the FHA must be developed so as to provide input into the DSA. Thus some portions of the FHA may be developed early in the safety basis development process, and in some cases con-currently with the safety basis development process. However, in no case should the FHA be back-fitted so that results of the FHA correspond to results of the safety basis documentation.

Information related to emergency response (number of emergency responders, number and types of apparatus, response time, etc.) should be incorporated into the safety basis documentation as a means of clearly establishing a “floor” below which this level of capability should not be reduced. This information may be discussed in a separate stand-alone evaluation of the site’s fire department services.

The FHA must address/define the specific DOE Order, Standard or mandatory code and standard requirements that are applicable to the facility. Non-compliances to these

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requirements must be 1) addressed immediately or in the near-term, 2) a corrective action plan must be developed to resolve the deficiency (the CAP will in some instances require DOE approval, or relief in the form of an exemption, equivalency or variance must be obtained from DOE.

6.9 D&D Facilities D&D facilities are those that have been deactivated, i.e. placed in a safe-shutdown condition and vacated, or are undergoing decommissioning to the ultimate end state through decontamination, dismantlement or demolition. The need for fire protection features in these structures is governed by the consequences of a fire to the public, workers, and fire fighters as well as the potential release of hazardous and radiological materials while the facility is in the transition process. Since property protection and program continuity are not always factors in a D&D facility, all DOE fire protection requirements may not be necessary or appropriate. Factors, which should be considered, center on the transition itself, such as fire protection equipment removal, and the impact that this transition has upon fire protection features and activities. Such factors are additionally important if the facility possesses a definable value and/or mission as determined by the DOE program office; or, if a fire would significantly increase the cost of the D&D process, e.g., destroy vital equipment required for D&D activities, delay transition commitments, or undermine public confidence. , increased cost of clean-up.

It should be noted that considerable cost savings(electric, heating, IT&M) may be realized when combustibles within D&D facilities are reduced to near zero which in turn permits impairment of the building’s fire suppression and alarm system.

A D&D Fire Plan should be developed for facilities undergoing transition to D&D status, including “Cold & Dark.” The D&D fire plan should address the following:

• Facility construction, including interior finish

• Fire protection features, their status, and plans for deactivation

• Potential need to restore system to service for D&D

• Facility hazards

• The removal of combustibles, including flammable or combustible liquids

• Periodic monitoring

• Appropriate signage showing status of facility and FP systems

• Securing the facility from unauthorized entry

• Requirements for performance of D&D activities

• Maintaining worker safety

• FD notifications

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Other pertinent information as necessary

Fire safety and emergency response for transitional facilities are governed by the requirements contained in 10 CFR Part 851 (including 29 CFR Part 1926) and the provisions of NFPA Standard 241, Safeguarding Construction, Alteration and Demolition Operations. (See also Factory Mutual Data Sheet 1-0 Safeguards During Construction, and Chapter 8 of NFPA 801, Fire Protection for Facilities Handling Radioactive Material.)

Decisions relating to fire safety of such facilities should be made on the basis of the following principles, with key aspects being captured in the D&D Fire Plan:

• The evaluation of fire risks imposed by the work in relation to the need for traditional fire safety features. The facility’s FHA may be utilized where applicable to complete this evaluation. This can be accomplished through a graded fire hazard analysis that has been reviewed and concurred with by the AHJ. All requests for relief should be processed in accordance with DOE procedures. Approved relief from normal DOE requirements should be listed on the signature page.

• Fire hazards within these facilities may change over time, such as an increase in combustible loading during abatement activities. Fire protection should be adequate to deal with these changes. The FHA together with updated pre-incident plans should account for this either through a phasing schedule, or be revised as appropriate when significant changes in occupancy or hazard occur that affect fire safety.

• Fire safety features that have originally been required by DOE may be rendered inoperable or considered no longer needed if justified by the FHA provided that the safety of D&D workers and emergency responders will not be compromised. Such features may be abandoned in place (and properly identified as being out of service) until they are dismantled as part of planned demolition activities.

• The decision to deactivate automatic fire suppression systems in large facilities should consider the possibility that fire department personnel may not be able to safely enter the facility to effect manual fire suppression. If DOE concurs that such an approach can be done safely without undermining public confidence, a defensive tactical approach, , i.e. exterior fire attack and protection of exposures, should be a part of the BNA described in Section 4.9 of this Guide and written into the fire department’s updated pre-incident plan. Such an approach necessitates additional emphasis on maintaining communication and cooperation between facility personnel and the fire department so that emergency responders are aware of changes in occupancy and fire protection system status.

• Retained fire protection features in these facilities are not required to comply with all of the design and installation criteria of the governing NFPA standard if the AHJ concurs that the system will function adequately during a fire in its altered design mode. The AHJ concurrence should be documented in accordance with site procedures.

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• Retained fire protection features should be inspected, tested and maintained to ensure that the features will function adequately during fire incidents, based on the facility’s past missions, hazards which remain, and the facility’s transition status..

• D&D facilities should be routinely inspected and reviewed by representatives of the fire department and fire protection engineering staffs consistent with established standard operating procedures and fire protection program criteria. Tours of facilities should also be conducted by the fire department to familiarize them with existing conditions and to revalidate pre-incident plans. Drills and training exercises should also be conducted at these locations at an appropriate frequency commensurate with the fire risks and complexity of the facility.

• Prior to commencement of work activities in a facility the D&D Fire Plan should be updated, or, appropriate procedures should be approved and implemented (including worker training) governing the control of potentially hazardous operations including, but not limited to, cutting and welding, storage and handling of flammable or combustible liquids, transient combustibles, and sources of ignition such as temporary wiring and heating equipment. Smoking areas, when allowed on the premises, should also be established.

• The fire risks associated with materials and processes used as part of the transition process should be evaluated by a fire protection engineer. Fire protection features should be adequate to limit these risks to an acceptable level. Combustible supplies required for D&D should be limited to a one day supply within the D&D facility unless automatic sprinkler protection is being maintained. Facilities for the storage of combustible D&D supplies should be stored outside and away from the structure using connex shipping or other similar storage arrangements.

• The deactivation of process lines containing hazardous materials as well as flammable or combustible liquids should be preceded by an analysis or performed under a work plan that addresses the methods used to control related hazards during the deactivation process. Appropriate safeguards need to be in place to control and minimize the release of residual materials that may remain in piping and tanks.

• Safeguards to assure D&D worker and emergency responder safety and health are expected to conform to the requirements in 10 CFR Part 851, and the requirements for buildings under construction or demolition, as provided in NFPA 241, Standard for Safeguarding Construction, Alteration, and Demolition Operations, unless relief has been granted by the AHJ. In buildings where regular tours and inspections are conducted, adequate exits and lighting must be provided as a minimum as required by NFPA 101. Compensatory measures should be established whenever routine surveillance is being performed in these facilities. These measures should be approved by the site fire authority. Locked D&D and abandoned facilities where there is no human occupancy do not need to maintain emergency egress features.

• Where no automatic system exists, an effective means for manually summoning the fire department and for communicating with personnel inside of a building is required. This can take the form of exterior fire alarm pull stations or call boxes, telephones (fixed or mobile), radios or some combination of the above based on the accessibility of the devices to all personnel and their reliability. However, in accordance with NFPA 101, all egress features must be reviewed once the facility is reopened for actual demolition activities. Stairwells should be inspected on a

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routine basis and maintained accessible, clear and dry in the event firefighting activities are required.

• All retained interior fire protection systems should be maintained operational to the extent possible while interior work activities are taking place. The sequence of removal of these systems should be clearly spelled out in contractor requirement documents and the FHA. Verification of operable status should include appropriate inspection and testing in accordance with established procedures. Sprinkler systems should be retained until all fixed and transient combustible materials have been removed. Where it is economically feasible wet sprinkler systems may be converted to dry systems to minimize heating needs. Any temporary deactivation of fire protection features during transition operations should be treated as an impairment, with appropriate interim compensatory measures implemented until the feature is returned to full operational mode pending final demolition. It should be noted that during winter months where limited heating is provided within facilities undergoing D&D it may be impossible to prevent sprinkler and standpipe system freezing due to the potential for hidden piping and piping low points which may not drain, or that cannot be economically be drained . Deactivated systems deteriorate rapidly. Fire suppression systems should not be removed from service for a prolonged period with the intent to restore protection for safety of workers when final disposition is funded.

• The site and facility fire water distribution system, including hydrants, fire department connections, and interior standpipe systems, should be maintained in an operable state. Access for mobile apparatus for emergency response should be maintained and verified on a frequent basis. (Refer to fire department pre-incident fire plans.)

• To the extent that the FHA validates the need to maintain fire protection features during transition activities, such features should be inspected, tested and maintained, consistent with established procedures, sufficient to ensure that they will function effectively during a fire, based on their intent during transition. Defects or design deficiencies that are not essential to ensure liability and effective performance, as determined by the AHJ, may remain as is.

Firefighting procedures may be developed and maintained in conjunction with efforts governing fire department procedures in general. DOE and contractor management should be kept routinely informed if fire department emergency operations for these special circumstances represent deviations from the norm. FHAs and/or DSAs should reflect unique fire-fighting strategies where rapid intervention may not be possible (moderation controlled areas) demolition activities have made the facility unsafe for entry in the event of fire, and where fixed fire protection systems may no longer be in-service, or of limited value.

6.10 Fire Protection Assessments Note: assessments may be combined with FHAs to form a single comprehensive document. When combined assessments are used, the resulting documentation must capture the key elements that should be contained in both an FHA as well as a fire protection assessment.

The principal objective of a fire safety assessment is to verify adequacy or identify deficiencies of fire protection programs.

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Facility and programmatic assessments should be performed under the supervision of a qualified fire protection engineer. Personnel conducting such assessments should have an appropriate level of knowledge and experience in the application of fire safety codes and standards in diverse facilities. Assessments should, as a minimum, encompass the following elements of the fire protection program:

1) Program Related (performed by both DOE and contractors): a. Comprehensiveness of the fire protection program b. Fire protection program procedures and policies c. Assessment process addresses compliance with fire protection related Rules,

DOE Orders, Standards, and mandatory codes and standards 2) Procedures for engineering design and review

a. Procedures for maintenance, testing, and inspection of installed fire protection systems and features

b. Fire protection engineering staff (number, qualifications, training) c. Emergency Services Organizations including the BNAs d. Management support e. Exemptions and documented equivalencies or deviations

3) Facility Related (principally, but not exclusively contractor self-assessments and DOE operational readiness reviews):

a. Fire protection of safety class and safety significant equipment b. Life safety considerations c. Fire protection of vital programs d. Fire protection of high-value property e. Fire suppression equipment

o Water runoff

o Facility fire prevention planning documents (evacuation plan/fire wardens extinguisher training)

o Fire apparatus accessibility

o Completeness of fire hazards analyses

o Fire barrier integrity

o Completeness of fire loss potential (MPFL) determinations

o Fire safety training

o Potential for toxic, biological and /or radiological incident due to fire

Combined Aspects (Program and Facility):

o Conformance with applicable Orders, codes and standards

o Inspection, testing, and maintenance Fire protection system Impairment process

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o Adequacy of facility appraisal o

o Administrative controls

Findings/Issues management process (tracking from discovery to closure) Temporary protection and compensatory measures

Annual fire protection assessments should be made of facilities valued in excess of $100 million, facilities considered a high hazard, or those in which vital programs are involved as defined by DOE.

Remaining low and ordinary hazard facilities should be assessed at least every three years or at frequencies determined by the AHJ. The schedule for facility assessment s shall be submitted to DOE for approval every three years. For groupings of small light or ordinary hazard facilities supporting the same mission it may be appropriate to assess all facilities at one time.

Comprehensive assessments of fire protection program elements by DOE and by contractors should be made every three years. These should be staggered so as to permit an in-depth review, as well as to minimize the resource impact that may occur on the Operating Contractor as a result of the assessment process.

Assessment reports should include a description of what was accomplished during the effort (areas toured, documents reviewed, and people interviewed). It should feature a "baseline" description of the facility, ordinary and special hazards and other occupancy considerations, and fire protection features. In addition, the report should document changes of significance that have occurred within the facility since the last assessment that affect fire safety, and it should list all noted deficiencies, along with a recommendation for remediation and interim compensatory measures, if necessary, pending resolution. A "model" assessment report is available at the following web site:

http://www.hss.energy.gov/nuclearsafety/nsea/fire//models/models.html.

DOE assessments of contractors are intended to confirm that comprehensive fire protection programs are in place site-wide. They should include a select review of facility and site fire protection features, fire safety policies and procedures, design oversight, fire protection system Inspection, Testing, Maintenance, Impairment activities and procedures ,the qualifications of contractor fire safety professionals, the adequacy of self-assessments, fire hazards analyses, and program performance as detailed in this guidance and other DOE Orders/ Manuals such as DOE O 226.1, Implementation of DOE Oversight Policy, and Table F-2 (Program Performance Measures) of DOE M 231.1-1A, Environment, Safety and Health Reporting Manual.

Additionally, it is expected that DOE assessments include capabilities to respond in a timely and effective manner to site fire emergencies and related events. This assessment responsibility includes contractors at sites where there is no site fire department or brigade and where effective emergency response relies on outside resources, such as offsite fire departments.

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6.11 Corrective Action It is expected that the corrective action process will encompass all fire protection "findings"; opportunities for improvement, violations or issues by any other name that require, e.g., facility, program, and emergency response. When modifications that are necessary to correct significant fire safety deficiencies will require more than one week, it is expected that interim compensatory measures (such as fire watchers) be provided until the modifications are complete. Compensatory measures should be initiated without delay commensurate with the finding and at the discretion of the AHJ.

Significant findings (life threatening or with a serious injury potential) from these assessments will be the basis, in part, for contractor entries into the Noncompliance Tracking System that is a component of the enforcement process required through 10 CFR Part 851. All other findings and recommendations should be entered into the Contractor’s issues management process which should track findings and associated recommendations from identification to closure. Significant and/or complex recommendations, and those that are expected to take a number of years to correct should require the development of a Corrective Action Plan (CAP).

6.12 Exemptions Variances & Equivalencies (Approved Requirement Relief) The DOE directives system and the requirements of 10 CFR Part 851 impose a range of explicit direction in the development, review, and approval of exemptions, variances and equivalencies as delineated below. Contractors are advised to consult with the AHJ before proceeding with a request for relief. One goal is to avoid unnecessary duplication of effort and the generation of unnecessary paperwork.

DOE M 251.1-1B, Departmental Directives Program Manual, states:

If the Order, Notice, or Manual includes specific provisions for exemptions, equivalencies, or other forms of relief from the requirements in the document, then those provisions must be applied. If the document does not include specific provisions for relief, the process in this chapter [of DOE M 251.1-1B] applies to granting permanent or temporary relief from the applicable requirements in those documents.

With respect to exemptions to the provisions of DOE O 420.1B, paragraph 6a of that Order states:

Exemptions to this Order (DOE O 420.1B) must follow the process defined for exemptions in DOE M 251.1-1B, Departmental Directives Program Manual, except for the approval authority defined in the responsibilities paragraphs of this Order.

DOE O 420.1B assigns the authority to grant exemptions to the provisions of DOE O 420.1B to the Secretarial Officer, unless delegated. Furthermore, a granted exemption to DOE O 420.1B is not considered an exemption from all other DOE directives or statutory requirements, such as 10CFR 851, that may have similar requirements or be affected by such relief. Please refer to the DOE directive or statutory requirements for information on exemption processing of the affected document.

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With respect to requests for relief from NFPA Code provisions, paragraph 6b of DOE O 420.1B states:

Exemptions, exclusions, and equivalencies to standards or other documents referenced in this Order should follow the provisions explicitly set forth in those documents; for example: the equivalency, alternative, and modification provisions in the NFPA Code.

Paragraph 5d(10) of DOE O 420.1B assigns the AHJ responsibility, and therefore the authority to approve equivalency decisions in accordance with those provisions, to the head of field elements with a notation to ensure that fire protection SME comments are addressed.

The following table summarizes types of deviations and approval authority.

Source of Requirement

Name of Deviation Approval Authority Concurrence Exceptions

10 CFR 851 Variance Deputy Secretary HSS, Undersecretary, CTA

Deminimus

DOE O 420.1X Exemption Assistant Secretary HSS (except for NNSA), CTA

DOE O 420.1X Equivalency Undefined Undefined

National Fire Codes Equivalency Field Element Manager

As directed

National Fire Codes Exemption Assistant Secretary HSS (except NNSA), CTA

Building Code Alternative Building Official (Undefined)

Undefined

Building Code Exemption Assistant Secretary HSS (except NNSA), CTA

Deviation from 10 CFR 851 is called a “variance.” The process for requesting and approving variances from the provisions of 10 CFR Part 851 is delineated in the Rule and in supplemental guidance promulgated by DOE. Consult the following web site for this information:

http://www.hss.energy.gov/HealthSafety/wshp/rule851/851final.html

Deminimus deviations do not require a variance but should be addressed in the FHA or other DOE approved analysis.

The Operating Contractor shall have in place a process for developing, internal approval, and submittal to DOE for approval exemption, equivalency, deviation request to Rule, Order, Standard, and mandatory code and standard requirements.

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The Heads of Field Elements should have in place a procedure or policy for processing requests for relief to DOE exemption, equivalency, deviation request to Rule, Order, Standard, and mandatory code and standard requirements.

Building codes, National Fire Codes, and a number of other national standards are required by 10 CFR 851 or DOE directives such as DOE O 420.1X. Deviations from these codes and standards are deviations from the DOE rule or order and must follow the approval process for the rule or order. However, codes and standards of NFPA and the building code allow for an equivalent or alternate means of achieving compliance with the code or standard. “Equivalencies” must be equal to or better than the underlying requirement and are considered to be in compliance with the code or standard. Where no equivalent or alternate means for achieving compliance is provided, or the alternative is not equal to the requirement, deviation from an applicable NFPA code or standard or the building code must be processed as an exemption to DOE O 420.1B , or, if worker safety is involved, it must be processed as a variance to 10 CFR 851. Combining variance and exemption requests is not encouraged due to the complexity of variance approval and the fact that variances issued to a contractor are voided when the contract is transferred. The Operating Contractor shall maintain a permanent list of minor technical deviations to which it grants relief.

Documented requests for relief should be developed by a qualified fire protection engineer or certified fire department officer and submitted through the AHJ to the appropriate reviewing authority. Documented approvals should be kept on file in an auditable form. When approved by the Field Element, multiple related deviations can be grouped by individual code or standard, or provided that the specific conditions are explicitly identified. A single request for relief addressing multiple issues within a single facility may also be acceptable.

The Heads of Field Elements may approve equivalencies to DOE Order and Standard requirements. To be approved the request for relief must clearly show that the proposed action provides a level of protection to that specified in the Order or Standard. Where this cannot be shown the request for relief must be processed as an exemption.

The level of documentation necessary to support a request for relief will vary depending on the issue. As a minimum, each request should identify the specific site location or condition at issue and the paragraph/section of the code or standard which addresses the issue; discuss why the requirements of the code or standard that cannot or should not be met , including benefits that are to be gained by approval; identification and justification of the acceptance of the threat or threats that will be incurred if the request is granted, justify the conclusion that the alternate configuration is acceptable from a safety, environmental, property damage, or program continuity perspective to what is stipulated in the code or standard; and discuss other pertinent data or information that supports the request for relief. All functions should also be addressed. For example, an automatic sprinkler system provides detection, local alarms, fire department notification, and fire suppression. The description of alternatives in an equivalency should address each of these functions. Additionally, relief under one source document is not considered relief from another. All codes and standards with similar requirements should be identified and any differences addressed accordingly. For example, automatic sprinklers may be required for property protection by DOE directives, for life safety by NFPA 101, for nuclear

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safety by NFPA 801, and for public safety by the building code. A request for relief from the requirement for sprinklers must justify deviation from each standard as well as from the directive and the building code.

Request for relief to environment, safety, and health requirements may require additional information including, but not limited to, special circumstances that may warrant granting the relief, application of the requirement results in a conflict with other requirements, application of the requirement in this instance is not likely to achieve the underlying purpose of the requirement, application of the requirement in the particular circumstance would not be justified by any health or safety benefit, and a description of any alternative or mitigating action that will be taken for protection of workers and which supports granting the requested relief.

When a positive determination is made in support of relief, then documentation should include signatures of all those involved in the decision, including that of the cognizant DOE fire protection engineer. The letter transmitting the request for relief may be used to impose limitations on the applicability of the relief given, that approval of the relief is based upon documentation submitted by the Operating Contractor, require commitments within the request for relief to be complied with, establish conditions of approval (COAs), etc,

A change in use or occupancy usually requires bringing a facility up to current codes and standards, voiding all exemptions, equivalencies and variances. Re-evaluation and resubmittal of requests for relief for the same deviations must clearly explain why the facility deviations could not be corrected during the conversion. A failure to follow request for relief commitments to which the Operating Contractor committed or a failure to comply with COAs may result in the request for relief being voided.

When approved by the Head of Field Elements as a matter of policy, a request for relief, other than for Rule 851 requirements, is not required when the following conditions are met:

1) A Corrective Action Plan which will lead to correction of the deficiency has been developed and approved by DOE;

2) A funding source for the CAP has been identified; 3) Resolution of the deficiency will take three years or less, or the corrective action is

included in Line-Item Funding; and 4) Compensatory measures are developed and implemented as appropriate

Requests for relief where corrective action is planned, but which do not meet the timelines established above should be processed as a temporary exemption.

The temporary exemption process should be employed when corrective action is planned but may take several years to implement, the issue is of a short-term duration, the facility in question has a very short continued operational life of three years or less, and similar circumstances.

All approved variances, equivalencies and exemptions to DOE directives should be provided or referenced within the FHA or FPA document itself along with all supporting information.

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Documentation related to approved relief should be reviewed during the FHA and/or FPA update to verify that conditions have not changed and the justifications are still valid. Additionally, such considerations may have other conditions for review according to a specified schedule, which should also be documented in the FHA. If there is no FHA or FPA for the facility, appropriate reviews and documentation should be consolidated and maintained with the fire protection staff for review by the AHJ or representative. The approved request for relief should be reviewed to determine if Conditions of Approvals and any other requirements associated with relief approval are being complied with.

The Operating Contractor should maintain a master list of all requests for relief submitted to DOE for approval, the nature of the request, date of request, and DOE action, including Conditions of Approval that may have accompanied the request.

6.13 Leased Facilities Prior to signing any lease agreement, sites should:

• Perform a fire protection assessment of the facility to verify the adequacy of life safety and fire protection features of the space including limiting the limit the loss of government-owned equipment to limits established by the DOE and potential mission interruption. This review may use a graded approach depending on DOE and joint tenant occupancy classifications

• Participate with the local jurisdiction’s fire department to ensure a pre-fire plan is in place.

• Define how fire-protection deficiencies within the leased space will be processed and funded both prior to (such as installing special extinguishing systems to address a DOE value or safety thresholds), or post occupancy (such as general maintenance upgrades).

• Participate with the local jurisdiction on coordination of evacuation plans.

• Define the frequency of DOE/owner conducted fire protection assessments. A graded approach may be taken to establish the frequency. In general, the owner would be responsible for “off-site” leases in accordance with local jurisdictions and the contractor for “on-site” leases.

• Specify in the lease agreement the DOE/owner responsibilities for inspecting, testing, and maintaining (ITM) of facility fire protection systems in accordance with local jurisdiction building and fire code requirements. In general, the owner would be responsible for “off-site” leases and the contractor for “on-site” leases.

• Where applicable, the lease agreement should specify how the maximum allowable quantities of hazardous material defined in the building code will be apportioned to the DOE contractor and to any other tenants in the building. Thus, the leased building’s fire safety control areas should be documented. All fire protection assessments and ITM records should be accessible to the local Authority Having Jurisdiction, the owner and DOE contractor

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The DOE should communicate all fire protection deficiencies within the facility/structure to the owner. It is recommended that those deficiencies that potentially impact life safety, and DOE owned equipment and associated mission be tracked until their resolution.

All fire protection assessments and ITM records should be accessible to the local Authority Having Jurisdiction, the owner and DOE contractor

7 EMERGENCY RESPONDER GUIDANCE The following paragraphs describe in broad terms the approach to achieve the objectives of an emergency response program: Contractors can achieve a comprehensive, multi-faceted emergency response capability in a number of ways. They can rely on an on-site emergency services organization, such as the fire departments and fire brigades that currently exist at many DOE sites; or they can rely completely on off-site fire departments to meet DOE determined response objectives. Contractors can also combine the capabilities of both on-site and off-site emergency services organizations so as to assure the timely and effective response to the spectrum of emergency conditions (fires, medical emergencies, technical rescue, hazardous material response, etc.) that they may encounter (e.g., mutual aid agreements).

When no site fire department or brigade exists and when reliance will be placed on off-site fire departments, a plan should be developed that details how such forces will be expected to respond in conjunction with the site emergency plan and how appropriate training and site familiarization will be provided to ensure that the off-site fire departments will be prepared for fires that occur on site. Appropriate drills should be performed periodically to verify the effectiveness of the plan. Contingency plans should be made in the event off-site responders are not available, e.g., at one site the state governor prohibited state and municipal forces from responding to a DOE site after a serious fire spread out of control, even though agreements were in place.

Emergency response records must conform to DOE reporting requirements in DOE O 231.1A, Environment, Safety, and Health Reporting, and should be based on standard fire incident reporting practices, such as the National Fire Incident Reporting System (NFIRS) or NFPA 901, Standard Classifications for Incident Reporting and Fire Protection Data, in lieu of state or site-specific reporting formats.

DOE site emergency services organizations considered to be career fire departments shall apply all appropriate NFPA Standards, including the Standard for the Organization and Deployment of Fire Suppression Operations, Emergency Medical Operations, and Special Operations to the Public by Career Fire Departments (NFPA 1710).

Other related emergency response organizations (such as brigades or emergency squads) should maintain current files with all standard operating procedures and fire pre-incident plans, firefighter training and certification programs, and appropriate documentation governing related

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activities. The level of documentation should be reasonable and commensurate with the contractor’s responsibilities. A program should be in place to ensure that this documentation is updated at appropriate intervals.

7.1 Fire Department Resources

7.1.1 Stations DOE Site fire stations, where provided, should be designed to provide sufficient capacity for mobile apparatus, including maintenance functions. Living quarters should provide a comfortable, private and safe environment for personnel, consistent with state or NFPA requirements. This includes adequate sleeping quarters where necessary (when personnel are working more than a 12-hour shift), kitchen facilities, training rooms, physical fitness areas, and other ancillary needs. To the extent that related occupancies such as alarm rooms, maintenance rooms, and personnel areas are co-located within the same facility, appropriate fire-rated physical separation, ventilation and exhaust, and other fire protection features should be provided to prevent interference and to ensure the viability of individual areas in the event of a fire. All areas of fire stations should be provided with automatic sprinkler protection. All sleeping quarters should be protected with quick response sprinklers, smoke detection and carbon monoxide (CO) detection that are connected to transmit alarms locally and to the site central reporting location.

Fire stations should be "centrally" located to the facilities protected so as to minimize response time. Station location should also reflect prevailing traffic patterns, climatic conditions, railroad tracks and other sources of delay. Where multiple stations are provided they should be located near the site’s high risk facilities or areas while providing an acceptable level of fire protection for other facilities located throughout the site. Station location and resource allocation should also consider the hazard classification of the facilities, the actual fire threat to personnel, the facility, and its mission, the level of automatic fire suppression provided (the extent to which manual firefighting efforts may be required, traffic patterns, potential road bottle necks, and other factors as may be appropriate.

Emergency radio communication should be compatible with other organizations involved with emergency response and should be designed to be effective in areas subject to structural interference.

7.1.2 Fire Department Apparatus Fire department apparatus should reflect all site-specific response requirements, including those described in the first paragraph above. Other examples include hazardous material response, heavy rescue, rough terrain rescue, chemical or large flammable liquid spills, and wildland fire response. The selection of apparatus must consider potential need and frequency, and whether special apparatus having limited need would be available through mutual aid or other means. Reserve apparatus, if utilized, should be properly maintained and equipped to provide its intended response capabilities whenever first-line apparatus is out-of-service. Periodic replacement programs for apparatus should be structured to avoid excessive "down time" and repair costs and should reflect the industry norm of useful life cycles (e.g., 20 years). The apparatus replacement program should be scheduled over time so as to avoid peaks in

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apparatus replacement cost. Fire departments should be required to maintain apparatus response and mileage logs to assist in identifying inappropriate use of apparatus and in developing replacement schedules.

7.2 Staff The minimum number of trained firefighters necessary to begin interior structural fire-fighting should be five, in line with the longstanding DOE guidelines on NFPA 1500 implementation and OSHA’s 2-in, 2-out criteria. (It is recognized that, where lives may be at risk, the Incident Commander has the authority and responsibility to initiate rescue with less than this minimum if, in his judgment, it is safe to do so, for instance, in properties fully protected by automatic sprinkler systems.) Fire ground commanders may initiate fire attack actions when the additional required minimum staffing will be provided by responding second due apparatus. Additional emergency response personnel will be necessary where multiple hose lines are required to suppress a fire and to support other fire ground activities such as search and rescue.

The minimum number of personnel required for fire fighting, hazardous material incidents, specialized rescue or other related events should be based on NFPA guidelines, pre-incident fire planning where possible, and the judgment of trained and experienced Incident Commanders. Historical DOE guidance maintains that a minimum of 5 SCBA equipped emergency responders shall be available at the fire ground prior to any interior firefighting or other operations are attempted.

7.3 Training and Drills Training of emergency responders may be based on existing requirements such as those used by the state in which the site is located, those delineated in 29 CFR Parts 1910 and 1926, as well as criteria developed by the NFPA. In addition, emergency responders should be provided with sufficient site-specific training and familiarization necessary to effectively respond to the unique conditions that characterize DOE facilities. As part of this effort, regular facility tours should be conducted utilizing current pre-incident fire plans as well as to verify that plans are accurate. 1

Fire fighters and fire department officers should be certified under state programs when available, or when such programs are not available through independent certification processes when approved by the Head of the DOE Field Element.

Drills and exercises should be structured to emphasize realistic scenarios and feature standard fire department tactical evolutions. Such drills should also be scheduled, as appropriate, during weekends and evening shifts when normal activities are reduced.

Consistent with the training needs identified above, adequate facilities should be provided for training. This includes "live fire" training, confined space entry, vehicle extrication, hazardous material response, and other site-specific conditions. Where on-site training facilities are unavailable, arrangements should be made for appropriate training for fire department

1 Contractors subject to 10 CFR Part 851 must adhere to 29 CFR Parts 1910 and 1926 if these regulations are applicable to the hazards at their covered workplace. See 10 CFR § 851.23 (a)(3) and (7).

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personnel off-site at nearby city or county training facilities, or at regional or state training facilities.

7.4 Pre-Incident Fire Activities Pre-incident plans should be developed on the basis of NFPA 1620, Recommended Practice for Pre-Incident Planning, with input from the site fire protection engineering staff as well as emergency responders.

Pre-incident fire plan documents or comparable electronic versions shall be developed in accordance with standard practices within the emergency services community and DOE expectations, as reflected in published guidelines. For additional information and to access “model” documents that can be downloaded and edited, refer to the DOE fire protection web site at: http://www.hss.energy.gov/nuclearsafety/nsea/fire//models/models.html

7.5 Fire-fighting Activities involving special considerations Procedures on fire-fighting activities involving special hazards should be developed and maintained. FHAs and DSAs should reflect fire fighting strategies where rapid intervention may not be possible (e.g., moderation controlled areas) and where fixed fire protection systems may no longer be available as in D&D facilities (See Section 4.16 for further information).

Access to classified matter during an emergency must be documented after the emergency and individuals who were provided access must complete nondisclosure forms as required by DOE Manual (M) 470.4-4, Information Security.

7.6 Baseline Needs Assessment Emergency response organizations are expected to meet the DOE O 420.1B requirement for the completion of a Baseline Needs Assessment (BNA). In developing the BNA, the intent is that this be a coordinated effort involving the AHJ and the representatives of the site emergency services organization. Additional expertise in unique emergency response or fire prevention issues, legal matters, labor-related issues, emergency medical protocols, etc., may be required to assist in the development of the BNA.

If an on-site fire department or fire brigade will be relied upon to provide complete emergency services, the full scope of its capabilities including: mission responsibilities, personnel, apparatus, equipment, facilities, programs, incident reporting, etc., should be delineated in a BNA. The BNA should address compliance with the NFPA codes and standards and other requirements that define the character of its mission and responsibilities. (This does not mean that the BNA has to be written to confirm code conformance on the basis of line-by-line comparisons. A reasonable degree of documentation is expected.) It should also address applicable contract provisions and aid agreements with other contractors on site as well as off-site organizations. The goal is to capture in one document information that will confirm that the fire department is fully capable of meeting emergency response requirements and needs. Note that there is a “model” BNA that can be downloaded and edited, available on the DOE fire protection website at http://www.hss.energy.doe.gov/nuclearsafety/nsea/fire/models/models.html

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If a contractor will rely completely on (non-DOE) off-site emergency services organizations to satisfy the emergency response requirement, then the contractor should first define completely its emergency services needs against the services available by the off-site organization. This can be done via a BNA or comparable document, commensurate with the off-site organization’s responsibilities. This document should delineate what is required (capability), why is it required (hazards, accident potential, code requirements, etc.), and how this capability is assured by the off-site emergency services organization. Where the off-site emergency responders exclude fire fighting involving nuclear or other site hazards, the BNA should clearly describe integration of site and off-site efforts.

If a contractor will rely on a combination of on-site and off-site emergency services organizations, the contractor should comprehensively demonstrate that an adequate emergency response capability exists on the basis of some combination of the efforts described in 5.1.1 and 5.1.2 above.

The BNA should include organizational responsibilities, collateral duties, facility hazards, response time requirements, personnel levels, required apparatus and equipment. In addition, the document should describe the organization's various programs that support its personnel. This should include training, physical fitness, and medical programs relating to emergency responders.

In developing the BNA, the basic assumption should be that there is only one emergency incident occurring onsite, with a casualty requiring emergency medical assistance. However, the document should also describe how the fire department would respond if a second incident occurred while the first was underway. The second response capability could be based on documented mutual aid agreements and utilization of some percentage of off-duty personnel overtime. To the extent that an insufficient response capability is determined to exist for this second emergency, the BNA should address the required supplemental emergency response resources that would be needed to respond to this event. Where the Fire Department provides service to others, unless dedicated FD services are reserved for protection of the site, the BNA should address the potential for offsite fire response concurrent with a required on-site response, including the potential for delayed response or a resource limited response. The BNA should also review FD activities and permitted practices that may negatively impact response time or result in reduced staffing to site emergency calls.

A critical factor in any such analysis is the minimum response time necessary to begin active intervention (fire suppression, emergency medical, technical rescue, etc.) activities. The determination of a minimally acceptable response time should be based on risk and should reflect categories, such as alarm, call processing, dispatch, response, and turnout times that have been established in NFPA 1710. DOE expects that the response time requirements of NFPA 1710 be the starting point in the determination. Site specific conditions, such as the widespread installation of automatic fire suppression systems, could be used to extend response time to structural fires through the NFPA 1710 accepted equivalency process. Similarly, the provision of localized Automated External Defibrillators (AEDs) and first-aid supplies, along with appropriate employee training, could be used, in part, as a basis for extending Emergency Medical Service response times.

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7.6.1 BNA Incorporation Information related to the site emergency services organization, such as the number of emergency responders, number and types of apparatus, response time, etc. should be incorporated into the site emergency plans, FHAs, and DSAs, as appropriate, to clearly establish a “floor” below, which this level of capability should not be reduced without appropriate compensating safeguards and/or the restriction of hazardous operations. The level below which on-site fire department resources should not drop should consider whether mutual aid response would be timely given the sites location, as well as whether off-site fire fighters are prepared and willing to respond to fire events at the site, especially if fires might involve radioactive materials or other hazardous materials. This information can be inserted in summary fashion or the BNA can be incorporated directly into the above-referenced documents.

8 FIRE PROTECTION DESIGN GUIDANCE Design aspects of new DOE facilities as well as modifications to existing facilities must be based on the provisions of the applicable requirements of the Code of Federal Regulations (CFR), DOE directives, the model building codes, and the applicable NFPA and other national codes and standards. The design process should include appropriate oversight by a qualified fire protection engineer of plans, specifications, and testing of fire protection features.

DOE facilities, sites, and activities (including design and construction) must have a level of fire protection that is sufficient to fulfill the requirements of the best protected class of industrial risks (commonly referred to as "Highly Protected Risk " or "Improved Risk") and should be provided protection to achieve "defense-in-depth." This includes meeting the applicable building code and NFPA Codes and Standards and exceeding minimum requirements when necessary to meet safety objectives. The applicable codes and standards are those in effect when facility design is completed ("code of record"). If there is a delay of more than a year between design and construction, the design should be updated to current codes and standards.

When significant modifications to a facility occur, as determined by the AHJ, the current edition of the code or standard must apply to the modification.

It may be necessary to exceed or supplement the requirements of the applicable NFPA code or standard when designing fire protection systems designated as safety class or safety significant in safety basis documentation.

Except for systems designated as safety class or safety significant, existing sprinkler systems installed under the 'pipe schedule' rules of NFPA 13, Standard for the Installation of Sprinkler Systems, do not require hydraulic verification, provided that: the sprinkler system is adequately maintained; there has been no increase in occupancy hazard classification; there has been no significant degradation in available water supply as determined by the AHJ;; and meets the water supply requirements of NFPA 13 for pipe schedule systems. Notwithstanding the previous statement , assurance should be made that sprinkler systems protecting nuclear, radiological, high value, mission sensitive/critical, and extremely large facilities are capable of meeting the required design density.

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8.1 Protection to Limit Loss Potential MPFL is a value representing the magnitude of a worst case fire; it is not a scenario. One way to view MPFL is the face value of an insurance policy covering fire and liability relating to a fire. In determining the value of the MPFL, which is used in part to assess the need for fire protection systems, the basic assumption is that automatic or manual fire suppression fails. This loss determination should include all direct and indirect costs associated with the fire and clean-up operations. In addition, there may be intangible costs such as mission interruption, erosion of public support, and local economic impact. All of these may need to be considered to ensure that appropriate levels of fire protection are included in a facility. Direct and indirect costs that should be included are:

a) Replacement cost of building and building systems; b) Replacement cost of contents; c) Impact on other missions when that can be determined either in dollar or programmatic

terms; d) Cost of environmental clean-up both inside and outside the facility; and e) Exposure damage to other buildings, structures and property.

When the Maximum Possible Fire Loss (MPFL) exceeds $50 million, a redundant fire protection system should be provided that, despite the failure of the primary fire protection system, will limit the loss maximum possible fire to levels determined by the Authority Having Jurisdiction (AHJ).

When the MPFL exceeds $150 million, a redundant fire protection system and a fire barrier should be provided to limit the MPFL to levels determined by the AHJ. Where redundant fire protection systems are specified, any two of the following are considered satisfactory (exclusive of the fire barrier provision when the MPFL exceeds $150 million):

a) Automatic suppression systems, such as fire sprinklers, foam, gaseous, explosion suppression, or other specialized extinguishing systems plus appropriate alarms. An adequate supply, storage, and distribution system is an essential element.

b) Automatic fire detection, occupant warning, manual fire alarm, and fire alarm reporting systems (considered together) combined with a sufficiently-staffed, properly-equipped and adequately-trained fire department or brigade that is able and committed to respond in a timely and effective manner.

c) Fire barrier systems or combinations of physical separation and barriers for outdoor locations.

d) Other systems, such as alternate process control systems, as approved by the AHJ.

Redundant fire protection systems may include dual water supplies to sprinkler systems, dual piping risers, or valving systems such that adequate redundancy in water supply to the sprinkler heads is provided to cover maintenance or emergency outages of either of the water supply systems or may include multiple types of automatic fire suppression systems (e.g., water sprinklers and a gaseous fire suppression system). Portable fire extinguishers, interior fire hose systems, or interior fire detection and alarm systems do not meet the definition of a redundant fire protection system.

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All DOE sites and facilities should have access to a fully-staffed, completely equipped and adequately-trained fire department that is capable and committed to respond to fires and related emergencies on site in a timely and effective manner. If determined by the BNA that such a capability does not exist and that DOE is, consequently, subject to a higher loss potential, then additional fire protection features should be provided to compensate for the absence of adequate emergency response capabilities. Additional fire protection features might consist of, but is not limited to, any of the following singularly or in combination: additional water supplies or increased water supply reliability, including redundancy, extinguishing systems and or fire separation for the protection of special hazards, installation of additional fire barriers to reduce potential fire loss, segregation of the risk into separate structures, increased administrative controls, and enhanced Inspection, Testing & Maintenance programs.

Facilit Construction New permanent structures in excess of 5,000 square feet floor area should be of noncombustible construction. Fire resistance should meet or exceed model building code criteria. Although possibly permitted by the building code, the use of combustible construction for facilities that form an integral part of nuclear, high hazard, radiological and mission critical facilities should be avoided.

It is important early in the project design phase to fully understand risk associated with the project and the extent to which facility construction may play a role in controlling those risks. Control of those risks may result in the need to specify a level of construction (fire resistive versus protected non-combustible) which exceeds that normally acceptable. For example, if collapse of the structure due to seismic reasons is unacceptable, then collapse due to fire would be equally unacceptable.

Interior and exterior walls may be classified as secondary confinement barriers to guard against radiological or other hazardous material releases should be primary confinement barrier fail. When walls are classified as secondary confinement, it will be necessary to provide a level of fire protection that will guard safety basis expectations.

Interior fire barriers should be provided to isolate hazardous occupancies, to minimize the potential for fire spread (including products of combustion) and loss potential, and to help assure the orderly evacuation of facility occupants, consistent with the conclusions of the FHA. Openings in such barriers should be protected with appropriately fire-rated doors, windows, dampers or penetration seals. (Refer to the building code.)

Process confinement systems are generally limited to one of the following: 1) ventilation systems, 2) gloveboxes, 3) material transfer systems that are enclosed, and 4) piping systems with or without tanks. To protect the integrity of the physical barriers associated with process confinement systems, fire protection features should include the following:

a) A fire extinguishing system to rapidly remove heat produced by fire to prevent or minimize damage to the process system or to prevent over pressurization the pressurization of a process confinement system and to rapidly extinguish a fire to minimize the loading of ventilation system filters with combustion products.

b) The introduction of the extinguishing agent in a way that does not result in over pressurization of the confinement barriers.

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c) Where appropriate providing vulnerable portions of the confinement system with a fire resistive enclosure, or fire wrap of suitable fire rating.

d) Administrative controls for the storage of combustible materials within or close to such systems.

Life safety provisions are governed by 10 CFR Part 851 for contractors and DOE O 440.1B for Federal employees. Means of egress and associated requirements should be in accordance with NFPA 101, Life Safety Code or the local building code. Refer to DOE G 440.1-8 for additional guidance. Additional or modified exiting requirements for toxic and explosive environments should be as determined by the appropriate authorities defined within the above stated documents. An approved exemption, deviation, or equivalency is required where requirements for life safety as defined by NFPA 101 or building code are not met. In addition, for explosive environments, exits should reflect the criteria contained in the DOE Explosives Safety Manual (DOE M 440.1-1A).

9 WATER SUPPLY AND DISTRIBUTION SYSTEMS Water supply demand consists of the following: 1) Sprinkler or water spray demand, 2) the simultaneous demand of other water-based fire suppression systems, such as plenum cool down and water spray sprinklers or exposure protection sprinklers, 3) Hose stream demand based upon fire department operations criteria and safety basis assumptions, i.e., calculation for interior hose streams required in order to avoid opening confinement barrier doors, and 4) other demands to which the system may be required to meet such as domestic or industrial demands. In calculating water supply demand, the system need only meet one of the following, not both 1) sprinkler demand in combination with a conservative hose stream demand, or 2) hydrant flow demand based upon an acceptable fire flow formula for structures lacking automatic sprinkler protection.

9.1 Demand Domestic water distribution systems that also serve fire protection requirements should be designed to satisfy the calculated Fire Hydrant Demand (see Paragraph 6.1.2) and the peak domestic demand at the same time. Where no other requirements are applicable, the peak domestic demand should be based on 2.5 times the calculated average daily demand plus any special demands, such as industrial or processes that cannot be reduced during a fire. The distribution system should be capable of meeting this combined demand at a minimum residual pressure of 20 psi at ground elevation (or higher elevation if special conditions apply) for a period of not less than 2 hours. Municipal supplies having the same capability are acceptable.

Within a building or facility, domestic water should be supplied by a separate service line and not be a combined fire protection and potable water service or a combined process water and potable water system.

Where combined fire and domestic process water systems are used, distribution piping should be routed and provided with valves such that the domestic and process systems can be isolated

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without shutting off the fire system supply. Combined fire and domestic water systems must meet the applicable requirements of NFPA 24, Private Fire Service Mains, in addition to other requirements that may be imposed for domestic systems.

9.1.1 Fire Hydrant Demand Where reliance is placed on fire department response, either for protection of unsprinklered buildings or where the fire department will serve as redundant (backup) protection, the water supply available from hydrants should be capable of providing the flow rates established in NFPA 1 based on the most severe facility fire risk on site. These values may be reduced by a maximum of 50% when the facility is provided with automatic sprinkler protection throughout, in accordance with the applicable NFPA Standards.

The results of water supply tests, according to NFPA 25, must be provided to the emergency services organization. Similarly, the emergency services organization for DOE sites should be immediately informed of any water line breaks or other water supply outages that would adversely affect its ability to respond to fires and related events.

9.2 System Arrangement Facilities having a Maximum Possible Fire Loss (MPFL) in excess of $100 million and Hazard Category 1 nuclear facilities should be provided with an additional, independent source of fire protection water. Where redundant water supplies are provided, they should be arranged so as to minimize the impact of single point failures.

Whenever feasible, all water distribution systems should be of the looped grid type providing two way flow with sectional valving arranged to provide alternate water flow paths to any point in the system. In addition, sectional control valves should be provided to limit the number of hydrants made inoperable during a single line break to a total of five, and individual sprinkler systems made inoperative to no more than one. Sprinkler systems should be provided with fire department connections to facilitate providing some level of water supply to all sprinkler systems in the event of a line break. Dead end runs utilized as a single supply to fire hydrants should not exceed 300 feet. Where special circumstances may require longer dead-end runs to hydrants may be required, consideration should be given to increasing the diameter of the piping supplying the dead-end hydrant in order to reduce friction loss and the potential for water hammer.

Listed and/or approved control valves should be installed at maximum intervals of not more than 5,000 feet on long supply lines and at maximum intervals of not more than 1200 feet on main distribution loops, feeders and all primary branches connected to these lines. Such control valves should also be installed at selected points throughout the distribution system to provide system control over each service area. At intersections of distribution mains, one less control valve than the total number of intersecting mains may be provided. As an aid in determining the minimum number of sectional control valves, the critical nature of the building/facility should be considered as well as the number of fire and domestic systems affected in a potential line failure.

Sprinkler system water supply lead ins should not run under buildings except for the minimum distance possible. Sprinkler system risers and alarm valves should be located as close as

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practical to a building entry point. Where a riser would otherwise be located in a potentially contaminated area, consideration should be given to locating the riser exterior to the building in a heated enclosure.

To the extent feasible, post indicator valves (PIV) should be used to the extent feasible for the control of fire protection water systems, including combined systems.

Hydrants should be provided so that hose runs from hydrants to all exterior portions of a protected building are no more than 300 feet. Hydrants should not be closer to than 40 feet to buildings.

10 AUTOMATIC SPRINKLER SYSTEMS A fundamental precept of the DOE Fire Protection Program is that all new facilities greater than 5000 square feet in total floor area, as well as facilities where a fire could cause unacceptable off-site and/or on-site consequences to health, safety, or the environment should be protected by automatic fire suppression systems (usually sprinkler systems). This policy stems from several factors:

1) DOE places a premium on safety. 2) The foundation of HPR rests on automatic fire sprinklers. 3) DOE hazards often demand superior protection. 4) DOE fire departments have limited resources. 5) Sprinklers have an extraordinary life safety record. 6) The cost of installing sprinklers is relatively low, e.g., less than the cost of commercial

grade carpet. 7) Sprinklers have become almost universally accepted in commercial facilities, and

requirements are becoming more prevalent in buildings as small as single family residences

8) Accident investigation and repair costs are unusually high at DOE sites. 9) Serious fires undermine public confidence. 10) Sprinklers can detect fire initiate suppression, sound evacuation signals, summon the

fire department, and typically extinguish fires with 1 or 2 sprinklers before fire has an opportunity to spread.

11) Sprinklers typically cause less water damage than fire hoses in facilities without sprinklers.

12) Alternative fire suppression systems are more costly to install and maintain, have a higher failure rate, their limited supply of agent more often results in re-ignition of fires and usually have to be backed by automatic sprinklers.

13) Although sprinklers have been required for DOE facilities since the Manhattan project, the most serious fires have occurred when the policy was not followed.

14) DOE is uninsured and does not maintain reserves required by self-insurance laws.

The resulting protection should be designed to ensure that a fire would be successfully controlled until such time that emergency response forces arrive to complete extinguishment.

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The FHA and the safety basis documentation should specify any additional requirements beyond those for a standard wet pipe sprinkler system.

All facilities of significance, including facilities where a fire could cause unacceptable off-site consequences to health and safety endanger workers, represent an unacceptable risk to fire fighters, an unacceptable mission impact, or unacceptable property loss, should be protected by an automatic fire suppression system (usually a Wet Pipe Sprinkler System). A decision to install another type of fire suppression system should be based on engineering analysis performed by a fire protection engineer. The analysis should consider in addition to initial design and installation cost, the long term cost of inspecting, testing and maintenance of the system over its useful life, especially where access for the performance of increased IT&M activities may be difficult due security or radiological concerns and/or costly. Other systems are usually installed for special purposes, such as protecting electronic equipment, and are normally installed in addition to automatic sprinklers. DOE has, historically, considered a facility with a floor area exceeding 5000 square feet or an MPFL in excess of $3 million as being significant from a property protection standpoint. Some examples of situations where automatic fire suppression systems may be warranted are:

a) facilities that contain critical or long procurement time construction items; b) a temporary-use trailer used as a control center for a vital one-time activity; c) a facility with high public visibility or sensitivity (as defined by the AHJ); d) electric power transformers with combustible contents that, of damaged, could result in

an extended shut-down of the facilities they serve; e) facilities in which a fire could result in the accidental release of significant quantities of

toxic or hazardous materials or emissions (based on engineering analysis); f) facilities that can be protected by extending automatic fire suppression systems from an

adjacent protected facility or area at a low incremental cost; g) facilities in which a fire could damage more important adjacent facilities; h) facilities used to store hard to replace or irreplaceable records; i) facilities that may warrant future automatic fire suppression systems, j) facilities where required for protection of human life.

k) facilities where fire could result in unacceptable programmatic or mission impact; and

l) facilities where fire could result in unacceptable risk to fire fighter safety.

Where required by the building code, an applicable NFPA code or standard, a Documented Safety Analysis (DSA) or an FHA, the design of fire protection systems to withstand seismic events should be in accordance the criteria developed by the National Fire Protection Association, except as required by other DOE criteria, such as in Section 7 of this standard for fire protection systems classified as safety class or safety significant.

Fire protection systems or portions of them, which must function to control effects of a Design Basis Accident (DBA) event (as determined by safety analysis accident scenarios) should be designed to be functional for all conditions included in the accident scenario. This should include both the event initial cause and its consequences. Example for seismic events the assumption may be that for a seismic event fire is expected to occur during and following the

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event, thus the fire suppression system or other fire protection feature may be required to function during and following the seismic event.

When the use of water sprinkler coverage is precluded because of nuclear criticality or other incompatibility reasons, nonaqueous extinguishing systems (e.g., inert gas, carbon dioxide, Halon alternatives, etc.) that will be successful in extinguishing the anticipated fire and which is not reactive to materials present should be used. . Additional precautions may be needed since these alternative systems are much less reliable than sprinklers and their limited supply of extinguishing agent may permit re-ignition.

Standpipes should be installed in all structures having three levels or more above or below grade. In other structures, such as those with extensive and/or complex interior layouts where deemed necessary by the DOE Fire Protection AHJ. Standpipes may also be required in nuclear and other facilities in order to maintain facility containment under fire conditions, i.e., avoid the need to run hose lines into the structure by blocking open doors. Standpipes should be designed and installed as Class 1 systems per NFPA 14.

10.1 General Application NFPA Standard 13 should be used to determine the occupancy classification for any facility. Due to the potential for facility occupancy changes or room occupancy changes within the facility the use of light hazard sprinkler design should be avoided.

Hydraulically designed sprinkler systems should be designed for a supply pressure of at least 10% but not less than 10 psi below the supply curve. This provides a pressure margin to accommodate minor system modifications, or degradation of the water supply and sprinkler systems that may occur over time.

10.2 Seismic Criteria [In addition to the applicable seismic requirements delineated in NFPA 13, the following criteria should apply in the design of new sprinkler systems relied upon to prevent or mitigate the adverse nuclear safety consequences of seismically induced: fires, inadvertent actuations, structural failures, and leakage as set forth in the facility DSA or FHA.]

[In the design of sway bracing, the criteria of Section 4-14.4.3.5.3 (or current equivalent) of NFPA 13 (1996) should be revised as follows. Horizontal force should be determined by the equation F(p) = K x W(p). A value of K consistent with the criteria in DOE-STD-1020-94 should be determined by an engineer qualified in seismic analysis. Values for K less than 0.5 should not be used unless specifically justified. Exception 1 or 2 following Section 4-14.4.3.5.3 should be applied. If Exception 1 is applied, use "K" instead of "half." If Exception 2 is applied, divide "K" by 0.5 to determine the multiplier for Table 4-14.4.3.5.3 (or current equivalent).]

11 FIRE ALARM SYSTEMS The design and installation of fire alarm systems must consider an evaluation of code requirements, any special needs or considerations of the facility being protected including the potential for radiation and contamination, the types of fires that may be anticipated, the best detection methods for the anticipated fire event, and the cost associated with not only initial

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design and installation, but long term maintenance as well. Where high lost potentials are possible, more advanced methods of fire detection may be prudent.

11.1 General Application Fire alarm systems should comply with NFPA 72 and have the following basic features:

a) Transmission of signals to the responding DOE facility fire department alarm center and other constantly attended locations in accordance with NFPA 72.

b) Local alarms for the building or zone in alarm. c) Visual alarms for the hearing impaired, where there are high noise levels, or where there

are special process requirements. d) The fire alarm control panel located near the main entrance or a protected location as

determined by the AHJ. For buildings with multiple alarm zones, a zone alarm panel or a graphic zone alarm panel at the main entrance to the facility. For facilities provided with a 24/7 operations center consideration should be given to installing the alarm panel or a remote annunciation panel within the operations center.

e) Supervisory devices for all critical functions (low water pressure, low air or supervisory air, valve alignment, loss of heat, loss of power, detection and alarm circuit trouble, etc.) except those (such as sprinkler system control valves) that are locked or sealed.

11.2 Alarm Actuating Devices Alarms activated by flow of water should be provided within a facility for occupant and emergency response notification wherever a sprinkler system is installed. A manual fire notification method, such as telephone, alarm, radio, or manual fire alarm boxes, should be provided at all facilities.

11.3 Alarm System Extensions Extensions to existing fire alarm systems and all new systems in existing buildings or facilities should be compatible with existing fire alarm equipment at the location, including keys/locks, similarity of alarm signals and equipment as well as user operated devices, training requirements, and maintenance procedures. Additions to fire detection systems must be in compliance with the current edition of NFPA 72.

12 STRUCTURAL FIRE PROTECTION CRITERIA

12.1 General Any materials with severe fire characteristics, such as urethane foams, and any materials that develop significant quantities of toxic or harmful products of combustion (as delineated in Material Safety Data Sheets and other sources of product information), shall not be used in interior applications. The use of foam plastics in construction should be prohibited unless it fully complies with F M Global Data Sheets. The use of foam insulation on the exterior of buildings should not be permitted where such application in combination with the potential for adjacent building exposure, exposure of the building to itself due to building arrangement, or wildland fire threat results in an unacceptable fire risk.

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12.2 Fire Barriers Wall, floor and ceiling, and roof and ceiling assemblies should be tested and rated for their fire resistance by Underwriter's Laboratories (UL) or similar nationally recognized testing laboratories, by FM.

12.2.1 Fire Resistance The development of an FHA and DSA should include consideration of conditions that may exist during normal operations and special situations (e.g., during periods of decontamination, renovation, modification, repair, and maintenance). Where required by the FHA or DSA, the structural shell surrounding critical areas and the supporting members should remain standing and continue to act as a confinement structure during anticipated fire conditions including failure of any fire suppression system not designed as a safety class. Fire resistance of this shell should be attained by an integral part of the structure (concrete slabs, walls, beams, and columns) and not by composite assembly (membrane fireproofing).2 A variety of coverings and coatings are available to limit the temperature of structural members in a fire. The two most basic categories of fire protection are membrane protection and direct application. Membrane protection refers to products that are used in such a way that they are independently supported from the surface they are protecting. This group includes batts, blankets and board stock. An example would be boxing in with board stock materials like gypsum board. Direct applied protection refers to products that are applied directly to the substrate they are to protect. They generally are adhesively attached to the substrate. These coatings can be either troweled-on, formed and poured or spray-applied. An example would be encasement in concrete, plaster, or gypsum. In no event should the fire resistance rating be less than 2 hours under conditions of failure of any fire suppression system not designed as a safety class. (Refer to NFPA Standard 221 and FM Global Data Sheet 1-22.) The use of membrane systems to obtain a fire resistive rating is considered unacceptable for facilities designed as confinement barriers, or which house equipment containing confinement equipment since failure of any part of the fire resistive system could result in failure of the entire system.

Special facilities should be designed and constructed using building components of fire resistant and noncombustible material, particularly in locations vital to the functioning of confinement systems. Combustible materials should not be used in the construction of process system confinement barriers.

12.3 Flame Spread In process and storage areas of Category 1, 2, and 3 nuclear facilities, Interior finish shall meet the requirements of the applicable building code or NFPA 101, with the following exceptions, exposed interior wall or ceilings (including ceilings formed by the underside of roofs), and any factory installed facing material utilized in nuclear, radiological , hazardous, explosive, and other facilities where the potential for unacceptable mission impact or fire loss exists, should have a flame spread rating of 25 or less and a smoke developed rating of 50 or less, per ASTM E 84.

Ductwork constructed of Fiberglass Reinforced Plastics (FRP) should be listed or approved for use without interior sprinklers, or should be provided with automatic sprinklers per the applicable 2 Membrane protection is defined in FM Global Data Sheet 1-21,"Fire Resistance of Building Assemblies", Section 3.0 on page 4 of the January 2004 edition.

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FM Data Sheets. Adequate precautions should be taken to protect ductwork that may contain combustible interior finishes, or combustible dusts, lint, or chemical residues.

12.4 Roofing Systems Roofing systems included but not limited to insulated steel deck assemblies with various coverings, lightweight (insulated) concrete, concrete with built-up coverings shall be FM Global Class 1 assemblies.

Membrane roof systems(thermal plastic, EDPM, etc) should be designed and constructed in to provide a FM Class 1 roof assembly.• Built-up bituminous membrane roofing on metal decks should be designed and constructed to provide a FM Class 1 roof assembly. Designers are encouraged to review the lessons learned from the two Paducah Gaseous Plant fires that involved the roof deck.

Metal roofing system shall be should be design and constructed to provide a FM Class 1 roof assembly as noted in FM Data Sheet 1-31.

12.5 Penetrations Fire barrier penetration seals should comply with NFPA 101, Chapter 8. Penetration seal materials and assemblies should be tested for their fire resistance and listed by UL or similar nationally recognized testing laboratories, or should be approved by FM. Where fire rated assemblies (walls, floor ceilings, roof ceilings) are either partially or fully penetrated by pipes, ducts, conduits, raceways or other such building elements, fire barrier penetration material should be placed in and around the penetrations to maintain the fire resistance rating of the assembly.

Where fire barriers are penetrated by the confinement system's ventilation ducting, fire dampers should be appropriately used to maintain the barrier integrity. However, the closure of such dampers should not compromise the functions of the confinement system where the loss of confinement might pose a greater threat than the spread of fire. In such cases, alternative fire protection means (e.g., rerouting, enclosing or wrapping the duct and supports with fire rated insulation equal to that of the barrier penetrated) should be used as a substitute for fire barrier closure. Sprinkler systems, such as those designed as a "water curtain," should not be considered a fire barrier substitute. Actual fire testing may be employed to prove the overall effectiveness of wall penetrations by unique equipment such as material transfer equipment that is enclosed within ductwork type arrangements. Transfer tunnels may include viewing and glove ports that must be protected from the potential effects of fire.

The installation of penetration seals must be well documented with the location of each opening being identified through drawings of seal numbering, documentation of penetrate seal selection (listed for intended application), documentation of worker training or qualification, and quality control during installation.

12.6 Carpets and Rugs Carpets and rugs should be tested in accordance with NFPA 253 (ASTM E-648) when applying the floor finish requirements of the Life Safety Code (NFPA 101) to DOE facilities.

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Carpets and rugs used in storage or industrial occupancies (no criteria in NFPA 101) should have a critical radiant flux not less than the following:

a) 0.45 watts per square centimeter in areas unprotected by an automatic fire suppression system; and

b) 0.22 watts per square centimeter in areas protected by an automatic fire suppression system.

13 LIFE SAFETY Life safety provisions should be provided for all new and existing facilities in accordance with NFPA Standard 101, "Life Safety Code" (LSC). Upon approval by the AHJ, the methods outlined in NFPA 101A, "Alternate Approaches to Life Safety," may be applied to support equivalency requests where strict compliance with the LSC is not practical. New facilities are expected to meet the requirements of NFPA 101 or the applicable building code. Where compliance with applicable requirements cannot be met for a new facility an exemption, equivalency, and variance as applicable is required. Compliance with the LSC is considered by DOE to satisfy the exit requirements of the applicable building code.

Any security, radiological control or other physical restrictions to prevent access to or egress from an area should not prevent emergency egress in the event of a fire or related condition. Where conflicting criteria exist, the most effective compromise should be implemented consistent with the objectives of DOE O 420.1 B. Deviations from building code or NFPA 101 requirements will require relief in the form of an approved exemption, equivalency, or deviation/variance request.

In areas where an accidental breach of a primary confinement system could expose personnel to radioactive material, a distance of 75 feet, as measured by the method in NFPA 101, should be the maximum travel distance to ensure that personnel can exit through the next confinement. As a general rule, exiting from areas or rooms having a common path of travel greater than 75 feet should be to corridors located on each end of the laboratory, research or production area where unsafe conditions may result in the event of a confinement system breach. Exiting may be through an area of equal or lower hazard, including radiological, but should not be required through an area of higher hazard. Where this approach is used to ensure that alternate exiting is available, it should be well documented.

Doors that serve as exits from security areas should comply with NFPA 101 and DOE security requirements. (Refer to the egress criteria for Correctional Occupancies for additional guidance.) When security-related hardware is installed on a fire door, the modifications should not adversely affect the fire rating of the door. Such modifications should be in accordance with door manufacturers' guidelines and should be evaluated by a qualified fire protection engineer. Where security requirements require deviations from building code or NFPA 101 requirements will require relief in the form of an approved exemption, equivalency, or deviation/variance request.

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Hazardous areas, such as radioactive spaces or spaces with inert atmospheres, should have sufficient detection, alarms and interlocks to assure that access by workers or emergency personnel will not endanger such personnel or result in a public hazard.

Exits and associated requirements for explosive facilities or environments should reflect the criteria contained in the DOE Explosives Safety Manual DOE M 440.1-1A, as defined by safety basis documentation, or as determined by the AHJ.

14 ELECTRICAL EQUIPMENT In addition to the applicable requirements of the National Electrical Code, NFPA Standard 70, transformer installations should comply with FM Global Criteria. .

Research, experiments, production, and other similar activities may require the use of electrical components or assemblies which are not listed or otherwise approved.

Each operating contractor should have in place a system whereby to approve for use equipment, materials or assemblies where there is no "listed" equipment or materials of the required type is available. The acceptance criteria should follow the requirements as defined in DOE-HDBK-1092-2004. As a minimum the approval of non-listed equipment, components or assemblies would be approved by the Contractor’s electrical safety committee or electrical safety officers. Installation methods should be in accordance with the manufacturer's instructions, NFPA 70, and other applicable requirements.

Where multi tiered cable trays are installed), they should be provided with fire protection/suppression as determined by the AHJ and in accordance with recognized practices and listings/approvals.

Where required by the DSA or other safety basis documentation, critical facilities should be served by dedicated, redundant electric circuits. The two services should be separated by physical distance or 4 hour fire rated construction such that a single fire event will not impact both power supplies. The electrical power supply should be served from a minimum of two separate sources. In lieu of providing two separate services, a single service supplied from a loop type transmission or distribution system having sectionalizing features may be provided when the reliability of the single service proves adequate when considered in conformance with IEEE 399 and IEEE 493. Locations where fire can damage both normal and emergency power should either provide fire separation commensurate with the potential fire exposure, or be protected by redundant fire protection systems, or a safety class fire protection system.

15 GENERAL PROCESS HAZARD FIRE PROTECTION Compressed gas cylinders that represent a significant fire or toxic gas hazard (as determined by the FHA or other engineering evaluation) should be isolated outside of facilities or housed in a special hazardous materials storage room, exhausted gas cabinets, or similar types of containment.

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When a process uses or produces combustible gases or vapors, the design should include features such as inert gas purging, premixing the gas to a nonflammable mixture with inert gas, or increasing the air flow within process confinement barriers to provide the dilution required to maintain the concentration of gases or vapors below the lower limit for flammability. The process should include suitable detection and alarm features designed to warn against the loss of inert atmosphere, etc.

Lightning protection systems should comply with NFPA 780. Such systems should be considered for buildings containing facilities for the use, processing, and storage of radioactive, explosive and similarly hazardous materials; for buildings over 50 feet in height; and for buildings containing valuable equipment. A risk assessment using the guide in Appendix I of NFPA 780 should be made of these buildings to determine the risk of loss due to lightning.

Process furnaces should be provided with a system for automatically shutting off the gas and purging with inert gas in the event of power failure, loss of coolant water, loss of exhaust ventilation, over temperature, or detection of hydrogen in the vicinity of the furnace. Automatic shut-down systems should provide an audible/visual alarm at the location of the incident, as well as to a continuously attended location (See FM Global Data Sheets for additional guidance.)

16 SPECIAL HAZARDS Hazards unique to DOE and not addressed by mandatory codes and standards should be protected by isolation, segregation, automatic fire suppression, or use of special control systems such as: inert gas, explosion suppression, etc., as determined by the FHA or other engineering evaluation and the AHJ. Devices for limiting or controlling the effects of a fire (relief valves, filters, blast walls, emergency shutdown systems, scuppers, etc.) should be provided when justified by the hazard.

Combustible control programs should be established for nuclear, radiological, high hazard, explosive and mission critical facilities.

16.1 Plutonium Processing and Handling Facilities (PPHF) Only hazardous gases or liquids that are necessary for a process should be used in PPHFs. No natural gas for heating purposes should be used unless the heating occurs in a separate building that is clearly isolated from the primary facility. Other flammable, explosive, corrosive, or toxic gases or liquids that are necessary to the process should be handled under special control and isolated to avoid releases or reactions that might cause injury to workers, the public, or the environment. Those flammable gases that are necessary for a process should be provided by a hard-piped system with the gas supply located outside of the facility in cylinders rather than from large capacity sources so as to limit the total quantity available in the event of a fire or explosion. Additional levels of fire suppression or fire separation may be required for the protection of these special hazards.

The use of combustible packaging materials should be limited to the extent feasible. Where combustible packing materials are required they should be stored specially designed cut-off rooms, in metal containers or in structures outside of a PSF in a location that should not

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endanger the storage facility or stored material if a fire occurs in the packaging material. To the extent feasible, packaging operations should be limited to designated areas.

Storage racks should be metal and designed to securely hold storage containers in place, ensure proper separation of storage containers, and maintain structural integrity under both normal operations and during a fire. Where safety class fire suppression is not provided, storage racks may be required to be fire rated if there is a potential for storage rack collapse under fire conditions, and subsequent potential for criticality following collapse.

16.2 Plutonium Storage Facilities (PSF) When required by the DSA or other safety basis requirements, nuclear materials shall be stored in fire resistant containers having a rating suitable to limit the impacts of fire on the material being stored.

16.3 Enriched Uranium Storage Facilities (EUSF) Combustible packaging materials should be stored in metal containers or structures outside of a UEUSF in a location that should not endanger the storage facility or stored material should a fire occur in the packaging material. The need to provide automatic fire suppression systems for these areas should be evaluated in the FHA and SAR.

The primary confinement system should be constructed of fire-resistant materials, and the process equipment and process being confined should be designed to prevent or minimize the probability of potential flammable or explosive conditions. Confinement enclosures for flammable metals should be designed with self-contained fire protection and extinguishing equipment; in some cases, inert atmospheres may be desirable within the enclosures.

The process should have ventilation that provides sufficient air movement around the process area to prevent exposure of personnel to the hazardous liquid or vapor. The design should incorporate roughing filters and/or other types of traps to remove entrained organic liquid droplets from the process off-gas before the off-gas enters the main ventilation ducting to prevent ventilation ducts from becoming coated with the organic material, and thus, creating a fire hazard.

16.4 Uranium Processing and Handling Facilities

16.5 Reprocessing Facilities To ensure the maintenance of the principal confinement systems within secondary confinement, design features should include provisions for fire sprinklers, water mist, or other suitable fire protection systems. This will provide rapid heat removal, reducing both the pressurization of the process cell or canyon and loading of the ventilation system filters with combustion products.

The use of combustible packaging materials should be limited to the extent feasible. Where combustible packing materials are required they should be stored in specially designed cut-off rooms, in metal containers or structures outside of a PSF in a location that should not endanger the storage facility or stored material if a fire occurs in the packaging material. To the extent feasible, packaging operations should be limited to designated areas. The need to provide

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automatic fire suppression systems for these areas should be evaluated in the DSA or other safety basis documentation.

Storage racks should be noncombustible and designed to securely hold storage containers in place, ensure proper separation of storage containers, and maintain structural integrity under both normal operations and during a fire. Where safety class fire suppression is not provided, storage racks may be required to be fire rated if there is a potential for storage rack collapse under fire conditions, and subsequent potential for criticality following collapse.

16.6 Uranium Conversion and Recovery Facilities To the extent practical, the primary confinement system should be constructed of fire-resistant materials, and the process equipment and process being confined should be designed to prevent or minimize the probability of potential flammable or explosive conditions. Confinement enclosures for flammable metals should be designed with self-contained fire protection and extinguishing equipment; in some cases, inert atmospheres may be desirable within the enclosures.

Physical isolation barriers should be designed for process areas that use hydrogen. Pressurized hydrogen gas storage areas should be surrounded with fire resistant barriers. The pressurized hydrogen storage tanks should be capable of being isolated from the distribution system using positive shutoff valves. The distribution system should either be double-walled piped (pipe within a pipe) or have hydrogen detectors located at strategic points, with the detector activated capability of shutting off hydrogen flow at the source.

Fire resistant, physical isolation barriers should be designed for both the fluorine gas storage area and process areas that use fluorine.

17 NUCLEAR FILTER PLENUM FIRE PROTECTION

17.1 Purpose and Scope Much of the information pertinent to fire protection for very high efficiency air cleaning filter systems specifically for DOE nuclear facilities has been developed over a period of years in technical papers, limited distribution reports and job specifications which are not readily available. This section provides the basis for fire protection for ventilation systems in DOE nuclear facilities and the recommendations and basis for specific situations that are common to many DOE facilities.

Chapter 10 of DOE-HDBK-1169-2003, Nuclear Air Cleaning Handbook provides the three major objectives for fighting fire in or around ventilation systems in nuclear facilities:

• To prevent fires from affecting the operation of the ventilation system;

• To protect the filtration function; and

• To prevent the release of material that has accumulated on filters.

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These are in addition to the Life Safety and property damage protection objectives discussed elsewhere in this Standard. Application of each of the subsequent requirements in Chapter 14 should focus on achieving these objectives.

Although the guidelines in this section are specifically applicable when only high efficiency particulate air (HEPA) type filters serve as the final means of effluent cleaning in a nuclear air cleaning ventilation system, the guidelines can be applied with engineering discretion to other types of filtration and cleaning systems and their configurations.

This section does not include specific definitive fire protection design requirements for High Efficiency Metal Fiber filter systems, Radioiodine Adsorber air cleaning systems, Deep Bed Fiberglass filter systems, or Deep Bed Sand Filter systems (See ASME AG-1-1994, "Code on Nuclear Air and Gas Treatment" for definitions. Refer also to Appendix A). This section does not include the protection of HEPA type filters utilized in a clean room application. (Refer to NFPA 318.)

17.2 Filter Plenum Construction

17.2.1 HEPA Filters All HEPA filters used in nuclear ventilation exhaust systems should meet the requirements for HEPA filters in ASME AG-1, Section FC, and be listed as a High Efficiency Particulate Air Filter Unit as tested in accordance with UL 586. (Note: For operating temperatures of HEPA filters, see Appendix B).

17.2.2 Duct Entrance and Prefilters Duct entrance filters minimize deposits of dust and other combustibles inside the ducting and protect the final filters from excessive particulate. Prefilters prolong HEPA filter life by protecting them from large particles. All nuclear duct entrance filters and prefilters located upstream or made part of final HEPA filter exhaust plenums should be listed as Class 1 Air Filter unit as tested in accordance with UL 900.

17.2.3 Filter Framing If all criteria in this section are met, filter framing systems may be constructed of combustible material provided that the material has a flame spread rating of 25 or less and smoke developed rating of 50 or less.

17.2.4 Number of Final HEPA Filters When nuclear HEPA filters serve as the final means of effluent cleaning, a minimum of two stages of HEPA filters should be arranged in series in the final filter plenum. In existing HEPA installations, one of the two stages of final HEPA filters may be located upstream from the final filter plenum.

17.3 Location of Final Filter Plenum Ventilation System Equipment

17.3.1 Final Filter Plenums Located Inside Buildings Filter plenums located inside process buildings and other buildings should be separated from all parts of the building and be enclosed by 2-hour fire-rated construction. Buildings should be provided with appropriate fire protection systems.

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17.3.2 Final Filter Plenums Located in Separate Building a) Separate buildings which house filter plenums should be of minimum 2-hour fire rated

construction when located less than 5 feet (1.5 meters) from an adjacent building. b) Filter plenum housing should be a minimum of 1-hour fire rated construction when

located more than 5 feet (1.5 meters), but not more than 20 feet (6.1 meters) from an adjacent building.

c) Filter plenum housing located greater than 20 feet (6.1 meters) from an adjacent noncombustible building may be of unprotected noncombustible construction provided that no unprotected openings occur in the adjacent building.

d) Unless the FHA determines otherwise, filter plenum housings need not be fire-rated or separated from an adjacent building if the adjacent building wall is of minimum 2-hour fire-rated construction with no unprotected openings.

17.3.3 Filter Plenums Located Near Combustible/Flammable Liquids Filter plenums located near combustible or flammable liquid storage buildings or tanks should be located not less than 50 feet away from the buildings or tanks and be housed in minimum 2-hour fire rated construction.

17.3.4 Small Filter Plenums Small filter plenums that serve as a final filter and have a leading surface area of 16 square feet (1.4 square meters) or less need not be separated by fire rated construction from other parts of a building or be located in a separate fire rated enclosure if the filter plenum is located in a building provided with an automatic fire sprinkler system, designed and installed in accordance with NFPA 13, and the filter plenum is provided with an automatic water spray system as described herein.

17.3.5 Existing Plenums Plenums that have already been built and are in service before issuance of these guidelines are not required to be upgraded with a fire-rated enclosure or minimum separation distance unless there is a significant hazard that endangers building occupants, the public, or the environment, as determined by an FHA per DOE Orders or is required by the AHJ.

17.4 Protection of Openings in Fire Rated Construction Fire rated enclosures should be designed to maintain the integrity of containment systems as reflected in the DSA and the following criteria.

17.4.1 Ratings for Doors a) Door openings into 2-hour rated filter plenum housings should be 1 1/2-hour minimum

fire-rated. b) Door openings into 1-hour rated filter plenum housings should be 3/4-hour minimum fire-

rated.

17.4.2 Fire Damper Ratings Listed 1 1/2-hour fire rated dampers should be installed per code requirements where ventilation ducts are not required to continuously operate for confinement during a fire.

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Fire dampers are not required when ducting penetrates 1-hour fire rated construction provided rooms on both sides of the barrier are completely protected by automatic sprinklers. Transfer grills and other similar openings without ducting should be provided with an approved fire damper.

Fire dampers should not be utilized in ducts penetrating fire rated construction where the ducting is an integral part of the nuclear air filter system equipment that is required to continuously function as part of the confinement system. Such duct material penetrating fire rated construction without fire dampers should:

a) be made part of that fire-rated construction by either wrapping, spraying, or enclosing the duct with an approved material, or by other means of separating the duct material from other parts of the building with equivalent required fire-rated construction; or

b) be qualified by an engineering analysis for a 2-hour fire-rated exposure to the duct at the penetration location where the duct maintains integrity at the duct penetration with no flame penetration through the fire wall after a 2 hour fire exposure and through the remaining downstream ducting. (See Appendix D for a discussion of this type of analysis.)

Dampers in the air cleaning system for the purpose of controlling pressure, direction, or volume of air flow and for isolation of filters during change out or inspection are permitted.

17.4.3 Other Penetrations and Openings in Fire-Rated Enclosures All mechanical and electrical penetrations made into fire-rated plenum enclosures should be fire stopped by listed materials meeting the requirements of ASTM E-814 with a fire rating not less than the rated enclosure.

17.5 Materials and Special Hazards Inside Plenums

17.5.1 Combustibles Located Inside Filter Plenum Enclosures Filter plenum enclosures should only be used for ventilation control equipment. The storage and accumulation of combustible materials as well as combustible and flammable liquids in any quantity should not be permitted. In addition, the storage of spare filters inside the filter plenum should not be permitted.

17.5.2 Electrical Equipment Utilized in Final Filter Enclosures All electrical equipment located in the filter plenum should comply with NFPA 70 and all electrical wiring located in the filter enclosure should be in metal conduit.

17.5.3 Processes Subjecting Final Filter Plenum to Flammable and Combustible Vapors When operations or processes involve flammable or combustible liquids that produce vapors, the concentration of the gases or vapors inside the final filter plenum should not exceed 25 percent of their lower flammable limit inside the filter enclosure.

If any accident or other situation could cause concentrations exceeding 25% for the LFL, Fixed combustible gas analyzers should be provided in the final filter enclosure when the process involves gases or vapor with analyzer alarms set to sound an alarm at 25 percent of the lower flammable limit. These alarms should be transmitted to a continuously manned location.

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17.5.4 Processes Subjecting Final Filter Plenum to Pyrophoric Dust Particles When operations or processes involve pyrophoric materials that may subject the final filter plenum to the pyrophoric dust particles, a method to remove the dust particles before reaching the final filter enclosure, such as a prefilter, should be required.

17.5.5 Processes Subjecting Final Filter Plenum to High Dust Loading, High Moisture, Acid, or Solvent Environments

Operations sometimes may involve processes that may subject the final filters to airstreams carrying high moisture content, high dust loading, acids, and solvents that may rapidly degrade, plug or disintegrate the final filter medium or separators. When operations involve these sorts of airstreams, preventive methods should be utilized to stop the degradation impact on the final filters. These can include, but are not limited to, more frequent filter change outs, prefilters, scrubbers or traps, filters rated for the particular environment, and the use of alternative chemicals. When chemical degraders to HEPAs are utilized, including hydrogen fluoride (HF), nitric acid (HNO3), and perchloric acid (HCLO4), processes should include scrubbers, traps, or other methods to remove the chemical before the final HEPA filters.

17.6 Prefilters, Duct Entrance Filters, and Fire Screens

17.6.1 Prefilters and Duct Entrance Filters Protection of the final filter plenum from dust and particulate loading should be accomplished by using duct entrance filters or prefilters or a combination of both as follows:

a) All gloveboxes, hot cells, and fume hoods connected to containment ventilation systems should be provided with at least moderately efficient (30 to 45 percent atmospheric dust spot efficiency based on ASHRAE 52-76) duct entrance filters.

b) High efficiency (at least 80 percent atmospheric dust spot efficiency based on ASHRAE 52-76 test method) prefilters should be provided in the ventilation system to protect the final HEPA filters from (1) particles with diameters larger than 1 or 2 microns; (2) lint; and (3) dust concentrations greater than 10 grains per 1,000 cubic feet (30 cubic meters). High efficiency prefilters not only provide a degree of fire protection to the final HEPA filters but can also extend the operational life of the HEPA filters.

c) High efficiency prefilters (at least 80 percent ASHRAE atmospheric dust spot efficiency should be located at least 36 inches (91 centimeters) upstream from the final HEPA filters.

d) Where airborne materials are known to be combustible (such as metal powders), replaceable prefilters should be located as near the source as possible. However, prefilters should not be located where there is an unacceptable radioactive hazard to personnel in changing the prefilters.

17.6.2 Fire Screens The purpose of fire screens is to protect filters from burning material. They are not flame arrestors, which can actually prevent the passage of flame by thermal quenching. Flame arrestors rely upon small passages to provide a geometry which is incompatible with the passage of flame. This small passage geometry makes flame arrestors unsuitable for dust or saturated vapor service. In contrast fire screens physically stop ignited, entrained, particles from

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moving through the duct work to the filters. Fire screens are therefore useful when ignited pieces are likely to be ejected from the main source of combustion and may reach the combustible filters. For this to occur, the particles must be light enough or buoyant enough to be entrained, but large enough that they remain at ignition temperatures when they reach the filters. Fire screens also provide the benefits of making the velocity profile in the duct more uniform, reducing channeling; and potentially breaking up larger flaming pieces into smaller pieces that are more likely to burn out before reaching the filters, because of the increased surface area. Typical cases would involve wood or pyrophoric materials. DOE-HDBK-1169-2003, Nuclear Air Cleaning Handbook states that fire screens may be required if the HEPA assembly if closer than 30 ft from the source and requires that they should be at least 20 feet from the pre-filters. The location most likely to be benefitted by the installation of fire screens is between smaller systems, such as a glove box, and the local exit filter of that device.

Fire Screens to protect final exhaust filters in traditional man entry style final plenums: In order to protect the final exhaust HEPA filters in Filter Systems from burning material, metal mesh screens (fire screens) may be used, if appropriate. Tests by Lee of Atlantic Richfield in 1974 established the following design features for fire screens to prevent the passage of fire• Fire screens should be located upstream from the prefilters and final filter plenums. • Fire screens with metal meshes from 8 to 16 openings per inch should be provided and located so that they are at least 4 to 5 feet (1.2 to 1.5 meters) upstream from all prefilters and at least 20 feet (6.1 meters) upstream from all final filter plenum enclosures.3

Where prefilters are located in final filter enclosures, fire screens should be located at least 20 feet (6.1 meters) upstream from the prefilters.

Duct entrance filters may not require fire screens unless a significant amount of combustible (materials) products/dusts are present in the exhaust stream exiting the duct.

Fire screens may not need to be installed immediately before final filter plenum filter enclosures as, indicated above, unless there is a duct entrance, without a fire screen, within 30 feet of the final filter plenum.

18 Detection Systems

18.1 Detectors a) Automatic fire detectors should conform to NFPA 72, "National Fire Alarm Code." b) Detectors should be rate compensated type heat detectors. c) Detectors should be approved for the specified use.

3 Numerical data obtained from: Lee, H.A., Final Report - Program for Fire Protection, Caves, Canyons, and Hot Cells, ARH-ST-104, Atlantic Richfield Hanford Company, Richland, August 1974, pp. 59, 60. Lee, H.A., Guide to Fire Protection in Caves, Canyons, and Hot Cells, ARH-3020, Atlantic Richfield Hanford Company, Richland, July 1974, pp. 33, 35. Burchsted, C.A., J.E. Kahn and A.B. Fuller. 1976. Nuclear Air Cleaning Handbook, ERDA 76-21. Oak Ridge National Laboratory. Oak Ridge, Tennessee, pg. 227. Hill, A.J., Fire Prevention and Protection in Hot Cells and Canyons, DP-1242, Savannah River Laboratory, Aiken, South Carolina, April 1977, pg 12.)

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d) Detectors should be of the 190 oF (89 oC) temperature range unless operations require higher temperature air flows (see Appendix B for maximum filter operating temperatures).

e) Detectors installed prior to 1997 that are supervised, with suitable, equivalent, and reliable methods of detection (as determined by the AHJ) that are not rate compensated type or not listed may continue to be used while they remain serviceable.

18.1.1 Detector Location Heat detectors or pilot sprinkler heads should be provided in ducting prior to final filter enclosures. Airflow should be considered when determining detector or pilot head location. Heat detectors or pilot sprinkler heads should also be provided in the final filter enclosures.

18.1.2 System Arrangement The detection system or pilot system should be arranged to detect a rise in air flow temperatures, actuate automatic fire suppression systems, when required, and transmit an alarm to the responding fire department or constantly attended proprietary station. The fire alarm system should be installed per NFPA 72.

A pilot operated system should only be used when automatic water deluge spray systems are required under Section 14.8.

Control units and signaling alarm systems connected to the heat detectors should be listed for their intended purpose.

Existing detection systems or pilot systems that provide equivalent and reliable methods of detection and alarm signaling transmission (as determined by past performance and/or engineering analysis) that are electrically supervised but are not listed may continue to be used while they remain serviceable.

18.1.3 Detection Testing Capability Detector installations should be engineered and installed so that they can be tested during the life of the detector. Remote testing should be provided for detectors that are not accessible due to unacceptable hazards. One method of providing remote testing is to provide detectors with heating strips or coils that can be energized by a separate control unit. If a line-type heat detection system is used, a heat testing pad should be provided outside the plenum for operability testing of the system.

Where high contamination levels do not exist, detectors may be installed so that the detector can be removed from the plenum enclosure and tested externally.

18.2 Deluge Spray Suppression Systems

18.2.1 Location Automatic deluge and manual water spray systems should be provided inside all final filter plenums for protection of the filters where they have a leading filter surface area greater than 16 square feet (1.4 square meters).

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Automatic water deluge systems should be provided inside all final filter plenums having a leading surface area of 16 square feet (1.4 square meters) or less when the filter plenum is not separated by fire rated construction.

Plenums that have already been built and are in service before issuance of these guidelines in 1997 are not required to be back-fitted with automatic deluge or manual water deluge systems unless there is a significant hazard that endangers building occupants, the public, or the environment, as determined by an FHA or as required by the AHJ.

The design of water deluge and spray systems should reflect the potential for filter failure mechanisms, such as filter media damage resulting from weakened media due to water absorption and excessive differential pressures during water discharge. Such failure mechanisms can be significantly mitigated by throttling back fan controls to reduce the pressure across the filter or by providing redundant filters. See Appendix.

18.2.2 Demister Guidelines Where automatic deluge systems are installed in filter plenum enclosures that do not contain prefilters, metal demisters should be installed downstream of the automatic deluge sprinkler heads and upstream of the first series HEPA filter. • Demisters should have a nearly 100 weight (wt) percent efficiency for water drops 50 microns and larger. They should have an efficiency greater than 99 wt percent for 1 to 50 microns with air flow velocities of 500 to 600 feet (153 to 183 meters) per minute, or at operating air flow velocities with operating water flow deluge delivery rate.

Demisters should be located as far away as possible from the HEPA filters (a minimum of 36 inches [91 centimeters]) and approximately 6 inches (15 centimeters) from the deluge sprinkler heads.

When automatic deluge systems are installed in final filter plenum enclosures that contain prefilters, water deluge sprinkler heads should be located upstream from the prefilters. In this configuration, the prefilters act as a demister.

18.3 Design of Automatic Deluge and Water Spray Systems Automatic deluge systems should be designed per the applicable provisions of NFPA 13 and water spray systems to NFPA 15, and as follows (see Appendix C):

18.3.1 Density Water density should be 0.25 gpm per sq. ft. over the entire filter plenum cross-section at the filters or 1 gpm per 500 cfm air flow, whichever is greater.

18.3.2 Sprinkler head type Spray sprinkler heads should be deluge type sprinkler heads.

18.3.3 Location from prefilters or demisters The spray pattern of the deluge sprinkler head should be in the form of a downward vertical water spray approximately 6 inches (15 centimeters) in front of the prefilter or demister. In addition, deluge sprinkler heads should be spaced so that each sprinkler head does not exceed 4 lineal feet of curtain coverage.

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18.3.4 Activation by detection Deluge sprinkler system should operate upon activation of fire alarm system heat detectors or pilot sprinkler heads located in either the final ducting or filter plenum housing. Manual activation should be provided as well.

Automatic deluge and water spray system equipment should be listed for its intended use as required by NFPA 13 and NFPA 15.

Existing automatic deluge systems that provide equivalent and reliable fire protection for plenum filtration systems (as determined by past performance and/or engineering analysis) may continue to be used while they remain serviceable.

18.4 Design of Manual Spray Systems Manual spray systems should be designed per NFPA 15 and modified as follows (see Appendix C):

18.4.1 Density Water spray density should be 0.25 gpm per sq. ft over the entire filter area.

18.4.2 Spray pattern and nozzle type Nozzles should be spray nozzles that form a full circle solid cone discharge.

18.4.3 Location from filters Spray nozzles should be horizontally directed at the face of the first series HEPA filters so that all areas of the first stage filters and framing support system are wetted.

18.4.4 Activation by manual operation only Activation should be by manually activating deluge valve or opening a normally closed Outside Screw & Yoke gate valve. Control devices to activate the spray nozzle deluge valve should be provided in the process operators control room or other locations accessible to fire fighters. When a deluge valve is utilized, manual activation may be provided at the deluge valve as well.

Manual water spray system equipment should be listed for their intended use as required by NFPA 13 and NFPA 15.

Existing manual spray systems that provide equivalent and reliable fire protection for plenum filtration systems are acceptable

18.5 Water Supply Guidelines Water for the deluge and spray systems should be provided by two separate water supply connections for reliability. (One may be a fire department connection if acceptable to the AHJ.)

Automatic deluge and manual water spray system water supplies should be hydraulically calculated and capable of supplying a simultaneous flow of the automatic deluge and manual water spray systems as well as the overhead ceiling automatic fire sprinkler systems for the fire area providing air to the plenum for a minimum period of 2 hours. A minimum 2-hour water supply is not required when a limited water supply system, discussed below, is justified and provided for criticality event reasons.

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18.6 Special System Guidelines

18.6.1 Water Drains Water drains with traps and a means to eliminate drain trap evaporation should be provided in plenum floors to provide liquid run off control.

Plenum drains should be piped to either a process waste system or to collection tanks.

Process waste systems and collections tanks should be of sufficient capacity to capture all liquid from the water deluge spray systems for the densities and durations required herein

Criticality safety should be observed in all drainage and storage systems where the potential for impacting fissile materials is encountered.

18.6.2 Limited Water Supply Systems Limited water supply systems for the deluge and water spray system water supply should be permitted when a documented criticality potential exists in the final filter plenum.

A documented criticality potential should be provided showing criticality calculations and the total amount of water allowed in the plenum enclosure before a limited water supply system is permitted.

Limited water supply can be accomplished by either limited capacity water tanks or system water flow control valves.

18.6.3 Maximum Air Temperatures When normal operating temperatures of final filter enclosure are expected to exceed 200°F (94°C) or when operating temperatures of the final filter enclosure exceed the manufacturer's limited continuous service temperature rating, a method should be provided to cool the ventilation air stream (for filter operating temperatures see Appendix B).

Normal operating temperatures do not include high temperatures associated with fire conditions.

High operating temperatures in the final filter enclosure can be minimized by long runs of ducts preceding the final filter enclosure, by intake of dilution air from streams from other spaces, or by water cooling systems inside the ducts.

18.6.4 Stainless Steel and Corrosion Resistant Equipment Stainless steel or noncombustible corrosion resistant equipment should be provided for all ventilation metal parts required for fire protection where components in the ventilation system are exposed to corrosive atmospheres. They should be designed either with stainless steel or other non-reactive materials to ensure their resistance to the harmful effects of corrosion.

Stainless steel water spray heads and nozzles, piping and fittings in the plenum, piping hangers in the plenum, demisters, and Teflon coated heat detectors are recommended.

Where a corrosion resistant or stainless steel fire protection product is required and that product is not available as a listed product from any manufacturer, the substitution is acceptable provided that the replacement product is equivalent, based on an engineering analysis.

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18.6.5 Lighting and Window Viewing Ports Lighting should be provided inside the filter plenum in front and between the filter banks in the area where automatic and manual heads and nozzles are located. Such lighting may be provided with an on and off switch provided that the switch is located outside the plenum at an accessible location.

Window viewing ports made up of wire glass, laminated lead safety glass, or fire rated glass should be provided for viewing inside the filter plenum. The window viewing ports should be provided at each location where fire protection spray system heads and nozzles are located and should be placed in such a way with enough windows so all heads and nozzles are visible from outside the filter plenum.

18.7 Fire Hazard Analysis It is not the intent of this Standard to prevent the application of alternative methods that provide equivalent or superior fire protection for nuclear final filter plenums. Therefore, equivalencies from fire protection guidelines provided in this section are permitted. However, equivalencies should only be permitted when a documented fire hazard analysis has been performed in accordance with DOE Order 420.1B and this Standard.

19 GLOVEBOX FIRE PROTECTION

19.1 Scope This section provides fire protection requirements for the design and construction of all new gloveboxes. It also addresses extinguishing methods, ventilation protection features, and general operating safeguards.

This standard is not intended for hot cells, although some design principles in this document may prove useful if similar hazards are present. Consult a qualified fire protection engineer before applying these criteria to hot cells.

If the use of the glovebox is to change or the glovebox is removed from service, an FHA to evaluate the potential fire hazards associated with the change.

19.1.1 Existing Glovebox Installations These criteria apply to existing glovebox installations when an FHA demonstrates conditions that warrant their application, or when determined by the AHJ.

19.1.2 Table-Top Gloveboxes Sections 15.3 and 15.5 do not apply to single, table-top, or mobile-type gloveboxes unless the potential fire hazards associated with these units warrant applying these sections to those installations.

19.1.3 Automatic Fire Protection Required An automatic fire suppression or inerting system is required in all new gloveboxes unless an FHA concludes that such a system is not warranted, and except as noted in 15.1.3 above. This is in addition to any facility wide fire suppression system such as automatic sprinklers.

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19.2 Glovebox Construction

19.2.1 Noncombustible Materials Gloveboxes should be constructed of noncombustible materials. The most common materials used are stainless steel and glass.

If the atmosphere and/or process within the glovebox is incompatible with the construction material of the box, an epoxy resin with inorganic fillers may be used to coat the interior metal surfaces of the glovebox. Where plastic linings are used for this purpose, an automatic fire suppression system or an inert atmosphere system designed and installed in accordance with the applicable NFPA Standard and section 15.01.04 is warranted.

All radiation shielding material added to the glovebox should be noncombustible. If combustible material must be used, it should be encased with a noncombustible material. Combustible materials that melt and could leak from the encasement should be avoided.

19.2.2 Glovebox Windows The number of glovebox windows should be limited to that required to provide the visibility necessary to ensure that safe operations, cleanup, and maintenance activities can be performed.

19.2.3 Window Materials Glovebox windows should be constructed of wire glass, fire-rated glass, or laminated safety glass. The window gasketing material should be noncombustible, or heat resistant. It should be understood that these materials limit fuel load, but noncombustible and heat resistant materials may not have any fire resistance; i.e. they can rapidly fail upon exposure to fire. Fire rated materials must be specified if the FHA requires the glovebox boundaries to resist fire transmission. A comparison of glovebox window material is provided in Appendix I.

If laminated safety glass is used in locations where radiation levels may be high enough to cause yellowing of the plastic, a cerium additive should be specified to prevent yellowing of the plastic laminate.

If either the glovebox atmosphere or operations require that an alternate window material be used, fire-retardant treated polycarbonate may be used. If fire retardant polycarbonate must be used, it should be sandwiched with noncombustible material (such as wire or tempered glass) whenever possible. As an alternative, the exterior side of the polycarbonate should be protected with a noncombustible material to guard against the effects of exposure fires.

19.2.4 Gloveports Gloveports should be installed in the stainless steel sides of the glovebox. If this is not possible, the gloveports should be installed using laminated safety glass or a fire retardant polycarbonate plastic and the quantity of plastic used should be limited only to that required to safely mount the gloveports.

Metal covers should be provided for each of the glove openings. Covers should be constructed of stainless or carbon steel. The covers should be held in place by a latch or other device constructed of noncombustible material suitable for the application. Utilization of the glovebox

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covers serves to protect against loss of integrity at a gloveport due to either internal or external fire exposure.

Noncombustible covers or plugs should be used to seal gloveport openings if the gloves have been removed.

19.2.5 Gloves Glovebox gloves should be selected based on the chemicals present in the glovebox. Generally, hypalon or neoprene gloves are used where permeation from the chemicals present is not a consideration. An additional outer cover may be provided if required for operational or personnel safety needs.

Gloves should be at least .030 inches (.076 centimeters) thick and should be of one-piece construction.

19.2.6 Methods for Containing Fire Spread Glovebox ventilation ducting should be provided with fire rated separation/isolation dampers or doors to minimize fire propagation. Fire barriers should also be provided between individual or groups of gloveboxes and within glovelines where warranted by the FHA.

The separation/isolation dampers or doors should shut by a fusible link. Where the glovebox is protected by an automatic fire suppression or detection system, the dampers or doors should be equipped to close upon activation of the system in lieu of providing conventional fusible links. In the case of fire detection systems, precautions such as heat detectors or dual zone smoke detectors should be utilized so as to avoid inadvertent operation and subsequent shutdown of the glovebox ventilation system.

Fire hazards analyses in combination with other ventilation and contamination control analyses should be used to determine where these separations are required. While specific guidance cannot be given due to the variety of glovebox applications, fire separation features should be considered for the following glovebox locations/situations:

a) Where required in conjunction with automatic fire suppression systems. b) At the connection point between the glovebox and its ventilation exhaust duct. c) At the connection point between a glovebox and a gloveline. d) Between gloveboxes or banks of gloveboxes which are connected in series, particularly

where the glovebox run crosses physical barriers which would serve as a fire stop to prevent fire propagation.

e) Unique situations where it is desirable to prevent fire propagation within a group of gloveboxes, or between a glovebox(s) and other areas.

f) The contents of gloveboxes and the need to limit contamination spread due to a fire is an important consideration in determining the number and location of separation devices.

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19.2.7 Criticality Safety Provisions Floor drains should be provided for all gloveboxes in which a criticality, process safety, or other similar engineering analysis determines that operations within a glovebox can create the potential for a criticality incident.

Where criticality is a concern and a drain system provided, the glovebox drain system design should provide for liquid collection/containment. Containment methods may include tanks, diked floors, etc. In addition, the drain piping and liquid collection systems/equipment should be designed to avoid criticality incidents.

19.2.8 Glovebox Utilities and Services All electrical components in the glovebox design should comply with the applicable sections of NFPA 70, National Electrical Code.

Utilities (e.g., water, air, gas, etc.) serving gloveboxes should be provided with shutoff or isolation valves for use in the event of an emergency. These valves should be located so as to permit rapid operator action while simultaneously protecting the operator from the emergency itself in or adjacent to the glovebox.

All heating devices used inside gloveboxes (such as hot plates, furnaces, etc.) should be listed/approved and equipped with automatic high-temperature shutoff switches. Where the presence of hazardous conditions warrant, the FHA should consider the need for high temperature alarms to be transmitted to a constantly attended location.

19.3 Automatic Fire Suppression/Inerting Systems

19.3.1 Inerting Systems Gloveboxes should be provided with inert atmospheres when:

a) combustible or pyrophoric metals are in use in significant quantities as determined by the AHJ; and

b) required by the FHA or SAR.

Glove box inerting may be used in lieu of an automatic fire suppression system when conditions warrant.

19.3.2 Inerting System Design Guidelines The system should be designed and installed in accordance with the applicable industry standards as supplemented by DOE criteria.

When required or when used as a substitute for other required automatic fire suppression systems, gloveboxes should be purged with an inert gas (commonly argon or nitrogen). The level of inerting provided should be sufficient to prevent ignition of the material(s) present. A safety factor should be included in establishing the inert gas design concentration. The safety factor compensates for errors in instrumentation or other conditions which might lead to an increase in oxygen level. For deflagration prevention, the flammable/combustible concentrations should be maintained at or below 25 percent of their lower flammable limit. For combustible and pyrophoric metals, the oxygen concentration should not exceed 25 percent

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of the level required for combustion. (Note that some combustible metals (e.g., aluminum powder) will burn in atmospheres other than air. Thus it is important for the designer to select an appropriate inert gas and establish a design concentration based upon the hazard.)

19.3.3 Oxygen Monitoring Where inert gas purging systems are installed, oxygen monitors should be provided to ensure the necessary concentration of inert gas is maintained. If an alarm (excess oxygen) condition is reached in the glovebox, the oxygen monitoring system should:

a) shut down the operations and electrical power to the glovebox, when warranted by the FHA, provided this action does not create an additional hazard; and

b) activate a local audible alarm (as a minimum) and, if high noise levels or other conditions warrant, cause a local visual alarm to be activated.

The designer and fire protection engineer should also evaluate gloveboxes equipped with inert gas purging systems to determine if:

a) an emergency purge or pressure relief system should be installed; and b) the hazard justifies providing annunciation at a continuously staffed location.

NOTE: The designer must analyze the consequences of curtailing operations after an oxygen alarm and establish the procedure necessary to shut down and stabilize conditions in the glovebox following an alarm

19.3.4 Oxygen Deficient Atmospheres Where justified by the hazards analysis, equipment to continuously monitor oxygen levels should be provided for working areas of facilities which are or may be occupied by personnel and which are equipped with gloveboxes or glovebox lines having inerted or oxygen deficient atmospheres. This should include pit or below grade areas where glovebox inerting gases may concentrate.

19.4 Automatic Fire Suppression Systems

19.4.1 System Types and Selection Automatic sprinkler or other approved fire suppression systems (foam water, dry chemical, dry powder, gaseous, water mist, etc.) should be provided for gloveboxes, except where an inerting system is provided per this standard. All systems should be designed, installed, acceptance-tested, and maintained in accordance with the applicable NFPA standards (see Section 3.0).

The following considerations apply:

a) Limited water supply sprinkler systems may be used if criticality is a potential (see Appendix H).

b) Gloveboxes should be provided with liquid runoff control if automatic sprinkler protection is provided.

c) Restricted orifice sprinkler heads may be used.

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d) In designing the distribution system for dry chemical systems, nozzles should be so oriented as to direct the discharge away from exhaust filters. This design step prevents direct loading of the filter by the dry chemical discharge.

e) The extinguishing systems should sound local alarms and transmit remote alarms to a continuously attended location for the purpose of initiating emergency action.

19.4.2 Design Considerations In selecting the type of automatic fire suppression system for installation in a glovebox under this standard, the designer should, as a minimum, consider the following:

a) potential for criticality; b) potential for contamination spread; c) effectiveness of the fire extinguishing agent on the anticipated type of fire; d) impact of the fire extinguishing agent on HEPA filters; e) potential for overpressurizing the glovebox due to activation of the extinguishing system; f) anticipated changes in glovebox use or operations which will increase the level of fire

hazard; and g) potential for inadvertent operation and the anticipated consequences.

19.4.3 Existing Halon Fire Suppression Systems Existing halon fire suppression systems which protect gloveboxes may continue in service if all of the following criteria are met:

a) The system is considered "essential" under Environmental Protection Agency regulations. (See also the Guidance on the DOE Facility Phaseout of Ozone-Depleting Substances, October 1995.)

b) The glovebox is required to have an automatic fire suppression system. c) The system complies with NFPA Standard 12A. d) The detection method should be designed to prevent inadvertent operation. (The use of

"deadman" abort switches is acceptable.)

Existing halon fire suppression systems which do not meet the above criteria should be replaced with a suitable automatic fire suppression system.

19.4.4 Multiple Hazard Gloveboxes If a glovebox operation involves multiple hazards (such as pyrophoric metal and flammable/combustible liquids), the FHA should determine the fire protection system design that provides the best overall protection.

19.4.5 Special Hazards Gloveboxes in which other special hazards are present (such as biohazards, medical or industrial toxins, flammable solids, water reactive materials, etc.) should be equipped with fire protection as determined by the FHA. At a minimum, this protection should consist of an automatic fire detection system complying with NFPA Standard 72 and the guidelines in Section 15.5 of this standard.

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19.4.6 Gloveboxes Removed from Service Fire suppression and inerting systems are not required to be maintained in gloveboxes which are removed from service provided that the following provisions are met:

a) All combustible materials are removed from the glovebox. b) Electrical power and flammable/combustible utilities are isolated and tagged "out-of-

service." c) The glovebox is tagged "out-of-service."

Resumption of activities within the glovebox should only be allowed after appropriate fire protection features have gone through acceptance tests and been reactivated on the basis of an updated FHA.

19.5 Manual Fire Suppression

19.5.1 Manual Fire Fighting All glovebox designs should include provisions for manual fire fighting. The extinguishing agent(s) selected should be appropriate for the hazards.

Where the potential for metal fires is present, an appropriate fire extinguishing agent (e.g., magnesium oxide sand, copper metal powder (30 - 60 mesh), carbon microspheres) in sufficient quantity should be provided. (Refer to Appendix G for an illustration of a mounting concept for a dry powder container.) In selecting the fire extinguishing agent, consideration should be given to the ease at which the metal can be separated from the agent. This is particularly relevant in the case of plutonium.

Where the fire potential is from other (non-metal) combustibles, dry chemical extinguishers are recommended. CO2 extinguishers may also be considered if class A combustibles are not a hazard in the glovebox. If grouped cables are present and water does not create the possibility of a criticality, then water should be used.

Manual suppression with fire hoses should be anticipated and addressed in the FHA as a last resort. Limited agent systems, particularly those that are non-aqueous, may permit re-ignition or may be compromised by failure of the glovebox boundary

In selecting the type of manual fire extinguishing unit and the application of extinguishing agent within the glovebox, the designer should consider:

a) the potential for glovebox overpressurization; b) the effect of fire extinguishing agent on filters; and c) the potential for increased contamination spread.

19.5.2 Quick-Disconnect Couplings Where manual suppression is the primary fire suppression method for the glovebox, pre-piped discharge points equipped with quick-connect couplings should be provided to facilitate the use of portable fire extinguishers. These couplings should be installed so that the extinguisher discharge is directed away from the exhaust filtration. (Tests have shown that a single disconnect coupling supplied by a 5 lb. [2.25 kilograms] dry chemical extinguisher can cover

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approximately 18 square feet [1.62 square meters].) Details of a quick connect coupling are provided in Appendix F.

If access is a problem, extension tubes or pipes that extend to accessible areas should be used to provide coverage for areas where it is difficult to reach the quick disconnect couplings.

Fire extinguishers with bayonet-type connectors may be used when it is not feasible to install quick-disconnect couplings. However, the designer should document the basis for not installing quick-disconnect couplings in the design report.

19.6 Fire Detection Systems Gloveboxes should be provided with an automatic fire detection system. (Refer to Appendix E for examples of glovebox fire detection systems.) A separate detection system is not required if the glovebox is equipped with an automatic fire suppression system that includes alarm features or an inerting system with alarm features.

The type of fire detection system to be used should be determined based on the hazards associated with the glovebox and operational needs. Air flow patterns within the glovebox should be considered when selecting and locating devices.

Fire detection systems should be designed, installed, acceptance-tested, and maintained in accordance with the applicable NFPA Standards.

If used, spot-type heat detectors should be installed not more than 8 feet (2.4 meters) apart.

Heat detection-type systems should be provided with remote testing capabilities.

A means should be provided to safely perform required inspection, testing and maintenance on the fire detection system installed in the glovebox.

Detection systems should sound local alarms and transmit remote alarms to a continuously attended location to initiate emergency action.

19.7 Glovebox Ventilation The criteria of this section are for gloveboxes and glovebox exhaust connections. For criteria for filter plenums and ventilation systems beyond the gloveboxes, refer to Section 14 of this standard.

19.7.1 Ventilation Design to Include Fire Protection Factors Glovebox ventilation requirements should be based, in part, on the results of the hazards analysis. Glovebox ventilation systems should be protected against the effects of fire.

Where feasible, glovebox ventilation should incorporate a downdraft design (that is, the ventilation inlet opening should be near the top of the box and the exhaust opening should be near the bottom of the box). Studies have shown that downdraft construction is best from a fire protection viewpoint, and it should be used unless operational features dictate otherwise.

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19.7.2 Exhaust Filters and Screens Glovebox primary exhaust openings should be provided with prefilters and fire screens to reduce vapor mist and fire propagation. The fire screens should be stainless steel screens (8 -16 mesh) or a perforated stainless steel plate using the same mesh opening sizes. The screens should be installed at the primary exhaust openings.

19.7.3 Flow Rate Considerations Glovebox ventilation flow rates in gloveboxes having an air atmosphere and in which flammable liquids or gases are used should be sufficient to prevent the atmosphere from reaching 25 percent of the lower flammable limit of the material in use. Maintaining oxygen concentrations at or below 25 percent of the lower flammability limit provides a safety factor against equipment malfunctions, accidental leaks, etc., which could lead to increases in the glovebox oxygen concentration.

Where hot plates or other heat sources are used in the glovebox, flow rates higher than that stipulated above may be required in order to prevent unacceptable overheating of the glovebox enclosure. Temperature increases which do not exceed 15 degrees above ambient room temperatures are, generally, acceptable.

19.7.4 Ventilation Exhaust Exhaust air from gloveboxes containing flammable or other hazardous atmospheres should be discharged to the outdoors. Such emissions should comply with applicable Federal and State emissions requirements.

19.7.5 Multi-Unit Exhaust Manifolds Glovebox exhaust ventilation lines should be designed so each box has its own exhaust port. The purpose of this criterion is to prevent flame or hot fire gases from traveling from one glovebox to another through a common header or interconnection arrangement.

19.7.6 Noncombustible Materials Noncombustible materials should be used for glovebox ventilation ducts regardless of duct type (rigid or flexible). Insulation materials used to wrap/cover ventilation ducts should also be of noncombustible material such as fiberglass.

20 Safety Classification Fire Protection Systems [Generic philosophy on safety classification is no longer needed since specific criteria for safety class and safety significant are now included in the standard. The new 2008-1 material lacks an introduction - the 3 steps highlighted in yellow may serve as an introduction.]

20.1 Wet Pipe Automatic Sprinkler Installations The following provides a summary of the requirements, criteria and guidance for new safety significant, and safety class wet pipe automatic Sprinkler installations:

20.1.1 Safety Significant (Design) In addition to the criteria for general use, the following additional design requirements/guidance is applicable for Wet Pipe Sprinkler systems used in safety significant applications:

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The following sprinkler components should not be used :

a) Vane or paddle type alarm devices; b) On/off sprinklers; c) Mechanical slip fittings; and d) Cast Iron fittings (Fittings should be a minimum of Malleable Iron per ASME B16.3 where

additional fitting strength is required).

Strainers should be used for all systems connected to water supplies prone to sediment or debris.

Sprinkler piping should be a minimum of Schedule 40 steel for pipes 6 inches or less in diameter and Schedule 30 steel for pipe greater than 6 inches in diameter.

Areas should be designed to no less than Ordinary Group 1 requirements (per NFPA 13) and should not exceed 130 square feet per sprinkler. For Ordinary Group 2 and Extra Hazard occupancies, sprinkler coverage should not exceed 100 square feet per sprinkler.

For Seismic Design Category SDC 3 and higher, a qualified structural engineer should evaluate locations where hangers and earthquake sway bracing utilizing the loads provided by the site seismic design authority in conjunction with NFPA 13 criteria.

Environmental conditions should be defined and documented for sprinkler systems and the system should be designed to remain operable for those events they are relied on as specified in the DSA. Examples include:

a) Seismic; b) Other natural phenomena hazards (NPH) such as high wind potential, tornados,

flooding, lightning, low temperature and humidity; c) Facility hazards, such as internal flooding, explosions, fire outside the system boundary,

missile and vehicle impacts, corrosive environments; d) Wildland fire; e) Physical damage from adjacent equipment and systems (for example – during a seismic

event); and f) Water quality.

Wet Pipe Sprinkler support systems, such as freeze protection, must be classified as equal or superior to the classified Wet Pipe Sprinkler system or, where timely corrective action is feasible, equipped with support system alarming devices connected to an alarming system that is classified as equal or superior to the classified Wet Pipe Sprinkler system.

To support appropriate implementation of the site or project QA program relative to fire protection systems, the following topics should be addressed (beyond what is specifically identified in DOE O 420.1B and referenced NFPA codes and standards):

a) Document control (documents are stored properly to avoid damage, responsibility for completeness, maintenance and distribution are identified, etc.).

b) Records of qualification of fire protection staff and control of qualification records.

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c) Procurement documentation and control of purchased items or services. d) Identification and control of components (e.g., sprinkler heads) per requirement 8 of

NQA-1-2008, Quality Assurance Requirements for Nuclear Facility Applications. e) Handling, shipping and storage requirements for components. f) Control of nonconforming items to prevent inadvertent installation or use. g) Commercial grade dedication of components based upon third party testing and

production monitoring. h) The QA Program should be audited in different phases (design, construction, and

operations) using DOE O 413.3A.

20.1.2 Safety Class (Design) In addition to the criteria for general use and safety significant applications, the following additional design requirements/guidance is applicable for Wet Pipe Sprinkler systems used in safety class applications:

Active features of a sprinkler system must be designed to preclude a single point failure for safety class sprinkler systems if the component failure results in the system’s inability to perform its safety function. Active features of a sprinkler system include the sprinklers themselves plus any other installed component that would exhibit a change in state.

There should be a minimum of two sprinklers in each area being protected.

20.1.3 Safety Significant (Operability) Technical Safety Requirement (TSR) Limiting Conditions for Operation should be defined (including appropriate action statements to address situations when the system is inoperable). TSR Surveillance Requirements should be defined consistent with NFPA 25 Inspection Testing and Maintenance requirements.

20.1.4 Safety Class (Operability) Technical Safety Requirement (TSR) Limiting Conditions for Operation should be defined (including appropriate action statements to address situations when the system is inoperable). TSR Surveillance Requirements should be defined consistent with NFPA 25 Inspection Testing and Maintenance requirements.

20.2 Water Supply The following provides a summary of the requirements, criteria and guidance for safety significant, and safety class Water supply systems supporting Wet Pipe automatic Sprinkler installations:

20.2.1 Safety Significant (Design) Underground piping should be limited to cement lined ductile iron (Class 52 minimum), polyvinyl chloride (PVC) piping (Dimension Ratio [DR] 14), and high density polyethylene piping (DR9). Additional limitations of material type may be imposed for seismic design.

Where restraints are required, two separate means of joint restraint should be used (e.g., thrust blocks, mechanical, rodding).

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Ferrous piping should be provided with corrosion protection such as polyethylene wrap or cathodic protection per AWWA standards.

A stable pipe bed such as backfilling around piping to a height of eighteen inches of sand bedding (from outside of piping) should be provided.

Sectional and sprinkler/standpipe control valves should be limited to factory assembled post indicator valve assemblies (PIVAs).

In-ground pipe identification systems should be provided (ribbon, trace wire, red mud etc.).

Environmental conditions should be specified for sprinkler systems and if necessary support systems should be provided to mitigate the condition. Examples include:

a) Natural hazards such as seismic events, tornado, high winds, flooding and lightning, temperature (e.g., below freezing), and humidity;

b) Facility hazards, such as internal flooding, explosions, fire, missile impacts, vehicle impacts, and corrosive environments; and

c) Wildland fire.

To support appropriate implementation of the site or project QA program relative to fire protection systems, the following topics should be addressed (beyond what is specifically identified in DOE O 420.1B and referenced NFPA codes and standards):

a) Document control (documents are stored properly to avoid damage, responsibility for completeness, maintenance and distribution are identified, etc.).

b) Records of qualification of fire protection staff and control of qualification records. c) Procurement documentation and control of purchased items or services. d) Identification and control of components (e.g., sprinkler heads) per requirement 8 of

NQA-1-2008, Quality Assurance Requirements for Nuclear Facility Applications. e) Handling, shipping and storage requirements for components. f) Control of nonconforming items to prevent inadvertent installation or use. g) Commercial grade dedication of components based upon third party testing and

production monitoring.

The QA program should be audited in different phases (design, construction and operations) using DOE Order 413.3A.

20.2.2 Safety-Class (Design) In addition to the criteria for general use and safety significant applications, the following additional design requirements/guidance is applicable for water supply systems used in safety class applications:

Active features of a water supply system should be designed to preclude a single point failure for safety class sprinkler systems if the component failure results in the system’s inability to perform its safety function.

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20.2.3 Safety Significant (Operability) Technical Safety Requirement (TSR) Limiting Conditions for Operation should be defined (including appropriate action statements to address situations when the system is inoperable). TSR Surveillance Requirements should be defined consistent with NFPA 25 Inspection Testing and Maintenance requirements, or other established requirements by equipment manufacturers and water purveyors.

20.2.4 Safety Class (Operability) Technical Safety Requirement (TSR) Limiting Conditions for Operation should be defined (including appropriate action statements to address situations when the system is inoperable). TSR Surveillance Requirements should be defined consistent with NFPA 25 Inspection Testing and Maintenance requirements, or other established requirements by equipment manufacturers and water purveyors.

20.3 Fire Barriers The following provides a summary of the requirements, criteria and guidance for new safety significant, and safety class Fire Barrier installations:

20.3.1 Safety Significant (Design) In addition to the criteria for general use, the following additional design requirements/guidance is applicable for Fire Barrier installations used in safety significant applications:

1) Environmental conditions should be defined and documented for fire barriers and be designed to remain operable for those events they are relied on as specified in the DSA. Examples include:

a. Seismic; b. Other natural phenomena hazards (NPH) such as high wind potential, tornados,

flooding, lightning, low temperature and humidity; c. Facility hazards, such as internal flooding, explosions, fire outside the system

boundary, missile and vehicle impacts, corrosive environments; d. Wildland fire; e. Physical damage from adjacent equipment and systems (for example – during a

seismic event); and f. Facility environmental impacts; e.g. corrosive environments.

2) Fire barrier support systems, such as structural bearing or non-bearing fire barriers, floor/ceiling, column/beam assemblies, and trusses/roof framing are the most important support element and must be classified as having a fire resistance rating at least equal or greater than that of the SS barrier and classified as equal or superior to SS fire barrier system where these elements provide structural support to credited SS fire barriers or failure of the support system component could fail and damage an adjacent SS fire barrier.

3) Protected openings and penetration seals are not considered support systems, rather they are part of the primary SS fire barrier and must be protected with appropriately fire-rated doors, windows, dampers or penetration seals, which similarly have been fire tested to maintain the fire resistance rating of the overall assembly.

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4) As stated in the general criteria of DOE G 420.1-1 the support systems must be designed, fabricated, erected, and tested to standards and quality requirements commensurate with their importance to safety.

5) To support appropriate implementation of the site or project QA program relative to fire protection systems, the following topics should be addressed (beyond what is specifically identified in DOE O 420.1B and referenced NFPA codes and standards):

a. Document control (documents are stored properly to avoid damage, responsibility for completeness, maintenance and distribution are identified, etc.).

b. Records of qualification of fire protection staff and control of qualification records. c. Procurement documentation and control of purchased items or services. d. Identification and control of components (e.g., fire dampers) per requirement 8 of

NQA-1-2008, Quality Assurance Requirements for Nuclear Facility Applications. e. Handling, shipping and storage requirements for components. f. Control of nonconforming items to prevent inadvertent installation or use. g. Commercial grade dedication of components based upon third party testing and

production monitoring on the contractor’s quality assurance program. h. Configuration and design control. i. Results of commissioning testing

6) The QA Program should be audited in different phases (design, construction, and operations) using DOE O 413.3A.

20.3.2 Safety Class (Design) In addition to the criteria for Safety Significant applications, the following additional design requirements/guidance is applicable for Fire Barrier installations used in safety significant applications:

1) The following components should not be used (FOOTNOTE: If the user chooses to utilize these devices, then their potential impact should be evaluated separately.

a. Entire sections of fire barriers constructed of fire rated glazing assemblies. b. Curtain style fire dampers should not be used in non-confinement ventilation

ducts for safety class fire barriers since their reliability to sufficiently close and latch under dynamic flow has been documented as a concern by the Nuclear Regulatory Commission.

2) For the most part fire barriers are passive. However, fire barriers may include active components necessary to address barrier openings including fire doors, glazing and dampers which must close during the performance of its nuclear safety function.

a. For safety class barriers only fire resistive glazing materials for use in rated fire doors is permitted, with a maximum area of 100 square inches allowed in one door leaf for the entire fire barrier.

b. Fire doors in safety class fire barriers must be equipment with automatic closures and positive latching devices in accordance with NFPA 80 which can be held open only with magnetic devices designed to close on either activation of any one of four detectors (two detectors on each side of the fire barrier). The detectors must be arranged to be independent of the fire alarm system and

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design to release the magnetic hold open device upon primary electrical failure. Fusible link devices that are integral to the door closers are not permitted

c. Where non-confinement ventilation ducts must pass through safety class fire barriers only multiple blade style dynamic fire dampers which will operate and close under anticipated air flow velocities and anticipated pressures are permitted or air flow must be shut down by redundant detection so as not to comprise their effectiveness. Fire Dampers shall be installed tested and maintained in accordance with NFPA 80.

20.3.3 Safety Class and Safety Significant (Operability) Technical Safety Requirement (TSR) Limiting Conditions for Operation should be defined (including appropriate action statements to address situations when the system is inoperable). The fire barrier must be un-altered, not breached, penetrated by unstopped or unapproved fire penetration systems, damaged or removed from its original design or approved configuration [consistent with this guide] and all fire barrier Technical Safety Requirement surveillance requirements must be current.”

Fire barriers shall be maintained and shall be properly repaired, restored, or replaced where damaged, altered, breached, penetrated, removed, or improperly modified. A program for the inspection and/or testing and maintenance of fire barriers and protected openings (e.g. fire doors and hardware, fire dampers, glazing, penetration seals) shall be established based on the requirements of NFPA 1 and NFPA 80. NFPA 1 and 80 should be used to establish the Technical Safety Requirement surveillance requirements and limiting conditions of operation and should clearly include requirements for damaged or compromised barriers identified during surveillances or facility operations. Fire barriers components (e.g. doors, dampers) should be readily accessible for inspection and testing as well as marked and identifiable in the field as required by National Recognized Testing Laboratory and fire barriers should be readily labeled and identifiable in the field. Safety Class and Safety

All fire barriers and their components should be visually inspected at least on an annual basis in accordance with the applicable NFPA code (e.g. NFPA 80) to ensure the critical characteristics of the barrier are preserved so its performance will restrict the spread of fire as expected by the safety basis. Testing shall also be conducted on all active barrier components (e.g. doors closures and dampers) to ensure they will function. For example the fire damper manufacturer may require that actuators be tested at a certain frequency, thus this testing frequency shall be incorporated into the Inspection, Testing and Maintenance (ITM) program for fire barriers. If a fire barrier or fire barrier component is damaged, it shall be replaced or returned to the required level of fire resistance using a listed/approved repair system or using materials and methods equivalent to the original construction.

21 Relocatable Structures

21.1 General Relocatable structures should be constructed to conform with the applicable requirements of the NFPA and the applicable building Code This section does not apply to relocatable structures

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that will remain in place for no more than 180 days onsite and that do not contain significant fire hazards and have no programmatic importance or significant value, as determined by the cognizant fire protection engineer. Modifications made to existing portable structures should be performed in accordance with this Standard. Site-specific interpretations of the provisions of this Standard should be the responsibility of the DOE AHJ.

1) Exception 1: Corridors should meet the requirements of the current edition of the Life Safety Code, NFPA Standard 101.

2) Exception 2: Tents or other membrane-type structures should be constructed of tentage material that has been tested and approved by a nationally recognized independent fire test authority for the anticipated end use. Approval should be based on the performance of large scale tests.

3) Exception 3: This criterion does not apply to semi-trailers and cargo containers.

21.1.1 Compartmentation Relocatable structures should be separated such that the largest fire area does not exceed the limits imposed by the building code.

21.1.2 Exception Relocatable structures over 16,000 square feet (1,487 square meters) in floor area that are protected by an automatic fire suppression system should be divided into separate fire areas by 2-hour fire-rated barriers so that no single area exceeds 16,000 square feet (1,487 square meters) in floor area. Such barriers should extend throughout the entire height and breadth of the structure, so designed as to prevent fire propagation through and around the barrier.

No fire area in a relocatable structure should have a MPFL exceeding limits imposed by the DOE AHJ.

21.1.3 Anchors and Supports Each relocatable structure should have support and anchoring systems properly designed and installed that will resist overturning and lateral movement of the structure.

21.1.4 Interior Finish The interior finish of all relocatable structures should comply with NFPA 101, as amended below.

Relocatable structures used for storing, processing, or involving radiological materials should have an interior finish with a flame spread rating <25 and a smoke development rating <50 per ASTM E84. If fire retardant pressure impregnated wood is used as interior finish it should be the non-leachable type that meets Underwriter's Laboratories (UL) "Standard Rain Test" and should be installed with corrosion resistant fasteners that will withstand the chemicals impregnated in the wood. It should be rated as FR-S material as currently listed in the (UL) Building Materials Directory or equivalent. Fire retardant paint is not acceptable for flame spread reduction for interior finish.

Interior finish requirements should also apply to the shell covering material of tension supported structures.

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21.1.5 Skirting Relocatable structures with open under-floor areas should be provided with skirting to prevent the accumulation of combustibles and debris beneath the structures.

21.1.6 Identification All relocatable structures should be marked with the number, symbol, or name for identification purposes. The marking system used should be permanent and consistent with the system currently used at the site.

21.1.7 Heating and Air Conditioning Heating and air conditioning equipment should be listed or approved by a nationally recognized independent fire testing authority and installed in accordance with its approved design and applicable industry standards. Portable heating appliances should not be permitted.

21.1.8 Surveillance Exterior structural features of relocatable structures should be inspected in conjunction with the site fire protection assessment program to monitor potential physical deterioration due to atmospheric conditions. If such deterioration has resulted in a significant increase in fire risk, structural repairs or other appropriate mitigating measures should be implemented.

21.1.9 Separation Distances Relocatable structures should comply with the following separation distances:

Exposing Wall Length

ft (m) Minimum Separation Distance

ft (m)

10 (3) 20 (6)

20 (6) 30 (9)

30 (9) 35 (11)

40 (12) 40 (12)

50 (15) 45 (12)

60 (18) 50 (15)

More than 60 (18) 60 (18)

The following adjustments of the separation distances specified above are cumulative, but the minimum distance should not be less than 10 feet (3 meters):

• 50 percent reduction for light fire loading, e.g., 8,000 BTU/sq. ft. or less.

• 50 percent increase for heavy fire loading, e.g., 160,000 BTU/sq. ft. or higher.

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• 50 percent reduction for limited supply suppression system in the exposing relocatable structure which completely protects the structure.

• 75 percent reduction for an automatic sprinkler system in the exposing relocatable structure.

• 75 percent reduction for exposure deluge system.

Exception 1:The separation distances requirement does not apply if the MPFL of the relocatable structure combined with all exposed structures is less than $3 million.

Exception 2:Tents and other fabric-type structures should comply with the separation distances and exposure protection requirements of NFPA Standard 80A.

In all cases, the required separation distance should be based on the "worst case" between the structures, such as when structures are positioned on an angle. Required distances to separate permanent buildings or facilities from relocatable structures should be determined in a similar manner. Due to the many factors that must be considered for permanent buildings, NFPA 80A should be used to establish their separation distance.

Exposures presented by exterior canopies, connecting walkways, etc. should also be considered when determining separation distances and protection features.

There should be no storage of combustible or hazardous materials between the relocatable structure and the exposed building(s).

21.2 Location Restrictions Relocatable structures should be placed so emergency vehicles can operate within 100 feet (30 meters) of the structure. The space between the structure and the road should be free of natural obstructions that would prevent or severely restrict access by emergency responders. Security barriers should be designed in a manner that permits emergency access. Landscaping and similar non-essential obstructions should not restrict emergency access.

Relocatable structures should not be located where they impede or otherwise hinder personnel egress or ingress to, or within, other facilities or structures.

Relocatable structures should not be located where they impede or otherwise hinder the access of emergency response vehicles to other facilities or structures.

Relocatable structures should not be placed inside permanent facilities that do not have sprinklers unless a fire hazards analysis demonstrates that there is no significant increase in fire risk to the facility. Structures that are placed inside permanent facilities should be protected with the same level of fire protection as provided for the permanent facility.

Relocatable structures should not be placed over control valves, access ways to underground utilities, utility corridors, gas mains, or water mains.

Exception: Relocatable structures may be placed above those utility lines that service the structure itself.

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Relocatable structures should not be placed beneath vital power lines or lines over 600 volts such that a fire in the structure could damage the lines. Such structures should also not be placed under other vital utilities, such as communication cables and inerting gas lines, unless the relocatable structure is protected by an automatic fire suppression system. Service conductor clearances and disconnects should be in accordance with NFPA 70.

Site location(s) for relocatable structures should be evaluated for wildland fire exposures. Where a significant fire risk exists, appropriate fire resistive building materials and/or other methods of protection should be utilized as determined by the cognizant fire protection engineer.

Relocatable structures should not be placed closer than 50 feet (15 meters) to a fire hydrant unless there are other hydrants within the distance specified in 8.3.. (See also, paragraph 8.3.)

Cargo Containers: Cargo containers should be limited to stacks 2-high unless otherwise approved by the cognizant fire protection engineer. The arrangement of cargo containers, should reflect the fire hazard of contents, the risk to personnel, value, and access for emergency responders.

21.3 Occupancy Considerations Unless a graded fire hazards analysis demonstrates that a particular occupancy represents an unacceptable fire risk to the health and safety of the public, site personnel, or to program continuity, there are no restrictions on the occupancy of portable structures except as delineated below and in the building code.

Relocatable structures should be governed by site or facility-specific procedures for the use and storage of combustible, flammable, radioactive, and hazardous materials so as to minimize the risk from fire. Such procedures should also exist for activities, such as smoking limitations, isolation of hot work, and other fire prevention measures that contribute to a reduction in fire risk.

21.3.1 Computer Automated Information Systems Equipment Relocatable structures used to house automated information systems or other computer equipment should comply with NFPA 75, "Protection of Electronic Computer/Data Processing Equipment

21.3.2 Laboratories Structures may be used to house laboratories provided they were designed for this purpose and comply with this Standard and the applicable NFPA Standards.

21.3.3 Hazardous Material Storage Relocatable structures may be used for the storage of hazardous materials if the structures comply with this Standard, the applicable NFPA Standards, and all applicable hazardous waste storage requirements.

21.3.4 Sleeping Facilities Sleeping areas should not be permitted in relocatable structures unless they are specifically designed for this purpose. Such facilities should conform with the provisions of NFPA 101,

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including the requirements for two remote means of egress and for a smoke detection system that alarms in the facility and is interconnected with the site fire alarm/signaling system.

21.3.5 Remote Facilities Where fire protection criteria of this Standard cannot be feasibly met because the relocatable structure is in a remote location, alternate fire protection features may be provided as determined by the AHJ.

21.3.6 Portable Heat Producing Devices Coffee pots, hot plates, ovens, and similar items producing heat or capable of overheating should be listed by a nationally recognized independent testing agency. All such devices or the receptacles into which they are plugged should feature a light or other equivalent means to indicate when the appliance is energized. Circuits should be de-energized at the end of each workday.

21.4 Fire Protection Requirements

21.4.1 Automatic Sprinklers Complete automatic sprinkler protection designed per the applicable NFPA Standards should be provided for relocatable structures as follows:

• In all structures over 5,000 square feet (465 square meters) built or installed after 1995.

• In all structures having an MPFL in excess of $3 million built or installed after 1995.

• In all structures where the MPFL will affect a vital program for a period longer than that specified as acceptable by the AHJ.

• In all structures where quantities of hazardous materials are used or stored in excess of the limits delineated in the Uniform Fire Code, or alternate model fire code as determined by the AHJ.

• In all structures used for sleeping quarters, including day care centers. (For such structures, "quick-response" sprinklers should be utilized.)

Exception 1: Limited supply suppression systems may be used where a reliable water supply is not available, or where the application of water would increase the overall hazard in the event of a fire.

Exception 2: Automatic sprinkler systems are not required in fabric or membrane type structures where alternate means of fire protection will provide an acceptable level of protection. Such means include, but are not limited to, fire detection systems combined with foam fire extinguishing systems and other special total flooding fire suppression systems.

21.4.2 Fire Extinguishers Portable fire extinguishers, listed by a nationally recognized independent testing agency, should be provided for relocatable structures in accordance with NFPA 10.

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21.4.3 Fire Hydrants At least one fire hydrant supplied by an adequate and reliable water distribution system should be located so that it does not require more than 300 feet (91 meters) of fire hose to reach any exterior portion of a relocatable structure or a group of structures to be protected.

Exception 1:This requirement does not apply to those structures that are required to be mobile and are moved on a regular basis to support an operation, such as field monitoring and sampling trailers.

Exception 2:This requirement does not apply to structures under 5,000 square feet (465 square meters) in floor area, or when the MPFL is less than $1 million.

Exception 3:This requirement does not apply to remote structures as determined by the DOE AHJ.

21.4.4 Emergency Egress All relocatable structures that are occupied by people should have access to a means to summon emergency assistance. Where a fire alarm or signaling system is not otherwise provided or required, this may take the form of a telephone, radio, or equivalent means.

• Relocatable structures should be provided with fire alarm and notification systems as required by NFPA 101 for the specific occupancy.

• Relocatable structures equipped with an automatic fire suppression or detection system shall also be equipped with local alarm(s) that transmit separate and distinct signals for fire, trouble, and supervisory to either: the site fire department/emergency response center, or to a continuously occupied station for the purpose of initiating emergency response.

• Provisions for emergency egress, including exits, emergency lighting, and exit signage should be in accordance with NFPA 101.

22 Wildland Fire Management A Wildland Fire Management Program comprises the full range of activities and functions necessary to plan, prepare, and respond to potential fires and rehabilitate undeveloped lands following a fire. General recommendations for the development of a Wildland Fire Management Program are provided below (see also NFPA Standard 1143, Wildland Fire Management.):

1) Integrate fire management into the DOE land-use planning and management process, objectives and practices. Identify the foreseeable effects that fire would have on the environment, as well as its impact on any hazardous or mission critical areas

2) Develop a Fire Management Plan based on direction in the site land-use planning and management process. . The Plan should be developed with consideration given to current use as well as proposed future uses. Amend Fire Management Plans as necessary to meet land management objectives.

3) Conduct fire management planning, preparedness, suppression, monitoring, and, where necessary, prescribed fire use on an interagency basis with stakeholder involvement.

4) Observe the following fire management priorities on all fires.

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5) Ensure firefighter, worker, and public safety. 6) Protect programs and missions• Protect mission property and natural and cultural

resources based on the relative values. 7) Initiate suppression of all wildland fires (except those classified as prescribed fires), in

accordance with applicable procedures. 8) Protect the interface between wildlands and all facilities and bordering structures from

damage, in accordance with NFPA Standard 1144, Protection of Life and Property from Wildfire through the use of fuels reduction, physical separation, or building features, such as fire resistive construction, or the use of exposure protection sprinklers.

9) Where appropriate, include a wildland fire risk assessment in other safety documents, such as the Fire Department Baseline Needs Assessment, facility Safety Basis document, Fire Protection Assessment, Fire Hazards Analysis, or other documents that analyze hazards to specific DOE structures, processes, or programs.

22.1 Wildland/Urban Interface The zone where structures and other human development meet or become intermingled with undeveloped wildland is referred to as the wildland/urban interface. The objectives of wildland/urban interface fire management are (1) to facilitate fire prevention and protection and minimize fire loss and damage to structures, other human development, and wildland resources; (2) to prevent a structure fire from spreading into wildland fuels; and (3) to encourage property owners to take an active role in establishing and maintaining their own fire prevention and safety measures in the wildland/urban interface. The following recommendations are applicable to this category:

Document DOE wildland fire protection and suppression assistance in mutual-aid agreements with all emergency response organizations engaged in such activities.

Collaborate with outside emergency response organizations to:

1) establish and update cooperative agreements that recognize the jurisdictional protection responsibilities and assistance capabilities of the respective cooperators;

2) educate wildland firefighters about safe operational procedures in the wildland/urban interface and provide training in safe wildland firefighting operations for structural firefighters who respond to wildland/urban interface fires;

3) provide education to adjoining off-site property owners on fire risks and hazards and on fire prevention responsibilities and actions to minimize losses and damage to structures and lands in the wildland/urban interface;

4) assess, analyze, and plan for fire prevention and protection in conjunction with other Federal, tribal, state, county, and local government entities and with community and citizen groups;

5) integrate wildland/urban interface considerations in the DOE land-use planning and management process, as well as in program project and plans;

6) implement fuel modification projects to mitigate fire hazards; 7) adopt special building construction requirements in wildland/urban interface areas, such

as the construction requirements of NFPA 1144; and 8) implement other practices that reduce wildland fire risks.

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22.2 Wildland Fire Prevention The objective of wildland fire prevention is the cost-efficient reduction of fire suppression expenditures and damages from human-caused fires to levels commensurate with resource and mission management objectives and fire management direction. DOE site wildland fire prevention should be planned and evaluated using the Fire Plan Analysis (FPA). (See Appendix B); coordinated with local stakeholders to encourage planning and analysis of stakeholder lands in accordance with wildland fire prevention programs utilizing the FPA; or coordinated with other agencies where risks affect other jurisdictions.

As used in fire management, wildland fire preparedness includes all fire management activities planned and accomplished in advance of wildland fire ignition to ensure safe, efficient, and effective suppression action. Activities include preparedness planning, fire detection, dispatching suppression forces, developing communication systems, rating fire danger, fire weather monitoring, fire suppression training and qualification, and prescribed fire support. Related direction is found in NWCG, PMS 310-1, Wildland and Prescribed Fire Qualification System Guide, FSH 5109.18, Wildfire Prevention Handbook, Appendix B; the Fireline Handbook; and the National Interagency Mobilization Guide (NFES 2092), published by the National Interagency Fire Center. DOE field elements and site management contractors should ensure that sites plan, organize, and implement a cost-effective wildland fire preparedness program that includes the elements as described below.

22.2.1 Interagency Planning Develop and conduct preparedness activities in conjunction with other Federal land managing agencies as well as other Federal, state, and local partners, such as the Federal Emergency Management Agency (FEMA); the Environmental Protection Agency (EPA); the National Oceanic and Atmospheric Administration (NOAA); the Department of Defense (DOD); and state and local wildland fire management planning, response, and recovery organizations.

22.2.2 Site Integration Ensure integration with the site land-use planning and management process and approved Integrated Safety Management Systems

22.2.3 Preparedness Planning Preparedness planning provides for timely recognition of approaching fire management situations and for setting priorities, deploying resources, and considering other actions to respond to those situations. Wildland fire preparedness planning should include the following.

22.2.4 Preparedness Plans and Reviews The purpose of preparedness plans and reviews is to ensure the timely recognition of and appropriate response to fire management situations and to provide the basis for ensuring program accountability. Preparedness planning requires (1) an intelligence system, (2) an analysis and decision-making process, and (3) identified actions to be taken at increasing levels of fire severity and activity (preparedness level). Preparedness plans should be documented in a site mobilization guide or other appropriate document.

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22.2.5 Intelligence System Each site should have a system in place to gather the information on both wildland and prescribed fires that is needed to permit timely decision making. One option is to coordinate with Geographic Area Coordination Centers (GACC) to submit a daily Interagency Situation Report to the National Interagency Coordination Center (NICC) during the region’s established fire season.

22.2.6 Analysis and Decision Making It is essential that DOE site management evaluate those factors that may significantly affect national, regional, and site fire situations and individual fire response actions. Among the factors that should be considered are existing and potential fire severity; suppression resource commitment and availability; prescribed fire activity; wildland fire use and mission; and interagency environmental, social, political factors or other pertinent factors. Alternative actions for responding to increasing levels of fire severity and activity must also be developed.

22.3 Preparedness Actions When developing preparedness plans, consider the following:

1) Actions for responding to fire preparedness levels (National Interagency Mobilization Guide, NFES 2092);

2) Preparedness levels and actions addressing the full range of anticipated fire danger and activities;

3) Documented processes to coordinate actions among cooperating agencies and to transmit decisions promptly to all affected organizations, including adjacent units and cooperators; and,

4) Schedules and approaches for conducting preparedness reviews.

22.3.1 Fire Management Plan Prepare a plan documenting the fire management program that most effectively achieves land-use planning and management process direction (See Appendix B).

22.3.2 Site Fire Plan Prepare annual site fire plans for any activity that increases wildland fire risk or constitutes a wildland fire hazard, such as land clearing, timber harvesting, mining, and power line or highway construction. These plans should describe the responsibilities.

22.3.3 Cooperative Firefighting Agreements Line officers should annually, or as otherwise required, review and update all cooperative wildland fire agreements.

22.3.4 Fire Weather Forecasting and Monitoring As necessary, determine, establish, and maintain sufficient fire weather forecasting and monitoring capability to support the National Fire Danger Rating System (NFDRS) and wildland fire management activities. Communicate and post the current NFDRS fire danger rating and implement preplanned operation limits when fire danger exceeds a “high” rating.

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22.3.5 Preparedness Training and Qualifications Provide training adequate to meet fire management needs. Ensure that cognizant DOE and contract employees meet standards for training, experience, and physical fitness before they are certified for wildland fire organization positions. Site management should adhere to the qualifications standards established by the NWCG, NFPA and state or local laws or regulations.

22.3.6 Wildland Fire Suppression The objective of this activity is to safely suppress wildland fires at minimum cost consistent with land and resource management objectives and fire management direction as stated in fire management plans. Expectations or actions to take in the event of a wildland fire include the following:

1) Ensure that suppression planning, operations, and personnel comply with the wildland fire suppression principles and practices that are set out in the site Wildland Fire Management Program and associated procedures.

2) Conduct fire suppression in a timely, effective, and efficient manner, giving the first priority to firefighter and public safety.

3) Decide how to organize and conduct suppression operations (suppression strategies). Line managers should minimize both suppression cost and resource loss consistent with the resource management objectives for the values to be protected. Consider fire behavior, the availability of suppression resources, the value of natural resources and property at risk, direction in the site land-use planning and management process, and the potential cost of suppression. Consider using a wildland fire situation analysis to document suppression strategy decisions

4) Conduct a cost-effective initial attack on any unplanned wildland fire. 5) Employees who discover a potential wildland fire are expected to take initial action

consistent with their wildland fire qualifications.. Wildland fire suppression is not limited to those employees with skills in wildland fire operations; rather, it may require the skills of employees in fiscal, human resource, telecommunications, communications, or other areas.

22.3.7 Suppression Action on Private Land Sites may develop a written reciprocal mutual aid or dedicated service agreement with a fire organization to render emergency assistance in suppressing fires and preserving life and property within the vicinity of the site from the threat of fire. Permission to conduct suppression activities on private land should be obtained from the landowner when feasible; however, suppression action should not be delayed while permission is sought.

22.3.8 Fire Suppression Safety All activities should reflect a commitment to firefighter and public safety as the first priority. DOE site management contractors should

1) establish procedures for issuance, use, and accountability of personal protective clothing and equipment;

2) ensure that training, use, appropriate employee medical surveillance programs, and maintenance and storage of the protective equipment comply with applicable standards;

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3) provide 8 hours of annual wildland fire safety refresher training to personnel directly involved with such activities; and,

4) ensure that work supervisors are responsible for the safety of employees engaged in wildland fire management activities.

22.3.9 Wildland Fire Reports Timely reports of fire activities provide information essential for land and resource management and for both internal and external administrative purposes. The DOE site offices (through site management contractors) should log a report for each wildland fire in accordance with standard site fire reporting methods, in addition to any other reporting requirements, such as the Occurrence Reporting and Processing System and reporting requirements of the National Interagency Fire Center. A prescribed fire that burns out of prescription and is declared a wildland fire should be reported as a wildland fire.

22.4 Wildland Fuels Management Fuels Management is the practice of evaluating, and treating wildland fuel to either reduce flammability or meet environmental goals by mechanical, chemical, biological, or manual means, including prescribed fire in support of the site land-use planning and management process. DOE sites should integrate fuel management and fire management programs in support of the following resource management objectives.

1) Use an interdisciplinary approach to integrate fuel management planning into all appropriate activities.

2) Identify, through economic analysis, the most cost-efficient fuel profile to meet resource management direction. Consider a full range of fuel management alternatives, including no treatment. Fuel management activities should be responsive to long-term site productivity, utilization opportunities, and air quality considerations.

3) Where a management activity, such as timber sales, thinning, or road construction, contributes to an unacceptable fuel profile, modify that activity to reduce its incremental contribution to the fuel profile.

4) On lands where repetitive management activities will occur, evaluate the projected fuel profile to determine the most cost-efficient time(s) of entry and the level of treatment(s).

5) Manage fuel in accordance with fire management direction in the site land-use planning and management process.

6) Inventory fuels and prepare a wildland fire risk assessment to be used in prioritizing treatment areas.

7) Be aware that defensible space areas, strategic fuel breaks, utility corridors, and safety zones require more intensive fuels management than wildland areas.

8) Sites with large wildland areas may need to prioritize its risk based upon potential wildland fire exposure to large populated areas, nuclear, radiological, high hazard, explosive, waste storage and processing, or other facilities which might represent an unacceptable exposure under wildland fire conditions.

9) When appropriate based upon potential hazardous material release, impact to mission, etc. consider the use of exposure sprinkler protection in order to protect these facilities for unacceptable wildland fire exposure that cannot be controlled by other means.

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22.4.1 Fuel Treatment Initiate fuel treatment in accordance with land and fire management plans. Establish priorities for treatment of fuel in these plans. Consider the following treatment options, prioritized in the order listed, when developing fuel management direction and plans.

1) Utilization. Use methods that reduce unwanted fuel through improved harvest techniques or through higher utilization standards. Favor utilization when the cost of onsite treatment equals the cost of removal for utilization.

2) Rearrangement. Redistribute fuel onsite to a condition that is less hazardous or one that enables more rapid deterioration or more effective disposal.

3) Removal. Remove unwanted fuel offsite for further utilization, storage, or disposal. (Test material before moving offsite to ensure that it is not contaminated.)

4) Disposal. Reduce or eliminate unwanted fuel onsite. Disposal methods include manual, mechanical, chemical, biological, and prescribed fire treatments and their associated activities.

5) Conversion. Replace hazardous fuel with less flammable fuel or fuel that offers less resistance to suppression.

6) Non-treatment. Where appropriate, identify if and when fire program costs plus anticipated net value changes do not justify fuel treatment.

7) Interim Protection. Provide protection on an interim basis only when the hazard of newly created fuel cannot be abated in a timely manner and when: a) An analysis of hazard and risks fully supports the cost-effectiveness of interim

protection; and ; b) Treatment takes place as soon as practical following creation of the hazard.

8) Supplemental Protection. Use supplemental protection only if the economic analysis indicates that this is the most cost-efficient means of mitigating the fire hazard until deterioration of fuel makes such protection unnecessary. Supplemental protection may be justifiable in limited situations as part of an overall land management strategy. When justified, the responsible authority should annually review and approve the continued use of supplemental protection.

9) Fuel Treatment Through Prescribed Fire: The objectives of prescribed fire use are (1) to use fire from managed ignitions in a safe, carefully planned, cost-effective manner to benefit, protect, maintain, and enhance DOE lands; (2) to reduce future fire suppression costs; and (3) to the extent possible, restore natural ecological processes and achieve the management objectives adopted in the approved land-use planning and management process for the site. The following fire use recommendations apply.

a. All proposals and decisions to use prescribed fire are subject to site analysis, documentation, and disclosure requirements for complying with the national environmental policy (Clean Air Act - 42 U.S.C. 7401 et seq.).

b. A Prescribed Fire Burn Plan (RxBP) meeting interagency requirements, including the use of fire complexity, should be prepared and approved before prescribed fire ignition. A decision to amend a RxBP requires approval at the same or a higher level of authority as required to approve the initial plan.

c. A prescribed fire may be implemented only with trained and qualified personnel. No less than the organization described in the approved RxBP may be used to

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implement the project. The size and complexity of each prescribed fire will determine the size of the organization needed to safely achieve the objectives of the project. Workforce and equipment needs should be coordinated to ensure that fire use and contingency actions do not exceed site capabilities and are coordinated with mutual aid responders. A qualified burn boss should conduct each prescribed burn.

d. Pre-Ignition Briefing and Forecast Requirements. Assigned personnel should be briefed before ignition to ensure that personnel safety considerations are clearly understood and prescribed burn objectives are clearly defined. During the briefing, discuss elements of the Job Hazard Analysis (JHA) specific to each individual job task. Take into account the slope of terrain and the fuel conditions in which employees will be working and have clearly defined escape routes. Each individual should know and understand his or her role and responsibility for maximizing accomplishment of prescribed fire objectives while minimizing personal safety risk. Obtain a project-specific weather forecast prior to ignition. The forecast should include all fire-behavior-related weather elements that are considered critical to personnel safety and attainment of prescribed fire objectives. Examples of weather parameters to be evaluated are wind speed, wind direction, relative humidity, temperature, and severe weather potential.

e. Smoke Management. Air quality considerations are an integral part of the fire use program (see Smoke Management discussion, pages C-3 and C-4 in Appendix C). Coordinate fire use applications with the appropriate air quality specialists and comply with all Federal, state, tribal, and local clean air, smoke mitigation, and visibility regulations applicable to prescribed fires. Appropriate computer modeling techniques may be used as described in the Implementation Guide (see Appendix A) to estimate potential downwind impacts. Smoke management contingency plans may be developed to mitigate potential negative or unacceptable impacts of smoke on air quality in such areas as Class I air sheds, identified smoke sensitive areas, hospitals, main travel routes, and airports.

Firing sites should use only designated sites, be subject to a fire management plan, and require the reduction of fuels annually or more frequently if required before firing activities commence, include provisions for fire department or wildland fire resource standby during firing site activities, and prohibit firing site activities under high fire danger or greater classifications.

Appendices Appendix A. Nuclear Filtration and Air Cleaning Systems ........................................................ A-1

Appendix B. Operating Temperatures for HEPA Filters ............................................................ B-1

Appendix C. General Criteria Summary Table and Plan Diagram ............................................ C-1

Appendix D. Discussion on Evaluating Duct Openings When Penetrating 2-Hour Fire Walls .. D-1

Appendix E. Example Glovebox Fire Detection Systems ......................................................... E-1

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Appendix F. Fire Extinguisher Quick Disconnect Coupling ........................................................ F-1

Appendix G. Dry Powder Extinguishing Agent Holder .............................................................. G-1

Appendix H. Limited Water Sprinkler Design ............................................................................ H-1

Appendix I. Glovebox Window Material Comparison .................................................................. I-1

Appendix J. Glovebox Overpressure Protection Valves ............................................................ J-1

Appendix K. Glovebox Fire Protection Survey .......................................................................... K-1

Appendix L. References L-1

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Concluding Material

Review Activity: Preparing Activity:

DOE Field Offices DOE-HS-21

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DOCUMENT IMPROVEMENT PROPOSAL FORM (form DOE F 1300.3)